Submission to the DLGE Douglas Local Plan (Order 1997) Inquiry
The Draft Plan to which this text refers
is available from the Isle of Man Department of Local Government and the
Having given due consideration to the document in the time available, Mec Vannin considers that the subjection of the document to Public Inquiry is premature since:
a) In light of what are clearly intended policy changes, there has been insufficient public consultation.
b) In any event, the time between the public release of this document and the Inquiry date is insufficient for organisations to make informed comment.
Nonetheless, attached is a brief comment upon the Draft Order.
All reference nos. are those used in the Draft Order.
The statement that the expansion of Douglas and Onchan is as a result of, "the locational preferences of the incoming working population," is an unsubstantiated piece of conjecture. We might equally conject that it is the result of bad planning in the past.
2.9 - 2.13
Low density housing (less than one dwelling per acre) is undesirable and an inefficient use of land. Greenfield development of this sort is insupportable in light of the admittedly limited land available.
A clear statement that "Low Density" housing in parkland is no longer acceptable is required in order to prevent further greenfield development pressure.
We support initiatives to encourage the use of existing buildings for residential purposes in town.
There should be a requirement rather than an "encouragement" to liaise with Fire Service and Constabulary in the layout etc. of development.
We question the use of the term "strategic significance" in the absence of any definition or reference to a strategy.
No confidence can be maintained in retail provision in Douglas except from the point of view of chain store / franchise operators. There has been a general attrition of retail diversity in the main shopping area of Douglas due to the loss of small traders.
We question why Shoprite (Victoria Road) has not been included in the definition of warehouse retailing.
3.16 / 3.19
This paragraph goes directly against existing DLGE Planning Policy which states:
"...it is not the function of the Planning system to interfere with or inhibit competition between users and investors in land."
Government Policy Document 1996, Section 17.9 para.2
Our interpretation of this policy is substantiated by the Planning Committee's treatment of several applications where objections were received from competitive interests. Where these objections were based upon the competitive element of the application, the objections have been dismissed as being outside the concern of the Planning department.
Having said this, Mec Vannin does not support the existing policy since it is the responsibility of government to regulate economic and market development for the common good.
Summary on Section 3
There is an implicit assumption that U.K. based based chain stores and retail warehouses are beneficial to our retailing economy. There is no evidence to support this: Family run specialist outlets always provided a diversity of goods at competitive prices despite claims to the contrary.
The principle stated has not been firmly adhered to e.g. the Business Park in Braddan.
That aside, the concentration of offices in Douglas has led to traffic congestion by day and desertion by night.
This policy also contradicts other elements of the Draft Order that look to re-introducing residents to Douglas properties.
This policy gives an unfair economic advantage to the dominant industry (finance) and runs contrary to the government policy of diversity.
The direct correlation of available office space to job creation, in the light of the current population and unemployment figures, clearly indicates a desire on the part of the government to further increase the population. This will further pressurise the limited land space for residential use.
4.12 - 4.24
Mec Vannin feels that we should move away from the principle of block zoning and look towards creating modules of blended developments that would incorporate residential, business and retail elements in an equitable proportion.
The existing skyline should be the criterion for building height. The five story ruling will lead (and has lead) to incongruous developments where the predominant height is lower.
The "yacht haven" scheme can only be described as a complete waste of time and resources, offering nothing more than a permanently wet puddle at the top of a tidal harbour. Other ports in the island offer better access for the sailing fraternity and would benefit more from the presence of a yacht facility. We feel that this is simply an excuse to provide the harbour link-bridge on one hand and to placate public opinion in favour of a yachting "facility" on the other.
Even now, the facilities are inadequate, with many passengers being forced to wait for buses in the wind and rain at busy periods when sheltered areas are full.
It is impossible to see how such a scale of development as proposed could be carried out without further losing passenger facilities, unless a high-rise development is envisaged. We must question the wisdom of creating basement parking below the high-water mark in this area. Many of the adjacent properties are faced with regular pumping of their basements.
A clear statement that the Villa Marina Gardens will be protected as lawns and gardens is required. This would be in keeping with the policy as stated in section 13 of the Draft Order.
The fact that planning and traffic management are considered as separate issues demonstrates that there is no cohesive policy of government in this area. There is a desperate need for the DLGE, Dept. of Tourism (which has responsibility for public transport) and the DoT to liaise in order to produce a public transport / traffic management policy for inclusion in this document.
The recommendations contained in section 7 in this respect are meaningless without an authoritative commitment from the other above mentioned departments to fulfil the objectives.
Likewise, the contents of section 7 require co-operation between departments. There is, however, a fundamental flaw in current DLGE policy towards parking provision. As long as developers are forced to provide long-term parking, cars will travel into Douglas to make use of it. If certain developers / businesses feel that parking provision is a necessity, then it is up to them to incorporate it in / acquire it for their premises.
There should be no further public sector provision for long-term car-parking. Public highway parking should be predominantly short-stay and permit holders only.
With specific reference to the note in 7.30, illegal parking will only occur if it is permitted.
It must be re-emphasized, however, that negative incentives to car usage on one hand will only be beneficial if complemented by an efficient, free public transport system on the other. This is a matter for an all-island policy.
Without some sort of assistance being made available for registered buildings the likelihood is that they will deliberately allowed to fall down. Derby Square is cited as an example of incongruous and unsympathetic renovation and alteration. The simple fact is that, in many instances, had these alterations not been made the properties would have become uninhabitable at an affordable price.
Douglas inner harbour is unpopular with yachtsmen because access is tidal, there can be substantial delays in getting the bridge swung and it has not been kept properly dredged. The proposals for this area will only make matters worse if carried out: Access will still be tidal, silting from the River Doo will increase and when access to the inner harbour coincides with rush-hour traffic using the link-bridge, who will take priority - the lone yachtsman on a falling tide or the traffic?
The general contents of this section can be supported but there is a clear conflict between the want to create more open space and the want for more residents and businesses within the existing Douglas boundary. The policies fail to identify an upper limit for Douglas' resident and working population within the constraints laid out and consequently, it is implicit that an increased population resulting from Douglas' continued economic expansion as planned will be shunted into other parts of the island.
Although the current usage of the Lord Street bus station is wasteful in terms of space, an enhanced public transport system as envisaged by the draft will require this space if it is to be "user-friendly" - a central bus station is an important transport node and should be developed as such. The proposals in the draft are a retrograde step.
14.2 and 14.3
The railway station and timber-yard area developed as a transport and bulk items storage point because of its natural link with the harbour facility. It would be more sensible to maintain this nature of use.
With reference to the rest of section 14, the suggestion that modular development take the place of blanket zoning should be implemented. Mec Vannin's previous suggestions regarding car-parking provision should likewise be implemented (i.e. no more long-stay) except where this would encourage the usage of the public transport system.
The failure of both the DLGE and Water Authority to co-operate in making water requirement plans in the past must be addressed. Areas should be identified where service reservoirs could be constructed and plans made accordingly. The possibility of large developments, whether business or residential, being required to incorporate a water storage facility adequate for their daily usage should be investigated.
Mec Vannin wishes to take this opportunity to re-iterate its opposition to a cable link. An apparently inexhaustible electricity supply will further encourage inefficient use of energy. This is contrary to stated government policy. Localised power generation and distribution, by whatever means, is much more energy efficient.
General Conclusion and Comment.
The thrust of the plan i.e. to revitalise Douglas within its developed area while protecting "green" areas within and without the town is supportable.
The individual policies are, however, inconsistent and lacking in cohesion with other government departments.
The priority should be to encourage (to the point of forcing) developers / businesses to make use of existing developed areas with respect to prevailing and desired market trends. To this end, the concept of designated usage should be relegated and precedence given to reuse of existing sites and buildings, the acceptability or otherwise of any proposal being judged more on its individual merits.
As a general comment on the draft document
itself, the feeling of the meeting at which it was discussed was that the
document could have been made a lot clearer: There were several occasions
when the subsections seemed to indicate one desire only to be contradicted
in the policy statements.
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