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residential estates adjacent to the site, and offer different but still legitimate design influences for new development on the outskirts of the town. The dwelling types proposed and the details and finishes chosen will set the development aside from adjacent residential areas and will include, amongst other things;
7.2.7 Within the development dwellings with distinct characteristics have been grouped together so as help establish and reinforce a sense of place for individual neighbourhoods rather than for a development as whole. The dwellings on the northern part of the site for example will be detached with natural stone featuring prominently as a finish and a low wall enclosing front gardens, whilst the terraced dwellings on the southern part of the site will be strongly influenced by the older, more traditional characteristics of the town centre. The three storey apartment blocks on plots C1 to C12 and C49 to C60 will be located within an open setting, and will sit comfortably on a low part of the site with a backdrop of mature woodland. In accordance with Housing Policy 5 of the loMSP and following consultation with the Housing Section of DoLGE at least $25 \%$ of the dwellings will be provided as affordable units.
7.3.1 As stated above the site is at present generally well screened from public viewpoints, with the Manx sod hedges which currently enclose three of the site boundaries contributing to this. These hedges, including those enclosing the lane which crosses the site, will not be adversely affected by development and are to be retained save for the creation of necessary access points. Any trees within existing hedges are also to be retained, and the Wildlife and
Conservation Officer for DAFF has not advised of any potentially adverse ecological impacts.
7.4.1 General Policy 2 of the loMSP requires new development to have regard to the amenity of existing local residents as well as providing satisfactory amenity standards in itself. The dwellings within the new development are positioned so as to ensure adequate separation distances to existing dwellings, particularly where windows face one another, and this will ensure that adequate standards of privacy and outlook are maintained. In a more general sense the impact of new development upon infrastructure can obviously have consequences for amenity, but the assessment above demonstrates that in this instance the development will not compromise local infrastructure provision. 7.4.2 The proposed development has also been designed to ensure that new residents enjoy appropriate standards of amenity, taking into account dwelling positions and separation distances, access and circulation arrangements, parking standards, servicing provision and amenity space. The layout also takes account of community and personal safety, with natural surveillance and location of pedestrian through routes as key elements. In particular the parking areas have been designed so to deter car crime without unduly impacting upon visual amenity within the development. The layout of the scheme has formed the subject of consultation with the Architectural Liaison Officer for the Isle of Man Constabulary. 7.4.3 In terms of open space provision the loMSP suggests that new residential development should provide 32 sq.m of public open space for every new resident, which should be applied having regard to particular circumstances such as the proximity and availability of existing open space (including school fields which are available for public use outside school hours). In this instance the public open space provided at the eastern site boundary would be suitable for a children's play area, which would supplement that already established within Reayrt ny Keylley (approx. 145 metres from where the existing lane will link the two sites). Reayrt ny Keylley also contains approximately 2 acres of parkland public open space, much of which is immediately adjacent to the new site boundary. The Inspector for the appeal
of PA 05/92153 concluded that the proximity and accessibility of the QEII school playing fields negated the need for formal space (i.e. sports pitches) to be provided within the development and that remains the case for the new proposal. Approximately 2.3 acres of public open space will be provided within phases 1, 2 & 3 of the development which will complement that provided in adjacent locations.
The General Policy 2 (part n) of the IoMSP requires new development to be designed so as to have "due regard to best practice in reducing energy consumption", and in this instance issues such as passive solar gain and the use of solar powered energy have been taken into account. In accordance with Energy Policy 5 of the IoMSP an Energy Impact Assessment/Statement for the development forms part of this document<sup>4</sup>.
Part (k) of General Policy 2 seeks to prevent development from prejudicing the use or development of adjoining land in accordance with the Area Plan; in this instance the Peel Local Plan has effect as an Area Plan and development of the remainder of the allocated land in the future will not be compromised by the detailed proposals now proposed. The pedestrian laneway and proposed distributor road which lead to the masterplan site will be fenced or gated off in the interim so as to not affect the agricultural use of those fields. Part (l) refers to contaminated land and land which is subject to unreasonable risk of erosion or flooding, which are not issues for the application site.
In response to PA 06/01393 Manx National Heritage requested for any approval to be "subject to the applicant undertaking a watching brief to recover any artefacts and recording any archaeological features exposed during groundworks. Additionally, all workmen on the site should be informed of the sensitive nature of the site so that any finds or traces of archaeological activity can be reported promptly to the Manx Museum in accordance with Manx Law". This approach has worked successfully on other development sites and, although it was not considered necessary for phase 1, Heritage Homes Ltd would be content for any approval to be conditioned accordingly.
4 An Energy Impact Assessment/Statement for the development is attached at Appendix 47.5.4 It is estimated that construction will generate approximately $18000 \mathrm{~m}^{3}$ of excavated material (soil etc), which will be re-used within the development. This will include the alteration of ground levels at the lower end of field 311826 as approved under PA 09/00521.
8.1 The site is within an area which is allocated for residential development in the Peel Local Plan. The Isle of Man Strategic Plan indicates that out of a total of 6000 additional dwellings 1000 will be distributed to the West during the plan period (2001-2016) in order to meet housing need, estimates which are necessarily broad given the assumptions involved and which "should not be regarded as absolute or maximum figures". Similarly the Plan's Residential Land Availability figures are no more than broad estimates, which cannot assume that all approvals will be taken up and which should not rely upon conversion and windfall projections in preference to the development of allocated land. On this point the Inspector for PA 09/00521 concluded "In order to meet Strategic Plan Housing targets for the West it seems wrong to resist a housing scheme on a site allocated for housing since 1989 and to instead hope to permit housing from unpredictable windfalls and conversions. The Planning Authority's preferred approach of hoping to permit windfalls and conversions instead of permitting development on an allocated site means that no affordable houses would be provided in the West. This compares with the proposed 11 affordable homes on the appeal site. This would be a strange approach to the Island's housing provision". 8.2 The Inspector concluded that it is not acceptable to resist a proposal "simply because there is a possibility that more houses might theoretically be built in the West between 2001-2016 than the total number set down to meet the needs of that area", as that in itself would not necessarily cause harm to the development and use of land. He went on to report that "there seems to be no acknowledgement of the important impact of market forces in determining provision of housing. If there is no need or demand for new housing in the West it is unlikely that a builder would build unnecessary houses which would not be sold. This in itself offers a measure of control over housing provision in excess of local need".
8.3 Dwelling completion numbers since 2006 have been significantly lower than those for the previous 4 years and the Department's Housing Policy Review Progress Report of July 2007 predicts that the next few years will see similarly low figures. In the medium term this is likely to lead to a shortfall in dwelling provision (when compared to the requirements of the loMSP) that would increase housing demand and prices. Additional land will not be allocated in response to this situation until after the completion of the first Area Plans (estimated to be late 2010 at the earliest, assuming that there are no delays), and allowing for obtaining planning approval and construction then the provision of new homes on that land will not be until at least 2013. In these circumstances it is important to ensure that land which is currently allocated for residential development can be developed in order to address demand and provide continuity of housing provision. 8.4 The application proposes the provision of 101 dwellings, at least $25 \%$ of which will be affordable homes. The Department's April 2009 assessment of the First Time Buyer Register indicates that the need for affordable housing in the west of the Island is increasing, which obviously will not be addressed if land which is designated for residential development cannot be used for such. It also states that in the medium term consideration may need to be given to the development of unzoned land in order to provide affordable housing, which clearly would be inappropriate if permission for such is being withheld on sites which are allocated for housing in a Local or Area Plan. 8.5 The application includes an assessment of how the phases now proposed and any future development of the adjoining zoned land will relate to the town's current and future infrastructure provision, which has involved extensive pre-application consultation with statutory authorities, service providers and other organisations. It is clear that the proposed development can be properly serviced without compromising infrastructure provision for Peel or the west of the Island. In respect of PA 09/00521 the Inspector concluded that "the proposed drainage arrangements would be satisfactory in terms of being safe, convenient and environmentally acceptable", and the arrangements for these subsequent phases will operate on the same basis.
8.6 The application also includes a design statement which explains how the proposal has evolved and which factors have influenced that process. The form, detailing and finishes of the dwellings for example will take visual cues from the older parts of Peel, whilst still allowing the development to provide modern standards of residential amenity. A Transport Assessment and an Energy Impact Assessment/Statement are included as required by the Isle of Man Strategic Plan. 8.7 Given the above the development of the site will compromise the provisions of neither the Isle of Man Strategic Plan nor the Peel Local Plan, and will help to address demand for both open market and affordable housing.
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