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The Commissioners are aware of a proposal (19/00462) for a sewage treatment works on the site of Glenfaba House. The Commissioners are well seized of the desirability of such a works but believe that the location is far from optimal. It is the desire of the Commissioners that an available alternative be considered at the same time as the application for full approval by the Manx Utilities Authority. It is understood that if there is no alternate plan on the table, a Planning Inquiry will not consider any alternate site even should this be available, and so the Commissioners present their proposal for this alternate site. Of necessity, it is for Approval in Principle only as the final design of a works would be better left to those professionally qualified. However, the land available at this site exceeds that at Glenfaba House, is closer to Peel town, is accessible through an industrial area which would also allow for pipe work to run close to oil and other pipework from that area and benefits from being almost level with Peel town reducing the need for pumping. It is also closer to the town and should therefore be less expensive in terms of pipework and other infrastructure.
The Fields proposed for use are currently not used for any purpose and are adjacent to the field being used for the deposit of silt from the Peel marina. Access is gained from the former Douglas to Peel Railway Line which is made up as far as the silt pond and is capable of making up for the additional distance needed to service the instant site.
Planning Application 19/00462 utilises a 13 year old report incorporating a carbon based fuelled plant to pump sewerage back from Peel sea-front and does not seek to incorporate non fuel based approaches such as simple gravity within the project. This appears to be a "quick fix" based upon an out-dated report of May 2008. Even so this 2008 report noted that the most suitable site was identified as the lands adjacent to Peel Power Station at Close Chairn, lands which were considered unsuitable at the time purely on a shorter term cost basis as they were not available at mutually acceptable terms. The currently proposed approach, by avoiding a carbon minimising approach, clearly risks contravening the island's UNESCO biosphere status. As noted in Mr Curran's Climate Change Impact Report dated 31 October 2019 to the Isle of Man Government which looks to achieve net zero emissions by 2050, he comments: "In 2017, UNESCO agreed a Declaration on Ethical Principles in Relation to Climate Change in which world leaders have called climate change the biggest challenge of the 21 st century. The Declaration speaks of the responsibility to address the challenge, and reinforces the role
of ethics at the centre of the discussion.
The MUA's outdated plan with a narrowly defined update utilising three elevated and distant sites does not "do the right thing"; pulling down a Victorian House without due process and destroying the trees around it based upon such an outdated plan with a narrowly defined update utilising three elevated sites does not "do the right thing"; using a carbon based system and not embracing the natural resources including gravity, hydro-electric and solar does not "do the right thing". Instead the MUA appears to be following a strategy based upon an outdated report with a restricted and narrowly defined update based upon three elevated and distant sites and not considering any long term (50 year minimum) carbon based assessment of the project.
The Commissioners appreciate MUA are trying to do the right thing by stopping the sewerage going into Peel bay; we appreciate that the politicians want this to be done on their watch to avoid further delays; we appreciate it was probably assumed that pulling down Glenfaba House made it a Fait Accompli to speed up the project. However the project as planned does not appear logical long term .... two wrongs don't make a right. We believe that MUA should look at this project on a standalone basis, on the basis of a long term plan which takes into account both the Island's UNESCO Biosphere status and the UNESCO commitments to climate change, and the Island's Commitment to tackling climate change to be adopted this month.
The primary consideration for this project should be to create a sewerage system which is fit for purpose for the future even if that means going back to the drawing board. We now know the preferred site is available to MUA/DOI/Government as they have secured it for the silt. By moving this over the river moves the smell from the silt further from Peel. This area becomes available for a forward thinking enclosed sewerage plant based upon renewable Hydro electric or other renewable energy as MUA sees fit. By making sewerage gravity fed directly towards the site as much as possible and without uphill distance from this low point in Peel minimises future energy requirements. It avoids cutting mature trees down in one of the few wooded areas near Peel and critical for carbon capture, and instead provides a site to create a new wooded and landscaped area for the people of Peel in its current industrial zoned area.
Instead of the risk of the negative PR when the public realises that the first new infrastructure project by MUA, post release of the Government's new carbon reduction climate change commitment, takes no account of its principals, MUA will be seen ultimately as proactive, as properly embracing the changing impact of the new Government Policy. There is a real PR opportunity here for MUA to celebrate how they are embracing climate change and the incredible challenges they will face in achieving 70% renewable in 30 years. It will avoid the realisation in 10 years time that a distant uphill site relying on fossil fuels to pump from Peel front is simply not fit for purpose. Whilst there will be a short term issue of dealing with the Glenfaba site, it could be sold, or indeed MUA could create a fabulous countryside recreation area in one of the few wooded areas near Peel for cycling and walking from Peel, celebrating its existing natural beauty and biodiversity.
For all of these reasons, the Commissioners desire that this alternative be considered in tandem with the MUA proposal.
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