Pembrokeshire County Council - Review of Local Development Plan - Episode 4

Local Development Plan Review – Deposit Plan

Comments and Observations

Pembroke Dock

Since I last wrote to PCC regarding the consultations for the authority’s Local Development Plan Review (LDP 2) I am pleased to note that many of the concerns I raised regarding the candidate sites, put forward by various bodies, have been acknowledged and these do not appear on the present draft plan.

I do, however, have major reservations relating to the sites HSG/096/00238 and HSG/096/00373 situated north and south respectively of “The Long Wall” (Pembroke Road) and east of Pembroke Dock Cricket Club. I hope that these sites are not precursors to the development of all the land along this ridge between Pembroke and Pembroke Dock.

I also have concerns about the reduction in size of the Pembroke Dock Conservation Area that took place in c2017. In submissions regarding this during the consultation period, I advocated the extension of the conservation area, as has happened in the neighbouring settlement of Pembroke, to continue, if in name only, the protection of High Street and Bufferland. Certainly, High Street is one of the earliest built areas of the town, developed as a private venture by the Bush Estate to provide leased housing for workers in the Royal Dockyard. The development of the above-mentioned housing allocations will continue to erode the setting and heritage value of the much older buildings in High Street. Being placed on and either side of the ridge, these allocations also detract significantly from the setting of Pembroke Dock as viewed from the high ground by the Cleddau Bridge and from Pembroke Castle.

One other housing allocation in Pembroke Dock (HSG/096/LDP2/2) is another site that sits conspicuously on top of the ridge that runs down to Pennar Point (Figure 1). This is an allocation that has extended the settlement boundary of Pembroke Dock from that published in the Adopted LDP (2013). There is concern that this allocation will merely open up the possibility of development further west along the ridge, as effectively happened with the allocation on the south side of Pembroke Road (HSG/096/00373) AFTER publication of the Adopted LDP (2013).

Green Wedges (GN 37)

It is pleasing to see areas of land designated as Green Wedge. The area south of Bufferland so designated, along the northern banks of the Pembroke River, east of Jacob’s Pill, is particularly welcome.

Figure 1

I do, however, wonder why the Green Wedge designation has not been continued further west towards Pennar Point to provide a similar protected margin along and behind the shoreline. (Figure 1).

Figure 2

One area I feel very strongly about being given this status is the land that runs from Treowen Road, south eastward to the western side of Jacob’s Pill (Figure 2). The development of this land would destroy the setting of the park adjoining Pennar Church which at present takes in expansive views up the Pembroke River to Pembroke Castle and onward to the headland at Manorbier. It also helps to provide a sense of rural remoteness for Jacob’s Pill – a location of some importance in the history of Pennar and Pembroke Dock in the last quarter of the nineteenth century. Jacob’s Pill and the northern banks of the Pembroke River gives the population of Pennar and Bufferland access to rural tranquillity within walking distance of their homes. Access to such spaces is important in ensuring  well-being and improved mental health for residents (GN 35 Green Infrastructure refers). Policies GN 38, GN 39, GN 40, GN 41 are also very relevant here. Figures 3a and 3b below show the extent of this view, the theoretical viewshed (from a height of 6 feet above the Pennar Recreation Area) being shown in red.

Figure 3a

Figure 3b

To return to the Housing Allocations mentioned earlier, HSG/096/00238 and HSG/096/00373, I am rather confused about the designation of the land east of these two housing allocations and on both the north and south sides of the Pembroke Road (Top Road) - as in Figure 4. 

Figure 4

The land immediately either side of the road is allocated as a hard rock resource, exploitable before any development can take place. The land immediately south of these allocations is allocated green wedge status. If green wedge has greater protection from development than hard rock resource allocated land, it is preferable that this land be allocated as green wedge. Green Wedge would also offer protection for the hard rock resource beneath the surface. This would help to ensure that there is not a ribbon of development eastward along Pembroke Road towards the neighbouring settlement thus retaining a visible gap between Pembroke and Pembroke Dock. Also, further development on this high ridge would be inappropriately conspicuous from numerous locations around Pembroke and Pembroke Dock and much further beyond. See the viewshed from this location (6 feet above ground level) in Figure 6.

Figure 6

Pembroke Dockyard

The status and allocation of the land within the dockyard walls has changed from that allocated to it in the Adopted LDP (2013). In the earlier map the importance of the dockyard and its collection is made explicitly clear by showing that it clearly lies within  the Pembroke Dock Conservation Area (PDCA). The plan that has been included with LDP2 does not make this important point clear and is misleading by omission. The extent of the conservation area is available via a different set of constraint maps, but someone reading the Adopted LDP(2013) plan and the LDP2 plan might be forgiven for believing that the conservation area is no longer an important factor in considering planning applications within the dockyard. 

This is far from the truth. See the two comparison plans  (Figure 7 - The plan from Adopted LDP (2013) and Figure 8 - The plan from LDP2 (2020)) on the next page..It is also contentious in so far as the proposals Milford Haven Port Authority (PCC’s strategic partner) have in place for the western end of the dockyard. MHPA’s plans involve the destruction and re-development of the area west of the ferry terminal, effectively replacing several listed buildings with an extensive slab of concrete and some VERY large sheds up to 40 metres high. These sheds (or shed) would be about twice as high as the two listed flying boat hangars in the eastern part of the dockyard. The scheme also envisages the filling in of the Grade II* listed dry dock and the Grade II listed Timber Pond – almost certainly the last such structure of its type in Wales and possibly the UK. MHPA’s plans are speculative and I am unaware of any companies that have made a commitment to making use of the facilities that MHPA intend to put in place. I am also aware that there is a need for well-paid employment in Pembroke Dock, but I also believe that other locations should be explored for the siting of these facilities before destroying the remaining last few dockyard industrial heritage assets.I also believe that the waste transfer licence obtained for the north eastern part of the dockyard, including the two flying boat hangars, is intended to put this area of the yard out of consideration as a location for the works that MHPA would like to carry out on the western end of the yard. The market for the type of waste that the waste transfer site has been licensed for is, and was, precarious. The main market for the waste is currently The Netherlands, on the eastern side of the UK. The eastern side of the UK has far better communication links than Pembroke Dock and is able to draw on a far wider area. It is also much nearer to The Netherlands!

[Milford Haven Port Authority have now published the pre-planning documentation for this development at: https://www.mhpa.co.uk/pembroke-dock-marine/

There is a prodigous amount of material here! To the uninitiated, very confusing! I will try and simplify this in another post. Ed 19 March 2020]

Now let’s look at the south eastern part of the dockyard where there are many restored offices, ex storehouses and privately owned residential buildings from the Victorian period. This area has been allocated as Port and Energy Related Development (PERD). On the Adopted LDP (2013) inset map for Pembroke Dock this is not illustrated particularly clearly. This includes the Dockyard Chapel, now home of the Pembroke Dock Heritage Centre. It also includes, surprisingly, the Pembroke Dock market which is outside the dockyard walls, but the property of PCC. These buildings are listed, many having been restored at great public expense. This designation also applies to the privately owned Paterchurch, (formerly property of PCC), a scheduled and listed Grade 1 medieval building which lies further west, just inside the dockyard wall. This designation (PERD) is severely inappropriate for such sites and should be changed to one that reflects the true nature of these areas.

Figure 7

Figure 8

Pembroke

Housing Allocation

Housing Allocation HSG/095/00147(Figure 9) lies partly within the Pembroke Conservation Area and in close proximity to Monkton Priory Church, Pembroke Castle and the Medieval dovecote that was attached to the priory. There are other important monuments and landscape features within close proximity too.

This is another example of where the layout of the mapping and the indication of other constraints that might have an effect on the suitability of the site for a housing allocation, is unclear and confusing. The hiding of large areas of the mapped area under indicators of more detailed mapping is particularly poor and is a misleading hindrance to those interested in PCC’s intentions for LDP2. There are certainly ways  in which the mapping could have been made more readable to the general public. The overall impression is that the mapping has been designed to be deliberately obfuscating to the general reader.

The map on the facing page shows clearly that the larger part of the housing allocation HSG/095/00147 lies within the Pembroke Conservation Area. It is interesting to note that CADW makes no comment about this being the case in their response to planning application 19/0339/PA .

I have also noted that on the Lle Portal Wales the old conservation area boundary is available for download, but not the present boundary. See Figure 9.

The follow map, Figure 10, shows the extent of land visible from the top of the Keep of Pembroke Castle. This area is shaded in red. The housing allocation discussed is shown outlined in orange.

It should be borne in mind that building at this allocation will detract significantly from the setting of both Pembroke Castle, Monkton Priory Church, Old Hall and the medieval dovecote. This will lessen the attractiveness of these sites to tourists, especially as viewed from the walls and towers of the castle,  and thus reduce the number of visitors who come to the town - particularly those on repeat visits. 

Pembroke is currently dependent on tourism as one of its main, but faltering, sources of income. This allocation would also run counter to the visionary developments of the South Quay, Westgate Hill and Darklin within the town.

See Para 4.34, page 43; Also the allocation is clearly against policy GN 22-Protection and Enhancement of the Historic Environment.

It is my strong view that this allocation/application, if passed, will set a precedent that will be very hard to challenge in future planning applications.

Figure 9

Figure 10

Finally......

GN 25 Retail and Commercial Centre Development
Paragraph 5.123 of this policy (pp. 118-119) suggests that there may be the possibility of the historic burgage plots outside the centre of the settlement, but being within the Pembroke Conservation Area, being used for residential development. I am staunchly against any such possibility being made available by the content of this paragraph. 

I hope that Pembrokeshire County Council is able to incorporate my comments into the Reviewed Local Development Plan.