Address to Pembrokeshire Planning Committee on 18 May 2021 re: Planning Application 20/0732/PA.

 

18/05/2021 09:45:00

Address to Planning Committee 18 May 2021 re: Application

20/0732/PA – Gate 4 Pembroke Dockyard

 

Mr Chairman, Councillors, ladies and gentlemen, my name is Adrian James and I am speaking to you today to update you on objections to the proposals put forward by Milford Haven Port Authority in their planning application 20/0732/PA,  at Gate 4, Pembroke Dockyard.

 

You have now had the benefit of the site visit/s undertaken on 12 May 2021. This will have involved going over the site in the dockyard and many of you will have thought “What a mess!”.

 

Many of you will have made your minds up about your decision already. I just ask that you temporarily set that aside for a few minutes and listen fairly to what I have to say today.

 

I will not revisit what I spoke about at the last meeting as you will all have received information from me by email and what was said at the meeting is an item of record on the Planning Committee Webcast.

 

I managed to get down to Pembroke Dock last week and I took the opportunity to look over the dockyard and Llanion. It was good to be home. I also took the opportunity to speak to a few of the people who would be affected by this application.

 

I will not discuss objections, as these have been presented in great detail and you will have read them. Today I will talk about the comments of support for the scheme.

 

This will be quite a difficult thing to do as I have no wish to betray confidences in such a public forum, so I will not mention names.

 

I asked the planning support team if I could see the comments, (both in support and objections), submitted regarding the application. Normally I would go to the county offices to read the file, however the present Covid situation has prevented this.

 

I am grateful for the help that the planning support team have provided in supplying redacted copies of most of the submissions made. There may be one or two that I have not seen, but this may well be due to the redaction process removing identifying features from the correspondence.

 

The officer’s report, as included in the papers presented to the committee imply that there were several individual representations of support submitted by members of the public. I can only find one – a brief submission made via an iPhone.

 

The submissions made by companies or bodies are more easily identified. All of these submissions are from sources that have a close association with the applicant – whether tenants of the applicant or bodies upon which the applicant has influence via membership. There was one exception to this pattern.

 

The letters of support were, in many ways quite similar. Some went into more detail than others. A majority contained identical phrases.

 

As I mentioned earlier, I have also spoken to several people in and around Pembroke Dock about the plan for the dockyard submitted by the applicant. The most interesting of these discussions was with the directors of a successful company that undertakes work akin to that imagined for the western dockyard,  locally, across the UK and abroad.

 

The discussion went on for well over an hour. Whilst the company supports the need for greater employment opportunities in the area – of the sort that the scheme might bring to Pembrokeshire, they were also dismayed that this might be at the cost of destroying the last monuments to shipbuilding in The Yard. They made the point that, as we are all aware, this unique collection of  monuments is an illustration of the reason that Pembroke Dock came into existence.

 

They doubted that 1800 jobs was a realistic expectation as the plans were way behind what is going on elsewhere in the UK and Ireland in this area of marine energy. They seemed to have little faith in the ability of the applicant to carry through the project to a successful conclusion as the scheme was well outside the applicant’s area of corporate expertise.

 

When asked as to why they had written in support of the project I was told that the applicant had had contacted them and asked that they wrote to PCC to express their support for the project. They felt that there was commercial pressure to express the desire for more employment in the area. They were advised about what to say and were offered a template letter to adapt.

 

I am not that naïve to NOT expect that such methods are employed. Personally, I would not do this as I believe that if anyone feels strongly about an application they should put forward their point of view in their own way. I have been approached to supply template letters and I have always refused to supply such as a matter of principle.

 

I was surprised by the response of these directors who clearly had affection for Pembroke Dock and its heritage.

 

You must now decide on whether this application is allowed. The application seems to have little intention of achieving a compromise, which is a shame. Pembroke Dock Town Council is opposed to the scheme and yet they fully appreciate the need for jobs in South Pembrokeshire.

 

It is in your power to save this unique last remaining assemblage of monuments to the birth of Pembroke Dock. I ask that you do not listen to the ridiculous notion that deliberately burying monuments is a way of preserving them. It is not. It will put them permanently beyond reach. I ask that you do not listen to trivial mitigation strategies that the applicant proposes for they are but crumbs of justification.

 

The present deplorable state of the western dockyard is down to the conscious decision of the applicant to neglect its duty of care owed to the listed monuments and the surrounding site. You will all be remembered for the decision that you make today. That is the result of the responsibility you have taken on. I ask that you please give Pembroke Dock the opportunity to forge a different, more sustainable and friendly route towards economic well-being. I, like many others, will rise to the challenge. There are alternatives to this proposal and the applicant needs to think again.

 

I wish you well. Thank you.

First Letter of Objection to Pembrokeshire County Council Planning Application 20/0732/PA in Pembroke Dockyard.

Letter Notes and diagrams available via hyperlinks in the text.
Pembroke Dock	East Bergholt
Pembrokeshire	Colchester
	Essex
Pembrokeshire County Council
Planning Department	Email:

 

21 January 2021

 

Dear Mr Simmons

 

Planning Application: 20/0732/PA (Outline) – Gate 4 Pembroke Dockyard

 

I am writing to state objections to the above planning application and to ask that Pembrokeshire County Council refuses to grant outline permission. I have attached to this letter my notes regarding the several ways in which this application fails to meet policy guidelines as set out in the adopted Local Development Plan (LDP). I have also attached some diagrams that illustrate some of my reasons for objecting to this application.

 

My reasons are:

 

1)      The scheme proposed would have negative environmental and social impact on those living in and around the site. Given the magnitude and impact of what is proposed, there are only vague expressions of the likelihood of it providing economic benefit to the local community. The scheme is not of strategic national importance otherwise it would be determined at government level.

 

2)      The scheme is inappropriate and damaging for a site within a Conservation Area, set within a Landscape of Outstanding Historical Interest.

 

3)      The area is identified in the LDP as having been allocated as an employment zone. Transformative development does NOT have to be such that it destroys the historical assets within its boundaries. Any transformation that takes place should build upon the assets already existing, particularly in a place that has such significance for cultural history of Pembroke Dock. This scheme is destructive of the cultural and amenity value of the site.

 

4)      Alternative sites for the scheme are available within the haven, but these have not been explored adequately by the applicant. The applicant’s trust port status places an obligation on them to build upon the assets that give the community of Pembroke Dock a sense of culture, place and well-being. In return they have been given extraordinary powers which they are now using to prize a project into their own property, for which it is ill suited for a range of reasons.

 

5)      The scheme would detract from the clear potential that the site has to act as a catalyst in boosting the visitor economy of Pembroke Dock. The site has obvious and great potential to help make Pembroke Dock into destination that visitors would return to.

 

6)      The scheme would, due to its scale and location, have a negative effect on the prospect of developing highquality visitor accommodation within Pembroke Dock. The ability to cater for tourists and tourism is an identified leading characteristic of the Pembrokeshire economy.

 

7)      Apart from the destruction of a unique signature collection of listed monuments that are a statement of the origins of Pembroke Dock, the proposed fabrication sheds and swathes of concrete inflict severe damage on the settings of other listed buildings and scheduled monuments within the dockyard and wider conservation area.

Notably the buildings whose context and setting will be drastically altered for the worse are:

i) Paterchurch (Listed Grade I and Scheduled Monument); ii) SW Dockyard Tower (Listed Grade II* and Scheduled Monument); 

iii) Bomb Stores at West End of Fort Road (Scheduled Monument); 

iv) Defensible Barracks (Listed Grade II* and Scheduled Monument); 

v) The former Commodore Hotel (Listed Grade II*); 

vi) The former Oakum Store (Listed Grade II); 

vii) The Foremens’ Office (Listed Grade II);

viii) A series of listed buildings that with The Commodore comprise the Terrace and Gateways etc. (Listed Grade II*); ix) A series of listed Offices, Stores and Houses (Grade II);

8)      See: https://cadw.gov.wales/advice-support/cof-cymru/search-cadw-records for further examples.

 

9)      The destruction of so many other buildings within the dockyard, that incorporate much skill, worked materials and effort is a waste of natural resources. Many of these buildings could be put to good use in a scenario that is very different and more sustainable than that proposed.

 

10)   The applicant is intending to use its extraordinary, but now inappropriate powers, to summarily evict a number of freeholders and tenants to allow the proposed scheme to take place. In many cases this means that the businesses displaced will find it extremely difficult to find alternative accommodation. This will undoubtedly affect their well-being and future economic resilience.

 

11)   The amenity of residents and properties within close proximity to the site will be severely diminished leading to loss of personal well-being and those characteristics of one’s home or workspace that make for a pleasant life.

 

12)   The location of some fabrication sheds and concrete work areas will allow unavoidable construction and maintenance noise to impinge on the well-being of patients, staff and visitors at the neighbouring South Pembrokeshire Hospital.

 

13)   The design of the proposed buildings is unsustainable.

 

14)   The design of the buildings pays but an imagined regard to local distinctiveness.

 

15)   The scheme, of uncertain nature and future, will critically diminish any future opportunities that Pembroke Dock will be able draw upon to use its rich history to its own economic benefit.

 

Pembroke Dock has a unique history and design. The buildings in the dockyard and town are a testament to the lives spent creating the place over the course of the nineteenth century. The dockyard employed the most skilful workers in its construction and to produce its signature product – ships. The masons, blacksmiths, carpenters and shipwrights built a town that reflected their talents and capability. They left us buildings and spaces, particularly in the dockyard, that have sadly been squandered. Now is the time to stop this desecration of the past and to put it to a use that will benefit, in all the best ways, the residents of Pembroke Dock.

 

I hope that the above and the attached notes and diagrams will be of assistance to you and your colleagues in making a decision. I request that you refuse this application for the longer-term benefit of Pembroke Dock, which needs to find a way forward that is not dependent on a boom-and-bust economic cycle.

 Yours sincerely

Adrian James

Second Letter to PCC to OBJECT to Planning Application 20/0732/PA - Gate 4 Pembroke Dockyard

Pembroke Dock

Pembrokeshire

Colchester

Essex

Pembrokeshire County Council

County Hall

Haverfordwest

Pembrokeshire

SA61 1TP

 

 

Dear Mr xxxxxxxx

 

Pembrokeshire County Council – Planning Application: 20/0732/PA - Demolition, part demolition and infill, modification of slipways, erection of buildings and ancillary development - for port related activities including the manufacture of marine energy devices, boat manufacture and repair and erection of plant (outline planning permission with all matters reserved for future consideration)

 

 

I am writing in connection with the above application, which I would ask that you REFUSE.

 

My reasons for requesting that the application be REFUSED are:

 

1.       If granted, this application will see the burial and/or destruction of a rare group (unique in Wales) of listed monuments that represent the last remnants of the industry (ship building) that gave birth to the town of Pembroke Dock. Aside from the effective loss of the listed structures (see the note at the end of this letter), there are other buildings that, although not listed, will be removed. Together with the listed structures, these buildings are very important within the context of the former Royal Pembroke Dockyard, Pembroke Dock Conservation Area and the Milford Haven Waterway Landscape of Outstanding Historical Interest (LOHI). It is the presence of the Dockyard that, in the nineteenth century, drove on developments around the Milford Haven waterway, including the array of defensive fortresses that were built, at great cost, in the middle of the nineteenth century and that today are slowly being brought back to life by a range both private and commercial developers. Removal of the monuments that gave rise to all this innovation and development effectively destroys the heart of the story of Pembroke Dock. See Annex A

 

 

2.      I also believe that in locating this project within the historic dockyard at Pembroke Dock, the Milford Haven Port Authority has neglected to explore adequately other locations within the haven where this development could be situated. Milford Haven Port Authority (MHPA), a trust port organisation has powers that are way beyond what are needed for their role in 2021. The authority is effectively a private development company that has available to it powers, (for example, compulsory purchase powers) that other commercial companies would give their right arm for. Of the other locations, there are three that are immediately worthy of consideration. These are:

 

·         Waterloo Industrial Estate, on the eastern side of Pembroke Dock;

·         Blackbridge Pill, East of the town of Milford Haven;

·         Development in partnerships with one (or more) of the other large, fossil fuel focused companies that operate around the haven and in its hinterland. i.e. Valero, Dragon LNG and Puma Energy.

 

Please see Annex B for further explanation of the best of these sites which is, I believe, the Waterloo Industrial Estate. I have not looked at the other possibilities mentioned above in such detail.

 

The construction of this scheme at an alternative location then opens-up the potential for the western part of the dockyard to be developed as a heritage, water activities and visitor attraction. This would bring a different range of employment opportunities to the town. This would also make the employment market in the town more diverse and more resilient to future changes in both local and national economic forces.

 

 

3.      Aside from the effectively irreversible damage to an important heritage site within both Wales and the wider UK, the submitted proposal states that sheds, (in two cases), of massive proportions are to be erected over the buried monuments and large areas of concrete slab will be laid over much of the remainder of the site. The two sheds are planned to have a maximum height of 40 metres, which is twice the height of any other buildings in the dockyard. The latest version of the indicative site plan submitted by MHPA is attached, showing the location of the two larger sheds (Shed A and B). Shed C has been located hard against the boundary of the former Commodore Hotel, a derelict Grade II* listed building, formerly the residence of the Captain-Superintendent of the Dockyard. This is currently subject to viability study by The Commodore Trust, a CIO whose ambition is to renovate the buildings and have it become an asset for the benefit of Pembroke Dock – both residents and visitors. Further information about the intrusive and dominating nature of these buildings and the way that they will affect the Pembroke Dock Conservation Area and Milford Haven Waterway LOHI can be found at Annex C.

 

 

4.      The construction of the proposed Mega Slip involves the dredging and excavation of the seabed immediately east of the Carr Jetty (Listed Grade II). These works, Particularly the excavation of bedrock to accommodate the new slip, is likely to disturb and damage the foundations of the Carr Jetty, which is an impressive monument. The Mega Slip will also see the partial destruction of the two western-most slips in the dockyard. These slips saw the genesis of some of the largest and most famous ships to serve in the Royal Navy prior to 1926. The slips serve as a monument to the men who built them, who served on them and died in the service of their country in World War I on these vessels.

 

 

Pembroke Dock is a town with a huge potential for future economic benefit from the visitor economy. It has a good access to the water, a history that is of incredible depth and variety and a stock of old buildings that has a distinctive and unusually symmetrical layout. It has, sadly, suffered from some very poor planning decisions in the past that have slowly eroded some of this heritage, and the reluctance of Pembrokeshire County Council to support the maintenance of the conservation area and promote the town and its special characteristics has been extremely frustrating and lacking in vision and ambition. However, I sense a change in attitude over recent months, which is refreshing and positive.

 

A prime mover in the promotion of a new and refreshing visitor experience would be the western dockyard, that could provide much employment through heritage, water-based activities and visitor focused businesses, plus providing accommodation for small scale marine environment focussed, or other businesses.

 

The economy of Pembroke Dock, after the closure of the dockyard in 1926, has been subject to a repetitive cycle of boom and bust. From 1957 the arrival of the oil industry in Milford Haven provided, for a period, well paid employment for the local population and, at times of construction and during maintenance periods, work for a large number of temporary employees from all over the UK and beyond.

 

As a background to these booms in employment, the visitor and hospitality economy has steadily grown within the county. This has provided a more stable and long-term jobs market – but at a lower pay rate – for much of the population of Pembrokeshire, but particularly in the north and the southeast of the county. Pembroke Dock, due to its, in my view, misguided attachment to the promises of the energy economy, has missed out on this more predictable and sustainable visitor economy – and this is despite having a number of visitors deposited on its doorstep by the Irish ferry service!

 

 

If the Pembroke Dock Infrastructure project were to be located to the east of the town, at the Waterloo Industrial Estate, Pembroke Dock would be able to benefit from a far more diverse range of employment opportunities, thus making its economy more resilient to the future ebb and flow of business fortunes.

 

 

Annex D provides some proposals for alternative uses for the western dockyard.

Annex E provides some planning reasons for the REFUSAL of this application.

 

Yours sincerely 

 

Adrian James

 

 

 

Annex A - Information Sent to Members of Pembrokeshire County Council's Planning Committee for the Meeting on 20 April 2021

Annex A 

The Setting of Application 20/0732/PA 

within 

Pembrokeshire’s Historic Environment 

Note: The Pembroke Dock Conservation Area shown on the maps below is the area as it was before 2017. The changes in the boundary brought about in c2017 have no relevance to the application area under consideration here.

Annex D - Information Sent to Members of Pembrokeshire County Council's Planning Committee for the Meeting on 20 April 2021.

 Annex D

 An Alternative Outline View

for using the

Western Dockyard

at

Pembroke Dock

Possible Future Uses of the Western Dockyard

Visitor Attraction

The western end of the dockyard has several monuments that relate to the history of the former uses of the place that brought a new industry to the remote west of Wales that saw the founding of Pembroke Dock and a place for the ships that were built there on the world stage. All this rich history might well be facing final oblivion if planning application 20/0732/PA is granted permission. That would be a great shame for Pembroke Dock, particularly as the town could have both the new project and a heritage-based visitor economy. Other possibilities are discussed here

 

It should also be remembered that the Irish ferry service deposits thousand of visitors at the dockyard every year.

 

Water Based Activities

The Timber Pond is a structure built in about 1843 within the extended dockyard perimeter that stood immediately to the east of what is now the Fort Road foreshore. At the eastern end of the pond there is a full width ramp made of a 12 ins (0.3 m) layer of pitched stone, over a 2 ft (0.6 m) layer of rubble and concrete, this laid over a 4 ft (1.2 m) layer of puddled clay. This ramp slopes down at an angle of about 25 degrees to the horizontal to a depth of around 18 Feet (5.5.m) below the western wall of the pond. The bottom of the pond made up of the puddled clay in a layer about 4 ft (1.2 m) ft thick. (The National Archives: ADM 140/486)

 

The predicted tidal ranges for Milford Haven, for years 2008 – 2026 are:

Highest astronomical tide - 7.85m (25 ft 9 ins)

Mean High Water Springs – 7.04 metres (23 ft 1 ins)

Mean high water neaps - 5.29m (17 ft 4 ins)

Mean low water neaps -2.47m (8 ft 2 ins)

Mean low water springs - 0.76m (2ft 6 ins)

Lowest astronomical tide - 0.04m (0 ft 2 ins)

 

The Timber Pond was designed with the intention of it being flushed out by the full range of tides experienced in the dockyard. The pond has two visible culverts that allow the transfer of water to and from the pond. One, on its northern side connects to the Graving Dock and the other, on the western side, connects to the foreshore of Fort Road Beach.

 

The timber pond would appear to be very useful facility for the introductory training of people who might wish to gain the basic skills of rowing, kayaking, canoeing or other similar water-based activities. Once the basic handling skills have been acquired, students can then access the main water of the haven via Slips 1 and 2 at most states of the tide. From here they can access the shallower water west of the Carr Jetty arches or other parts of the waterway to the east.

 

The Timber Pond was, on its western side a roadway that gives access to the Carr Jetty and beyond this the 12 ft high Dockyard Wall (Listed Grade II) that provides shelter from the predominantly westerly winds.

 

A survey conducted in 2013 stated that the pond was in generally good condition, although the exit of the northern culvert into the Graving Dock was inaccessible due to a thick layer of mud in the bottom of the dock. The western culvert discharged successfully onto the Fort Road beach.

 

To the south of the Timber Pond there is a grassed and concreted area that could provide parking and picnic facilities in association with the former Flying Boat Centre building that could be repurposed as a refreshment of storage facility. Building 44A Workshop (Former Admiralty Store, previously Admiralty Building 20A Trailer & Tangye Pumps) (MHPA Bldg. M689), could easily be used as a store for equipment associated with the activities that would take place in the Timber Pond.

 

Small Business/Heritage Use

There are a number buildings within the area that it is proposed to develop that could serve the dual purpose of being bases for local businesses and heritage attractions.

 

Some of the buildings that it is proposed to destroy could very well be repurposed, where necessary, for small business use. This would allow the historical significance of the dockyard and its past to be appreciated. There are fantastic examples of such adaptions at Chatham Historic Dockyard, where formerly basic and functional buildings have been adapted to make wonderful offices, museums, shops and restaurants.

 

A few examples of such buildings are:

Building 26 Workshop (Former Admiralty Workshop, previously Building 2H Hayes Joiner’s Shop, previously Iron Store) (MHPA Bldg. M675).

This small building, built of strap pointed, squared quarry faced blocks of carboniferous limestone is suited to small business use, possibly as a small scale workshop or, with improvements to insulation and wash facilities as an office space. See page 124 of Environmental Statement Appendix 10.3

 

The Former Pattern & Gunnery Fitting Shop (later Hayes Building 4H Machine Shop) (MHPA Unit 17)

 This building could fulfil a similar role to the Iron Store above, as could the Former Testing House (later Hayes Building 5H Stores) (MHPA Unit 19), Building 8 Heavy Engineering (Former Admiralty Salvage Shed, previously Admiralty Building 5A Salvage Shed, previously Shipbuilding Shop No. 1 and Shipbuilding Shop No. 2) (MHPA Bldg. M662A) .

 

Building 29 Blast / Spray Shop (Former Admiralty Rigging Shed, previously Admiralty Building 17A Boom Shed) (MHPA Bldg. 678)

An example of one of the many buildings in the dockyard that instead of being demolished, could be repurposed for use as a visitor attraction. One use, for example, might be as the venue for a large-scale audio-visual presentation/experience of an aspect of the history of the activities that took place in the dockyard throughout its life. Here that might be the history and use of Boom Defences, with a focus on this obscure defence activity at Pembroke Dock and other harbours on the western seaboard of the United Kingdom. This would be a niche, intriguing and unique experience for visitors that would publicise a military activity that is little known. There are numerous other examples that could be used that would bring little known activities to a wider audience. This could be a self-standing business or part of the wider heritage experience of visiting the site, speaking of which…….

 

Heritage focused activities

The oldest building within the western dockyard is the medieval tower at Paterchurch. The origins of this building are unknown, but it seems to have been a substantial medieval house with a large, 10 metre tall look out tower attached. A few hundred metres to the west was a small chapel and burials have been discovered in the vicinity. The small shed to the east of the chapel is clearly another surviving part of the medieval mansion, but the rest of the old house, if anything remains of it, must be buried beneath the concrete slab to the west and north of the tower. It should be remembered that the house originally stood on the south bank of an inlet of Milford Haven and some drawing show the building accessible by a bridge, over what appears to be deep ditch.

 

At present the building seems to have been hemmed in by containers and other artefacts by an inconsiderate neighbour, but if this end of the dockyard was repurposed as a visitor attraction, then the tower could well be opened up to the public and made accessible form the rest of the yard. It is a fascinating building. For more information see www.pdboyinsuffolk.blogspot.com and links from there.

 

The remainder of the western dockyard, particularly the monuments that will disappear should the Pembroke Dock Infrastructure (PDI) project go ahead, tell the story of the construction of ships from the preparation of the timber in the Timber Pond, to the building slips and the fitting out at the Carr Jetty. The Graving Dock represents the repair work that was undertaken at the dockyard and the technology used at the time to empty the dock once the caisson was in place to gain access to the bottom of the ship that had been floated in. Ultimately the dock could be used to house an historic vessel that might have associations with Pembroke Dock/Milford Haven.

 

This unique combination of monuments could tell a story that would capture the imagination of visitors and boost the visitor economy of the town. Should the PDI project go ahead in the dockyard, this last chance to change the image and fortunes of Pembroke Dock will be lost.

 

Of course, the western dockyard could provide a new home or “outstation” for other maritime/heritage groups, both local and national. Examples might be the West Wales Maritime Heritage Society, the National Museum of Wales, the Imperial War Museum, the Royal Air Force Museum, The National Museum of the Royal Navy, The National Army Museum etc. There would be adequate accommodation and there would be access to a range of funding streams. These could cater for the conservation deficit that would exist in the cost of repurposing of the buildings.

 

 

The Milford Haven Port Authority (MHPA) has produced a prodigious amount of documentation to support their application to take advantage of up to £60 million worth of grant funding and other investments. The reality is that this money is too small a sum to and the dockyard site too small a site to implement their ambitions. I suspect that in the end compromises will be made that will see the monuments effectively destroyed, an expansion of the boating building facilities offered by Mainstay Marine and perhaps the removal of some of the fabrication businesses from Waterloo Industrial Estate to fill the empty buildings newly erected in the yard. 

 

The compromises made will be the reduction in height of the large sheds, to say 20 metres and possibly, in the case of Shed C abutting the Commodore, the removal of the shed to the west of the paddock. Perhaps this is MHPA’s plan – aim high and negotiate for less. However, any such compromise still delivers a death blow to what really matters – the fate of the monuments that will be lost and the employment opportunities that will be missed. The PDI project should be built on the Waterloo Industrial Estate.

 

One of the greatest obstacles to this happening is whether Natural Resources Wales (NRW) can agree to the building of a super slip down the western side of Cosheston Pill. This is where the past endeavours of the Port Authority will come back to haunt them. I hope that NRW is able to see beyond this to the future prosperity of Pembroke Dock, and allow the building of the slip. Perhaps the answer is a partnership between MHPA, PCC and some of the businesses that operate at Waterloo and Warrior Way to ensure that Pembroke Dock gets the best of both worlds.

Annex E - Information Sent to Members of Pembrokeshire County Council's Planning Committee for the Meeting on 20 April 2021.

Annex E 

Planning Reasons

for

Refusing

Planning Application 20/0732/PA

A special note: The highlighted text refers to the relevant planning documents, the aspects of which are being discussed in each paragraph. Some abbreviations are....

PPW - Planning Policy Wales - click here to download this document.

LDP - Local Development Plan - click here to access the web pages relating to the LDP, and here for the descriptive document.

SP - Strategic Policy

GN - General Policy

Reasons

 

1)            The scheme proposed would have negative environmental and social impact on those living in and around the site. Given the magnitude and impact of what is proposed, there are only vague expressions of the likelihood of it providing economic benefit to the local community. The scheme is not of strategic national importance otherwise it would be determined at government level. (PPW 11 Ch 2 People and Places: Achieving Well-being Through Placemaking; PPW 11 Section 6, 6.7.12)

 

2)            The scheme is inappropriate and damaging for a site within a Conservation Area, set within a Landscape of Outstanding Historical Interest. (Pembroke Dock Conservation Area Appraisal, LDP SP 4, Plan Strategy 5.21 p.53; LDP GN 38 p.127-129; PPW 11 Ch 2 People and Places: Achieving Well-being Through Placemaking; PPW 11, Section 6)

 

3)            The area is identified in the LDP as having been allocated as an employment zone. Transformative development does NOT have to be such that it destroys the historical assets within its boundaries. Any transformation that takes place should build upon the assets already existing, particularly in a place that has such significance for cultural history of Pembroke Dock. This scheme is destructive of the cultural and amenity value of the site. (LDP GN 35, esp. 6.148, p125, PPW 11 Ch 2 People and Places: Achieving Well-being Through Placemaking)

 

4)            Alternative sites for the scheme are available within the haven, but these have not been explored adequately by the applicant. The applicant’s trust port status places an obligation on them to build upon the assets that give the community of Pembroke Dock a sense of culture, place and well-being. In return they have been given extraordinary powers which they are now using to prize a project into their own property, for which it is ill suited for a range of reasons. (PPW 11 Ch 2 People and Places: Achieving Well-being Through Placemaking; PPW 11, Section 6 throughout)

 

5)            The scheme would detract from the clear potential that the site has to act as a catalyst in boosting the visitor economy of Pembroke Dock. The site has obvious and great potential to help make Pembroke Dock into destination that visitors would return to. (LDP SP5 Plan Strategy 5.26 – 5.28, pp. 53-54; LDP GN 16, p.98; LDP GN 38 p.127-129; PPW 11 Ch 2 People and Places: Achieving Well-being Through Placemaking; PPW 11, Section 6 throughout)

 

6)            The scheme would, due to its scale and location, have a negative effect on the prospect of developing high-quality visitor accommodation within Pembroke Dock. The ability to cater for tourists and tourism is an identified leading characteristic of the Pembrokeshire economy. (LDP SP 1, p.48; LDP SP 5 Sec 5.26-5.28; LDP SP 16, p. 73, LDP GN 1, pp. 75-78; LDP GN 2, pp. 79-80; GN 3, 6.22 p. 82-83; PPW 11 Section 5.5, esp. 5.5.2, 5.5.4; PPW 11, Section 6 throughout)

 

7)            Apart from the destruction of a unique signature collection of listed monuments that are a statement of the origins of Pembroke Dock, the proposed fabrication sheds and swathes of concrete inflict severe damage on the settings of other listed buildings and scheduled monuments within the dockyard and wider conservation area. Notably the buildings whose context and setting will be drastically altered for the worse are:

i)             Paterchurch (Listed Grade I and Scheduled Monument).

ii)            SW Dockyard Tower (Listed Grade II* and Scheduled Monument).

iii)           Bomb Stores at West End of Fort Road (Scheduled Monument).

iv)           Defensible Barracks (Listed Grade II* and Scheduled Monument).

v)            The former Commodore Hotel (Listed Grade II*).

vi)           The former Oakum Store (Listed Grade II).

vii)          The Foremens’ Office (Listed Grade II).

viii)         A series of listed buildings that with The Commodore comprise the Terrace and Gateways etc. (Listed Grade II*)

ix)           A series of listed Offices, Stores and Houses (Grade II)

 

See: https://cadw.gov.wales/advice-support/cof-cymru/search-cadw-records for further examples. (LDP GN 38 p.127-129)

 

9)            The destruction of so many other buildings within the dockyard, that incorporate much skill, worked materials and effort is a waste of natural resources. Many of these buildings could be put to good use in a scenario that is very different and more sustainable than that proposed. (LDP GN 38 p.127-129)

 

10)          The applicant is intending to use its extraordinary, but now inappropriate powers, to summarily evict a number of freeholders and tenants to allow the proposed scheme to take place. In many cases this means that the businesses displaced will find it extremely difficult to find alternative accommodation. This will undoubtedly affect their well-being and future economic resilience. (PPW 11, 3.57 Compulsory Purchase is inappropriate as other sites exists)

 

11)          The amenity of residents and properties within close proximity to the site will be severely diminished leading to loss of personal well-being and those characteristics of one’s home or workspace that make for a pleasant life. (PPW 11 Ch 2 People and Places: Achieving Well-being Through Placemaking)

 

12)          The location of some fabrication sheds and concrete work areas will allow unavoidable construction and maintenance noise to impinge on the well-being of patients, staff and visitors at the neighbouring South Pembrokeshire Hospital. (PPW 11, 3.19 – 3.24, pp. 29-30; PPW 11 Section 6, 6.7.12, 6.7.22 - 23)

 

13)          The design of the proposed buildings is unsustainable. (PPW 11, throughout, but para. 2.6 and 2.7 is a good summary)

 

14)          The design of the buildings pays but an imagined regard to local distinctiveness. (LDP GN 38 p.127-129; PPW 11, Section 6 throughout)

 

15)          The scheme, of uncertain nature and future, will critically diminish any future opportunities that Pembroke Dock will be able draw upon to use its rich history for its own economic benefit. The community needs to establish a long term, viable economy that is independent of external windfall funding and influence. (LDP GN 38 p.127-129. PPW 11, Page 7 summary header. i.e

What is Sustainable Development?

“Sustainable Development” means the process of improving the economic, social, environmental and cultural well-being of Wales by taking action, in accordance with the sustainable development principle, aimed at achieving the well-being goals.

Acting in accordance with the sustainable development principle means that a body must act in a manner which seeks to ensure that the needs of the present are met without compromising the ability of future generations to meet their own needs.)

 

16) The Development could be sited elsewhere in Pembrokeshire. Other possible locations are:

·         Blackbridge, S/EMP/086/LDP/01, area 33.45 ha, Use Class B1, B2, B8.

·         Pembroke Science and Technology Park, Pembroke Dock, S/EMP/096/00001, area 22.38 ha, Use Class B1.

·         Waterloo Industrial Estate, Pembroke Dock.

·         A co-operative venture with one of the fossil fuel focused businesses that occupy land on either side of the Milford Haven Waterway.

 

(LDP SP 3, p. 51 for the first two locations above; LDP GN 39, p.129-130; PPW 11, Section 6 throughout, 6.4.14, 6.7.12)

 

17) The site in the western dockyard would involve the movement of large, heavily laden vehicles through the Pembroke Dock Conservation Area. A site to the east of the town, at Waterloo and Warrior Way would give easier access from the A477. This location is also more convenient for the siting of a railhead on the empty plot adjacent to the railway track into Pembroke Dock. This land is owned by the applicant and such a move would at least reduce the number of heavy lorry trips required to be made along the A477. (LDP SP 10, p.61; LDP GN 39, p.129-130, PPW 11, Section 4.1, esp.4.1.4 and 4.1.5. Also Section 5.3, esp. 5.3.19)

 

18) Pembroke Dock is identified as a hub town in the LDP. This scheme undermines the admirable ambitions stated in the LDP. (LDP SP 14, p. 68)

 

AJ. 5/4/2021