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....
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
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