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
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