HAMPSHIRE CHAMBER OF COMMERCE OBJECTION TO PORTSMOUTH CITY COUNCIL PLANNING APPLICATION 13/00993/OUT RE-SUMBISSION OF 12/00998/OUT. Trafalgar Wharf, Hamilton Road, Portchester, Portsmouth PO6 4PX Outline application for a mixed use development comprising: Up to 163 dwellings in 2, 3 and 4 storey buildings and one 10 storey building with associated landscaped areas and parking, Construction of buildings for B1, B2, B8 use following the demolition of existing buildings Flood defence barrier Revised main access This proposal was drawn particularly to the Chamber s attention by BMF South, a major constituent committee of the British Marine Federation, because of the site s strategic importance to the marine industry and their desire to protect marine sites. Hampshire Chamber of Commerce s main objection is to the misuse of valuable, irreplaceable shore side facilities for marine activity one of the Solent LEP s (Local Economic Partnership) main growth target sectors. The Planning and Transport committee of the Hampshire Chamber considered the Trafalgar Wharf application on 8 th January 2014 Background The Solent Waterfront Strategy and Solent marine industries The Hampshire Chamber of Commerce has been consistently supportive of the marine industries within the Solent region over many years. When SEEDA, with similar objectives, invested in purchasing key waterfront sites, the Chamber and SEEDA worked together with the British Marine Federation to commission the Solent Waterfront Strategy. This ground breaking document published in 2007 considered the marine industries in great detail. It described the wide range of marine industries operating within the Solent and the fundamental importance of those industries individually and collectively to the regional economy. A total of approximately 25% was given as the contribution of the marine sector to the regional economy, without including certain large elements such as oil and cruise ships. Because of the major recession of the last five years, there have been significant shifts in the marine economy. The port of Southampton has continued to expand, cruising has boomed, while the building of warships has declined. Despite these and other changes, the Chamber considers this Study to remain highly relevant and useful. The Solent Waterfront Strategy highlighted some of the threats to the prosperity of the marine industries, in particular those relating to waterfront sites. Suitable sites which provide access to deep water and to land are limited; many of them are heavily constrained by existing 1
development or nature conservation designations of national and European significance. There is too the constant threat of redevelopment of these sites for higher value uses unless they are protected by planning policy. Once lost a site cannot be replaced. The study provided a Solent wide context for considering any proposals for change of use. This too has been a constant theme of Hampshire Chamber s concerns, namely that the policies for marine industries have to be considered on a Solent wide basis; a district by district basis is not sufficient. The cross boundary inter connections of the supply chain issues have been intensively studied by Marine South East which provides information, research and support focussed on marine industry. Clusters of economic activity The Study has also demonstrated that the marine industries are a clearly defined sector but containing numerous sub-sectors e.g. defence, leisure, fishing, port. It shows too that the marine sector has also a strong tendency to cluster in which a number of firms operate close together and often on the same site supporting each other. Portsmouth Dockyard is clearly one such cluster, the Port of Southampton another and the leisure marinas, yards and back up industries on the Hamble and at Lymington are others. In the leisure industry, where firms are generally small, multiple small firms cluster together in boatyards such as Hamble Point Marina. Trafalgar Wharf is another cluster example. Policy SEEDA, PUSH and the Solent Local Enterprise Partnership (LEP) In policy terms the marine economy of South Hampshire, including the Isle of Wight, has been at the forefront of economic policy for the last 10 years or so. Its importance is being constantly reaffirmed by the bodies responsible for the economy in the region.eg SEEDA, then PUSH and now Solent LEP. It has been recognised as an industry of special importance in planning documents. Thus, the initiatives of the South East Plan in establishing the importance of the marine economy as a sector and the need to consider and make provision for expansion of dynamic sectors, and particularly the needs of those sectors and its clusters, has been taken on both by PUSH and now by the LEP. National Planning Policy Framework The National Planning Policy Framework (NPPF) para 21 bullet points 2, 3, and 4 requires local authorities to set out their economic vision and strategy for the area, to identify either criteria or individual strategic sites to meet anticipated needs over the plan period, to support existing business sectors taking account of whether they are expanding or contracting and to support the promotion and expansion of clusters of economic activity. It is within this context that the Hampshire Chamber objects to this proposal for Trafalgar Wharf as a threat both to the Marine use of the site and to the wider promotion of the marine economy in the Solent LEP/PUSH area. 2
Economic Profile of Trafalgar Wharf Hampshire Chamber of Commerce notes that in the supporting documentation there is no study of the economic importance of the marine industries, which sites might be important, or of the place of Trafalgar Wharf within the wider context, either of Portsmouth Harbour or of the marine industries in the Solent. The Chamber considers this is a fundamental shortcoming of the material submitted by the applicant. Trafalgar Wharf is an important marine site both locally and regionally. In its present form it was developed by Vosper s to provide manufacturing space for the building of medium sized naval craft for Oman in the 1980 s. It has therefore all the facilities that such a site requires in terms of access to deep water and buildings and other infrastructure. When Vospers ( BAE) concentrated their activities within Portsmouth Dockyard, the site was sold and has since been strongly marketed and developed for a range of leisure, boating and marine services including repair and maintenance of medium sized craft. This exercise appears to have been successful in that the website shows that 80 firms are now housed within the Trafalgar Marine complex. Many of those are marine firms, which together comprise a strong and growing cluster. The largest of the sheds on site, built for shipbuilding is now a dry stack, - an effective way of storing motorboats undercover at high density, but with low employment. Effect on Trafalgar Wharf of the proposed redevelopment site The planning application is for the proposed redevelopment of 2/3 of the Trafalgar Wharf area, leaving 1/3 with the largest of the sheds outside the application site even though within the same ownership. About half of the application site is to be redeveloped for housing or housing related purposes. Of the area to be redeveloped for housing the Portsmouth local plan adopted in 2012 clearly shows this is part of the area to be retained for industrial use with a strong emphasis on marine use. It is on this land that the 10 story tower block is to be erected. The loss of key waterfront land and an existing marine cluster The Chamber s first consideration is for the loss of a substantial area of key waterfront land to housing. The Chamber would ask the planning committee to take account of the potential of this site which provides for local employment close to homes, particular for those with engineering and marine skills. It is the largest dedicated yard within Portsmouth Harbour which is not under the control either of the Royal Navy or of the Port. It has particular potential and importance because of the reduction in employment as a result of cut backs in warship manufacturing in the Dockyard. As such it would be the natural focus of the measures put in place by the Government to assist and make good some of this loss through the cooperation with the Solent LEP. Bad Neighbour Effects of the Residential Tower Block The Chamber notes the other objections to the tower block from English Heritage because of the dominance of the structure and the visual impact on Portchester Castle. The tower block is also objected to by Marine South East because of the potential impact and bad neighbour effects 3
between residents in high value marine view properties and an industrial working site. The Chamber shares this concern. The harm which can be claimed by residents when seeking to curtail activities on industrial sites can be those of hours of working, levels of noise, smell etc. There is experience of this from various sites. Residents have of course statutory rights under the control of the Pollution Act. These are a threat to the type of operations which are carried out on boatyards such as Trafalgar, where heavy lifting and industrial processes must take place in the open. The future of marine firms displaced by the redevelopment The second element which concerns the Chamber is the lack of information on what happens to the 80 firms who are currently operating on the yard. While some of these are in the retained land already in use by marine industries, the whole remainder of the site is to be redeveloped and it is not clear what latch the new premises will provide for existing, tenants or whether these will be either suitable or affordable premises for marine purposes. It is surprising that such information is not given, equally surprising that none of the existing tenants have expressed their concerns. The redeveloped buildings appear to be largely office / business rather than workshops. It should be noted that much marine related work does not require high quality accommodation and often work takes place on boats themselves pulled up on yard space sometimes with temporary structures. Flood Defences The Chamber notes that as planning gain the developer proposes to put in place improved flood defences. This will benefit primarily the new housing areas and also other existing houses. This is clearly a pre-requisite for the housing and is not in our view as important for the continued operation of the yard. The planning gain for protecting other houses is not sufficient reason to let go such a significant proportion of working yard, or compromise the operation for the remainder. Housing versus vital economic assets The Chamber notes no social housing is to be provided as part of the housing area, or the low economic return. This further limits the public berthing of the proposal as a whole on the balance to be drawn between additional housing and the protection of vital economic assets such as Trafalgar Yard. Recommendations by Hampshire Chamber of Commerce The Chamber strongly urges the Council not to grant consent for application 13/00993/OUT without further information on two key points; The importance of the Trafalgar site to the marine economy, both of Portsmouth and the wider Solent Local Economic Partnership (LEP) area. The future of the 80 firms, currently located in Trafalgar wharf, that are to be displaced by this proposal. 4
The Chamber considers that, in its present form, the application should be refused. The grounds for this are:- It reduces the area of this key marine site, contrary to PCS11 (both as shown on the Proposals map and in the text of the Policy) The design of the housing and its proximity to the working yard create a bad neighbour situation which threatens the future operation of the marine site by noise, working hours and other environmental effects.(conflict with PCS11) Destroys a flourishing marine cluster in a sector(marine) which is key to the economic strategy of the Solent LEP and PUSH. Destruction of the marine cluster is contrary to NPPF para 21 The Hampshire Chamber of Commerce would urge the Local Planning Authority:- to work with Solent LEP to update and refresh the Solent Waterfront Strategy as a basis for considering the future of this and other sites within Portsmouth harbour and in the wider Solent. To look elsewhere for means to improve the local flood defences These comments were agreed by Hampshire Chamber s Planning & Transport Committee. Jimmy Chestnutt Chief Executive Hampshire Chamber of Commerce Hampshire Chamber of Commerce is the Independent Voice of Local Business across the county and is one of the largest business representational groups in the UK. It brings together the combined influence, strength and expertise of the county s three former major Chambers of Commerce. This substantial business network engages businesses of all sizes and in all sectors whether throughout Hampshire, or in local groupings as and when required and focussed on the areas of Solent LEP, Enterprise M3 LEP, South Hampshire, the New Forest, North or East Hampshire, or the city regions of Portsmouth, Southampton, Winchester and main towns such as Aldershot, Andover, Basingstoke, Eastleigh, Fareham, Farnborough, Fleet, Gosport, Havant. 5