SPS response to ABP Port Master Plan 2009 – 2030 Draft

The Development Office Associated British Ports Ocean Gate Atlantic Way Southampton SO14 3QN

16th October 2009

Dear Sirs

Port of Southampton Master Plan 2009 – 2030: Consultation Draft

The Council of the Solent Protection Society has considered the consultation draft of the Port Master Plan and wishes to register its very significant reservations about various aspects of the Plan, which arise from any future commercialisation of Dibden Bay.

The SPS recalls that the Government proposes to promulgate a National Policy Statement in the near future to act as a guide to the Infrastructure Planning Commission in relation to the ports sector and feels that it is premature to reach definitive conclusions on this Master Plan until that Policy Statement has been formulated.

At the time of the Public Inquiry into the last proposal for the development of Dibden Bay, this Society was one of the objectors represented by Counsel, and so it has approached the new Plan with a view to determining whether there have been any major operational or contextual changes, which should cause it to change its earlier views.

The Inspector at the 2004 Inquiry considered that there were “credible alternatives” to the expansion of Southampton and SPS remains of the opinion that the Port Master Plan assumes too readily that any expansion must occur in Southampton. Whilst this is an understandable commercial aspiration for the Board of ABP, it may not be a balanced view from a national perspective and fails to have regard to the relationship of the Port to the context of the wider Solent.

The reservations of SPS at this stage are broadly (inter alia) :-

1 That Dibden Bay is an environmental site of national importance and its foreshore a site of international importance. Further, in the event of further development at Dibden Bay, SPS considers that some attempt should have been made in the Port Master Plan to address the issue of environmental compensation, notwithstanding that the Plan is at a very early stage.

2 The scenario propounded by ABP in which the Port will stagnate or be marginalized if it does not expand, rather than one in which the port continues to thrive on the eastern bank of the Test requires further substantiating evidence, which is lacking in the present version of the plan.

3 The impact on the landscape of further development of Dibden Bay and particularly its effect on the New Forest National Park, the City of Southampton and the River, together with the ecological effect of the additional capital dredge directly attributable to Dibden Bay are understated in the Port Master Plan.

4 While the development of the landside infrastructure is beyond the immediate scope of the SPS, concerns expressed at the last public enquiry relating to the development of the A326 and the rail links to the proposed port facility do not appear to have been addressed in the present draft of the Port Master Plan.

5 The effects on the quality of life of waterside communities, those adjacent to the necessarily enlarged or altered transport links, and those persons using the Solent for recreational purposes do not appear to have been adequately addressed.

6 Any development at Dibden Bay should be assessed in the light of other alternative developments and traffic forecasts that may exist at the time that a formal application for consent is made.
7 The current proposals do not adequately consider the effect of the increased through-put of the port on other users of the whole Solent area. This applies in particular to the western Solent which lies outside the present remit of any harbour authority and which may be increasingly used by coasters or other feeder vessels.

The Solent Protection Society awaits with interest the publication of the National Policy Statement concerning UK ports and will re-examine the Master Plan in the light of that statement.

Yours faithfully

Jeremy Clark SPS Chairman