These comments have been submitted in response to the revised application under TCP/11822/Y-P/00637/14. The comments are from the Solent Protection Society (SPS) which exists to protect the Solent for future generations. We have already commented on the earlier 3 applications and where still relevant the same points are repeated below, modified when appropriate by the information in the revised application.
Harbour wide Issues
This is an Outline application which, we understand, only seeks approval for Landscaping and Layout with Access, Appearance and Scale left as Reserved Matters.
Given the sensitivity of the Harbour and its conservation designations this should have been a Full application not an Outline one. There are no landscape details other than a broad description and this is inadequate for an approval of this aspect. Some information related to Access, Appearance and Scale is given and we will comment on the information presented as we consider that the aspect of Scale in particular is highly relevant in this location and that the views from the sea and across the harbour are vital considerations.
Any approval given to Layout must in the view of SPS make clear that any significant variation from the drawings finally submitted at Outline stage concerning Appearance and Scale will require a full application not an application for approval of Reserved Matters.
- Access. It is understood that no access points are significantly changing but we would hope that Highways advice will form part of the Outline evaluation as this could result in loss of important landscape features for which mitigation will be required.
- Appearance. SPS would expect to see more detail on this and more information about the appearance in the wider context, but the proposed materials and architectural form, subject to the comments below, would seem appropriate at this stage. SPS would expect a high standard of design to be a condition of the Outline approval.
- Scale. This is a significant aspect of the impact on the wider landscape and the view from the Solent. The introduction of 3 storey high blocks of terraced housing at both Bembridge Marina and Duver Marina are significant matters of scale and there is insufficient information in the form of say photomontages to judge the impact in the overall context of the harbour.
- Landscaping. There is inadequate drawn information and this would be difficult to provide without the detailed building and site proposals. SPS do not consider that Landscaping should be included in any approval but should be subject to the same conditions as suggested for the other Reserved Matters and tied to the requirements set out in the Ecology report.
- Layout. SPS considers that the proposed footprints and uses on each site are broadly appropriate subject to the detailed comments below on a site by site basis. There should only be minor alterations in any Reserved Matters application such that they do not change the proposed scale, massing and location of the proposed buildings (if approved) as the sensitivity of these are critical to the overall appearance and ambiance of the harbour.
- Overall. All these areas of the harbour need reinvestment if they are not to fall into further decline and SPS recognise that the investment has to be supported by some form of commercial return unless a philanthropist comes along. In principal SPS are not opposed to the areas selected being redeveloped in some form. In the overall context of the harbour they do not represent a significant area of land or a large scheme, even taken collectively but SPS does have some reservations in detail which are set out on a site by site basis below.
- 3. Flooding. This is a significant factor with depths up to 1.4m predicted. The applicant has proposed measures to flood proof the individual properties but has not solved the problem of access in the case of a flood for emergency vehicles, evacuation etc. The EAs position in the past has, SPS understands, been to resist any form of new residential development in Flood Zone 3 unless there is safe and dry access in and out, which as far as SPS can see is not the case here. The applicant is relying on early flood warning and evacuation before the flooding occurs. This has not been accepted by the EA in the past for new build residential and to do so now would set a precedent which would, if granted, need to be clearly circumscribed. More residential development increases the risk of future problems for the emergency services and may well lead to a demand for further flood defences which could well have a significant impact on the shoreline particularly at the Duver Marina. This is therefore a serious concern for SPS. We note that the EA has yet to comment on this aspect of the application.
- 4. Protected Areas. The areas proposed are already under development and so the proposals are unlikely to have a significant impact on the adjoining protected areas provided the mitigation measures in the ecology report can be maintained. However buildings such as the old boathouse are little used and so more intensive use may have an impact on the adjoining water area. The area is a sensitive site within SEMS, and the lagoons hold species listed as Vulnerable on the IUCN Red List. (Starlet Sea Anemone)”. SPS welcomes the additional ecology information which is well presented and supports the idea of the silt pond as additional mitigation which will enhance the mosaic of habitats and SSSIs in the vicinity of Bembridge Harbour. SPS also welcomes the proposals to reduce light pollution as much as possible and will look at this more carefully when the reserved matters are considered.
- Timing. It is important that improvements are developed in advance of or in parallel with the residential development. SPS would expect to see suitable conditions to ensure dwellings are not occupied until agreed improvements have been completed.
Site Specific Issues
1 Site 1. Duver Marina.
- There are no views from the sea or harbour illustrated and this should be sought from the applicant so that a proper assessment of the impact on the Solent and its tidal rivers can be assessed.
- Subject to seeing this, SPS is concerned that the 3 storey terrace block of housing in its proposed form will be over dominant and detrimental to the appearance of what is at present a somewhat disjointed but picturesque collection of smaller scale buildings. While some effort has been made in the revised application to articulate the skyline and reduce the impact of the gable walls beside each terrace, in the view of SPS this is not sufficient and the skyline needs to be broken by at least one if not two of the units being limited to 2 story. This may reduce the number of units by one.
- SPS supports the need to try and maintain local small scale marine industry and is concerned that if further residential development is permitted at The Duver it will give rise to conflict with boat repair and overwintering activity leading to further loss of marine facilities.
- The proposal to base the harbour office here and rebuild it is supported
- The proposal to build residential property increasing the risk from flooding with inadequate evacuation will create a demand for further flood defence and is therefore not supported unless a satisfactory means of evacuation is devised such as raising the Duver access road.
- The proposal to improve the sewerage arrangements and other marine facilities is supported.
2 Site 2. Bembridge Marina.
- The proposals are generally at the far end of the harbour and adjoin the main residential areas so there is no objection in principal to some development in this location.
- The intensity of development, however, results in very limited external space around the buildings particularly the block of 5 and could result in a slab like appearance at the end of the harbour when viewed from a distance. The scale and form could therefore be more varied. Again a view from the harbour in context would be helpful to see the scale and massing before a final decision is taken. A photomontage of the proposed outline should be sought and made available to objectors. No effort has been made in the revised application to address this point so we would suggest that gable walls on each side of terraces are reduced on these blocks too and that at least one or two units in the centre are reduced to two stories. This may mean a reduction of one unit overall. The somewhat mediocre architecture of former housing around the harbour should not be taken as a precedent to follow.
- There remains a concern about flooding, however, there are more defences at this point and the increase in units relative to existing housing is less significant. It will be a balance between EA advice and other considerations as to whether the increased risk for evacuation is justified.
- The floating shower and toilet facility will add to the apparent density at the end of the harbour but is not considered significant from an SPS point of view.
- Site 3. Selwyn Boat Yard and Old boathouse.
- The proposal to create 6 small single storey light industrial units is reasonable and SPS have no objection to the proposal in principal as they will have a minimal visual impact on the Solent. We note there is now no turning area at the end which may give rise to some practical problems.
- These units are not considered high risk from a flooding point of view but could lead to a demand for increased flood defence from occupiers which SPS imagines could impact on the banking particularly on the SE side. The ambiance and visual character of the landscape banking should not be jeopardized and should be conditioned accordingly.
- The Proposed house is isolated and so the flood risk issue for evacuation is more significant here. The overall detail is even vaguer for this building and it will stand out above the houseboats, we think, though no sections are provided. It has been kept long and low and only 2 storey and it has trees either side but it would have to be an exceptional piece of architecture to justify a property visually here, particularly as Natural England’s conditions may mean it moving further up the slope. As it is only a single property there is more chance of an evacuation plan being effective provided the use of the house is limited to owner occupation only, but we remain concerned that any new flood defences will change adversely the quiet, natural serenity of this area.
- There is insufficient detail to grant an Outline approval in such a sensitive location in the view of SPS. This house should be subject to a full application and perhaps a split decision should be given on the application, if Outline approval is to be granted to the industrial units, with a refusal for the house due, as a minimum, to lack of information. It would be wrong in our view to establish the principal of residential development on this site without full details including detailed ecological impacts and mitigation, if not an EIA, once foundation details are known.
- We note that the applicant states that development of the industrial units is dependent on the grant of planning approval for the house. In the view of SPS specific harbour improvements should not be tied to specific sites gaining residential approval. We are not party to the detail of the business plan but as this is now rightly a single application, the income generating development and the improvements should be viewed in the round across all sites.
- SPS is concerned that the mitigation plan and the CEMP may not be properly monitored considering the lack of ecologically trained personal in the E Wight. A contribution to the cost of monitoring could be a condition of approval.
- The ecological report regards the scrub composition to be removed to make the carpark at Bembridge Marina as “not unusual”. This is true, but since the RSPB have recently removed so much scrub and trees from the Brading Marsh, low level cover for birds and mammals of this type is not as common in the immediate surroundings as it was previously. Care should be taken therefore not to suburbanise the carpark, and that the current species mix should be retained around it.
- SPS is concerned that the public access along the old railway track is maintained in the future.