Solent Protection Society ‘Away Day’ 2019

This year our ‘Away Day’ to Eling Tide Mill took place on 7th October, a month later than usual in order to fit in with the availability of the Mill for a private visit.

Eling is in the centre of our region, close to Totton, at the head of Southampton Water. There has been a tide mill at Eling for over 900 years and the current Mill is over 200 years old, having been rebuilt c.1785 after storm damage in the 1770s. It is one of only two tide mills still operating in the UK. It was re-opened in 2018 as a fully operational flour mill after a restoration funded by a Heritage Lottery grant, to provide “The Eling Experience”. This includes the Mill itself, the visitor centre and a walk around Bartley Water (the mill pond). The Mill is a Grade II* listed building. The visitor centre includes a café and a museum. At the entrance to the Mill there is a small gift shop. Using the same method as millers from days gone by, freshly milled wholemeal flour is available for sale in the gift shop. The wheat, which is milled at Eling, comes from a local farm – Manor of Cadland – and carries the New Forest Marque.

The Mill is located on the seaward side of the causeway across Eling Creek. When the tide comes in, it pushes open one-way gates and fills up the millpond. When the tide turns and starts to ebb, it slowly uncovers the waterwheel, but the sea gates are closed, trapping the water in the millpond so the level in the millpond stays at the high tide level. When the tide has dropped to well below the waterwheel axle, the sluice gate can be raised. Water from the millpond strikes the lower blades of the waterwheel, spinning it round and allowing the milling to begin.

The photograph is an aerial view of Eling Creek facing East. In the centre is the artificial causeway which was once the main road from Southampton to Hythe and Beaulieu. The Mill is the red-roofed building on the causeway and the visitor centre is the white-roofed building to the left. The lake in the foreground is Bartley Water, the tidal pond which stores the water to drive the mill. In the distance, top right of photo is Goatee beach, which faces Southampton docks across the River Test.

For much of the mill’s life it was owned by Winchester College. A lease survives from the year 1418, when the College leased the mill to Thomas Mydlington, requiring him to maintain the mill and the causeway. The causeway was prone to collapse, for example it washed away in 1887. This problem continued up until 1940 when modern engineering calculations revealed the cause to be the design of the sluices. This was then corrected.

The tenancy of the mill included the right to collect tolls from vehicles using the causeway. Four-wheeled vehicles were charged 6d (2.5p) and two-wheeled vehicles 4d. These rates remained unchanged until 1970. In 1967, the toll collector was Tom Mackrell who had been one of the last people to operate the mill when it closed in 1946. Tom was toll collector and mill foreman, working for his brother Raymond, master miller of Eling Tide Mill. Having been out of action since then, the mill reopened in 1980.

This visit provided an opportunity to see two sides of your Society’s work – protection of ancient sites such as the Tide Mill, and mitigation of the effects of near-by large-scale industry such as the mountain of containers stored by Associated British Ports at the entrance to Eling Creek, top left of the photograph.

A blot on the landscape at Eling – ABP’s unsightly storage for empty shipping containers.

Proposed English Coastal Path (South) progress report

The English Coastal Path (South) is part of the proposal by Natural England (NE) to achieve as full a coastal path as possible along the area bordering the Solent. It is part of the coastal path project which covers the whole of England.

In our last newsletter we set out the method and format for defining the path and the full text of our consultation comments on the important Highcliffe to Calshot section. This report brings the developments up to date although these are running later than expected. Progress is being made however, with more sections out to consultation.

The identification map above is published again for ease of reference:

Three sections have now been published and the consultation period is now complete, although as far as we are aware, there has been no final decision on these sections from the Secretary of State:

  • Section 1 – Highcliffe to Calshot
  • Section 5 – Portsmouth to South Hayling
  • Section 7 – East Head to Shoreham

Section 4 – Gosport to Portsmouth has now been published with consultation comments due by 15th August 2019 together with Section 2 – Calshot to Gosport with comments due by 11th September 2019.

Solent Protection Society (SPS) has responded to the Gosport to Portsmouth section and our comments are set out below. We will also be responding to the Calshot to Gosport section.

Section 6 – South Hayling to East Head is now expected to be published in October 2019 and finally the Isle of Wight section in February 2020… we shall see!

SPS is supportive of better access to the Solent shoreline. Our main concern is with the safeguarding of the many protected areas and sanctuaries for birds, wildlife and environmental habitat along our shores and the control of access to “spreading room”, that is the area between the path and the water.

Calshot to Gosport

The proposed route from Calshot to Gosport uses the Hythe ferry together with the ferry at the mouth of the Hamble river. This avoids the large Southampton docks industrial area though we feel it is a pity some of the western shore north of Hythe has been omitted. Along the River Hamble the north side of the river is difficult to access, the south side is more accessible, thus using the ferry is a sensible solution. SPS has asked what will happen if, in the future, the ferries cease to run and Natural England have stated that a review will be held by a new team in that event. The path on the eastern shore of Southampton Water diverts inland a little in a few places but the beach is still available where it is above high water. The path cannot officially transit the beach as part of its route.

Gosport to Portsmouth

Portchester Castle from Port Solent

The Gosport to Portsmouth route makes the best of a job made difficult by the large tracts of MOD land for which no access can be granted. There are a few miles of dreary inland road walking, but the stretch from Fareham Creek via Portchester Castle to Port Solent, is well worth exploring. South of the Naval Dockyard, the route follows the established Millennium Promenade, a fine route which explores the rich history of the old harbour waterfront. SPS is aware of a concern regarding access to the Camber Docks raised when the Land Rover/BAR development (now ‘Ineos Team UK’) was built in Old Portsmouth.

There is a long established public right of access to walk the perimeter of the Camber Docks which includes access to the memorial to the lost crew of the ‘Wilhelmina J’. We note that the preferred route clearly shows this, but we raised a concern that the draft wording could be interpreted by the current tenants on the site to prevent public access to the dockside for extended periods, rather than the brief interruptions for which the documented diversion is intended. We believe that most members of the public would wish to simply wait for a few minutes while a boat is craned in or out, resuming their walk once the activity is complete.

More detailed information on each section can be found be clicking this link.

The section maps are detailed and the text gives explanations about the various decisions taken along the proposed route. The full environmental appraisals are also available for each section.

Fawley New Town

View of the site from the west

In the Autumn 2018 issue of the Society’s Newsletter we reported on the proposal to build a new town at Fawley on Southampton Water. This article is an update of developments since then. This is perhaps the most important development on the shores of the Solent this century and as such it is receiving close scrutiny from The Solent Protection Society. The new small town would be built on the site of the Fawley Power Station, which was closed in 2013. This is a brown field site but it is surrounded by the New Forest National Park and a small part of the scheme would be on National Park land.

The developer, Fawley Waterside Ltd., applied to both New Forest District Council and to New Forest National Park in May 2019 for Outline Planning Approval. The two applications are being considered together. NFDC invited comments by 31 August. Full details of the Plans, responses by interested parties, and comments from official bodies including local authorities and government departments are to be found on the NFDC Planning department website: at the last count there were 406 documents. NFDC had originally hoped to make a determination by 31 August but need more time and have now agreed with the developers to an extension of the time to 15 January 2019. Even when NFDC have made their determination the scheme might need to be referred to the Secretary of State for a potential call-in.

Illustrative view of Fawley Waterside across Southampton Water

We, Solent Protection Society, submitted our response on 27 August. Of course we have concentrated on those aspects of the plan which directly affect the Solent, such as view from the sea, and possible effects of pollution of the sea and of the Solent air.  The full text of our response is reproduced here.

“Dear Sirs,

These comments are from the Solent Protection Society (SPS) which exists to protect the Solent and its tidal rivers and estuaries for future generations.  The comments are primarily directed at the element of the scheme within the control of NFDC however we have copied them to NFNP as that aspect of the scheme in the national park, while of less concern to SPS, is an integral part of the whole and does have some impact on the waterfront.

SPS is generally supportive of the planning policies laid down by both NFDC and NFNP, however, we are concerned that aspects of the proposals that front the waterside do not adequately meet some of those policies.

In particular:

  1. We consider that the size and scale of the buildings fronting the water, being much further forward than the former power station could be over dominant, with no landscape mitigation and will be unacceptable when viewed from Southampton Water. They do not sufficiently ‘scale down in density towards the water front’ as set out in policy ii a).
  2. We consider that the light pollution from these building will be to the detriment of the marine environment and have a far greater impact than the existing power station.
  3. We would expect to see the waterfront buildings set  further back with extensive tree planting in front to mitigate the impact and enhance the coastal margin, the coastal path and the proposed ‘Solent Promenade’.
  4. We would remind NFDC and NFNP that there is a real risk of storm water overflows from the proposed sewerage system and we would expect to see this fully mitigated with complete separation of storm and foul water and full storage capacity for foul water to prevent any storm discharge of foul water into Southampton Water or the Western Solent. Petrol interceptors to all roads and parking areas should be provided before discharge of storm water. Such storage capacity should not rely on Southern Water.
  5. We would expect to see regular monitoring reports on water quality adjoining outfalls and in the salt marshes as a legal condition of any approval with adequate penalties for any breach of EA standards and that this applies both during demolition and construction as well as in the future once the development is complete.
  6. We would expect any approval to condition by legal agreement any dredging activity and to ensure that there was beneficial use of dredging to replenish the salt marshes.
  7. While not of direct concern to SPS we note that the infrastructure of roads in particular will be seriously impacted by the size of this development and that more extensive works than those proposed will be needed if it is not to cause serious congestion and further pollution to the north.
  8. We would expect the scheme to include mitigation of climate change and for a substantial proportion of the development to be to Passive House standards.
  9. The proposal is likely to substantially increase the footfall on the coastal path and we would expect to see moneys from planning obligations directed to ensuring that the coastal margin and the many protected areas in the vicinity falling as spreading room, whether or not there is a Section 26 notice, are adequately protected by fencing to restrict both pedestrian and dog access in particular.
  10. We note the National Grid building on the waterfront is to remain which is a pity as it will assume a greater prominence and has no merit in the landscape. Planting in front of this would be of assistance in mitigating the impact.
  11. We have not been able to find a specific reference to the ‘view from the sea’ which is critical from the busy shipping lane of Southampton Water. It may be in the documents somewhere but we would expect to see a photomontage of the view from Southampton Water superimposed on the existing buildings and including the National Grid building and the landscape to the south. Only then will it be possible to really judge the scale and mass of the proposals.”

The Principal Development Management Officer of NFDC, Mr Ian Rayner, has written to Deloitte, the agent of Fawley Waterside Ltd, to set out the latest position of the Local Planning Authority on their application proposals, and has published his letter on the NFDC website. It is 12 pages long so we will not reproduce it here, but pick out the points which may be of most interest to SPS members:-

He says:

  1. we do need to have a clear understanding of the scheme’s viability”.
  2. “The south-east corner of block 11 extends very close to the harbour entrance and ought to have a greater setback.”
  3. “In my view, 3 of the landmark buildings are of particular concern. The 98 metre high tower would be a very significant building. It seems that the driver for the height of this landmark building is to provide a structure that is visible from both ends of the Solent. I don’t believe this should be the overriding driver for determining the height of this building. The key objective should be to design a landmark building of a scale that is appropriate to the new townscape and to its location on the edge of the National Park, which I think could be equally achieved by a lower building.”
  4. “The 49 metre high landmark building in the site’s north-west corner is set fairly close to the taller 98 metre high landmark building. We need to see clearer images of how this tower would work in proximity to the larger tower, but together I do feel that these 2 landmark buildings would present too dominant an edge to this part of the development.”
  5. “The 56 metre high crystal tower has been designed to reflect the glass end of the existing power station building. However, it has been confirmed that it would not be viable to rebuild the existing structure and that the proposed new building would therefore need to be built with new materials… I think this building, as proposed, is inappropriate.”
  6. “In the light of the Environment Agency’s response, we would ask you to clarify the detail behind the foul drainage proposals, and to confirm what discharge consents are being utilised for these works.”
  7. “As set out in Natural England’s response, you need to better demonstrate how nutrient neutrality will be secured. This a critical matter, and unless you can demonstrate that nutrient neutrality will be achieved, it will not be possible to grant planning permission.”
  8. “In their consultation response, our Environmental Health team have asked that you provide additional information in order to clarify the development’s potential impact on air quality, as well as to ensure that future occupants have an appropriate quality living environment. I would ask that you respond to the specific questions that have been raised.”
  9. Our Environmental Health team have also posed a number of questions relating to noise and lighting (aside from the noise concerns raised earlier in this letter). Again, I would ask that you provide additional information to address the concerns that have been raised.”

We believe that, if approved, this project is likely to take about 10 years to complete. We intend to keep members up to date by reporting on progress in future SPS newsletters and on the SPS website.

Eastney – Fraser Range development proposal

Solent Protection Society takes a close interest in the conservation of the natural heritage and historic assets of the Solent shoreline. In particular, we are concerned with safeguarding the views towards that shoreline by users of the Solent, a viewpoint not always given priority in planning applications.

The fortifications at the eastern end of Southsea seafront are of significant historical value, with Fort Cumberland a particular highlight, considered the most impressive piece of eighteenth century defensive architecture remaining in England. The context within which the fort is situated, on the low shingle spit at the entrance to Langstone Harbour, should be protected with any development in the vicinity suitably moderated.

SPS has objected to a plan to redevelop the former Fraser Range for housing, a site immediately to the south west of Fort Cumberland in this image from Google Earth. The existing buildings on the Fraser Range site date from more recent occupation of the land by the Ministry of Defence and while we note that there have been valid objections raised by others on grounds of twentieth century archaeological significance, our objection to this proposal is based on the adverse impact on the views towards Fort Cumberland from the sea.

The plans show five significant buildings immediately fronting the sea, two of which (Building 2 and Building 5) are redevelopment of existing structures, while Buildings 3, 4 and 6 are completely new developments.

Building 2 and Building 5 are existing two storey structures with flat roofing which includes small covered service access structures. We do not consider that these existing roof structures provide a precedent for the addition of a full third storey that the developer has added to each of these buildings.

While the increased height of Buildings 2 and 5 alone represents an unacceptable impact on the view from the sea, the new structures, Buildings 3, 4 and 6, are significantly more damaging to the skyline. All three of the buildings are new, and buildings 4 and 6 are drawn at a full five storeys in height, dwarfing the two redeveloped buildings and obliterating the view of Fort Cumberland from the south west.

Given the potential for future development of the south east corner of Portsea Island as an important destination for cultural tourism within the city, in our response to the planning application we have urged Portsmouth City Council to reject this development and safeguard the heritage context of the Eastney spit.

This is a particularly pertinent example of Solent Protection Society’s commitments both to the preservation of the Solent area’s cultural heritage and the maintenance of the view of the Solent shoreline from the sea.

Local Planning Authorities – Development policy for new homes

The local planning authorities bordering the Solent are publishing development policies designed to meet government set targets for the construction of new homes for the years ahead. At first sight this seems an unlikely topic for the Solent Protection Society to dwell upon but it is of relevance to anyone interested in the future of the region.

Development at the southern edge of Milford taken on the road from Hurst Spit.

Of particular importance to the Society, is the consequential impact of new development on our shores, estuaries and river banks? Certainly some, such as that at Fawley, will, but this replaces an already heavily developed shoreline. In other cases development may be some way from the coast but will be clearly visible from the water. We have taken up with various planning authorities around the Solent the potential damage caused to the seascape by proposed new building development and are pleased to see that some authorities are exercising control on this point within their latest development plans. Can we hope that all authorities will follow this lead?

The wider Solent must maintain its attraction as a place to live and work as well as continuing as a successful destination for holiday makers and yachtsmen. To this end development plans should have particular regard to the visual impact of new buildings on the approaches to the towns and villages surrounding the Solent.

Secondly, dare we make the point that the number of new homes proposed is going to increase demand for more school places as well as hospital beds and medical practices. Can the existing facilities cope? If not where are the additional buildings to be put?

These are matters for the authorities to consider. From Solent Protection’s position we will continue to monitor the proposals and endeavour to ensure that that the Solent and its environment are protected for future generations.

Fawley Waterside and Calshot development plans

A major development is being planned on the site of the Fawley Power Station by a new company, Fawley Waterside Ltd. The company has ambitious plans to create a new small model town, with echoes of Poundbury, the prettiest New Forest Villages, and Old Lymington, with about 1500 homes. There will be a marina accessible from the Solent 24/7. They also plan to build an Hotel, a Yacht Club, shops and restaurants and marine industries, with the objective of creating more than 2000 jobs in the new community.

Proposed site plan for Fawley Waterside and Calshot Village

Work has already started on demolition of the old power station structures and the iconic chimney, which can be seen from most of the Solent, is to be removed. In its place, Fawley Waterside propose to construct a glass tower 100m high, subject to grant of approval for an outline planning application yet to be submitted. We will bring you details of this application when available.

Artist impression of the ‘canal side’ development and glass tower

The same development company are also planning to build 30 new homes in nearby Calshot village. Both projects are described in brochures published by Fawley Waterside Ltd., all of which can be accessed and downloaded by selecting this link. The link will take you to an index page for all documents published by the developer. Their recently published Calshot Village Exhibition brochure provides a high level summary of both projects.

Solent Protection Society is keeping a very close eye on these projects: we aim to influence the plans to help to achieve a development of which the Solent community can be proud and which enhances our environment.

Solent Protection Society submits evidence to the Landscape Review

In November 2018 the Government called for evidence to be submitted to the independent review of England’s National Parks (NPs) and Areas of Outstanding Natural Beauty (AONBs). This is a brief summary of some of the key points SPS has made. The full submission can be found on the SPS website by selecting this link.

The Solent  Protection Society is primarily concerned with the shoreline and the view from the sea as it affects the National Parks, AONBs and the tidal river estuaries that make up the Solent from the Needles to Selsey Bill. We are concerned with the economic, social, leisure and environmental well-being of the Solent not just its appearance. Many of these aspects are interdependent and sometimes in conflict. The New Forest National Park and the AONBs on the north shore of the Isle of Wight and  in Chichester Harbour play a crucial role in safeguarding this special place and seascape.

The AONBs, however, hold less clout in the planning system than the National Park and in our view need strengthening to offset the pressure from development, particularly housing targets. The view from the sea is often not appreciated as much as it should be, particularly when this may be the only view that is easily gained of a densely wooded AONB, such as the north east shore of the Isle of Wight .

We have a concern that incremental enlargement of small scale houses and chalets or new builds which individually my not be great but cumulatively start to change the landscape is not sufficiently appreciated or controlled by local planning authorities. The effect on the AONB should have a greater priority in considering such applications.

In addition we would like to see the introduction of smaller area AONBs associated  with river valleys when viewed from the river or the opposite bank before such areas of important natural landscape are lost such as on the Hamble or the western shore of Southampton Water.

Finally Marine Plans in particular deliberately overlap land based plans and have a number of policies that have to be taken into account when considering changes to the landscape.  The difficulty with Marine Plans is deciding what weight to give to each policy in a particular circumstance. SPS considers that where NPs and  AONBs are concerned the protection of the landscape and seascape should be of a higher weighting and this needs to be endorsed by land based planning authorities and the Marine Management Organization.

Annex to the report on changes to the South Marine Plan

Following on from our report on the South Marine Plan becoming law, we have made further analysis of the detail.  In brief the changes on which SPS may have had some influence would seem to be:

  1. Vision amended to be more relevant to SMP area. (Vision)
  2. More information on the Coastal Concordant. This may relate to our concern that local authority boundaries in the Solent did not meet up. (General considerations)
  3. Additional text on monitoring. (We had suggested 3 years was too frequent)
  4. Wording on aquaculture to define it as ‘sustainable’ not just any aquaculture. (Obj 1)
  5. No restriction on dredging for ports and harbours. We were concerned there should be no extraction in the Solent. (Obj 1)
  6. Wording to make clear that land based infrastructure must be ‘appropriate’. (Obj 2)
  7. Wording on employment to make clear the skills and activities to be supported. (Obj 4)
  8. The words ‘enhance and promote’ related to Marine Protected Areas. We had been concerned that these do not displace traditional use so may be the reverse of our comment, though from an ecological point of view we would support it. (Obj 5)
  9. Climate change defined as ‘greenhouse gas emissions.’ We had asked for clarification in the technical annex. (Obj 7)
  10. We had asked for the view from the sea to be specifically stated however the wording has not been changed. (Obj 9)
  11. MPAs. Wording added to ‘enhance and promote’ and to ensure boundaries can be changed until such time as all Marine Conservation Zones are confirmed. (Obj 10)
  12. Reference to the government’s litter strategy added. (Obj 11)
  13. Some ‘enhance’ text added on biodiversity though no specific mention of salt marshes as we had suggested. (Obj 12)
  14. Support for re-use of material. (Obj 12)
  15. More emphasis on water quality and moved to be under Obj 11 to add weight. (Obj 12)
  16. More strength and clarification given on the use of the hierarchical format of a) to c) or d). for each policy. We were concerned that the weighting appeared equal and in certain cases considered more emphasis should be given to avoid.

The South Marine Plan finally becomes law

In July 2018 the government finally approved the draft South Marine Plan (SMP) on which The Solent Protection Society (SPS) and many others had commented in early 2017 and which was covered in last year’s newsletter.1.1 South Marine Plan PHOTO of Southampton Docks

With the final plan, the Marine Management Organisation also published a Modifications report, setting out the changes that had been made in the light of the comments made.

Overall, as expected, there has been no significant change to the 12 main objectives or the 50+ individual policies. There has, however, been a change in emphasis or clarification on about 20 of the policies and on 7 of the general principles such as the Vision and the relationship to land based plans.

Eighty one organisations or individuals commented, generating over 1500 comments. Of these 81 organisations, some 50% came from 21 local authorities, 12 Ports and Shipping and 9 NGOs. We assume SPS was counted as an NGO but no breakdown is given.

We were asked to agree, or agree with comment, or disagree, with the 75 questions asked about the objectives and policies. Overall the percentage of respondents answering yes, no or no comment showed 58% agreed, 18% agreed subject to comment, 6% disagreed and 18 % gave no response.

In SPS’s case we agreed with 43% of the policies and commented on 57%. We did not disagree with any, nor did we not respond to any question.

This perhaps reflects the fact SPS has a broad range of interests in the SMP area, whereas many organisations are from a particular sector and focus. For example, referring to the second reference below, it is not clear exactly what the pie chart is showing… is it the % of respondents or the % of questions answered in a particular way.  So did we have any influence?

It is difficult to say as there is no direct correlation and the modifications report does not show the exact changes to wording on each policy. This requires a detailed-reading of the final Plan itself and the Technical Annex.

We had sought to make the vision more relevant to the Solent area and while supporting aquaculture we did not want a free for all. In both cases there have been changes of emphasis.

Other policies on which we may have helped to get a change in emphasis related to land based infrastructure, support for small scale marine industries, litter prevention, bio diversity and water quality.

The South Marine Plan is now an important consideration for both Marine Licence applications and land-based planning applications on the coastline of the UK. Any application must be judged against the policies in the plan and if it cannot comply fully, must demonstrate how it mitigates the impact. If this is insufficient then it is likely to be refused.

Judgement on Marine Licence applications falls to the Marine Management Organisation (MMO) in consultation with various statutory bodies and government departments. The public can also comment, although the process of finding out about applications is not as easy as it should be.

Within its area of concern SPS now monitors all applications monthly and more information can be found elsewhere on this site.

The South Marine Plan can be found at this link.

The Modifications report can be viewed by selecting this link.