Pembroke Dock planning application submission deadline 22 January 2021
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) – Pembroke Dockyard, The Dockyard, Pembroke Dock, SA72 6TE.
The NDS has objected to this planning application, submitted by Milford Haven Port Authority (MHPA), which would infill listed structures and construct 40m high buildings in the historic Pembroke Royal Dockyard. We consider that these proposals would cause substantial harm to the significance of the Pembroke Dock Conservation Area and the loss of many Grade II and II* listed heritage assets. We contend that the arguments presented for this scheme do not justify such harm and that insufficient evidence has been presented for consideration of alternative brownfield sites. The fact that this is an outline planning application also carries further, as yet unspecified, risks to the historic assets. For these reasons we call on the Local Planning Authority to refuse planning permission.
The proposed scheme would severely damage Pembroke Dock Conservation Area and crucial listed buildings. The Grade II* Graving Dock would be infilled and partially built over, the Grade II Timber Pond infilled and built over, and the Grade II Building Slips Nos 1 and 2 partially demolished and removed. It would also be detrimental to the setting of the adjacent Grade II Carr Jetty, which adds to the group value of these threatened structures at Pembroke Dockyard.
These structures are the last and most important features of the magnificent and unique assemblage of thirteen slips, graving dock and timber pond constructed and functioning 1809–1926. Pembroke Dock specialised in building warships during the transition from wood to iron and steel, sail to steam and turbines. While the eastern slips were sacrificed in 1979 for the Irish ferry terminal and the deep-water berth Quay 1, we now live in a more responsible era, when significant community assets merit planning protection.
The Royal Dockyard established at Pembroke Dock from 1809 was entirely unique: the only one in Wales, the only one on the west coast of Britain, and the only one created solely as a shipbuilding facility. It built over 260 warships for the Royal Navy, including many of the most prestigious warships of the nineteenth and early twentieth centuries, as well as five royal yachts. Many of these vessels were built on the two large slipways at the western end of the yard which are threatened by the current development proposal.
After the closure of the dockyard in 1926 the facilities were turned over to the Royal Air Force, and for some time the former dockyard site was the largest flying boat base in the world, its aircraft playing a significant role in the Battle of the Atlantic. The Royal Marine, and later Army, forts and garrisons established to defend Pembroke Dockyard – many of which were maintained well into current memory – have combined with the Royal Navy and Royal Air Force to give the area a rich military character and flavour. The Dockyard represents the core of this heritage.
The Royal Dockyard was the reason for the establishment of the town of Pembroke Dock; without the former, the latter would not exist. The dockyard brought an entirely new workforce to the area, many of whom were originally from the west of England and brought their families with them, giving the town and wider area its unique demographic and West Country or Cornish surnames.
NDS Criteria for Objecting
- Destruction (demolition/infilling) of the listed structures – The Grade II* Graving Dock would be infilled and partially built over, the Grade II Timber Pond infilled and built over, and the Grade II Building Slips Nos 1 and 2 partially demolished and removed.
- Depletion of the national stock of historic dockyard features – intact timber ponds are nationally very rare. The example at Pembroke Dock survives intact and is especially fine, with an additional function as a tidal reservoir to speed up the filling of the dry dock. It is therefore a matter of concern that this will be effectively destroyed, as there is no evidence that such a process has ever been successfully reversed. Instead, this historic group of listed structures could become the authentic core of sustainable placemaking.
- Damage to the legibility of the dockyard – The dockyard, which occupies historic vistas around the Haven, will no longer be seen. The group of three surviving slipways seen on Google Earth, together with the associated dry dock and timber pond, are a remarkable group which represent the heart of the historic dockyard and, if made publicly accessible, would immensely lift the dockyard’s importance in the eyes of the public, with great tourist potential, and also provide context for the many listed dockyard buildings that survive further east.
- Disregard for Planning Policy Wales (Edition 10, 2018) and the principles of the Pembroke Dock Conservation Area Character Appraisal and Management Plan (2017) – These state that there should be a general presumption in favour of the preservation or enhancement of a listed building and a conservation area and their settings. For any development proposal, the most important consideration is the statutory requirement to preserve buildings, their settings and any features of special architectural or historic interest.
- Level of harm to the historic environment versus public benefit is not demonstrated – There is insufficient evidence that MHPA has evaluated other possible sites around the Haven. The NDS accepts that improving Pembroke Dock employment is desirable, but how many of the new jobs proposed by this scheme will be for locals, and how many for companies from further afield and even overseas? Where is the evidence for local jobs? Moreover, by rejecting the viability of heritage to drive economic and social benefit to the community MHPA ignores economic evidence from other dockyard towns such as Portsmouth (£610.3 million p.a. to the local economy) and Chatham (£4.54 million p.a. in the Medway and Kent economies) from tourism and business.
Despite its Welsh significance, the heritage of Pembroke Dockyard and its surroundings has arguably never been treated with the respect it deserves and has never been comprehensively interpreted in ways accessible to the public.
The NDS views this application as utterly negating existing policies to conserve the listed dock, timber pond and slips which signify the origins of its community. The Society urges that an alternative site in the area be found for the proposed marine engineering facilities and a fresh lens be directed at interpreting and conserving Pembroke Dockyard’s remaining heritage.
As highlighted within the above criteria, this application fails to comply with local and national planning policies for the protection of Pembrokeshire’s historic environment, and the NDS calls upon the LPA to refuse planning permission.
Dr Ann Coats
21 January 2021