Delivered by . Sian Waters Programme Officer PCC LDP Examination County Hall, Freemans Way, Haverfordwest, Pembrokeshire SA61 1TP.

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1 5 High Street Cardiff CF10 1PZ Delivered by T: F: Sian Waters Programme Officer PCC LDP Examination County Hall, Freemans Way, Haverfordwest, Pembrokeshire SA61 1TP Our ref: RP/MILT2003/LDP Your ref: E: Dear Sian PCC LDP EXAMINATION MHPA POSITION Following my appearance at the LDP Examination Hearing Sessions 5, 6 and 10 on behalf of my client Milford Haven Port Authority (MHPA), I wanted to clarify a number of points to the Inspector which have arisen mainly in response to Matters Arising Changes (MACs) produced by Pembrokeshire County Council (PCC). I understand that it is at the Inspector s discretion whether to consider these further comments, however I would hope they are accepted positively, given that the MACs propose changes to the LDP policies and explanation which affect the MHPA s submitted statements on its requested changes to the LDP to achieve soundness. Part of the MHPA case was to request specific allocations at Milford Dock (Mixed Use to include retail) and Pembroke Dockyard (for employment) and it requested the selective deletion of Policy SP 2 (from Milford Dock) which could cause confusion in its original form.of words and explanation. During Session 5, PCC agreed that Policy SP 2 should be expanded to reflect its position that the policy, as spatially defined by Focused Changes, is not intended to be exclusive to port and energy uses and other uses would also be appropriate. Revised wording by PCC to Policy SP 2 to reflect this position was awaited whilst the other Hearing Sessions progressed. During the Hearing Session 6, PCC introduced a MAC to Policy GN.7 Mixed Uses. This had the potential to undermine the MHPA position for inclusion of Milford Dock under this policy, and the Inspector allowed me to consider the policy overnight and comment on it at the Hearing Session 10 on Retail. B E L F A S T B I R M I N G H A M B R I S T O L C A R D I F F E D I N B U R G H G L A S G O W L E E D S L O N D O N M A N C H E S T E R S O U T H A M P T O N Registered in England Turley Associates Limited no Registered office: 1 New York Street, Manchester, M1 4HD

2 2 Given this convoluted and overlapping process of PCC changes to Policies SP 2 and GN.7, MHPA wants the Inspector to be clear on its position in light of these changes should he choose to accept them, and to understand its further requested additions to make them sound. MHPA submitted the following suggested amended/additional wording (shown in bold and yellow highlight below) to the Inspector at Hearing Session 6, 05/09/12 in respect of Policy GN.7: GN.7 Mixed-Use Allocations The following sites are allocated for mixed-use developments, within which a significant considerable proportion of the development shall be employment related: Mixed-Use Site Name Area (Ha) MXU/040/01 Haverfordwest Old Hakin Road 1.31 MXU/048/01 Johnston Arnold s Yard 5.47 MXU/086/01 Hubberston Dale Road 4.64 MXU/086/02 Milford Haven Milford Dock Mixed-use development will combine employment and other potentially compatible uses (such as residential, leisure and community facilities) on the same site. It may include live-work units, but might alternatively include a mix of land use(s) within a single site. The purpose of this policy is two-fold firstly, by providing a range of uses, it will encourage sustainable and thriving communities where people can undertake more than one activity within a single site, such as living, working and recreation. Secondly, it may stimulate investment in employment development in conjunction with the development of residential or other forms of development on the site. The allocations of this policy will contribute towards the supply of suitable employment land across the Plan area, helping to meet the requirements of paragraph of PPW. 6.37a To ensure that pproposals for on each mixed-use site are required to include a significant proportion of employment uses, Supplementary Planning Guidance (SPG) will be prepared for each site, taking into account and demonstrating viability issues. and

3 3 also providing an indicative mix of uses to inform the submission of any subsequent planning application. The SPG would be subject to local consultation in the normal manner. The site at Milford Dock is differentiated because it is centrally located within a hub town, previously developed, accessible and already includes a range of mixeduses. The allocation of Milford Dock reflects emerging master planning work for the site by Milford Haven Port Authority to create a mixed-use visitor destination development of further residential, employment, port, leisure, community, retail and tourist uses. This development has the potential to contribute positively to regeneration in Milford Haven town centre and the wider area. The impact of the retail elements of the proposals for Milford Dock will be considered against the retail policies of this plan. The proportion of employment uses required on this site will be balanced against the need to achieve a broad mix of acceptable uses for the destination development proposed. 6.37b Where applications come forward on mixed use sites in advance of SPG being adopted the proposals will be required to demonstrate the scheme will provide considerable employment land unless economic viability considerations justify a more modest provision. Planning conditions or legal obligations will be used to ensure that schemes approved under this policy deliver the expectedenvisaged proportion of employment development element. Where employment uses on mixed-use sites (including those within a live-work unit) are proposed for change to another use, the requirements of policy GN.8 must be satisfied. MHPA is therefore still seeking the allocation of Milford Dock under Policy GN.7 as amended by our changes above, which would allow Milford Dock to come forward with a range of uses (as per the emerging master plan) to include retail and contribute to the transforming change to the town and town centre as envisaged in the LDP evidence base. In terms of Policy SP 2, PCC provided me with its draft wording on Monday 10th September and asked for comments. MHPA welcomes the PCC amendments to the explanation to Policy SP 2 but considers that it requires further minor additional wording. In addition, at present the spatial definition of Policy SP 2 extends, as far as we can see, only up to the western edge of Nelson Quay at Milford Dock and therefore excludes Nelson Quay and the boatyards to the east of Nelson Quay. Our evidence has requested that the allocation under Policy GN.7 includes the whole of Milford Dock including these boat yards, and notwithstanding this, the spatial definition of Policy SP 2 should be extended to the whole of Milford Dock. There is no logic to the exclusion of the boatyards which are in fact the area to which the LDP evidence base implicitly directs the linkages between Milford Haven town centre and the dock/marina. We very much welcome the response for explicit reference to the development potential at Pembroke Dockyard. I attach a Google earth marked up aerial photograph illustrating the key areas of development potential and these have respective site areas as follows:

4 4 Site A Site B Site C Site D Site E Site F Total Ha (3.04 acres) Ha (1.04 acres) Ha (3.04 acres) Ha (3.41 acres) Ha (1.75 acres) Ha (5.86 cares) Ha (18.14 acres) In addition, there are a number of smaller sites around Pembroke Dockyard that will continue to provide development opportunities and these amount to a further 1 ha approximately. This confirms the position I set out at Hearing Session 6. In the context of the above, our comments on the MAC for the SP 2 explanatory text are shown (in bold and yellow highlight below) in the text below: 5.10 Milford Haven Port already hosts major energy-related installations and infrastructure and there is potential to further develop this role. It also provides a ferry terminal, at Pembroke Dock, providing freight and passenger connections to the Republic of Ireland. As well as the ferry terminal, there are also extensive areas of employment land at Pembroke Dockyard, together with smaller areas used for other purposes. Within Pembroke Dockyard, discreet areas of land are available for re-use for employment and/or port-related purposes. Additionally In the case of both Pembroke Dockyard and Milford Dock, re-configuration of areas currently in use may be proposed in conjunction with transformative development proposals. Within Milford Dock, such proposals may include employment, port related and mixed-use (including tourist, retail and leisure uses) development. On the basis of the above changes by MHPA, it would be happy for the SP 2 spatial definition to continue to apply to Milford Dock (as a whole to include the existing boatyards) and to overlay the GN.7 mixed use allocation it has requested; and for it to continue to apply to Pembroke Dockyard and to overlay an employment allocation which recognises the importance of this site in the Hub town. I would be grateful for your confirmation that this letter has been passed to the Inspector. Yours sincerely Rob Peters Office Director

5 5 CC: Jeff Teague, MHPA Kevin Hobbs, MHPA

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