APPENDIX E

Notes on REVISED submission (12 June 2003) by Harrison Trust on Cowes SDF.

Paragraph numbers relate to Document received 12/6/03.from Ashwell Property Group and other consultants on behalf of the Harrison Trust.

1.2 Note priority as developer of land. But acknowledging proper planning principles. The GBR Challenge base is an appropriate occupier and accords with the SDF Vision.

1.3 If other teams are attracted to the locality where will they locate if waterfront sites are developed with housing.

1.4 It is noted that other locations could meet the GBR Challenge requirement for waterside land.

1.5 A copy of the consultants brief from the Harrison Trust (or a summary) would be helpful.

1.6 There is no case made as to which policies of the UDP they refer to. What about E7.

1.7 NOTE the GPG they refer to and rely heavily upon relates specifically to detailed site development briefs. The consideration of development should be within the plan lead system, in this case the UDP.

1.9 The occupation of the site by the GBR Challenge would be entirely consistent with the SDF. I don’t believe the suggested failure of sustainability suggestion is correct.

What do the Harrison Trust proposals actually guarantee?

2.2 Typo DFM site FBM?

2.3 The land is a former shipbuilding and current industrial site so some contamination could be expected. No details of type or extent

2.4 What are current uses as stated in 2.1? It is in active use for boat building and also the production of turbine blades which are imported and exported to the site by water.

2.5 see 2.3

2.6 What proportion of users or property are marine related, details? As per 2.1

2.9 Why are cost abnormal for a waterside industrial site? Flood risk reduction works will be more extensive and costly to provide level of protection for residential use than other uses. PPG is that areas at risk should not be considered for residential development. Other sites are available for residential development within the Island.

Why is a mixed use scheme required in the wider context of Cowes harbour? The SDF suggest that the majority of the site be retained for marine related business in accordance with the development plan policy but that there is the opportunity for mixed use in the northern part of the site to complement the linking of Cowes and East Cowes town centres

2.10 Why did the trust not set out alternative development/regeneration options other than the mixed use approach with substantial residential element? (the ratio of mixes was not varied only the locations in the ‘options’ tested.)

3.1 OK

3.2 OK

3.3 GPG quoted and heavily relied on in this submission related to the preparation of site specific briefs for adoption as SPG. The SDF is not at this stage.

3.4 We accept SPG should be clear and believe that the vision and questions are clear.

3.5 The in combination effects of all proposals will need testing and this will apply equally to the Harrison Trust Proposals to modify the estuary by reclaim / dredging and quay wall work.

3.6 OK

3.7 The reference is a step change in the economy and investment, not change for change sake. The SDF is seeking an employment lead regeneration.

4.1 GPG does not relate to SDF type SPG. Examples are all site specific issues. Note that they are not considered as abnormal and could equally include floodrisk.

4.2 and 4.9 The presence of European and International Nature Conservation Designations dictates this approach and is realistic.

4.3 – 4.8 It is recognised that site specific work will be required as proposals are developed to deliver the strategy.

4.14 can but might not. Mixed use developments may be appropriate in some locations and indeed are suggested for the northern part of the Harrison Trust Land but this does not mean that every site should be developed as a mixed use development. Mixing some uses with residential development can impose additional constraints on the viability of employment.

4.16 Potentially high values of waterfront locations relate to the enhanced values achievable if the sites are available for residential development. The Harrison Trust Land is currently in industrial and employment use.

4.17 in some instances .. The basis for the policy and specific instances where it might be applicable are listed in UDP para 8.13. Note from meeting 2 December 2002 between Isle of Wight Council Planners and Harrison Trust consultants records that – PW from Harrisons consultants concluded that E4 was not appropriate for application to their site or proposals. The housing was not enabling development but part of a mixed use scheme.

4.18 Reference to the Harrison Trust proposals……FOR THE GBR CHALLENGE and visitor centre and public access. It refers to deep water access. It recognizes a number of issues which may have significant cost implications, and the possible need for enabling or mixed uses.

4.19 para 4.26 of the SDF refers to ‘Proposals being advanced by individual land owners for sites within the study area for example the GBR Challenge/Harrison Trust and that they may require an element of residential development to cross fund other elements of their proposals. It also refers to active ground floor uses. The SDF reflects this in that part of the Harrison site falls within Zone 1. The preceding sentence to that quoted from the letter in appendix 4 about retaining employment land with deep water frontage is ignored.

Conclusions do not reflect opportunities to look at wider than single site opportunities to cross subsidise development. The Harrison site is split between zone 1 with mixed uses and zone 2 for marine business. The letter refers to the need to protect land for employment from other uses and the need to ensure that employment sites with access to deep water frontage are protected for uses which need access to deep water. The letter was written before the wider opportunities arising through Project Cowes were identified.

5.3 note ‘ uses promoted by the brief’

5.4 site specific

5.5 site specific again. ‘where specialist advice included’ see section 6.2 plus SDF acknowledges further specialist work is needed eg understanding hydrology of estuary and the in combination effects of .

5.6 but goes on to say ‘but planning briefs should not always defer to the local property market’

5.8 – 5.13 Current snapshot of demand does not indicate longer term demand up to at least 2011. Nor does it take account of potential demand arising from the marketing of Project Cowes. The letter quoted (7^th May 2003) post dates SDF study (March 2003). It reflects that demand will change over time and that without the availability of sites opportunities to attract new investment may be lost as it has been in the past.

The Isle of Wight Economic Partnership has highlighted proven demand for waterside sites both from our own indigenous companies and from potential inward investors. The demand for the available land assets of the Project Cowes area are from a variety of different types of companies in different sectors, not just marine sectors. It should be noted however that demand for larger waterside sites is generally from marine companies or companies involved in developing some product lines for use in the marine sector. There is also demand and a need for smaller key sites to be retained for marine leisure, events and tourism.

These levels of demand are being experienced, at present with very limited marketing or promotion of commercial development opportunities or inward investment packages. As Project Cowes gathers momentum more marketing and promotion, budgets allowing, will be undertaken, which may engender greater levels of demand for employment sites and commercial property than experienced at present. This is an important point and has to be fully considered whilst considering future demand for certain types of sites and land assets in the Medina Valley. Left to market forces assets of the Island will be increasingly developed for other uses than employment.

5.10 Information relating to individual companies may be commercially sensitive or confidential and given in confidence by IW Partnership rather than by Project Cowes.

5.11 Some requirements for services may be generated from the wider Solent area rather than just from Island markets. The Island should be in a strong position to provide the facilities to meet those demands. PPG 20 para 2.9 notes that in the coastal zone development plan policies should normally not provide for development which does not require a coastal location. Housing does not require a waterfront location.

5.12 It is not clear why these assumptions have been made other than to minimise potential demand for waterfront sites.

5.13 These are opportunities to attract companies/employment/investment into the Island form other Solent Locations. They may be specifically attracted to Cowes due to GBR challenge which is cited as one of the benefits from the GBR Challenge proposals. Cowes is the premier location of the Island for marine related employers.

5.17 Chapter 8 of the UDP acknowledges that there is more land allocated for employment purposes than indicated by past build out rates but that this allows a choice of sites and ensures that land shortages will not prejudice appropriate economic development. It is not the case that housing will be needed to match the job creating potential of employment land. The UDP meets the Regional housing requirements.

Conclusion (un numbered) Even with their conclusion that demand is lower the best land should be prioritised where there are special physical requirements. The best deep water access site in Cowes Harbour is the Harrison Trust land.

6.3 The ferry routes are between Cowes/E.Cowes and Southampton. (not Portsmouth as stated) and operated by Red Funnel. Times quoted are for Fishbourne to Portsmouth Wightlink Ferry. The fast service uses Red Jet Cats not hydrofoils.

6.4 – 6.6 OK except that the Floating Bridge does carry cars and light vans.

6.7 Buildings? Otherwise OK and this is why the SDF is suggesting the relocation of the Ferry terminal.

6.8 – 6.10 OK

6.11 …nor in Zone 3 other than at Kingston and none in zone 4. The area has significant and adequate housing allocations in the UDP and SDF are set away from the waterfront other than that at East Cowes Marina which was an historic extant consent. Housing does not need a waterfront location. It is not suggested that the regeneration of the area should be base on becoming a dormitory area for Southampton. This in itself is not sustainable.

6.12 and 6.13 Part of the case made by the Harrison Trust for the need to purchase the JS Whites site was that it was needed to provide a new access from Medina Road for industrial traffic to avoid existing residential areas (Which had historically had heavy industrial traffic using them). Also the benefits of employment uses on the waterfront are that they can import and export large and heavy goods directly by water. Cowes needs to be served by commercial traffic for retailing, house removals etc. Flawed analysis and conclusion. Residential development already exists which was built primarily for those employed in the waterfront sites. The wider area is already a mixed use area.

7.1 OK the SDF is consistent with the UDP.

7.2 - 7.3 Harrison Trust have been made aware from the start of the employment policies of the UDP. The SPG has now been through two specific public consultation stages as well as the background from the aims of the Island’s Community Strategy, Corporate Plan and UDP with their consultation processes.

7.4 see earlier comments and preceding sentence in the letter to that quoted.

7.5 and 7.6 Meetings with the Harrison Trust agents have taken place with IW Economic Partnership or Planning on ten occasions between September 2002 and May 2003 as well as their attendance at Stakeholder presentations.

7.7 Environment Agency have been involved in process and consulted and were party to workshop sessions with English Nature.

7.8 – 7.9 A list of meetings, documentation, exhibitions, questionnaires and result has been prepared.

7.12 – 7.13 Harrison trust have only presented 2 basic options of a variation on a theme of a large area for housing and the GBR challenge site and visitor centre. Despite the claimed consultation and evolution of the scheme the current proposal for the site is basically the same as their originally presented preferred option.

8.1 Why is the issue of flood protection of a coastal site seen as abnormal, why is the contamination of an industrial and shipbuilding site seen as abnormal, both are what would be expected and presumably reflected in land values and price of purchase. This only become as significant due to the Harrison Trust proposed change of use and function of these areas for residential development. The costs are noted and recognized in 6.44 but not as being abnormal.

8.3 What prominent link from East Cowes? Many of the points are matters of detail which have not been demonstrated.

8.4 No it doesn’t, read 6.22, but the presence of GBR challenge could be of benefit to the image of the Project Cowes area.

8.5 key words are ‘where appropriate’

8.6 Ocean Village a poor example of what is offered other than high mooring costs and premium house prices. Previous public space and shopping have been redeveloped for additional housing since its opening and the vibrant pubic asset promised has not been fulfilled. The waterside activity such as boat trips or as a centre for events bears no relationship to the availability of housing on the site. Housing residents could object to the disruption and nuisance created by events.

8.8 SDF looks across a number of sites to deliver the range of uses, it does not suggest that every site identified should each have a mix of all the uses. The quoted paragraph concludes with “We have looked at ways of combining this economic and employment growth whilst reconciling the pressure of residential development.”

8.9 ‘most efficient use’ for what purpose, land value or employment is the question.

8.10 – 8.11 Their proposal only opens the waterfront in front and separated from the proposed residential uses NB the NB.

8.12 The SDF recognizes this by the Zone 1 allocation of part of the Harrison site. There is no evidence to support the contention that the current proposal is the only viable option.

8.15 Where will the additional business’ and other teams which may be attracted to Cowes because of GBR Challenge be located.

8.16 maximise potential for what? Land value?

8.17 OK

8.18 Question if outline will provide sufficient detail. EIA will need to provide information for possible Appropriate Assessment. Will it include in combination effects on the cSAC which the SDF recognises will need additional research as suggested by ABPmer to be required Note ABPmer are consultants who have been employed on the Medina Sustainability studies and as advisors to project Cowes/EN and EA re required work to understand environmental impacts.

8.19 Possible bad neighbour issues by importing residential uses to an employment area, see UDP policy G10.

8.20 Could GBR Challenge operate without commercial road traffic? See earlier paras 6.12 and 6.13. Should GBR therefore be in East Cowes?

8.21 enabling development could come from cross site development considerations. Harrison Trust maintained that policy E4 was not relevant to their proposals (Meeting 2/12/02) and that they were relying on exceptions to policy E3. ie. that their land was a redundant site.

8.22. …….through the GBR Challenge and centre of excellence for sailing aspects and not as a housing site.

8.23 Some of the abnormal cost will be due to the higher standards required by the introduction of residential uses.

8.24 Value of site relates to potential use and site conditions. Value should not reflect residential values as it is a current employment site.

8.25 Their proposals for the site do not satisfy UDP policies.

9.1 Various point already addressed above. Most are points of detail which will be taken into consideration as briefs and proposals are worked up for individual sites or areas. This does not preclude the establishment of an overall strategy and approach to the regeneration of the Project Cowes area.

9.2 There is evidence of current demand for waterfront sites in Cowes and East Cowes from employers seeking to invest in the Island. This is a snapshot when the longer term potential for attracting additional marine related employment to waterfront areas is seen as being required to support the sport and leisure activities of the area.

9.4 The vehicle ferry terminal at East Cowes serves the Island and not just East Cowes. The amalgamation of land by the Harrison Trust was stated to be partly to allow the creation of freight road access to the waterfront to avoid the residential areas.

9.5 The Council have Not invited a mixed land use proposal for the site and in any case the proportion of the mix has not been discussed.

The Harrison Trust have not made representations in the earlier consultation rounds. In fact there has been some confusion in the publics mind as to whether their proposals form part of Project Cowes proposals through their own consultations.

9.6 Harrison Trust Proposals

Adopted UDP (not Local Plan)

‘Opportunity to achieve 50% employment’ could also be said to be 50% loss of employment land to provide housing which does not need a waterside location.

Appendix 4 title page refers to letter dated 23/10/03 which should read 23/10/01.

Appendix 5 appears to relate entirely on unexplained assumptions to reach the conclusions used in the report. Not clear why Yacht construction and yacht manufacture are not seen as employers where waterfront location required. The easiest way to provide waterfront access is to have a waterfront location. Does GBR challenge fit into category of only needing waterfront access? Again Housing does not require a waterfront location.