Comments on representations from PD Ports, Logistics and Shipping on the Project Cowes consultation re Medina Wharf, Artic Road Cowes.
The letter describes the Medina Wharf site as having the longest waterfront of sites considered and that it is equivalent to several of the other sites in aggregate water frontage and area. It is therefore the current largest aggregate site.
The point is made that it has the shallowest minimum depth of water of all the sites (but ignores Newport which dries). It suggests that any of the vessels using the site could be accommodated at other wharfs. Shipping movements to and from all the wharfs is high tide reliant. The SDF acknowledges that the number of wharfs could be rationalised but suggests that Medina Wharf should be one of those retain for aggregate and bulk goods handling purposes.
The sites open countryside location is noted and good the views from the site. It should be noted that the converse is also true in respect of views of the site from the valley.
It is agreed that an abbreviated description in a table could imply that the site imports grain and pulses when it is known that these are only exported. It is however the only site exporting grain from the Island and supports an agricultural consortium of farmers allowing them to reach their European and overseas market directly by export by sea.
The take up rate of employment land across the Island is questioned and stated as 3 acres per annum over the last 38 years (actually 1960-1998). The actual figures quoted in the SDF are 2.1 hectares (which is 5.2 acres) and this related to new allocated land not to redevelopments. The letter also ignores the faster take up rate recently quoted for St Cross business park which alone was at 2 hectares per annum. The letter also ignores the following paragraphs showing more recent development of employment land around Cowes and East Cowes and makes a false calculation of there being 13 years worth of employment land.
The writer appears to contend that optimising economic and sustainability benefits of regeneration relies on residential development. Project Cowes is based on the regeneration of the economy and is employment driven.
The writer questions the sustainability of the SDF in that it shows employment uses within zone 4 where he says these are only accessible by the car. Site 17 is well served by the Cowes to Newport cycleway and a similar route is proposed for the east side of the Medina. Contrary to the writers claim site 17 is actually in the widest part of the river, is an existing wharf facility but is further upstream than alternative sites in Cowes and East Cowes.
It is agreed that there are a number of aggregate sites within the study area (although the possibility of sites elsewhere on the Island is questionable and was not stated by D Moore). The suggestion that the Island should have no aggregate importing facility and presumably that all aggregate should be locally won or imported by road via ferry services would appear to be the least sustainable solution. The writer agrees that to only have one wharf would lead to significant competition issues and cause a switch to road freight. This would then appear to support the SDF approach for consolidation of aggregate wharf facilities but to two sites as is in fact suggested. The recent merger of two aggregate companies might reduce the competition between these sites.
The issue of the poor state of the existing quay walls was pointed out to the Project team late in the process (and in confidence) but this alone is not a justification for supporting redevelopment of the site for higher land value uses or justifying the lose of wharf facilities. The condition of many quay walls around the harbour will require ongoing maintenance overtime, refurbishment and eventual upgrading or replacement in reaction to rising sea levels.
The report questions the provision of the enabling housing land at Kingston within Zone 3 and that there is no reason to support housing on one side of the river and not the other particularly when Cowes is the ‘preferred location for housing’. This does not recognise the fact of the UDP allocations that were subject of the Public Inquiry. It appears to be implying that SPG can modify the existing UDP whereas the UDP has to provide the context within which SPG will be applied. The PD site lies outside the development envelope of Cowes and remains in effect in the countryside from a policy point of view. Also the housing element of the comprehensive allocations at Kingston is set well back and screened from the estuary. An equivalent location on the west bank would fall outside the PD site.
PD’s comments conclude that the SDF should be reconsidered to change the proposals for Medina wharf to comprise a mixed use of enabling development (presumably housing) and employment activities with public access and that commercial shipping should occupy alternative locations. This does not consider the difficulties posed by the long narrow nature of the site, limited access possibilities, the reclaimed nature of much of the PD site and the visually prominent location within the countryside.
The consultants for Project Cowes foresee an on going need for commercial wharfs and bulk handling of goods such as aggregates. The zoning in the vision does recognise that there may be potential for specialist marine facilities on the Northern part of the PD site, effectively an extension to the type of facilities provided at Victory Yard. The proper course to consider a significant change in the role of this site is through the development plan process and not the provision of SPG.