The post you are reporting:
I have posted the following objection:
I comment on this application in my capacity as Chairman of Dover Peoples' Port Trust Limited (DPPTL), a community organisation with over 1000 paid-up members living or working in the Dover District, and which exists both to campaign for meaningful community involvement in the governance of the Dover Harbour Board (DHB) and to hold DHB to account in respect of its strategic direction and its day-to-day activities insofar as they impact the town of Dover and its citizens.
There are several disturbing aspects both to the present application and to the events leading up to its submission.
Firstly, there are what we consider to be two defects in the application itself.
The declaration in section 6 that pre-application advice was sought from DDC officers in a meeting on 22/4/15 is followed not by disclosure of the content of such advice but a reference to the minutes of that meeting. DDC has refused to allow me to view these minutes or to provide me with the gist of the advice given and we therefore contend that this application is incomplete and that its validation by DDC officers was wrong. No decision should therefore be taken on this application until the applicant provides this information or other steps are taken to place it in the public domain.
In section 7 the applicant claims that : 'There has been extensive consultation about the entire scheme which was subject to EIA prior to be consented (sic) by the Dover Harbour Revision Order 2012.' Here we take issue with both the description of the consultation and the form which it took. We believe that the consultation amounted to the bare minimum laid down in MTP2, the DfT's document laying down rules for the governance and conduct of trust ports and can hardly be described as extensive. Furthermore, the consultation which took place was on the forerunner of the scheme contained in the 2012 HRO, the provision of a second ferry terminal (T2), and not on the construction of a non-RoRo freight dock. We therefore consider the applicant's assertion in section 7 to be at best misleading.
Aside from the contents of the application itself, there are other aspects which give us cause for concern.
Notwithstanding the subsequent confirmation by the Marine Maritime Organisation (MMO) (itself questionable due to the radical differences in the nature, size, location, frequency and volume of ship movements under the two schemes) that the existing EIA was adequate, it would appear that the DDC decision not to require a fresh Environmental Impact Assessment for the amended scheme was taken by officers with no public consultation or formal reference to the planning committee. We do not believe that decisions affecting a matter of such gravity should be delegated to employees of the Council or taken behind closed doors without their implications first being considered at the highest level and subjected to scrutiny.
The design and Access and Heritage Statement prepared by Royal HaskoningDHV states:
'Prince of Wales Pier Furniture
The pier furniture which is included in the listing of the Grade II Pier will be appropriately stored in a secure facility and re-located where appropriate or within a similar maritime setting within the Western Docks following completion of the DWDR development. This mitigation measure was recommended within the Historic Environment Chapter of the Dover Terminal 2 Environmental Impact Assessment (Maritime Archaeology Ltd, 2008).
It is considered that the removal of the furniture prior to further works along the pier structure will be of benefit to the long term survival of these architecturally and historically important assets.'
We believe that these statements are far too vague, giving ample scope for backsliding, and that in a scheme of this importance and complexity the fine details of where these heritage items are to be re-located ought already to have been decided. These details should therefore have been included in this application and, in order to safeguard these assets, no decision ought to be taken on this application until such detailed plans are provided by the applicant.
In the same document, lip service is paid to adherence to DDC's Heritage Strategy and Dover District Core Strategy of 2010. In paragraph 2.7.2 of the document, reference is made to the T2 development being recognised within the Core Strategy as being one of four development opportunities central to its success. But this application is not in respect of the T2 development but the DWDR scheme, which has not been considered in the context of the Core Strategy and has not been the subject of public consultation.
In the following email text a council officer admits that the proposal description in the application is vague: 'Dear Mr Garstin, Thank you for your email. At this point, there are no notes on the LBC file as no site visit or meeting has yet to take place. However, outline permission for the overall development, including the works at the pier, formed part of the Harbour Development Order which was an Act of Parliament so our role in heritage is to make sure that the changes which do take place, are not unduly harmful to the listed pier. The proposal description is, unfortunately, rather vague and does not give the full picture. The pier, when the Hovercraft dock was built in the 70's was partially covered by the dock and the concrete section of the pier at the landward end, was added at that time. It is this area which will be most affected by the proposal. The removal of the listed furniture is to prevent damage during the process and will be replaced once the pier re-opens to the public following the works.'
Obviously DHB has managed to convince DDC that the heritage assets will be replaced and the pier re-opened following the works. However there is no detail on this aspect of the application and we believe therefore that the granting of consent by the planning committee to the proposal would create a serious risk of the permanent loss of this historic structure which is dear to thousands of Dovorians. DDC may be convinced but DPPTL is not and neither, we suspect, are the community. I shall not go into the detail of how the pier is held in such esteem by the community as that is obvious from the many comments already received from citizens on DDC's planning website and by the outpourings of anger in the press and on social media. However, given the town's feeling and its distrust of the applicant, the Planning Committee should use their power to delay this consent until the additional detail is provided, to demand binding undertakings from DHB as to the timescale for re-opening the pier and reinstating its furniture, and to stop the application in its tracks if such detail and undertakings are not forthcoming.
DPPTL and its members want the best for Dover, and we shall support the DHB wholeheartedly in trying to provide it. But we don't think this proposal as it stands bears out DHB's mantra that it has the community at its heart. In particular DHB's announcement that the pier will close in early September merely demonstrates its disregard for the community, Dover's heritage maritime assets (of which it is merely the custodian, not the proprietor), and its arrogance in taking the consent of the planning committee for granted.