MNPF Chairman’s objection to Care Home on Locksway Road

Subject: Objection to Application For Care Home 19/01322/FUL:- Forest Lodge Locksway Road

It would add weight to my Objection below if you could send your own versions to PCC too.

This is a scheme to demolish the existing “Forest Lodge” a late 1960’s traditional 2 storey brick building and replace it with a 3 storey, 66 Bed Care-Home for the elderly. The RN Benevolent Fund are interested in operating it.

According to the developer, “the proposal will make a positive contribution to the residential character of the area; and create a landmark building and community focal point. It will also introduce a new element of community healthcare on a site traditionally known for such uses and wholly appropriate within a residential area“.

The scale and massing of the proposal is all wrong as is the killing and destruction of  mature trees. Even if they were to be replaced their loss isn’t justified by this particular scheme. The applicant’s rationale is as follows:- the removal of “13 trees, 1 hedge, 1 group and several trees within G20 require removal to accommodate the proposals. T6, T7, T12, T13, T14 and T18 are category ‘B’ trees. Based on the proposals, the removal of these trees is unavoidable” seems to render irrelevant the loss of habitat at a time when PCC claims to be “greening Portsmouth”. It pre-supposes too the development is appropriate. The statement also ignores the fact the other 7 trees are all mature, all subject to Tree Protection Orders (TPOs) and all healthy.

According to his proposal “The trees to the front of the site along Locksway Road have significant impact on the local treescape and high amenity value, with the trees to the rear having a moderate impact as they are not as visible to the general public”. The obvious implication here is that if the trees aren’t readily visible they don’t count! The whole point of TPOs is to preserve them for the amenity they provide to the character and landscape of the locality.

That is compounded by the applicant’s statement that his is a “landmark” building. It’s actually a typically bland design from an off-the-shelf pre-packaged computer generated programme LNT has keyed into. The Hospital and Villas are “Landmark” in the ordinary use of the English language:- this dev’t isn’t!

By enlarging the built “footprint” on the “Forest Lodge” site the opportunity to re-use the Hospital or the Edwardian Villas for a Care-Home becomes compromised. The application expressly states there is a demand for elderly residential care in Portsmouth but to build it on this plot misapplies the principle of sustainable development because it’s not re-using an existing building. Only if the existing Main Hospital building or the Villas are fully re-used could there be a claim that a new build is sustainable and only then if it can be shown there are no other opportunities to build such a facility in existing buildings elsewhere in the neighbourhood. Of course there is:- at Langstone Campus, they’re all vacant and no TPO trees would require removal.

The Master-plan concept for Milton wasn’t wrong:- it just didn’t suit NHS Property Services. That’s got nothing to do with sustainable dev’t but everything to do with short-term financial objectives to the landowner. The 2005 Sustainability Strategy I refer to below was intended as a pan-Gov’t strategy both nationally and locally to be applied across all facets of Gov’t including the NHS. It was meant to encompass all Gov’t activity nationally and locally including education, health, transport, housing, energy, agriculture and fishing for the long-term benefit of future generations. NHS Property Services may have chosen a short-term solution but the wider and bigger long-term issue remains:- the absence of a “Presumption in Favour of Sustainability” means a residential option for the Hospital is constrained whereas this use wouldn’t be.

The applicant also tries to use his Sustainability Assessment to endorse PCC’s approach to sustainable dev’t as if it’s a given fact. If it was we wouldn’t need to be doing a Neighbourhood Plan for Sustainable Dev’t at all would we?

PCC hasn’t properly applied sustainability in it’s planning decisions at any time since Tony Blair’s 2005 UK Strategy for Sustainable Dev’t was introduced. Since then the National Planning Policy Framework (NPPF) set about defining 3 characteristics:- economic, environmental and social  sustainability to be considered in both plan making and decision making and none of them are meant to be mutually exclusive.

The House of Commons Papers in describing the NPPF and Sustainable Dev’t states:-

Sustainable development is development that meets the needs of the present without compromising the ability of existing communities and future generations to meet their own needs. It is central to the economic, environmental and social success of the country both that these three aspects of development are addressed positively and equally and that planning both serves to protect and to enhance and add value to the environment. This is the core principle underpinning planning.

PCC’s habit of prioritising the economic benefits to the landowner has been at the expense of the environmental and social benefits for the rest of us. It’s as I said at last Wednesday’s Forum, we wouldn’t have an Air Pollution problem had PCC applied “sustainability” properly and done what it said it was going to do in their 2001 Portsmouth Plan, their 2006 Supp Planning Doc on Air-pollution and their 2012 Local Plan. We have these issues because PCC hasn’t planned at all:- it’s just enabled development with very little control and virtually no consideration of long term consequences. Everything’s been a chaotic reaction to issues they should have foreseen and planned for.

Oddly from the objective of sustainability, the PCC Highways Officer has recommended refusal because of the lack of car and cycle parking spaces!

There are two good aspects about this application:- the Ground Source Heat Pumps providing 15% of the site’s energy requirements and the use. The use though is too intensive for such a green plot. The demand for a 66 bed Care-Home is best provided in the Hospital Main Building or in the Edwardian Villas.

We know from living with the excessive housing growth here over the last 20 years, the local environment in Milton has degraded and our quality of life has suffered as a consequence. By re-using part of the Hospital for a Care-Home such as this more of the parkland character can be preserved and less of the Hospital is left vacant for a pure residential use. This would help de-stress the potential impacts on the local environment (air-pollution, habitat damage etc), highway capacity and other infrastructure following the grant of a purely housing use.

We had about 300 Objections to the Homes England application. If we could get anywhere near that number then perhaps these developers (and also PJ Livesey for Phase 2) might wake up and realise they shouldn’t be paying NHS Property Services premium prices for a Hospital site (which in any case should really have a negative value because of it’s disrepair and high conversion costs) on an expectation PCC will, as usual, grant soft planning consents to build on what’s still a community asset in a parkland setting. Who knows, that realisation might even lead to NHS Property services eventually accepting PCC’s bid for the Hospital. That would be in everyone’s best interest City-wide.

Here’s my Objection:-

From: Chair MiltonNPF <>
Sent: 14 October 2019 12:15
To: <>
Subject: Objection to Application For Care Home 19/01322/FUL:- Forest Lodge Locksway Road

We object to the Planning Application 19/01322/FUL to develop the “Forest Lodge” site for a 66 bed Care Home.

The development is not “Sustainable Development” within the meaning of para 11 of the NPPF and nor does it meet the objectives of the 2018 UK Government’s 25 Year Environment Plan.

In summary:-  .

1) The application fails to consider the wider implications of developing on an essentially “green” plot.

2) It dismisses the loss of 13 trees and a hedge by implying their lack of visibility from Locksway Road is a justification.

3) It is at odds with the 2018 UK Gov’t’s 25 Year Environment Strategy which aims to recover nature and to use and manage land sustainably

4) It superficially claims the development creates a “landmark” building when it is a stereotypical design seen all across the Country

5) The scale and massing proposed in this application is inappropriate.

6) It amounts to a lost opportunity of re-using existing buildings in St James’ Hospital including the Edwardian Villas.

7) It is inconsistent with Council’s declaration of a Zero Carbon Emissions target for 2030.

The loss of 13 early, semi, and over mature trees all in healthy condition and all subject to Tree Preservation Orders is justified by the applicant as being unavoidable by virtue of his development. TPOs are imposed with the intention of protecting the visual amenity and character of the area and not to be felled for a development that is avoidable. These trees may not be obviously visible from Locksway Road as the applicant states, but they do exist and they do contribute to absorbing excessive carbon emissions from the atmosphere.

Portsmouth Plan Policy PCS13  states that the Council will protect green infrastructure by ‘refusing planning permission for proposals which would result in the net loss of existing areas of open space,’ on the basis that open space is a core aspect of the city’s green infrastructure network. The background papers on green infrastructure for the emerging Portsmouth Plan emphasise the enormous deficits in green spaces, trees and natural habitats:-

The UK Government’s 25 Year Environment Plan of 2018 aims to recover nature and manage land sustainably are undermined by the scale and massing proposed on the “Forest Lodge” Plot.

At a time when there is a vacant Grade 11 Listed Hospital only 500 metres away on the market, it would make far more sense from an environmentally sustainable perspective to re-use/rebuild the existing “Forest Lodge” for a pair of houses or a local Nursery and accommodate the 66 beds in the Hospital Main Building. From a “carbon” perspective that would also sustainably re-utilise “embedded carbon” in both the Hospital’s construction materials (with the added benefit of making an efficient use of a nationally important heritage asset) and the existing 1960.s Forest Lodge building. Failing that, and only if a new building can be unequivocally justified from a long-term sustainability perspective, a new Care Home of this magnitude could be erected to the North of the Hospital Main Building somewhere along Langstone Way. Furthermore, and from a more “holistic” planning perspective, the pair of vacant Edwardian Villas known as the “Beeches” and “Fairoak House” currently in disposal by Homes England on the former Hospital Estate could provide a wonderfully landscaped 66 bed Care-Home for the elderly..In that way these “Curtilage Listed” buildings could continue in a use they were originally designed and built for and better comply with PCS 23 on Design & Conservation and Historic England’s objective to retain a beneficial usage for heritage buildings.   .

The 2005 Sustainability Strategy and the 25 Year Environment Plan are intended to be applied Government-wide both nationally and locally. The failure by the NHS Property Services to Master-Plan their own exit from a nationally protected Grade 11 Hospital site is not remedied by piece-meal uncoordinated and fragmented disposals of plots of land. The disposal process of the NHS’s remaining interest in the Hospital is in any case underway so it is premature to grant consent.for this proposal when sustainable opportunities to accommodate the demand will exist in the very near future.

Sustainable development means meeting the needs of the existing generation without compromising ability of future ones to meet theirs. The existing needs for a Care-Home can be on the Hospital site whereas the future needs of residents bereft of anywhere near the sufficiency and quality of green spaces in the City will be lost.forever.with a building of this scale on a highly valued “green” plot.

What the applicant is proposing is an intensification of the use of land in a City suffering from an over intensification of the usage of with all of the adverse consequences to health and well-being from pollution and lack of green-spaces. He is incorrectly applying Policies PCS13, PCS15, PCS16,PCS17 and PCS23 by looking at his development from a narrow perspective whereas the correct approach is to look at the NPPF’s and the Portsmouth Plan’s objectives overall.

With a more sympathetic appreciation of the green” nature of the “Forest Lodge” site and the re-use of “brownfield” land on the Hospital Estate, the Care-Home could properly become a “landmark” building as the applicant aspires to construct. In so doing, the mature trees, groups of trees and a Privet Hedge are retained, wildlife habitat preserved and visual amenity maintained. His reference to the PCS Policies above would then become both more appropriate and more pertinent..

The purpose behind Policy STJ1 in the emerging Milton Neighbourhood Plan is to preserve and enhance nationally important historic buildings, preserve and enhance green spaces and comply with the Existing Portsmouth Plan policy MT4 in achieving Sustainable Development and reducing the impact on the local highway network.

Although the re-use of “Forest Lodge” for a Care Home is welcomed as is the adoption of Ground Source Heat Pumps as a means of a renewable energy source,a 66 Bed Care Home is better accommodated elsewhere.on the St James’ Hospital site.

This application should be refused as contradictory to all aims of long-term sustainable development objectives, the NPPF and the wider objectives of the Portsmouth Plan..

Rod Bailey

Chairman Milton Neighbourhood Planning Forum