St James’ Hospital Inquiry “Closing Statement” Milton Neighbourhood Forum


  1. The Milton Neighbourhood Forum (the Forum) strongly oppose the application by PJ Livesey to convert the Grade II Hospital and Chapel into 151 Apartments and 58 houses and associated car-parking.
  2. The Forum considers that the appeal scheme proposes an overdevelopment of a heritage site. Had the Appellant been able to cross-subsidise the conservation cost of redevelopment and restoration across both vacant Hospital sites, the heritage harm could have been reduced, the historic landscape better preserved, and the open spaces retained.
  3. The application is for a residential development as is the adjacent plot 1. Bringing the two sites to market separately thwarts PCS 13 which requires the provision of additional open space. 
  4. The benefit of a Legal Right of access over a “Permissive” one is overstated. The Appeal Scheme is a residential conversion with enabling development and includes the reinstatement of a publicly recognised pedestrian and cycle route linking Longfield Road with Locksway Road, it is therefore inconceivable the public could be denied access.
  5. Similarly, we do not accept that new development encroaching upon the northern Airing Courts particularly at the Northeast can be justified to the extent claimed.
  6. The harm from the proposed scheme is not sufficiently justified and cannot be considered to significantly and demonstrably outweigh any perceived benefits.


Matron’s Garden 

The scheme seeks to reduce the locally sensitive Matron’s Garden to a single border of trees on four sides of three large, detached houses and garages together with 10 visitor car parking spaces. The Inspector has heard testimony from the Council, the Portsmouth North MP, and public witnesses as to the long-held appreciation of this tranquil green enclosure within the Hospital’s designed landscape. The ‘Garden’s’ isolation is the  very quality that makes it exceptional. Instead of dismissing it as a planning impediment, the Appeal Scheme should embrace it to retain the arboretum feel of the landscape for future residents and visitors alike.

Harm To The Setting of the Listed Hospital Building 

A residential conversion for the hospital is a significant heritage benefit. It is however, recognised that there is harm to the setting of the heritage assets, and we disagree with the extent of new housing. The appellant’s evidence was in error dating the 1937 Lancashire House as post WW2 and further, the (1907) Edwardian Villas are not 1928-32 as stated. That later date considerably diminishes the significance of these early examples of detached villas in a psychiatric setting. The villas have an integral relationship with the Hospital. Building across the North East Airing court and “Chapel View” causes significant harm to that relationship. Additionally, it creates incongruous sightlines from the important vantage point of the Chapel.

Setting and Publicly Accessible Open Space

Local and heritage protections do not rely on public accessibility. MT4 and MH1  protect the hospital’s setting. PCS 13 and ENV1 protect open space. The erection of 9 houses on the North-East Airing Court are a doubly injurious outcome not compensated for by public access to the southern lawn and southern Airing Courts. Furthermore, the proposed redirected north/south cycle path will impede the free flow along the long-established route via the roadway known as “Chapel View” which defines the extent of the eastern Airing Courts.

Demolitions and Open Space

Demolition of the 1950/60’s single storey buildings to the south west of the Goddard Wing are welcomed. The Forum is unable to reconcile the Appellant’s inclusion of verandas and courtyard enclosure demolitions within a net open space calculation consistent with the ordinary meaning of the term open space. There is an open space loss within the Appeal scheme with different ways of calculating it. We believe the Forum’s is more readily understandable.

Car Parking and Traffic Generation

Exceeding the car-parking quotas of the MNDP and to a lesser extent those of the Local Plan, are detrimental to the designed landscape and deters greener modes of travel. For the avoidance of doubt, whilst the MNDP’s visitor parking standard is not explicit, it is intended that visitor parking accord with those under the Local Plan. SYTRAs highway report for the emerging Plan explicitly references the Locksway/Milton Road and Moorings Way/Eastern Road junctions. The Appellant has agreed to mitigate the first and is unable to make improvements to the second where more of the Scheme’s traffic will flow. The SYSTRA report identifies it will operate beyond capacity by 2026 and is incapable of mitigation. We cannot reconcile these conclusions with the benign outcomes of the appellants traffic assessment. 

Demonstrably Significant Benefits Outweighing Harm

  1. The Appellant’s case rests on the value attributable to the 1879 Asylum’s high degree of architectural and historic significance, accepting that a degree of change is necessary. Loss of early fabric is unfortunate but considered acceptable to Historic England and the Conservation Officer. However there comes a tipping point where the loss of historic landscape undermines the very essence of the scheme’s justification. We do not accept the incursion across the North East Airing Court and “Chapel View” is justified.
  2. The absence of a coherent Masterplan across both sites, frustrates the ability to achieve open space gain required under PCS 13 as required.
  3. The sale of the site appears to be predicated on a Keppie Massie valuation of the site with a 20% incentive to the landowner to sell. This is inconsistent with the spirit of Historic England Guidance to public authorities with heritage assets when disposing of them. In these circumstance price is not to be the overriding objective.
  4. We agree with the LPA, the Appeal Scheme does not produce “Significant and Demonstrable Benefits Outweighing Harm” when considered against the overall objectives of the Local Plan and MNDP.
  5. Overall, there are good reasons to dismiss the Appeal Scheme.

Rod Bailey

Milton Neighbourhood Forum

4th July 2023