Comments on the Portmouth Local Plan by the Chairman of the Milton Neighbourhood Planning Forum.

Housing Needs and Housing Targets Update: –

The inconsistent “Top-Down” Nationally produced projections are unhelpful in determining what the appropriate level of local housing need really is. At best it’s a guide: – more likely it is a fanciful threshold to be judged against at Examination.

If the current Plan identified a potential supply of 11,484 new homes from 2006 to 2026 and we managed 6,082 including 2,116 “Affordable” additional homes to 2018 then we are almost balancing supply and delivery on an annual basis.

However, the PUSH target of 14,560 from 2011 to 2034 is not based on supply or capability of supply. It is also proposed at a time when the resident population here is increasing at a faster rate than the working population with a growth in population of 4.5% since the 2011 Census. This is higher than the rest of Hampshire and the UK.

With resident’s wages lower than the Solent average, then the implications for our resident population will be to increase housing costs suggesting we need to adjust the “Affordable Housing” Ratio to 40%.

Forecasting local needs using national targets on such a random basis can’t be a good way to prepare a local housing policy.

Employment Land

If we have 2 workers “in-commuting” to every 1 “out-commuting” we must conclude we have a good demand for employment. However, with a resident population increasing at a faster rate than the working population and with resident’s wages lower than the Solent average, then the Employment Land supply must on the face of it be OK. What the evidence suggests though is the underachievement in educational qualifications by residents is leading to them suffering lower wages as compared to the “in-commuters”. For an efficient and sustainable City in the long-term, the residents need and the business needs should match. That will reduce unnecessary demands for “in-commuting” to a City with poor transport infrastructure whilst simultaneously improving opportunities for the indigenous Portsmouth residents.

Methodology and conclusions of the Housing and Economic Land Availability Assessment

Notwithstanding the Disclaimer, which is both reasonable and appropriate, there are a few contradictions and inconsistencies which might lead to unintended consequences.

If Portsmouth residents under achieve educationally compared to national standards by 12.5% at Key Stage 2 and by almost 15% at Key Stage 4 https://www.compare-school-performance.service.gov.uk/schools-by-type?step=default&table=schools&region=851&la-name=portsmouth&geographic=la&for=secondary&la-name=portsmouth,  and we also have poor access to health facilities then it is counter-intuitive to include school and health facilities in a Housing Availability Assessment irrespective of the disclaimer. By including for example existing community/employment sites such as Eastney Health Centre (50 dwellings), St James’ Hospital (340) and King Richard School (100), other objectives around deprivation factors such as poor healthcare and education provision are undermined.

It is also misleading to include sites such as Fraser Range (130) and Langstone Campus (120) for your calculations if the sites are unsuitable and would better meet wider deficiencies: – see comments on Green Infrastructure below. The inclusion of these sites raises an expectation housing is acceptable notwithstanding the obvious restrictions and constraints, (most of which undermine every other Plan Objective).

Methodology and conclusions of the Transport Evidence Review

This study is far too superficial to be used in an Evidence Review.

For instance, it makes reference to LTP3 but that assumes Portsmouth will have a population figure of 205,200 by 2026 which is totally at odds with the “Issues and Options” Consultation this “Evidence Review” is supposed to be in support of.  The “Issues” Consultation refers to a rapidly increasing population estimated to be 213,000 back in about 2016/2017!

The Review also refers to mitigation measures such as a City Centre Road Improvement Plan that’s been put on hold pending credibility checks and wildly optimistic reductions in Air Pollution levels. It mentions “improvements” at junctions such as a Velder Avenue/Milton Rd/Rodney Rd junctions whereas this junction is better described as a perfect example of  highway failure because queuing traffic at peak times exceeds a mile in 2 directions.

It makes references to a 2015 Strategic Housing Land Allocation Assessment never adopted and a non-determined planning application for 107 houses at St James’ Hospital concluding the consequences of development will reduce traffic as if they are “evidence”!

What Portsmouth needs is a comprehensive report based on reliable evidence of highway capacity at all of the junctions and major roads in the City with growth assessments aligned to realistic and consistent development options. Portsmouth also needs to understand from the Ferry Operators and the Commercial Dock operators what their realistic assessments/assumptions are on passenger and vehicle numbers are and what the likely freight traffic will be.

If the 2018 National Infrastructure Commission’s Report identifies Portsmouth as having significant congestion problems (joint 4th worst outside London) we can’t carry on assuming there is capacity for further demand. The NPPF requires that infrastructure be in place to accommodate development and for at least the past 20 years all of our main roads fail to deal efficiently with the volume of traffic.

Considering we have significant problems with air pollution and a Public Health Report identifying pollution from road traffic as a factor in our 19% higher incidences of premature deaths from cardio-vascular disease and almost 30% higher cancer premature deaths than the national average then why is this Report so silent on sustainable transport improvements and traffic reduction measures? We only have one reference in this paper to an “Active Travel” initiative (Segregated Cycle Lane at Tipner Bridge) but we are supposed to be assessing potential sites against Sustainable Development Objectives.

We want an assessment of rail passenger and freight capacity and consider how (and if) they can be expanded and ultimately we must have a far better understanding of our transport requirements assessed against capacity otherwise we will carry on perpetuating the same mistakes as we have always done in the past.

Methodology and conclusions of the Open Spaces Needs and Opportunities Assessment

This is a well researched and academic report.

It exposes the real paucity of “Amenity Green Space”, “Children’s Play-Spaces”, “Allotments”, and “Natural and Semi-Natural Green-Spaces” in Portsmouth.

Currently we only have 23% of the requirement for “Amenity Green-space”  (the requirement is stated as 215 ha but we have a current deficit of 166.55 ha).

We have an even greater discrepancy in the requirement for Children/Young Persons Play-Spaces because we only have 14% of their needs (the requirement is stated to be for 180 ha but reports a deficit of 166 ha).

We have 82.5% of the Allotment requirement and 81% of the Natural and Semi-Natural Green-space requirements but this drops to 68% by 2034.

The recommendations appear acceptable in terms of greening initiatives but what seems to be missing is how they’re evaluated in contributing to meeting health improvements. I also think it is too conservative on population growth predictions. It is looking at requirements for 9.3% from the 2011 Census to 2034 but the Housing evidence already announces a 4.5% increase by 2017/18.

The Green Infrastructure Paper  is also a very good background document supporting the Open Spaces theme. It usefully expresses positive aims to create, protect, enhance and manage Portsmouth’s green infrastructure to balance development needs.

I like the inclusion of the term “Blue-Spaces” and the recognition we are unique with this coastline of ours and with our SPAs. I like the “Green-Grid”initiative and the reference to “Green-Roofs” and “Green-Walls”. I also like how the paper makes the link to improvements in physical and mental health and well-being.

In para 6.4 there’s a clear recognition of the problems for green infrastructure planning,,,,. “A lack of clear, spatial, and actionable delivery plan (or mechanisms) for implementing GI around the city” ……….. “approaches were high level and aspirational yet lacking in any solid implementation plans”…. “A pro-growth agenda – Central government continues to strive towards higher levels of housing delivery to help meet housing needs. It is not impossible that there could be potential for a deprioritising of environmental concerns such as green infrastructure delivery, in favour of other pressing development needs such as housing or the economy. It will be important for the Council to continue to recognise the importance of balancing the three”.

All that is fine commentary but rather than express problems, I would like to see a better expression of opportunities to create new GI/Open Spaces followed by the how they could be achieved. I therefore think the paper should be more dynamic in identifying new sites to redress the current imbalances/deficits rather than the problems associated in achieving them( important though they are).

The Open Space Assessment maps show those areas most deprived of “green-infrastructure” to be in North Southsea, Fratton, Buckland and Landport, but there’s no mention of suitable opportunities to redress their deficit. What those residents need is more closely accessible “wild-spaces” they can safely get to.

The creation of a Country Park at Horsea Island/Port Solent makes a great use of the former land-fill site for example and is very welcome, but this is not convenient for the North Southsea/Fratton residents. Remember too, there is already a Country Park relatively closely at Portsdown Hill and this just emphasises the unequal distribution of amenity open-space.  Our housing “evidence” on the other hand, identifies opportunities for housing on partially used or derelict sites such as Fraser Range (130) and Langstone Campus (120).

These are prime areas for nature conservation on a coastal fringe unique to Portsmouth (as recognised in the commentary on the “Blue-spaces”) and could serve as “wilder” areas more easily accessible for residents in the south of Portsea Island. If both the Open-Spaces and the GI paper are silent on the opportunity these sites offer notwithstanding their eminent suitability then the next step must be to include them.

Natural England’s Objectives in making the British coastline more accessible would also be better respected with an enhanced publicly accessible coastal fringe.

If the aim is to create GI, then I would expect to see a recognition that the vacant Portsmouth University site at Langstone Campus could be seen as an opportunity to extend Milton Common to widen the coastal fringe for public access (at least during Summer months when the Brent Geese are absent) and for Fraser Range to be “greened” to create a balancing effect to offset the hustle and bustle/vibrancy of the western and central seafront areas.

Other comments in general

The Public Health document is an indictment on this City. 

The limitations on school-playground/games areas, together with the huge deficit of children’s play-spaces exposed in the Open-Space document, illustrates just how far we’ve sunk in disregarding their needs and the needs of our future generations. That is a disgrace when you think of the high obesity levels in our children. Too many of our schools are close to busy congested roads and the expansion of Portsmouth Academy at AQMA6 on the multi-activity games area tells you all you to know about how the Council values the health and well-being of its children.

Town Planning of its own can’t remedy health inequalities but there is a responsibility to better use planning policies to prohibit a further widening of differences irrespective of political will (both nationally as well as locally).

We should therefore quantify in monetary terms the long-term costs and benefits of land-use options so we can make more informed judgments on sustainable development objectives including human health. For far too long our priorities have just looked at short-term benefits to landowners at the expense of long-term costs to the public.

Far too much time and effort has also been wasted trying to follow inappropriate rules on housing delivery and unrealistic “growth” targets as if there is infinite capacity. We make vain efforts at trying to keep traffic flowing to the detriment pedestrians and cyclists relegating them to nuisances to be tolerated rather reversing the presumption to encourage active travel. We have finite land availability in the most densely populated City in the UK with a chronic under-provision of green spaces and public services, huge congestion on our inadequate highway network, high levels of deprivation and ill-health and poor educational achievement.

The City is flat but it is so hard to get around safely by bike. Bikes use little space whereas the private car takes up far more but often just has the one occupant. We should make more effort to enable walking and cycling to be easier, safer and healthier.

I would like the next Portsmouth Plan to have a greater emphasis on improving Portsmouth for residents:- it’s all well and good to encourage visitors and promote economic regeneration but our own residents, children and grand-children need to share the economic benefits too.

We should make better use of derelict coastal sites to exploit our unique coastal situation for the benefit of the many and not just a minority of landowners. I would like to see a new school on Langstone Campus to better serve the SE Quadrant of Portsea Island not just because it is environmentally superior to our other school-sites but also because it is accessible safely by bike or on foot and, being adjacent the Chichester and Langstone Harbour SPA, there is very little else the site can be re-used for.

I would therefore like the next publication of evidence papers to show how we can plan more positively towards sustainable goals and properly appraise and evaluate the costs and benefits associated with them.

Rod Bailey

17 March 2019

 

Marketing of St James’ Hospital by the NHS

The Milton Neighbourhood Planning Forum oppose the magnitude of development offered in the Montague Evans Sales Brochure.

There are over 300 objections outstanding on the existing Homes England planning application on the St James’ Phase 1 site predicated on it’s non-compliance with local and national planning policy objectives.

The marketing guidance for Phase 2 seems to ignore these and local concerns. It also poses significant problems for the City Council’s stressed highway network and it’s community infrastructure especially schools.  

Because the existing Planning Policy MT4 permits development only in the event the existing highway network can accommodate the additional traffic generation, the extent of residential use suggested is a nonsense.

There is an overriding public interest in the Hospital remaining in a community service use such as Elderly and Dementia Care or Adult Social Care consistent with the existing “Institutional Use”.

MT4 looks to preserve the Grade 11 Listed Hospital for a mix of health-care, residential training, education or resi-conversion but there’s little scope for much else because the “Presumption in Favour of Sustainable Development” is dis-applied with the International Conservation constraints on the Langstone Harbour Special Protection Area, RAMSAR & Special Area of Conservation.

The redevelopment of St James’ Hospital for up to 299 new dwellings would undermine the Chichester and Langstone Harbour conservation objectives.

The Solent-wide Mitigation Project to off-set the likely significant impacts of increased housing development within 5.6 km of the Special Protection Areas is now questionable.

The recent “Sweetman” ruling in effect reverses the presumption that mitigation schemes for new housing developments are prima-facie acceptable. Whereas the Council could previously claim to have screened out the need for an “Appropriate Assessment” in any early consultation by relying on their Mitigation Strategy, that’s no longer possible. By it’s very nature, the legal designation of a Special Protection Area endorses the cautionary principle against harm. So unless the purchaser has in mind a compliant scheme demonstrably unlikely to have any significant effect on the SPA, he cannot reasonably anticipate a favourable outcome.

Notwithstanding the obvious financial risks to any lender and the possibility of the developer going bust from lengthy delays in getting a residential scheme to fruition, the suggestion of the capability of the site to provide an additional 299 homes clearly misunderstands these local constraints.

Rod Bailey

Chairman Milton Neighbourhood Planning Forum

AGM 2 Jun 17[7682]

AGM notice 2018

Subject: Planning Application 18/00288/OUT:- Proposal by Homes England for 107 Dwellings on St James’ Hospital

The Milton Neighbourhood Planning Forum objects to the Outline Application for 107 new dwellings at St James’ Hospital.

1) It’s based on an outdated Planning Policy for St James’ Hospital

2) The supporting documentation is incomplete and flawed

3) The grant of approval would cause harm.

1) Outdated Planning Policy for St James’ Hospital 

Policy MT3 in the Portsmouth Plan 2001-2011 carried forward into the 2011-2026 Plan assumed strategic policies on transport, health and education services would be achieved to sustain the growth.

The 2001 Plan aimed to secure housing with an adequate supply of health and education services together with a City free from unnecessary traffic congestion and with a choice of effective public transport systems and alternatives to the car.

The 2011 Plan aimed to make Portsmouth an accessible city with sustainable and integrated transport; and by ensuring there is adequate supporting infrastructure for the new development and growth of the city.

None of this ever happened. The reality is in the reverse. 

Core Objective 2 of the 2011-2026 Portsmouth Plan aspires to make Portsmouth an accessible City with a sustainable and integrated transport system but it is not achieved. Traffic congestion is rising and the Council has no means of improving public transport to enable any switch away from car-dependency.

Core Objective 6 to encourage and enable healthy choices and appropriate access to health-care and support is undermined by expanding GP waiting lists and rising deficits in hospital bed numbers leading to a worsening of health outcomes and a consequential increased costs to heath-care.

Core Objective 8 to ensure adequacy of supporting infrastructure for development and growth totally fails when there are rising deficits in school-place sufficiency. The Council’s bolt-on-solution of parking portakabin classrooms in playgrounds as a reaction to the growing numbers of children is resulting in higher levels of childhood obesity with the loss of play-space to run around in.

Effectively these 3 failures have contributed to increases in Portsmouth’s relatively high levels of deprivation, comparative low-life expectancy and lower than average educational achievement.

This application replaces health and education uses in a City with inadequacies in both for housing in the most densely populated City in England with 5,318 residents/sq km.

The reliance on MT3 to deliver housing on St James’ Hospital to replace the existing health-care and educational use is no longer rational let alone sustainable. This Policy is outdated and inappropriate.

2) The supporting documentation is incomplete and flawed. 

Despite an assurance to the Milton Neighbourhood Planning Forum given on 4 April 2018 the Council would publish an amended Application Form/obtain confirmation from the applicant the proposal is for 62 houses and 45 flats, the Application Form is still published as proposing 107 houses. Furthermore an entire section of the Environmental Appraisal Appendices (8.1-8.9) is still not published notwithstanding a request by Natural England on 13 April 2018 to be given the information and notice given that Table 23 therein is also incomplete. The applicant has so far not submitted a Biodiversity Mitigation and Enhancement Plan. Given the applicant has signed to say there will be affects on protected and priority species and on nearby designated sites, habitats, and other biodiversity sites, this effectively means Statutory Bodies and the public, are not being provided with all of the facts.

The D&A Statement reports on input from the local community whereas the local community has largely been ignored. It assumes compliance with existing policies in the Portsmouth Plan and a Site Allocations document of 2014. The latter was never adopted and MT3 in the former is outdated. It also relies on residential densities some of which are excessive and inconsistent with the Portsmouth Plan (The PP recommends no less than 40 dwellings/ha unless the development site is close to the City Centre and Transport Hubs).  This site is poorly accessible by public transport and 40 dph is more appropriate.

The D&A Statement also claims to enhance the setting of a Grade 11 Listed Chapel with the construction of 3 blocks of three-storey flat roofed apartment blocks one of which is only about 25m from the Chapel.

These buildings are too high (10m) and too unsympathetic to the Hospital’s landscape and design.

The Transport Assessment ignores reality and takes little account of developments elsewhere impacting on an already congested road network. This Assessment relies on the Local Transport Plan 3 which is outdated and no longer fit for purpose. LTP 3 assumes the population in Portsmouth will rise to 205,200 by 2026 whereas the “Issues & Options” Consultation of 2017 reports the population as being 213,000 already.

In any case the TA concludes the proposed development of 107 houses will reduce vehicular movements but has no credible means of justifying the statement. Indeed, the Application Form states it provides parking spaces in excess of 50% greater than it had when used as a hospital and school.

It is absurd to make an assumption on vehicular movements for this part of the Hospital in 2014 by applying a floor-area calculation to an 80% occupancy rate as a means of assessing the full traffic impacts without understanding the intensity of floor-space use or it’s type. For example, the Child Development Centre and the Harbour School were at 92% occupancy according to the TA but Children are not cars drivers.

Fairoak House and Yew House were both 100% vacant and described as having 3 main access points and yet the TA proposes access and egress to their redevelopment be solely through one:- Fairoak Road.

Fairoak Rd is thereby committed to a daily increase of 220 vehicles with the applicant claiming:-  “No access is shown to experience a significant increase of vehicles in any one direction, suggesting that the development will have a nil detriment impact on the local highway network”. No account of the Dog Walker Vans parked in Fairoak Rd for St James’ Green seems to be taken into account either.

An application for 15 Houses and 45 Flats to discharge vehicles into Fairoak Rd needs to start from a premise Fairoak Rd did not exist at all when the Hospital was fully operational. 

It is nonsense to describe Locksway Road and Milton Road as working well when between 16.00 and 17.45 weekdays there is a traffic queue beyond Copnor Bridge over a mile away and on Summer weekends it backs up along  the Eastern Road to Portsmouth College even further away.

The DfT Traffic Count figures for this junction indicate a 6.3% increase in vehicles in 2016 compared to 2014.

The TA states it is reasonable to walk 2 miles to facilities using approved guidance but that guidance is misunderstood by the applicant because it is meant to apply to existing towns and communities and not new developments. In any case for Portsmouth it is hard to encourage walking and cycling when the main barrier to both is personal safety. Portsmouth suffers 51 deaths or serious injuries/100,000 annually compared to the average for other cities and towns of 38.5/100,000 (City Council Public Health Report 2016).

This TA concludes an absurdity because it’s based on an absurdity. 

The Planning Statement claims to embrace Portsmouth’s Planning Planning Policy PCS14 (Improving Air Quality, Well-being and Health-care requiring Health Impact Assessments be requested on major new developments) by stating the proposed development is only“considered” to be in compliance with the aims of PCS14 by offering electric vehicle charging points and requiring Travel Plans. It also makes reference to the City Council’s Infrastructure Delivery Plan 2011 by identifying that the south of the city is well served by GP surgeries (some with potential to expand). It also suggests there is adequate GP provision to accommodate projected growth in the south of the city to 2026!

The population expansion, high incidences of diabetes, obesity, lower life expectancy, aging demographics create huge demands on the Health Service and the increased difficulties in getting GP appointments suggest Portsmouth is not adequately provided for in terms of GP numbers.

The Planning Statement also makes no direct reference to other infrastructure needs and so the absence of school-places isn’t mentioned. It simply states Policy PCS16 (Infrastructure and community benefit) requires development to provide or contribute towards the provision of infrastructure needed to support it, and to provide or contribute towards community benefits related to the development. The policy stipulates that where new infrastructure is needed to support new development, it must be operational no later than the completion of the development or phase of development for which it is needed. Even if it is possible to recruit more GPs and nurses by the completion date, a new school will take far longer to build.

The Heritage Assessment is inconsistent and falsely describes “Fairoak” and “The Beeches” as undesignated and insignificant.

Firstly they can be described as “Curtilage Listed” by reference to the HA’s own statement of the boundary wall with Locksway Road where the wall is described as enclosing the historic curtilage of the Hospital. They can also be described as “Curtlage Listed” by reference to Historic England’s Guidance of March 2017:-  https://content.historicengland.org.uk/images-books/publications/listed-buildings-and-curtilage-advice-note-10/heag125-listed-buildings-and-curtilage.pdf/

Secondly the buildings have a national significance in that they are very early and rare examples of the “Colony-Plan” System of psychiatric care where patients are moved away from a rigid institutional approach. They have a local significance by virtue of their designer, the celebrated Portsmouth architect Arthur E Cogswell (1858-1934).

The “Colony Plan” system had been developed in Germany and Austro-Hungary and was widely adopted in Scotland but not in England. These Villas were placed within the landscaped grounds of the asylum to allow patients a degree of independence deemed beneficial to their recovery.

Cogswell worked for the hospital’s architect George Rake in 1879 until Rake died in 1884,  Cogswell became the hospital’s architect. Much of what he designed has been destroyed but these Villas are a testament to the high degree of civic pride that Portsmouth placed on its asylum and are worthy of retention and re-use.

3) Potential Harm of an Unconditional Approval

The traffic generation is not properly assessed and therefore the Council’s Environmental Health Officer cannot make any reliable statement on compliance with Air Quality standards. Indeed the applicant is relying on an Environmental Appraisal and a Transport Assessment by the same Consultancy Company WSP. You cannot properly audit two essentially conflicting aims by the same organisation because the required level of objectivity risks being lost.

Fundamentally however, the Environmental Assessment refers to the Council’s 2017 Air Quality Strategy which has now been deemed by DEFRA as inadequate requiring the Council to produce another Strategy this Summer. The reasons for the Council’s failure are complex and long-standing but for these purposes the “cautionary principle” needs adopting whereby unknown consequences cannot be assumed to be safe. That principle is enshrined in Environmental Law both domestically and at the European level.

AQMA 9 at Velder Avenue/Eastern Road exceeded annual NO2 Limits in 3 of the last 4 months of reporting so it cannot be assumed adding more traffic to the area will be safe.

Unless, and until, the true effects on Air Quality arising from the proposed development can be quantified, the Council should exercise greater caution before granting approval.

In Summary this application should be refused on the following grounds:-

1) the loss of Historic Buildings in defiance of their “Curtilage Listing”.

“Fairoak” and the Beeches” could be better re-used for Social Care/Dementia Care to free up bed-spaces at QA and their access can be retained via Woodlands Walk to mitigate stresses to residents in Fairoak Road.

2) their replacement with 3 inappropriate 3-storey blocks of apartments damages the “Setting” of a Grade 11 Listed Building (The Chapel).

3) the excessive dwelling densities on that part of the site closest the Hospital are inconsistent with the Portsmouth Plan and it’s aims to concentrate higher densities in the City Centre and close to public transport hubs;

4) the flaws in the Transport Assessment’s conclusions on the numbers of vehicular movements, on sustainable transport, and the dismissal of existing traffic congestion are too important to be ignored;

5) the absence of any credible evidence the provision of sufficient GP and school-place numbers will, or could be, achieved by the occupation date would impose more stresses on existing Milton residents and families;

6) the absence of evidence the use of the development will not damage air quality and will not be injurious to the health and well-being of existing residents elsewhere in Mliton is contra to the “cautionary principle” required for Public Health purposes;

7) the incomplete Environmental Appraisal in relation to the impacts on the Chichester and Langstone Harbour SPA and the failure to submit a Biodiversity Mitigation Plan once agreed with the Hampshire County Council Ecologist means a proper judgement cannot be made on wildlife stress; 

Rod Bailey

Chairman Milton Neighbourhood Planning Forum

26 April 2018

Subject: Demolition Application 18/00484/DEM “Fairoak” and “The Beeches” St James’ Hospital

OBJECTION

The demolition of these buildings should be determined as part of the wider application for the redevelopment of the south eastern part of St James’ Hospital (referred to as Plot 1 in 18/00288/OUT)

This Application is a mischievous attempt to hide the demolition of important historic buildings and amounts to a deception on behalf of a Government Agency.

The National Planning Policy Framework puts great emphasis on the Nation’s Heritage and unless and until a final scheme is approved, there can be no justification for their removal because any “Public Interest” benefit cannot properly be determined.

There is no Heritage Assessment with the Demolition Application and the one accompanying the development scheme is tin any case too shallow to properly justify the removal of “Fairoak” and “The Beeches” as it ignores “Curtilage Listing”, ignores the historical significance in terms of the evolution of the Hospital and it’s design by local architects, and totally misses the point in recognising the importance of landscape and setting endorsed by the NPPF..

I shall be grateful if you will refrain from considering this Demolition Application in isolation from the Outline Application 18/00288/FUL

Rod Bailey

Chairman Milton Neighbourhood Planning Forum