St James’ update

The St James’ planning application returns to the PCC planning committee on December 21st.

That the Secretary of State be advised that had Portsmouth City Council Planning Committee been able to determine the application, it would have resolved to REFUSE planning permission for the following reasons:

1) In the absence of sufficient information being provided for the Habitats Regulations Assessment, as requested by Natural England, there is no certainty around the mitigation strategy which is required to address the likely significant effects in respect of recreational disturbance, as is identified in paragraph 4.1.8 of the Draft Habitats Regulations Assessment (ref. 200127 0991 HRA V1B) dated 18th December 2020 submitted. As such, the proposal should be refused due to the uncertainty regarding unmitigated adverse impact on protected habitats in accordance with the Habitats Regulations.
2) Insufficient viability justification has been provided, noting the uncertainty arising from the cost of mitigation under the Habitat Regulations, to demonstrate that the scheme is unable to provide affordable housing contrary to Policy PCS19 of the Portsmouth Plan 2012.

This application has also now been taken to appeal on grounds of non-determination and the Secretary of State is now the determining authority in this case. The Appellant asked the Planning Inspectorate to request that PCC undertake a further public consultation in light of the number of amended plans submitted with the appeal and the responses to that further consultation are material considerations for the determining authority.

You can see the officers report under

20/00204/FUL documents COMMITTEE REPORT 21.12.22

A Portsmouth City Council summary of the current planning on the future of St James’ hospital

Executive Summary

St James’ Hospital was declared surplus by the NHS bodies that held it and offered to market as part of the Government position at the time to dispose of public sector land for housing development.  Part of the site was transferred to the then Homes and Community Agency (HCA), now Homes England, part was sold for private development and part retained for the continued operation of health services in the area.  Within a similar timetable the University of Portsmouth reduced their occupancy of the adjacent Langstone Campus site, meaning the opportunity on that site could be considered in conjunction with the longstanding development allocation at St James’.

In 2017, encouraged by PCC, the HCA, NHS bodies and University jointly commissioned LDA design to review the opportunity and special qualities of these sites and produce a suite of documents, informed by evidence, to create development principles and a framework document that would be used by the then landowners and, any subsequent landowners of the site, to guide and support subsequent planning applications relating to the site.  These documents were submitted to PCC for review and the applications that have been bought forward since that time are demonstrably being guided by the principles considered within them.

Extracted below is an image from that 2017 development principles framework document, and it can be seen that the current Homes England and PJ Livesey schemes are broadly in accordance with it, as in deed is the care home on the southern side of the site.  The opportunity for a ‘land swap’ between the previously-developed and greenfield element of the UoP Langstone campus site is also included.  That opportunity is now part of the Portsmouth Development Plan through inclusion in the Milton Neighbourhood Plan.

The St James Hospital Site is currently being pursued in two distinct parts, one by Homes England; (outlined in blue below) who have held their proposals in abeyance to allow them to be redesigned to retain two buildings that were determined in March 2021 to benefit from statutory protection as listed buildings, and one by PJ Livesey; (outlined in red below) which involves the conversion of the main hospital building and additional residential development in the surrounding land which is the subject of an appeal for non-determination which is scheduled to be heard by Inquiry in April 2023.

Homes England   107 Dwellings  
PJ Livesey     209 Dwellings  

Both Schemes have collaborated to produce shared supporting documents such as a cumulative Transport Assessment, but both will currently be frustrated by an objection by Natural England, raised in respect of the PJ Livesey scheme, that the proposed developments will have a Likely Significant Effect on the Solent Wader and Brent Geese (SWBG) Strategy sites on Milton Common, which are considered to be land functionally linked to the Solent Special Protection Areas.  An adopted mitigation strategy for these effects is now considered to be out of date by Natural England.

The timetable for the PJ Livesey appeal is dictated by the need to update that strategy and relevant survey work, leading to a new strategy that the Council will need to consider adoption of, is being carried out between October 2022 and February 2023.  Further public consultation is currently bein

g carried out on the Appeal scheme and Planning Committee consideration of that response, if necessary, is expected to be in December 2022.

In October 2022, the Milton Neighbourhood Plan was made and now forms part of the development plan for these sites.  Due consideration of the policies therein will now need to be given by the LPA and PINS for all relevant developments.

Timelines for redevelopment of St James Hospital

March 2018                              Application made by Homes England on land in former St James for 107 dwellings (18/00288/OUT)

February 2019                          Application considered by planning committee.  Deferred to seek additional legal advice regarding heritage status of effected buildings

January 2020                            Application resubmitted and revalidated by Homes England for 107 dwellings

March 2021                              Report considered by planning committee in respect of heritage status of effected buildings

April 2021 – to date                   Homes England confirm their intention to amend the scheme to retain buildings now considered to be protected by virtue of ‘curtilage listing’

February 2020                          Applications made by PJ Livesey for 230 dwellings by conversion of Listed Hospital and new buildings within the grounds.  PPA agreed to manage determination (20/00204/FUL and 20/00205/LBC)

December 2020                        Amend plans received, now 209 dwellings, and update to PPA to aim for determination in April 2021

March – July 2021                      Updated submissions made an extensions of determination time up to 16 July 2021 agreed

December – January 2021          Further updates and amendments made to respond to consultee and community concerns.  Extension of determination time to 13 January 2022 agreed

January 2022                            Committee consideration of application.  Application deferred.

February – March 2022              Amendments submitted and consulted on in response to deferral

July 2022                                  Appeal for non-determination made to PINS by PJ Livesey (non-determination appeals are required to be made within six months of the agreed determination date)

August 2022                             Appeal Validated.  Inquiry scheduled for 22 November 2022.

14 Sept 2022                            Statement of Case submission required     

14 Sept 2022                            Natural England reconfirms its holding objection associated with impacts to Milton Common

21 Sept 2022                            Initial case management conference held

26 Sept 2022                            Natural England confirms its objection to the appeal and the necessity to carry out survey work over the winter period making the November Inquiry unfeasible

28 Sept 2022                            Second case management conference held.

30 Sept 2022                            Case Management Conference Interim Summary provided by PINS.  PINS confirms that a further case management conference will be held on 28 Feb 2023, following carrying out the necessary survey work and resultant habitats regulation assessment, with a provision date of 12 April 2023 to open the Inquiry.

October 2022                           Ongoing work between the Appellant, the LPA, NE, and HIWWT to scope and arrange survey work at Milton Common.

11 October 2022                       Full Council decision to make the Milton Neighbourhood Plan brings that document into full force as part of the development plan and the policies in it will now need to be given weight by all decision makers, including the Inspector on appeal.

Key planning considerations at St James Hospital  

Heritage and design – The Homes England scheme is being redesigned to allow the retention of two ‘villas’ considered to be protected by the statutory list.  No new plans have yet been submitted for consideration since the March 2021 committee consideration.  The impacts on heritage and design from the PJ Livesey scheme were a matter of concern for local people and an issue for deferral for the January 2022 Planning Committee.  No objections from relevant statutory consultees or the Council’s experts were however made.  Amended designs for the buildings in the grounds of the Listed Hospital building were submitted and consulted on but were not considered to be preferable to the original design.  The Appeal proposal is being determined on the original design.

Ecology – Both sites have been scoped in as causing indirect harm to the Solent SPA, through recreational disturbance and eutrophication of water by excess nitrates, and causing direct harm Solent Wader and Brent Geese strategy (SWBGS) sites at Milton Common.  While Natural England have amended their guidance regarding the ‘nitrates’ issues, resulting in greater mitigation payments being required, there are in place mitigation strategies to fully manage the adverse indirect impacts by recreational disturbance and eutrophication. Natural England, in respect of the PJ Livesey scheme, after the formal consultation period and reporting to Planning Committee in January 2022 have however confirmed a formal objection to development on this site based on the direct harm to SWBGS sites at Milton Common, as the mitigation strategy that was in place, the Milton Common Local Nature Reserve and Management Framework (‘the Framework’) has now been deemed to be out of date and requires updating following new mapping and winter survey work.  That work is now being commissioned and should be completed by February 2023.  It is anticipated that an updated Framework will be materially similar to the existing Framework and will provide effective mitigation for development on these sites through a financial contribution to alteration to Milton Common and associated access management strategies.

Highways – An ‘in combination’ transport assessment including the proposed growth from both sites has been submitted with the relevant planning applications and assessed by the LHA.  Noting the level of vehicular movement reasonable associated with the current lawful use the increase in movements is relatively small, and will, in officers’ opinion be more than adequately mitigated by two proposed junction improvements to be secured by planning obligation.

Open space provision/retention and trees – No concerns have been raised about open space delivery on the Homes England site, but has been a matter of significant debate on the PJ Livesey site.  On that site it is the developer’s contention, and officers’ opinion that the amount of open space is marginally increased following development and the accessibility of that space, secured by planning obligation is materially improved.  These matters are disputed by local residents and the Council is currently waiting on updated information from the MNPF (from email from Rod Bailey 28/09/22).  The PJ Livesey scheme also involved the loss of a number of mature trees and replanting, with a larger number of less mature trees in the new open spaces.  This was a matter of concern for local people and the January 2022 Planning Committee.

Current position for PJ Livesey Appeal

Draft reasons for refusal were sought by the Inspector in advance of the first case management conference held on 21 September 2022.  Prior to that case management conference Officer’s discussed with the Leader of the Council, as the senior member of the effected ward, those reasons and the roles parties could play in the appeal Inquiry.

While the January Planning Committee sought clarifications on a number of things through the decision to defer the application, only one matter was felt to be supportable by Officers; the inability to positively conclude that there was no adverse effect on SWBG sites at Milton Common due to the ‘out of date’ Framework as evidenced by the Natural England objection.  This uncertainty consequently created a circumstance wherein the overall viability of the development could not be correctly assessed and further to this the viability-based reasoning for the reduction in Affordable Housing provision below the policy expectation could not be evidentially justified.

The other matters raised in the deferral by the Planning Committee; namely ‘…the design of the new build elements, the retention and replacement of protected mature trees and the highway implications of the scheme‘ were not considered to be supportable by Officers and Members were advised that if they wish to suggest that they should be included in the draft reasons for refusal Officers would be unable to give evidence at the Inquiry to that effect.  The relevant Members would therefore be asked to provide any such proof of evidence and make that evidence to the Inquiry.

Cllr Vernon-Jackson, representing all three Ward Members, along with a representative of the Milton Neighbourhood Forum attended the Case Management Conference and raised the option of taking on Rule 6 status in the Appeal in order the represent those concerns that do not currently form part of the draft reason for refusal made by PCC.  The Inspector has asked them to come to an early decision as to whether they wish formal Rule 6 Status or whether they will instead attend the Inquiry as Interested Parties.

Next Steps

The Homes England application is currently in abeyance as PCC waits for Homes England to resubmit further plans.  It is understood from past meetings that they wish to bring on board delivery partners to take the planning application/s forward, a process that may involve splitting the site.  We have not yet been informed that a delivery partner has been appointed.

The PJ Livesey site is currently scheduled to be considered by Public Inquiry on 12th April 2023.  In advance of that Inquiry there are three key work streams being undertaken.

Survey work at Milton Common will imminently start to gather the necessary winter visitor survey to enable an updated Framework document to be produced.  That updated Framework is hoped to be completed by February 2023, whereat it will need to be considered for adoption by PCC Cabinet.

On 28 September 2022 at the appeal’s second Case Management Conference, PJ Livesey suggested that further public consultation could be undertaken on the plans that make up their submission to PINS.  This submission included a large number of documents that were marked up ‘not seen by LPA’, albeit these were largely plans and amalgamated elements from previous iterations into a final submission.  The Inspector agreed that this should be undertaken and asked the Council to carry out that consultation.  Officers have asked for formal confirmation that this consultation, and the associated expense, is required by the Inspector but have nevertheless commenced it and it is currently ongoing.  PCC will of course want to review those consultation responses and consider whether they justify any change in its current positon.  This may warrant presenting a report on the matter to the PCC Planning Committee, preliminarily suggested to be December 2022.  If the Planning Committee, having considered those consultation responses, determine that additional reasons for refusal should be promoted by the LPA it is considered that this could then be done with a minimal risk of costs being sought against the Council as this course of action is a result of the request of the Appellant and the decision of the Inspector to carry out that public consultation and four months’ notice will be able to be given before the April opening of the Inquiry.

The Appellant and PCC will continue to liaise in the preparation of the necessary supporting documents for the April Inquiry, including a Statement of Common Ground, draft s106 Agreement and the exchange of other technical evidence.

Update on Neighbourhood Plan examination

The Milton Neighbourhood Development Plan Examiner Liz Beth MA MRTPI held a Hearing on 6th April at the Civic Offices to determine the Local Green Space Designations before issuing her Final Report on 26 April. 

With the Examiner’s Modifications, the Milton NDP will meet the Neighbourhood Planning Basic Conditions of conformity with National and Local planning Policy and Guidance. She found our Plan to be well-evidenced and focussed.

The City Council Planners will now arrange for the amended Plan to go to Referendum in the Summer and we hope that as many residents in the Plan area will vote positively to endorse it. It is after all a Development Plan to improve the Local Environment and we are a small group of volunteers who have given up significant amount of our time and energy over seven years to get it to this stage.

The Planning Forum had submitted for Local Green Space Designation for twelve areas of Green Space, eleven of which are already classed as Open-Space in the current Portsmouth Plan. The additional area of Green Space the Forum wanted to secure, was on the east side of Chapel Way in St James’ Hospital to include the greenfield space north of “Woodlands Walk” between the Chapel and “The Limes” building.

Our hopes for St James’ Hospital may still be frustrated by the proposed Hospital conversion and new house building on green space and adjacent to the building on the former airing courts but the Examiner had to make allowances for a “Live” application. She did however support our Policy proposals for a mix of uses including; Specialist Residential Accommodation including Elderly or Dementia Care; Residential Training; Healthcare and Other Community Uses; and Residential Conversion.

The NHS Solent Trust objected to the Designation of a Local Green Space to the north of Woodlands Walk but did agree to a compromise it could be retained as Open Space unless and until a healthcare use materialised. The Examiner did however rebut the Solent Trust’s assertion they could keep healthcare development rights on the green-space north of the Chapel up to the tree belt. This was predicated on the premise it would upset the setting of the Hospital and Chapel. That effectively means no more car-park expansion.

With regards to the Campus and the University Playing Fields, the northern end of the Sports-fields will be designated as Local Green Space along with the Brent Geese Core Area adjacent to the Harbour. This is a far higher level of protection than the current Portsmouth Plan PCS13 “Greener Portsmouth” affords them. Space on an area from the Artificial Games Areas southwards to the boundary with Locksway Road Development on the Sports-Fields “May” be permitted but, this should only be for a similar extent in area terms of the 3.15 ha they currently have on Langstone Campus. That would also only be on condition the Campus is reinstated to green space appropriate for a coastal setting. The University are most likely to want housing but our aspirations for an educational use are preserved.

We have another eight green spaces with this higher level of protection including “Matron’s Walk” and “St James’ Green” in St James’ Hospital. Although The land north of the Chapel is deemed not suitable for development because of the impact on the setting of the Hospital it could not be designated a Local Green Space as such and nor can “Matron’s Garden”. Unfortunately, it is within the gift of the respective landowners to disallow it.

The Full Report can be seen under Examiners report. (top of page menu)

Rod Bailey

Chair Milton Neighbourhood Planning Forum

Milton Neighbourhood Plan Examination – Green Space Map

The Hearing will take place in the Civic Offices, conference room 1,  on 6th April 2022 from 10.30 to approximately 1500 with a break for lunch.

The hearing will be focusing upon the following points:

  1. Clarity around designations shown on the “Green Space Map”, including an alternative to designating land in private ownership to be ‘publicly accessible’, which is not a land-use issue.  The shading should show LGS clearly and separately together with a boundary of each LGS designation.  A further designation of ‘Open Green Space’ could also be included for sites not designated as LGS.
  2. LGS 1: The inclusion or not of the adjacent wooded area currently designated as ‘Proposed publicly accessible open space’.
  3. LGS 2: The inclusion or not of the adjacent wooded area currently designated as ‘Proposed publicly accessible open space’.
  4. LGS 3: How the proposed compromise with designation as open space but with the possibility of future development for hospital use may be made within permitted policy limits such as the NPPF paras 101-103.
  5. LGS8: Designation of part of this site as suitable for future development, however caveated is not compatible with LGS designation.  The development site could be removed from the LGS8 designation or the development proposal removed, and potentially left as ‘open space’ designation in a similar way to LGS3?
  6. The addition of Milton Locks Nature Reserve as an LGS.  A brief description of the ecological value of the Locks, and other attributes justifying designation as a LGS would be useful to see at or before the Hearing.

The floor will not be open to any other topics and people can only speak if invited by the examiner. 

The following have been invited; NHS (both Solent Trust and, property services), Homes England, Portsmouth University, and the Hampshire and Isle of Wight Wildlife Trust.

Those who responded to reg 16 have also been informed but to attend to view only rather than to speak.

Members of the public are able to attend to observe, invitation to speak will be only at the discretion of the examiner. If you would like to attend, please contact so that we can manage numbers.

Neighbourhood Planning Forum objection to St James Phase 2 – 18 March 2022

Milton Planning Forum’s Objection to Phase 2 St James’ Hospital PJ Livesey Scheme

The scheme is wrong. It’s too intensive; 

  1. it damages the setting of the Grade II Listed Building (breaching Policy MT4); 
  2. what should be retained as open space to “set” the Hospital in its landscape is being offered up as new green space in order to build over “Matrons Garden” supposedly protected under Policy PCS13 (A Greener Portsmouth); 
  3. there is not the highway capacity to accommodate the traffic generated and thereby also breaches Policy MT4 (and also PSC17 Transport);  
  4. it doesn’t provide Affordable Housing and could have if the site had been master-planned coherently 
  5.  the owner is a Gov’t Dep’t whose overriding Objective is to secure a long-term re-use of the historic assets consistent with the Local Plan and not the maximisation of disposal receipts (begs the question of why PCC’s bid was rejected!)

The Milton Neighbourhood Planning Forum Objects to the revised application for 151 new apartments in the Grade II Listed Hospital and 58 new houses in the Hospital grounds.

These comments should be read in conjunction with our earlier Objections dated 16 March 2021 and 15 March 2020.

The Officers’ Report to and Minutes of, the Planning Committee of 12 January 2022, misrepresent a proper understanding of the Portsmouth Plan Policies MT4; PCS13; PCS17; PCS19; and PCS23 in relation to the St James’ specific policy objectives; and the general policies on green space loss; transport; affordable housing; and design & conservation.

The key St James’ Policy is Policy MT4. It specifically requires the integrity and appearance of the Hospital and its setting be preserved, and the highway capacity to be sufficient to accommodate the additional traffic.

The application does not accord with the NPPF paras 65; 98; 111; 130; 131; 132; 134; 200; and 201; in relation to affordable housing; green space loss; unacceptable impact on the road network; visual amenity and loss of trees; and conservation of heritage assets within their setting.

The Committee did not have confidence the applicant’s uninspired house designs befitted the Hospital and its setting; of sufficiency of capacity in the local road network; an adequate justification for the absence of affordable housing; or the extent of the tree loss. 

House Design and Setting

The absence of a 3D interpretation of the impact the three-storey buildings on the setting is a telling omission- especially unreasonable considering the 2020 Design Review’s emphasis that “Views in and out are important

By replacing flat roofs with pitched ones so close to the Hospital building, and on its Airing Courts; its setting has been further impaired. Building within either the western or eastern airing courts is harmful but doing so with three storey buildings is manifestly inappropriate, wrong, and unjustified on Government land. 

Para 200 of the NPPF requires clear and convincing justification for harming the setting of a Listed Buildings. The applicant has none. The landowner is a Government Dep’t and in disposing of sites with historic assets, maximisation of disposal receipts is not an overriding objective:- Instead, under these circumstances, Gov’t Dep’ts have a higher duty to meet social and environmental objectives consistent with local and national planning to ensure the re-use of the historic building can be secured. The building can be secured by its conversion for 151 apartments. Any claim the houses are required to “cross-subsidise” the conversion costs is fallacious because the “owning” Dep’t had every opportunity to master-plan its exit coherently with Phase 1 and “Forest Lodge”, especially when all three sites were known to becoming vacant within short periods of each other. The failure to do so was also against the express wishes of Local MPs. It is not for Planning Authorities to support bad disposal strategies at the expense of the communities they serve.

Para 201 of the NPPF kicks in when harm to heritage assets is substantial. Because those plain and discordant three storey “Harrison” types now have pitched roofs on them; views towards and from within the Hospital, are obstructed to an even greater extent. What the applicant formerly described as “Less Than” Substantial harm is unequivocally “Substantial” now due to the imminent proximity by only a few metres to the flanks of the Hospital’s main elevations. Indeed, the Design Review recognised the potential for that harm in their comments on the original scheme where they advised caution on the treatment of boundaries. Using their words, “A management plan should ensure that boundary treatments of private spaces, where they are deemed necessary to create defensible space, have minimum impact on the elevations of the hospital building when viewed from eye-level around the site”.      

These are not minimum impacts. They are substantial impacts. They despoil the Hospital’s rightful place in its own landscape. The intent of MT4, and the NPPF, is to secure the prominence of a Grade II Listed Hospital building in the setting it was built with.

The Design Review disapproved of parking between the wings:- “The provision of parking between the wings is particularly unsatisfactory“. No regard has been given to the Review’s comments with the siting of 22 spaces between Lowry and Fernhurst wings; 21 between Fernhurst and Exbury wings; 22 between Exbury and Overton; and 10 between Overton and Langstone wings.

Para 157 of the NPPF also imposes on decision makers to take account of landform, layout, building orientation, massing and landscaping to minimise energy consumption. Unless the “Oxlades”; “Fairfields”; “Claybury’s” and “earsleigh” House Types incorporate Solar PV roof tiles on their east and west facing pitched roof slopes all are poorly orientated. The positioning of the four “Oxlades” (numbers 24-27); the ten new “Fairfield” types (numbers 32-41) and the four “Clayburys” (46-49) at the north would be better re-orientated to maximise Solar PV generation. To the west; the eight “Earlsleighs” (numbers 8-15) are similarly poorly orientated especially so when they don’t match the symmetrical layout of the Hospital. The nine three-storey inappropriately designed and positioned “Harrison” types in the Eastern Airing Court, are all orientated poorly for Solar PV maximisation too, compounding their wrongful positioning within the Grade II Listing setting.

The Design Review recommended taking design cues from the Grade II Hospital building. Where and what are they? At the very minimum, we would have expected better detailing such as quoins around windows and door frames and it shouldn’t be too difficult to introduce different patterns of brickwork interspersed with flint either. 

The Design Review Report exposed the absence of any relationship with the Homes England site and advised of a need to link the two and show how they “demonstrate” the wider changes to this part of Portsmouth. That absence of any “demonstration” may well be a consequence of poor intercommunication between the two  parties, or, because of the landowner’s incoherent and fragmented disposal strategy, but, the Planning Authority has an obligation to ensure the overall outcome will produce holistic improvements. We can’t see any in this proposal.  

Green Spaces

The Roundabout and Airing Court green-spaces are essential to the setting of the Hospital and must be disregarded in any calculations towards green space enhancement. There can be no justification for the loss of “Matrons Garden”  (protected by Policy PCS13) on the grounds the loss is being compensated for elsewhere.  

Notwithstanding the loss of “Langstone” and “Turner” Blocks, there is a net loss of Open Space by approximately 1,000 sq m .

Traffic Generation and Highway Capacity

Milton Road is congested. Velder Avenue is congested. Eastern Road is congested. 

Policy MT4 had always assumed a Private Hospital would risk intolerable congestion. It is therefore not the difference between a housing or Hospital development:- it’s either or both! 

The Committee, Planning Officers, and PCC’s Highways Officer have mistakenly taken into account a hypothetical traffic value ascribed to the Hospital’s past use is relevant.

Policy MT4 would not have been drafted to make explicit reference to the highway restrictions unless PCC and the then Highways Authority, Hampshire County Council, were aware of the highway limitations. Between 2006 when Policy MT4 was formally adopted and now, car registrations in in the City have risen faster than the population making us the 4th most Congested City in the UK. 

Members and Officers have failed again to understand the context. MT4 was drafted in the full knowledge the Hospital site had, and was, still being developed for 349 new houses. If each of these only had three vehicles for every two households, that adds another 575 cars to an already busy road network and since then, PCC has needed to declare part of Milton Rd; all of Velder Avenue; and part of Eastern Rd an Air Quality Management Area. This is the same AQMA that barely complies with UK Legal Limits now, and may not even do so, if PCC wouldn’t reduce their “actual” monitored pollution readings in there reporting to the Department for Environment (16% in their last Annual Statement to DEFRA). 

The public has not been shown any evidence in the revised application documents that a reassessment of traffic impacts on the local roads has even been undertaken. All we can see is a drawing of an indicative scheme with traffic lights at the junction of Locksway Rd/Milton Rd dated September 2021 which was described as “aspirational”  at the Planning Committee. It did not prove the junction was adequate to accommodate the demand in 2021 and nor does it do so in March 2022.

There needs to be robust evidence Milton Rd; Velder Avenue; and Eastern Rds will accommodate the redevelopment of St James’ Hospital taking account of the redevelopment of Kingston Prison. 

Affordable Housing

The landowner is a Government Dep’t. Gov’t Dep’t’s in disposing of sites with historic buildings, are not required to maximise disposal receipts. As stated above, that is not their overriding objective:- Instead, their objective is to secure a long-term future for historic buildings consistent with local and national planning in the wider social and environmental context.

Local and national planning policies are required to secure a minimum level of affordable housing in new developments. 

The NHS had every opportunity to masterplan their exit from St James’ coherently. Had they done so, the site “in toto” could have supplied the requisite proportion of social housing by “cross-subsidising” the conversion costs across the whole site. It is not for Planning Authorities, or the communities they serve, to subsidise bad disposal strategies on behalf of Central Gov’t Dep’ts:-in those circumstances Gov’t Policy and the NPPF places viability for communities above viability to housebuilders. 

Tree Loss

The revised application reduces the total number of trees to be felled against the original proposal. However, because the application still proposes building on green spaces inappropriately, too many are lost without justification.

Carbon Footprint  

Although the works in the Hospital conversion are acceptable and meet the requirement to preserve the integrity of the Hospital, there remains the issue of the demolition of Lancashire House. The re-use of Lancashire House is an opportunity to create a “Community Energy Hub” and meets National Planning objectives to reduce the “carbon footprint” in larger new developments. It’s a historic building depicted in at least two of Edward King’s many paintings of the Hospital. He was a renowned artist “committed” by his family to St James’ in 1926 and died there in 1951. All pre-1948 buildings within the curtilage of Listed Buildings are deemed to be “Listed by association”. 

The NPPF para 157 and the emerging Portsmouth Plan encourage the use of “decentralised” energy supply; the Council has a “Net Zero” Carbon Emissions Target for 2030; and the 2020 Design Review expressed the lack of information justifying its loss. “Embedded Carbon” and the opportunities its steeply pitched south facing roof offer for Solar PV generation compound the wastage of such a significant building. The Design Review expressed the view “It was disappointing not to hear more about the approach to sustainability and we support the Milton Neighbourhood Forum in pushing for this development to be exemplary in terms of sustainability. Reducing embodied carbon is as important as promoting sustainable ways of living and minimising energy in use, and there are many opportunities to articulate this further, from water management and details of permeable paving through to biodiversity and ecology gains”.

This proposal is offering development inconsistent with the objectives of local and national planning policy and should be refused. 

Rod Bailey

Chair Milton Neighbourhood Planning Forum

18 March 2022