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

Comments on Local Plan March 2019

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,  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


St James’ Marketing September 2018

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