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1) It’s based on an outdated Planning Policy for St James’ Hospital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1) Outdated Planning Policy for St James’ Hospital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;
Chairman Milton Neighbourhood Planning Forum
26 April 2018