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