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