Forum objection to St James Phase 2 development

The Milton Neighbourhood Planning Forum objects to the Planning Application for 230 new Dwellings and 485 Car-spaces at St James’ Hospital.

1) There is no “Presumption in Favour of Sustainable Development” anywhere in Portsmouth by virtue of the Chichester & Langstone Harbour (and other Special Protection Areas around Portsmouth’s coast) wildlife habitats constraints. This scheme is not proposing Sustainable Development compliant with the National Planning Policy Framework (NPPF). It undermines the UK Government’s 25 Year Environment Plan’s objectives. It is not balancing environmental and social needs with landowners and developers financial motives.

2) It misapplies Policy MT4 in the current Portsmouth Plan because it fails to comply with  qualifications on local highway constraints and the intentions of MT4 requiring the integrity and appearance of the building to be preserved.

3) The absence of highway capacity and other infrastructure was identified in the 2017 Issues and Options for the emerging Portsmouth Plan 2021-2036 prevents the intensification of development proposed

4) The proposed number of 485 car-spaces is excessive and goes well beyond current guidance on parking standards by 37% and exceeds the emerging standards by 80%. Such a scale undermines PCC’s ability to achieve a “Net Zero Carbon Emissions” target.    5) Exposure of local residents to higher levels of air pollution created by increased congestion on the local highway creates an unacceptable risk of harm to human health.

6) There is no use of renewable energy in contravention of National Planning Policy which also undermines PCC’s intentions to be “Zero Carbon” by 2030.

7) There is harm to the setting of the Grade II Listed Hospital implicit in the Heritage Assessment which identifies pre-1909 structures as “Significant” and says there will be a degree of heritage harm to the designed grounds and the asylum buildings.

8) The Health Impact Assessment’s conclusions are false.

9) The total quantum of “Affordable” Housing is non-compliant with Portsmouth Plan Policy PCS19 and the 2019 “Providing Affordable Homes in Portsmouth” Brief.

10) The proposed use increases stresses on the community infrastructure such as schools and community facilities as recognised in the 2017 “Issues and Options” to the emerging Portsmouth Plan 2021-2036. Existing Policy MT4 proposes continued use as a Hospital, Residential Training or Education. Health and Education uses would help address local deficits, generate employment and help reduce car-dependency and are therefore more appropriate.

1) Absence of any “Presumption in Favour of Sustainable Development” and Non-compliance with the NPPF and UK’s 25 Year Environment Plan

The increases in recreational stresses on the environmentally sensitive habitats in Langstone Harbour created by future residents in housing developments on St James’ Hospital is not addressed in the Milton Common Restoration Framework (see paragraph 5.5 therein).

Paragraph 177 of the NPPF states the presumption in favour of sustainable development does not apply where the plan or project is “likely to have a significant effect on a habitats site” (either alone or in combination with other plans or projects), unless an appropriate assessment has concluded that the plan or project will not adversely affect the integrity of the habitats site.

The designation of Langstone Harbour as a Special Protection Area for habitat conservation in 1987 has not prevented recreational stresses from the population expansion of Portsmouth and the surrounding areas. As a result, Negative Impacts on the Langstone Harbour SPA over many years has required PCC to create “Mitigation” measures to reduce the harm. The current “Mitigation” (the “Bird Tax”) is an “Interim Strategy”.

It has become apparent these measures are ineffective. Current data shows that only 18% of Langstone Harbour is in “favourable condition”. In other words 82% is not “favourable”. Therefore the applicant cannot rely on any assumption his development will have no significant effect on local habitats through the payment of a “Bird Tax”. All he can do is hope. Hope isn’t good enough.

The withholding of residential planning permissions on residential schemes imposed by Natural England in 2019 to reduce eutrophication in the Harbour from excessive nitrate concentrations is being addressed by schemes to avoid increasing the nitrate burden. Rather than resolving the actual cause from over-development effecting a sensitive environment PCC’s response is to create an “”Interim Nutrient Neutral Mitigation Strategy” which proposes “Mitigation Credits”, “Off-setting” and taking agricultural land elsewhere out of intensive farming reliant on nitrogen fertilisers.

The applicant accepts he is not proposing a solution. Instead he explains there is to be further negotiation with PCC and Natural England. Special Protection Areas were designated to protect wildlife habitats. “Interim Mitigations” imply harm can be reduced. The UK’s 25 Year Environment Plan goal is to improve wildlife habitats (as well as our air, and our water quality). “Mitigation” is not improvement! We want to see an improvement to the water quality in Langstone Harbour, not hope the applicant can successfully negotiate a compromise.

2) Misapplication of Policy MT4 for St James’ Hospital 

This application proposes to re-use a Victorian Grade II Listed Hospital with 230 dwellings accommodating  approximately 550 residents and 485 car-spaces. It proposes replacing a hospital in the most densely populated City in England . We have 5,400 residents/sq km but we do not have sufficient healthcare facilities to support it.

The scale of development is excessive. It is an intensification of a residential use beyond the capacity of the local highway network to accommodate it. The application is therefore contrary to the current Portsmouth Plan Policy MT4.

Policy MT4, drafted for the 2001-2011 Portsmouth Plan and carried over to the current one, explicitly constrains the options for the redevelopment of the Grade 11 Listed Hospital. It qualifies it’s re-use whether as a Hospital or conversion to a residential training centre; education or for housing, by requiring the re-use to preserve the integrity and appearance of the building. Critically MT4 also qualifies these re-uses by inserting the constraint, subject to the surrounding highway network being able to satisfactorily accommodate the additional traffic generation.

3) Absence of Capacity on the Local Highway Network 

The Transport Evidence Paper produced by Systra for the emerging Portsmouth Plan state that existing traffic volumes exceed capacity at the road junctions at Milton Road and Velder Avenue.

In relation to St James’ Hospital it states “The Transport Assessment completed for the St James’ Hospital – Plot 1 development, for 107 residential dwellings, concluded that there is no expected change in traffic flows in comparison to the former hospital buildings, and that mitigations to the surrounding road network are not required. It should be noted that this application has not been formally approved by the Council. While the 107 dwellings proposed in Plot 1 of the development may not materially impact the identified congested hotspots, there could be traffic implications with the remaining development of the site identified in the Site Allocations: Locksway Road, Milton (2014) report and July 2015 update”.

The Applicant’s Transport Assessment ignores reality.

It dismisses the “rat-running” distortion of the 2014 count as “unlikely” when our evidence says otherwise (202 reported confirmations of the use of St James’ Hospital as a Rat-Run as at 15th March 2020). Instead it presumes a relationship between a Hospital Floor area and vehicles.

The relationship should be about use. Psychiatric Patients don’t drive every day and any vehicle movements that were made during the Hospital’s operations were generally associated with mental care staff and visitors. Similarly, the TA refers to the Child Dev’t Centre and Harbour School on the Phase 1 site as making up 45% of the floor area and hence 45% of the Hospital’s vehicle movements. Children do not drive either and Fairoak House and The Beeches therein were closed in 2014. This is why the Portsmouth Plan Transport Evidence Paper qualifies Homes England’s TA for the Phase 1 application.  It says HE’s TA “has not been formally approved” and “may not materially impact….”. To say otherwise would be both factually incorrect and a misstatement but from PCC’s perspective it’s also saying they cannot rely on it. The Milton Neighbourhood Planning Forum too has already submitted evidence undermining the Homes England’s Transport Assessment’s claims.
It is absurd to conclude a proposed development of 230 houses and 485 car-spaces will reduce vehicular movements to that applicable to that same part of a Hospital when it was operational. There is absolutely no credibility in such a conclusion. Is it at all conceivable with parking for 485 vehicles there will only be 76 departures and 24 arrivals in the morning peak? No of course not.
In any case, what MT4 is saying is that even if it were to be re-used for a hospital, the additional traffic must be capable of being “satisfactorily accommodated”.

We are the joint 4th most Congested City outside London and the junctions at the southern end of the Eastern Rd; Velder Avenue/Milton Rd/Rodney Rd cannot meet current peak demands and nether can Goldsmith Avenue/Eastney Rd. The Transport Assessment takes no proper account of developments elsewhere impacting on the already congested road network such as the Kingston Prison redevelopment for 267 apartments.

Increasing traffic congestion from this scheme is inevitable because our local highway network is unable to operate efficiently now when peak demand exceeds capacity. Policy MT4 is explicit:- redevelopment of the hospital must be capable of being accommodated.

4) Excessive Car-Parking The car-parking element is 485 spaces whereas the current PCC Parking standards on 230 houses and apartments in this location should be 352. PCC’s emerging Parking Policy would allow just 270. That alone  means the applicant is intending to generate additional traffic above what PCC currently permit and intends to restrict in the future. Ironically PJL claims the site is accessible for public services/amenities and is good for walking and cycling whereas the rationale for the excessive car-parking appears to assume otherwise.

At a time when PCC is committed to being “Net Zero-Carbon” by 2030 in terms of emissions such a high level of car-parking is at best mischievous and at worst negligent.

5) Road Traffic Air Pollution From Proposed New Development

The applicant’s AQ Statement recognises that “Development should, wherever possible help to improve local environmental conditions such as air and water quality” but then says:- ‘the focus of planning policies and decisions should be on whether proposed development is an acceptable use of land, rather than the control of processes or emissions (where these are subject to separate pollution control regimes). Planning decisions should assume that these regimes will operate effectively.’

This both undermines causes and effects and misleads the reader into thinking because PCC has a regime and the will to control it, the development will be acceptable. That’s factually untrue and traffic from the development feeds into the local Air Quality Management Area 9 covering parts of Eastern and Milton Roads and Velder Avenue. PCC does not yet have a lawful Air Quality Plan.

The latest 2019 AQ Report identifies pollution levels in AQMA 9 are rising and currently they are only within “Legal” limits by 6%. It describes the 2017-2018 NO2 annual average change  as being “moderately adverse”  and the “NO2 annual average exhibits an upward trend in the last 5 years demonstrating an AQ deterioration in the long-term similar to the previously reported 5 year trend.”

The Applicant’s AQ Statement concludes “concentrations of relevant pollutants (NO2, PM10 and PM2.5) at nearby sensitive receptors and at the Proposed Development are predicted to meet the relevant air quality objectives in the opening year. Therefore, it is considered that no mitigation measures will be required during the operational phase“.  That is an unscientific conclusion. As the outgoing Director Public Health admitted at the PCC Committee recommending the Mini Clean -Air Charging Zone, the Council’s predictions are based around modelling which could be erroneous.

There are rising pollution levels in AQMA 9 and the City has never reached legal compliance with air pollution targets since the legal limits set in 2010 were imposed together. Owing to the improbability of reaching legal compliance for many years to come, it would be unsafe to allow this scheme.

The absence of any substantive evidence or likelihood 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 in decision making involving potential threats to Public Health.

6) Absence of Renewable Energy  Nowhere  in the proposed scheme is there any adoption of “Renewable Energy”. The NPPF at para 150:- New development should be planned for in ways that: a) avoid increased vulnerability to the range of impacts arising from climate change. When new development is brought forward in areas which are vulnerable, care should be taken to ensure that risks can be managed through suitable adaptation measures, including through the planning of green infrastructure; and b) can help to reduce greenhouse gas emissions, such as through its location, orientation and design. Any local requirements for the sustainability of buildings should reflect the Government’s policy for national technical standards.
Why is there no Solar PV on roofs of new buildings? These can be installed in the construction phase using Solar Tiles. It is irresponsible to expect future residents to have to retro-fit them.

The applicant’s Energy Statement says:- “Due to the nature of this scheme, renewable technologies have been discounted. The report highlights lower energy consumption can be achieved by using energy efficient, be lean and be clean measures, which will bring benefits to the development throughout the lifetime of the building rather than the lifetime of a technology.

That is not acceptable when the Council declared a Climate Emergency in March 2019 and set a Zero Emissions Target for 2030.

There is a disused Boiler House (Lancaster House) with external brickwork in exceptional condition and because there will be a network of service pipes for steam heating throughout the Hospital, the retention of this building for a renewable communal heating scheme would be eminently more sustainable than demolition.

7) Harm to the Setting of the Grade II Listed BuildingThere is harm to the setting of the Grade II Listed Hospital implicit in the Heritage Assessment which identifies pre-1909 structures as “Significant” and says there there will be a degree of heritage harm to the designed grounds and the asylum buildings. This contravenes the intentions of the Portsmouth Plan Policy MT4 requiring the integrity and appearance of the building to be preserved. The integrity and appearance is compromised by the construction of new houses and car-parking spaces on the female (west) and male (east) Airing Courts which are intrinsically connected to the main building. The applicant actually acknowledges that too because his Heritage Statement reports:-

“…. It is thus the case that views out eastwards from this location were designed to be particularly ‘open’ or uninterrupted. However, the new dwellings unavoidably bring new built form into the former eastern airing grounds here (where there was not previously built form), and somewhat closer to the asylum buildings. This results in a small degree of heritage harm to the designed grounds and the asylum buildings


Para 7.39. “…… it is the case that new built form is introduced into the former eastern airing grounds, where there was not previously built form; and thus the new build unavoidably results in a small degree of heritage harm to the designed grounds and the asylum buildings, including the chapel“.

and again:-

7.40. “The new dwellings at Area 3 area situated in the former western airing grounds. They are in a single row, and comprise two pairs of semi-detached homes, and a short terrace of three homes…..  it is the case that new built form is introduced into the former western airing grounds, where there was not previously built form; and thus the new build unavoidably results in a small degree of heritage harm to the designed grounds and the asylum buildings.

Internally, there is damage to the Entertainment Hall. It was placed at the heart of the building and offered a focus on life outside of the purely clinical setting.  It’s Gothic Byzantine features reflect the design of the building and are a testament to mental health regimes of the time.  The loss of this feature within the applicant’s scheme is unacceptable. It would surely be better to preserve it as a social space which reflects the heritage of the building.

8) Health Impacts The applicant’s Health Impact Assessment identifies themes using a Health Urban Planning Checklist and concluded it will have positive health effects for all of the following 11 key health themes:-  Housing quality and design;  Access to healthcare services and other social infrastructure;  Access to open space and nature;  Air quality, noise and neighbourhood amenity; Accessibility and active travel;  Crime reduction and community safety;  Access to healthy food;  Access to work and training;  Social cohesion and lifetime neighbourhoods;  Minimising the use of resources; and  Climate change.

This scheme is to redevelop a Hospital in a quality landscape. This is a use which gets to the heart of a community especially when it was created out of local funds for the benefit of local people. At a time when the City is bereft of adequate health facilities but is over-burdened with development and traffic congestion and also suffers a 75% under-provision of green-spaces, how can this proposal ever be considered as having a positive health impact on the local community?

The Health Impact Assessment recognises the nearest GP Surgery is at  Devonshire Avenue is at the limit of comfortable walking distance but it omits to say it’s closing!

The development destroys green spaces, harms the SPA, degrades the air quality and compromises the Council’s aspiration for “Net Zero Carbon Emissions” by 2030. It does nothing for social cohesion or improving health. Indeed it is far more likely to lead to the reverse.

9) Insufficiency in “Affordable Homes” and non-compliance with PCS19 and “Providing Affordable Homes in Portsmouth” Brief of 2019.  Notwithstanding the applicant’s reliance on MT4 to deliver housing on St James’ Hospital to replace  existing health-care uses is no longer sustainable within the spirit of the NPPF, there would be far too low a provision of Affordable Housing for a development of this scale anyway. This City needs more Affordable Family Houses rather than more “Affordable” Apartments. However, this scheme proposes only 7 Affordable Houses. 18 of the Affordable Homes are in a pair of 3 Storey Apartment Blocks overshadowing Brasted Court, justified by a claim they compliment the scale and form of the adjacent Falcon House. Falcon House is a 2 Storey building. This both illustrates the applicant’s lack of appreciation of the site and the neighbourhood, but it also shows his lack of willingness to comply with existing planning policies.

10) Increased Stresses on Community Infrastructure Policy MT4 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.


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 aspires to encourage and enable healthy choices and appropriate access to healthcare and support. However that is totally 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 the nation.

Core Objective 8 aims to ensure adequacy of supporting infrastructure for development and growth but also totally fails when there are rising deficits in school-place sufficiency in the right locations. The Council’s bolt-on-solution of creating temporary classrooms in playgrounds as a reaction to the growing numbers of children risks higher levels of  childhood obesity with the loss of playgrounds for activity breaks and outdoor PE.

Effectively these three failures in the Core Objectives have contributed to increases in Portsmouth’s relative high levels of deprivation, comparative low-life expectancy and lower than average educational achievement. The Applicant’s Health impact Assessment does not stand scrutiny and this application could never redress these local imbalances whereas it might do if it was retained as a Hospital.

This application must be refused. 

It is not the obligation of the City Council to underwrite developers profits because they choose to overbid for sites. It is their business to professionally appraise development opportunities and if they miscalculate then that is their problem. That’s “developers risk”.

It is not the City Council’s responsibility to subsidise landowner’s land values with inappropriate planning consents either.

The City Council’s role is to enable “Sustainable Development” compliant with the Statutory Plan and the NPPF. This scheme does neither.

Rod Bailey

Chairman Milton Neighbourhood Planning Forum

15 March 2020

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