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25/04/2018
Hi guys - here is the full objection I am submitting on behalf of KMG regarding Phase 1 of St James hospital! I can only apologise in the delay - it’s so busy and they have thrown so many documents at us that it’s taken ages to sort through! I wrote an objection however, the chairman of our neighbourhood planning team sent me this and it’s just amazing. Have ever so slightly rejigged it but feel free to take out bits and submit! I’m working on a bullet point version right now which I will post separately within the hour.
Please either log onto the planning portal, type in 18/00288/OUT and submit a comment (weblink below)
Http://Publicaccess.portsmouth.gov.uk/online-applications
Or you can email the guys at the planning department at [email protected] quoting your name, address, whether you object etc as well as the application number (above!)
Please feel free to share and get people to comment! And huge thanks to Rod Bailey who has put together such a comprehensive and detailed objection!
I object to the outline application regarding the construction of 107 dwellings.
Home England’s statutory objectives are to improve the supply of housing in line with government policy, secure the regeneration or development of land or infrastructure and contribute to the achievement of sustainable development and good design with a view to meeting the needs of people. They say "these objectives have guided the proposals for development of the Site" but there's no real evidence they've applied them. Here are some of the reasons why I am objecting to this application.
1) The loss of Historic Buildings in defiance of their "Curtilage Listing" ("Fairoak" and the “Beeches"). These could be re-used for Social Care/Dementia Care to free up bed-spaces at QA and their replacement with 3 3-storey blocks of apartments are not in keeping with the surrounding area and would damage the "Setting" of a Grade 2 Listed Building only 20m away (The Chapel)
3) The excessive dwelling densities on that part of the site closest the Hospital
4) The absurdity of the Transport Assessment's conclusions on the numbers of vehicular movements, on sustainable transport, and it's ignorance of existing traffic congestion
5) The absence of any credible evidence the provision of sufficient GP’s and school-place numbers will or could be achieved by the occupation date
6) The detrimental effect on local air quality.
Portsmouth Plan Policy MT3 (which determines this) is dated back to 2001 to provide 145-170 new homes. This Policy is now outdated and inappropriate.
Policy MT3 carried forward into the 2011-2026 Plan assumed strategic policies on transport, health and education services would be achieved to sustain population and economic growth. It aimed to secure a mix of 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 by ensuring there is adequate supporting infrastructure for the new development and growth of the city.
However, this has not happened. In reality the reverse is more true.
The 2012 Plan Core Objective 2 to make Portsmouth accessible with sustainable and integrated transport has not been achieved.
There is rising traffic congestion, high levels of road accidents (with 51 serious injuries or deaths/100,00 compared to an average of 38.5 elsewhere in the UK) and a total inability of the Council to manage public transport.
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 consequential increases in costs to heath-care.
Core Objective 8 to ensure adequacy of supporting infrastructure for development and growth fails with the rising deficits in school-place sufficiency. PCC'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 than other comparable cities and towns because there's little play-space to run around in. Effectively, all 3 failures have contributed to increases in Portsmouth's high levels of deprivation, comparative low-life expectancy and lower than average educational achievement.
Another important change since the Adoption of MT3 is highway capacity and traffic congestion. Portsmouth cannot meet it's National Air Quality Objectives by 2020 (it's been required to submit a Local AQ Action Plan to DEFRA by July or then abouts following a legal challenge to the government) then the absence of any credible pollution reduction is a valid objection. The applicant intends to leave a note to the new occupants to consider walking and cycling and then do a follow up survey later to discover if they do!
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 Harbour School element of the Application (area closest the University Playing-fields) for the mix of 3 and 4 bed family houses is as OK as it can be but the rest of it doesn't make sense especially the 45 flats in the 3 Apartment Blocks with access from Fairoak Rd. They raise the dwelling density to 70/ha whereas the Portsmouth Plan only recommends no less than 40/ha. To be fair to PCC's Transport Planner, he agrees the density is excessive for this part of the City.
These 3 new Apartment Blocks are too high, too close to the Grade 2 Listed Chapel, too ugly and the higher density isn't warranted. Their occupation will also intensify the use of Fairoak Road excessively.
PCC's Environmental Health Officer says the impact on Air Pollution from the road network will be negligible notwithstanding the Transport Assessment estimates nearly 500 vehicular movements daily. It's based on PCC's 2017 Air Quality Strategy which is now accepted by DEFRA as being flawed and PCC are required to produce another so the city could be compliant by 2020. The applicant is also basing their Air Quality assessment on the same flawed assumption.
The Transport Assessment is complex but the basic assumption is wrong:- "Anecdotally and from on-site observations, the junction (mini roundabout at Locksway Rd/Milton Rd) appears to operate well within peak periods, and only experiences congestion as a result of the junctions upstream or downstream". That's the whole point! The local road network is already at max capacity. Figures show a 6.3% increase in traffic in the 2 years 2014-2016
The applicant has relied on the Hospital being at 80% occupancy in 2014 and made calculations of what the trip generations would have been at 100% so that the estimated 220 trips/day along Fairoak Rd and the 251 daily trips from/to the Harbour School end are described thus:-
"There is likely to be a decrease of 43 vehicles during the weekday morning peak period and a decrease of 1 vehicle during the evening in comparison to the former hospital buildings. It is reasonable to assume that the development proposals will reduce daily traffic and therefore provide a material benefit to the local highway network"
This is a irrelevant comment as 80% of occupancy has no relation to the intensity of occupation or, of use. The Harbour School and Child Development Centre for example were at 92% occupancy in 2014 but so what?? Children don't drive cars!
PCC's Transport Planner and the Applicant is relying on PCC's Local Transport Plan 3 but that's way out of date predicting a population of 205,200 by 2026. Last year it was 213,000 in the "Issues and Options" Consultation.
The Transport Assessment's conclusions on accessibility and sustainable transport is also wrong in that it says walking 2 miles to facilities is reasonable whereas that's a distance used by the Department for Transport for calculating requirements for existing towns and communities. It's not intended to be applied to new developments. In any case, we've got the highest casualty rates for pedestrians and cyclists compared to other town's and cities (see above) so is it reasonable to expect new occupants to be non car-dependent?
The Planning Statement makes no direct reference to other infrastructure needs 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. How can that be made to happen? It can't!
The loss of the Villas is not justified. The Heritage Assessment (HA) dismisses these pair of Edwardian buildings ("Fairoak" and "the Beeches") as two of four "undesignated buildings of limited heritage significance."
These buildings could be "Curtilage Listed" because the Heritage assessment quotes PCC's Conservation Planner's insistence on the retention of boundary wall at Locksway Road about 400m away as marking the historical curtilage of Hospital. It's also inconsistent with Historic England's recent advice on Curtilage Listing. Historic England say that they leave these actual decisions though to the Local Authority and unless groups want to pay them £1,500 for proper advice they have to rely on their Councils.
The Heritage Assessment refers to the retention of "Falcon House" and "Baytrees" (Villas at the north of the Hospital) as sufficient representatives of the "Villa" design to justify bulldozing them by stating:- "Two of the villas have already been demolished. Should an additional two be demolished as part of the proposed development, two would remain, preserving the relationship between the hospital main building and the villas. The historical value of the hospital main building, derived from the relationship between it and the villas, would remain unharmed". It's therefore just as valid to say the loss of "Fairoak" and "The Beeches" would harm the historical relationship between the Hospital and the Villas! In any case, both "Falcon House" and "Baytrees" are considered by the NHS as inefficient and best replaced totally contradicting the applicant's claim that they are working with the NHS in preparing a cohesive "Development Framework".
Another claim in the Heritage Assessment is that the loss of the Villas can be justified by virtue of their disassociation from the Hospital and the Chapel by existing tree-screening. That's not a justification:- they're set in a leafy landscape because the very philosophy of Victorian and early 20th Century psychiatric care was to foster tranquility through careful well-planned landscaping.
All the Villas were designed and built by the local architect Albert Cogswell who was originally an apprentice to George Rake the Hospital building's original architect. "Fairoak" and "The Beeches" were created to serve the wealthy inmates and "Falcon" and "Baytrees" for the less well off. All of them preserve a symmetry of design and layout within the Hospital's landscape created to enhance earlier generation's views on psychiatric care. There is therefore a very important local historic significance in retaining these Villas.
The Portsmouth Society has already made an objection on the proposed loss of the Villas on similar grounds.
A higher priority must be given to public interest before private gain to landowners and developers which is why I object to this application with all of these valid points.
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