Housing Application on Former Harbour School, St James' Hospital Grounds
Martin Silman
Housebuilder "Vistry Group" has submitted a Plan to build 58 houses and 90 plus car-spaces on the former Harbour School site on St James' Hospital. It conforms with their public consultation on 19th July at Milton Village Hall. The site forms part of the Homes England parcel of the Hospital otherwise known as Phase 1.
The Forum responded that we thought it a decent scheme in terms of layout and design with a pleasing central amenity area ("Orchard Park"), helping give it an attractive "sense of place". However, we commented the 50% loss of Biodiversity and the excessive parking was unacceptable.
The layout of the houses; the "streetscape", with different building finishes interspersed with street trees and green verges is a vast improvement on the PJ Livesey scheme at the main Hospital where ugly looking three-storey houses interrupt views of the Hospital and where parking for 389 cars despoil what's left of its parkland landscape.
EV Charging Points are provided to every dwelling and there's ample cycle storage:- 124 long-stay, and 13 short-stay spaces. There is a footpath on it's western boundary with Cheriton Rd linking Oakdene Rd with the site and the residue of the privately owned Hospital land to the north.
The use of gas for heating and hot water is disappointing (but permissible under current Building Regs). In part, this is mitigated by the installation of Solar PV Panels for each house. Some of the house types show chimneys but these must be decorative as solid fuel burning on new houses is no longer permissible.
The buildings exceed energy efficiency requirements under current Buildng Regs. All of the houses are served with sustainable drainage systems and rain gardens will be provided throughout the site. It's disappointing that parking areas use block paving instead of permeable paving (such as "grass-crete").
Superficially the scheme looks good. However, the number of Affordable Homes is deficient. Vistry Group is providing 17 affordable homes but not the 18 to comply with Planning Policy. They say they'd be prepared to supply more but it would be on condition they wouldn't be expected to meet Community Infrastructure Levy (CIL) payments in full. CIL helps fund community facilities (roads, parks and open-spaces, libraries, schools, social care etc). We'd said that the numbers needed to be nearer 50% (or nearer 29) to compensate for their absence on the Main Hospital given the "trade-off" of the expense of the Hospital compared to development of the Harbour School site which is virtually "greenfield".
Many residents will question why housing is appropriate to replace a Hospital and a School when we have deficiencies in health and education facilities as well as highway capacity, and green spaces. The answer is because we can under our broken "planning system" which is what that the Milton Neighbourhood Plan wants to address.
We must accept housing is a valid option. St James' had been identified as suitable for housing since 2001. It's therefore not feasible, to oppose housing outright. All we can do is challenge the "what" and the "how" the housing use is proposed.
We didn't have a Neighbourhood Plan when the Livesey scheme went to Committee in Jan '22. We do now. The excessive car-parking and the magnitude of on-site biodiversity loss, is a serious problem and would outweigh the proposal's advantages, irrespective of the magnitude, or otherwise, of the Affordable Housing.
PARKING:- The application could be for 96 car spaces or 92 depending which document supporting the scheme is viewed. Either way, that's excessive. The Milton Plan's standards are 75 with a further 7 for visitors. The reduced parking ratio/dwelling was suggested by PCC as an objective they'd support. AQMA 9 and heavy local congestion is the justification. Congestion at the Milton Rd/Velder Ave Jnct'n was identified by the Council's Highway Consultants as operating over capacity five years ago and by 2041 queues are estimated to be 116 vehicles going northbound at peak times. This excludes weekends and Summer Holidays. 116 vehicles extends to 688m according to the Consultants which means stationary traffic going beyond Priory Crescent by over 400m or a quarter of a mile.
The Consultants acknowledge the jnct'n cannot be physically altered and can only offer a modal shift to "bus priority" as a possible remedy. We think that's too late. In any case, more parking creates more car usage as evidenced by research for the London Plan. When added to the excess of parking on the Hospital site (19 more spaces at Appeal than approved at PCC's Committee of 12/01/22), the cumulative overprovision on St James' compared to the Milton Plan's standards is 83 or 87 spaces depending on which document is applied. The cumulative total for the Hospital would become 481 or 485.
This overprovision of parking undermines health interventions to increase active travel. We questioned at the Hospital Planning Inquiry how traffic lights at the Milton Rd/Locksway Rd jnct'n could work going south so close to the Goldsmith Avenue signals With a 116-vehicle queue towards Velder Ave, it's not going to work northbound either.
We're also aware that air pollution is shortening our lives, and asthma in our children is becoming widespread as evidenced by the Council's Planning and Health document of 2020 which shows just how much unhealthier we already are compared to elsewhere in the UK.
More parking = more cars = more pollution and more traffic accidents.
BIODIVERSITY The scheme lead to an "On-site" Biodiversity Net Loss of 50%. That's unacceptable in an Authority with a Nature "Emergency".
The applicant is already required to make financial contributions under the Solent Recreation Mitigation Strategy to "mitigate" harm to wildlife from increased human activity. In addition he must pay compensation to offset nutrient contamination of Langstone Hbr. (sadly, all permitted by Natural England). None of this helps wildlife recovery locally. All it does is offer the chance that it might recover elsewhere.
The Milton Plan requires new dev'ts to achieve a Biodiversity Net Gain. It was intended that new dev't could increase biodiversity within the site, achievable perhaps through private and public gardens/spaces; hedgerow planting; swift and bat boxes etc. Policy in the current Portsmouth Plan, requires new dev't to retain and protect biodiversity and produce a net gain where possible. It says "unavoidable" negative impacts on biodiversity should be mitigated. Again, that's not good enough. The applicant is seeking to mitigate the Biodiversity Loss on an "accredited and identifiable site being developed and secured in conjunction with Wild Capital". In our view, this is unacceptable. National Planning Policy shouldn't "undo" Local Planning Policy, recently made. It wouldn't cost much to restore the pond on the retained NHS site near the "Orchards".
Research by the British Ecological Society investigated at 20 housing applications in Kent between over half a dozen or so years to 2020 and none showed any evidence that biodiversity off-setting and mitigation worked.
Excess parking is avoidable. Car-parking takes up valuable space that could be planted with trees, bushes or hedgerows.
Finally, it's not even certain at this stage what the full biodiversity/ecological conditions actually are. With an overall loss of 1.14ha permanent grassland; 0.12ha of bramble and mixed scrub; and "other" broadleaved woodland and urban trees (approx 700 sqm); the Aug 2024 Prelim Ecological Survey concluded further ecological assessments should be undertaken; and done so prior to submission. Meanwhile, the Protected Species Report of July 2024 concluded the Bat Survey results couldn't be published because the Survey itself can't be completed until the end of October. It identified the dev't would have negative impacts on bat roosting in trees and foraging opportunities. It says without avoidance of damage and/or mitigation, an offence will be committed.
The application has been validated by PCC with a closing date of 18th October prior to a full understanding of ecological impacts, and against the advice of the applicant's consultants.
This application should be refused on excessive parking, biodiversity loss grounds and non-compliance with Local Planning Policy on Affordable Housing.
The Forum expects to submit it's Objection over the coming weekend 12th and 13th October. For residents wishing to comment they should e-mail or write to "
Rod Bailey
Milton Neighbourhood Forum
10th October 2024