TIME TO WRITE YOUR OBJECTIONS: 1) 14/01615/FUL | Construction of up to 2.2m high fencing to south west boundary. Deadline Friday 23rd January 2015. publicaccess.portsmouth.gov.uk/online-applications/applicationDetails.do?activeTab=summary&keyVal=NGF247MOGUM00 2) 14/01664/FUL | Construction of two-and three-storey dwellings comprising 14no 4-bed houses, 12no 3-bed houses, 2no 2-bed houses and 2no 1-bed flats with associated access roads, parking, cycles stores, open space and landscaping works | Land At St James Hospital (formerly Light Villa And Gleave Villa). Deadline Friday 30th January 2015. publicaccess.portsmouth.gov.uk/online-applications/applicationDetails.do?activeTab=summary&keyVal=NH15MDMO0DK00 If these links fail then you can go directly to the PCC planning pages and search for the references above. To write your comments you need to register first, if you havent already done so. An e-mail will be sent to you for verification purposes. It was quite an easy process, even I managed it! Good luck everybody, remember that the more people who object the better our chances of stopping this mess from happening. Summary: There has been a great deal of work going on in the background by the Milton Forum (one person in particular has been burning the midnight oil) and I am now in a position to be able to offer you an absolute treasure trove of information that will even make Luke Stubbs sit up and listen. There is so much information and so many reasons to stop the building of the properties by Crayfern and prevent the construction of a 7 feet high fence which would carve the beautiful grounds of St Jamess in two, that we suggest you take the parts that are most important to you and add them into your comments opposing these developments. The following is a comprehensive list of reasons why this must not be allowed to proceed: The application fails to properly reflect the Portsmouth Plan (PP) and it incorrectly apply the principles of the National Planning Policy Framework (NPPF). The NPPF requires the planning system to deliver Sustainable Development by performing 3 roles:- environmental, social and economic. 1) Environmentally the development increases air pollution, stresses the Special Protection Areas of Milton Common and Langstone Harbour and does not properly reflect either the NPPF principles or the PP policies on directing development to more publicly accessible locations (PCS17). The application is inconsistent with the Portsmouth Plan policies PCS13, and PCS15.. 2) Socially the proposal does not address the absence of adequate local health-care and educational facilities. The development places too great a burden on the existing community and is inconsistent with the NPPF objective of supporting health, and cultural well being and inconsistent with the Portsmouth Plan policies PCS 14 and PCS19. 3) Economically the costs to the City and to the local community of the absence of adequate infrastructure is excessive. The CIL receipts are insufficient to cover the costs of the deficit in local GP care and school places and at a City-wide and sub-regional level the NHS is already incapable of meeting current demands. The application of a S106 Planning Obligation to address these deficiencies is disproportionate to the number of houses applied for and is therefore an inadequate means of making what would otherwise be an unacceptable development, acceptable. The proposal is therefore inconsistent with PCS16. The applicants Planning, Design and Access Statement (D&AS) refers to the 12 Core Planning Principles in the NPPF and says 4 are relevant to the application:- housing, design, energy efficiency and managing patterns of growth in locations which are sustainable. Disagree:- Core Principle 1 says that Development should be plan-led and empower local people to shape their surroundings. The overwhelming responses to the public consultation on the Site Allocations proposals proves the local people do not want more housing on St Jamess Hospital and in any case, taken holistically, the (PP) says the neighbourhoods of Milton, Baffins and Anchorage Park have limited scope for housing development. Core Principle 2 says planning should be a creative exercise to improve the places where people live their lives. The D&AS does not adequately demonstrate how the development mitigates the existing traffic congestion in Milton Rd or Velder Ave/Eastern Rd which is already an Air Quality Management Area. It falsely claims the development doesnt harm the living conditions to dwellings in the north but it will do at peak times in Moorings Way at the Good Companion junction because residents will be affected by noxious fumes arising from the increased traffic flows. Core Principle 3 promotes sustainable economic development to deliver homes, businesses, industrial units and infrastructure. This application is for yet more homes but St Jamess Hospital has already provided 260 new homes in the past 10 years or so with no compensating infrastructure improvements. Furthermore, the NHS has released land at St Marys Hospital Milton Road for 125 dwellings on the east side, there are 191 under construction on the west in addition to the conversion of Finchdean House to 73 flats. The former East Shore School just to the north of the Good Companion (and only about 500m from the application site) was redeveloped some 6 or 7 years ago for 93 dwellings and across the Eastern Rd from that site is the former Council Depot which was redeveloped for 153 houses in 2004/05. So why housing? Why not a health clinic:- this is a NHS site. Why not a school? Core Principle 5 requires that the differing roles and characters of the areas be accounted for and that green belts be protected. The public consultations, the Keep Milton Green the representations by Natural England, the RSPB, and the Hants & Isle of Wight Wildlife Trust support more recognition of the need to protect the bio-diversity and the parkland character of the St Jamess Hospital site. The PP Open Space policy refers to a lack of suitable spaces to provide the green infrastructure assets to absorb the pressure of new development. St Jamess Hospital could readily provide the additional open/green space the PP aspires to realise whereas housing in this location creates greater stress on the existing green infrastructure assets. The applicants D&AS claims that the development supports PCS13 (A Greener City) but that cannot be factually correct if there will be an increase of 100 plus residents so close to a Special Protection Area. Core Principle 6 supports the transition to a low carbon economy taking full account of flood risk and climate change but if that were true the scheme would have converted the existing building and made more use of renewable energy. I am surprised the houses do not incorporate solar panels on the rear facing roofs to better comply with PCS15 especially as many of them have south facing gardens. Core Principle 7 is supposed to conserve and enhance the natural environment but the Bat Survey reports that a number of trees will need to be felled and the greater number of people demanding use of the nearby Special Protection Area will compromise the indigenous wildlife habitats. It would therefore be far more NPPF and PP compliant if the development was constructed in a less highly valuable location environmentally. Core Principle 8 refers to the re-use of previously developed land and it relates to 7 because although the land has been partially developed previously, it is not brownfield in the proper meaning of the term:- this is intended to mean industrial uses. There are more appropriately defined brownfield sites to be developed closer to the City Centre such as at the Hard (Brunel House) and/or the former Tricorn site in preference to developing on the St Jamessite. Core Principle 9 promotes mixed uses and acknowledges the benefits of open land for wildlife. So does the PP. This application is to develop a site that is mostly green! Core Principle 10 promotes conservation of heritage assets which is another reason to consider re-using the existing building. Core Principle 11 concerns concentrating development in the most accessible locations to make the fullest use of public transport, walking and cycling. The (PP) proposes that housing development should be directed towards the City Centre and more accessible locations with good public transport connections (PCS17). Eastney Peninsula is probably the only location further away from a railway station in this City than the application site! The applicants D&AS claim that the site is in a sustainable location in relation to shops, schools and employment is totally false. Core Principle 12 supports local strategies to improve health, social and cultural well-being. Repeat, why not use the site for a health clinic or a school? The PP states the Council has a key role in promoting environmentally sustainable development. The PP policies on Infrastructure and Community Benefit assumes 401 houses in the Eastern Coastal Zone need to be constructed for the entire Plan period to 2027 and it demands the required infrastructure be ready before completion of the development. There has been no expansion or improvement to healthcare and education facilities, and no effective highway improvements or additional open space provision for this magnitude of development. In summary, the applicant claims the land-use is sustainable whereas in reality, increasing the number of houses in this neighbourhood is totally unsustainable because it creates too great a demand on an already congested road network, too significant a demand on local schools which are straining under excessive class numbers and too big a stress on oversubscribed GP facilities. I estimate there is no GP Surgery within 5 sq km of this area bounded by Milton Rd/VelderAvenue and Henderson Rd/Ferry Road. Development in this location is therefore inconsistent with PCS17. Any further residential development at St Jamess Hospital should therefore be rejected. A more appropriate use of this site is a GP led Health-Centre but otherwise the site could be a Nursery/Small local infants school to serve the 260 houses already built on the St Jamess site in the past 10-15 years. I deliberately omitted Core Principle 4:- ita about design and thats too subjective. Finally and supplemental to the above there is an Air Quality issue locally as well as nationally and the approval of this proposal could quite conceivably place an unnecessary health risk to residents near to and adjacent to Eastern Road/Velder Avenue and Milton Road as well as to pedestrians and cyclists from vehicular exhaust emissions. This locality is already an Air Quality Management Area because of the excessive vehicular traffic pollution and therefore to grant consent for a further 30 houses with 61 car-spaces could be a serious breach of Portsmouth Councils responsibility to its residents. I refer to the Councils own obligations to comply with the National Air Quality Strategy where they publish Tim Yeos quote as chair of the Environmental Audit Committee air pollution probably causes more deaths than passive smoking, traffic accidents or obesity yet it receives very little attention from the Government or the media. In the worst affected areas this invisible killer could be taking years off the people most at risk such as those with asthma. DEFRA is more explicit:- it confirms everyones lives are being shortened by 6 months due to airborne pollution.
Posted on: Tue, 13 Jan 2015 21:06:20 +0000
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