14th Jul 2023

Penny makes Deputation to the Planning Inspectorate re Milton, St James’s development site.

Further to my work and campaign to support local people across Baffins and Milton Ward and the future development of the former St James’s site in Milton, I have made a further deputation to the City Council and planners regarding my concerns.

This continues on the back of my most recent intervention, highlighting concerns with the City Council’s Planning Department, the deputation below highlights further serious concerns that residents have regarding potential development.


Dear Mr Cassidy,

I enclose my Supporting statement to be read alongside my oral evidence.

As I mentioned in my oral evidence we have worked hard to build capacity in Portsmouth to enable local people to take part is planning and shaping their local community. This included training sessions organised with planning aid to help people start neighbourhood planning forums. This is why I am so concerned that having made huge efforts to try and shape this local development the MNPF are listened to.

I first met with the Forum back in 2014 in respect of the development of the St James’ Hospital site and their wish for the site that it would be developed in an environmentally ethical and sustainable manner with the aim of providing much-needed affordable homes in the city, whilst retaining the sites fundamental character, and much valued green space. The site is much treasured in a city that has very few extensive green spaces and borders Langstone Harbour; an area of scientific and environmental interest.

I have supported the Forum with producing a Neighbourhood Plan for the area to be submitted and considered primarily by the Local Authority, as part of the planning process, and key stakeholders concerned in the sale of and disposal of the site most notably the NHS and Homes England, but also the University of Portsmouth, owing to a campus they retain which borders the site. The NHS (who owned the St James’ site) took the decision to dispose of the site into two parts, one to Homes England (formerly the Homes and Communities Agency) and another part to a private developer; PJ Livesay – with the sale of the land being offered on the basis of a successful planning application. It has resulted in two applications being produced and considered by the Local Authority for the redevelopment of this site.

Throughout this process, the Forum has attempted to engage with all stakeholders concerned with or connected to the site, but has made little headway in respect of their views and aspirations for its development, and so took the step of designing and producing a Neighbourhood Plan. This has not been an easy task, but they have done so with determination and the support of advisors experienced in this field. The Neighbourhood Plan produced (by the forum) was intended to provide a broad and diverse mix of housing, education, and community facilities whilst retaining the character of the site by preserving some of its historic buildings and green spaces, based upon the ‘20 minute neighbourhood concept’ in line with the Environment Plan, and now to the Levelling up agenda by creating much needed affordable homes.

Last summer, I met with the MNPF, Homes England, Officers and Councillors from the Local Authority (prior to the submission of the Neighbourhood Plan) as a means of opening a channel of communication between these groups but also so they could learn more in respect of the Neighbourhood Plan due to be submitted by the Forum. Of particular concern to the Neighbourhood Forum and others attending the session was that the Local Authority had failed to respond to a report produced by Homes England in 2019, which could have enabled a Master Plan to be produced for the site to ensure its integrity and character were retained. The Forum are now deeply concerned that this will result in the fragmentation of the site, which would have poor outcomes, particularly in respect of environmental concerns, but most importantly that it is unlikely to provide the much-needed affordable homes required in the city. Homes England agreed to continue communication with the Forum and asked for a copy of the Neighbourhood Plan to be shared with them when it was completed. Homes England are also open to the potential to amend their scheme with the caveats that they would not want to delay the process for determining the planning applications, further, and that as a Government funded organisation, they would need to be mindful of costs to the public purse, should further delays be encountered. Homes England was particularly concerned at the loss of the developers for the site if it became apparent there were likely to be significant delays in determining the applications.

While not an argument against the developer I wanted to set out the context against which this development has been brought forward.

Material issues.

I agree with the Council’s concerns outlined in its reasons for rejecting the application:

1) In the absence of sufficient information being provided for the Habitats Regulations Assessment, as requested by Natural England, there is no certainty around the mitigation strategy which is required to address the likely significant effects in respect of recreational disturbance, as is identified in paragraph 4.1.8 of the Draft Habitats Regulations Assessment (ref. 200127 0991 HRA V1B) dated 18 December 2020 submitted. As such, the proposal should be refused due to the uncertainty regarding the unmitigated adverse impact on protected habitats in accordance with the Habitats Regulations.

2) Insufficient viability justification has been provided, noting the uncertainty arising from the cost of mitigation under the Habitat Regulations, to demonstrate that the scheme is unable to provide affordable housing contrary to Policy PCS19 of the Portsmouth Plan 2012.

3) The loss of protected trees is unacceptable and the replacement tree planting proposals does not enhance and protect the historic landscape. In particular, the loss of trees and open space on the site known as Matron’s Garden, is wholly unacceptable and is in breach of policies PCS13 of the Portsmouth Plan and ENV1 and ENV2 of the Milton Neighbourhood Plan.

I also have concerns about the impact on local Highways, in particular the proposed changes to the Moorings Way/ Eastern Road junction. I do not think this has been properly thought through and able to accommodate the additional traffic. The moving of the stop line would also create traffic problems, in particular with buses turning at that junction.

I agree with the MNPF that:

1 The level of development is excessive, and overall, the setting of the Grade II Listed Hospital is harmed by the poor layout at the northeastern and western airing courts.

  1. The magnitude of development on open spaces essential to the setting of a Listed Building will create a net loss of quantitative and qualitative open space overall and unnecessarily remove of too many mature TPO protected trees.
  2. The new build house designs are poor and ill-suited so close to an iconic Grade II Listed Hospital building
  3. The level of parking is excessive and introduces “clutter” a more thoughtful scheme would have avoided.
  4. The highway impacts are not properly evaluated and the air pollution assessment is out of date.
  5. The failure to provide affordable housing on viability grounds to the developer is inappropriate when Government landowners are not required to maximise receipts in their disposals of sites with heritage assets.

Both the MNPF and the Council have concerns regarding the ‘Matrons garden’. That would be a loss of green space of note to the local biodiversity.

Finally the proposal conflicts:

Policies MT4; PCS 13; and PCS 19 in the Portsmouth Plan


Milton Neighbourhood Development Plan Policies MH1; PLD1; ENV1 and 2; STJ1; and TSP1 and 2.

I would therefore ask that this development does not proceed as currently designed.

Yours sincerely,

Penny Mordaunt MP