Ref: A073350/SM/sm Date: 13 September 2013

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1 Ref: A073350/SM/sm Date: 13 September 2013 Ian Parkinson Development Control Team Leader Planning Portsmouth City Council Civic Offices Guildhall Square Portsmouth PO1 2AY Dear Ian LIGHT & GLEAVE VILLA SITE, ST JAMES HOSPITAL, PORTSMOUTH PROPOSED RESIDENTIAL REDEVELOPMENT ENVIRONMENTAL IMPACT ASSESSMENT SCREENING OPINION REQUEST TOWN AND COUNTRY PLANNING (EIA) (ENGLAND) REGULATIONS 2011 On behalf of our client NHS Property Services Ltd, we write to formally request a screening opinion as to whether Environmental Impact Assessment (EIA) is required for the above proposal. This request is submitted further to our meeting with you on 22 August 2013 where we presented an initial proposal to redevelop the site to provide 30 dwellings, open space and associated development. This letter describes the proposed development, analyses the character of the site and its context, and considers the impact of the development with reference to the EIA Regulations. It concludes that, having regard to the developments character, location and potential impacts, it will not have significant environmental effects and, therefore does not comprise EIA development. Application Site and Surrounds The site is approximately 1.24 hectares in size (see site location plan) and previously contained the Light and Gleave Villas, both of which have now been demolished. The site is located within the grounds of the listed St James Hospital and includes a number of trees which are protected by a tree preservation order. The hospital and its grounds lie to the south and west of the site. To the north is a residential area and to the east is the Langstone Portsmouth University Campus and facilities. Proposal The proposal is to submit a full planning application to provide 30 new dwellings, an area of open space and associated infrastructure and landscaping. We enclose a provisional site layout (ref: P4) showing the proposed distribution of dwellings across the site. EIA Having regard to both the EIA Regulations and Circular Guidance (02/99), the proposed development is not Schedule 1 development where EIA would be mandatory. The Circular states that development listed in Schedule 2 requires EIA if it is likely to have significant effects on the environment, by virtue of factors such as its size, nature or location. Paragraph 29 states that Schedule 2 development is development of a type listed in Schedule 2 which: a) is located wholly or in part in a sensitive area as defined in regulation 2(1); or

2 b) meets one of the relevant criteria or exceeds one of the relevant thresholds listed in the second column of the table in Schedule 2. The application site is not located within a sensitive area as defined in regulation 2(1). However, the proposed development is considered to fall within Class 10(b) of Schedule 2 to the 2011 Regulations - i.e. an urban development project where the area of development exceeds 0.5 hectares. Schedule 3 of the Regulations sets out the selection criteria which must be taken into account in determining whether a development falling in Schedule 2 is likely to have significant effects on the environment. The three broad criteria (including a number of detailed considerations in each criterion), are: 1) characteristics of the development; 2) the environmental sensitivity of the location; and 3) the characteristics of the potential impact. In addition, the Secretary of State s view (Circular 02/99, paragraph 33) is that, in general, EIA will be needed for Schedule 2 development in three main types of case as follows: 1) for major developments which are of more than local importance; 2) for developments which are proposed for particularly environmentally sensitive or vulnerable locations; or 3) for developments with unusually complex and potentially hazardous environmental effects. Characteristics of the Development The character of the development is that of a small residential development located within the parkland setting of the existing hospital site. The development will provide residential (open market and affordable) dwellings to meet local needs. It is not of a scale or nature that is of more than local importance. It will not have any regional or national significance. Looking at the detailed criteria: a) Annex A of Circular 02/99 is relevant in considering the size of the development, confirming at para A18 that EIA is unlikely to be required for redevelopment of land unless the new development is on a significantly greater scale than the previous use, or the types of impact are of a markedly different nature or there is a high level of contamination. The scale of development at 30 units is not considered to be significantly greater in scale than the former use of the two Villas in association with the hospital. The likely impacts of residential use, compared to the former healthcare use of the site, again are not considered to result in any significantly different environmental effects. The site is not subject to high levels of contamination. We also note that in considering sites that have not been previously intensively developed para A19 states that EIA is more likely for development of 5 hectares or more or where it would result in significant urbanising effects (giving the example of a new development in excess of 1,000 dwellings). Clearly the proposal falls considerably below both of these relevant thresholds. b) This development is not being proposed in parallel with other development, although we are aware that reserved matters approval has recently been granted for 13 dwellings on the Skillploy site to the west of the site. As such there is assessed to be no cumulative impact. c) In regard to the use of natural resources, the proposal makes good and efficient use of an existing previously developed site and the proposed development would not give rise to any significant implications in respect of use of natural resources.

3 d) The proposed development is unlikely to create any significant implications in respect of the production of waste. e) The proposed development is unlikely to be a significant potential source of either pollution or nuisances. f) There is unlikely to be any undue risk of accidents in relation to the proposed development. Accordingly, the characteristics of the development are not such that there are likely to be any significant environmental effects arising. Location of Development a) The site forms part of the wider St James Hospital complex. The Light and Gleave Villas were last occupied for healthcare uses but were surplus to requirements and have both been demolished in recent years. The site is considered to be suitable for the limited level of development proposed and this would not affect the operation of the main hospital. b) It is considered that, due to the previously developed nature of the site, the development of the site for housing as proposed will be unlikely to have significant environmental implications in respect of the relative abundance, quality and generative capacity of natural resources in the area. Indeed the site is allocated for development in the Development Plan. c) It is further considered that the development will be unlikely to have any significant environmental implications on the absorption capacity of the natural environment. In this respect we note that the site is approximately 400m from the Chichester and Langstone Harbour SPA and Ramsar designation. Immediately to the east of the site are playing fields forming part of the University campus. These have previously been identified as being occasionally used by Brent Geese for foraging. These playing fields are not considered to have potential for significant future use by wading birds due to the existing levels of use and surrounding development (HRA for the Portsmouth Site Allocations DPD: Screening Statement). The application site itself is assessed to have no value for geese or wading birds given its enclosed nature and the height and density of tree cover. The application will be supported by Ecological Reports and suitable mitigation measures, in line with those identified in the Council s Screening Statement, will be incorporated in the proposal (including appropriate boundary treatments, retention of trees, development limited to 2 stories in height and appropriate lighting levels). The need to provide recreational space has also been considered so to minimise pressure on the adjacent playing fields and therefore impact on potentially valuable habitat for Brent Geese. The site will have no direct access to the playing fields operated by the University, which will be separated by substantial boundaries, fencing and vegetation. In addition to generous sized gardens, open space will be provided on site to help meet the recreational needs of future residents. There will also be access to the existing recreational spaces to the south on the St James site. As such taking account of the low number of units (30) and the nature of development proposed, there is assessed to be limited increase in pressure for recreation on valued habitats in the vicinity. Accordingly, the proposal will not give rise to any significant environmental effects in respect of conservation of natural habitats, wild flora or fauna.

4 Characteristics of the Potential Impact Firstly we note that EIA was not required in connection with the proposed redevelopment of the nearby Skillploy site for a similar form of development. The character and nature of the environmental impacts are unlikely to result in any significant change from the previous use. Whilst there would be some increased traffic from the development, the impact in terms of congestion and air quality would not be so significant as to require EIA. The proposed development remains unlikely to create any undue impacts, having regard to the criteria under this heading, namely: the extent of the impact; the transfrontier nature of the impact; the magnitude and complexity of the impact; the probability of the impact; and the duration, frequency and reversibility of the impact. Planning Application Supporting Documentation Notwithstanding the above, and as discussed at our recent meeting, the planning application will be accompanied by a range of documentation to address matters pertinent to the site circumstances and development proposals. These will include: Design And Access Statement Planning Statement (including SCI and Affordable Housing Statement) Transport Statement Arboricultural survey including AIA and ADS Desk top archaeology study Ecology phase 1 extended survey including, addressing the potential for impact on the nearby SPA Contamination report Landscaping proposals/strategy Flood Risk Statement/Drainage Statement CfSH Pre-assessment We will seek to confirm the extent of supporting information with you but consider that these documents will allow a full and proper assessment of the pertinent issues and any potential environmental effects arising from the development through the planning process. Summary Whilst the proposals are Schedule 2 development, having regard to the nature of them and the specific site circumstances, we consider there is no requirement for EIA to be undertaken, as the development would not give rise to significant environmental effects. We look forward to receiving the Council s Screening Opinion in due course. Yours sincerely, Simon Metcalf Associate Director enc

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