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PDPLA Response To The Portsmouth Local Plan 'Issues & Options' 2017

PDPLA Response To The Portsmouth Local Plan 'Issues & Options' 2017

The Portsmouth & District Private Landlords Association represents nearly 500 residential landlords in Portsmouth and residential landlords (the 'PRS") provide approaching 30% of all housing in the city.

What is often overlooked is that the PRS gives the city and the businesses within it the flexibility to develop and grow. As IBM and Zurich and others moved from the city and the University started to grow, there were inadequate student halls to accommodate the demand. The PRS stepped in and met the need which allowed the University to grow unhindered from around 10,000 students to its current 23,000.

Now, as student halls finally arrive to fill that particular void, the PRS is adapting once again to meet todays need which appears to be accommodation for the rapidly growing workforce in the Naval Base.

Whilst it is unusual to receive a request for 50 or 60 rooms, it is not uncommon - we had 2 such requests in August, one from Douglas Haig of Cardiff, who said:

"If it wasn't for the PDPLA then it's very likely that my father wouldn't have been able to take on the work, or certainly not been able to have met the requirements that were asked of him by the main contractor that works for the MoD.

My father's company manufactures and fits pipes of all sizes and for most system types (from waste water to weapons lift hydraulics) within commercial and military ships. One of their current contracts is the fit out of the new aircraft carriers, Queen Elizabeth and Prince of Wales and they were required to continue works on the Queen Elizabeth when she came to dock in her home of Portsmouth dock yard for the first time after her sea trials.

His company is based in Portsmouth but the specialist skills and volume of those skills required to complete the work required in time by the Navy meant that in addition to the sizeable local workforce an additional 50 men were also required. The contract is for a period of 10 weeks and extra services such as bills and linen changes were required. Hotels were full for much of the contract period and realistically too expensive over such a period to consider. Our experience of the Airbnb market was mostly a poor standard and not a great service. The larger letting agents were not interested in assisting us.

Tony Athill of the PDPLA kindly agreed to contact his members to see if there was any assistance they could give me, and predominantly the response was superb. I dealt with approximately 15 landlords that showed a high level of education and understanding of the market and also of our needs. The quality of the properties has in general been very high with detailed information about the property and clearly meeting their compliance requirements.

It was noticeable that the properties that we had access to were those that were mostly new to the market (as in recently developed), the amount of available property in the area was surprisingly low and realistically, if it hadn't been for Tony and the members of the PDPLA, I doubt that we would have been able to source the amount of property that we required.

It is likely that given the demands of the aircraft carriers that they will have to continue to import bulk labour for periods of time and the available accommodation going forwards will be a consideration as to whether the contract demands and timescales can be met."

This is just one of a number of examples - but our underlying assertion is that the importance of the PRS, especially regarding shared housing, to the viability and development of the city is frequently underestimated and many actions of the planning committee, such as the continued demonization of HMO"s and the resistance to many new developments, hinders the city as a whole and discourages the refurbishment of individual properties which is required if whole areas are not to fall into dereliction.

Specific Responses To The Issues And Options Document...

Vision and Objectives

We agree with the vision statement, "To make Portsmouth the premier waterfront city with an unrivalled maritime heritage - a great place to live, work and visit" however the Issues & Options focus within the Local Plan has too little focus on objectives 3-6, none on 7 & 8 and very little on objective 2, so in its current form we see it as unbalanced and primarily focused on Housing.

Our suggestion would be a much more inclusive approach - the Local Plan needs to be the summary  or umbrella of a range of supporting plans, some of which are in development, others such as the CCG don"t outlook far enough and others do not appear to exist yet.

Population Growth & Housing

We suspect there is a flaw in the underlying PUSH logic which resulted in the current 14-17K new dwellings requirement. The analysis extrapolates growth between 2000 and 2010 but does not identify that much of this growth is due to the increase in student numbers. As that has now peaked or will do by 2020 according to the OBR (http://budgetresponsibility.org.uk/docs/dlm_uploads/Student-numbers-July-2015-Economic-and-fiscal-outlook.pdf) we would argue that there is a case for revisiting this analysis with PUSH and ensuring the city strives for the correct number of dwellings with all associated investment from central government as opposed to a mistakenly high number for the same investment.

The PDPLA does not accept AH1a or AH1b.  Whatever policy PCC adopts, it needs to be consistent and to apply to all developments. With this in mind, student halls should not be exempt and developers should not have the option of 'removing the affordable element when it proves not to be viable". It is likely that PCC will need to take a less onerous approach to affordable housing to ensure developers remain interested in proceeding, but once a suitable balance is found the solution will be fairer and clearer for all involved.

SH1b is preferred. Obviously there will be some sites where it is necessary to use a national developer but in the majority of cases, we would argue that smaller sites or individual plots are much more likely to meet the needs of the city and will have the benefit of creating local employment and putting money into the local economy compared to the opposite in both cases when passing large blocks to national developers. We would go further and state that a number of our members have shown interest in selling their portfolio if they could invest instead in new build in the city - this would have the double benefit of freeing up existing homes for 1st time buyers and also, if done properly, creating more affordable housing in the city.

We have no view on sites for travelling communities.

We argue strongly that the current approach whereby councillors demonise HMO"s is counter productive and damages the city"s ability to adapt and grow. With this in mind, we favour HMO1b.

The University has stated that there may already be too many halls rooms under development and there is definitely too narrow an offer - yes some students want and can afford 'top end, en suite, pigeon-hole rooms" but many do not or cannot. Therefore, we either need to monitor and manage such developments in line with need (hard to do and unlikely to succeed) or we need to ensure that any future accommodation can be used for other tenant groups should student numbers change.

There is mention / discussion of the need for student accommodation but little consideration of the needs of the growing transient workforce, young single people on low incomes who are only eligible for Housing Benefit at the room (in a shared house) rate or are  in low wage jobs As owning a place of your own is an aspiration of many but requires a longer period of saving for a deposit than it used to, providing more quality shared accommodation (rooms to rent) so they do not need to rent one bed flats and can save faster would help the younger population and free up one bed flats couples, intern freeing up homes up the ladder. 

It is understandable that councillors supported by local residents have a NIMBY approach /to shared housing striving, they say they want mixed and balanced communities but in reality people want to live in communities similar to their own. 

In response to question 3, we favour increased use of permitted development to allow existing retail and commercial properties to be developed as residential housing.  There are many retail 'centres" in the city and most could probably reduce by 10-15% without impact. This would add a great deal of residential space with limited impact.  The benefits could be even greater if encouragement were given for demolition and redevelopment of taller buildings which retain a retail element on the ground floor.

The Local Economy

The current approach appears too focused on existing 'work spaces" with little investment in the north or east of the city. This will only compound travel issues as employees seek to travel from home to workplace.  This approach needs to be rebalanced - perhaps Cosham can be served by increased employment at Lakeside, but Copnor/Milton/Eastney either needs better East-West access to workplaces on the western side of the island or more employment locally. St James, Langstone Campus and Fraser Gunnery Range all offer options other than housing and there are swathes of the 'industrial core" to the east of the railway line which need to be updated and could favour mixed developments quite favourably.

Fraser would be an ideal site for a business / professional services / finance / insurance business park and residential development, but a link road from the Eastern Road across the new Milton Common bund and then onto Ferry Point would be a pre-requisite.  Such a link, providing a permanent lake at Eastney Lake would provide huge boating / marina / associated industries and residential opportunities in what is now an underdeveloped and neglected area of the island, whilst also providing a viable alternative to the current inadequate 'Eastern Corridor"  transport route for the 42,000 people who live in Baffins, Milton and Eastney.  (For comparison, 42,000 people is equivalent to Corby, Peterborough or Evesham - all of which have bypasses - we have Milton Road!).

Neither LE1 or LE2 really suit the need in the city. LE2 has some elements of benefit - BAR and Lakeside make sense, but the MoD need to be pushed to either free space or make better use of it and the concept that the city centre would appeal to any major corporate user is a fallacy, what employers of this type now look for is ease of access, large footprint, copious on-site parking as they find in locations like Whiteley. So zoning Portsmouth city centre for 'new office uses" is a failing strategy and risks missing much more viable opportunities.

Question 5: One new opportunity hitherto not considered is large commercial / professional employment use at the Fraser Gunnery Range site in Eastney, coupled with top end residential.

From a retail perspective we favour R2a - Relaxing existing policy on city, town and district centres to provide greater diversity in secondary frontages including residential, employment, cultural and leisure activities.

Question 7: What other options do you think the council should follow in the new local plan? A big weakness in the Portsmouth economy is that lack of 'makers" - most of the manufacturing we have is 'assembly" rather than bottom up 'design and build" and as a result, we are always likely to remain under-skilled and under-paid and also, most likely to be disenfranchised or redundant as needs change. There are small steps that may create some of the capability that is missing - the City Technology School may produce some alumni with the necessary basic skill set, some employers such as BAR will help engender it, but the city does little if anything to encourage an environment where entrepreneurs would want to set up or where startups may incubate. The city needs FabLabs and MakerSpaces, it needs shared / communal workshops. Indeed, if we are to build 17,000 houses and there is strong encouragement from the general public that these be 'affordable" - shouldn"t the city be encouraging new building techniques and materials - a factory produced low cost housing solution with a pipeline of say 200 houses / annum committed by PCC would give a local business the basis on which to invest and grow to become a national provider, to the greater benefit of the city.  Just an example but a good one, in terms of showing the type of skills and capabilities the local plan could be encouraging but which currently, it does not.

The other big gap in the overall plan is a lack of a conference centre. The south coast is poorly served - the Brighton Centre is ageing access is poor, Bournemouth has been updated but has similar issues, there is nothing in between or to the north before London. A large, flexible seafront or harbour facing development offering a range of spaces which can handle small meetings up to say 4-5 thousand person events with associated hospitality and hotels would fill a major hole in the cities economy, create jobs, provide extensive hotel accommodation and significantly increase visitor numbers. Whilst individual initiatives of this nature are not the purview of the planning team and thus are not likely to major in the Local Plan, they need to be part of the coordinated whole of which the Local Plan forms a part. The PDPLA have organised 3 successful landlord shows and struggled to find an ideal venue……. The city is currently poorly served with modern, flexible conference facilities and the plan does need to recognise this.

So for question 9, see the above  paragraphs.

Health & Wellbeing

The only option, HW1 (Seek to enhance health and well-being through new development in Portsmouth) is not something anyone would disagree with, but it is too vague to add any value to the Local Plan.

The plan needs to state today"s objectives in this area - which current green spaces are protected and which could be better used? Will the council continue only to place adventure playgrounds on council estates or will similar facilities be made available to other residents? Is there an intention to add street lighting to the city parks to make them more appealing to joggers and others during the 6 months of the year they are dark outside of working hours? Where are the priorities for cyclists - both to improve existing cycleways and to get them out of harms way on our roads and thus allow cars to flow more freely?

Heritage, Design & The Built Environment

Option H1 appears too limited. Whilst we should conserve and enhance heritage assets, assuming anything over 50 years old is a heritage asset and is a mistake which restricts progress and development.

Option DD1 proposes that PCC follow NPPF guidelines and seek higher residential densities in areas of high accessibility. We agree with this and believe that areas between Somers Road and Victoria Rd N be classed as highly accessible.

Adoption of minimum internal space standards as proposed in SES1 would have a negative impact on the PRS. The PDPLA estimates that around 200 dwellings would  be lost if these standards are applied without regard to additional space available in communal areas in these dwellings

SES2 is also too weak - any new home should be built with widened doors and level access, as should any new business or commercial premises.

Option TB1b proposes that tall buildings be encouraged in new locations across the city. We agree with this approach - whilst context is important, some of today"s planning decisions stifle much needed development.

Moving Around The City

We face a difficult transition during the plan period. Today we have a 50 year old infrastructure which is not fit for purpose and PCC"s own traffic team have predicted a significant increase in traffic in the next few years.

By the end of the plan period, we can expect many electric vehicles reducing congestion and pollution and also, a high degree of autonomous driving which again will reduce congestion and delays due to accidents, plus may start to address some of the issues we see today with parking.

Our challenge as a city then, is how to get through the next 10 years or so such that our actions improve flows in the city where possible, do not worsen the situation anywhere when avoidable, yet with the minimum of investment knowing that changes in technology will reduce many of the issues we see today by the end of the plan period.

There are one or two hotspots that have to be addressed.  There is no east-west unrestricted traffic flow across the city, the eastern corridor needs to be upgraded or replaced and the M275 needs to feed better into the local arteries that it currently leads into.   All else can probably wait, though we must take the opportunity in the interim to upgrade traffic control and monitoring systems such that they enhance as oppose to impede and are available once the technology is able to use them.

With these points in mind, option TR1a favours congestion reduction by improving capacity and removing bottlenecks whereas TR1b favours reduction of traffic by introducing alternatives. This is not an 'either/or" decision, we need investment in both. In the short term, investments need to be made reduce to congestion as all of the options in TR1b take longer to implement and are dependant on how current technologies develop.

Housing Requirements Summary

Given the choice of HT1a (14,560 new dwellings) or HT1b (17,020) we vote for option HT1a on the basis that a 20% increase in housing in the plan period is probably too much unless significant infrastructure investment can be secured. See also the earlier comments - we believe the PUSH predictions to be based on incorrect analysis of the data and are overstated.

We agree that with this level of planned housing we need provision of space for new businesses and  support ET1a targeting 120K sq. m of new employment floorspace. We would add that a lot of this could be accommodated in the MoD land around the island which is currently poorly utilised

The retail option (RT1) does not really offer any option. Continuing to focus on Portsmouth"s Commercial Road without any major investors is futile - much better to extend Gunwharf, invest in the smaller centres and allow a range of alternative developments in the Commercial Road area

We would add the old Fraser Range as a strategic site for development, though not necessarily predominantly housing. However, that part of the island needs better transport access to encourage development"


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