Submission to the Planning Enquiry

Sutton 1 in 4 Network Submission to the Public Enquiry into

Land at Springfield University Hospital

Appeals by London (South West) & St George’s Mental Health NHS Trust

London Borough of Wandsworth References: 2010/3703 and 2010/3706

Planning Inspectorate References: APP/H5960/A/11/2156427
and APP/H5960/E/11/2156424

Sutton 1 in 4 Network is a Service User group of people that have had mental health issues, some enduring mental health conditions and some recurring over many years. Almost all of the members have been in patients. Many have endured the care regime at the Springfield site and also many have been treated at the Sutton site before it was relocated to Springfield ostensibly on a ‘temporary basis’ which now transpires to becoming permanent! Many have been treated at both sites.

Sutton 1 in 4 Network’s Service Users Coordination Group have become increasingly concerned since being recently involved and have voted overwhelmingly against the Trust’s current planning applications numbers APP/H5960/A/11/2156427 and APP/H5960/E/11/2156424.

We therefore strongly oppose the current plans to build on the site and respond to the Trust’s statement of case and statement of common ground below.

It should be noted that the Trust have failed to consult Sutton Service Users in a manner that would actively account for service user concerns despite having many years to do so. The consultation process that they have undertaken over many years has been merely nominal to service user concerns and until very recently when it has dawned on the Trust that those service user concerns should be at the very heart of all that they do, note para 8.27 of their Statement of Common Ground.

On Tuesday 11th October 2011 an open and public meeting having been requested by service users, was attended by service users and their representatives across the 5 boroughs to discuss the current proposed plans and how the Trust were merely seeking support at the Public Hearing for the basic provision of allowing building work to be undertaken on the site. Mr Andrew Simpson was invited to the meeting and stated that the ‘footprint’ of the 25, 000 square metres was sufficient to satisfy one of the main service user concerns ie one of private enclosed gardens and views of green open space. He stated that once permission to build on the site was obtained then the detailed planning for the ‘hospital’ or a residential hospital type accommodation in the blocks in the footprint and if need be alternatively in the blocks to the south west of the site could be planned and accommodated and  not as they appear on the current plans.  The meeting was very skeptical over hearing this new approach and, of course, this is not to be considered the Public Hearing.

From the meeting it is our understanding that the Trust had bought the Metropolitan Open Land (MOL) and that building on that land would not be allowed but then also stated that should permission not be granted, that other developers in the future would in all likelihood obtain permission to build on the land. We note that there is intrusion of new buildings in the proposals on to the land in any event and fail to see how these two statements are compatible. How can the Trust build on the land, state they would not allow building on the MOL, which is in their ownership, but then state that other developers at some unspecified time in the future may also build on and make the MOL in to a new housing estate? This is very contradictory.

It was also revealed in the meeting that recent Ministry of Justice regulations dictated that substantial containment ie fencing or walls was essential when providing the secure enclosed open spaces for detained patients under the Mental Health Act. With the reduction of beds, publicly stated by the Chief Executive proposed to be 15 to 18 per ward in the near future and the national inclination to treat patients in the community, we fail to see how the footprint will accommodate this essential imposed regulation. It is most unfortunate that the Trust have failed to address the overriding concern for the planning application that being the position of the foot print for the new hospital facilities and their overriding duty to care for service users on the land that they have inherited from past Trust management as opposed to developing a housing estate for the public generally.

The explanation that the alternative to building permission being granted was essentially to “sell as much of the site as possible without planning permission as there would not be funds to develop an alternative plan. Thus the money received would not be sufficient to relocate to any of the other sites the Trust own.” When questioned it was stated that the Trust would not be able to afford anywhere else.  Sutton 1 in 4 Network are skeptical of these statements and believe them to be leverage by the Trust in order that service users support the appeal. Again mixed messages are constantly being given to service users.

We see no reason why plans to develop the site without the new hospital facilities thereon but substituted by additional residential units could not be submitted for consideration and the new hospital facility moved off site. Further, as no rational alternative to the Springfield site has ever been explored or considered we believe that the Trust, NHS London and Wandsworth Council, have failed in their statutory duties to consider all alternatives for and on behalf of all 5 boroughs and the 10% of nationally sourced patients. As some 80% of the Trusts patients are non Wandsworth based it is reasonable to assume that the planning process should take account of the majority and not the minority of patients living and sourced from the London Borough of Wandsworth.

Sutton 1 in 4 Network does not relish strenuously objecting to the Trust’s appeal. We do so because we are drawn to the inescapable conclusion that as the current plans are the only plans that are being appealed, we cannot and should not be sidelined with statements from the Trust, that have no effect in law. All the promises under the sun, as to unspecified detailed future plans for the facilities available to service users, will not change the fact that this public enquiry in the Trust’s appeal on planning applications numbers APP/H5960/A/11/2156427 and APP/H5960/E/11/2156424 do not include the elements that the Trust are lately trying to secure service user support on.

The fact that the Trust have used tactics to try and elicit service user support, especially by stating that money will run out to enable new and adapted plans is most unfortunate. The Trust has, in our opinion, mismanaged the planning process especially as it relates to Sutton service users over many years.

Sutton 1 in 4 Network see no reason why a detailed examination of alternative sites could not have been examined across the 5 boroughs eg the Sutton General Hospital site and probably among many others.

The contention that it is impractical to move Springfield from its current site is one that Sutton 1 in 4 Network would take issue with the Trust, NHS London and the PCT as no alternatives have been put forward for consideration. It is our contention that the Trust management does not have the will to relocate the site and their submission  documents do not reflect any or even a partial fair assessment of alternatives to redevelopment of the Springfield site.

In the Statement of Common Ground para 8.27 London (South West) & St George’s Mental Health NHS Trust states, “that the Trust’s decision to appeal is based, above allon its duty of care to the people that it serves and that it is the Trust’s overriding responsibility to ensure that patients are cared for in modern, purpose-built facilities which will best aid their recovery.  It is also the Trust’s duty, as a public body, to make the best use of public resources in achieving this important aim.”

Sutton 1 in 4 fully support the fact that the current buildings are not fit for the purpose of caring for psychiatric patients in the 21st century. We also agree that the Trust should use the resources allocated to them by the public in the best possible way and to provide modern, purpose–built facilities which will best aid the recovery of their patients. Unfortunately, we do not agree with the Trust that their overriding concern ie the “above all” criteria is being met and further do not agree that they are best using public resources to achieve the best possible care for their patients in order to aid their patient’s recovery. It is our opinion and experience that the Trust have consistently failed, over many years, to provide care, treatment and services of the required standard.

Dealing first with the Trust’s Statement of Case, Sutton 1 in 4 Network would like to comment on their statements:

Para 3.2.8.1 “the provision of new state of the art mental health facilities
which are critical to the Appellant’s duty to provide appropriate mental health care in the Borough”

State of the art mental health facilities do not assure state of the art care. We wish it was as simple as that but it is not.

Sutton 1 in 4, most of the 5 borough’s LINks, the Care Quality Commission (CQC) and many of their predecessor’s reports into and about the Trust, all have major concerns with aspects of the quality of care at Springfield. An example in the recent CQC report into the Trust being that many staff did not appreciate that many of their patients were there on a voluntary basis rather than on a compulsory section under the Mental Health Act. This is an indication of serious management failures and unlawful detention of patients as their movements were unlawfully restricted. There are many other examples.

The current plans indicate that patients would not have access to fresh air and a view of open space.  Despite assurances at the 11th October 2011 meeting that these concerns would be addressed in detailed new plans should building consent be granted, Sutton 1 in 4 still have major doubts that the Trust can fulfil this commitment and are skeptical that once building permission is granted, nothing would then stop the Trust from merely submitting divisive plans in any event. We are wary of what we are being told.

Their new proposed state of the art facilities only indicate an enclosed yard and no visual access to the open land the Trust are actively promoting redevelopment of. We can only comment on current proposals not those that have merely been voiced to calm service user fears. It seems that such energy is being made for the benefit of the developers plans for residential views over the open land and not for patients. There may be other legal problems that should be subject to legal considerations eg the provisions of the Disability Discrimination Act 2005 and Equality Act 2010.

Similarly, we have concerns that the redevelopment of the site does not account for, nor have plans for, any future needs to expand the redeveloped facilities to cater for future patients needs. The proposed footprint is very much enclosed by listed buildings and proposed new housing. The site has been in existence since the mid nineteenth century and this management are restricting future management and Trust boards to expanding facilities for future generations. The fact that current financial plans in the economic crisis now facing the country does not mean that the projected reduction in capacity and available beds  would not change in the future. The possibility for increased future capacity and in patient bed needs, even to recent past numbers, does not seem to be planned for. They are restricting their own ability to expand should this be necessary.

The Trust seem focused on “the Borough,” meaning the London Borough of Wandsworth.  Despite their arguments for keeping facilities based in Tooting, no consideration to relocating to elsewhere within their catchment area has been considered, or if it has been considered,  not properly considered. They serve 5 London Boroughs in South London and their preoccupation with Wandsworth Borough seems inequitable and possibly unlawful. After all, the original ‘St George’s’ was located in London SW1 at Hyde Park Corner and was subject to a relocation itself, to Tooting. It is not unreasonable to consider further relocation of the Mental Health services for the 5 Boroughs to a site within the 5 Boroughs other than Wandsworth, as they agree with the Trust that no other site in Wandsworth is available apart from the current site.  Some 80% of patients come from a location other than Wandsworth. Full consideration of proposed other sites should have been part of the process and has patently not been.  Relocation to more appropriate open and less restrictive land is not an unreasonable option given the huge amount of public opposition, restrictive legal obstacles and the Listed Building status problems. The whole site has become for one reason or another ‘not fit for purpose’ and no amount of tinkering with plans will change this fact. You cannot fit a square peg in a round hole.

Para 3.2.8.3 “the delivery of a significant quantity of housing and affordable
housing on this site thus making a significant contribution to
meeting housing need and making best use of land”  

Undoubtedly this is true, however we object to making the “best use of land” for the benefit of a developer and their profits, when the best use of the land and resources should be directed for the benefit of the public as a whole and patients in particular. Monetary consideration should be second place to the needs of the public and patients and this, in our view, just cannot happen on the current site. Even if, as was stated on 11th October 2011 by the Trust, that the freehold of the proposed housing was limited to leasehold and a charitable land trust set up to manage the new development was enacted by the Trust, this would still not address the historic, main and sole use of the land as a facility for the treatment of psychiatric patients, rather than as a housing facility with a psychiatric facility tagged on the edges.

Para 3.2.8.5 “the wider benefits to the MOL as a whole, which must be balanced against any more local impacts.”

The hospital was conceived and developed since the nineteenth century with regard to the Metropolitan Open Land (MOL) being as a facility and pleasant view for in patients. It is Sutton 1 in 4 Network’s view that any redevelopment should have this in mind and be in line with the Trust’s commitment to recovery when developing any new site. The current plans do not do this. The basis of the Listed Building status will always dictate new mental health facilities will take second place to the legal duty not to demolish any of the current listed buildings. Therefore, given that is true and unavoidable, no new plans would satisfy the original nineteenth century conceived plans and development of the original hospital as they would always be constricted by the economic need to satisfy the developers plans and profits. The current proposed location of the new hospital facilities do not allow for open and pleasant views over the MOL and as stated above these are the plans to be considered not any others, not submitted for planning considerations.

Para 3.2.9 “….. but which are significant in demonstrating the virtues of the Appeal Scheme as a form of sustainable development making efficient use of brownfield land  and enhancing the area.”

Again this is undoubtedly partially true. However, again the Trust, we contend, are merely complying with financial consideration at the expense of in patient needs and experience expectations. It is concerning that the Trust consider the plans to build, what has perhaps ungratefully come to be known as, ‘H – Block’ type hospital facilities amongst expensive and high specification residential units whose exclusive marketing point is a view of the Metropolitan Open Land, is “enhancing the area.” We anticipate that the public would not consider having a Psychiatric Hospital near them as an enhancement. We are also of the view that if the public thought that, then their view is unreasonable and discriminatory. Having said that we do not see any way that the new facilities could be located amicably taking account of all of the public’s views, anywhere within the current site. Even if, as stated by the Trust, the service user concerns were listened to and acted upon and the new facility was sited in the south west corner of the site, then we suppose that this would still be subject to objections by other members of the public. Further, development of the new hospital facilities in the south west of the site could hardly be described as a brownfield site as it would intrude on to the MOL as does the proposed housing.

Para 3.3 “The listed building consent refusal.” 

We do not see the justification to allow the demolition of one Listed building over another even if it is only described as being in the curtilage. Surely every listed building should be afforded the legal protection that the Listing provides including those in the curtilage? If this is not the case, then the Trust and their architects should be applying for demolition of those buildings that would afford the best possible outcome for the public and the service users and especially their in patients. This is just further evidence to suggest the site itself is not fit for purpose.

Para 3.4.1.1 “the Appellant’s statutory duty to deliver mental health care”

The Trust does not have to undertake this statutory duty on the current site. Alternative sites and plans should have been considered and examined. As stated above Sutton 1 in 4 Network believes the Trust and NHS London have failed in their statutory duties to consider all alternatives in a fair and considered manner for and on behalf of all 5 boroughs and the national patient responsibilities they have.

Para 3.4.1.2 “the changing economic landscape and how NHS trusts are now expected to fund new capital projects” 

It could be argued that by insisting in developing the current plan and refusing to consider other options, that the Trust have denied themselves the ability to maximise funds obtained by the sale of the current site, in totality, and move to a site where the land is cheaper. Given the Trust Board are committed to making “the best use of public resources”  it seems to us that they fail again to meet their own criteria or at least objectively discount the possibility of an alternative by a detailed examination and financial examination of those alternatives. Merely examining the outcome that suits the Trust Board and their perceptions of the plans is not the reasoned and objective statutory standard the public expect and require of a Public Authority.

Para 3.4.1.4 “the locational requirements requiring service provision within
this Borough;” 

We fail to see what “locational requirements” are imposed upon the Trust. Again they are blind to the fact that they have service commitments to 5 London Boroughs as opposed to what they see as “this Borough.”  The sad fact is that somewhere along this process and eventual, if successful, building of the state of the art facility, the Trust will have to disappoint some of their service users as to the location of the service they provide. No one Borough and their disabled public requiring in patient treatment has any less right to the services over the patients of the other boroughs, therefore the “locational requirements” are irrelevant because, as has been pointed out above relocation off the current site is an option that could be considered and which has not been.

Para 3.4.1.5 “having regard to the above, why there is a compelling and urgent need for new, state-of-the-art 21st Century mental health facilities at the Appeal Site.” 

We agree there is a compelling and urgent need for the new facilities, but not at the expense of the public needs and in patient experience of the new facilities being offered or rather not being offered in these proposed plans. We consider the current site not fit for purpose in any event and that relocation should now be the priority of the Trust.

Para 3.4.2 “Accordingly the Appellant’s own Director of Nursing and perhaps one other will present evidence which addresses these issues. This evidence will also explain the likely consequences for the Appellant should the appeals be dismissed. In the absence of a planning consent to secure these facilities the Appellant’s ability to continue to provide services at the Appeal Site will be seriously undermined.”

It is the firm view of Sutton 1 in 4 service users that for the Trust to indicate that there would be “consequences” if the appeals were dismissed is merely scare tactics.  The consequences, if the Trust’s statements on the 11th October 2011 were to be believed, surely would be the demise of Springfield and service users being sent to other mental health trusts nearest to their homes, which would also be in line with Department of Health guidelines regarding treating people near to home.  Given the concerns of service users and the latest CQC findings regarding the poor standard of care given by the Trust and the Chief Executives public admissions that they have a long way to go to improve those services and taking into account their history, it is our view that the consequences could only mean improvement of care outcomes for service users should these “consequences” occur. Service Users in Sutton would welcome the ability to choose where they receive treatment and the Trust’s difficulties, should the planning appeal go against them, could in fact be a positive step for Sutton Service Users. The commissioning of mental health services on the behalf of Sutton service users would surely merely present a ‘blip’ in the greater scheme of things. This is undoubtedly true within the other boroughs too. Psychiatric treatment is not the exclusive  remit of this Trust and there could be positive outcomes if the appeal does not obtain approval eg kick starting the comprehensive positive changes to the quality of care that service users have been crying out for.

Having said that we do not actually want the Trust to fail in providing high quality services. We would encourage the Trust to relocate to a more appropriate and better located site and start again considering their statutory duties to provide services for all 5 boroughs and their national commitments in a fair equitable and non discriminatory manner.

Now dealing with the Trust’s  Statement of Common Ground:

In regard to Public Transport Services it should be noted that for Sutton residents access to the Springfield site is almost impossible. For example Sutton service users living in some parts of Wallington and Beddington would have a torrid time getting to and from Springfield. Service users elsewhere in Sutton relying on Public Transport find it just as difficult, there being no direct route. Sutton 1 in 4 Network service users using public transport services can take up to 2 hours to go to and from the Trust site.

Para 5.5 Car parking spaces.

It is very concerning, when Sutton residents visiting their loved ones in Springfield, being almost totally reliant on private motor vehicles to attend the site, are faced with a 38% reduction of car parking spaces available to them when visiting should the new site be given approval.  Parking as highlighted by other objections is problematic in any event and particularly so when Public Transport alternatives are so difficult to access.

On the 11th October 2011 as an example of even current difficulties in regard to parking we can report directly that the open and public meeting starting at 11am meant that one service user attending the meeting was unable to find a parking space despite complying with the registering of her vehicle on the site. After the meeting she had been clamped by Trust security and faced the possibility of a £50 fine. This incident only highlights that with a 38% reduction in car parking spaces available service users and their families would face increased problems to lawfully park and then have to perhaps pay for the privilege.  The worthy agenda for increased bicycle parking spaces is viewed with skepticism by Sutton service users and in any event would hardly be a facility that would find favour amongst most Sutton visitors and patients on the site nor the other outlying boroughs.

Para 5.61 “‘Flexible’ open space comprises open areas around the new mental health facilities.  The mental health facilities will also have internal courtyards providing open space for patients and staff.”

What on earth does ‘flexible’ open space actually mean (see below)?  Given the current trend to reduce in patient treatment to a minimum and increase the treatment regimes in the community, it is reasonable to assume that an increased proportion of patients subject to a restriction of their liberty under a section of the Mental Health Act eg a 6 month (recurring if necessary) Section 3 order will occur.

Reduction of so called ‘voluntary’ patients ie those apparently free to come and go, but in reality are unlawfully treated in the same way as sectioned patients, will make access to ‘flexible’ open space less and less likely.

The fact is that patients detained and incarcerated under a section will only be allowed access to the internal courtyards. The Ministry of Justice’s regulations dictating secure and substantial fencing surrounding any proposed open garden and viewing space further intrude into the proposed plans. These statutory considerations have not been planned for and we cannot see how they could fit into the current plans. The Trust could not have made access to fresh air more like a prison than if they actually tried. In truth actual prisons would have more access to fresh air and green open spaces than what is being proposed by the Trust in these plans.

Para 8.2 “Springfield Hospital also provides specialist services to patients from the rest of the London and from the rest of the United Kingdom.”

As 9.4% of in patients and 8.1% of outpatients are from elsewhere than the 5 Boroughs served by the Trust we can not see any objection from these patients as to the relocation of the hospital site, as they have substantial travel arrangements already. Sutton 1 in 4 Network  are concerned these national patients, carers and family may not have had the opportunity to voice their concerns.

The tables showing figures are misleading.

Table 8.1 (para 8.5) Origin of Outpatients at Springfield Hospital by Local Authority 2010-2011  does not make clear the percentages of out patients seen locally. “This is because routine mental healthcare is also provided in facilities in those boroughs.”  It is disingenuous to promote figures for merely one side of the equation and not the other. In Table 8.2 (para 8.6) one gets a sense of the scale of patient treatment numbers as both in and out patients when comparison of Wandsworth (29.8%); Sutton (26.7%); and Merton (26.8%) is made.  This surely suggests an almost even number of patients for each borough to deal with. Consequently, these figures could as easily read for Sutton or Merton should the current location of the hospital have been in those boroughs. The slant of the presentation of the figures and manner of wording of them unfairly shows a bias towards Wandsworth and the status quo ie approval of the plans at the appeal.

Tables 8.3 and 8.4  (paras 8.7 and 8.8) merely shows the disposition of patients as they relate to “Number of Outpatients from LB Wandsworth”

Para 8.8 in the narrative they deal with the residents of the London Borough of Merton. Despite having an almost identical disposition the London Borough of Sutton does not seem to be part of the plans of the Trust. This is typical of the way Sutton residents have been treated. Kingston and Richmond residents too do not seem to figure in the plans of the Trust.

Nowhere under section 8 does the Trust detail what actual facilities the new ‘state of the art’ modern hospital actually contain. This is incredible as the Trust are at pains to explain how the reptiles, bats, cyclists will be treated, how new schools are to be provided and social housing. What exactly is the public going to obtain? How many beds? What will the disposition across the boroughs be? What out patient facilities are there? What the Trust intend to do about Transport links for residents in Sutton, Richmond and Kingston who find visiting the Trust so difficult?

Para 8.9  Employment

Relocation to elsewhere other than the current site would continue to see the Trust being a major employer. Alluding to the fact that there would be significant job losses should the location not be Wandsworth is again scare tactics. A table showing the disposition of staff’s home addresses would have been helpful, as staff traveling from outside the Borough of Wandsworth could have given a better idea of the implications of a relocation of the site.

As it is, any relocation to the outer boroughs is likely to attract a different cross section of society to be employed by the Trust, in accordance to the demographics of the new location.

Para 8.18 “Both the London Borough of Wandsworth and the Appellant are of the view, for the reasons set out at Document J12, that the only realistic way to deliver new mental healthcare facilities is through the development of parts of the Springfield Hospital site for non-hospital uses.” 

Of course the London Borough of Wandsworth and the Trust will agree that the Springfield site should be developed. It is in the interests of both parties to do so for varying reasons.  It is particularly noticeable that the majority of patients currently treated are non Wandsworth residents, but are not equally treated in this document. There is a bias towards Wandsworth at almost every turn of the page.  We are concerned as to what discussion with the other boroughs has been held. We have no idea. We certainly have not been consulted.

Alternative Sites

Para 8.19 “Both the London Borough of Wandsworth and the Appellant are of the view that there are no alternative sites in the Borough which are owned by the Trust and which would be suitable as an alternative location for new hospital facilities of the scale envisaged at Springfield Hospital.” 

This is good news for the other Boroughs, especially the outer Boroughs, as the Trust has restricted its search of alternatives sites to the London Borough of Wandsworth and even then they qualify their search to facilities “owned by the Trust”. Surely a clearer example of discriminatory action against the psychiatric patients that do not live in Wandsworth could not be made.  It’s dismissal of non Wandsworth sites is clear too in the next paragraph.

Para 8.20 “If the Trust was to provide replacement facilities at another of its sites, for example at Tolworth Hospital, this would be a significant disadvantage to the many local patients  in Wandsworth and it would also have the undesirable effect of increasing the distance travelled by patients and staff as detailed in the Health Service Travel  Analysis Tool (“HSTAT”) analysis (Document M30; an overview of the HSTAT methodology is Document M29).  HSTAT is an NHS / Transport for London model which assesses the travel implications of reconfiguring / relocating healthcare services and this assessment has been carried out by an independent third party,  Jacobs, which is the company responsible for running the HSTAT model for Transport for London and the NHS. “

So the Trust have no regard for the “significant disadvantage(s) to the many local patients….” in Sutton, Kingston, Merton and Richmond only for those in Wandsworth, nor to the near 10% of national patients who may be better pleased to be closer to the motorway network than they are at present. They are merely concerned with disadvantages to Wandsworth residents.

Similarly,  “and it would also have the undesirable effect of increasing the distance travelled by patients and staff”  where is the concern for the other 4 Boroughs and National patients?

These statements and proposed actions are clearly discriminatory and then we are told in para 8.21 “that the staff and patient numbers differ in this from those stated above because a different period of time has been analysed”  So discriminatory even on wrong data.

Para 8.27 “It is acknowledged by both parties, therefore, that the Trust’s decision to appeal is based, above all, on its duty of care to the people that it serves and that it is the Trust’s overriding responsibility to ensure that patients are cared for in modern, purpose-built facilities which will best aid their recovery.  It is also the Trust’s duty, as a public body, to make the best use of public resources in achieving this important aim.”

The Trust’s duty of care extends to a far greater degree than has been indicated in this Statement of Common Ground.  It is acknowledged by Sutton 1 in 4 Network that the parties to the appeal are the London Borough of Wandsworth and the Appellant, however it is also true that more patients are treated outside Wandsworth than inside and the Trust has not been equitable to the care needs, travel and other arrangements to those patients, family and friends. The land and facilities are held in trust by the Trust for and on behalf of the public now and for generations in the future and making the best use of its resources has not been considered fairly, equitably or in a non discriminatory manner.

Para 11.42 Conducive to Enjoyment and Wellbeing 
Sub section 8 “improving the therapeutic qualities of the landscape to benefit the NHS patients and the wider community consistent with London Plan Policy 3.2 (Improving Health and Addressing Health Equalities);”

Sutton 1 in 4 Network fails to see how the proposed changes to the “landscape” will have any therapeutic effects on patients subjected to incarceration and detention under a section under the Mental Health Act and only permitted out to an enclosed courtyard? Similarly, how the same can be said for “flexible open spaces” that will not be available to those under a section or unlawfully restricted in their movements because the Trust have failed to ensure their staff know the difference between the rights of a voluntary patient and those restricted under the section? Please refer to the latest CQC report into the Trust as evidence of this.

The true nature of what  the Trust mean by “flexible” open spaces is shown in subsection 10 of para  11.42 ie “providing publicly-accessible open parkland on the Metropolitan Open Land which accommodates a variety of ‘flexible’ formal and informal uses which are appropriate to the historic setting and which appeal to the majority of the local community”  Thus the Trust’s ability to provide open space such as a garden to in patients is negated because these open spaces will be open to the public and that does not accord with its duty to provide them to in patients subject to lengthy stays in hospital. This is bordering on neglect should this be allowed to happen and the current plans do not accommodate the regulatory instructions of the Ministry of Justice for the fair detention of Mental Health Act sectioned patients some of whom have been detained for many years.

Para 12.120 “The NHS facilities at Springfield have developed in an uncoordinated way and have resulted in a hospital that is unconnected and physically dislocated, spread across the site.  This causes problems for the day-to-day operation of the Hospital, affecting the services and care provided for both in-patients and out-patients.  The Appellant’s brief requires the new NHS facilities to be consolidated to improve the operational and functional efficiencies, which include security.  All this will enhance patient care and staff well-being.”

It is a matter of opinion whether the new NHS Facilities will improve operational and functional efficiencies and enhance patient care and staff well being. The Trust culture has been resistant to change over many years. Management have been unable to demonstrate its ability to supervise effectively even basic standards of care. How this will change even in a brand new facility is beyond the thinking of  Sutton 1 in 4 Network members.  What is not in doubt will be the increased security. The design of the new facilities in a block with a centrally accessed courtyard, is reminiscent of a high security prison environment. Surely we are beyond that? These plans if approved would not “enhance patient care” in our opinion.

Further, “the Appellant’s brief” was written by the appellant, for the appellant and had no input from Sutton service users. So for them to state that consolidation was a requirement again shows the Trust’s unfair, inequitable and  discriminatory application of the original brief.

Para 12.126 “The new healthcare facilities have significant scale and it would therefore be inappropriate to locate them on the boundaries of the site, close to residential properties surrounding the Hospital.” 

Which is definitely an argument in favour of relocation.

Bizarrely this is what the Trust  indicated would actually be considered by the Trust in subsequent detailed planning applications should their appeal to build on the site be successful. It is hardly surprising then that Service Users do not trust what the Trust says to them when in an official Public Appeal to their planning application, they submit to the Judge, a statement that a location on the boundaries to the site for the hospital facility would be “inappropriate” but verbally, days before the hearings, attempt to allay service users fears by telling the opposite and that redevelopment on the boundaries and adjacent the MOL could be planned for. We can not believe the Trust and its intentions.

Finally Sutton 1 in 4 Network believes that Wandsworth Council and London (South West) & St George’s Mental Health NHS Trust have reneged in their responsibilities to review this planning application in a fair, equitable and non discriminatory manner. Despite the 243 pages of the Statement of Common Ground between the London Borough of Wandsworth and London (South West) & St George’s Mental Health NHS Trust they have failed to take into account the needs of the 4 other Boroughs involved. It is excruciatingly obvious that only one option is on the table and this in our view is discriminatory to the thousands of mentally ill patients that do not live in Wandsworth and generations of similar patients yet to come.   Nowhere in the entire document is the fact that Equality Impact Assessments have been made or considered in the various decisions that have been made by both Public Authorities across many years of decision making. Should the Public Enquiry ignore these discriminatory actions of both the Trust and the Council, it is our opinion the whole process would be flawed.

Sutton 1 in 4 Network asks that the appeal by London (South West) & St George’s Mental Health NHS Trust under London Borough of Wandsworth References: 2010/3703 and 2010/3706 and Planning Inspectorate References: APP/H5960/A/11/2156427 and APP/H5960/E/11/2156424 be dismissed and building permission under the above quoted references be rejected.