Dear Planning: please address our material objections to the Hospital applications

Residents are very concerned that Poole Hospital has employed a real estate company, Savills, at public expense, to ‘summarise’ our comments on the Poole planning application, and to seek to influence planners to dismiss genuine objections.

The Poole planning application for additional theatres is part of the Clinical Services Review, which would see Poole becoming a Planned Hospital, with loss of A&E, Maternity and Paediatric Units, and new building at RBH to increase emergency and maternity care there. The Trusts on their petitions refer to the Poole and RBH planning applications as one. These are entirely interdependent works funded from the same government investment.

Objectors raise many issues of which clinical risk is only one. Savills letter is disingenuous in claiming to review objections when the letter ignores all objections made other than risk to life. I will list 5 key areas of objection here.

1) Clinical risk

However, to address the issue of clinical risk, many of the 529 objectors do indeed express concerns about the inevitable clinical risks of longer journey times to access care in emergency. ‘Potential risk’ to 396 ambulance patients per year was acknowledged by the CCG in the High Court. This figure excludes the majority of maternity and paediatric emergencies, who self-present at hospital, and for whom longer travel time is a ‘significant risk’ according to the CCG’s own Equality Impact Analysis.

There are also arguments that enabling changes that increase risk to life is a material planning matter. Increasing risk cannot be in ‘the public interest’, and the public interest is a planning matter. The CCG have been unable to provide any research evidence to support reducing emergency sites in rural areas, there is clear research that longer time to care in emergency increases mortality, and no proper risk assessment on the plans has been carried out.

Furthermore Poole Plan notes the need to ‘improve health’ (Challenge 7 page 16), and that issues in the 7 Poole LSOA’s that are particularly deprived include an aging population, income deprivation and tackling air pollution from traffic congestion. An aging population is a key determinant of need for health services, including emergency care as health declines, yet this care is being moved further away, and transport costs and accessibility are also a particular issue for those on fixed incomes or who do not have access to a car.

2) Traffic congestion, air pollution and CO2 emissions

This is one of many other objections raised by residents. These plans will create perhaps 200,000 additional journeys, for patients and their visitors, across the already chronically traffic congested conurbation, affecting access, air pollution, CO2 emissions and health.

BCP Council has declared a climate emergency and committed to work towards becoming carbon neutral. The development plan for Poole recognises that the need to travel should be reduced (Challenge 6) and that climate change will adversely affect Poole (Challenge 8 and objective 7). Policy PP1 states there is a presumption in favour of sustainable development. Creating more travel is not sustainable development.

Bournemouth is already the third most traffic congested location in the UK and Yellow Buses say the conurbation roads will be at a standstill unless something is done to address traffic congestion. This will make it worse. The impact of roads at a standstill on patient safety in emergency also needs to be considered. Many emergencies self present, so do not benefit from blue light conditions, and ambulance progress is impeded, and sometimes blocked, by the current levels of traffic congestion.

Poole and RBH both offer elective and emergency care at present. Poole will stop emergency admissions, of which there were 39,500 last year, and RBH will stop elective operations, of which there were 73,500 last year. Most of these 113,000 residents, and their visitors, will have to make longer journeys:  from Poole and the west, to access emergency care at RBH, and from Bournemouth, Christchurch and the East to access elective care at Poole.

In fact, 200,000 extra journeys across the conurbation is likely to be a conservative estimate. An elective operation generates perhaps two journeys – one to drop off, and one to collect the patient. An emergency admission, with a hospital stay anywhere between overnight and a week or more, is likely to generate significantly more than two journeys, due to visitors: and some patients have several visitors each day.

I am very concerned about Savills suggestion that the planning application be considered ‘in isolation from the longer term role of Poole as the Major Planned Hospital’. This Chief Operating Officer of RBCH also claims in the Briefing Note that the ‘reconfiguration’ is a matter for the future. It is not. While reconfiguration may be ongoing over a period of time, the Poole application is clearly part of this work – in fact the Briefing Note states (Page 1 para 4) that these are the only building works required to transition Poole to a Planned Hospital. At what point, if not now, will the impact of Poole and Bournemouth Hospitals changing roles on traffic congestion, air quality and CO2 emissions be considered by Planners?

The £147 million is one pot of government money tied to changing Poole to a Planned Hospital and increasing Emergency care at RBH. It is dishonest to claim that increasing operating theatres at Poole has nothing to do with Poole becoming the Planned Hospital. The Trusts in their own petitions in support of their Planning Applications refer to the £147 million ‘investment’, as shared between the hospitals and the only funds available to implement the changes.

3) Sustainability of RBH as the Dorset Major Emergency Hospital

Residents have raised concerns about the absence of the new road originally seen as a requirement for the hospital reconfiguration to go ahead, the current chronic traffic congestion across the conurbation and particularly around Bournemouth, and the further negative impact upon this of the hospital plans. Staff report it takes them an hour to get out of the car park at 5pm. Concerns have also been raised regarding RBH being situated on the River Stour flood plain and the implications of unavoidable climate change for the sustainability of the hospital. There are also concerns about the viability of a single A&E and Maternity unit serving a population of 750,000 (conurbation catchment + west Hampshire). Residents from west Hampshire would have trauma A&E and consultant led maternity accessible at RBH for the first time. Cuts of 245 Dorset acute beds across the County also affect viability.

4) Vitality of Poole

The mergers of the hospitals, which follows the merger of the councils, gives a strong message that Poole is becoming a suburb of Bournemouth, and will cease to be a town in its own right. Vitality of our town centres is a material issue for planning. The merger of the councils to make BCP means there is risk to Poole and Christchurch in terms of keeping their identity. The development plan for Poole has as its first objective to transform and revitalise Poole Town Centre and also lists its regeneration as a challenge (Challenge 1). Policies PP3 to PP5 are all about growing and regenerating Poole as a separate centre, not as a suburb of Bournemouth. There is also a neighbourhood plan for Poole Quay that forms part of the adopted plan. This also talks about creating a vibrant High Street and Quay (PQF8 and PQF10).

5) Legitimacy

There are concerns about these plans going through while we are still waiting to hear the Secretary of State’s decision following the Independent Review. The Trusts have not yet applied to the Competition and Markets Authority for Merger.

To clarify the statement in the briefing note, the Judicial Review did not address whether the Clinical Services Review decisions are right for Dorset. The Judicial Review addressed whether the CCG had followed the correct process in deciding to proceed with the Clinical Services Review proposals in September 2017. The Appeal Court Judges accepted that 400 ambulance patients a year would be put at clinical risk by longer journey times. They debated whether the CCG had erred in describing, at worst, the deaths of 400 people, as ‘minimal clinical risk,’ as this is how the matter had been presented to the CCG Board in September 2017. The Judges did NOT address the issue of the maternity, paediatric and adult emergencies who self present to hospital, and so had not been included in the risk assessment. A Dorset Consultant in Emergency Medicine, reporting back in August 2017 on behalf of a panel of Clinicians selected by DCCG, stated that the risk assessment was ‘not fit for purpose,’ due to the exclusion of the majority of maternity and paediatric emergencies, the exclusion of those who face the longest journeys under the plans, the methodology used and that the risk assessment had insufficient power. Unfortunately the Lead Judge decided the Emergency Medicine Consultant was ‘not qualified to comment’. The Judges also ruled that the CCG were not obliged to ensure they could recruit staff for the proposed new ‘integrated community services’ that the cuts to acute care are predicated upon, before proceeding with those cuts.

There are also concerns about the applicants misleading the public by setting up ‘petitions’ that present what are in fact applications to progress the end of emergency care at Poole as ‘funding bids to improve services.’ There is no bid. While there are further hoops to get through in terms of Treasury approval of the business case, the £147 million investment has been allocated for some time. Confusion is apparent with residents signatures that are accompanied by comments such as ‘keep A&E at Poole’ being counted by the Trusts as in support of the planning applications that transition Poole to a Planned Hospital, with loss of A&E, Maternity, Paediatrics and Oncology beds, and increase Emergency Care at RBH.

In fact opposition to these plans is substantial, contrary to what is claimed in the Briefing Note. Criticisms were submitted by senior staff during the consultation process but were ignored. 36,910 residents have signed petitions to save A&E and Maternity at Poole, and 9 Dorset Councils and 2 MP’s supported referral of the plans for Independent Review.

Damien Stone