The Marlow Society lodges its strong objection to the above planning application which it considers to be in contravention of Local Plan policies G3 (General Design Policy), GB2(Development in the Green Belt) and RT19 (Little Marlow Gravel Pits).

Planning Application No. 05/07748/FULEA.

The Marlow Society lodges its strong objection to the above planning application which it considers to be in contravention of Local Plan policies G3 (General Design Policy), GB2(Development in the Green Belt) and RT19 (Little Marlow Gravel Pits).

Explanatory paragraph 2.14 states that 'New development will need to be carefully assimilated into the existing landscape by sensitive design, and by respecting, and where possible enhancing the established characteristics of the area'. Policy G3 requires that new development should take account of existing site characteristics such as local land form, natural features, views and vistas and have regard to landscape quality.

This application contravenes policy G3 for the reasons set out below.

Explanatory paragraphs 9.11 and 9.12 state that 'there is a general presumption against inappropriate development in the Green Belt'. The bulk and mass of the proposed structures comprising a 500 seat spectator stand, covered terraces, changing rooms, community facilities and offices ,form buildings which the Society consider to be inappropriate development which detracts from and obstructs the openness of the Green Belt, in contravention of policy GB2(3).

Although development of sports and recreational facilities are appropriate uses within the Green Belt, the building of large structures such as these proposed (said to be two storey but having the effective height of 3 storeys) is in conflict with PPG 2 paragraphs 3.4 & 3.5.which describes the facilities that might be permitted stating that,' such facilities include small changing rooms and unobtrusive spectator accommodation', criteria which these structures do not meet. In no sense can these buildings be described as small or unobtrusive. Spectator facilities here will provide accommodation for some 4000 people while only 157 car parking spaces are provided. It seems inevitable, therefore, that parked cars would spill out onto the surrounding areas of green belt. It seems likely that, if these structures can accommodate this number of people, then, not only is the parking provision inadequate but so are other facilities being proposed at this stage which would lead to future additional building to meet this deficiency.

In addition to the inappropriateness of the proposed buildings, the installation of flood lighting masts to all playing and practice areas is considered to be detrimental to the rural nature of the area by day and the floodlighting intrusive to the surrounding area by night. Floodlighting would also be very visible in the Little Marlow and Abbottsbrook Conservation Areas and from the high escarpments of Quarry Woods to the south and the Chiltern AONB areas to the north, in direct contravention of policy RT19.

Not only are these structures considered to be inappropriate development in the Green Belt but do not form essential facilities for this club's past and present level of activity, which, according to the Transport Assessment submitted with the application will grow very little. If built, there would, therefore be a strong incentive to expand the use of the facilities. Indeed it is the expressed intention of the applicant to use these buildings for conference and meeting rooms and social functions which are not related to outdoor sport and recreation and therefore not permitted uses within Green Belt policies.

Permitting the erection of buildings of this size and bulk within this area would establish a dangerous precedent and precursor for other similar sized structures which the applicant seems to suggest would facilitate the development of the Country Park concept as set out in the Supplementary Planning Guidance for the Marlow Gravel Pits area, adopted in March 2002. It is this Society's view that these structures and any other similar development would not be suitable 'enabling development' as described in the SPG and would not be conducive to the quiet enjoyment of outdoor leisure activity within a country park envisaged by the Planning Brief.

Such inappropriate development in the town's Green Belt could only be justified by the existence of very special circumstances as outlined in Policy GB.2(2). No 'special circumstances' exist in this case. The special circumstances which seem to be suggested by the applicant are the need for and the provision of 80 houses on the existing football ground within the town. Completing the erection of these houses on this Green Space site seems to be regarded by this applicant as a type of planning gain only available to the community if planning permission is granted for inappropriate development within the town's green belt. Development of housing on the existing football ground should not be dependent on consent for development elsewhere, which is an unacceptable manipulation of the planning system. Each application site should be independently considered for development on its compatibility with zoned land usage and adopted planning policies. The artificial establishment of 'very special circumstances', and making consent on both sites a condition for the development of either, is again, an unacceptable manipulation of the planning system which should not be tolerated, and is, perhaps, susceptible to subsequent challenge.

Supplementary Planning Guidance.
The proposed development fails to meet any of the twelve Aims and Objectives of the Supplementary Planning Guidance set out in paragraph 4.3. Paragraph 4.2.4 states that 'any additional recreational development must be tempered by the overall requirement to protect and enhance the ecological and landscape qualities of the site'. The SPG Master Plan envisages a limited amount of change with a large amount of the area devoted to quiet enjoyment and low intensity uses with a very small number of additional buildings (SPG paragraph 5.1.5). A football complex with stands and terraces capable of accommodating some 4000 people and their cars, floodlights, and large buildings, which are also intended for alternative uses not permitted within the Green Belt, clearly does not comply with these requirements. Planning history of the Gravel Pits area will show that similar facilities have been the subject of planning applications by the Marlow Rugby Club which were not permitted for reasons of non-compatibility with Green Belt usage and no exception should be made in this case. Such development would also discourage the propagation of wildlife and the promotion and enhancement of bio-diversity in the area.

For these reasons the Marlow Society requests that this application is refused unconditionally. It regards this application as a vital test of the integrity of the Adopted Local Plan to 2011 and the Adopted Supplementary Planning Guidance for the Gravel Pits Area both of which were subject to extensive local consultation and agreement. It is confident that the Council will not compromise the effectiveness of adopted planning policies and supplementary planning documents and the consultation process.

Yours sincerely,
R F Waters
Chairman.