Letter 23 Nov 07 objecting to Marlow Football Club plans

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RE: Planning Application No. 07/07535/FULEA. Land at Westhorpe Park, Little Marlow, Buckinghamshire.

Application for the provision of new community football facilities for Marlow Football Club including: floodlit football ground including part covered terraces and 246 seat stand with attached building accommodating one-storey club house.

Below is a copy of the letter sent by The Marlow Society:

Mr.Chris Steuart,
Planning and Major Projects Directorate,
Wycombe District Council,
Queen Victoria Road,
High Wycombe, Bucks.,
HP11 1BB.

23 November 2007.

Dear Mr. Steuart,

Planning Application No. 07/07535/FULEA. Land at Westhorpe Park, Little Marlow, Buckinghamshire.

Application for the provision of new community football facilities for Marlow Football Club including: floodlit football ground including part covered terraces and 246 seat stand with attached building accommodating one-storey club house.

The Marlow Society lodges its strong objection to the above planning application which it considers to be in total contravention of Local Plan policies G3(General Design Policy), GB2(Development in the Green Belt) and RT9(Little Marlow Gravel Pits).

Policy G3 General Design Policy.
Explanatory paragraph 2.14 to Policy G3 states that, ‘New development will need to be carefully assimilated into the existing landscape by sensitive design and, where possible, enhancing the characteristics of the area’. Policy G3 requires that the new development should take account of existing characteristics such as local land form, natural features, views and vistas and have regard to landscape quality. This application contravenes all these requirements.

Policy GB2. Development in the Green Belt.
Explanatory paragraph 9.11 and 912 to Policy GB2 state that ‘there is a general presumption against inappropriate development in the Green Belt’.
The bulk and mass of the proposed structures provide covered accommodation 524 spectators incorporating a covered stand accommodating 264 spectators with an attached building which includes a huge club house/function room, changing rooms and offices) forms inappropriate development which detracts from the openness of the Green Belt in contravention of Policy GB2(3). It is this Society’s view that this proposed development does not comply with the description of acceptable development as set out in Policy GB2(2b) as being essential facilities for outside sport and outdoor recreation. Marlow has plenty of such facilities and this facility is being provided only to facilitate the development of the football ground within the town, the subject of registered outline planning application 07/07553/OUT.

Although development of sports and recreational facilities are appropriate uses within the Green Belt, the building of large structures, such as those proposed, (said to be one storey but having the effective height of two stories – some 24ft) is in conflict with PPG 2 paragraphs 3, 4, and 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. Spectator facilities here would accommodate over 2000 people (applicant’s estimate), while only 124 standard parking spaces are provided. It seems inevitable, therefore, that parked cars would spill out onto the surrounding areas of green belt. It also seems probable that, if this development can accommodate this number of people, then, not only is the parking provision inadequate, so are other essential 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 is considered to be detrimental to the rural nature of the area by day and intrusive to the surrounding area by night. Flood lighting would be very visible in the Little Marlow and Abbottsbrook Conservation Areas and would be highly visible from the high escarpments of Quarry Woods to the south and Chiltern AONB to the north, in direct contravention of Local Plan Policy RT19.

Not only are these structures considered to be inappropriate development in the Green Belt, but they do not provide essential facilities justified by this club’s past or present activity. Additional paying spectators are estimated at an optimistic 137, which could easily be accommodated at the existing football ground, indicating that this activity will grow very little. With only a limited increase in paying attendance, it is difficult to see how this extensive complex would be sustainable and, consequently, there would be a strong incentive to expand the use of the facilities to fund the future upkeep of the complex. Indeed it is the expressed intention of the applicant to use the club house area, the so called community area and bar area (which we estimate could accommodate up to 500 people) for functions which are not related to outdoor sport and recreation and are not, therefore, permitted uses within Green Belt polices.

Neither does the applicant’s assertions that this development will provide much needed facilities for the community have credibility. All the schools in Marlow have large playing fields and the provision of ‘all weather’ pitches for Great Marlow School have just been approved by your Council. Marlow Sports club is extending its sporting facilities and the town’s parks and open spaces provide ample sporting and leisure areas for all the town’s organisations and people. To assert that new facilities have to be provided in the town’s green belt to meet requirements for football league promotion, ignoring the opportunity to upgrade existing facilities and the contravention of current adopted planning policies is completely unacceptable.

Such inappropriate development within the Green Belt could only be justified by the existence of very special circumstances as set out in Local Plan Policy GB2 (2). No ‘special circumstance’ exist in this case. It is apparent to this Society that the only special circumstances which seem to be important to the applicant is the pressing desire to develop ninety four dwellings on the existing football ground within the town. Completing the erection of these houses on this Green Space site seems to be regarded as by this applicant as a type of planning gain only available to the community if planning permission is granted for inappropriate development is permitted within the town’s greenbelt.

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 should be independently considered for development on its compatibility with zoned land usage and adopted planning policies. The apparent dependence of the development of each site on permission being given for both is, again, a manipulation of the planning system which should not be tolerated and is, perhaps open to subsequent challenge.

Supplementary Planning Guidance.
The proposed development fails to meet any of the twelve Aims and Objectives of the Supplementary Planning Guidance adopted for the Gravel Pits Area in March 2002 as 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 over 2000 people and their cars, floodlights and large buildings which are intended for uses not permitted within the greenbelt, is clearly not compatible with these requirements. The planning history of the Gravel Pits area will show that similar facilities have been the subject of planning applications by the Marlow Rugby Football Club which were not permitted for reasons of non-compatibility with Green Belt Usage and no departure from this policy should be made in this case. Such a development would discourage the propagation of wild life and the promotion and enhancement of bio-diversity in this sensitive area.

Permitting the erection of buildings of this size within this area would establish a dangerous precedent and precursor for other similarly 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. It is this Society’s view that these and any other similarly scaled development would not be suitable ‘enabling development’ as described in the planning guidance and would not be conducive to the quiet enjoyment of outdoor leisure within a country park as envisaged by the planning brief.

For these reasons the Marlow Society requests that this application is refused unconditionally. It regards the determination of this application as a vital test of the integrity of the Adopted Local Plan to 2011, and the emerging Wycombe Development Framework (Policy 7) dealing with the future development of Marlow and the protection of its green belt. The Society is confident that the Council will not compromise the effectiveness of adopted planning policies and supplementary planning documents and the prolonged and comprehensive local consultation that was involved.

Yours Sincerely

RF Waters,

Chairman.