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planning report D&P/0213b 9 June 2015 Charlton Athletic Training Grounds in the Royal Borough of planning application no. 15/0949/F

Strategic planning application stage 1 referral Town & Country Planning Act 1990 (as amended); Authority Acts 1999 and 2007; Town & Country Planning (Mayor of London) Order 2008

Proposal Demolition of buildings and development of a new academy/training centre, indoor pitch, replacement 3G pitch, car parking, floodlighting to replacement 3G pitch and academy match pitch and associated landscaping. The applicant The applicant is Charlton Athletic Football Club the architect is HB Architects and the agent is Signet Planning.

Strategic issues Metropolitan Open Land is the most relevant strategic issue to this application. Recommendation That Greenwich Council be advised that the application broadly complies with the London Plan and need not be referred back to the Mayor.

Context

1 On 5 May 2015 the Mayor of London received documents from Greenwich Council notifying him of a planning application of potential strategic importance to develop the above site for the above uses. Under the provisions of The Town & Country Planning (Mayor of London) Order 2008 the Mayor has until 15 June 2015 to provide the Council with a statement setting out whether he considers that the application complies with the London Plan, and his reasons for taking that view. The Mayor may also provide other comments. This report sets out information for the Mayor’s use in deciding what decision to make.

2 The application is referable under Category 3D of the Schedule to the Order 2008:

3D: Development— (a) on land allocated as Green Belt or Metropolitan Open Land

3 Once Greenwich Council has resolved to determine the application, in this instance, it is not required to refer the application back to the Mayor.

4 The Mayor of London’s statement on this case will be made available on the GLA website www.london.gov.uk.

page 1 Site description

5 The application site is located within an area of Metropolitan Open Land (MOL) comprising both areas of open space and land in recreational use spread across 36.5 hectares and bounded by Bexley Road (A210) to the north, Footscray Road (A211) to the west, with Avery Hill Road defining its southern and eastern boundaries. The application site is 13 hectares in total with a gently sloping topography towards its southern edge. It is accessed from the south via Sparrow Lane, a narrow access road flanked by semi-detached housing towards the junction with Avery Hill Road at its southern end. The proposal site is located towards the centre of the area of Metropolitan Open Land and within the existing complex of Charlton Athletic Football Club’s training grounds.

6 The existing facilities consist of the Pippenhall building lying in the northern part of the site which is used mainly for educational purposes; a second building/portacabin used as a classroom and the Community Trust offices (on the north western boundary). These facilities have a collective footprint of 1,019 sq.m. A number of other sports grounds immediately surround the site including Footscray playing fields to the west and Cambridge Mission Sports ground to the east. The ’s Avery Hill campus lies to the eastern edge of the MOL, which is made up of a series of two storey perimeter blocks. The surrounding context surrounding the MOL is predominantly low-rise suburban housing.

7 The nearest section of the Road Network (TLRN) is the A20 Road, 1.7 kilometres south of the site. The site is currently served by two bus routes (162 and B13) on Avery Hill Road. An additional four bus routes (160, 233, 314 and 321) serve Footscray Road. New rail station is situated 1 kilometre to the south-west of the site, which is on the Dartford Loop line. The site records a low Public Transport Accessibility Level (PTAL) of 2, on a scale of 1 to 6 where 6 is the highest.

Details of the proposal

8 The proposals are formed as two concurrent planning applications. Application one involves the development of a combined professional, academy and community trust facility with adjoining indoor playing surface. This will result in a total built footprint of 2,170 sq.m and is to be located on land in use as five-a-side pitches, immediately to the south of a mature treeline at the centre of the site. This application also includes the extension and enhancement of an existing 3G playing surface to meet the requirements of Academy players and the provision of floodlighting to an existing natural grass pitch immediately to the south of the proposed facility hub. This will be designated as a show pitch and is a key requirement of the Premier League’s Elite Performance Plan (EPPP), in order to achieve Category one status.

9 Application two involves the construction of a two storey pavilion building on the existing community car park at the southern end of the site. This will have a built footprint of 165 sq.m. and is designed to consolidate existing changing rooms and education facilities which are currently housed in a range of low quality buildings and portacabins, distributed along the western edge of the site. A new floodlit 3G pitch for use by the Community Trust is also proposed, immediately to the north of the existing community car park at the Sparrows Lane end of the site.

Case history

10 The Mayor considered a previous iteration of the proposals on 30 April 2014 where it was concluded that the application was in broad compliance with London Plan policies relating to Metropolitan Open Land, leisure/tourism and urban design and the Mayor did not wish therefore to be consulted on the proposals following the Council’s committee decision. This application was

page 2 subsequently granted planning permission by Greenwich Council.

11 In assessing the previous application, the Council accepted that the proposals met the special circumstances criteria of the NPPF in that the facilities hub building was recognised as being essential to enabling the club to meet the requirements necessary to achieve EPPP Category one status, and thereby remain competitive with other academies operated by major football clubs. Strategic planning issues and relevant policies and guidance

12 The relevant issues and corresponding policies are as follows:

 MOL London Plan

13 For the purposes of Section 38(6) of the Planning and Compulsory Purchase Act 2004, the development plan in force for the area is the Greenwich Core Strategy and Development Management Policies Development Plan Documents 2014 and the London Plan (Consolidated with Alterations since 2011).

14 The following are also relevant material considerations:  The National Planning Policy Framework and Technical Guide to the National Planning Policy Framework.  National Planning Practice Guidance. Principle of development - Metropolitan Open Land

15 The whole site is designated within Greenwich’s Unitary Development Plan (2006) as Metropolitan Open Land. Policy 7.17 of the London Plan provides that MOL should be given the same level of protection as Green Belt land in that inappropriate development should be refused except in very special circumstances. Further policy guidance contained within paragraphs 79- 92 of the NPPF on the protection and enhancement of the Green Belt, also applies equally to MOL. Paragraph 89 of the NPPF states that a local planning authority should regard the construction of new buildings as inappropriate, with a number of exceptions. 16 The Club is seeking planning permission for a facility that would enable full compliance with the Premier League’s Elite Performance Plan (EPPP) and thereby achieve Category one status. This is highlighted by the applicant as being essential in order to support the continued growth of the Charlton Athletic Community Trust, the development of the Academy and to meet the future ambitions of the Club. The EPPP is a comprehensive document that forms part of the Premier League rules, including specific requirements for academy facilities and are adopted by Championship clubs who aspire to achieve Premier League status. These requirements include issues relating to student welfare, staffing, recruitment, sports science and training programmes and covers age groups from eight to 21. There are also more specific requirements relating to the provision of medical facilities, the need for a floodlit 3G pitch and an indoor pitch for use all year round with a recommended size of 105 x 68 metres. 17 The applicant has since indicated that the consented application, whilst meeting the majority of Category one requirements, fell short of full compliance due to the lack of a gymnasium as part of the medical facilities (common to all academies); the omission of a parent’s lounge and lack of a permanent indoor pitch. In addition, a number of other aspects of the scheme fell short of minimum space standards, including medical facilities, classrooms and administrative areas. 18 In the context of principle of use and in assessing the impact of the proposed development on the openness of the MOL, the proposals can be categorised into two elements: a) the appropriate element, and b) the inappropriate element.

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19 The appropriate element of the proposed development: - The demolition and removal of the changing/classroom and groundsmen’s facilities which are currently distributed across the western edge of the site and are recognised as falling below the standards required of the EPPP, and their replacement with a two storey community hub pavilion of a 165 sq.m. footprint, located on the existing car park area in the southern portion of the site. - The retaining and refurbishment of the existing Community Trust facility for use as storage. - An extended and enhanced 3G playing surface for the Club’s Academy, within the location of the existing 3G surface to the north of the tree line crossing the northern portion of the site. 20 The above can be considered as appropriate development in the context of paragraph 89 of the NPPF, which states that the provision of appropriate facilities for outdoor sport, outdoor recreation and for cemeteries, as long as it preserves the openness of the Green Belt and does not conflict with the purposes of including land within it; and/or the replacement of a building, provided the new building is in the same use and not materially larger than the one it replace, are exceptions to inappropriate forms of development. These elements of the proposals are recognised as meeting these requirements in that they do not collectively result in any increase of existing building floorspace, height or massing in comparison to the existing distribution of buildings and structures and would therefore ensure the protection of MOL’s quality of openness.

21 The inappropriate element of the proposed development: - The proposed combined professional, academy and community trust facility with adjoining indoor playing surface, which whilst broadly utilising the existing area taken up by five-a- side pitches, is positioned alongside an existing mature treeline, and is of a similar bulk and height to the extant scheme’s facility, is recognised as inappropriate development in the policy context of the NPPF as the new building will be materially larger than the facilities it replaces with a building footprint of 2,170 sq.m. The combined footprint of existing facilities is 1,019 sq.m. 22 Paragraph 87 of the NPPF advises that inappropriate development is by definition harmful to the MOL and should not be approved except in very special circumstances. Paragraph 88 advises that when considering any planning application, local planning authorities should ensure that substantial weight is given to any harm to the MOL. “Very special circumstances” will not exist unless the potential harm to the MOL by reason of inappropriateness, and any other harm, is clearly outweighed by other considerations.

23 In this instance, the applicant has presented a clear operational need for the new facilities in order to achieve full compliance with the Premier League’s EPPP and has cited a number of similar planning applications where this has been accepted as meeting the ‘very special circumstances’ policy requirement of the NPPF. The earliest such case involved an application for EPPP compliant sports facilities within the Green Belt by Derby County Football Club, which was called in by the Secretary of State in 2000. He concluded that the provision of an elite training facility for a major football club constituted ‘very special circumstances’ that could allow planning permission to be granted for the facility in the Green Belt. This principle has since been repeated for a number of similar applications, including Tottenham Hotspur Football Club’s new training facility, located in the Green Belt at Myddelton Lodge, Enfield. This was referred back to the Mayor in April 2015 following the Council’s committee decision to approve, where he concluded that he was content for Enfield Council to determine the case itself, subject to any action that the Secretary of State may take, and did not therefore wish to direct refusal (reference D&P/1330d).

24 Very special circumstances in relation to the operational need for the facilities and their

page 4 collective contribution to the development of football at local and regional level can be considered as an acceptable special case and therefore meet the policy tests detailed above, with regards to inappropriate development on MOL, as set out in the NPPF, the London Plan and Greenwich’s Development Management Policies Development Plan Documents.

Community Infrastructure Levy

25 The Mayor has introduced a London-wide Community Infrastructure Levy (CIL) to help implement the London Plan, particularly Policies 6.5 and 8.3 towards the funding of Crossrail. The rate for Greenwich is £35 per square metre. The required CIL should be confirmed by the applicant and Greenwich Council once the components of the development have been finalised.

26 There are no other strategic policy considerations relating to this particular application.

Local planning authority’s position

27 This is yet to be determined.

Legal considerations

28 Under the arrangements set out in Article 4 of the Town and Country Planning (Mayor of London) Order 2008 the Mayor is required to provide the local planning authority with a statement setting out whether he considers that the application complies with the London Plan, and his reasons for taking that view. Unless notified otherwise by the Mayor, the Council must consult the Mayor again under Article 5 of the Order if it subsequently resolves to make a draft decision on the application, in order that the Mayor may decide whether to allow the draft decision to proceed unchanged, or direct the Council under Article 6 of the Order to refuse the application, or issue a direction under Article 7 of the Order that he is to act as the local planning authority for the purpose of determining the application and any connected application. There is no obligation at this present stage for the Mayor to indicate his intentions regarding a possible direction, and no such decision should be inferred from the Mayor’s statement and comments.

Financial considerations

29 There are no financial considerations at this stage.

Conclusion

30 London Plan policy on Metropolitan Open Land is most relevant to this application. In general, the application complies with this policy for the following reasons:  Metropolitan Open Land: The applicant has provided sufficient information to demonstrate how the proposals meet very special circumstances for the inappropriate element of the scheme. The impact on the openness of MOL is considered to be limited and raises no specific strategic issues.

for further information contact: GLA Planning Unit (Development & Projects Team). Colin Wilson, Senior Manager – Development & Projects 020 7983 4783 email [email protected] Justin Carr, Strategic Planning Manager (Development Decisions) 020 7983 4895 email [email protected] James Keogh, Case Officer 020 7983 4317 email [email protected]

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