15/00526/FUL Kempton Park Racecourse Scale 1:10,000 N © Crown copyright and database rights 2014 Ordnance Survey 100024284. Planning Committee

3rd June 2015

Application No. 15/00526/FUL Site Address Kempton Park Racecourse, Staines Road East, Sunbury on Thames,TW16 5AF Proposal Use of Kempton Park for a temporary park and ride operation in association with the Rugby World Cup 2015 for twelve matches (including two warm up matches) at Twickenham Stadium As shown on the details provided in the Park and Ride Management Plan produced by CSP Ltd received 14.4.2015 and the commitments detailed in the “Agreed Commitments by Kempton Park/CSP and Rugby 2015”, as set out in Appendix 8 of the Park and Ride Management Plan. Applicant Kempton Park Racecourse / The Ward Sunbury East Call in details None Case Officer Matthew Clapham Application Dates Target: Under 13 Valid: 29.04.15 Expiry: 29.07.15 weeks

Executive The application site is a substantial area of land to the south of the A316 Summary Great Chertsey Road and north and east of Staines Road East. The land is predominantly open in character aside from the Grandstands, offices and other associated buildings used for the operation of this well established racecourse. The site is designated as Green Belt.

The application is concerned with the temporary change of use of parts of the land within Kempton Park as a Park and Ride facility in association with the upcoming Rugby World Cup in September and October of this year, together with two warm up games during August and September.

The Park and Ride facility would accommodate up to 3000 cars with spectators being transferred to and from matches by trains or dedicated shuttle buses. The operation would be managed by CSP who are an established car park management company who have retained a contract at Wembley Stadium for 20 years and who also manage events such as the Epsom Derby , the 02 Arena, the 2014 Ryder Cup and all events at Twickenham. The facility is required as the usual car parks that adjoin Twickenham Stadium and are used for the Six Nations matches and Autumn Internationals are largely unavailable, having been designated for use by the media and broadcasters, together with hospitality providers. It is also anticipated that the demographics of the spectators at the World Cup will be different to the usual matches at Twickenham with attendees more likely to use public transport and with over 400,000 international visitors attending matches overall.

The Park and Ride facility would utilize existing entrances to the racecourse and a plan has been submitted for each individual match. This would allow other events that are taking place at the racecourse to operate in tandem with the Park and Ride facility. Temporary floodlights would be required for those events that take place in the evening. 5 matches kick off at 8pm; 1 at 4.45pm; 5 at 4pm and 1 at 2.30pm. All the 8pm kick off matches are either on a Friday or a Saturday evening.

In view of the site's location in the Green Belt, it is accepted that the use of the land for car parking would be viewed as 'inappropriate' development which would represent a departure from the Council's adopted planning policies. However, the applicant's have put forward a strong case which demonstrates a series of 'very special circumstances' that justifies the erection of this particular temporary use on this site, in particular the importance of this international sporting event for the UK.

Subject to any further comments from the Highways Authorities, it is not considered that this temporary use would give rise to any significant transportation or air quality concerns that would justify refusal, subject to the additional traffic management arrangements.

Recommended This application is recommended for approval subject to conditions and Decision confirmation that there are no objections on highway safety or transportation.

MAIN REPORT

1 DEVELOPMENT PLAN

1.1 The following policies in the Council’s Core Strategy and Policies DPD 2009 are considered relevant to this proposal:

 GB1 - Saved Local Plan Policy (Green Belts)  LO1 - Flooding  EN1 - Design of New Development  EN3 - Air Quality  EN7 - Tree Protection  EN13 - Light Pollution  CC2 - Sustainable Travel  CC3 - Parking Provision)

2 RELEVANT PLANNING HISTORY

2.1 The site has been the subject of numerous planning applications, the most relevant being listed below:

04/00203/FUL Construction of an all-weather race track with Approved associated floodlighting and access/service tracks; 19.04.04 demolition of an existing derelict Grandstand and construction of coach and car park; erection of new racing facilities buildings to include 20 additional new loose horse boxes, veterinary facility building and Dope Testing Unit, security offices, loading ramp, machinery storage building; demolition of existing single storey stable lads hostel and construction of a new 2 storey stable lads hostel building. Provision of car park and concourse lighting, water features and landscaping and realignment of edge of Kempton Lake.

96/00411/FUL Continued use of the land and buildings for the Approved for the purposes of holding a fortnightly Antiques Market, together with public and trade exhibitions Displays, sales and auctions.

SPE/FUL/88 Use of approximately 1.05ha of land as a public Approved Market, with associated trader’s parking, together with the use of the existing racecourse car park for visitors’ car parking.

3 DESCRIPTION OF CURRENT PROPOSAL

3.1 The application site is a substantial 32.5 hectare area of land to the south of the A316 Great Chertsey Road and north and east of Staines Road East. The land is predominantly open in character aside from the Grandstands, offices and other associated buildings used for the operation of this well established racecourse. The site is designated as Green Belt. There are existing floodlights at the course together with a turf and an all weather racetrack.

3.2 The application has been submitted by the Kempton Park Racecourse in order to temporarily change the use of parts of the land within Kempton Park as a ‘Park and Ride’ facility in association with the upcoming Rugby World Cup in September and October of this year, together with two warm up games during August and September.

3.3 The Park and Ride facility would accommodate up to 3000 cars with spectators being transferred to and from matches by trains or dedicated shuttle buses. The operation would be managed by CSP who are an established car park management company who have retained a contract at Wembley Stadium for 20 years and who also manage events such as the Epsom Derby , the 02 Arena, the 2014 Ryder Cup and all events at Twickenham. The facility is

required as the usual car parks that adjoin Twickenham Stadium and are used for the Six Nations matches and Autumn Internationals are largely unavailable, having been designated for use by the media and broadcasters, together with hospitality providers. It is also anticipated that the demographics of the spectators at the World Cup will be different to the usual matches at Twickenham with attendees more likely to use public transport and with over 400,000 international visitors attending.

3.4 The Park and Ride facility would utilize the six existing entrances to the racecourse and a plan has been submitted for each individual match, with 7 separate car park areas shown within the site. This would allow other events that are taking place at the racecourse to operate in tandem with the Park and Ride facility. Temporary floodlights would be required for those events that take place in the evening.

3.5 The dates and kick off times of the matches to be using the Park and Ride facility are as follows:

Saturday 15th August 8pm England v France

Saturday 5th September 2.30pm England v Ireland

Friday 18th September 7pm Opening Ceremony

8pm England v Fiji

Saturday 19th September 8pm France v Italy

Saturday 26th September 8pm England v Wales

Saturday 3rd October 8pm England v Australia

Saturday 10th October 4.45pm Australia v Wales

Saturday 17th October 4pm Quarter Final

Sunday 18th October 4pm Quarter Final

Saturday 24th October 4pm Semi Final

Sunday 25th October 4pm Semi Final

Saturday 31st October 4pm Final

3.6 As part of the World Cup organisation and the ticketing process, it is understood that ticket holders will be informed when they receive their tickets that car parking will not be available in the vicinity of Twickenham Stadium and will be guided to this Park and Ride facility. There are three main routes that are considered to be the most likely to be utilised in order to access the racecourse. These being 1) from the south west via the M25/M3 to Sunbury Cross and 2) from the south via the A3/M25 and Hampton Court along the A308 (Staines Road East) and 3) from via the A316. A section of the A316 itself will be closed ahead of, during and after the matches in the Stadium area to ease congestion and to allow buses and coaches to be parked adjoining the Stadium to ease the entry and exit of spectators (I understand the closed section will be between the Hospital Bridge Roundabout and the London Road Roundabout).

3.7 Copies of the proposed site layout, entrances and parking areas are provided as an Appendix.

4 CONSULTATIONS

4.1 The following table shows those bodies consulted and their response. It should be noted that this application is being presented to Committee prior to receiving most responses due to the need to determine the application at the June Committee because of the short timescales between the Committee meeting and the first match. The County Highway Authority have been involved in ongoing meetings with the applicants.

Consultee Comment Advised no objection subject to condition, County Highway Authority formal response awaited. Members will be updated at the meeting. Environment Agency No response to date Environmental Health - No objections Pollution Control Officer (Air Quality) Environmental Health – Noise No objections and Lighting Officer County Council Lead No response to date Local Flood Authority Highways England No response to date London Borough of Richmond No response to date upon Thames Surrey Wildlife Trust No response to date Surrey County Council – No response to date Archaeology

5 PUBLIC CONSULTATION

266 addresses were subject to public consultation and to date 3 letters of objection letters have been received raising the following points: - Increased traffic generation / congestion - Emergency vehicles being delayed - Exhaust fume pollution and air quality - Impacts upon Sunbury residents while benefits are on residents outside of Borough A further letter was received requesting that the car park operator uses temporary traffic lights to assist with traffic flow on Staines Road East

6 PLANNING ISSUES

- Green Belt - Highway Issues and Parking - Residential Amenity, Noise and Light Pollution - Air quality - Flooding, Biodiversity and Archaeology

7 PLANNING CONSIDERATIONS

Green Belt

a) Background

7.1 The site lies within a designated Green Belt and Saved Local Plan Policy GB1 is most relevant as it seeks to ensure only ‘appropriate’ development is allowed in the Green Belt. The National Planning Policy Framework (NPPF) states that the construction of new buildings should be regarded as ‘inappropriate’ development, which by definition would be considered as harmful to the Green Belt and should not be approved except in very special circumstances. The NPPF continues by stating that:-

‘When considering any planning application, local planning authorities should ensure that substantial weight is given to any harm to the Green Belt. ‘Very special circumstances’ will not exist unless the potential harm to the Green Belt by reason of inappropriateness, and other harm, is clearly outweighed by other considerations’.

The following paragraphs assess the proposal on the above basis having regard to the harm to the Green Belt.

b) Harm to the Green Belt

7.2 The NPPF makes provision and details some exceptions where development would not be considered as inappropriate within the Green Belt. One of these

exceptions would include the re-use of the buildings. In this instance, the use of the land is the subject of the application and it will result in the land being covered by up to 3000 cars. It is accepted that this use for extensive car parking would therefore not be deemed as “appropriate” when having regard to the NPPF and the Planning Policy Guidance Note on Green Belts.

7.3 While some the parking areas are already in use for parking and are already laid out in hardstanding, other parking areas (which are permitted to support the racecourse use and are therefore not unrelated to the site), particularly that at the centre of the course and those to the south and south east of the site are open grassland. Given the open character and undeveloped nature of these parts of the application site, it is acknowledged that the use would clearly affect the openness of the existing Green Belt to some degree and the areas of car parking would be visible within the Green Belt which would result in some visual harm to the Green Belt setting. The change of use is therefore ‘inappropriate’ and causes some visual harm which must be added to the ‘substantial weight’ to be given to the principle of the ‘development’ in this case. As described below there must also be added the ‘slight’ harm from lighting and ‘limited’ harm from additional traffic. Set against this is the very substantial benefits for the country in hosting such a prestigious international sporting event with wide public appeal. In Green Belt terms it is considered the ’inappropriateness’ and ‘other harm’ is very clearly outweighed in this case subject to the management controls proposed.

c) Very Special Circumstances

7.4 This application is for a temporary period, comprising 12 matches on 12 separate days. It is part of the Rugby World Cups transport strategy to ensure the smooth running of the tournament. It is described as ‘an essential part of the wider transport strategy for the Twickenham Stadium matches, due to its sustainable location being adjacent to a railway station, its proximity to Twickenham Stadium and the existing number of parking spaces’ and the proposal is fundamental to facilitating the world class sporting event’. The Rugby World Cup has in some quarters been described as the third largest international sporting event behind the Olympic Games and the Football World Cup. I understand that the most recent event in Europe (France 2007) was attended by over 2.2million spectators and generated income of £257m.

7.5 Due to the amount of parking spaces required, there are limited realistic alternative sites within this close a proximity to Twickenham Stadium. The parking spaces usually used by the Stadium are largely unavailable as they will be occupied by the broadcasting, media and hospitality functions. Any other parking capacity will be reserved for athletes, team officials, technical officials, press, broadcast, workforce and tournament guests. 500 spaces have been sourced at Hounslow Civic Centre and Blue Badge Holders will be accommodated at the Tesco Car Park adjoining the stadium. In terms of those matches which kick off at 8pm there are concerns that in the absence of an alternative parking area or other modes of transport, there is likely to be significant congestion at Twickenham station after the matches as spectators attempt to catch trains before the last train for their individual destination and in some cases, miss the last train.

7.6 In assessing Green Belt proposals, it has already been explained that substantial weight must be given to the harm to the Green Belt. It is also considered that the amount of cars parking at the site, notwithstanding the existing parking areas and hardstanding, the scheme would lead to moderate additional visual harm. However, in view of the fact that the use is on a temporary basis to facilitate the operation of an International event and that the existing racecourse already has a capacity in excess of 20,000 people with associated parking the need for this use is genuinely ‘very special’ and clearly outweigh the Green Belt harm. Taking the above into account, it is considered that the objections raised on Green Belt grounds cannot be sustained in this particular instance.

Design, Appearance and Visual Impact

7.7 No physical development is proposed. There will be temporary signage and temporary floodlights for those areas where lighting does not already exist. The lights, mounted on wheels are 9.14m when in use and may be folded down to 1.73 in height when not in use. Given the temporary nature of the use, the adverse impact of the additional lighting will be ‘slight’.

Highway Issues and Parking

7.8 The County Highway Authority have been involved in discussions with the applicants regarding the proposals. They have not objected to the proposal subject to a condition and any further responses will be reported orally to the Committee. Similarly, the response of Highways England who are responsible for the nearby M3 and A316 is awaited, although I understand that they have already been involved in the transport arrangements in view of the closure of the A316 near the Stadium on Matchdays. A Park and Ride Management Plan has been submitted as part of the application. This confirms that the organisation and delivery of the tournament traffic management plan and car parking operations will be done by an established company in CSP who already manage events at Twickenham Stadium and Kempton Park itself.

7.9 The arrival of up to 3000 cars together with other events taking place at the racecourse will inevitably lead to an increase in traffic movements in the area and this cannot be disputed. However it should be noted that the Park and Ride Management Plan has been set up to carefully plan the events and to ensure the smooth operation of the parking and transport arrangements. The transport routes, parking arrangements and plans have been submitted for each individual match day showing which car parks and entrances will be used for each match.

7.10 The applicant has confirmed that as a result of this proposal a total of 6,750 parking spaces would be available on the site at any one time. With the Park and Ride spaces being limited to 3000 cars, this allows in excess of 3000 spaces for the other events that will be taking place at the racecourse in parallel with the temporary Park and Ride facility ensuring that there would be no requirements for cars to be parked in adjoining roads off the racecourse at peak times.

7.11 The applicant has also stated that the proposal will facilitate sustainable travel modes for the Rugby World Cup, as such any potential harm arising from the

Park and Ride operation in the local highway network should be balanced against the sustainable benefits of the proposals to the wider highway network and transport strategy for the Rugby World Cup. It is also pointed out that the majority of the Twickenham matches are held at the weekend outside normal weekday peak hours. In addition, were the transport arrangements to be left unmanaged with spectators being allowed to make their own way to Twickenham Stadium, a significant number would use the busy A316 and may well use local roads to avoid traffic hold ups and attempt to find alternative routes to try and get to the Stadium via Hampton and Teddington to the south or Ashford and Feltham to the north.

7.12 In terms of general transportation, two additional trains are being provided to operate from Kempton Park Station each hour to complement the existing two trains per hour. The two additional trains will run directly to Twickenham, while the two existing scheduled trains will require passengers to change at Teddington. The additional trains will allow the smooth transfer of spectators to the stadium. On the return back to Kempton Park after matches, due to the predicted congestion at Twickenham Station, it is considered that most spectators will utilise the shuttle buses which due to the closure of part of the A316 will be parked up by the Stadium to a swift return to Kempton Park.

7.13 Whilst there is some harm that will arise on 12 occasions from the traffic generated by the proposal this is mostly at weekends and at times when prevailing traffic levels are lower than weekdays and such potential inconvenience from this would be limited. separate matches over a two and a half month period, it is not considered that the level of traffic movements is such that would cause significant adverse impacts upon Spelthorne residents and the benefits of supporting the transport strategy for a prestigious International event clearly outweigh the potential harm from the change of use.

Residential Amenity, Noise and Light Pollution

7.14 The proposed Park and Ride Scheme would utilise the existing entrances to the course and many of the existing parking areas. In addition, as part of the management plan various measures are being taken to minimise disruption to local residents. The Kempton Park existing Traffic Regulation Order will be in place to prevent parking off site in local roads and the car park D in the centre of the course will be utilised as a priority where possible and each car park will be filled first at the furthest point away from residential properties. The shuttle buses themselves will be directed directly to and from the Sunbury Cross Roundabout and the A316 to avoid any buses travelling along the Staines Road East. Due to the closure of the A316 it is anticipated that spectators will quickly leave the Stadium and get back to Kempton Park with a journey time of approximately 10mins. This will enable the car parks to close for the evening matches by 11.30pm at the latest with the majority of spectators having left comfortably before this time.

7.15 In terms of lighting, a maximum total of 16 temporary lights will be provided and used when necessary, with it being unlikely that all 16 will be used at any one time, with car park D at the centre of the course being the car park that will be most utilised for 11 of the 12 matches. Unless contingencies apply, the car parks E and F, those closest to residential areas will only be used on two

occasions. The Management Plan also states that lighting will be turned off as soon as the car parks are emptied of spectators. As stated previously, the park and ride facility will only be used on 12 occasions over a two and a half month period. The Councils Environmental Health Officer has not raised any objections in terms of noise or light. The racecourse is a public facility with events taking place on a regular basis and while some additional noise and disturbance may be expected, it is considered that the measures that have been set up as part of the management plan are sufficient to ameliorate any significant concerns regarding impacts upon local residents.

Air Quality

7.16 The applicant has submitted an Air Quality Assessment with the application. Sunbury Cross is one of the most sensitive areas in terms of Air Quality within Spelthorne Borough. The Assessment has concluded that predicted air quality impacts as a result of the park and ride were not significant at any sensitive location within the vicinity of the site. Notwithstanding this, the Assessment has highlighted various mitigation measures that will be used to minimise any impacts. These include the advantages of a stringent management plan to allow the smooth passage of vehicles, checking tickets on entry to car parks rather than the racecourse gates to avoid stopping traffic flows on the adjoining roads, the additional train services that are being provided that will allow approximately 800 passengers per journey to use public transport rather than attempting to drive into Twickenham. On the journey to the Twickenham Stadium from Kempton Park, spectators will be encouraged to utilise the trains rather than shuttle buses to further reduce emissions. The Councils Environmental Health Officer have not objected to the proposal on the basis that the air quality impacts from these 12 events are likely to have a limited impact on Air Quality as a result of the proposal and it is not considered that the additional movements generated would sustain a justifiable pollution objection and arguably the escalation of parking with public transport use results in less potential impact on air quality in the wider area than would arise if the facility were not provided.

Flooding, Biodiversity and Archaeology

7.17 The applicants have submitted a Flood Risk Assessment (FRA). Parts of the site are located within the 1 in 1000 year event Zone 2 Flood Risk Area. No built development is proposed and the use is temporary both in terms of the 12 events and also with the cars moving off the site within a few hours of arriving. The FRA continues by stating that the flood risk to the site is low, particularly as the events are being held in the summer / early autumn and that the risks are manageable by the Kempton Park Racecourse and will not increase flood risks elsewhere. Therefore the application is considered to be acceptable on flooding grounds and would comply with Policy LO1 of the CS & P DPD.

7.18 Part of Car Park F is located with an Area of High Archaeological Potential. As no ground disturbance is anticipated, there are not considered to be any concerns regarding this issue. The lake towards the northern part of the site, ‘Half Moon Covert’ and a reservoir on the eastern part of the site are designated as Sites of Nature Conservation Importance (SNCI) and the Reservoir is also a Site of Special Scientific Interest (SSSi). A very small part of the lake falls within car park D with existing internal routes that may be used

falling in close proximity to both the lake and ‘Half Moon Covert’. In view of the temporary nature of the use and the existence of both the racetrack and the existing routes and racetrack on parts of these areas, it is not considered that there are any specific concerns regarding the SNCI. The reservoir subject to an SSSi is some distance from the proposed parking areas and no adverse impacts are considered to arise.

Conclusion

7.19 In terms of Green Belt the applicants have demonstrated ‘very special circumstances’ which clearly outweigh the Green Belt harm to justify the temporary of the site as a Park and Ride facility for the Rugby World Cup. This is subject to satisfactory responses from the Highways Authorities. On all other considerations the proposal is also acceptable. The application for a Park and Ride facility is therefore recommended for approval.

8 RECOMMENDATION

8.1 Subject to satisfactory responses being received from the Highways Authorities to GRANT planning permission, subject to the imposition of conditions as set out below.

CONDITIONS

1. That this permission be for a limited period of 77 days only, commencing 15th August 2015 and expiring on 31st October 2015 when the use hereby permitted shall be entirely discontinued, unless an emergency extension of time is requested and approved in writing by the Local Planning authority.

Reason:-.To safeguard the openness of the Green Belt, the visual amenity of the area and the amenity of local residents.

2. That the use be carried out in accordance with the details provided in the Park and Ride Management Plan produced by CSP Ltd received 14.4.2015 and the mitigation measures detailed in paragraph 6.1.2 in the Air Quality Assessment produced by Redmore Environmental received 29.4.2015.

Reason:-.The condition above is required in order that the development should not prejudice highway safety, nor cause inconvenience to other highway users, and to accord with the National Planning Policy Framework 2012 and policies CC2 and CC3 of Spelthorne Borough Council's Core Strategy and Policies Development Plan Document February 2009.

3. The Park and Ride operation shall comply with the commitments detailed in the “Agreed Commitments by Kempton Park/CSP and England Rugby 2015”, as set out in Appendix 8 of the Park and Ride Management Plan.

Reason:-.The condition above is required in order that the development should not prejudice highway safety, nor cause inconvenience to other

highway users, and to accord with the National Planning Policy Framework 2012 and policies CC2 and CC3 of Spelthorne Borough Council's Core Strategy and Policies Development Plan Document February 2009.

4. The development hereby permitted shall be carried out in accordance with the following approved plans:- 957/29/3_SLP01 and 957/29/3_PAR01 received on 14.4.14.

Reason:-.For the avoidance of doubt and in the interest of proper planning.

5. The lighting arrangements hereby approved shall only be used on the 12 event days unless agreed in writing by the Local Planning Authority and the lights shall be switched off and lowered as soon as each car park is empty of vehicles.

Reason:-.To safeguard the residintial amenity of the occupiers of the adjoining properties) in accordance with policies SP6 and EN1 of the Spelthorne Borough Core Strategy and Policies Development Plan Document 2009.

PARK & RIDE PLAN KEMPTON PARK

Scale @ A3 : Not to Scale

Plan No. : 957/29/3 _PAR01

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