Application no: 20150081
Location: The PHB Stadium, Ebbsfleet United Football Club Ltd Stonebridge Road Northfleet Gravesend DA11 9GN
Description: Hybrid planning application (part outline and part full detailed) for the proposed phased demolition of existing stands, ancillary buildings and structures and erection of new Stonebridge Road Stand (Phase 1 - full detailed) and erection of Plough End, Town End and Swanscombe End Stands with associated access and parking (Phase 2 - outline with all matters except layout reserved).
Applicant: Ebbsfleet United Football Club
Decision Level: Planning Regulatory Board
Recommendation Permission with Conditions and Informatives
Draft recommended conditions will be set out in a supplementary report
1. Site Description
1.1 The site comprises the Ebbsfleet United Football Ground currently known as the PHB Stadium in Stonebridge Road, Northfleet situated in an industrial/commercial location near the western edge of the Borough.
1.2 The ground has three stands and an open end at the western end of the ground (Swanscombe end) and there are other areas adjacent to the stands which are also uncovered and open to the elements.
1.3 The Town or main stand on the north side of the pitch, and which contains the changing rooms and offices, is the oldest stand at the ground dating from 1914 and is a partly wooden and partly corrugated iron sheeted structure.
1.4 At present the Stadium holds around 4,532 spectators of which 500 are seated. There is no restriction on ground capacity in planning terms. Average attendances at the ground are considerably lower than this - in the current season (2014/2015) this is around 960. Capacity crowds have though on occasions been attracted, most recently for the Conference play-off final against Dover Athletic at the end of the 2013/14 season which drew an attendance of 4,294 and Ebbsfleet United was the highest attended club in their division for last season.
1.5 The club currently play their fixtures in the Vanarama Conference South division, one league from the Football Conference division and thus two leagues away in the football pyramid from Division 2 of the Football League. The football ground has been in active use for sporting purposes since 1905. 1.6 Gravesend & Northfleet Football Club, as it was previously known, was born as a merger of two existing neighbouring clubs - Gravesend United and Northfleet United in 1946. The club has had a long history with some limited success in the lower divisions outside of the Football League including being within the Football Conference and most notably winning the FA Trophy at Wembley in 2008. In May 2007 the club had changed its name to Ebbsfleet United and in February 2008 had been taken over by an internet venture MyFootballClub.co.uk involving paid members owning the club and voting on decisions. In May 2013, the club was purchased by a Kuwaiti company, KEH Sports Ltd. The Borough Council are however the current landowners of the ground.
1.7 There have been some recent ground improvements including refurbishment of the toilets at the rear of the Town stand. The Stonebridge Road stand (more recently renamed the Liam Daish Stand) originally built in 1959, and which replaced a smaller stand dating from 1920, has also been renovated in the last few years but there are no spectator facilities within that stand. The Town stand, which contains the club office, only has a maximum of two years life while parts of the Plough end stand, built in 1952, are closed due to the dilapidated state of the concrete terracing. The un-covered Swanscombe end terracing was re-terraced to more modern safety standards in 1980.
1.8 There are some limited commercial and corporate facilities within the ground. There is a supporter’s club bar adjacent to and east of the Plough end stand with other facilities including toilets around the ground, a club shop (located in a container), various refreshment kiosks/mobiles, grounds keepers store, a rain water harvesting tank and a sponsor’s lounge (within a portacabin). There is also a portacabin and two containers in the car park within the ground used for storage and maintenance.
1.9 The Stonebridge Road frontage has a number of large advertisement hoardings either on the roadside boundary or just behind the boundary of the ground which is enclosed partly by timber fencing and partly by concrete panel fencing.
1.10 The total site area of the ground as shown in the red line plan is 1.75 hectares (4.4 acres)
1.11 Adjoining uses include:-
to the north-west: a terrace of 4 residential properties (64-67 Stonebridge Road) on the A226/Lower Road signalised junction, an area of open land and warehouse units on the Northfleet Industrial Estate; to the north-east: a builder’s merchants and further small industrial units, with an aggregates wharf beyond; to the south-east: a car wash facility and workshop building, with the Ebbsfleet stream underground in culvert and beyond that the former Plough Inn, now a cafe and restaurant; and to the south-west, across the A226: a car dealership, petrol filling station, a retail unit and former furniture warehouse now used as a gymnasium; and the Ebbsfleet Industrial Estate.
1.12 Other nearby residential properties include Railway Street and Wallis Park, Northfleet to the south east of the ground and 70m and 100m away from the ground respectively and Phoenix Court, Swanscombe, 130m to the south west of the ground.
1.13 Vehicular access to the site is from the A226 Stonebridge Road roundabout and from the A226 Stonebridge Road at a point immediately behind the Swanscombe End terracing, some 160 metres to the west. These vehicular access points are also shared by pedestrians entering the football ground via the home and away turnstiles. There are 4 pairs of turnstiles at the home entrance into the ground. Adjacent to the home turnstiles and vehicular entrance is a small brick Southern Water pumping station building, originally a Northfleet UDC building dating from 1932.
1.14 Stonebridge Road is a single carriageway road with one running lane in each direction but has wide 3.0m plus lanes and is subject to a 30mph speed limit. There are footways both sides and the carriageway and footways are lit. There are traffic lights beyond the stadium to the west at the junction of the A226 with Lower Road.
1.15 Part of the open area to the north-west of the football ground is used for car parking on match days and provides parking for approx. 70 cars. The remainder of this open area comprises a fenced compound currently used by Sian Formwork Ltd, civil and construction engineers, including CCS Scaffolding but was once used for further ground car parking and other storage uses. Vehicular access to the football ground and to Sian Formwork is shared in this location. An electricity pylon also occupies a central position within this open area, with a 400KV National Grid power line crossing the site.
1.16 On match days an additional 20 spaces are provided for players at the adjoining Sian Formwork Ltd compound. Some 550 parking spaces are available for spectators at the Ebbsfleet International Station Car Park C which is an approximate 5-10 minutes walking time from the ground. Ebbsfleet International Station and Northfleet station are within walking distance from the ground and provide access to spectators to the national rail network. There are bus stops outside the ground in Stonebridge Road which provide access to a wide range of bus services including Arriva’s Sapphire Bus Route.
1.17 Coaches arriving with either supporters or visiting teams drop off and then park away from the ground. For supporters the coaches park at the Ebbsfleet International Car Park C; for visiting teams that arrive by coach, provision is made within the Club’s parking area.
1.18 The open area to the north-west of the ground occupied by Sian Formwork and for stadium car parking was once allotments. Moreover much of the area now occupied by the football ground was once a clay pit serving a local cement works. Whilst this was restored during the 1890s, there is no record of its depth or the fill material used. It is also understood that the football ground terracing comprises made-ground with concrete steps over.
1.19 The whole of the site is low lying (at 3.0-3.5m AOD) and would be susceptible to flooding (being within the Environment Agency’s Flood Zone 3a) should the Thames flood defences fail or be overtopped during an extreme tidal event. The site could also be affected by flooding from the Ebbsfleet stream during an extreme pluvial event, notwithstanding the fact that the adjoining section is in culvert.
1.20 The site lies within an Air Quality Management Area (AQMA) which was designated in 2002 in recognition of existing poor air quality due to high concentrations of particulate matter (PM10s).
2. Planning History
2.1 The use of the Stonebridge Road ground as a football stadium is an historic one, pre- dating the introduction of planning legislation in 1947.
2.2 There is a significant amount of planning history since then. This includes:
TH/3/57/084: Erection of turnstiles and entrances. Permitted 6.6.1957
19750853: Outline application for erection of replacement club house. Permitted 30.3.76
19760458: Details of single storey club house. Permitted 30.6.76
19780298: Erection of four 21 metre high floodlight pylons. Permitted 14.4.78
19790482: Construction of new concrete terracing and erection of new covered stand at Swanscombe End erection of men’s wc and new turnstiles and erection of boundary wall to Stonebridge Road. Permitted 28.06.1979
19800986: Erection of two storey rear extension to main spectator stand. Permitted 23.12.1980
20071068: Demolition of existing terracing and erection of a modular building to provide a study centre. Permitted 25.01.2008
20131012: Removal of existing floodlights and erection of four 18 metre high floodlight columns. Permitted 20.12.2013.
3. Proposal
3.1 The proposal is for redevelopment of the PHB Stadium to provide an enhanced and improved football stadium for Ebbsfleet United football club and enhanced facilities for the local community.
3.2 It will comprise:
A new main stand to the Stonebridge Road elevation (Phase 1A)
The removal of the existing concrete terracing and the provision of new terracing at the ‘Plough End’ of the ground. The terracing being suitable for seating at a later date (Phase 1B)
The removal of existing concrete terracing and the provision of new terracing at the ‘Swanscombe End’ of the ground. The terracing being suitable for seating at a later date (Phase 1C)
The demolition and construction of a new stand to replace the existing main (Town) stand (Phase 2)
Car parking and all other ancillary areas.
3.3 It is stated that Phase 1A will commence by May 2015 at the latest with Phases 1B and 1C following after completion of Phase 1A so that the disruption to supporters and the reduction in ground capacity is kept to a minimum. The new main stand to the Stonebridge Road elevation, Phase 1A, is to be progressed and completed as soon as possible during the 2015/16 football season and it is hoped that the stand could be used for spectators before the internal areas of the stand are complete. 3.4 All of the main facilities are contained in the current main stand and these will continue to be used until the new main stand, Phase 1A, is complete in all respects. At that stage EUFC will take a decision regarding the demolition and construction of a new stand to replace the existing main stand as Phase 2 of the redevelopment.
3.5 The planning application is a hybrid one – part fully detailed and part in outline, with the Phase 1A stand to Stonebridge Road comprising the detailed component and plans of the remaining stands being illustrative only.
3.6 The application submission comprises:
1. Covering letter and application form from Planning and Development Associates (PDA) 2. Planning Statement (including Heritage Statement) from Planning & Development Associates (PDA) 3. Design & Access Statement from Alexander Sedgley Ltd, Architects 4. Drawings and 3D images from Alexander Sedgley Ltd, Architects 5. Archaeological Desk-Based Assessment from Swale & Thames Archaeological Survey Company 6. Vision Statement from Ebbsfleet United Football Club (EUFC) 7. Statement of Community Engagement EUFC/PDA 8. Draft Travel Plan from EUFC 9. Transport Statement from PDA 10. Phase I & II Ground Investigation Report from Environmental Protection Strategies Ltd 11. Phase II Environmental Report + Appendices from Herts & Essex Site Investigations 12. Environmental Sustainability Statement from AECOM 13. Biodiversity Report from FOA Ecology Ltd 14. FRA/SUDS from Marks Heeley Ltd 15. Construction Management Plan from Faithorn Farrell Timms (FFT)
The applicants have provided officers with a business plan to demonstrate viability of the scheme but this does not form part of the application submission.
3.7 In respect of the height of the new development the replacement Stonebridge Road stand as part of the phase 1 works will be built to a height of generally 9.7m high, compared to the current Liam Daish stand of 7.3m, thus an increase of 2.4m in height (or just over 8ft) with only at one end (at the eastern end) increasing to 10.4m as the proposed replacement stand there (to be built as a later phase) is a slightly higher stand. That stand will be a replacement for the Plough end stand which is currently 7.0m high.
3.8 The Town end stand (where there is existing seating and the changing rooms and offices for the club) and which is currently 7.3m high will be replaced by a new stand shown in the illustrative plans as being to a height of approx. 6.4m, thus lower than the present stand, and the Swanscombe end terracing where there is no stand or cover from the elements will also have a low stand of about 6.4m in height.
3.9 The following materials are proposed for the new Stonebridge Road stand:
Low level walls - Dark grey coloured Forticrete blockwork. High level walls - Curtain walling with areas of clear glazing and translucent red coloured metal sheet. Roof - Red coloured metal sheet. An anti-graffiti coating could be applied to the polished forticrete concrete blocks and the metal work.
3.10 The new Stonebridge Road stand will include solar panels. However there are no changes currently planned in the way of new communications equipment such as masts, tv gantry, cctv, satellite dishes, scoreboards, screens or other digital displays at the ground or new PA equipment.
3.11 There are no proposed changes to the newly installed Floodlighting system with the exception of the slight movement of one pylon and realignment of associated bulbs. The new Floodlights were installed in 2014 and are of Football League standard (400 lux).
3.12 The existing advertisement hoardings to the Stonebridge Road frontage will be removed apparently ahead of the planned development.
3.13 It is proposed that the main car park will remain at the Swanscombe End of the Stadium. However, the Club confirms that they will resurface the existing Swanscombe End Car Park upon final phase completion and will also provide lined vehicle bays. The Club is also providing a 10 bay covered and secure cycle parking facility within the Phase 1A development at the Stonebridge Road stand.
3.14 In respect of facilities for spectators with disabilities the Club has advised that wheelchair users will have dedicated access to watch the games off the terrace walkway at high level within the new stand that is accessed by platform lifts from both ends of the stand. The Club also confirm that within its main Swanscombe End Car Park that four spaces are dedicated closest to the turnstiles as Disabled Vehicle bays, one of which is allotted to away disabled supporters providing it is booked prior to match day, and that visiting teams are made aware of this facility.
3.15 The proposed community use of the stadium is set out in the Club’s vision statement and community engagement plan. The vision is to create a football league club with a 6,000 spectator capacity in a family orientated stadium. The proposal is to create a community hub within the new main stand. The club has already been undertaking community initiatives for several years. The community hub will continue those initiatives offering local groups a venue to hold events including health and youth employment and career clinics and evening social diversionary activities with young people. The stand will include, for example, a room for a sound recording/mixing studio.
3.16 The proposals are not part of a wider mixed use redevelopment for the site and neither do they include other commercial activities such as separate retail uses other than as ancillary to the main use.
3.17 As part of the negotiations with the club during both the pre-application enquiry stage and the processing and evaluation of the planning application the club have been asked to consider highway improvements just outside the ground in terms of improving both parking arrangements and pedestrian safety and movement. The club has agreed to undertake such improvements at an agreed phase of the development and these have been set out in an additional drawing with such works to be carried out under a s278 agreement. 4. Planning Policy Considerations
4.1 Section 38(6) of the Planning and Compulsory Purchase Act 2004 requires applications to be determined in accordance with the development plan unless material considerations indicate otherwise. Where there are other material considerations, the development plan should be the starting point, and other material considerations should be taken into account in reaching a decision. One such consideration will be whether the plan policies are relevant and up to date.
4.2 The Regional Strategy for the South East (the South East Plan) was partially revoked on 25 March 2013. Since then development plans across the former South East government office region have comprised local plans, and where they exist, neighbourhood plans.
4.3 The Borough Council has been in the process of preparing a new Local Plan (Core Strategy) to replace the adopted Local Plan First Review 1994 since 2005.
4.4 Following a number of public consultations, the Council submitted the Local Plan Core Strategy to the Secretary of State in May 2013. This was then examined by an independent Inspector and the Inspector’s Report was received in July 2014. The Inspector found that the Core Strategy is sound and provides an appropriate basis for the planning of the Borough to 2028, providing a number of main modifications are made.
4.5 At the GBC Full Council meeting on 30 September 2014 the Council adopted the Gravesham Local Plan Core Strategy and Policies Map with immediate effect. The adopted Core Strategy incorporates all the modifications recommended by the Inspector in his Report and set out in the accompanying Schedule of Modifications and it also includes additional minor modifications. The policies in the adopted Core Strategy replace many of the Local Plan First Review saved policies and the First Review Proposals Map.
4.6 The Council also agreed that the Gravesham Local Plan Second Review (Deposit Version) (2000) should no longer be used as a material consideration for development control purposes.
4.7 The Development Plan for Gravesham therefore now comprises:-
The Gravesham Local Plan Core Strategy (September 2014) Remaining Saved Policies of the Local Plan First Review (1994) Saved Policies from the Kent Minerals and Waste Local Plans.
4.8 There are a number of other planning policy documents which are of some relevance to the consideration of planning applications and are material considerations, including national planning advice and guidance in the National Planning Policy Framework (NPPF), the National Planning Practice Guidance (NPPG), and supplementary planning guidance.
Local Planning Guidance
Gravesham Local Plan Core Strategy, September 2014
4.9 The Core Strategy sets out the Council's spatial vision and strategic objectives for the Borough to 2028 and the policies which will deliver them. It identifies the main areas where major change is likely to take place and allocates sites which are key to achieving the strategy.
4.10 The application site is shown as being within the urban area and fronting on to a district distributor in the Gravesham Local Plan Policies Map.
4.11 The most relevant policies from the adopted Core Strategy in relation to this development are as follows:
Core Strategy Policy CS01: Sustainable Development Core Strategy Policy CS02: Scale and Distribution of Development Core Strategy Policy CS03: Northfleet Embankment and Swanscombe Peninsula East Opportunity Area. Core Strategy Policy CS08: Retail, Leisure and the Hierarchy of Centres Core Strategy Policy CS09: Culture and Tourism Core Strategy Policy CS10: Physical and Social Infrastructure Core Strategy Policy CS11: Transport Core Strategy Policy CS13: Green Space, Sport and Recreation Core Strategy Policy CS18: Climate Change Core Strategy Policy CS19: Development and Design Principles Core Strategy Policy CS20: Heritage and the Historic Environment
4.12 A Site Allocations and Development Management Policies Development Plan Document will be prepared following the adoption of the Core Strategy.
4.13 Of particular note is policy CS03 as the football ground is within one of the Borough’s identified opportunity areas (Northfleet Embankment and Swanscombe Peninsula East) being within sub area 1.3 and indicated as having regeneration potential but where the potential for redevelopment is constrained by ground conditions, heritage and archaeology and existing uses (such as the football ground)
Gravesham Local Plan First Review 1994
4.14 The Gravesham Local Plan First Review was originally adopted in November 1994.
4.15 A substantial number of policies of the Gravesham Local Plan First Review were saved by a Direction dated 25 September 2007 of the Secretary of State under paragraph 1 (3) of Schedule 8 to the Planning and Compulsory Purchase Act 2004 as transitional arrangements pending adoption of the Core Strategy.
4.16 Saved policies contained in the Gravesham Local Plan First Review should still be accorded significant weight, albeit that the weight accorded should be greater where policies are consistent with the National Planning Policy Framework (NPPF, paragraph 215).
4.17 Those Local Plan First Review policies that remain in force are listed in Appendix 1 of the Local Plan Core Strategy. The remaining saved policies will be replaced following the adoption of the Site Allocations and Development Management Policies Development Plan Document.
4.18 The following remaining saved policies are relevant to the consideration of this application:
Policy T1: Impact of Development on the Highway Network Policy T2: Channelling of Traffic onto the Primary and District Distributor Network Policy T3: Development Not Well Related to the Primary and District Distributor Network Policy T5: New Accesses onto Highway Network Policy T6: Safeguarding of South Thames-side Development Route (A226 Diversion) Policy P3: Vehicle Parking Standards
National Planning Policy Guidance
National Planning Policy Framework
4.19 The National Planning Policy Framework (NPPF), March 2012, has replaced all the national planning policy guidance (PPG’s) and statements (PPS’s) and is a material consideration.
4.20 At the heart of the NPPF is a presumption in favour of sustainable development (paragraph 14) which means approving development proposals that accord with the development plan and where the development plan is absent, silent or relevant policies are out of date planning permission should be granted unless any adverse impacts would so significantly and demonstrably outweigh the benefits or specific policies in the NPPF indicate development should be restricted.
4.21 The NPPF includes (in paragraph 17) a set of 12 core land-use planning principles underpinning plan making and decision taking.
4.22 The core principles of relevance to this type of development include:
identifying and then meeting the housing, business and other development needs of an area securing high quality design and a good standard of amenity for existing and future occupants of land and buildings; and actively managing patterns of growth to make the fullest use of public transport, walking and cycling, and focusing significant development is locations that are or can be made sustainable. taking account of and supporting local strategies to improve health, social and cultural wellbeing for all, and deliver sufficient community and cultural facilities and services to meet local needs.
4.23 The following sections are considered to be the most relevant in this context:-
• 2: Ensuring the Vitality of Town Centres • 4: Promoting Sustainable Transport • 7: Requiring Good Design • 8: Promoting Healthy Communities • 10: Meeting the Challenge of Climate Change, Flooding and Coastal Change • 12: Conserving and Enhancing the Historic Environment
National Planning Practice Guidance
4.24 On the 6th of March 2014 a new web-based resource for Planning Practice Guidance was launched (http://planningguidance.planningportal.gov.uk/)
4.25 It supports and clarifies areas in the NPPF and replaces a substantial list of guidance documents published from 1978-2013. Supplementary Planning Guidance
4.26 The Council has adopted a number of Supplementary Planning Guidance documents, Development Briefs and Conservation Area Appraisals. These elaborate on saved policies in the Gravesham Local Plan First Review and policies in the Gravesham Local Plan Core Strategy and are material considerations in determining planning applications.
4.27 In addition the Council has adopted a number of documents that have been produced by Kent County Council also as Supplementary Guidance.
4.28 Relevant supplementary planning guidance includes:-
Adopted Kent Vehicle Parking Standards (SPG 4 published in 2003 and adopted in 2006) and endorsed as supplementary guidance by GBC on 6 July 2009.
Planning Policy for vehicular accesses to classified highways (Planning Guidance Note No 6)
5. Reason for Report to the Planning Regulatory Board
5.1 Major development proposal and at officers discretion; the Borough Council are the landowners of the football ground.
6. Consultations, Publicity and Representations
Consultations
Planning Policy Manager, GBC
6.1 Subject to consideration of relevant planning issues and constraints, the proposal to redevelop and upgrade the existing football ground is supported in principle under policy as it would assist in achieving Gravesham Local Plan Core Strategy (September 2014) strategic objective SO15 by improving opportunities for recreation, sport, walking and cycling.
6.2 The proposals also accord with a number of important Core Strategy policies, including CS13 by enhancing the quality and accessibility of this important local sporting facility. It is noted that the proposal also accords with policy CS09 in terms of representing an opportunity to expand cultural and tourist activity in the area. The proposal also has the potential to complement emerging proposals for the nearby London Paramount resort.
6.3 Because the proposal involves the upgrade and redevelopment of an existing stadium and does not easily fit the definition of a ‘more intensive sport and recreation use’ under’ main town centres uses’ set out in the glossary to the NPPF, it is not considered that the requirement to apply the sequential approach under policies CS08 and CS09 is engaged. It also follows therefore that no impact test would be required under policy CS08, subject to any supporting retail or leisure uses being ancillary and of an appropriate scale relative to the primary use of the site.
6.4 The site is considered to be in a sustainable location for a football stadium given its extremely good public transport linkages (bus and train) and potential for shared use of car parking in and around Ebbsfleet Station. The site is also within easy walking distance of the established residential communities of Old Northfleet and Swanscombe.
6.5 The proposal is not considered to be inconsistent with area policy CS03 which, although recognising the potential for regeneration sub-area 1.3, accepts that the football ground may remain in-situ as part of any future proposals but act as a constraint on development adjoining (see paragraph 4.4.6 bullet point 3). It should be noted that this is not considered to be prejudicial to the potential residentially-led regeneration of the Key Site to the east of Grove Road under the same policy.
Regulatory Services -Environmental Health, GBC
Environmental Protection Comments
6.6 Noted the headline figure here is for the Stonebridge Road stadium to be developed with a view to increasing the capacity and associated facilities from around 4,500 to 6,000.
6.7 At the pre application stage the comment was made that it would be expected an agreed comprehensive Code of Construction Practice covering all environmental impacts including pest control from the clearance/construction of this development would be provided. A construction management plan produced by Faithorn Farrell Timms (ref t1-2760) has been provided which gives an outline of general environmental controls including hours of work, no on site burning, wheel wash, noise control, public hotline etc. which are satisfactory. It also makes a commitment that the approved CMP will be completed by the principal contractor who will liaise with Ebbsfleet United Football Club and the Council to revise and approve as required. This is welcomed and this Service will await contact from the principal contractor in due course.
6.8 Requests a planning condition be imposed requiring the submission of a comprehensive Code of Construction Practice covering all environmental impacts.
6.9 At the pre application stage the comment was made that the traffic report would need to include consideration of noise impacts on the nearest residential properties. The transport statement supplied does not make any reference to noise impact.
6.10 It is assumed as there is no mention of any further enhancement to the lighting this will not change in the foreseeable future.
6.11 It is assumed waste management will make comment on the arrangements for disposal and collection of waste for this site.
Contaminated Land comments
6.12 Based on the review of:
Phase I and II Ground Investigation Report; E P Strategies Ltd; 14th October 2014; Ref. UK14.1535 Phase II Environmental Report; Herts & Essex Site Investigations; January 2015; Ref. 12529
The initial phase I and II report identified hydrocarbon contamination affecting parts of the site, including within the groundwater. Very limited soil sampling only was undertaken but this was mainly to aid disposal. No gas monitoring or groundwater sampling was undertaken.
6.13 The further phase II report expanded slightly on the original investigation, however still no ground gas monitoring was conducted and only very limited groundwater sampling. Although the report identifies original sampling locations WS3 and WS4 as being most greatly impacted by hydrocarbons, they focus their attention on WS2 which is known to be located near a historic oil spill. There is no further discussion regarding these other locations. A deep sheet and auger borehole was due to be drilled on the 29th January and as such its details were not included in the report.
6.14 The report concludes that further investigation is required to delineate the extent of the hydrocarbon contamination, both within the soils and groundwater. Six rounds of ground gas sampling are proposed to determine the gas regime of the site. A planning condition is therefore recommended to ensure these works are done.
Air Quality Comments
6.15 There are no comments directly on air quality but would expect the introduction of controlled parking in the area would be a necessity.
GBC Leisure
6.16 From a sports development perspective the Council’s Leisure Team supports the application for the re-development of the Ebbsfleet Utd Football stadium. The redevelopment will improve the supporter’s experience dramatically as well as allowing the club to market itself positively with local residents, especially young people.
6.17 The new stands/stadia will provide a good mix of services that the club requires in order to be successful from both a commercial and community angle. The size of the new development appears realistic in terms of the crowd sizes that would be generated by an existing non-league club with future aspirations to move up the league levels.
6.18 As part of the consultation phase it may be prudent and useful to gain some comment from Sport England from a sports development, stadia and playing pitch site perspective.
GBC Property Services
6.19 No comments
GBC Community Safety
6.20 No comments
GBC Waste Management
6.21 Advises that the EUFC Waste Management and Recycling Statement within the submitted Environmental Sustainability Statement appear to cover most of the issues required with regard to waste management. The only other thing that may help would be the funding of a few litter bins near the entrance to the stadium for people to deposit their litter when approaching the ground. Comments that it is good to see the club can litter pick the area after matches.
Kent County Council Highways and Transportation
6.22 This application is unusual and difficult to assess in terms of highway impact as the facility already exists on the site and the potential increase in attendance, if any, is difficult to assess. The Transport Statement (TS) submitted by the applicants indicates that whilst the current stadium has a capacity of 4,500, current attendance rarely exceeds 1,000 and is unlikely to exceed 1,500 in the foreseeable future. The transportation requirements therefore do not change significantly from the existing development. The TS also indicates that a relatively high proportion of attendees currently travel to the ground by non-car means (50%) and the availability of public transport within a reasonable distance, both bus and train, is good. The site is located in a sustainable location and with the provision of a robust travel plan (which needs to be monitored); access by non-car means is likely to remain the case in the future.
6.23 Given the above, and the detailed information provided in the TS, the conclusions reached in the TS that the overall impact of the proposal in transportation terms is neutral is accepted.
6.24 Whilst the parking provision on site is not compliant with the Kent Parking Standards for a stadium with a capacity of 6,000 (400 spaces), it is accepted that the stadium is never likely to reach capacity and the current arrangements for parking does not appear to cause a problem in surrounding roads. The fact that home matches generally only occur once per fortnight on Saturday afternoons or evenings during half the year, makes it unrealistic to provide high levels of on-site parking which would remain empty for the vast majority of the time. There is a current arrangement for the use by attendees of the nearby Ebbsfleet Station Car Park C (when the car park would normally be empty) but this is on an informal basis and cannot be guaranteed to be available for the future. A more formal arrangement would be preferred to be established if this is possible. The current car parking area at the western end of the stand is informal and its capacity would be increased if it was properly surfaced and parking spaces marked out.
6.25 Pedestrian access to the ground, particularly immediately outside the entrance is not good, with the remnants of a previous road layout still remaining and being used for informal car parking. The pedestrian crossing arrangement over Stonebridge Road is poor and the footway width on the opposite side of the road, used by pedestrians coming from the Ebbsfleet car park, is restricted in width. Discussions with the applicant have indicated that as part of the redevelopment they would agree to make improvements to the existing public highway at the entrance to the ground to provide better pedestrian access, and queuing areas. This would need to be covered by a Section 278 Agreement with the Highway Authority.
6.26 Alongside these works, the existing bus stop in Stonebridge Road outside the ground should be relocated nearer the entrance and the existing on-street parking along Stonebridge Road alongside the ground needs to be reviewed and amended through an appropriate Traffic Order, details of which will need to be discussed with the applicant.
6.27 Therefore there are no highway objection to the application and would recommend the following conditions are applied to any consent granted:
1. Details of works to the existing public highway immediately outside the entrance to the stadium, including the provision of a wider pedestrianised area, an improved pedestrian crossing facility across Stonebridge Road, and widening of the existing footway on the south side of Stonebridge Road, shall be submitted to and approved by the Local Planning Authority. The works shall be undertaken at the applicants' expense under a Section 278 Agreement with the Highway Authority and shall be completed in its entirety prior to the new stand at the eastern end of the site coming into use.
2. The applicants shall use their best endeavours and at their expense to secure a Traffic Order for parking restrictions alongside Stonebridge Road immediately outside, and along the whole frontage of the new stadium, including the marking of bays as appropriate, to the prior approval of the Local Planning Authority. This work shall be completed prior the stadium at the eastern end of the site coming into use.
3. The applicants shall use their best endeavours and at their expense to relocate the existing bus stop on the north side of Stonebridge Road closer to the stadium entrance in a position to be submitted to and agreed by the Local Planning Authority. This should be carried out at the same time as Condition 2 above.
4. The existing parking area within the site to the west of the stadium shall be properly surfaced and individual parking spaces designated by white lining or similar, details of which shall be submitted to and approved by the Local Planning Authority prior to this work commencing. The car park works shall be completed prior to the use of the western stand commencing unless otherwise agreed by the Local Planning Authority.
5. Provision of parking facilities for site personnel and visitors prior to commencement of work on site and for the duration of construction in a location to be agreed by the Local Planning Authority
6. Provision of wheel washing facilities prior to commencement of work on site and for the duration of construction, details to be agreed beforehand by the Local Planning Authority.
7. Provision and permanent retention of secure cycle parking facilities in accordance with current Kent County Council standards prior to the completion of the construction works and in accordance with details to be submitted to and approved by the Local Planning Authority
8. The applicants shall prepare a final Travel Plan generally in accordance with the Draft Travel Plan submitted with the application prior to the first phase of the development coming into use. The Travel Plan shall be monitored at yearly intervals and the results, together with any amendments to the plan, shall be submitted to the Local Planning Authority.
Senior Engineer, GBC
6.28 Comments on the proposed off site highway works in the s278 drawing as follows:
the removal of the existing carriageway area in front of the turnstiles and the realignment of kerbs to define the approach to the roundabout is supported
the improvement of the pedestrian crossing point in Stonebridge Road should be a key element of this scheme and has not been addressed. The central island needs to be “fattened out” to a width of 2 metres at the point where pedestrians are crossing and there should be corresponding pedestrian points on both footways. existing guard railing should be removed from the kerb lines (in line with KCC policy); the access to the car parking area has been moved and will conflict with the pedestrian crossing point. I would recommend that the car park entrance is retained at its present position (accessed by a vehicle crossover defined by different surface material) so access/egress is directly onto the roundabout. This car park should be managed so that the gates are kept closed as spectators arrive and leave the ground on match days;
the bus stop is shown to be moved some distance beyond the northern limit of the ground. My recommendation is that the bus stop should be moved towards the roundabout (to suit greatest demand). Hence the bus stop should be located at the end of the layby area currently set out for car parking and protected by a bus stop clearway;
other parking along the frontage of the stadium in Stonebridge Road should be controlled by TRO (either by time limit or by pay and display machines) to protect it from long term parking by rail commuters;
is there a requirement for coach parking on match days? If so, this needs to be addressed;
there is a low spot on the kerb line fronting the stadium which results in water and mud collecting – particularly at the point where pedestrians are likely to be crossing. Can we be assured that this will be dealt with during the highway works;
reiterates that the works should be carried out as a condition of development, justified by the larger stadium capacity and greater throughput.
Parking Manager, High Speed 1
6.29 Views awaited
Environment Agency
Note: These are initial comments rather than a formal response which is still awaited.
6.30 Whilst we have no objection in principle to this application, we do have a question about the Ebbsfleet Culvert that runs adjacent to the stadium.
6.31 The river Ebbsfleet is a main river and flows in an underground culvert close to the Plough end of the stadium. The EA has a right of access on land within 8m of the culvert, and our prior written consent is required prior to any works within this 8m easement. The culvert has a height of 1500 mm.
6.32 As the culvert is not shown on the applicant's plans it is unclear whether the new stadium would be more or less than 8m from the culvert.
6.33 If any building is likely to encroach into the 8m byelaw margin of the River Ebbsfleet, then we would wish to see details so we can assess whether such encroachment would hinder the maintenance or future works to the culvert. Until such details have been provided, we would object to the grant of planning permission on the grounds that inability to properly maintain the culvert would increase flood risk elsewhere, contrary to paragraph 103 of the National Planning Policy Framework.
6.34 If the planning authority is satisfied that all buildings would be more than 8m from the culvert, then we would have no objection to the proposed redevelopment. We would wish this to be secured through condition, and we would wish to see details of the proposed landscaping in the 8m byelaw margin so we can ensure that no structures are placed in this area which could hinder the maintenance or future works to the culvert.
6.35 We understand that landscaping adjacent to the Plough end of the stadium is a reserved matter, and in formulating details the applicant should have regard to the possibility of improving the ecological value of the river Ebbsfleet, after which the football club is named. In particular, we would encourage modifications to open the culvert and allow daylight to the river, provide habitat, improve diversity of flow and ultimately return the river to a natural state insofar as possible.
6.36 Other than the matters above there are no major concerns with the application. A standard suite of planning conditions relating to contamination remediation, piling and surface water drainage is recommended. The impact on the culvert could potentially also be resolved by way of condition - for example by conditioning that no works take place within 8 metres of the culvert structure. However confirmation would first be needed of the actual location of the culvert to ensure that it would be possible for the applicant to comply with the condition.
Southern Water
6.37 Has advised of the water main records showing the approximate position of public water distribution main within the site. The exact position must be determined on site by the applicants before the layout of the development is finalised.
6.38 All existing infrastructure should be protected during the course of construction works. No excavation, mounding or tree planting should be carried out within 3 metres of the public main without consent from Southern Water.
6.39 Due to changes in legalisation regarding the future ownership of sewers a sewer deemed to be public could be crossing the property and should any sewer be found during construction works an investigation of the sewer will be required to ascertain its condition, the number of properties served and the potential means of access before any further works commence on site. The applicant is advised to discuss the matter further with Southern Water.
6.40 Advises that following initial investigations there is currently inadequate capacity in the local network to provide foul sewage disposal to service the proposed development. The proposed development would increase flows to the public sewerage system and existing properties and land may be subject to a greater risk of flooding as a result. Additional off- site sewers or improvements to existing sewers will be required to provide sufficient capacity to service the development. Alternatively the developer can discharge foul flow no greater than existing levels if proven to be connected and it is ensured that there is no overall increase in flows into the foul system.
6.41 Requests an informative requiring the applicant/developer to enter into a formal agreement with Southern Water to provide the necessary sewerage infrastructure required to service the development. 6.42 Advises that the Council’s Building Control officers should comment on the adequacy of soakaways to dispose of surface water.
6.43 Requests that a condition is attached to the consent requiring the submission of details of the proposed means of foul and surface water sewerage disposal.
6.44 Advises that Southern Water can provide a water supply to the site and that Southern Water will require formal application for connection and on-site mains to be made by the applicant or developer and that an informative is imposed.
6.45 Due to vibration, noise and potential odour generated by sewage pumping stations no habitable rooms should be located closer than 15 metres to the boundary of a proposed pumping station.
Kent Fire and Rescue Service
6.46 Advises on compliance for access for fire appliances in relation to the requirement of the Building Regulations 2010.
Kent Police Crime Prevention Design Advisor
6.47 The application has been considered with regards to Crime Prevention Through Environmental Design (CPTED) matters, in accordance with the DCLG Planning Practice Guidance March 2014 (Paragraphs 10 & 11) – Crime Prevention and the Kent Design Initiative (KDI) - Design For Crime Prevention document dated April 2013.
6.48 Advises that the applicant/agent has considered crime prevention and has attempted to apply the seven attributes of CPTED in their Design and Access Statement (D&AS).
6.49 The applicant’s attention is drawn to the Kent Design Initiative (KDI), which will also assist them with Crime Prevention and Community Safety.
6.50 Requests that a condition, letter or informative be included as part of the planning approval to ensure that Crime Prevention is addressed effectively:
6.51 The use of a condition, a letter or an informative will address both their statutory duties under Section 17 of the Crime and Disorder Act 1998 and will show a clear audit trail for Design for Crime Prevention and Community Safety.
South East Coast Ambulance Service NHS Trust (Kent)
6.52 Clear emergency access is required at all times. Rendezvous points needed around the building work for all emergency services in case of major incident.
Arriva (Southern Counties)
6.53 No comments received South Eastern Rail Services
6.54 No comments received
National Grid
6.55 National Grid has no objections to the above proposal which is in close proximity to a High Voltage Transmission Overhead Line – ZR.
6.56 Information has been provided in relation to safety clearances and working arrangements.
UK Power Networks Ltd
6.57 No objections
Southern Gas Networks PLC
6.58 No comments received
KCC Heritage and Conservation
Note: These are KCC comments in relation to the Desk Based Assessment (DBA) submitted with the pre-application enquiry and EIA screening and a formal response will follow.
6.59 The site does not contain any known designated heritage assets. It does not contain any known undesignated heritage assets although this may reflect the lack of any previous formal heritage assessment of this site. The site of the application is within a general area of high archaeological potential for Palaeolithic, Mesolithic/Neolithic and post medieval archaeology and there may be heritage importance in the current stadium buildings themselves. There are known designated and undesignated heritage assets in the immediate vicinity and a thorough and robust assessment of heritage issues is essential to ensure informed planning decisions are made for this site.
6.60 This area has complex geology and topography and understanding the palaeo- topography and the current ground levels is crucial to understanding the potential for significant archaeology within the site. The adjacent area contains surviving outcrops of Boyn Hill Gravels; an outcrop is located c.75m east of the proposed development site, although we know from recent investigations in the wider area that the BGS mapping of the Boyn Hill Gravels has underestimated their extent. BGS mapping also shows Alluvium overlying Chalk at the site with a band of Head deposits along the southern boundary. There are further Head Deposits highlighted to the west of the site. On the basis of this geological background and previous investigations in the area, mainly for the Channel Tunnel Rail Link (HS1) and the South Thameside Development Route stage 4, this area is likely to have high potential for early prehistoric remains. The quarrying may actually have brought proposed modern disturbance closer to the level of potential sensitive deposits.
6.61 There are two designated heritage assets within c.500m of the development site; one associated with Baker’s Hole Palaeolithic site to the south west; and the other referring to Aspdin’s Kiln to the north east. Other significant archaeological remains have been identified within the valley to the south, including sites containing the eponymous Ebbsfleet Ware Neolithic pottery and a well-preserved Anglo-Saxon watermill.
6.62 The development site lies within the lower reaches of the River Ebbsfleet. The Ebbsfleet was clearly of importance, especially ritual significance, during the later prehistoric, Roman and Anglo Saxon periods, as indicated by the nationally important complex at Springhead to the south and a range of other sites which have been recorded along the valley. The 2nd edition OS map highlights that the Ebbsfleet was tidal as it went past the development site and there are indications of the river being canalised and utilised for industrial activity.
6.63 The site may contain key evidence relating to the medieval and post medieval use of the Ebbsfleet and the development of this area. The Gravesend, Rosherville and Northfleet tramline ran along Stonebridge Road and there may be remnants of early industrial buildings and structures regarding the origins of the modern day Northfleet community.
6.64 The site may have been used as a football ground from the early 20th century and the current stadium complex is identifiable on the 4th Ed OS map. On this basis, the buildings and site themselves may be of heritage interest, reflecting the origins of football and leisure facilities for the Northfleet and Ebbsfleet community. The history and significance of the current stadium buildings need to be thoroughly assessed.
6.65 The applicant has commissioned an Archaeological Deskbased Assessment (DBA) and we have been reviewing a draft of this report. At present the report is not well structured and only about one-third contained assessment data. It is at present not sufficiently detailed and does not provide appropriate understanding of the heritage of this site.
6.66 Our comments on the DBA and on this Screening Opinion are provisional in view of the limited nature of development details. We have not been provided with details of groundworks although it is proposed for some demolition. Despite the site being already partially developed and within a former clay pit, we consider there is still potential for the site to contain significant archaeology.
6.67 On the basis of current information it may be considered unnecessary to consider heritage issues through an EIA process but it is essential that there is a robust and comprehensive assessment of archaeology, historic buildings and historic landscapes (see NPPF para.128). It is crucial that consideration of heritage should include assessment of the geological, palaeo-environmental, Palaeolithic, Mesolithic/Neolithic and industrial potential of the site in particular. This will require the use of specialists to assess the geological and Palaeolithic potential – names of specialists who have an awareness of the area can be provided on request. The assessment will need to consider information held by the BGS and any geotechnical reports held by the landowner or developer. Records held by the Gravesend Historical Society should be consulted particularly with regard to former quarrying. It should also include a rapid site walkover survey to check if any geological deposits are visible around the edges of the site. It is important that the desk based assessment is as thorough as possible to enable decisions about the archaeological potential of the site, the impact of the proposed development and the need for further archaeological evaluation and/or mitigation to be determined.
6.68 In summary, recommends that this application is not determined until a robust and appropriately detailed DBA is provided. It may be that this development can proceed with suitable mitigation for heritage issues but at this stage there is insufficient assessment of heritage.
Natural England
Statutory nature conservation sites – no objection
6.69 This application is in close proximity to the Bakers Hole Site of Special Scientific Interest (SSSI). Natural England is satisfied that the proposed development being carried out in strict accordance with the details of the application, as submitted, will not damage or destroy the interest features for which the site has been notified. This SSSI does not represent a constraint in determining this application.
Protected species
6.70 This application and associated documents has not been assessed for impacts on protected species. Natural England’s Standing Advice should be applied to this application as it is a material consideration in the determination of applications in the same way as any individual response received from Natural England following consultation.
Local sites
6.71 If the proposal site is on or adjacent to a local site, e.g. Local Wildlife Site, Regionally Important Geological/Geomorphological Site (RIGS) or Local Nature Reserve (LNR) the authority should ensure it has sufficient information to fully understand the impact of the proposal on the local site before it determines the application.
Impact Risk Zones for Sites of Special Scientific Interest
6.72 Natural England has recently published a set of mapped Impact Risk Zones (IRZs) for Sites of Special Scientific Interest (SSSIs). This can be used by LPAs and developers to consider whether a proposed development is likely to affect a SSSI and determine whether they will need to consult Natural England to seek advice on the nature of any potential SSSI impacts and how they might be avoided or mitigated.
Gravesham Access Group
6.73 No comments received.
Sport England (SE Region)
6.74 Views awaited
Dartford Borough Council
6.75 No objections
Northfleet Harbour Restoration Trust
6.76 Overall the Northfleet Harbour RT Trustees support the scheme because of the positive improvements to the area.
6.77 Northfleet Harbour RT is keen to preserve the possibility of de-culverting the River Ebbsfleet as it forms one of the Trusts key aims: the proposals for the new stadium at Ebbsfleet United Football Club are not prejudicial to this and we feel the development would have a positive effect upon the local area.
6.78 It is a little disappointing that the River Ebbsfleet is not named in the Biodiversity report and the only reference seems to be as a "drain".
6.79 The ground floor plan shows the supporter's bar to be situated at the S.E. end of the stadium facing Grove Road across the culverted River. Although we didn’t find an elevational view of this end it would be reasonable to assume (being built under the Plough end stand) some windows (hopefully at ground level) along with the doors that are depicted to serve the bar and an open external circulation area that would face toward the River Ebbsfleet. This could be positive for the opening up of the River in the longer term (post car-wash, etc.) - interesting to see the form of boundary fencing that will be proposed with regard to affecting views in/out.
Publicity
6.80 The application has been statutorily advertised on site and in a local newspaper as a major development proposal.
6.81 In addition the owners and occupiers of 940 nearby and adjoining premises and residential properties were notified of the application.
6.83 Only one representation was received being from residents at Phoenix Park not objecting to the application but querying the height of the stands and advising that they would not wish to lose views of the river and passing ships from their property.
7. Planning Analysis
Introduction
7.1 The proposals the subject of this application involve the phased redevelopment of the existing Stonebridge Road football ground through the reconfiguration of the pitch area and the rebuilding of stands and supporting facilities to both improve the spectator experience as a sporting venue and its utility as a community facility.
7.2 As a result of the improvements, ground capacity would be increased from around 4,500 to 6,000 supporters allowing possible future entry into the Football League and progression through to Division 1 level.
7.3 All works at the stadium would effectively be within the confines of the existing site, which has been in active use as a football ground for in excess of 100 years.
7.4 The development was the subject of extensive pre-application discussions in January this year. The proposals were screened for Environmental Impact Assessment (EIA) development (reference 20150063) which confirmed that an EIA was not required.
7.5 In addition the applicants have carried out their own pre-application consultation and engagement with the community by holding a public drop in event in January to which over 2000 households and local businesses were invited, along with local councillors. This was followed by a presentation to supporters of the club at the ground.
The Issues
7.6 The issues to consider and evaluate in this application are:
Policy Considerations and the Principle of Development Impact of the development from the proposed increase in ground capacity Highways and Parking Issues Visual Impact and Design Issues Amenity Impacts Environmental Impacts Other Issues – Safety/Evacuation
These matters are considered and discussed below.
Policy Considerations and the Principle of Development
7.7 In planning policy terms the proposal to redevelop and upgrade the existing football ground is supported in principle as it would assist in achieving Gravesham Local Plan Core Strategy (September 2014) strategic objective SO15 by improving opportunities for recreation, sport, walking and cycling.
7.8 The proposals also accord with a number of important Core Strategy policies, including CS13 by enhancing the quality and accessibility of this important local sporting facility and policy CS09 in terms of representing an opportunity to expand cultural and tourist activity in the area. The proposal also has the potential to complement emerging proposals for the nearby London Paramount resort which will be the subject of an application later this year to Government under the NSIP process.
7.9 Because the proposal involves the upgrade and redevelopment of an existing stadium and does not easily fit the definition of a ‘more intensive sport and recreation use’ under ‘main town centres uses’ set out in the glossary to the NPPF, it is not considered that the requirement to apply the sequential approach under policies CS08 and CS09 of the Local Plan Core Strategy is engaged. It also follows therefore that no impact test would be required under policy CS08, subject to any supporting retail or leisure uses being ancillary and of an appropriate scale relative to the primary use of the site.
7.10 The site is in a sustainable location for a football stadium given its extremely good public transport linkages (bus and train) and potential for shared use of car parking in and around Ebbsfleet Station and is within easy walking distance of the established residential communities of Old Northfleet and Swanscombe.
7.11 The proposal is not considered to be inconsistent with area policy CS03 of the Gravesham Local Plan Core Strategy which, although recognising the potential for regeneration of sub-area 1.3, accepts that the football ground may remain in-situ as part of any future proposals but act as a constraint on development adjoining. It is not considered to be prejudicial to the potential residentially-led regeneration of the Key Site to the east of Grove Road under the same policy.
Impact of the development from the proposed increase in ground capacity
7.12 Although the principle of the development is accepted in planning policy terms a key consideration, which to some extent impacts on the evaluation of some of the other main issues and in particular the highway impacts of the development, is the potential increase in the numbers of spectators that are likely to be attracted to the redeveloped stadium.
7.13 The redeveloped stadium in its final form will increase capacity to 6000 with 2,000 seats which is in part intended to meet Football league ground grading criteria. That said the current National Conference and Football League ground grading criteria is 4,000 capacity including 500 seats for the former and 5,000 capacity including 2,000 seats for the latter (1,000 in the first season of entry), and in addition the Football League now requires far better changing accommodation and a minimum 200 away supporters to be provided with covered accommodation.
7.14 It is of course acknowledged that the football ground is already there and has a current potential capacity for home games of just over 4,500 and the intention is to increase to a capacity of 6,000 thus an increase of 33% in the ground capacity. As the current average attendance for matches is 960 the club is only achieving 21% of its existing capacity. When the club was in the National Conference average crowds were at around 1200, peaking at an average of about 1,500 in season 2004/5, thus only about a third of the ground capacity.
7.15 On the other hand it does not follow that just because of increased capacity that the stadium will be full to capacity at each home fixture. This will obviously depend to a large extent on the success of the club and results during a season which will clearly have a bearing on the club’s following and whether the club will progress through to football league status although it should be acknowledged that an improved stadium in its own right may also generate significant additional spectators (both from home and away supporters) to enjoy enhanced facilities and a better (and perhaps safer, particularly if family orientated) experience of watching football and the novelty of what effectively would be a new stadium. The likely increase in spectators will also in part be dependent, amongst other things, on the demographics of the area, the extent of the fan base, marketing, affordability, population increases and increase in the provision of local housing and the catchment area available to the club given the attraction of other clubs locally (Dartford, currently in the Football Conference; Gillingham in League 1; Charlton Athletic in the Championship; as well as the numerous London clubs in the Premiership)
7.16 However if the current ground average is only 960, at a full capacity of 6,000 this would represent a six fold increase in attendances at the stadium and that potential significant increase needs to be taken into account.
7.17 Nevertheless evaluation of similar stadium redevelopments or where clubs have progressed from the National Conference into the Football League Division 1 and 2 (including Burton Albion, Crawley Town, Dagenham and Redbridge, Fleetwood Town, Morecambe and Stevenage Borough) shows that the increase in capacity does not necessarily result in a dramatic increase in attendances at football grounds. However, this does not mean that the new ground might not be filled to capacity as even within the National Conference Burton Albion attracted a crowd of 6,192 at their new stadium in the promotion season of 2008/9 when their average crowd was only 2,434.
7.18 On progression into the Football League, most of the above clubs have increased their average crowd figures. The best comparisons are probably Dagenham and Redbridge and Crawley Town, which both have ground capacities around the 6,000 proposed for Stonebridge Road. In the case of Dagenham and Redbridge, the average attendance in their promotion year of 2006/7 was 1,756 (within a range of 947 to 4,044 for league games). Their best season for attendances on promotion to the Football League thereafter was 2010/11 when playing in Division 1 when the average crowd was 2,769 (within a range of 1,907 to 4,446 for league games). Their largest league gate over this period was in 2008/9 when an attendance of 4,791 was achieved. In the case of Crawley Town, the average attendance in their promotion years of 2010/11 was 2,521 (within a range of 952 to 4,054 for league games). Their best season for attendances on promotion to the Football League thereafter was 2013/14 when playing in Division 1 when the average crowd was 3,486 (within a range of 2,407 to 5,680 for league games). Their largest league gate over this period was the 5,680 recorded in that year.
7.19 Whilst the club is probably correct, as they have set out in their supporting planning and transport documents, in asserting that the average attendance is unlikely to exceed the existing ground capacity, it is important to recognise that the intention of investing in the ground is to facilitate subsequent promotion into the football league where crowds are likely to significantly exceed levels previously experienced when playing in the National Conference. There are also likely to be exceptional occasions when capacity crowds are likely to occur – for example when playing a larger club that has been relegated though the divisions or is drawn in a cup competition.
7.20 It is also acknowledged that the increase in the ground capacity of Ebbsfleet United will not be realised until after all the various phases of the redevelopment of the ground have been undertaken. The club have provided the following information in respect of the ground capacity of the football ground during the various phases of the development:
Phase 1 – construction of the new Stonebridge Rd stand May 2015 – Dec 2015
Capacity of remainder of ground.
Plough End: 500 Old Main Stand: 524 Swanscombe End: 754
Total: 1778 (2524)
Phase 2 – construction of new Plough End May 2016 – Dec 2016
Capacity of remainder of ground.
Stonebridge Rd: 992 Old Main Stand: 524 Swanscombe End: 754
Total: 2270 (3016)
Phase 3 – construction of Swanscombe End May 2017 – October 2017
Capacity of remainder of ground.
Stonebridge Rd: 992 Plough End: 2300 Old Main Stand: 524
Total: 3816
Phase 4 – construction of replacement Old Main Stand May 2017 – October 2017
Capacity of remainder of ground. Stonebridge Rd: 992 Plough End: 2300 Swanscombe End: 1742
Total: 5034
Complete stadium
Stonebridge Rd: 992 Plough End: 2300 Swanscombe End: 1742 Old Main Stand: 1026
Total: 6068
7.21 The capacity of the redeveloped stadium will not therefore exceed the current ground capacity of 4500 until the club have completed Stonebridge/Plough/Swancombe phases (provisionally October 2017) but before the completion of the replacement of the old main stand (Town End). The club have confirmed that the FA Ground grading committee does not have an issue with the usage of a reduced capacity Stadium whilst redevelopment works take place.
7.22 Overall, and although the redevelopment will be on a phased basis such that ground capacity will not increase initially and notwithstanding the effects that team success or otherwise or other external factors may have an attendances at the ground, the impact of a redeveloped stadium with increased capacity on the local area and its environs remains a material planning consideration and as such would justify careful consideration of the likely impacts not least in terms of the need to facilitate the safe and commodious movement of both pedestrians and road traffic and to consider the potential to achieve public realm improvements outside the ground.
Highways, Access and Parking Issues
7.23 In respect of traffic and parking issues the matters to consider are, as indicated above, the impact of the increased ground capacity, the likely levels of traffic that would be generated by the development, the provision of and potential for car and coach parking both within and off the site and the availability of other sustainable methods of transport to and from the site.
7.24 Ebbsfleet United Football Club like so many existing football clubs operates from a restricted urban site with little provision for car parking on site. The ground pre-dates planning control such that there is no requirement to provide car parking facilities for supporters. There is only limited parking at the ground itself including limited parking to serve players, officials and directors etc. on match days but there is also currently the use of Ebbsfleet Car Park C which is just a short walk from the ground which is available for the parking of up to 550 cars set aside on match days albeit that this appears to be on an informal basis. In reality from surveys undertaken on normal match days approx. 120 of the 550 allocated parking spaces in car park C are being used by supporters although this could significantly increase at some bigger matches or as the club progresses through promotion. This use was negotiated in part because of on street parking problems that were occurring in Thames Way.
7.25 It is only in the case where new stadiums are proposed that new facilities can be planned in from the outset but this is not the case here where the limits of the ground contain the ability to provide on-site parking.
7.26 The application is supported by a transport statement and a draft travel plan which is described as an interim document. The travel plan aims to encourage the use of more sustainable modes of transport, reduce unnecessary and unsustainable travel and improve facilities to promote sustainable travel.
7.27 The transport statement indicates, from a survey undertaken by the club, that 50% of supporters come to the ground by car, 14% by bus, 20% by train, 14% walked and 2% were dropped off by car but there were no supporters surveyed that cycled to the ground.
7.28 The current stadium is well related to the primary highway network with good access such that it should have sufficient capacity to cope with the additional increase in ground capacity and the anticipated increase in attendances at the redeveloped and enlarged stadium.
7.29 In respect of parking provision the development as a new development for a 6000 capacity stadium would require the provision of 1 space per 15 seats (under adopted KCC vehicle parking standards) and that provision should also be made for coach parking with a maximum standard of 1 coach space per 300 seats (such provision is to be provided as an alternative to car parking provision), thus potentially a car parking requirement on site of some 400 spaces. Clearly this level of car parking cannot be met on site.
7.30 In respect of parking provision paragraph 39 of the NPPF indicates that in applying parking standards to both residential and non-residential development local planning authorities should take into account the accessibility of the development; the type, mix and use of development; the availability of and opportunities for public transport; local car ownership levels; and an overall need to reduce the use of high-emission vehicles.
7.31 Currently there are about 70 unmarked spaces at the Swanscombe end of the ground besides the away turnstiles. Discussions have been held with the club to achieve formalisation of the parking area which will potentially increase the available parking area and this could be further increased once the containers and portacabin are removed from site. The applicants have advised that they would agree to undertake this at an appropriate trigger point in the redevelopment of the ground. It should in any event be noted that because of the proposed phased approach to the development and the need for a secure an safe construction compound area and which is likely to be within the current Swanscombe end car park some of the current parking area will not necessarily be available during the construction period.
7.32 Some additional parking is however being provided and, in addition, the phase 1A redevelopment will be providing cycle provision within the ground, notwithstanding that the survey work undertaken by the club indicated that currently no spectators cycle to the ground. The additional parking area though is indicated as being for players and directors and will be next to the main entrance into the ground.
7.33 The club will continue to benefit from the availability of car parking for supporters on match days within Ebbsfleet car park C which is the subject of an informal arrangement with HS1.
The club has advised:
It should be noted that as previously stated the match day car parking facility at Ebbsfleet International Station (currently 550 spaces) will run alongside the main car park as an additional facility. It should also be noted that by prior arrangement the capacity of that car park can be increased to a capacity of 800 vehicles per match.
The club has further advised:
The Club met with David Pye, Product Development Manager (Car Parks), HS1 Ltd on the 19.03.2015. The outcome is that HS1 would positively welcome formalising the agreement with EUFC and will relay this information directly to GBC together with their support for the proposed development. The agreement would cover the use of Car Park C initially with possible expansion into Car Park D if required.
7.34 The club has subsequently advised that a licence agreement has been drafted and is circulating between the Club and HS1. Confirmation will be provided in due course once the licence is signed, but the existence of the agreement and the initiatives adopted by the Club to promote use of the car park can be included in the Detailed Travel Plan.
7.35 Whether or not a more formalised agreement on off-site parking provision is possible there is no doubt that a robust travel plan, with appropriate monitoring and management is necessary to deal with the parking issues and traffic generated by the club on match days and to achieve a satisfactory modal shift to other more sustainable modes of transport – bus, train and cycle or car sharing.
7.36 Moreover bearing in mind that the ground capacity is significantly increasing (even if at match days that capacity is not necessarily reached immediately or at all times) and that there is a significant shortfall of on-site parking there needs to be a requirement of the planning application to encourage linkages to the station parking and more sustainable uses of transport and it is imperative that safer pedestrian movement to and from the ground is achieved. To this end discussions have been taking place that has resulted in the submission of draft proposals for public realm and pedestrian safety improvements in front of the ground entrance in Stonebridge Road. It is considered that these must be implemented at an appropriate trigger point in the redevelopment of the ground.
7.37 The Board will note that the application proposals do have the support of KCC Highways and Transportation subject to the impositions of a range of highway/parking planning conditions.
7.38 Subject to these conditions it is therefore considered that the development is acceptable in highway and parking terms.
Visual Impact and Design Issues
7.39 Gravesham Local Plan Core Strategy (September 2014) policy CS19 on Development and Design Principles sets out a range of factors that the Council will take into consideration when evaluating the design merits or otherwise of a proposal.
7.40 The requirement is for any development to be visually attractive, appropriate to context, to make a positive contribution to the street scene/public realm and the character of the area.
7.41 The proposed stadium complex will be a significant development in a prominent location at a key gateway on the A226 corridor, with the Stonebridge Road roundabout providing access to Northfleet Embankment West, Old Northfleet, and the Ebbsfleet Valley.
7.42 The general form, shape and profiling appear to be appropriate to the context and the function of the stadium and the glass exterior will make a very positive contribution to the street scene and local character. 7.43 The scale of the new stands is generally in accordance with the current scale of the development at the site. They are generally not significantly higher than the current stands. The replacement Stonebridge Road stand as part of the phase 1 works will be built to a height of generally 9.7m high, compared to the current Liam Daish stand of 7.3m, thus an increase of 2.4m in height (or just over 8ft) with only at one end (at the eastern end) increasing to 10.4m as the proposed replacement stand there (to be built as a later phase) is a slightly higher stand. Moreover the indicative stand proposed as a replacement for the current main stand (Town End stand) is currently shown to be lower in height.
7.44 The phased approach to the development with the Stonebridge Road stand being constructed as the first phase and the potential delay in the completion of the development or other existing stands being redeveloped will mean that there will need to be a temporary fix to the ends of the new Stonebridge Road stand and revised plans to show how this will be achieved have now been provided.
7.45 The Board will note that there is just one neighbour comment as a result of the publicity given to the application querying the height of the stands and expressing concern if there were loss of views. Whilst such a matter is not a material planning consideration the assessment would be that having regard to the distance residential properties are away from the ground the increased height of the stand ought not to result in material loss of views or vistas.
7.46 There is therefore no objection to the scale and massing of the development
7.47 Materials chosen for the development or of a good standard and quality. The applicants have considered the use of anti-graffiti finishes to the exterior of the stands and this can be the subject of a recommended planning condition.
7.48 There will be a need for good quality hard and soft landscaping and for suitable boundary treatments, again which can be the subject of planning conditions. The applicants have been encouraged to incorporate steel bollards to the frontage of the site to Stonebridge Road.
7.49 The ground improvements do offer scope to remove some of the unsightly advertisement hoardings on the Stonebridge Road frontage and the applicants have confirmed that these will not be reinstated post the completion of the stand. It is likely that there will be a need for advertising in and around the ground to inform the public of forthcoming games and to promote the club as a commercial enterprise – the need for such advertising and other signage will need to be carefully thought through in order that it can be integrated into the design of the complex rather than treated as an ‘add-on’ and it is recommended that further details be sought as a planning condition.
7.50 Consideration could also be given to the inclusion of a public art feature as part of the necessary improvements to the public realm and pedestrian improvements to support the development, at the Stonebridge Road entrance to the stadium or at the roundabout immediately outside.
7.51 The development proposals are supported by a sustainability statement and the scheme will incorporate measures to reduce carbon emissions and reduce energy consumption pursuant to Core Strategy Policy CS18. The club already conserve water by rain water harvesting. The phase 1A Stonebridge Road replacement stand will incorporate solar panels to the road frontage of the stand.
7.52 Given the nature and scale of development proposed for the surrounding area (including the proposed Garden City within Ebbsfleet Valley and the London Paramount Entertainment Resort) it is likely that sites in and around Ebbsfleet Station will come under pressure for redevelopment to higher grade uses. The proposed improvements to the stadium could potentially also act as a catalyst for such change.
Amenity Impacts
7.53 Policy CS19 of the adopted Core Strategy also requires that the amenity of occupants and those of neighbouring properties and land should be safeguarded and adverse environmental impacts from pollution (including noise, air, and odour and light pollution) avoided. Whilst the site is already occupied by an existing stadium, it is essential that these issues are addressed.
7.54 The ground is located some distance from residential properties. There are still many main league football grounds that are located close to and adjoining residential dwellings and where the main pedestrian routes to such grounds are through narrow residential streets
7.55 The development does not result in any changes to the recently installed revised floodlighting other than minor re-siting of one of the pylons such that there would be no material increase in impact from floodlighting of the playing pitch and thus problems of either light spillage or light pollution.
7.56 Material impact in noise from the ground and from spectators both arriving and leaving is likely to be dependent again on whether the increased capacity of the ground is reached on a regular basis. Impact from noise within the ground has the potential to be more contained upon the completion of a fully enclosed stadium but potentially noisier with larger crowds or with louder PA systems. Additional information on the impact of noise has been requested from the applicants in order to fully respond to the comments of the Borough Council’s environmental health officers in relation to noise impacts.
7.57 Air quality impacts have been assessed and it is considered that such impacts are not likely to materially worsen as a result of the development but to some extent will be dependent on parking controls outside the ground.
Environmental and Other Impacts
7.58 In respect of impacts on water supply and sewerage provision Southern Water do not raise an overriding objection but have requested a condition requiring details of the proposed means of foul and surface water sewerage disposal to be submitted for approval.
7.59 The Environment Agency’s formal comments are awaited but their initial comments queried the proximity of the new development to the Ebbsfleet River which is located in culvert on the eastern boundary of the stadium. The applicants advise that they have checked this and do not believe that there is any incursion into the 8m byelaw margin indicated by the Environment Agency. The Environment Agency have requested that conditions should be imposed to safeguard the culvert and for details of contamination remediation, piling and surface water drainage.
7.60 In respect of archaeological impacts despite the site being already partially developed and within a former clay pit, KCC Heritage and Conservation have advised that there is still potential for the site to contain significant archaeology. KCC have indicated that at this stage there is insufficient assessment of heritage and a more detailed Desk Based Assessment (DBA) needs to be provided but the development might be able to proceed with suitable mitigation for heritage issues, probably through a planning condition.
7.60 In respect of waste matters the applicants advise: Ebbsfleet United FC has a current contract with Countrystyle Recycling for the removal of all waste from the Stadium. The contract covers weekly collection service and waste is sorted into three categories;
• General Stadium Waste. • Mixed Recycling Waste. • Pitch regeneration waste – Grass Cuttings, Soil.
A statement has been provided extracted from the Sustainability Plan which deals with the issue of waste.
In addition, EUFC can confirm that its Maintenance Operatives collect litter from the Stonebridge Road pavement post every home match played at the Stadium.
There are no objections from GBC waste management to the development but additional litter bins are suggested.
7.59 In respect of ecological impacts these have been assessed in a biodiversity report that accompanies the application. Bat survey are to be undertaken and measures such as building bat boxes and bird boxes into the development could be encouraged together with appropriate types of wild life friendly landscaping of the site. Natural England does not have any objections to the development.
Other Issues - Safety/Evacuation
7.54 The safety, security and evacuation measures are also critical considerations.
7.55 The applicants have confirmed that the ground alterations have been designed to accord with the requirements of the Department for Culture, Media and Sport (DCMS) publication Guide to Safety in Sports Grounds (Fifth Edition, 2008 – the ‘Green Guide’) as the technical manual for the design of stadia and for calculating their final ground capacity.
7.56 There are no overriding concerns expressed in response to the consultations from Kent Fire and Rescue Service, Kent Police and South East Coast Ambulance Service NHS Trust (Kent)
7.57 The club have provided officers with their current contingency plan for emergency and evacuation dated August 2013 and their current ground safety certificate with the Fire Authority. The contingency plan covers safety and control measures for fire, bomb threats, electrical failure, adverse weather, safety systems, crowd problems, stewarding, ticketing and evacuation.
7.58 These will however need to be reviewed in the light of the expanded stadium and to take into account the various construction phases of the redevelopment of the ground and this can be dealt with as a planning requirement of approval.
8. Conclusion
8.1 These proposals for the redevelopment of the Ebbsfleet United Football Ground are well considered and well designed and offer the prospect of making a very positive contribution to the street scene and the local area as well as offering both a first class modern family orientated sporting venue and a community facility and an asset for the residents of the Borough and beyond to enjoy.
8.2 The development is consistent with adopted local plan policy and there are no overriding material considerations or other objections such as to withhold planning permission in this case.
8.3 Although there are some remaining consultation responses that are still awaited it is not considered that these are likely to be an impediment to determination of the application and in this case PLANNING PERMISSION is recommended subject to appropriate planning conditions and informatives. RECOMMENDATION
Subject to
No adverse consultation responses from the Environment Agency, KCC Heritage and Conservation, the HS1 Parking Manager, and Sport England (South East)
PERMISSION subject to planning conditions/reasons and informatives
Draft Planning Conditions will be set out in a supplementary report.
However the following is a list of the likely suggested planning conditions:
- Time limit and commencement conditions for both the detailed and outline components of the scheme
- Development to conform to the approved plans
- Materials to conform to the submitted details and application of anti graffiti system
- Contamination Assessment to be submitted for approval
- Piling details of the stands to be submitted for approval
- Drainage details including foul and surface water sewerage disposal to be submitted for approval
- Protection of the Ebbsfleet culvert by exclusion of any built development within an 8m zone
- Construction Management details to be submitted for approval
- Provision of wheel washing facilities prior to commencement of works on site
- Details of construction compound to be submitted for approval
- Waste Management to conform to submitted details – provision of additional litter bins outside the ground
- Environmental Sustainability proposals to be implemented
- Archaeological Assessment to be provided/undertaken prior to built development works
- Off Site Highway Works to be undertaken after the completion of Phase 1A
- Formalisation of the existing Swancombe end parking area at appropriate trigger
- Provision of and retention of additional car parking at the Plough end of the ground
- Implementation of parking controls outside of the ground
- Relocation of the bus stop outside of the ground
- Submission of final Travel Plan prior to the first phase of the development coming into use and agreement to monitor at yearly intervals - Provision of and permanent retention of secure and covered cycle parking facilities
- Provision of disabled parking and viewing facilities for mobility impaired
- Details of any proposed ventilation equipment to the kitchens including any external flues or trunking to be submitted for approval
- Details of new entrance and turnstiles to Stonebridge Road to be submitted for approval
- Details of the phasing for the removal of the existing portacabins and containers
- Advertisement hoardings to be removed; control and submission of future external advertising proposals
- Full details of the boundary treatments, including security fencing and including steel bollards to Stonebridge Road to be submitted for approval
- Spectator management strategy and safety plan and evacuation procedures to be revised to take into account the various construction phases and provision of an enlarged stadium
- Safety and security measure to accord to the principles and physical security requirements of Crime Prevention through Environmental Design
- Community use of the Stonebridge Road stand to accord with the submitted details/hours of use
- Restriction on retail use other than as ancillary to the stadium use
- Details of any new communications equipment or PA systems to be submitted for approval
- Details of any external lighting to the new stands to be submitted for approval
- Landscaping – hard and soft including surface treatments to be submitted for approval
- Ecology and Biodiversity proposals to be implemented