SUMMARY REPORT
Application Ref: 20170221
Site Address: Ebbsfleet United Football Club, Stonebridge Road, Northfleet, Kent DA11 7GN Application Demolition of the Plough End Stand and ancillary buildings and Description: erection of a replacement Stand (Phase 1B), integrated 55- bedroom hotel together with new access, parking and ancillary facilities
Applicant: Ebbsfleet United Football Club
Agent: P+DA - Planning & Development Associates (Alan Gunne-Jones)
Ward: Northfleet North
Parish: Non Parish Area
Decision due date: 14 June 2017
Publicity expiry date: 21 April 2017
Decision level: Planning Regulatory Board - 17 May 2017
Reasons for referral: At the discretion of the Interim Development Manager; the previous application for the redevelopment of the ground was the subject of a report to the Board
Recommendation: To be set out in a supplementary report
Summary of Reasons for Recommendation
The proposal is for the demolition of the Plough End Stand at Ebbsfleet United football ground in Stonebridge Road Northfleet and other ancillary buildings and for the erection of a replacement stand (Phase 1B), integrated 55-bedroom hotel together with new access, parking and ancillary facilities.
The Borough Council granted planning permission in 2015 to a hybrid planning application under GR/2015/0081 for the redevelopment of the whole football ground that will meet Football League ground grading criteria and increase capacity from 4,500 (prior to current improvements) to 6,000. That part of the permission that was granted in full is currently being implemented, with the new main stand fronting Stonebridge Road nearing completion. The remainder of the permission was in outline form. Because the current proposal deviates from the original permission by including a 55 bed budget hotel at the Plough End, a separate full planning application has been necessary.
The key issues to consider are the principle of the development, whether the hotel in this location is sequentially appropriate, design issues, flood risk issues, highway access and parking issues and impact of the development in environmental terms. At this stage there are a number of key consultation responses that have not been received. In addition a number of responses to the various key issues and concerns are awaited from the applicants. Progress in these matters will be reported in a supplementary report along with a formal recommendation.
MAIN REPORT
1. Site Description and Surroundings
1.1 The site comprises the Ebbsfleet United Football Ground currently known as the Stonebridge Road Stadium in Stonebridge Road, Northfleet situated in an industrial location near the western edge of the Borough.
1.2 The ground has three stands with seating and some standing areas and open terracing at the western end of the ground. The Town or main stand on the north side of the pitch, and which contains the existing 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.
1.3 Ebbsfleet United currently play their fixtures in the Vanarama Conference South division, one league from the Football Conference division (National League) and thus two leagues away in the football pyramid from Division 2 of the Football League. They are currently involved in the promotion play-offs. The football ground has been in active use for sporting purposes since 1905.
1.4 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 were the landowners of the ground but sold this off in 2016.
1.5 Prior to the recent ground improvements referred to below the ground had a capacity of around 4,500 spectators of which 500 were seated, although the average attendances at the ground have been considerably lower than this - in the season 2014/2015 this was around 960. Capacity crowds have though on occasions been attracted, notably 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 2014/2015. The play off final in the 2015/2016 season between Ebbsfleet and Maidstone Utd drew a crowd of 3,800 to the stadium.
1.6 There have been some recent ground improvements including refurbishment of the toilets and improved floodlighting but more significantly the Stonebridge Road stand was demolished in 2016 and is being replaced with a new main stand as a result of a planning permission (hybrid type application) to replace all the stands granted in April 2015 (20150081). The seating has in part been made available for spectator use since Christmas 2016 and the whole stand is due for completion in May/June 2017.
1.7 The total site area of the ground as shown in the red line plan is 1.79 hectares (4.4 acres).
1.8 Adjoining uses include:-
to the north-west: a terrace of 4 houses (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.
1.9 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.
1.10 Vehicular access to the site is from the A226 Stonebridge Road roundabout and from the A226 at a point immediately behind the Swanscombe End terracing, some 160 metres to the north-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.
1.11 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.
1.12 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.
1.13 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.
1.14 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.
1.15 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.
1.16 The whole of the site is low lying (@3.0 – 3.5m AOD) and would be susceptible to flooding 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.
1.17 It should also be noted that the site lies within an Air Quality Management Area (AQMA) which was established in recognition of existing poor air quality due to high concentrations of particulate matter (PM10s). Further information on this designation is available at http://www.gravesham.gov.uk/index.cfm?articleid=809.
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 of existing floodlights and erection of four 18 metre high floodlight columns. Permission 20.12.2013
20150063: Request for a screening opinion in respect of development comprising the demolition of existing stands and ancillary buildings and the phased development of a new stadium, with associated access and parking. The development does not constitute EIA development 13.02.2015
20150081: 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 1A - full detailed) and erection of Plough End, Town End and Swanscombe End Stands with associated access and parking (Phases 1B, 1C and Phase 2 - outline with all matters except layout reserved). That application was considered by the Council’s Regulatory Board meeting on 4 April 2015 and planning permission was granted subject to conditions. The permission was issued on 30.04.2015
20150517: Application for approval of conditions 6, 9, 11, 14, 15, 18, 19, 20, 21, 22, 23, 24, 31, 36 and 43 attached to planning permission reference number 20150081 relating to contamination assessment and remediation, piling, drainage and water protection, wheel washing, details of the construction compound, archaeology, geo-archaeological investigations, safeguarding measures, written scheme of investigation (WSI), implementation of any safeguarding measures to ensure preservation in situ of important archaeological remains and/or further archaeological investigation, implementation of a programme of building recording, travel plan, removal of the existing portacabins and containers and details of crime prevention. Approved 29.07.2015
20170142: Application for approval of conditions 7, 34, 37, 38, 40, 41, 44 and 46 attached to planning permission reference number 20150081 relating to details of a verification report demonstrating completion of works, odour elimination, advertisements, boundary treatments, telecommunications and PA Systems, external lighting to the stands and ground, community use, including the hours of use and hard and soft landscaping and surface treatments. Pending Consideration
3. Proposal
3.1 The application is for the demolition of the Plough End stand and ancillary buildings including the club supporter’s bar and the erection of a replacement stand (phase 1B) and an integrated 55 bed hotel together with new access, parking and ancillary facilities. The application is a full application but also effectively a continuation of the hybrid planning permission 20150081 dated 30 April 2015.
3.2 The application follows on from a pre-application consultation submitted to the Council at the end of last year (PRE20160865) similarly for the demolition of the Plough End stand with replacement stand, function room for the football club and a smaller 46 bed budget hotel with non-match day car parking (24 spaces) within the site but also 168 spaces off site on land on the east side of Grove Road, although during pre-application discussions a larger hotel of 56 beds was also tabled. Although no formal response was made to the pre- application enquiry a meeting was held with the club and its planning advisors and a number of comments were provided to the club including an assessment by Design South East at a Design Surgery.
3.3 The current planning application does not include the off-site parking shown in the pre application stage but proposes a three storey hotel with integrated stand at the Plough End of the existing football ground. The hotel as now proposed is slightly larger than the initial pre application proposal with 55 beds and to a 3* quality being mid-price, focussed on the upper economy market segment and predicated on limited service and lower price accommodation and indicated as being for the Holiday Inn Express franchise (InterContinental Hotels Group - IHG) in the visual images provided with the application.
3.4 At ground floor the hotel building comprises enhance lobby and reception area including administration office, together with a restaurant/server, bar area and wc’s additional administration office, kitchen area, spectator wc’s and a plant room but also integrated within the building format is a turnstile for the football ground and kiosks at either end to serve the football spectators. The first floor includes 28 rooms each with en-suite bathrooms as well as plant rooms and stores plus staircase and lift access. The second floor includes 27 rooms, plant rooms and stores and one un-notated larger room. Each of the rooms is approx. 3.0m by 6.5m (approx.19m²) apart from room 4 which is 6.1m by 4.5m. It is stated the bar can also be hired out for non- match days. The proposed stand/hotel has a gross external area (GEA) of 2973.1m².
3.5 The proposed maximum height of the stand/hotel will be 12.6m above the exterior ground level although the terracing will be slightly lower as the pitch level is approx. 0.75m lower. The height of the stand/hotel is lower at 11m at the entrance side rather than pitch side. The existing Plough End stand (currently providing seating), and which is to be demolished, is 7.0m high. The new Stonebridge Road stand currently under construction is 10.4m high so the proposed new Plough End stand/hotel will therefore be about 2m higher. The existing floodlight columns will be integrated into the roof structure of the hotel/stand.
3.6 Outside of the hotel the forecourt area is shown as providing 25 non match day parking spaces (which has slightly increased from the 23 shown in the initial plans provided) for the use of the hotel and a cycle store area with the parking area being used as a congregation space for spectators on match days. Access to the parking area is via an access road (initially shown as an in and out arrangement, but now showing as a single access) exiting onto Stonebridge Road at the roundabout junction with Grove Road, and Thames Way.
3.7 There are two turnstiles located significantly back from the frontage of the site and access/exit gate to provide entrance to the ground for vehicular use. No details are indicated of surface treatments. The width of the access is 4.5m at the minimum pinch point rearward of the proposed turnstiles. The spectator viewing provided for the Plough End will not at this stage involve any seating as currently provided in the Plough End stand or as is being provided in the new replacement Stonebridge Road stand but will be in the form of covered terracing with 11 rows of standing terrace together with 8 seats in total for spectators with disabilities, 4 at either end including wheelchair space. It is indicated that the capacity of the terracing will be 1750 spectators.
3.8 The intention of the hotel is that it will provide integral guest accommodation to compliment the enhanced sporting, community and conference facilities at the ground. The new Stonebridge Road stand currently being completed will include a range of conference and banqueting facilities which can be hired out every day along with a community hub.
3.9 There was no indication in the original submission of employment to be created by the proposals. The applicants have subsequently advised:
In terms of employment agreement has been reached with IHG to operate the hotel as a Holiday Inn Express and we will be recruiting all management and service support staff from the local Gravesham community where possible. We anticipate 20/25 staff on a rota basis plus other local jobs will be created within the supply industry. On the new main stand EUFC will be running the conference and banqueting business in house and again recruiting locally and we anticipate up to 20 new staff. We are running a job seekers programme with recruitment agency Middleton Murray and this has already generated good local interest.
3.10 In addition to the 25 parking spaces to be provided immediately outside the hotel this will be complemented by the existing Ebbsfleet United match day car park at the Swanscombe End which has a capacity for approx. 60 further vehicles. It is also indicated in the accompanying Travel Plan that the Ebbsfleet International Car Park (Car Park C) which is also available for match day car parking can provide a compliment to the requirements of the hotel if necessary. This is about a 5 minute walk from Stonebridge Road.
3.11 The following materials are proposed for the stand/hotel:
Low level walls: Dark grey coloured Forticrete blockwork High level walls: K Rend silicone coloured panels to be used for the walls of the hotel. Roof: Red coloured metal sheeting.
3.12 The application submission comprises various site plans and block plans, floor plans and elevations and the following additional supporting documents:
Application Form - Planning & Development Associates (PDA); Covering Letter - Planning & Development Associates (PDA); Planning Statement (including Heritage Statement) - Planning & Development Associates (PDA); Sequential Assessment - Planning & Development Associates (PDA); Design & Access Statement - Alexander Sedgley Historic Building Recording - Swale & Thames Archaeological Survey Company; Vision Statement - Ebbsfleet United Football Club (EUFC); Travel Plan – EUFC; Phase I & II Ground Investigation Report - Environmental Protection Strategies Ltd; Phase II Environmental Report + Appendices - Herts & Essex Site Investigations; Update Bat Inspection of Buildings Report - FOA Ecology Ltd; Flood Risk Assessment - Marks Heeley Ltd; Construction Management Plan - Faithorn Farrell Timms (FFT)
Supplementary Information:
Football Grounds with Hotels (PDA)
4. Planning Policy, Development Plan and other Material Considerations
4.1 Section 38(6) of the Planning and Compulsory Purchase Act 2004 requires planning 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 Development Plan for Gravesham comprises:-
• The Gravesham Local Plan Core Strategy (September 2014) • Remaining Saved Policies of the Local Plan First Review (1994) • Kent Minerals and Waste Local Plan 2013 - 2030 (July 2016)
4.3 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), supplementary planning guidance, and, where they exist, neighbourhood plans.
Gravesham Local Plan Core Strategy, September 2014
4.4 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.
4.5 The development site is shown as being within the urban area and fronting on to a district distributor in the Gravesham Local Plan Policies Map.
4.6 Stonebridge Road and the junction with Grove Road are shown as subject to Highways Safeguarding (under saved policy T6) while Grove Road is subject to High Speed 1 Safeguarding (under Core Strategy Policy CS11) in the Policies Map.
4.7 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
4.8 Policy CS01 (Sustainable Development) embeds the presumption in favour of sustainable development contained in paragraph 14 of the NPPF in the Local Plan.
4.9 Policy CS02 (Scale and Distribution of Development) makes a commitment to meeting the Borough’s objectively assessed need for 6,170 new dwellings over the plan period and outlines where new development will take place.
4.10 Policy CS03 (Northfleet Embankment and Swanscombe Peninsula East Opportunity Area) is relevant as the site of the proposed car park is specifically within sub area 1.3 (Grove Road and lower Ebbsfleet Area) consisting of a number of separate sites that have regeneration potential. Part of the sub area has the potential for residentially led regeneration to complement the proposal to extend residential development in sub area 1.4.
4.11 The key site schematic plan shows Grove Road as being improved for bus, pedestrian and cycle links and the land proposed as car park as environmental and landscape improvement.
4.12 Policy CS08 (Retail, Leisure and the Hierarchy of Centres) indicates, amongst other things, that the Council will apply the sequential approach to the location of main town centre uses, support development of a scale and type appropriate to the position of centre in the hierarchy and their character, safeguard retail character and function and encourage the provision of a mix of units.
4.13 The supporting text to policy CS09 (Culture and Tourism) in paragraph 5.3.8 indicates that the Council further seeks an improvement in the quality and an expansion of visitor accommodation in the Borough through:
New hotel development with proximately to the town centre and riverside or close to the A2; Encouraging new bed and breakfast start-ups; and Investigating the expansion of other forms of visitor accommodation.
Paragraph 5.3.12 indicates:
Hotels are also a difficult issue in that whilst they are classified as a main town centre use their location is often dictated by their function and the market they are designed to serve. The Ebbsfleet planning permission allows for hotel development as part of the mix whilst outline planning permission has also been granted for a 60 bed hotel adjacent to the A2 at Coldharbour Road, Northfleet. Notwithstanding this, the Council would still wish to see the town centre as a focus for new visitor accommodation in line with national policy and to support its role as an expanded business centre and tourist destination. The potential to include hotel accommodation as part of the Heritage Quarter development has been identified under Policy CS05 Gravesend Town Centre Opportunity Area.
Paragraph 5.3.13 also advises:
Whilst Gravesend town centre and the local centres are the sequentially preferred location for arts, culture and tourism development, new smaller scale facilities will also be supported in other locations where they relate to the location or meet immediate local needs and will not have unacceptable impacts, for example in terms of residential amenity and traffic generation.
4.14 Policy CS09 (Culture and Tourism) states:
Unless otherwise justified on the basis of a locational connection, functional justification or a requirement to meet smaller scale local needs, proposals involving arts, culture and tourism development will be directed in the first instance to Gravesend Town Centre as the sequentially preferred location for such development in advance of edge of centre and then out of centre sites
4.15 Policy CS10 (Physical and Social Infrastructure) supports proposals and activities that protect, retain or enhance existing social infrastructure. Where there is the threat of loss of existing infrastructure, consideration will be given to viability and whether sufficient alternative provision is available.
4.16 Policy CS11 (Transport) sets out that new developments should mitigate their impact on the highway and public transport networks as required and seeks to ensure sufficient car parking is provided in accordance with adopted car parking standards. 4.17 Policy CS18 (Climate Change) requires new development to reduce the causes and impacts of flooding, minimise impacts on waste water systems, reduce impact on the supply of potable water and reduce the overall carbon footprint of the Borough.
4.18 Policy CS19 (Development and Design Principles) sets out detailed criteria against which the acceptability or otherwise of proposed development will be evaluated. In particular it requires new development to be visually attractive, fit for purpose and locally distinctive. It should conserve and enhance the character of the local built and natural environment and integrate well with the surrounding area. It requires new development to safeguard the amenity, including privacy, daylight and sunlight, of its occupants and those of neighbouring properties and land and avoid adverse environmental impacts from pollution. Proposals should include details of appropriate hard and soft landscaping, protect and where opportunities arise enhance biodiversity and provide appropriate facilities for the storage and disposal of waste.
4.19 Policy CS20 (Heritage and the Historic Environment) gives a high priority towards the preservation, protection and enhancement of its heritage and historic environment as a non-renewable resource, central to the regeneration of the area and the reinforcement of sense of place. Particular attention in this regard will be focused on those heritage assets most at risk. When considering the impact of a proposed development on a designated heritage asset, the weight that will be given to the asset’s conservation value will be commensurate with the importance and significance of the asset. For non- designated assets, decisions will have regard to the scale of any harm or loss and the significance of the heritage asset.
4.20 A Site Allocations and Development Management Policies Development Plan Document will be prepared following the adoption of the Core Strategy.
Gravesham Local Plan First Review 1994
4.21 The Gravesham Local Plan First Review was originally adopted in November 1994.
4.22 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.
4.23 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).
4.24 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.
4.25 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
4.26 Save Policy P3 indicates:
Developments expected to make provision for vehicle parking in accordance with KCC Vehicle Parking Standards, as interpreted by the Borough Council, unless justified as an exception. All vehicle parking provision should normally be made on the development site.
Kent Minerals and Waste Local Plan
4.27 The following policies from the Kent Minerals and Waste Local Plan (2016) apply to the current application because the proposal lies within the 250 metre safeguarding consultation zone for Robin’s Wharf in Grove Road (see plan attached). Whilst the actual aggregates operations are some way distant from the site and there are other intervening uses, a consideration is whether the hotel and mineral operations are compatible.
Policy CSM6: Safeguarded Wharves and Rail Depots Policy DM8: Safeguarding Minerals Management, Transportation Production & Waste Management Facilities
National Planning Policy Guidance
National Planning Policy Framework
4.28 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.
4.29 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.
4.30 The NPPF includes (in paragraph 17) a set of 12 core land-use planning principles underpinning plan making and decision taking.
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.
4.31 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
4.32 On the 6th of March 2014 a new web-based resource for Planning Practice Guidance was launched (http://planningguidance.planningportal.gov.uk/)
4.33 It supports and clarifies areas in the NPPF and replaces a substantial list of guidance documents published from 1978-2013.
4.34 It contains guidance on assessing housing need; design; public consultation; open space provision in new development; travel plans, transport assessments and statements in decision-taking; health and wellbeing; water supply, wastewater and water quality; light pollution; determining a planning application; the use of planning conditions and viability, amongst other things.
4.35 The NPPG gives guidance on what is a material planning consideration in determining a planning application indicating that the impact of a development on the value of a neighbouring property or loss of private rights to light could not be material considerations.
4.36 The NPPG includes more detailed advice on the use of planning conditions (replacing the cancelled Circular 11/95).
Supplementary Planning Guidance
4.37 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.
4.38 In addition the Council has adopted a number of documents that have been produced by Kent County Council also as Supplementary Guidance.
4.39 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)
Ebbsfleet Implementation Framework (EIF) 2017
4.40 The Ebbsfleet Development Corporation (EDC) has recently published an Implementation Framework (2016) that provides a context and statement of ambition for development within the Garden City and its relationship with those areas adjoining. Whilst this document has been consulted upon, it has no formal planning status but it does bring together the existing planning permissions and aspirations for the area. The Borough Council has endorsed the document (at Cabinet 30 January 2017) and it is capable of being a material consideration, but the weight that it is likely to be accorded is low.
4.41 The EIF shows the site as being within a mixed use area.
4.42 The most significant impact of the developments that are being promoted by the EDC in relation to the football ground will be an increase in traffic on Grove Road, including a Fastrack route running through to Gravesend Town Centre. This may have implications for the width of Grove Road and the layout of the junction with Stonebridge Road/Thames Way. Also relevant is the allocation by the Local Plan Core Strategy of 200 new dwellings to the Land East of Grove Road and Robin’s Creek Key Site. 4.43 The EDC has commissioned some work to be prepared (by Arup) into options for improvements to Grove Road.
5. Consultation and Publicity Responses
Consultations
GBC Planning Policy
5.1 The development plan and the relevant development plan policies are set out in section 4 of this report (and thus are not repeated here).
5.2 Policy comments will therefore focus on flood risk and the justification for locating a hotel here rather than in a more central, accessible location as required by both local and national policy, as well as some comments in relation to parking provision.
Flood Risk
5.3 The application site lies within an area susceptible to both tidal and fluvial flooding under extreme events (Environment Agency flood zone 3a). Whilst it is afforded a high degree of protection from tidal flooding by the existing Thames tidal defences, and these are likely to be upgraded over time as part of the Thames Estuary 2100 (TE2100) project, there remains a residual risk of flooding through a breach or overtopping.
5.4 The potential for tidal flooding in this area is well understood from the Kent Thameside Strategic Flood Risk Assessment update (SFRA, 2009)1. This included modelling of a breach in the flood defences at Robin’s Creek during an extreme tidal event. It is clear from this that should this occur flooding would be deep and water fast moving. This confirms the applicant’s site specific Flood Risk Assessment that the depth of flooding could be in excess of 2.5m. Also, given the likely surge tide profile of such an event, flooding through a breach on a return tide cannot be precluded.
5.5 The potential for fluvial flooding would arise during an extreme rainfall event increasing flows in the River Ebbsfleet. Whilst this runs in culvert from south of the railway past the site, if the capacity of this is exceeded during such an event, there could be surface flows through the A226 Thames Way tunnel towards the north.
5.6 Past records of extreme rainfall events provide little evidence of the potential for this given the area has changed so much over the past few years. The worst rainfall event in recent times occurred on the 15 September 1968, when over 100mm of rain fell in parts of Kent over a 24 hour period.2 However, the A226 Thames Way tunnel was not there at this time and the area to the south of the railway largely comprised of former mineral workings that would have attenuated flows.
1 See http://selfservice.gravesham.gov.uk:8081/webdocs/Environment%20and%20Planning/GLP/CLIM- 04_Updating_the_Strategic_Flood_Risk_Assessment_December_2009.pdf 2 The record on this day was 129mm of rainfall in 24 hours at Bromley. See http://www.metoffice.gov.uk/media/pdf/3/2/Southeast_England_Floods_-_15_September_1968.pdf 5.7 The Ebbsfleet Wide Water Management Strategy (2005) included modelling of a 1% extreme rainfall event based on the potential impact of development in the Ebbsfleet Valley.3 Whilst this is somewhat dated and only took into account drainage of rainwater to the south of the railway, it found that the level of water would not exceed that of the site subject of the current application. In any event, it is recognised that any water flowing through the A226 Thames Way tunnel to the north would be dispersed over a fairly large area.
5.11 The only record of surface water flooding to the north of the railway is contained in the Kent Thameside Surface Water Management Plan (2013), whereby the carriageway of the A226 at Stonebridge Road flooded to a depth of 300mm in 2009. No properties were affected.
5.12 Given the above, the greatest risk from flooding appears to be tidal should the defences be breached or overtopped and it is appropriate that the site specific Flood Risk Assessment (FRA) should concentrate on this.
5.13 Policy CS18 on Climate Change requires applications for development in areas at risk of flooding to be accompanied by a FRA in accordance with national policy and Environment Agency guidance to demonstrate that proposals are adequately defended and safe over their lifetime. Proposals are required to pass the ‘Sequential’ and ‘Exception’ Tests as appropriate. A Flood Risk Management Plan (FRMP) may also be required to ensure that residual risk of flooding is adequately managed in the interests of safety.
5.14 The proposal introduces a hotel use into an area of flood risk, with sleeping accommodation on the first and second floor and a restaurant/bar on the ground floor. Hotels are deemed to be a ‘More Vulnerable’ use in flood risk terms, requiring the application of both the Sequential and Exception Tests4.
5.15 The Sequential Test effectively directs such uses in the first instance to areas at lower risk of flooding (i.e. Zone 1 then Zone 2) before development in Zone 3a (defended floodplain) can be considered. National planning policy on flood risk is applied slightly differently depending on whether a site is being considered at the plan making or application stages. Where a site has been allocated for development through the local plan, there is no requirement to apply the Sequential Test at the application stage because this issue will already have been addressed.
5.16 This does not apply in this case. Whilst the site lies within the Northfleet Embankment and Swanscombe Peninsula East Opportunity Area, to which policy CS03 applies, it is not identified as a ‘Key Site’ and cannot therefore be considered a strategic allocation. The potential for regeneration and redevelopment is however recognised in the supporting text (Sub Area 1.3). The Sequential Test therefore applies.
5.17 If the proposal passes the Sequential Test, the next step is to apply the Exception Test.
3 See GR/2003/0660 at https://plan.gravesham.gov.uk/online- applications/applicationDetails.do?activeTab=summary&keyVal=ZZZZYWHPXC924 4 See tables 2 and 3 of PPG section on flood risk at https://www.gov.uk/guidance/flood-risk-and- coastal-change 5.18 The Exception Test contains two parts. The first is that that the proposal must provide wider sustainability benefits to the community that outweigh flood risk, informed by a Strategic Flood Risk Assessment where one has been prepared. The second part of the test requires that a site-specific FRA must demonstrate that the development will be safe for its lifetime taking into account the vulnerability of its users, without increasing flood risk elsewhere, and, where possible, reducing flood risk overall.
5.19 Whilst the application is accompanied by a site specific FRA, this is not a particularly robust document in terms of the way in which the Sequential and Exception Tests have been applied. For example, in applying the Sequential Test it argues that because the football ground has been in this location since the 1890s, it would not be possible to move the club into a lower risk flood zone and that this is better than a site in flood zone 3 in general because it benefits from flood defences.
5.20 However, this completely misses the point, in that a football ground is an assembly and leisure use that is categorised as ‘Less Vulnerable’ in flood risk terms and is acceptable anyway in flood zone 3a. The issue here is the introduction of a hotel which is a ‘More Vulnerable’ use and only acceptable where the appropriate tests are passed.
5.21 However, the NPPF (at paragraph 102) advises that if, following the application of the Sequential Test it is not possible, consistent with wider sustainability objectives, for a development to be located in zones with a lower probability of flooding, the Exception Test can be applied if appropriate.
5.22 Planning Practice Guidance (PPG - at Paragraph: 036 Reference ID: 7-036- 20140306) also recognises there will be instances where a development cannot reasonably be located in an area of lower risk of flooding, with this in some instances linked to an area being subject to redevelopment or regeneration. The Guidance (at Paragraph: 033 Reference ID: 7-033- 20140306) also advises that the Sequential Test should be applied in a pragmatic way, recognizing that the circumstances of the case may mean that it might be impractical to suggest that there are more suitable alternative locations elsewhere.
5.23 It is arguable that this applies here. The first point is that whilst the hotel would be open to the general public, one of the key drivers of the scheme is to have accommodation on site that can be used in combination with the conference and other facilities in the main stand etc. There may therefore be a functional relationship between the hotel element and the other facilities at the new ground, which means that it can only reasonably be located at the stadium. If this is accepted, the Sequential Test is passed and it is possible to move on to the Exception Test.
5.24 Turning to this, the FRA completely ignores the first requirement to demonstrate wider sustainability benefits that outweigh flood risk. Local planning authorities are advised to consider what criteria they will use in making such an assessment, having regard to their Local Plan Sustainability Appraisal framework. Proposals that fail to score positively against such criteria or local plan policies should be refused. The inadequacy of the FRA in this respect is unfortunate in that a strong case can actually be made for the proposal that potentially meets the requirements of policy. 5.25 The sustainability benefits of the proposal have been assessed against the criteria set out in the Sustainability Appraisal of the Gravesham Local Plan Core Strategy and local plan strategic objectives and policy. It is considered that the sustainability benefits of the scheme are strong and that consideration should be given as to whether these can be considered to outweigh flood risk in this instance.
5.26 Whilst the second part of the test is addressed in terms of not increasing flood risk elsewhere, the issue of safety is only considered in terms of postponing matches and evacuating the building in accordance with a Flood Response Plan. However, whilst not all of the items may be relevant in this case, national guidance (PPG at paragraphs: 038 Reference ID: 7-038-20140306 and 039 Reference ID: 7-039-20140306) sets out that that the following should be covered by a site specific FRA to demonstrate that a development is safe over its lifetime:
the design of any flood defence infrastructure; access and egress; operation and maintenance; design of development to manage and reduce flood risk wherever possible; resident awareness; flood warning and evacuation procedures; and any funding arrangements necessary for implementing the measures.
5.27 Where access and egress is important to the overall safety of the development, it is also necessary to give consideration as to whether the safe and free movement of people during a ‘design flood’ can be achieved, as well as the potential for evacuation before a more extreme flood. In this instance, a ‘design flood’ would relate to a 0.5% probability (1 in 200 year return period) tidal flood event. As the site is protected to at least this level by the Thames tidal flood defences, safe and free movement of people is assured and it is arguable that protection against residual risk due to breach or overtopping that is the primary concern.
5.28 In terms of the proposal being safe for its lifetime having regard to the vulnerability of users, it is necessary to recognise that occupants of the hotel could include any members of the general public including those who are elderly, frail or disabled. This means that there may be more vulnerable people in the building should it need to be evacuated during a flood event.
5.29 Whilst it would be preferable for the building to be evacuated and people removed to a place of safety during a flood, a breach of the flood defences or over-topping could result in rapid inundation of the surrounding area. It is also important to remember that flooding could occur during hours of darkness, when people are asleep, making evacuation more difficult to organise - particularly if lighting in the area was to fail as a result of flooding.
5.30 This means that whilst subscribing to the Environment Agency flood warning service and having a Flood Risk Management Plan may be the first line of defence should a serious flood event occur, it would not necessarily guarantee the safety of occupants of the building. 5.31 However, the fact that the first and second floor accommodation in the building are likely to be set above the theoretical tidal flood level (plus an allowance for freeboard) would provide occupants with a means of escape to a place of safety from which they could be subsequently evacuated.
5.32 In terms of not increasing flood risk elsewhere, it is accepted that this part of the football ground is either already occupied by buildings or hard surfaced. Flood risk from surface water run-off during an extreme rainfall event may therefore be reduced through the use of Sustainable Urban Drainage (SUDS) and rainwater harvesting for pitch irrigation.
5.33 However, the site specific FRA does not appear to address whether the new buildings occupy more space than those to be removed and whether this would increase flood risk elsewhere by reducing water storage capacity during a flood event. Having said this, any such impact is likely to be marginal given the scale of built form compared to the area that would be flooded should the tidal defence be breached or over-topped.
5.34 Given the potential depth of flooding that might occur at the site, a more critical issue is the potential effect of this on the structure of the building given occupants might have to seek refuge on the upper floors. The building therefore needs to be designed to withstand the forces that might act upon it and to withstand impact damage from floating debris.
5.35 One option in this respect may be to design the building to be flood resilient (i.e. easily repairable should a flood event occur) but not flood resistant (i.e. so that the ground floor would be allowed to flood when water reached a certain depth to equalise pressure on either side of the external walls).
5.36 The conclusion reached here therefore is that, notwithstanding the content of the site specific FRA as submitted, a case could be made for the proposal that would meet the requirements of both local and national policy in relation to flood risk. It is suggested that this be discussed with the Environment Agency. If planning permission is granted for the hotel element, suitable conditions should be applied to address the points made above i.e.
There should be no sleeping accommodation at ground floor level; The finished floor level should be set above the theoretical flood level at 2015 + an allowance for freeboard – in other cases this has been taken as 600mm for sleeping accommodation; There should be a requirement to subscribe to the Environment Agency Floodline + a Flood Risk Management Plan put in place; The building should be designed and constructed to withstand the forces that may be imposed on it under flood conditions, including potential impact damage from floating debris; and The ground floor of the building should be designed and constructed with flood resilience in mind.
Whether this is an acceptable location for a proposed hotel use
5.37 As noted above, both national and local plan policy consider hotels to be a ‘main town centre use’ which should be directed sequentially to town centres before edge-of-town centre and then out-of-town centre sites are accepted (see policy CS08 and the NPPF at paragraphs 23 – 27 and Glossary for definition of main town centre uses). There is no requirement under either local or national policy to apply an ‘Impact Test’ where hotels are not located in a town centre (see NPPF at paragraph 26 – this test only applies to retail, leisure and office development).
5.38 Whilst the applicant has submitted a Sequential Assessment in support of the proposal to demonstrate that there are no more central sites capable of accommodating the hotel at the current time, it is recognised that some such developments have specific locational requirements which mean they can only be delivered in a specific place.
5.39 This is recognised in both policy CS09 on Culture and Tourism and its supporting text (at paragraph 5.3.12). It is accepted in this context that hotels are a difficult issue in that whilst they are classified as a main town centre use, their location is often dictated by their function and the market they are designed to serve. Policy CS09 therefore includes the caveat (at 5.3.16) that the sequential approach (i.e. town centre first) will be applied unless otherwise justified on the basis of a locational connection, functional justification, or a requirement to meet smaller scale local needs.
5.40 Planning Practice Guidance (at Paragraph: 011 Reference ID: 2b-011- 20140306 ) also advises that the use of the sequential test should recognize that certain main town centre uses have particular market and locational requirements which mean that they may only be accommodated in specific locations. Robust justification must be provided where this is the case, and land ownership does not provide such a justification.
5.41 In this instance, whilst the hotel would be available for use by general members of the public, it is intended to have a functional relationship with other facilities being provided at the new stadium – including the conference facilities being created. Notwithstanding the Sequential Assessment that has been provided, it is arguable therefore that the proposal is capable of demonstrating particular locational requirements related to the synergy with other facilities to be provided at the new stadium.
Car Parking
5.42 Whilst it will be for others to provide a view on the adequacy of car parking arrangements to serve the hotel element and how these may function on match days, it is noted that Condition 28 to planning permission GR/2015/0081 only requires the car park at the Swanscombe End to be kept available for the parking of cars and for vehicle manoeuvring at all times when the ground is in use and for no other purpose.
5.43 It does not appear to require that these spaces should be available for supporters etc. attending matches only for the parking of cars in general – which would not rule out their use to serve the hotel. 5.44 However, this does raise an issue in that the intention of redeveloping the ground is to meet ground grading criteria for higher divisions (i.e. the National Conference and ultimately the Football League)5.
5.45 These ground grading criteria include certain requirements in relation to parking arrangements for the visiting team’s coach, visiting directors and unmarked spaces for match officials. Is the intention to use the car park at the Swanscombe End as parking for the hotel consistent with these ground grading criteria or would it result in a reduction of spaces available to serve the hotel?
Ebbsfleet Development Corporation (EDC)
5.46 EDC has no objection to the application, but offers the following comments:
• The EDC’s Implementation Framework identifies the Stonebridge Road roundabout and Grove Road as a gateway area that will provide a key pedestrian, cycle and vehicular access into the Northfleet Riverside area. It is therefore important that the design of the football ground, associated uses and surrounding public realm is complementary to this vision. Whilst not an adopted document, it has recently been endorsed by GBC and is therefore a material planning consideration in determining this planning application.
• In terms of car parking and traffic movements, the football club should be looking beyond just car-borne visitors, making greater use of HS1 / Fastrack links with any absolutely necessary parking provision being possibly linked to existing car parks with shuttle services for supporters. The safety of supporters (and hotel patrons) should also be considered, to encourage trips by sustainable means, which should be considered holistically having regard to wider regeneration proposals, including arrangements for safe and discreet servicing of the hotel and function room. The football ground proposal should also consider additional noise/air quality from increasing traffic (sensitive as incorporating sleeping accommodation), and should also have regard to industrial noise from the surrounding area, including from aggregates operations that take place from Robins Wharf.
Kent Highways and Transportation
5.47 Generally there is no highway objection to this application and it is considered that elements such as traffic generation and parking for the new stadium itself were covered in the previous hybrid application previously granted consent (20150081) and was in outline form for this current phase (Phase 1B). The previous consent included the requirement for works immediately outside the stadium fronting Stonebridge Road to improve pedestrian access facilities. These works are included in a pending Section 278 Agreement with KCC Highways, the details of which are agreed.
5.48 However, this application now includes a 55 bed hotel which did not form part of the previous application and whilst in principle does not raise a highway
5 For Football League ground grading criteria see http://www.efl.com/global/appendix1.aspx , for National Conference and lower league ground grading criteria see http://www.thefa.com/get- involved/player/clubs-leagues/ground-grading objection, does raise a number of issues which need to be addressed before any planning consent is granted:
1. Access road to hotel - This should be of sufficient width to allow for two- way traffic and avoid the possibility of vehicles reversing back out onto the roundabout. As shown on the latest layout the access road measures 3.6m wide at its narrowest point widening to 4.2m at the entrance to the parking area. This is insufficient width for two-way light traffic, notwithstanding larger delivery vehicles / coaches, and should be a minimum of 4.8m wide throughout.
2. Access road pedestrian crossing - included in the detail design under the pending Section 278 Agreement and within the public highway, a pedestrian dropped kerb crossing point (including tactile paving) is proposed close to the car park entrance to provide a safe crossing point for pedestrians across the access road. This should be shown on the layout drawings for this current application and also should demonstrate that sufficient vehicle / pedestrian visibility is available at this crossing point - 2.0m x 2.0m minimum.
3. Exits from stadium stands - more information is required in explanation of how the entrances / exits from the stands are to be managed. One of the exits is severely restricted by parking space no. 22 and it is unclear if a wall will separate the parking area from the general pedestrian congregation area around the exit shown. This could be of concern at times of emergency when the free flow of pedestrians needing to exit is restricted.
4. Hotel parking - The current KCC Parking Standard (SPG4) for a hotel recommends a maximum of 1 space per bedroom plus 1 space per 2 staff. On the assumption of 10 staff (not clearly defined in the application documents) this amounts to a maximum of 60 spaces compared with the proposed provision of 25 spaces on non-match days. However, the site is located in a relatively sustainable location with two nearby train stations and frequent bus services in the vicinity which, together with a robust Travel Plan for the hotel (more below), should reduce the reliance by hotel guests and staff on the use of the private car to travel. In this respect it is considered that the number of parking spaces proposed (25) is adequate in this location.
However, it is unclear what the parking arrangements for the hotel are on match days when the car park immediately adjacent to the hotel will be unavailable, and on non-match days should the hotel car park become full. It would appear that the car park at the opposite end of the stadium is only available on match days when it is likely to be full anyway and restricted to season ticket holders, and that the alternative parking at Ebbsfleet station is a considerable walking distance from the hotel (with luggage) and only available at a discounted price on match days.
A clear explanation of how the parking for both the stadium and the hotel will be managed on both match and non-match days should be submitted. There is concern that with robust management of parking it will result in additional on-street parking detrimental to highway safety.
5. Coach dropping off / parking - In accordance with SPG4 Parking Standards a coach dropping off / parking area should be provided in close proximity to a hotel at a rate of 1 space per 20 bedrooms i.e. 3 in this case. However, given the sustainable location and the expected usage of the proposed hotel this could be reduced to a minimum of one space. No coach stopping / parking spaces are shown on the layout and additionally a coach entering the car parking areas would be unable to turn and is likely to reverse out of the access road onto the roundabout which would be a severe highway hazard to other road users. Coaches would not be able to stop to load / unload in the highway immediately outside the car park entrance due to the proximity of the roundabout approach road and the roundabout itself. Suitable and safe provision for a coach needs to be identified.
6. Servicing - no indication of how the hotel is to be serviced and the size of vehicles likely to be used for servicing. Again the parking area does not have sufficient space for service vehicles to stop and to turn road such that they are able to exit in forward gear similar to the concerns regarding coaches as above.
7. Cycle parking - There are two areas shown for cycle parking, one outside the stadium entrance presumably for stadium guests / staff, and one off the car parking area which is for hotel guests / staff but not in a particular convenient location. Neither of these cycle parking areas appear to be secure or weatherproof which is essential in encourage use of cycles to travel to the facilities and should be reconsidered and improved.
8. Travel Plan - whilst the Travel Plan submitted for the stadium is acceptable, the hotel should have a separate Travel Plan specific to that use rather than a brief and rather vague addendum attached to the stadium TP. This should include information as to how sustainable travel by guests and staff is to be encouraged, target modal shift figures, and a regime of monitoring.
9. Construction Management - a Construction Management Plan covering both the stadium stand and the hotel (including details of materials storage and construction staff parking) should be submitted either as an application document or Conditioned such that it is submitted and approved prior to any construction works commencing.
5.49 In conclusion, whilst there is no highway objection in general to the proposal, the issues raised above should be addressed and submitted for further consideration prior to any consent being granted.
Sport England
5.50 Sport England is satisfied that the proposed development meets the following Sport England Policy exception:
Policy E3 – The proposed development affects only land incapable of forming, or forming part of, a playing pitch, and does not result in the loss of, or inability to make use of any playing pitch (including the maintenance of adequate safety margins), a reduction in the size of the playing area of any playing pitch or the loss of any other sporting/ancillary facility on the site.
5.51 As part of this consultation Sport England consulted the FA who confirmed that they are ok with the proposal. This being the case, Sport England does not wish to raise an objection to this application. The proposal should accord with Sport England’s relevant design guidance. Leisure Manager, GBC
5.52 From a sports and leisure development perspective, the council’s Leisure Team supports the application for the re-development of the Ebbsfleet Utd Football stadium. The Plough End Stand, which will house a bar/social area, noted as being available usable on non-match days for private hire, as well as the proposed hotel, both provide additional improved amenities for the local area. These types of facilities as mentioned will also help to support the club with on-going revenue streams in addition to the football activity at site. How these elements mix in reality, especially a working hotel and home football matches, may require some further thought from an operational perspective (and planning perspective), including the management of on-site car parking and the communal areas surrounding the stadium itself both pre and post- match.
5.53 It is noted that Sport England have responded with no objection to the development and further comments are anticipated to be received from the national governing body of Sport (i.e. Football Association). We assume that the latter will provide some comment on the stadia design, safety and layout from a spectator perspective and links to current stadia grounds guidance documentation, specific building regulations and DDA guidance e.g. “Guide to Safety at Sports Grounds” etc.
The Football Association (The FA)
5.54 No comments received to date
GBC Regulatory Services, Contaminated Land Comments
5.55 The site investigation did not identify contamination on this part of the site. The following condition is recommended:
The applicant shall undertake a watching brief during construction in case any contamination issue is encountered. If during development any contamination is found, the Local Planning Authority should be informed as soon as practical and the work shall not continue until written agreement is provided by the Local Planning Authority as to the appropriate measures to be taken to resolve the matter and they are satisfied that those measures have been carried out.
GBC Regulatory Services, Environmental Protection Comments
Noise Informative
5.56 As these proposals do not include residential dwellings this Service cannot insist on a formal noise assessment relating to noise but it would be in the developer’s commercial interests to provide sleeping accommodation with a good standard of noise insulation. The applicant should therefore be advised that they provide a scheme taking into account the existing noise levels from traffic, commercial noise levels and noise from crowds on match days prior to commencement of any works on site Works of Construction
5.57 The Construction Management Plan ref T1-3880/SJ-CRF included with the application has been assessed and is considered acceptable for this development.
Environment Agency – Original Comments 07 April 2017
5.58 We have reviewed the information submitted and object to the application on Flood Risk grounds. Please see details below.
Reasons
5.59 The FRA submitted with this application does not comply with the requirements set out in paragraph 9 of the Technical Guide to the National Planning Policy Framework. The submitted FRA does not therefore, provide a suitable basis for assessment to be made of the flood risks arising from the proposed development.
5.60 In particular, the submitted FRA fails to:
1. Provide a culvert survey in order to confirm its exact location in relation to the proposed built development on the site.
This survey should determine the line and dimensions of the culvert, which includes the culvert height, width, depth below ground and invert level. Please note that approximate location for these purposes would not suffice. It is in the applicant’s best interests to confirm this exact location as if development damaged the culvert, the developer and/or their contractor would be fully responsible for the repair and any flooding to third parties which could result as a consequence of the damage caused.
2. Comply with Condition 10 of the "Notification of Grant of Permission to Develop Land document" dated 30 April 2015.
No development shall take place within 8m horizontally of any part of the structure of the culvert which carries the river Ebbsfleet unless otherwise agreed in writing by the Local Planning Authority, in consultation with the Environment Agency.
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.
Overcoming our Objection
5.61 You can overcome our objection by submitting an FRA which covers the deficiencies highlighted above and demonstrates that the development will not increase risk elsewhere and where possible reduces flood risk overall. If this cannot be achieved we are likely to maintain our objection to the application. Production of an FRA will not in itself result in the removal of an objection.
5.62 We ask to be re-consulted with the results of the FRA. We will provide you with bespoke comments within 21 days of receiving formal re-consultation. Our objection will be maintained until an adequate FRA has been submitted.
Conditions and Informatives
5.63 Should our Flood Risk objection be overcome we would recommend the following conditions be included in any planning decision to address the risks to groundwater.
Groundwater and Contaminated Land
This site is based in an area of commercial/industrial uses which may have led to contamination of the ground in part. Site assessments have not identified significant risks from historic contamination, but hotspots form spillages, pollution incidents or leaks may need to be addressed.
Condition
If, during development, contamination not previously identified is found to be present at the site then no further development (unless otherwise agreed in writing with the Local Planning Authority) shall be carried out until a remediation strategy detailing how this contamination will be dealt with has been submitted to and approved in writing by the Local Planning Authority. The remediation strategy shall be implemented as approved.
Reasons: To ensure that the development does not contribute to or is not put at unacceptable risk from, or adversely affected by, unacceptable levels water pollution from previously unidentified contamination sources at the development site in line with paragraph 109 of the National Planning Policy Framework.
Condition
No infiltration of surface water drainage into the ground is permitted other than with the written consent of the Local Planning Authority. The development shall be carried out in accordance with the approved details.
Reasons: To ensure that the development does not contribute to or is not put at unacceptable risk from, or adversely affected by, unacceptable levels water pollution caused by mobilised contaminants in line with paragraph 109 of the National Planning Policy Framework.
Earthworks Informative:
The CLAIRE Definition of Waste: Development Industry Code of Practice (version 2) provides operators with a framework for determining whether or not excavated material arising from site during remediation and/or land development works are waste or have ceased to be waste. Under the Code of Practice: excavated materials that are recovered via a treatment operation can be re-used on-site providing they are treated to a standard such that they fit for purpose and unlikely to cause pollution treated materials can be transferred between sites as part of a hub and cluster project some naturally occurring clean material can be transferred directly between sites.
Developers should ensure that all contaminated materials are adequately characterised both chemically and physically, and that the permitting status of any proposed on site operations are clear. If in doubt, the Environment Agency should be contacted for advice at an early stage to avoid any delays. The Environment Agency recommends that developers should refer to:
the Position statement on the Definition of Waste: Development Industry Code of Practice and; The Environmental regulations page on GOV.UK
Environment Agency- revised comments 2 May 2017
5.64 The applicant has provided additional information (Drawing 1127 SP01 PL5 – Proposed Site Plan & Drawing 1127 GA10 PL2 – Proposed Section BB) in response to our objection to the proposal.
5.65 The additional information does not provide all the requested information, as such we maintain our objection.
5.66 The objection can be overcome by providing a culvert survey that confirms its exact location in relation to the proposed built development on the site. This survey should determine the line and dimensions of the culvert, which includes the culvert height, width, depth below ground and invert level. Details of how the survey was carried out should also be provided
5.67 Please note that approximate location for these purposes would not suffice. It is in the applicant’s best interests to confirm this exact location as if development damaged the culvert, the developer and/or their contractor would be fully responsible for the repair and any flooding to third parties which could result as a consequence of the damage caused.
5.68 We would also like to clarify that the 8m byelaw margin relates to the edge of the culvert not the centre line of the culvert.
Southern Water
5.69 Please find attached a plan of the sewer records showing the approximate position of a public foul sewer within the site. The exact position of the public sewers must be determined on site by the applicant before the layout of the proposed development is finalised.
Please note: - No development or new tree planting should be located within 3 metres either side of the centreline of the public sewer; - No new soakaways should be located within 5 metres of a public sewer - All existing infrastructure should be protected during the course of construction works.
5.70 Furthermore, due to changes in legislation that came in to force on 1st October 2011 regarding the future ownership of sewers it is possible that a sewer now deemed to be public could be crossing the above property. Therefore, 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 potential means of access before any further works commence on site. The applicant is advised to discuss the matter further with Southern Water, Sparrowgrove House Sparrowgrove, Otterbourne, Hampshire SO21 2SW (Tel: 0330 303 0119) or www.southernwater.co.uk”.
5.71 The results of an initial desk top study indicates that Southern water currently cannot accommodate the needs of this application without the development providing additional local infrastructure. The proposed development would increase flows into the wastewater sewerage system and as a result increase the risk of flooding in an around the existing area, contrary to paragraph 109 of the National Planning Policy Framework (NPPF).
5.72 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. You will be required to provide a topographical survey and/or a CCTV survey with the connection application showing the existing connection points, pipe sizes, gradients and calculations confirming the proposed flow will be no greater than the existing contributing flows.
5.73 Should the Local Planning Authority be minded to approve the application, Southern Water would like the following condition to be attached to any permission:
Development shall not commence until a drainage strategy detailing the proposed means of foul and surface water disposal and an implementation timetable has been submitted to an approved in writing by, the Local Planning Authority in consultation with the sewerage undertake. The development shall be carried out in accordance with the approved scheme and timetable
5.74 We suggest the following informative:
The applicant/developer shall enter into a formal agreement with Southern Water to provide the necessary sewerage infrastructure required to service this development. The applicant/developer should contact Southern Water, Sparrowgrove House, Sparrowgrove, Otterbourne, Hampshire SO21 2SW (Tel: 0330 303 0119) or www.southernwater.co.uk” in order to progress the necessary infrastructure.
5.75 The planning application form makes reference to drainage using Sustainable Urban Drainage Systems (SUDS). Under current legislation and guidance SUDS rely upon facilities which are not adoptable by sewerage undertakers. Therefore, the applicant will need to ensure that arrangements exist for the long term maintenance of the SUDS facilities. It is critical that the effectiveness of these systems is maintained in perpetuity. Good management will avoid flooding from the proposed surface water system, which may result in the inundation of the foul sewerage system. Thus, where a SUDS scheme is to be implemented, the drainage details submitted to the Local Planning Authority should:
- Specify the responsibilities of each party for the implementation of the SUDS scheme - Specify a timetable for implementation - Provide a management and maintenance plan for the lifetime of the development. This should include the arrangements for adoption by any public authority or statutory undertaker and any other arrangements to secure the operation of the scheme throughout its lifetime.
5.76 Due to the vibration, noise and potential odour generated by sewerage pumping stations, no habitable rooms should be located closer than 15m to the boundary of the proposed pumping station.
5.77 We request that should this application receive planning approval, the following condition is attached to the consent:
Construction of the development shall not commence until details of the proposed means of foul and surface water sewerage disposal have been submitted to, and approved in writing by, the Local Planning Authority in consultation with Southern Water.
5.78 Following initial investigations, Southern Water can provide a water supply to the site. Southern Water requires a formal application for connection and on- site mains to be made by the applicant or developer. We request that should this application receive planning approval, the following informative is attached to the consent:
A formal application for connection to the water supply is required in order to service this development. Please contact Southern Water, Sparrowgrove House, Sparrowgrove, Otterbourne, Hampshire SO21 2SW (Tel: 0330 303 0119) or www.southernwater.co.uk.
5.79 The proposed development would lie within a Source Protection Zone around one of Southern Water's public water supply sources as defined under the Environment Agency’s Groundwater Protection Policy. Southern Water will rely on your consultations with the Environment Agency to ensure the protection of the public water supply source.
Kent County Council, Lead Local Flood Authority (LLFA)
5.80 No comments received to date
KCC Archaeology
5.81 No comments received to date
GBC Conservation Architect 5.82 The Kent Historic Environment Record indicates no heritage assets on the actual site. The first series OS map, 1871-1890, show the land having been old clay pits at that time with a corn windmill to the north of the site, next to Botany Bay in the Northfleet Marshes. To the east of the site was the Weston & Co cement works on Grove Road with associated wharf and the Aspin’s Kiln, Scheduled Monument 1004227. The County Archaeologist has commented previously on the site’s heritage potential in the previous application 20150081 and there is no need to repeat those comments.
Dartford Borough Council
5.83 Dartford Borough Council has no comments to make.
Kent Police Crime Prevention Design Advisor
5.84 Having reviewed the on line plans and documentation, I note section 4.3 Safety in the Design and Access Statement (D&AS) and also section 48 Safety/Evacuation within the planning statement, however, there appears to be no specific mention of crime prevention or CPTED within these documents, however safety, security and evacuation measures are referred to.
5.85 I can confirm that my colleague and I met with the applicant/agent on the 15th of April 2015, to discuss the initial proposals, however the proposed hotel was not discussed at this time and to date had no communication from the applicant/agent regarding the hotel proposal. I note that the applicant/agent is hoping to achieve BREEAM excellent, should the application proceed for which it is possible to achieve BREEAM points for security. There are other issues that may need to be discussed and addressed including a formal application for BREEAM and Secured By Design (SBD) if appropriate.
5.86 There is merit in pre-application meetings prior to submission of any planning application and by meeting with us and discussing issues such as Crime Impact Statements (CIS) and any formal applications for this scheme such as BREEAM, Secured By Design (SBD), and SBD National Building Approval Scheme need to be addressed and agreed. Further details can be found at the following web link: https://www.kent.police.uk/advice/businesses/planners- and-developers/
5.87 I would be grateful if you could draw the applicant’s attention to the Kent Design Initiative (KDI), which will also assist them with Crime Prevention and Community Safety. I would welcome a meeting with the applicant/agent to discuss Crime Prevention for the hotel in particular, in more detail and any notes from a meeting/consultation may be passed back to the Planning Officer dealing with the application as part of my full response to this planning application. A copy of the protocol and guidance can be found at the following web link: https://www.kent.police.uk/advice/businesses/planners-and-developers/
5.88 If the applicant fails to contact us, this may have an effect on the development with regards to Secure By Design (SBD) and BREEAM, as awarding these items retrospectively can prove difficult and costly. This could also have knock on effects for the future services and duties of the Community Safety Unit (CSU) and local policing.
5.89 With the above in mind, I recommend that a CPTED planning condition be imposed to ensure that safety and security are maintained.
UK Power Networks
5.90 No objections.
HSE
5.91 The proposed development does not currently lie within the consultation distance of a major hazard site or major accident hazard pipeline and therefore the HSE does not need to be consulted on any developments on this site.
National Grid
5.92 Notes that the development is within the vicinity of National Grid’s transmission assets and the enquiry has been passed to the Asset Protection team for further detailed assessment.
Southern Gas Networks (SGN)
5.93 No specific comments. Advises on the location of pipes owned by SGN. There is a pressure gas main near the site. Advises on safety requirements for works within 3m of a pressure system.
Swanscombe and Greenhithe Town Council
5.94 No observations.
Kent Fire and Rescue Service
5.96 Access provided for fire appliances appears to be satisfactory.
Natural England
5.97 No comments.
Aggregate Industries
5.98 Views awaited.
Northfleet Property LLP (Developers of the former Northfleet Cement Works) 5.99 Ebbsfleet Development Corporation has resolved to grant planning permission to NPLLP for a Mixed Use Development on its land at the former Northfleet Works. This scheme includes upgrades to Grove Road as part of the access strategy.
5.100 There is no objection in principle to the proposed development, but there is concern that the full effect of the proposed hotel, along with the conference facilities and sports activity has not been fully considered within the application in terms of parking and access. NPLLP request that Gravesham Borough Council and Kent County Council take account of the Mixed Use Development proposals and related access proposals for Grove Road in determining the football club application, and also take full account of the ongoing study of the area by Ebbsfleet Development Corporation.
Additional Consultations Awaiting Response
5.101 In addition to those referred to above the following consultees have also not responded to date to the consultation:
Northfleet Harbour Restoration Trust GBC - Community Safety Team South East Coast Ambulance Service NHS Foundation Trust Arriva Southern Counties Network Rail (South Eastern) HS1 GBC - Economic Development Manager
Publicity
5.102 The proposals have been advertised on site and in a local newspaper as being a major development proposal. In addition over 950 nearby dwellings and premises have been notified of the application.
Objections
5.103 Two objections have been received from club supporters
Whether it is appropriate to have a hotel attached to a football stand The compatibility of having a football stand within/adjacent to a hotel Whether the functionality of the football ground is being compromised Lack of cover for supporters The current new stand results in exposure to the elements due to the gap between the roof and the new seats New stand is any unoriginal and unfit design and should not be repeated; lack of thought to architecture Terracing very shallow for supporters Lack of atmosphere that this will create within the ground Intrusiveness of the hotel from the inside of the ground The hotel should be separate from the grounds stand Potential disturbance to hotel patrons from football matches Need to consider within the context of overall ground improvements and unknown as to what is proposed for the replacement of the other remaining stands It is questioned whether a hotel is needed as there will be hotels provided as part of the longer term proposals for the wider area
Letters of Support
5.104 There are three letters of support from football supporters, the grounds being
The development which will bring employment and facilities to the area, and enhance the appearance of a largely industrial area of Northfleet. The hotel and resultant new stand will be fantastic for not only the area but the football club It will allow Ebbsfleet United to become financially stable and progress up the football pyramid A minority of Ebbsfleet fans seem to be against this but it mainly those whose only interest is drink. Greater contribution to the local community
5.105 There have been no responses to date either for or against the proposals from neighbours/premises that directly adjoin or are directly affected by the proposals. The final expiry date for neighbour responses to statutory and discretionary was 21 April 2017.
5.106 The football club/directors held a meeting on Thursday 20 April 2017 at the ground to answer fans concerns about the proposed development.
6. Planning Analysis and Interim Development Manager Comments
6.1 This application is for the demolition of the Plough End stand and ancillary buildings including the club supporter’s bar and the erection of a replacement stand (phase 1B) and an integrated 55 bed hotel together with new access, parking and ancillary facilities at the Ebbsfleet United Football Ground in Stonebridge Road Northfleet.
6.2 The application site benefits from a hybrid planning permission under GR/2015/0081 for the redevelopment of the football ground that will meet Football League ground grading criteria and increase capacity from 4,500 (prior to current improvements) to 6,000. That part of the permission that was granted in full is currently being implemented, with the new main stand fronting Stonebridge Road nearing completion. The remainder of the permission was in outline form. Because the current proposal deviates from the original permission by including a 55 bed budget hotel at the Plough End, a separate full planning application is required.
The Key Issues
6.3 The introduction of the hotel element does however raise issues separate from the redevelopment of the ground itself that need to be addressed. The key issues in this case are considered to be: The Principle of the Development and the appropriateness of siting a hotel in this location given that hotels are deemed to be a ‘main town centre use’, and therefore whether this location is acceptable in policy terms or can be otherwise justified; The design of the Plough End stand with a hotel included, how it relates to the new stand under construction and potential future phases and any visual impacts; Considerations relating to the introduction of an hotel into an area identified as susceptible to flood risk (Environment Agency flood zone 3a – defended tidal flood plain and fluvial risk) The appropriateness of the proposed access arrangements and the adequacy of car parking provision and whether the introduction of the hotel element is compatible with the primary use of the site, having regard to the Transport Assessment that accompanied the original application and the conditions attached to the original consent; Whether the location is environmentally suitable for the introduction of a hotel use given its surrounding context – including the fact that one side of the hotel will be facing into the football ground, which will have noise and other impacts; and Other Issues – Archaeology, Safety etc.
6.4 It should be noted that the application has not been the subject of an Environmental Impact Assessment screening (EIA) on the basis that the overall redevelopment of the ground was subject to EIA Screening and this concluded that the development was not a qualifying EIA development, the inclusion of an integral hotel was not considered an addition that warranted a repeat of the screening process.
Principle of the Development/Sequential Assessment
6.5 The principle of redeveloping the ground has already been agreed in 2015 and this represents a much welcomed investment in the future of the area that has the potential to act as a catalyst for future regeneration.
6.6 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.
6.7 The proposals 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 at Swanscombe Peninsula which is intended to be the subject of a Development Consent Order application towards the end of this year to Government under the NSIP process, albeit that the hotel element in seen as more complementary to the conference and business facilities being located within the newly constructed Stonebridge Road stand at the ground.
6.8 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.
6.9 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.
6.10 The details that were submitted at the time of the previous hybrid application showed that the intention then was for the Plough End stand to provide spectator viewing for up to 2300 spectators. The current proposals see a reduction to 1750 although the amount of seating provided in the new Stonebridge Road stand has seen an increase. The club advise that they are designing eventually to have 1% disabled persons seating in line with the Green Guide. The new stand has 8 spaces for wheelchairs and takes the number in the ground to around 20.
6.11 The club advise that the current and revised stadium capacity and breakdown of seating / terrace is as follows:
CURRENT CAPACITY (INCLUDING NEW STAND) NEW MAIN STAND(SEATING) 1016 SWANSCOMBE END (TERRACE) 759 PLOUGH END (SEATING) 534 OLD MAIN STAND (SEATING) 629 MAIN STAND SIDE (TERRACING) 196 CURRENT TOTAL CAPACITY 3134
CAPACITY AFTER PLOUGH END DEVELOPMENT NEW MAIN STAND (SEATING) 1016 SWANSCOMBE END (TERRACE) 759 PLOUGH END (TERRACE) 1750 OLD MAIN STAND (SEATING) 629 MAIN STAND SIDE (TERRACE) 196 TOTAL CAPACITY AFTER PLOUGH END PHASE 4350
6.12 Overall it is not considered that the inclusion of a hotel into Phase 1B of the redevelopment of the ground would in itself be detrimental to the fundamental reason for playing of football at the ground and can be seen as complementary to the facilities being provided elsewhere within the stadium.
6.13 In respect of the hotel element the application is accompanied by a sequential assessment as the application site is an out of town centre location and type of development as a hotel would be considered sequentially on a town centre first basis. The applicant’s sequential assessment concludes:
The hotel and stadium are integrated, with one benefitting from the other and vice versa. This can only be achieved if they are developed together at the site of the stadium development. The hotel is an integral part of the stadium re-development, which aims to provide guest accommodation to assist with the widening of services and facilities at the ground floor level e.g. conferences, social events, community uses and events, sporting activities etc.
The proposed development creates a conference and sporting venue with the added benefit of on-site rooms. Whilst there is a possibility that alternative sites might be suitable for a smaller hotel building, the alternative sites either do not have the scope to provide the associated parking spaces which are required as part of the development or do not have the location specific connection with the stadium. In addition some of the alternative sites are contingent on parking studies and there is uncertainty whether they will form part of a mixed-use development and therefore can be delivered as a standalone component as part of a larger development. In this case the need to be addressed is the location specific nature of the Application Scheme - the link between the stadium and the associated hotel development. The proposed development is appropriate to its proposed location. It cannot be disaggregated and located elsewhere because the synergy between the football club and the hotel would then be lost.
This sequential assessment has concluded that the proposed hotel development cannot be accommodated on town centre or edge of town centre sites.
6.14 Whilst the hotel would be available for use by general members of the public, it is clearly intended to have a functional relationship with other facilities being provided at the new stadium – including the conference facilities being created. Notwithstanding that the Sequential Assessment that has been provided, it is arguable therefore that the proposal is capable of demonstrating particular locational requirements related to the synergy with other facilities to be provided at the new stadium.
6.15 It is therefore considered that in policy terms there is no conflict with policies CS08 and CS09 of the Gravesham Local Plan Core Strategy.
Design and Visual Impact
6.16 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. 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.
6.17 When the previous hybrid application was considered in 2015 it was considered that the general form, shape and profiling appeared to be appropriate to the context and the function of the stadium and the glass exterior would make a very positive contribution to the street scene and local character.
6.18 It is considered that the current new Stonebridge Road stand is already making a positive contribution to the local area and to realise the objective of offering both a first class modern family orientated sporting venue and a community facility and an asset for the residents of the Borough. There have been some negative comments about the internal elevations within the ground due to the block walling and this is currently being reviewed.
6.19 The proposed hotel and stand by reason of its 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 is perhaps even more prominent as it will display effectively a main focal point for the ground and a visually importance entrance with the hotel at the forefront of the ground.
6.20 In design terms there was no planning objection to the draft elevations and visuals provided for the phase 1B (Plough End) improvements in the 2015 scheme. The current proposals are not significantly different in general terms exposing the same form and massing and similar design and materials but perhaps with a more outward facing exterior towards the street than would have been with just a replacement stand. The hotel element will not result in a significant increase in the height of the development from what was previously proposed simply as a replacement stand for the Plough End in this location. The replacement stand only was shown as being up to 10m so the hotel building will be approx. 2.5m higher than shown in the hybrid permission.
6.21 However there are some design matters that have not been fully explained by the applicants including full detail of materials, colour and texture of the rendered panels, whether they are susceptible to staining, the materials for the recessed walling above the entrance to the hotel and at the other similar corner of the building and proposals for dealing with graffiti.
6.22 It will be necessary for good quality hard and soft landscaping and for suitable boundary treatments, which can be the subject of planning conditions. Some of these matters have not been fully explained in the current submission.
Flood Risk
6.23 The Board will note from the extensive policy assessment that the site is within a flood risk area. The policy conclusion is a case could be made for the proposal that would meet local and national policy in relation to flood risk but that various conditions would need to be applied.
6.24 There are also ongoing discussions with the Environment Agency in respect of the location of the development relative to an existing culvert just beyond the eastern boundary of the site and who at present are maintaining an objection to the development.
6.25 In addition a response is awaited from Kent County Council as the Lead Local Flood Authority (LLFA) in relation to sustainable drainage.
Highways and Parking Issues
6.26 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.
6.27 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.
6.28 The current application is supported by a planning statement (with some transport information) and a travel plan which aims to encourage the use of more sustainable modes of transport, reduce unnecessary and unsustainable travel and improves facilities to promote sustainable travel. The travel plan does include an appendix relating to the hotel development but the original hybrid application did include a separate transport statement which has not been provided this time.
6.29 The direct parking provision for the hotel element (25 spaces) clearly does not and cannot meet the adopted parking standards due to the constraints of the site. The Councils adopted parking standards are those set out in the Kent and Medway Structure Plan SPG4: Vehicle Parking Standards (July 2006). These are expressed as maximum standards.
The requirements for Hotels are:
Car Parking: Employees Guests 1 space per 2 staff 1 space per bedroom
Additional provision for guests where bars/restaurants are open to the public would be required at the rate of one third of the appropriate standard for Class A3. Coach/Goods Parking - Adequate space for deliveries; provision for coaches for developments exceeding 20 bedrooms.
6.30 Nevertheless the synergies with the existing ground and the conference facilities being provided and the sustainable location of the site which is served well by public transport connections weigh in its favour. There will have to be controls and management s to ensure that the parking area is managed to prevent indiscriminate parking.
6.31 It should be noted that the area being shown for car parking for the hotel was shown in the hybrid application as providing a parking area for players and board directors such that the access arrangements would have been the same as now proposed albeit less intensively used and operated.
6.32 Although there is no overall objection in highway terms from KCC Highways and Transportation to the development proposals there are some matters that they have sought further information on including in relation to the access road to hotel which should be of sufficient width to allow for two-way traffic, details of safe pedestrian crossing of the access road, more information is required in explanation of how the entrances / exits from the stands are to be managed, details of what the parking arrangements for the hotel are on match days when the car park immediately adjacent to the hotel will be unavailable, and on non-match days should the hotel car park become full, details of coach dropping off / parking an indication of how the hotel is to be serviced and the size of vehicles likely to be used for servicing, detail of the security and weather cover for the two areas shown for cycle parking, travel plan details to be separate form that for the stadium to include information as to how sustainable travel by guests and staff is to be encouraged, target modal shift figures, and a regime of monitoring and a Construction Management Plan covering both the stadium stand and the hotel (including details of materials storage and construction staff parking).
6.33 A full response from the applicants is awaited to these matters.
Environmental Issues
6.34 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.
6.35 However it is not considered that the additional facilities in terms of hotel provision at the ground are likely to result in any additional material impacts that have not already been assessed. Consideration was given to this issue during the assessment of the hybrid planning application. It should be noted that 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. The development does not result in any changes to the recently installed revised floodlighting other than minor re-siting 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. 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.
6.36 There has been some discussion about the impact on hotel patrons from the noise and disturbance when the ground is being used for match days. However from information provided by the club there are several examples of where hotels operate successfully from within football stadiums. The Council’s environmental health officers do not see this as a fundamental concern.
Other Matters
6.37 Archaeological issues were a fundamental consideration in relation to the Phase 1 Stonebridge Road stand and resolution of this and the intrusive investigations that were required to be undertaken did result in a significant delay to the progress in constructing the Stonebridge Road stand 6.38 Currently a response is being sought from KCC Archaeology to the demolition works and groundworks required to build the proposed stand and hotel for the Plough End of the ground.
6.39 The Kent Police Crime Prevention Design Advisor suggests that there should also be discussions in relation to crime prevention measures relating to the hotel.
Neighbour Comments
6.40 The Board will note that notwithstanding the very wide publicity given to the current planning application there have been only very limited neighbour responses/objections albeit that there have been some concern expressed by club supporters but conversely there are also notably letters of support.
6.41 In terms of the objections the applicant’s agent has responded to a number of the points as follows:
There are a number of precedents of football grounds with hotels Football Grounds with On-Site Hotels Bolton Wanderers FC (Macron Stadium - Bolton Whites Hotel & Events); Blackpool FC (Bloomfield Road - Blackpool FC Hotel & Conference Centre); Chelsea FC (Stamford Bridge - Millennium & Copthorne Hotels); Reading FC (Madejski Stadium - Millennium Madejski Hotel); MK Dons FC (Stadium MK - DoubleTree by Hilton Hotel); Coventry FC (Ricoh Arena - DoubleTree by Hilton); AFC Telford (New Bucks Head - Telford Whitehouse Hotel) Football Grounds with Adjacent Hotel Sunderland AFC (Stadium of Light - Hilton Garden Inn); Norwich City FC (Carrow Road - Holiday Inn);
The days of clubs operating for 23 days are over - this is only way small clubs can survive and there are many examples of clubs with hotels. It is difficult to see the functionality of the football ground being compromised, given the 23 days of football activity. The construction would be similar to Phase 1A and spectators will be fully covered. Sight lines have been fully addressed within the design and there will be no intrusive posts or restricted views as at present and it will match the main stand. Gates have risen significantly in the past two years (Community Day – 2,477) and since the new stand opened the atmosphere has significantly improved. The design allows for a greater circulation space on match days away from the road. The current stand is part closed and condemned and the concrete is unstable.
7. Conclusion 7.1 At this stage there are a number of key consultation responses that have not been received. In addition a number of responses to the various key issues and concerns are awaited from the applicants. Progress in these matters will be reported in a supplementary report along with a formal recommendation.
------
Recommendation
A recommendation will be set out in a supplementary report