Representations

Representations to the Pre-Submission Draft 'Central Council Local Plan 2035'

On behalf of Forte Developments and Rugby Football Club

Proposed Relocation to Land off Sundon Road, Luton

February 2018

17521.R02

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Contents

1 Introduction ...... 3

2 Background to Luton Rugby Football Club ...... 5

3 Site Description ...... 9

4 The Proposal ...... 11

5 Representations ...... 13

6 Summary and Conclusion ...... 18

Appendices

1 Site Location Plan and Proposals

© Kirkby Diamond 2018

All Rights Reserved. No part of this report or any of its contents may be reproduced, copied, modified or adapted, without the prior written consent of the author, unless otherwise indicated for stand-alone materials.

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1 Introduction

The following representations have been prepared on behalf of Forte Developments in relation to their proposals to help relocate Luton Rugby Football Club. The Club is seeking to redevelop their existing grounds at Newlands Road and to relocate elsewhere. Land off Sundon Road has been identified to accommodate a new facility. The development will provide both improved facilities and most critically, ensure the continued viability and financial stability of the Club.

1.1 Forte Developments have been appointed by Luton Rugby Football Club Limited to take their relocations proposals forward. The Club is in financial difficulties and to sustain its continued operation, it is intended to redevelop their existing grounds at Newlands Park in Luton, for residential purposes.

1.2 The relocation of the Club has been considered for many years, but it has been difficult to identify an alternative location for the Club that would both meet their needs, and be affordable. Although the proposals remain at an early stage, a potential site has now been identified that might accommodate the Club's relocation. The site lies a short distance to the north of Luton, off Sundon Road. Details of the site and indicative proposals are provided within our representations.

1.3 The site at Sundon Road falls under the administrative area of Central Bedfordshire Council and is immediately to the north of the identified 'North of Luton' expansion area. Accordingly, the replacement facility would not only serve the existing members of the Club (which come from both Luton and Central Bedfordshire), but also the future residents within the strategic allocation. Aside from the immediate needs of Luton Rugby Football Club to secure its future, there is a recognised need for additional rugby provision to meet the needs of Central Bedfordshire. This is set out in the Council's evidence base.

1.4 As well as meeting the needs of the Club, it will also provide the opportunity for other community sports uses in order to provide a significantly wider benefit. For example, the inclusion of high quality pitches will allow their use for other sports, and the facilities within the club house (gym, treatment rooms, bar etc) may also be used more widely.

Page 3 of 21 1.5 It is recognised that the site is within the Green Belt. However, it is considered that the provision of high quality sports and recreational facilities would be consistent with the objectives of the Green Belt and the purposes of including land within it.

1.6 In this context, the representations to the emerging 'Central Bedfordshire Council Local Plan 2035' by Forte Developments concern the following policies:

• Policy SA1 'North of Luton'; • Policy EE13 'Outdoor Sport, Leisure and Open Space'; and • Policy SP4 'Development in the Green Belt'.

1.7 In brief, they seek to promote the delivery a new facility for Luton Rugby Football Club off Sundon Road. The nature and scope of our representations is set out in the following report. Before doing so however, we briefly outline the background to the proposals for Luton Rugby Football Club.

1.8 Due to the timescales involved in the project and the relatively recent identification of the site off Sundon Road, representations have not previously been made to the emerging Central Bedfordshire local plan, though they have been the subject of initial discussions with the Local Planning Authority. 1 Nevertheless, it is suggested that the emerging plan should be amended to accommodate the requirements of the club given the significant community benefits that it would deliver.

1 Application Reference CB/17/04495/PAPC

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2 Background to Luton Rugby Football Club

2.1 Luton Rugby Football Club was formally established in 1930 by a group of local rugby enthusiasts. At that time, the Club had no facilities of its own but played matches in Farley Hill. The Club based itself in various public houses within Luton. Nevertheless, it was very successful until it was held in abeyance during the Second World War. The Club later reformed, but still had no premises or grounds of its own. Home matches were then played in .

2.2 It was not until 1960 that the Club was able to acquire the freehold of a site at Wood Meadow, Farley Hill through the donations of Club Members. This provided them with two pitches and a clubhouse and served the Club well. However, the pitches at Wood Meadow became compacted with clay making them difficult to use. It had also become clear that even the investment of a huge amount of money (which the Club did not possess), would not improve them sufficiently.

2.3 Accordingly, the grounds at Farley Hill were sold in 1987 for development purposes and the Club relocated to Newlands Road, where they remain. The facility at Newlands was officially opened in 1988. This allowed the Club to expand, including the formation of new youth teams. The Club now has more than 250 children aged 6 and over that are registered to play. Luton Rugby Football Club fields a total of sixteen teams on a regular basis, and also provides coaching support for many local schools. Many of the players come from the areas surrounding Luton, including Central Bedfordshire.

2.4 The Club is a large organisation, managed by volunteers. Historically, it has relied upon income from bar sales, club events and the rental of the function room. However, this has become increasing difficult to sustain. The existing facilities are now in poor condition; the function room was built in the 1980's and needs extensive refurbishment. There is also considerable competition for function rooms and venues within Luton. Similarly, bar sales have reduced dramatically over recent years.

Page 5 of 21 2.5 Consequently, the Club is now in a position where it does not have enough income to cover its liabilities. Its continued existence is wholly reliant upon donations and this is unsustainable. It is therefore critical that funding is found to bridge the increasing financial gap. While the Club has tried to borrow money from banks, it is unable to do so, as it would be unable to service any loan or secure it against assets of sufficient value

2.6 The relocation proposals would first provide the Club with a new facility, and one that does not carry a significant maintenance liability. Second, it would deliver a critical injection of capital that may be used to fund the Club to ensure its survival.

Existing Grounds at Newlands Road, Luton

2.7 The existing grounds at Newlands Road are approximately 8.28 hectares in size. The site is located approximately two miles to the southwest of Luton town centre. The site is linear in form, extending between Newlands Road (which forms the site's eastern boundary) and M1 Motorway to the west.

2.8 The Club currently contains two main pitches, together with three training pitches. It also accommodates a clubhouse that includes changing facilities, bar and restaurant and offices. In addition, there is a multipurpose hall that is used to host private functions. These facilities were built in the 1980's and are in poor condition, requiring extensive refurbishment.

2.9 A footpath bisects the site into two parcels. The clubhouse and the main pitches are located on the southern half. There is a vehicular access off Newlands Road here, which serves the clubhouse with parking provision distributed around the building. The training pitches are on the northern half, which is largely open.

2.10 The site is well located in relation to existing transport infrastructure. In terms of public transport, two routes currently run along Newlands Road; Service 46 links Luton to Hemel Hempstead via Slip End on an hourly schedule; and Service 231 runs between Luton and , via Slip End and Caddington at hourly intervals. Within walking distance from the site, a further two services provide regular access to Luton town centre.

Page 6 of 21 The Proposals at Newlands Road

2.11 It is proposed that the Club's existing premises be redeveloped for residential purposes. Initial plans have been prepared which show that the Club's existing grounds could accommodate approximately 850 apartments including a mix of one, two and three bedroom units. The sale of the land would fund the club's relocation and leave a residual sum of money to ensure their continued future. This is critical to the club's ongoing survival and financial stability.

2.12 While the development is in the early stages, indicative proposals have been prepared. These have evolved through an analysis of the constraints and opportunities affecting the site and indicate the following key elements:

• A net developable area of 4.58 hectares; • The provision of approximately 858 apartments with a total of 60,828sqm floorspace; • A scheme including a high proportion of two and three bedroom apartments; • A series of buildings ranging from four to six storeys with undercroft parking beneath; • A landscape buffer along the site's western boundary adjacent to the motorway; • The inclusion of open space and landscaping between buildings; and • Primary access points off Newlands Road.

2.13 Further information has previously been provided to the Council on these proposals.2

2.14 It is considered that the principle of residential development on the site is acceptable. This was considered in brief during the examination of 's emerging Local Plan and the Inspector commented on the potential of the site when reviewing housing sites suggested by landowners and developers. The Inspector commented that:3

" … Land alongside the M1 motorway is currently used by Luton Rugby Club and comprises sports pitches and ancillary buildings and parking. Given this use, and having regard to Paragraph 74 of the Framework, the site is not a clear cut opportunity for a residential allocation. Instead, any housing proposal could reasonably be considered through the development management process, having regard to relevant policies in the Plan and any material considerations. This could for example, include consideration of the merits of developing the site to assist the relocation of the rugby club and any overall need for playing fields and open space, as appropriate. However, these are not matters which I need to conclude on here … "

2.15 Accordingly, the Inspector concluded that there was no need to allocate the land for residential development, and that it could instead be delivered through the determination of a planning application. The Inspector made specific reference to the provisions within the National Planning Policy Framework concerning the development of existing sports and recreational buildings. This suggests that such land should not be built upon unless it is surplus to requirements, or:4

" … The loss resulting from the proposed development would be replaced by equivalent or better provision in terms of quantity and quality in a suitable location … "

2.16 In this case, the development would not result in the loss of any sports or community facility. Indeed, it would specifically facilitate the Club's relation and directly enhance the level of sports provision, ensuring the survival of Luton Rugby Football Club. Accordingly, the proposal satisfies the provisions of the Framework concerning the development of existing sports fields.

2 Application Reference CB/17/04495/PAPC 3 'Report on the Examination of the Luton Local Plan' 1 August 2017 §121 4 'National Planning Policy Framework 2012 §74

Page 7 of 21 2.17 The Local Plan Inspector considered the need for additional housing provision and the supply of land within the Borough in detail. In brief, the Inspector found that there was a need for 17,800 new dwellings within Luton over the plan period.5 It was concluded however, that there was only sufficient capacity to accommodate approximately 8,500 dwellings within Luton.6 Accordingly, there is an unmet need of some 9,300 dwellings, which is to be met elsewhere within neighbouring authorities, including Central Bedfordshire. However, the Inspector explicitly noted that the requirement of 8,500 was not intended to be a ceiling, and that it is not seen or applied as a constraint to delivery; this was specifically reflected in modifications to the plan to enable development proposals to come forward on non-allocations sites where they comply with policies within the plan.7

2.18 In this context, the development of the site at Newlands would make a significant contribution towards meeting the unmet need for new dwellings in Luton. Indeed, it could potentially satisfy 9% of the identified shortfall. This in turn may reduce the extent of housing land needed within neighbouring authorities such as Central Bedfordshire.

5 'Report on the Examination of the Luton Local Plan' 1 August 2017 §96 6 'Report on the Examination of the Luton Local Plan' 1 August 2017 §134 7 'Report on the Examination of the Luton Local Plan' 1 August 2017 §135

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3 Site Description

Land off Sundon Road

3.1 Luton Rugby Football Club has long held aspirations to relocate, as discussed above. However, it has proved difficult to find a site that is of sufficient size to meet their needs, yet also affordable.8 Given the tightly defined boundary around Luton's urban area and the shortage of land within in, it is clear that no sites are available within Luton's administrative area.

3.2 Accordingly, the search has been extended to the areas adjoining Luton where they will continue to serve the club members (who come not only from Luton but also from the wider surrounding area including Central Bedfordshire). It will also be noted that the majority of land surrounding Luton's urban area is all within the Green Belt, and much of it is subject to other landscape designations.

3.3 A potential site has now been identified to the north of Sundon Road, in the vicinity of its junction with Road. A site location plan is included at Appendix One. The site is approximately 5 miles to the north of Luton town centre and less than a mile to the south of Sundon. The land falls just outside the administrative area of Luton, and is within the boundary of Central Bedfordshire Council.

3.4 The site is approximately 8 hectares in size and is currently used for arable purposes. Vehicular access is currently gained in the southwest corner, off Sundon Road. There is a second access off Church Road in the northeast corner of the site.

8 A minimum area of 8 hectares is required to accommodate the required pitches, parking and club building etc

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The Surrounding Area

3.5 The surrounding area is largely open countryside. The Church of St Mary lies to the east, and a small area of adjoining land provides car parking for the church. The Church of St Mary is a Grade I listed building.

3.6 The site is immediately to the north of the Strategic Land Allocation referred to as 'North of Luton'.9 In brief, the allocation proposes around 4,000 new homes together with 20 hectares of employment land. The growth location will include new community provisions and infrastructure.

3.7 A new strategic road will link the A6 with the M1 Motorway. Other improvements would be made to public transport including a potential link with the busway to enhance connections to station and Luton town centre. The allocation involves the removal of land from the Green Belt. A portion of the Growth Location is also within the Chilterns Area of Outstanding Natural Beauty.

3.8 A short distance to the west, land is allocated to provide for the purposes of the Sundon Freight Interchange.10 This allocation will provide a rail facility extending to approximately 5 hectares, together with 40 hectares of employment land. The development will use the planned strategic link road between Sundon Park Road and Junction 11a of the M1 Motorway.

3.9 Having regard to the emerging allocations, it is evident that the surrounding area will change significantly in the future, and that the site identified by the Club has the potential to serve the expansion area and help to meet the needs of the future community.

9 Pre-Submission Draft 'Central Bedfordshire Council Local Plan 2035' 2018 Policy SA1 10 Pre-Submission Draft 'Central Bedfordshire Council Local Plan 2035' 2018 Policy SE1

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4 The Proposal

The sale of the grounds at Newlands would enable Luton Rugby Football Club to relocate to the site at Sundon Road, where a new and significantly enhanced facility would be provided. Indicative plans have been prepared to show the potential extent of the proposals.

4.1 The site at Sundon Road is similar in size to the Club's existing grounds. It is proposed that the site would accommodate a new clubhouse together with three full size pitches. In summary, the proposals would include the following:

• A clubhouse; • Two full-size, artificial pitches (3G pitches); • One, full-sized grass pitch; • Two half-sized pitches for the Under 12's; • Two quarter-sized pitches for the Under 10’s; • A training area, based on one half of a full sized pitch; • Car parking for approximately 350 spaces including disabled spaces (approximately 5%); • Parking for up to six coaches, with turning for potential use by bus operators; and • Overflow parking area for a potential additional 30 to 50 cars.

4.2 The clubhouse would be the centrepiece of the scheme and stands at the heart of the pitches. It sits immediately between the two full size, artificial pitches, which could be viewed from the clubhouse building both at lower terrace level or the upper terrace level at first floor. The third full size pitch can also be viewed from the clubhouse to the north offering a range of views as well as a high level of surveillance of the site.

4.3 Initial sketches have been prepared to identify the size of the proposed clubhouse. These are included at Appendix One. A single, two storey building is proposed with a footprint of 920 sqm. The plans show that at ground floor level, the proposed building would include a series changing rooms and toilets for the various teams, together with space for storage, operational and administrative functions. There would also be a gym, physiotherapy rooms and a small club shop.

Page 11 of 21 4.4 At first floor level, the building would include a bar and associated kitchen along the western elevation, and a community room on the eastern elevation. There would be viewing balconies on either side of the building, overlooking the two principal pitches. The first floor would also include offices and a clubroom for members. A two bedroom flat is provided for the ground staff and to provide security.

4.5 A new vehicular access would be provided off Sundon Road on the site's southern boundary. This would lead to an area of car and coach parking. Access from Sundon Road allows any traffic arriving from Luton to turn left onto Sundon Road and avoid having to travel through the settlement of Lower Sundon. The access is sited west of the existing junction to prevent traffic backing up and interfering with the junction at Sundon Park Road.

4.6 The layout focuses built development closer to the road frontage, whereas the remainder of the site would be predominantly open. This ensures that any impact on the openness of the Green Belt is minimised. All the pitches are set away from the site perimeter to allow for screen planting to be introduced to define the site, provide some visual buffering, particularly to the adjacent settlement, and also some security from the surrounding open countryside.

4.7 It is anticipated that the area under the car parking can be used for any storm water storage and attenuation to serve the site, as the site falls towards the southern boundary and this would provide for the most natural location for any surface water attenuation.

4.8 The proposed facility offers the scope to accommodate other community uses. In particular, the 3G sports pitches may be able to host other activities when they are not in use by the club. Similarly, facilities in the clubhouse may be open for the wider benefit of the community.

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5 Representations

Representations to Policy SA1 'North of Luton'

5.1 Policy SA1 'North of Luton' makes provision for a Strategic Land Allocation to the north of Luton. The allocation is intended to provide a sustainable urban extension to Luton that will include a mix of uses. The allocation is expected to deliver some 4,000 new homes, together with a mix of 20 hectares of employment land.

5.2 Amongst other things, the allocation makes provision for a 'health and social care hub', retail and educational facilities, and leisure uses.11 Insofar as the proposed leisure facilities are concerned, these are to include:12

• Indoor sport and leisure facilities; and • Outdoor sport, leisure and open space, including pavilions and allotments.

5.3 Some further clarification on the scope of outdoor sport provision can be found within the Council's 'Infrastructure Delivery Plan'.13 This suggests the inclusion of football pitches together with a sports pavilion, but makes no provision for any other outdoor sports facilities: of particular relevance, it makes no provision for rugby pitches. Moreover, the proposed infrastructure is not expected to be delivered until 2023 to 2035.

5.4 The demand for rugby facilities has been considered within the Council's evidence base and specifically within the 'Leisure Facilities Strategy' 2017.14 This considers the extent of existing provision within Central Bedfordshire and the needs of the four existing teams within its administrative area. 15 However, it did not have regard to needs of rugby clubs within the

11 Pre-Submission Draft 'Central Bedfordshire Council Local Plan 2035' 2018 Policy SA1 12 Pre-Submission Draft 'Central Bedfordshire Council Local Plan 2035' 2018 Policy SA1(1)(f) 13 'Infrastructure Delivery Plan' 2018 'Appendix A: Infrastructure Schedule for North Luton' 14 Leisure Facilities Strategy' 2017 Chapter Three 'Playing Pitch Strategy' 15 Ampthill RFU, Biggleswade RFU, Dunstablians RFU, Leighton Buzzard RFU

Page 13 of 21 neighbouring authorities, including those of Luton Rugby Football Club. Notwithstanding, it concluded that insofar as the adequacy of pitch provision for the future was concerned:16

" … the amount of activity at club sites, particularly at peak times, means that clubs are approaching capacity. The additional teams that will be generated through population growth will be spread across Central Bedfordshire and will generate a small additional impact at club bases.

Analysis indicates that the existing pitches at rugby clubs will be sufficient to meet current and projected needs assuming that pitches are well maintained and able to sustain appropriate numbers of matches. All pitches are however already close to capacity meaning that significant increases in participation above and beyond those highlighted above as generated from population growth may mean that additional facilities are required … "

5.5 It further commented that:

" … When taking into account the additional training requirements that further teams will generate, it is clear that clubs will be reaching capacity … but it should be noted that this includes expressed growth only (i.e. not growth likely to occur as a result of population increases).

Concentration of growth generated from population projections at one of the rugby clubs (and / or significant growth in cub membership) may therefore generate capacity issues at specific clubs. This could be addressed through further grass pitch or 3G provision … "

5.6 Taking account of the above, the Council's evidence base clearly shows that the existing rugby clubs (excluding the needs of Luton) are reaching capacity and that concentrations of population are expected to generate capacity issues that might be addressed through further provisions.

5.7 The extent of growth arising from the Strategic Land Allocation to the north of Luton clearly represents such a 'concentration' of population. However, it is remote from existing rugby facilities in Central Bedfordshire, and the provisions in Policy SA1 'North of Luton' do not identify any specific provision for rugby pitches to accommodate the identified demand.

5.8 In this context, it is suggested that the potential relocation of Luton Rugby Club to land off Sundon Road would be well placed to meet the identified need and anticipated demand for additional pitches arising from the population growth. Moreover, while the allocation appears only to make provision for football pitches, the facility proposed on behalf of Luton Rugby Football Club could also accommodate other community uses that would benefit the future residents. Furthermore, the development would ensure the continued future of Luton Rugby Football Club, thus ensuring that the needs of existing members in Luton are also met.

5.9 In conclusion, the provisions of Policy SA1 'North of Luton' are not 'positively prepared'. Although the Council's evidence base identifies a need for additional rugby provision arising from population growth, the plan fails to make provision for this. Accordingly, the plan does not meet the objectively assessed needs and infrastructure requirements in this respect. Furthermore, it does not take account of the unmet needs from neighbouring authorities. On this basis, the policy is unsound.

5.10 It is suggested that the allocation of land off Sundon Road to provide a replacement rugby club would both meet the needs of both Central Bedfordshire Council and those of Luton Rugby Club.

16 Leisure Facilities Strategy' 2017 Chapter Three 'Playing Pitch Strategy' §10.64

Page 14 of 21 Representations to Policy EE13 'Outdoor Sport, Leisure and Open Space'

5.11 When referring to open space and sports provision, the allocation under Policy SA1 'North of Luton' makes reference to:17

" … outdoor sport, leisure and open space in accordance with Policies EE12 [sic] including sports pavilions and allotments … "

5.12 We would first note that the reference to Policy EE12 is incorrect, as this policy refers to 'Public Rights of Way': it is assumed that the correct reference is to Policy EE13 'Outdoor Sport, Leisure and Open Space'.

5.13 Policy EE13 'Outdoor Sport, Leisure and Open Space' seeks to protect existing facilities in the first instance and to mitigate against their loss. Further, it aims to make provision for delivery of new outdoor facilities on new residential developments. In doing so, the supporting text makes reference to the Council's 'Playing Pitch Strategy', which we have discussed above in our comments on Policy SA1 'North of Luton'. In brief, the assessment shows that existing rugby clubs within Central Bedfordshire are already close to capacity, and that additional facilities will be required to meet the needs generated from population growth.18

5.14 In this context, the National Planning Policy Framework recognises that the planning system can play an important role in facilitating social interaction and creating healthy, inclusive communities.19 To deliver the social, recreational and cultural facilities and services the community needs, planning policies and decisions should:20

" … plan positively for the provision and use of shared space, community facilities (such as … sports venues …) and other local services … "

5.15 Furthermore:21

" … Access to high quality open spaces and opportunities for sport and recreation can make an important contribution to the health and well-being of communities. Planning Policies should be based on robust and up to date assessments of the needs for open space, sports and recreation facilities and opportunities for new provision. The assessments should identify specific needs and quantitative or qualitative deficits or surpluses of open space, sports and recreation facilities in the local area. Information gained from the assessments should be used to determined what open space, sports and recreational provision is required … "

5.16 For the reasons outlined above, it is contented that the Provisions of Policy EE13 'Outdoor Sport, Leisure and Open Space' together with Policy SA1 'North of Luton' are 'unsound', as they fail to make adequate provision for rugby pitches to meet the identified demand. On this basis, the policies have not been 'positively prepared'.

5.17 It is suggested that the land off Sundon Road be allocated to meet the identified need, and to serve both existing residents of Luton and Central Bedfordshire who currently use Luton Rugby Football Club, as well as the future residents of the expansion area.

17 Pre-Submission Draft 'Central Bedfordshire Council Local Plan 2035' 2018 Policy SA1(1)(f) 18 Leisure Facilities Strategy' 2017 Chapter Three 'Playing Pitch Strategy' §10.64 19 'National Planning Policy Framework 2012 §69 20 'National Planning Policy Framework 2012 §70 21 'National Planning Policy Framework 2012 §73

Page 15 of 21 5.18 The supporting text to Policy EE13 'Outdoor Sport, Leisure and Open Space' considers the location of new facilities. It is considered that the proposed allocation off Sundon Road complies with these requirements. Firstly, the supporting text states that:22

" … New sports facilities are to be sited in accessible locations to encourage use but away from residential properties to minimise disturbance to residents. New pitches are to be supported by changing and pavilion facilities, car parking and other ancillary facilities in accordance with the respective NGB requirements and local circumstances … "

5.19 The initial proposals presented on behalf of Luton Rugby Football Club off Sundon Road are clearly consistent with this objective. Given the enhancements to accessibility proposed as part of the North of Luton Strategic Land Allocation, including the proposed link road as well as improvements to cycle paths and pedestrian routs etc, the site will occupy an extremely accessible location. Equally, it will be away from residential properties where it will not cause disturbance.

5.20 The supporting text goes on to require that:23

" … Where possible all new sports facilities will be sited in locations which allow the facility to expand as the club grows and or to accommodate additional demand from further housing growth …

5.21 Again, the site at Sundon Road is able to comply with this requirement, as there is scope to expand on to adjacent land to the east and northeast, which is also under the control of Forte Developments.

5.22 On this basis, the proposals at Sundon Road are able to comply with the requirements of Policy EE13 'Outdoor Sport, Leisure and Open Space' and its allocation for the relocation of Luton Rugby Football Club would be consistent with its aims and objectives.

Representations to Policy SP4 'Development in the Green Belt'

5.23 It is recognised that the proposed allocation off Sundon Road currently lies within the Green Belt. However, the proposed allocation for sports provision is not inconsistent with the policies concerning the protection of the Green Belt.

5.24 The National Planning Policy Framework seeks to retain the openness of the Green Belt, and the purposes of including land within it. It states that once Green Belts have been defined, local planning authorities should: 24

" … plan positively to enhance its beneficial use, such as looking for opportunities to provide new access; to provide opportunities for outdoor sport and recreation … "

5.25 This objective is consistent with the other aims expressed within the Framework, which recognise that the planning system can play an important role in facilitating social interaction and creating healthy, inclusive communities, and that to deliver the social, recreational and cultural facilities and services the community needs, planning policies and decisions should plan positively for the provision and use of shared space, community facilities such as sports venue and other local services.25 In this respect, the proposed allocation of land off Sundon Road wholly complies with the principles of including the land within the Green Belt and the objectives of enhancing opportunities for access.

22 Pre-Submission Draft 'Central Bedfordshire Council Local Plan 2035' 2018 §15.14.21 23 Pre-Submission Draft 'Central Bedfordshire Council Local Plan 2035' 2018 §15.14.22 24 'National Planning Policy Framework 2012 §81 25 'National Planning Policy Framework 2012 §69 and §70

Page 16 of 21 5.26 Similarly, while new development in the Green Belt is controlled and new buildings should be regarded as 'inappropriate', the Framework identifies specific exceptions, including:26

" … Provision of appropriate facilities for outdoor sport and outdoor recreation … so long as it preserves the openness of the Green Belt and does not conflict with the purposes of including land within it … "

5.27 Accordingly, national planning policy accepts that the Green Belt provides an appropriate location for new outdoor sports and recreation. The proposed development is wholly consistent with this.

5.28 The development would also respect the purposes of including land within the Green Belt.27 In particular, we would note that:

• The proposal would not amount to unrestricted sprawl; • It would not result in the merger of neighbouring towns; • It would not amount to encroachment into the countryside; and • It would not affect the setting and special character of any historic town.

5.29 Finally, we would also note that the character of this area and the surrounding landscape is likely to change considerably in the future given the proposals under both SA1 'North of Luton' and the allocation of land to the west for the purposes of the Sundon Freight Interchange together with a substantial area of employment provision.28

5.30 To an extent, the provisions of Policy SP4 'Development in the Green Belt' are consistent with the Framework: it states that the Council will work proactively with developers and landowners to enhance the beneficial uses of the Green Belt. However, given the failure to make adequate provision for leisure needs and specifically those related to rugby (as set out above), it is contended that Policy SP4 'Development in the Green Belt' should explicitly encourage such uses and make appropriate provision.

5.31 As noted at the outset, there is no opportunity for Luton Rugby Football Club to find alternative land of the size needed within the confines of Luton's administrative area, and the land surrounding the urban area (largely falling within Central Bedfordshire) is within the Green Belt. As such, the only means of achieving the continued viability of Luton Rugby Football Club is though the use of land within the Green Belt. On this basis, Policy SP4 'Development in the Green Belt' is 'unsound' and no positively prepared, as it could present an unnecessarily restrictive approach that will prevent the Council from meeting its identified needs.

26 'National Planning Policy Framework 2012 §89 27 'National Planning Policy Framework 2012 §80 28 Pre-Submission Draft 'Central Bedfordshire Council Local Plan 2035' 2018 Policy SE1

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6 Summary and Conclusion

6.1 Luton Rugby Football Club Limited has appointed Forte Developments to take forward proposals for their relocation. The primary purpose of the project is to provide the Club with new facilities and to secure its future and financial stability. The Club has been in financial difficulty for a number of years and the project is critical to its survival. The proposal involves the redevelopment of the Club's existing grounds at Newlands Road. It would provide a substantial injection of capital that would not only fund the relocation of the Club, but would also leave a residual fund that may be used to sustain it.

6.2 It has been difficult to find appropriate land to accommodate the club. However, it is proposed that the Club would relocate to land off Sundon Road, a short distance to the north of Luton. This site provides an ideal opportunity for the Club, being of a suitable size to meet its needs, and accessible to its members and supporters. The proposals here will provide a new clubhouse alongside three full size pitches and a range of smaller pitches for its youth teams and training functions. The site falls under the administrative area of Central Bedfordshire Council, and would also serve the future community in the planned expansion to the north of Luton.

6.3 On behalf of Forte Developments, representations are made to the emerging 'Central Bedfordshire Council Local Plan 2035' in respect of the following policies:

• Policy SA1 'North of Luton'; • Policy EE13 'Outdoor Sport, Leisure and Open Space'; and • Policy SP4 'Development in the Green Belt'.

Page 18 of 21 6.4 It is suggested that the policies are 'unsound' and that they have not been 'positively prepared' on the basis that:

• The Council's evidence base recognises that a need exists for additional rugby provision. Existing clubs within Central Bedfordshire are at capacity, and more pitches will be needed to meet needs arising from concentrations of population growth; • The Council's assessment of the need for additional rugby provision takes account only of the needs arising within Central Bedfordshire, and not those within neighbouring authorities, as it is required to do so under the Framework; • Although a need is identified, the plan fails to make provision. In particular, while additional demand is expected to arise as a result of concentrations of population growth, the proposed allocation north of Luton makes no provision for sports other than football; and • While outdoor sports and recreational facilities are consistent with Green Belt objectives, the Council's policy fails to plan positively to enhance its beneficial use, such as looking for opportunities to provide new access and opportunities for outdoor sport and recreation.

6.5 Taking account of the above, it is requested that the policies be amended, and that land off Sundon Road should be allocated for the provision of a new rugby and community sports facility. It is concluded that:

• The proposed relocation of Luton Rugby Football Club would ensure its continued survival and that the land off Sundon Road would meet its needs; • The facility would ensure not only that the needs of existing users (which include many from Central Bedfordshire) are served, but also that the needs of future residents are met; • The proposed location is consistent with the Council's requirements and in particular, it would offer an highly accessible location alongside the urban expansion to the north of Luton; • Although accessible, the proposed location would be separate from the main body of residential development and would not cause disturbance; • The location allows scope for future expansion to ensure that it can meet additional needs arising from the north of Luton expansion; and • The proposed development is consistent with the Government's aims and objectives concerning development within the Green Belt.

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