SUPPORTING PLANNING STATEMENT
MARCH 2018
NEW DISABLED SEATING AND ASSOCIATED ACILLARY FACILITIES AT TURF MOOR STADIUM
on behalf of: The Burnley Football and Athletic Co. Ltd. Table of Contents
1. INTRODUCTION ...... 3 2. DEVELOPMENT CONTEXT ...... 5 3. ACCESSIBLE STADIA GUIDE ...... 10 4. DESCRIPTION OF PROPOSED DEVELOPMENT ...... 13 5. PLANNING POLICY ...... 18 6. PLANNING ASSESSMENT ...... 27 7. SUMMARY AND CONCLUSIONS ...... 31
Appendix A ...... Site Location Plan
Appendix B ...... Proposed Site Plan Planning Statement Burnley Football Club, Burnley
1. INTRODUCTION
1.1 This Planning Statement has been prepared on behalf of The Burnley Football and Atheletic Co. Ltd. It accompanies a Full Planning Application for demolition of existing Stadium Control Box building and erection of 2 new corner stands (Use Class D2) to provide additional disability seating with ancillary facilities, lighting and associated advertisement consent application. Ancillary facilities include concession stands, toilets, accessible lift, changing places facility, store rooms, sensory room, under pitch heating boiler room, new Stadium Control Box, ticket office queuing space and new replacement Big Screen TV. The application concerns a site at Turf Moor Stadium, Harry Potts Way, Burnley, BB10 4BX.
1.2 This Statement describes the extent of the proposals and the planning issues which they raise. It should be read in conjunction with the series of detailed technical reports that also accompany the application.
1.3 In promoting the proposed use our client appreciates that due regard must be given to a number of relevant up-to-date policy considerations as well as other material planning considerations. In developing these proposals, full regard has been given to the provision of Section 38(6) of the Planning and Compulsory Purchase Act 2004.
1.4 The general approach to, and content of, this application has been discussed with Senior Officers of Burnley Borough Council (BBC), prior to its submission a Pre- Application meeting was held on 12th January 2018. These discussions have influenced the evolution of the scheme into its final form and the supporting information accompanying the application.
1.5 Our pre-application dialogue has enabled us to settle the list of documents which accompany this application. These include:
• Design & Access Statement (DAS), prepared by Wilson Owens Owens; • Planning Statement, prepared by Zerum; • Coal Mining Assessment, prepared by Paul Waite Associates; and • Phase 1 Ground Conditions Report, prepared by with Paul Waite Associates.
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1.6 The application is also supported by a full set of plans and elevations, prepared by the scheme architects, Wilson Owens Owens.
1.7 Due to the existing use and scale of works proposed the following planning considerations are dealt with as part of the Design and Access Statement:
• Crime Impact • Refuse and Recycling • Site Waste Management • Lighting Strategy
1.8 The remainder of this statement:
• Provides context and describes the applicant, site and its surroundings; • Describes the development proposals; • Outlines the Development Plan framework and relevant national policy guidance; • Provides a detailed analysis of the main planning considerations; and • Concludes by summarising the main points raised in this document which we consider support a grant of planning permission.
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2. DEVELOPMENT CONTEXT
2.1 This section briefly describes the applicant, the site, its surroundings and local setting, and outlines the relevant planning history of the site.
THE CLUB
2.2 Burnley Football Club was formed in 1882 and was one of the founding members of the football league in 1888. Nicknamed the Clarets due to the dominant colour of their kit; Burnley has had success across the football leagues and associated trophies. In more recent years Burnley earned a place in the top flight of English football, the Premier League, after a 33-year absence. Turf Moor has always been the home ground for Burnley Football Club, since it was built in 1883, and currently has a capacity of 21,401.
2.3 In 2015 all Premier League clubs pledged to meet the guidance for accessible stadia set out under the Accessible Stadia Guide (ASG) by August 2017. This was in order to better represent the needs of fans and bring current stadiums up to an acceptable standard. A January 2017 Ministerial Report titled ‘Accessibility of Sport Stadia’ highlighted that there would be ability to take legal actions against the Football League and clubs if the required changes where not implemented. It is worth noting that recently promoted clubs Watford, Burnley and Middlesbrough were given an deadline of August 2018 to meet the ASG guidance, by the Premier League.
2.4 The standards this proposal aims to meet are those set out in the Accessible Stadia Guide as published by the Football Stadia Improvement Fund and Football Licencing Authority (now the Sports Ground Safety Authority – SGSA). This document represents a good practice guide to the design of facilities to meet the needs of disabled spectators and other users. The document was contributed to by a working group which included high profile organisations and agencies operating within the world of sport, especially football, including: The Football Association (FA), The Football League (FL), FA Premier League (FAPL), Sport England (SE), The National Association of Disability Supporters (NADS), Football Stadia Improvement Fund (FSIF) and The Football Licencing Authority (FLA).
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SITE DESCRIPTION
2.5 The Application site comprises an area of approximately 732m2. To aid identification a location plan with the development site boundary shown edged in red is appended (Appendix A).
2.6 The sites of the proposed developments are at the north-east and south-east corners of the exiting Turf Moor Stands. Figure 2.1 below highlights the proposed locations of the new stands and associated developments. The south-eastern corner (Marked A below) currently houses the existing stadium control room and various mechanical equipment; on match days a marquee operates as temporary ticket office queuing area. This site is located between the Bob Lord Stand and the Jimmy McIlroy Stand.
2.7 The north-east location is currently hard standing which on match days has a temporary marque with a bar for fans. It is also currently used for pitch side access for maintenance vehicles (pitch lights and cherry pickers) as well as disabled access to the existing disabled seating. This site is at the corner of the James Hargreaves Stand and the Jimmy McIlroy Stand (Marked B below).
B
A
Figure 2.1 2.8 To the south of the site is Harry Potts Way which, leads to Burnley’s town centre. On the other side of Harry Potts Way and adjacent to the site is residential housing
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separated from the road and stadium with fencing. Directly west of the site is Burnley Cricket Club one of the founding teams in the Lancashire League Cricket. Directly East and North of the stands are matchday parking facilities beyond which is residential dwellings and some smaller grassed areas.
2.9 The existing stand at Turf Moor has undergone continuous improvements since its first use in 1883. Most of these improvements have reflected the increase in popularity of the Club as they were promoted through the leagues. A number of recent additions and alterations have helped bring the stadium to a more acceptable standard. A proposed stadium extension was planned in 2007 with the multi stage expansion plans, costing £20 million. Progress of these plans was halted as a result of the 2008 financial crisis. Since then there have been no new plans for development of a similar scale. More recent changes, on a smaller scale, have included the opening of a new club store in 2016, fronting Harry Potts Way.
SITE ACCESSIBILITY
2.10 The location of the proposed development is on the existing hard standing in between stands at Turf Moor. North and East of the stands is currently allocated car parking which is used primarily on matchdays by traveling fans. The site is accessible by car from Harry Potts Way bordering the development site to the south. There is disabled parking on site which is conveniently located next to the proposed north east corner development so as to enable ease of access for those less able.
2.11 The site is currently bordered to the south by an existing cycle network that also travels along the western boundary of the adjoining cricket ground. The site is considered accessible by cycle.
2.12 The main town centre is a 15-minute walk west of the site where the main train station is located. There are clear pedestrian links and signage directing fans to and from the ground on match days.
2.13 The main bus station is a 5-minute walk away, off Centenary way. There are also bus stops around the ground and outside the main entrance to the ground on Harry Potts Way.
2.14 On a match day, Harry Potts Way closes 2 hours before kick-off and reopens 30 minutes after the final whistle.
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PLANNING HISTORY
2.15 A review of previous applications on the site reveals the following planning history:
• APP/2017/0276- Formation of memorial park- Granted permission on 28/07/17.
• APP/2015/0202- Increase the height of 2 floodlight towers from 33m to 44m high– Granted permission on 28/09/2015.
• APP/12/09/2014- Demolition of existing club shop and construction of new ground and first floor extensions to provide ancillary office and function room facilities, new club shop and first floor display facility. Relocation of ticket office to Harry Potts Way including new ramp and canopy- Granted permission 12/08/2014.
• APP/2009/0726- Retention of free standing stadium/matchday gateway signage- Granted permission 01/02/2010.
• APP/2008/0715-Display of non-illuminated montage & signage to boundary wall on Harry Potts Way- Granted permission 28/10/2008.
• APP/2008/0099- Phase 1 development of Turf Moor to include a leisure and office development- granted permission- Granted permission 07/04/2008.
STATEMENT OF CONSULTATION
2.16 Discussions have taken place with Senior Officers of the local planning authority on the 12th January 2018. The contents of these discussions have established the principle and need for development on the application site, as well as the supporting documentation that would be required (summarised earlier).
2.17 In determining the appropriate approach to pre-application consultation, both the applicant and their main professional advisors have sought to adopt a ‘best practice’ approach to both design and delivery.
2.18 Burnley Football Club seeks active engagement with the community on a range of issues and community projects. Disabled access is just one issue that the club have engaged with supporters on. The club endeavours to ensure that all fans, customers
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and associates at all levels of the club are treated without prejudice and with the utmost respect.
2.19 With this in mind, the Disabled Supporters at Burnley FC were consulted in order to inform design proposals and their requirements as part of the evolving plans. Plans were also detailed and posted on the website for fans as part of a news article published on the 11th December 2017. This was accompanied by a 6-minute video interview with Stadium and Operations Manager, Doug Metcalfe who explained the proposals.
2.20 Given the communication the club has had with fans and the consultation that took place with council officers in the preparation of these proposals we believe that an appropriately comprehensive process of pre-application consultation has been undertaken.
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3. ACCESSIBLE STADIA GUIDE
3.1 Of prime importance to this development proposal is the Accessible Stadia Guide (ASG). This proposal has been designed in order to meet the guidance set out in the ASG. As outlined earlier this requirement was placed on all Premier League clubs, by the Premier League, in 2015 and Burnley have until August 2018 to comply. This application is representative of Burnley’s commitment to the Premier League and their fans to meet an agreed standard. This application will also help avoid financial implications that may be put on the club should they not make reasonable adjustments to Turf Moor Stadium that will satisfy the Equalities and Human Rights Commission, the regulator. The key areas of the ASG which needed to be considered are:
Transport and Access to the Stadium
3.2 Cars are the most common means of transport for disabled supporters to matches. As such there is a duty to provide parking and specifically located pick up/drop of points for both home and away disability supporters. This includes the management of these spaces to ensure that they remain allocated and designated. This should be done through the use of matchday stewards. These spaces should be located as close as feasibly possible to the principle entrance.
Entering the Stadium 3.3 Ticket offices at stadiums should be well lit and use non-reflective glass at areas where the vendor is separated from the customer. It recommends that an audio induction loop be used for those hard of hearing. A lower cluster of windows should be provided for wheelchair users.
Access into the Stadium 3.4 Access via separate designated points is considered more appropriate for disabled guests than using a main entrance where larger crowds will gather. Turnstiles should not be used at these designated entrances as they are unsuitable for some users.
3.5 There should be sufficient space for those assisting the disabled person and the individual to be passed by someone in the opposite direction.
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Circulation Areas 3.6 Passenger lifts should be provided as means of access and means of escape for all users to all levels of the new building. Tactile indicators and appropriately high lift buttons should be provided.
3.7 In new build stands small changes of level should be avoided. Where unavoidable ramps may be used. All ramps should comply with the regulations as set out in the guidance.
3.8 Corridors and passageways need to be wide enough to allow wheelchair users to manoeuvre, for other wheelchair users to pass and, where necessary, to turn through 180°.
3.9 Internal doors openings should be between 800mm and 825mm depending on the approach.
3.10 To reduce the impact on spectators at pitch side areas, the optimum use of lateral gangways to entry/exit points should be applied.
Viewing Areas 3.11 New and existing stands are expected to provide accessible viewing areas for all disability groups. These must be of an appropriate viewing quality, to give all spectators a suitable viewing angle.
3.12 For existing stands, the Gudie to Safety at Sports Grounds (the ‘Green Guide’) recommends that management provide spaces for people who use wheelchairs. The Football Task Force recommend that the ‘Green Guide’ and Accessible Stadia Guide’s Table 4 (below) is applied to existing stands, where this is impracticable it will be necessary to consult with supporters and local disability groups over compensatory provision elsewhere in the stadium and this may result in a requirement for extra spaces in new stands. The Accessible Stadia Guide’s Table 4, below sets out the expectation on new stadium developments:
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Seated Capacity of Newly Number of Wheelchair Spaces Constructed Ground Under 10,000 Minimum of 6 or 1 in 100 of seated capacity (whichever is greater) 10,000 to 20,000 100 plus 5 per 1,000 above 10,000 20,000 to 40,000 150 plus 3 per 1,000 above 20,000 40,000 or more 210 plus 2 per 1,000 above 40,000 Table 3.1
3.13 It is recommended that a range of vantage points be provided and therefore the best approach it to disperse these throughout the stadium. Designated viewing areas should be located in ‘family’ areas within the stadium.
3.14 Wheelchair users should be provided with a choice of sitting next to a disabled person or non-disabled companion.
3.15 Management, access consultants and designers should demonstrate that they have determined the design requirements in their access plan by consultation with local disability groups and disabled supporters.
3.16 Sightlines should consider that wheelchair users cannot always rotate and move their head nor stand up. As such an unobstructed view is required where should the persons in front of the wheelchair user stand their view remains unobstructed. This can be achieved through the use of raised platforms.
3.17 It is recommended that some fully enclosed and heated areas are provided. These will be more favourable with elder disability users or those more susceptible to the cold in winter months.
Toilets for Disabled Visitors 3.18 Suitable toilets should be dispersed around the ground.
3.19 Toilet facilities should be located in the most convenient locations.
Refreshment Facilities 3.20 Refreshment stands should be designed so that disabled people can use them independently or with companions. This includes locating them at the most convenient of locations to the viewing areas to reduce unnecessary travel time.
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4. DESCRIPTION OF PROPOSED DEVELOPMENT
4.1 The preliminary sub-sections of this Statement have already touched upon the context and content of the application. More detail is provided as part of the submitted Design and Access Statement (DAS), prepared by Wilson Owens Owens.
4.2 In summary, the application comprises a Full Planning Application for demolition of existing Stadium Control Box building and erection of 2 new corner stands (Use Class D2) to provide additional disability seating with ancillary facilities, lighting and associated advertisement consent application. Ancillary facilities include concession stands, toilets, accessible lift, changing places facility, store rooms, sensory room, under pitch heating boiler room, new Stadium Control Box, ticket office queuing space and new replacement Big Screen TV.
4.3 The proposed Site Layout Plan (Appendix B) shows the extent of the proposed development in relation to the nearest roads, surrounding land uses and wider area. Careful thought has been given to ensure that the proposed scheme respects its immediate surroundings and does not impose on the neighbouring land uses.
4.4 The proposal can be split into two elements which focus on two distinct corners of the current stadium. A brief breakdown of the proposals for each location is detailed below:
NORTH EAST
4.5 The North-East stand will be 4 storeys high and introduce new disabled wheelchair positions and seating at all levels. The stand will be accessible from the eastern side, opening to a main entrance lobby. There are 3 internal 17 person lifts with room for 2 wheelchairs each. There will also be a changing places facility at ground floor level. The existing screen and scoreboard will be relocated above the new stand. A sensory room will also be provided at the first floor. Access to pitch level for pitch grow lights and cherry pickers will remain at ground floor level.
SOUTH EAST
4.6 The existing Stadium Control Box will be demolished to accommodate the new stand. There will be a new ticket office queuing area built at the back of the club store and
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existing ticket office. This will be a large reception area for queuing. North of that will be the main entrance to the new stand which is 3 storeys high. The ground floor will house a large store room for the current club shop which fronts onto Harry Potts Way and a new under soil heating plant room. New disability access seating will be added at each level. The stand will also house a new Stadium Control Room at the 3rd storey. There is access to the offices above the club shop at the first floor and two 17 person lifts, each capable of carrying 2 wheel chairs, servicing all floors.
4.7 New TV camera positions are located within both corner stands.
4.8 Advertisement consent is also sought for signage used for identification of ancillary functions in the stands. The detailed design of this is in the accompanying DAS. The signage is designed to a high standard and is of a non-intrusive scale so as to serve a functional purpose and not effect nearby amenity.
DESIGN
4.9 The stands have been designed to maximise the use of space available whilst obtaining the clubs objective of providing a fit for purpose stand which can meet the Premier League requirements, based on the Accessible Stadia Guide and provide for the disabled fans who attend.
4.10 The proposed infill stands have a functional purpose, whilst subservient in size; discrete in that they are set back from the rear line of the grandstand; but are confident in that they could set the design agenda for future works at Turf Moor.
4.11 Additional seating has been provided at multiple levels as well as pitch side. Previously, there had only been seating at pitch side in these two corners. In accordance with the ASG these stands offer viewing areas at multiple levels to create a better viewing experience for users of the stand. Sections of the existing stands side awning will be removed to ensure that optimal angles are created to view the entire pitch. In the North-East corner additional raised platforms in line with the ASG standards will be added at pitch side to improve the viewing experience from this level.
4.12 The seating layout has been prepared to the guidance of the ASG. This has meant that there is an optimal internal layout which allows ease of movement around the
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internal core of the stands. Additional space has been left in the main lobbies and concession areas of the new stands in order to allow ease of circulation for users.
4.13 The use of ramps into and out of the stands and down to pitch level, as well as double size doors at all entrances and exits will ensure movement into, out of and throughout the new stands is unhindered and accessible for all.
4.14 The proposed stands fill in the existing corners of the eastern part of the stadium. This creates a more complete stadium whose appearance further enhances its surrounding and setting. An infilled stand is a sign of the progress of the club and representative of stands across the Premier League where clubs have developed on existing stadiums in order to meet the needs of fans though necessary improvements.
4.15 The proposals have been developed through careful consideration of the site including:
• The stadium’s capacity for extra seating and the appropriate location for this; • Evaluation of surrounding uses and how best to sympathetically design so as not to affect them; • Detailed analysis of the site itself including orientation, access and current capacity; and • Pressures of the site in terms of deliverability.
4.16 As described in the accompanying DAS, the design opportunities associated with the site were considered to include:
• Increase the number of positions available for disabled fans; • Increasing the viewing experience for disabled users of the stadium through improved sightlines to the pitch; • Produce a well-designed building that is both functional and in keeping with the existing stadium; • Create a number of ancillary facilities improving and modernising the existing offering at the stadium.
MATERIALS
4.17 In terms of materials, the proposed scheme will be constructed using a carefully balanced palette of materials which is both functional and aesthetically pleasing.
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Further details of the proposed materials are outlined in the DAS, but can be summarised below.
4.18 A complementary palette of materials is proposed to ensure that the new stands exist harmoniously alongside the existing stands. The predominant materials proposed are listed below:
• Glazing • Translucent Polycarbonate Panels • Glass fibre reinforced concrete panels • Perforated Steel Sheet panels
4.19 The use of artwork printed onto the sides of the stands to enhance the visual appearance. These utilise contrasting materials and printed imagery onto the sides of the lower elements of the stands.
4.20 More details of the proposed materials used and their arrangement on the built structures can be found in the accompanying DAS.
REFUSE STRATEGY & SERVICING
4.21 The Club will extend the existing waste management provision into the new areas. Waste will be limited to match days on (between 20 and 26 fixtures per year).
4.22 A recycling policy is in place with the separate collections involving the segregation of paper, cardboard, glass, plastic and grass cuttings kept separate from the general waste streams. The policy is adopted at board level within the club and is embedded throughout.
4.23 1100 litre bins are the preferred form of waste disposal and these are collected on a twice weekly basis from the site with a central waste compound in the south west corner of the stadium.
ACCESS & SECURITY
4.24 The Turf Moor Stadium is a managed site with full time staff operating a 24 hour 7 day a week schedule controlling access to the stadium and monitoring of CCTV across
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the whole site. CCTV operation and management of the ground will be extended to the new developments.
4.25 Primary access to the site will be via Harry Potts Way using the existing pedestrian and vehicle entrance which is already covered by CCTV. The nature of Burnley FCs operations requires that they have multiple access points to the site. These are monitored by both physical staff and CCTV. The perimeter of the site is high brick walling and fencing further enhancing security.
4.26 The club operates a high level of safety and security policy and protocol both on matchdays and non-matchdays. Matchday security is coordinated external stewarding organisations and the local police.
4.27 External doors and ground floor windows to the new stands will be limited where appropriate to enhance security and unauthorised access into the building.
4.28 The club currently uses a Grade 3 intruder alarm system which will be included within all elements of the new development.
ACCESSIBILITY & PARKING
4.29 The existing site already benefits from great transport links and as such is not currently over capacity so as to cause a negative impact on local traffic on match days beyond that which would be expected.
4.30 There are currently 310 parking spaces, 44 of which are disabled spaces.
4.31 Disabled Parking is available in the north car park, Harry Potts Way car park and on Brunshaw Road. All positions are in very close proximity to disabled entry and exit to Turf Moor.
4.32 There are pick up/drop of points on Belverdere Road near Ormerod Yard, Brunshaw Road. It may be possible to make arrangement for Harry Potts Way.
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5. PLANNING POLICY
5.1 Section 38(6) of the Planning and Compulsory Purchase Act 2004 requires that when determining a planning application, the decision maker must make their determination in accordance with the development plan unless material considerations indicate otherwise.
5.2 Given this obligation, this chapter therefore considers national planning policy guidance relevant to the application, which is a material consideration in the determination of this application, as well as reviewing the development plan for the site which currently consists of the Local Plan 2006. Burnley Borough Council submitted a new Local Plan for Examination by the Secretary of State on the 20th July 2017. This is a material consideration for current development proposals and indicates the direction of planning policy in Burnley.
NATIONAL PLANNING GUIDENCE
5.3 The National Planning Policy Framework (NPPF) was published on 27th March 2012 and is the Government’s attempt to put in place a clearer, more consistent National Planning Policy Framework which consolidates more than 1,000 pages of national planning policy, in 47 documents, into 1 document. This Framework has replaced all the other national planning policy documents.
5.4 The NPPF has a clear presumption in favour of sustainable development which should be seen as a golden thread running through both plan-making and decision-making. The Ministerial Foreword sets the tone of the document when it states that,
‘Development that is sustainable should go ahead, without delay – a presumption in favour of sustainable development that is the basis for every plan, and every decision.’
5.5 The NPPF outlines that the primary objective of development management is to foster the delivery of sustainable development. Local planning authorities should look for solutions rather than problems, working pro-actively with applicants to secure developments that improve the economic, social and environmental conditions of an area. The concept of sustainable development is reinforced throughout the NPPF, including Paragraph 49 which states that housing applications should be considered in the context of sustainable development.
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5.6 The Framework identifies 12 core planning principles which should underpin both plan making and decision taking. Amongst other things, planning should:
• Proactively drive and support sustainable economic development to deliver the homes, business and industrial units, infrastructure and thriving local places that the country needs. Every effort should be made to objectively identify and then meet the housing, business and other development needs of an area, and respond positively to wider opportunities for growth. • Always seek to secure high quality design and a good standard of amenity for all existing and future occupants of land and buildings. • Take account of the different roles and character of different areas, promoting the vitality of our main urban areas, recognising that some open land can perform many functions (such as for wildlife, recreation, flood risk mitigation, carbon storage, or food production). • Promote mixed use developments and encourage multiple benefits from the use of land in urban and rural area. • Actively manage patterns of growth to make the fullest possible use of public transport, walking and cycling, and focus significant development in locations which are or can be made sustainable • Take account of and support local strategies to improve health, social and cultural wellbeing for all, and deliver sufficient community and cultural facilities and services to meet local needs
5.7 Section 4 of the NPPF relates to the promotion of sustainable transport. Paragraph 32 states that, ‘Development should only be prevented or refused on transport grounds where the residual cumulative impacts of development are severe.’ The proposed development would not have a material adverse impact on the road network. There is therefore no justification for refusing the proposed scheme on transport grounds.
5.8 Section 7 of the NPPF relates to Good Design. Paragraph 56 in particular states that a well-designed development is key to sustainable development and that it is ‘indivisible from good planning, and should contribute positively to making places better for people.’ In summary it states that Councils should aim to ensure developments:
• will function well and add to the overall quality of the area; • establish a strong sense of place;
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• optimise site potential and sustain an appropriate mix of uses; • respond to local character and identity; • create safe and accessible environments; • are visually attractive as a result of good architecture and appropriate landscaping.
5.9 In determining applications, great weight should be given to outstanding or innovative designs which help raise the standard of design more generally in the area. The application scheme responds to this as it has been designed to a very high standard by a leading architect, and makes use of land that is currently vacant and under used.
5.10 The NPPF is the latest in a sequence of similar policy statements recording successive Governments’ growing commitments to removing obstacles to investment, development and the creation of jobs. It is therefore an important consideration in the context of this proposal. We have concluded that this proposal represents a positive response from the NPPF with particular regard to sustainability, good design and appropriate approach in respect of regeneration projects.
NATIONAL PLANNING PRACTICE GUIDANCE (NPPG)
5.11 On 6 March 2014 the Department for Communities and Local Government (DCLG) launched this planning practice guidance web-based resource.
5.12 The NPPG, in a similar manner to the NPPF, states good design is integral to sustainable development, and is about creating places that work well for everyone whilst looking good, lasting well, and adapting to the needs of future generations. The NPPG states that the key issues to be considered in development are:
• Local character; • Safe, connected and efficient streets; • Network of greenspaces; • Crime prevention; • Security measures; • Access and inclusion; • Efficient use of natural resources; • Cohesive and vibrant neighbourhoods.
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5.13 The NPPG then states that development should look to be:
• Functional; • Supportive of mixed uses and tenures; • Inclusive of successful public spaces; • Adaptable and resilient; • Distinctive in character; • Attractive; • Permeable to movement.
DEVELOPMENT PLAN
5.14 As outlined the Planning and Compulsory Purchase Act 2004 requires that planning applications be determined in accordance with the statutory development plan, unless material considerations indicate otherwise.
5.15 The Burnley Local Plan is an older-style document, having been adopted in 2006. The Plan has been saved and as such still constitutes the development plan for Burnley. Having said that, paragraph 215 of the National Planning Policy Framework (NPPF) sets out that due weight should be given only to those policies in existing plans according to their degree of consistency with the Framework. With this in mind, it is now a held principle by the Planning Inspectorate on behalf of the Secretary of State that whilst some policies may be classed as ‘saved’, they would only hold material weight if they are up-to-date in respect of the requirements of the NPPF.
5.16 The key policy from the Burnley Local Plan that applies to this application is Policy CF5. This policy requires that Burnley Football Club as one of the town’s greatest assets and further development and improvement of the clubs facilities will enhance this role. The Council will assess any proposals against the following criteria:
• contributes to urban regeneration in accordance with General Policy GP1 – “Development within the Urban Boundary”; • links to proposals in the Regional Park; • is of suitable scale, character, appearance and landscaping in relation to its surroundings; • has no adverse impact on the amenity of local residents including from non- sporting activities;
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• is accessible by a choice of means of transport which may include a requirement to produce a Travel Plan in accordance with Policy TM3 – “Travel Plans”; and • has the potential to encourage wider involvement in sport, and address issues of social exclusion.
Non-sport related uses will only be permitted where they are ancillary to the main sporting use.
5.17 Having regard to the above, more detail and a full list of UDP policies considered relevant to this application are listed below:
Policy GP1: Development Within the Urban Boundary Policy GP3: Design and Quality Policy GP5: Access for All Policy GP7: New Development and the Control of Pollution Policy GP8: Energy Conservation and Efficiency Policy GP9: Security and Planning out Crime Policy E20: Views Policy E21: Gateways and Throughroutes Policy CF2: Intensification of Use of Existing Sports and Recreation Provision Policy CF5: Major Sports Facilities Policy TM4: Transport Hierarchy Within Development Proposals Policy TM15: Car Parking Standards Policy BTC9: Gateways and Throughroutes
5.18 Policy GP1 States that new development should be located within the urban boundary as identified on the proposals map.
5.19 Development that makes a positive contribution to the distinctive character of Burnley and utilises good design and quality will be approved as outlined in policy GP3. Development proposals will be assessed based on; how they contribute to civic pride, identity and sense of place; if the overall design is sustainable; the proposed use and materials used; the adaptability of the building for future expansion and provision of new facilities; and the movement through to within and around a development amongst other criteria laid out in the policy.
5.20 Policy GP5 states that all development which provides facilities and services for the public should make appropriate provision for access for all. This includes disabled,
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mobility impaired, sensory impaired, the elderly, children, parents with children, women, those with learning difficulties and different ethnic and social groups through incorporating suitable design and the provision of on-site facilities needed by such groups.
5.21 Policy GP7 aims to ensure new development is assessed by the relevant pollution control authorise were necessary. New development should accord with any advice given by these authorities in order to minimise the impact on its surroundings especially when near to sensitive land uses.
5.22 All new development should reduce energy consumption and include energy efficiency measures. This includes the siting and location of the building to minimise overshadowing and maximising solar potential whilst also including appropriate landscaping and combining heat and power in the technical design of buildings were appropriate. Appropriate materials should also be used to help with energy conservation and efficiency in order to accord with Policy GP8.
5.23 Policy GP9 aims to alleviate the potential for crime in new development through suitable design and layout which includes natural surveillance defensible spaces.
5.24 Policy E20 states that developments should respect roofscapes, skylines and views. Development should not detract from prominent public views or affect views into major open areas.
5.25 Policy E21 requires that on identified throughroutes and gateways development proposals are expected to be of good quality design and enhance surroundings,
5.26 Policy CF2 seeks to approve development where it increases the use and availability of existing outdoor sports and recreation facilities through the provision of ancillary facilities. This is providing they do not unacceptably impact residential amenity, increased traffic and include measures to reduce noise pollution and minimise light spillage whilst implementing access for all as expressed in Policy GP5.
5.27 Major Sports Facility expansion and redevelopment is supported through policy CF5. Proposals should be of an appropriate size and scale and consider residential amenity as well as the production of Travel Plans to minimise traffic impact. Burnley Football Club is represented under CF5/1 of this policy and recognised as one of the towns greatest assets stating that further improvement and development of the
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club’s facilities will enhance this role. The council will assess proposals for expansion at the ground against the criteria laid out in policy CF5 as shown earlier.
5.28 All development proposals will be expected to demonstrate how they have encouraged sustainable transport in accordance with the hierarchy laid out In Policy TM4.
5.29 Policy TM15 states development should make provision for on site parking as set out according to the standards in appendix C of the Local plan.
5.30 Developments visible and adjoining gateways and throughroutes should be of good quality that enhances its surroundings according to policy BTC9.
MATERIAL CONSIDERATIONS
5.31 Other material policy considerations include:
• Burnley Local Plan Proposed Submission Document (July 2017) • Burnley Town Centre Public Realm Strategy (September 2011)
BURNLEY LOCAL PLAN PROPOSED SUBMISSION DOCUMENT
5.32 Burnley has developed a new Local Plan which will replace the existing UDP. This Plan has been through various drafts and consultation periods and has been submitted to the Secretary of State on the 20th July 2017 for examination prior to adoption. As this plan is under examination there is scope for elements to be adjusted in line with feedback from the inspector to improve the soundness and legal compliance of the Local Plan. However, as the Plan has reached the phase of examination in its current form it is considered a material consideration in planning decisions.
5.33 Below is a list and description of key policies within the examination version, published on 20th July 2017, which are considered relevant to this application:
Policy SP1: Achieving Sustainable Development
5.34 Burnley will take a positive approach to reflect a position in favour of sustainable development looking to improve the economic, social and environmental conditions of the borough.
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Policy SP4: Development Strategy
5.35 Development will be focused on Burnley. Burnley is important for its leisure, retail and excellent public transport links. Development will be supported in the development boundaries where it is of an appropriate type and scale. In the development boundary, schemes should appropriately reuse and demonstrate high sustainability standards.
Policy SP5: Development Quality and Sustainability
5.36 The council will seek high standards of design, construction and sustainability. Developments will be expected to minimise energy and water consumption. BREEAM assessments will be requires on developments over 1000m2 in non-residential developments and a rating of ‘Very good’ expected. Development should also include high quality materials respecting local context and seek to promote sustainable transport and inclusive accessibility.
Policy IC1: Sustainable Travel
5.37 Developments should be located in areas well serviced by walking, cycling and public transport. Development should maximise the opportunity for use of sustainable forms of transport and provide safe and convenient access for all sections of the community.
Policy IC3: Car Parking Standards
5.38 Development will be expected to provide appropriate levels of parking for the nature and scale of intended use. The council will assess parking provision against existing parking provision and the required need in the area. For non-residential developments standards should be expected to meet appendix 9 in the Local Plan.
BURNLEY TOWN CENTRE PUBLIC REALM STRATEGY
5.39 The Burnley Town Centre Public Realm SPD highlights key principles from the design of new public realm. It analyses in detail the history and potential of Burnley’s latent character and wealth of assets. As part of the document the following analysis of Turf Moor public realm is expressed:
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‘Burnley is also a very sporting town, with a buzzing atmosphere on match days. Turf Moor and the cricket ground do not currently benefit from quality public realm environs, although development plans at the football ground suggest a commitment to public realm improvements. Interventions that celebrate this locations’ importance as a sporting festival location would be desirable. The approach to Turf Moor along Yorkshire Street is also a key gateway into the town centre.
The below guidance was included to represent the needs around Turf Moor:
‘Guideline CA8 – Yorkshire Street Gateway and Turf Moor Approach The public realm should maximise space for pedestrian movement and be clutter free in order to improve movement to and from the football ground.’
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6. PLANNING ASSESSMENT
6.1 Having set out the policy background this chapter considers the principal issues that are considered relevant in the context of this application:
• The Principle of Development • Scale, Massing & Design • Access & Parking • Ground Conditions
PRINCIPLE OF DEVELOPMENT
6.2 The aim of this proposal is to meet ASG standards for better disability seating at Premier League Clubs. This requirement was committed to by the Premier League in 2015; Burnley had been given a deadline of August 2018 to comply. This was a year after the majority of Premier League clubs due to their recently promoted status. The timing of this application will enable to the club to meet this deadline.
6.3 This application proposes a development which remains within the existing Use Class of the stadium. The principle of development has previously been established by the stadium development. The nature of the proposal could not be situated anywhere else to meet the needs of the club. This application will bring Burnley’s existing stadium up to the standards expected of a Premier League Club in terms of disabled seating. Supplementing the disabled seating a number of associated uses are being proposed within the stand along with additional facilities to compliment the existing uses across Turf Moor.
6.4 Turf Moor has been the home ground of Burnley Football Club a year after the formation of the club in 1882. These proposals represent the next evolution of the club in terms of provision for its fans. Burnley FC has an active role in the community and as such has undertaken advice and consultation from fans and industry experts in order to deliver high-quality stands which improves the overall provision of facilities at the Club. This shows an appropriate consideration of public consultation and reinforces the high quality of design and its appropriateness in its given location.
6.5 The additional stands add more modernised facilities alongside the disabled seating. The Stadium Control Box which sits at first floor level will be relocated to the top floor
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of the south east corner stand. This will provide more modern facility and strategic viewpoint of the stadium allowing better control over the functioning and safety of the overall stadium, whilst also providing a better service to fans. There is a larger store room proposed attached to the club shop to allow expansion of the current offering. The new ticket office queueing area is carefully designed to provide a permanent solution to what was previously a temporary facility. This ticket office extension will help reduce queuing outside the stand and aid in the flow of fans to and from the ground prior to kick off. A sensory room is also provided to enhance the facilities available to the disabled users.
6.6 We consider that based on the above the development proposal accords with the NPPF, UDP policies GP1, EW4, CF2 and CF5 and Emerging Local Plan policies EMP3, SP1, SP3 and SP4.
SCALE, MASSING & DESIGN
The proposed stands do not exceed the existing height of the stadium. This helps to create a low cumulative impact on the overall massing of the stadium and limited impact on the amenity of surrounding uses. The stands infill the current corners on the east side making the stadium look more complete.
6.7 Materials used for the new stands are in keeping with the existing materials of the other stands creating a homogenous look which positively contributes to its surroundings. The expansion and overall impact of the stadium on its surroundings is positive.
6.8 The stands have also been designed in order to maximise accessibility. This has included situating the main entrances close to available parking and also designing to the ASG standards.
6.9 The ASG standards have informed a large variety of the features within the building. These include:
• Increased number of disabled seats; • larger lobbies; • larger lifts providing access, egress and evacuation to every floor; • a range of viewing platforms over multiple floors;
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• a varied seating arrangements to allow disabled persons to have a choice of who they sit next to; • larger entrance and exit ways; • limited use of ramps; and • raised platforms at pitch side seating.
The above are a few design features amongst others listed earlier in the summary of ASG features expected to be in place in modern day Premier League stands.
6.10 There is a Grade II listed millstone in the perimeter of wall leading up to the stadium on Harry Potts Way. This is a small millstone some distance from the proposed stands and it is therefore considered not to be affected by this development.
6.11 It is considered that the application scheme responds to the NPPF, UDP Policies GP3, GP8, GP9, E20 and Emerging Local Plan policy SP5.
ACCESS & PARKING
6.12 The site is highly accessible in terms of sustainable transport options. There are Bus stops located outside the ground on Harry Potts Way. The main bus station is also located a 5-minute walk from the ground.
6.13 Pedestrian links through to the Train Station and main town centre is 10-15 minutes’ walk from the ground. The number and variety of sustainable modes of transport ensures that the site is considered to be accessible.
6.14 It is however acknowledged, that the majority of disabled fans, as these stands are primarily built for, will use car as their preferred mode of transport. The ground already has 44 disabled parking spaces. The current allocation of disabled parking spaces is sufficient to meet the current needs of the stadium alongside the proposed expansion. As with any football club, expansion of a stand is often undertaken with the expectation of future growth and support of the club. The increased seating capacity for disabled fans does not necessarily mean that there will be an increase in disabled fans attending the game right from the introduction of more available seating. The Club is through working hard to ensure a full use of the positions. There may be a slow increase in the number of disabled supporters attending games over a period of time. For this reason, we consider the amount of spaces currently provided on site adequate for the level of disabled support expected. Burnley FC monitor the
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levels of disabled fans attending the game and should the need for additional disabled parking arise this will be dealt with accordingly by the club.
6.15 It is considered that the application scheme responds to the NPPF, UDP Policies GP5, E21, TM4, TM15 and BTC9 and Emerging Local Plan policy IC1 and IC3.
GROUND CONDITIONS
Phase 1 Ground Conditions Report
6.16 In support of the application a phase one ground condition assessment has been undertaken. The results of which assessed against the intended use and structural requirements of the proposal. Where appropriate recommendations are made for mitigation of any potential issues. These will be implemented where necessary. For more details please see the accompanying report.
Coal Mining Assessment
6.17 Due to the historic nature of the site a Coal Mining Assessment has also been produced to support this application. The results of which are represented in an accompanying report. Where appropriate recommendations are made for mitigation of any potential issues. These will be implemented where necessary. For more details please see the accompanying report.
6.18 It is considered that the application scheme responds to the NPPF, UDP Policies GP9.
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7. SUMMARY AND CONCLUSIONS
7.1 This document seeks to address the main elements of the application proposal and to provide an overview of the planning policy framework against which the application will be assessed. This section summarises a number of general and site-specific arguments in favour of the proposed development.
7.2 Pre-application discussions have taken place with Officers of the Council prior to submission of the application. The comments received have helped develop and shape the scheme into the form as presented by this application along with informing the required supporting information.
7.3 The application has been considered against the policies of the current development plan, the emerging Local Plan and national government guidance. It has been illustrated that the proposal conforms to the criteria set out in these policies and that the principle of development is acceptable. This report clearly demonstrates that the proposed development has policy support and is aligned with national policy.
7.4 The development designs to the ASG standards and primarily significantly improves the quality and quantity of disabled seating and wider acccessible provision at Burnley football club.
7.5 The proposed use is acceptable as all elements remain within the existing Use Class of the stadium therefore the principle of developing these sites is already established.
7.6 The principle of development is considered acceptable in this location as it is sensitively extends the current stands without influencing negatively on the amenity of surrounding land uses. As such it is considered that the proposal represents a modest addition to the stadium as a whole and helps to improve the visual appearance through infilling the corners.
7.7 The stands are located in a highly accessible location both within Burnley and as part of the whole stadium. There are a number of modes of public transport in the local area and conveniently located disability parking near the entrances to the proposed stands.
7.8 The proposed development respects the context in which it sits and reflects the recent high-quality re-developments that surround the site.
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6.1 In summary the proposal will:
• Increase the number of disabled seats at Burnley’s ground; • Provides additional ancillary facilities enhancing the growth of the Club; • Develops with the highest standards of design in mind; • Maintains sustainable transport connections to and throughout the ground; and • Ensures it does not negatively impact on the amenity of the local area.
6.2 The NPPF makes it clear that there is a ‘presumption in favour of sustainable development’ and that this is the ‘golden thread’ running through both plan making and decision taking. The proposed development is consistent with the NPPF’s core principles. The scheme has been designed to a very high standard, makes use of brownfield land and is in a sustainable, urban location that benefits from nearby services and community facilities.
6.3 In summary, the proposed development will provide two high quality corner stands and ancillary uses which meets the needs of end users. We have illustrated that the development makes every effort to accommodate disability users and is not overbearing as to affect any amenity issues with surrounding uses.
6.4 Statute requires that this application be determined in accordance with the development plan unless material considerations dictate otherwise. This proposal satisfies all relevant national and local policy considerations. In these circumstances, this application should be welcomed, and planning permission granted accordingly.
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APPENDIX A - SITE LOCATION PLAN
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Planning Statement Burnley Football Club, Burnley
APPENDIX B– PROPOSED SITE PLAN
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