planning report D&P/3627/01 6 May 2015 , Road in the London Borough of Richmond Upon Thames planning application no.15/1025/FUL

Strategic planning application stage 1 referral Town & Country Planning Act 1990 (as amended); Greater London Authority Acts 1999 and 2007; Town & Country Planning (Mayor of London) Order 2008.

The proposal Temporary change of use of part of Old Deer Park to provide a Fanzone in conjunction with the Rugby World Cup 2015 for up to 30 event days (between 11 September and 7 November), including associated facilities, temporary structures and attractions, and event branding. The applicant The applicant is London Borough of Richmond Upon Thames and the architect is Wildstone Planning.

Strategic issues The inappropriate development on Metropolitan Open Land has been justified by very special circumstances. Transport concerns need to be addressed.

Recommendation That Richmond Upon Thames Council be advised that the application complies with the London Plan, for the reasons set out in paragraph 27 of this report and does not need to be referred back to the Mayor. The Council should, however, take account of the comments made in that paragraph of this report.

Context 1 On 1 April 2015 the Mayor of London received documents from Richmond Upon Thames Council notifying him of a planning application of potential strategic importance to develop the above site for the above uses. Under the provisions of The Town & Country Planning (Mayor of London) Order 2008 the Mayor has until 12 May 2015 to provide the Council with a statement setting out whether he considers that the application complies with the London Plan, and his reasons for taking that view. The Mayor may also provide other comments. This report sets out information for the Mayor’s use in deciding what decision to make. 2 The application is referable under Category 3D of the Schedule to the Order 2008: “Development on land allocated as Green Belt or Metropolitan Open Land in the development plan, in proposals for such a plan, or in proposals for the alteration or replacement of such a plan.”

page 1 3 Once Richmond Upon Thames Council has resolved to determine the application, it is required to refer it back to the Mayor for his decision, as to whether to direct refusal or allow the Council to determine it itself, unless otherwise advised. In this instance the Council does not need to refer the application back to the Mayor. 4 The Mayor of London’s statement on this case will be made available on the GLA website www.london.gov.uk. Site description 5 The application site which has an area of 7ha is designated Metropolitan Open Land, within Richmond. It is owned by the Crown and leased to the Council. Old Deer Park is located between Gardens, and the . The site is bounded by Twickenham Road A316 to the south, Royal Mid Golf Course to the north, and leisure centre to the east. The western border will be fenced to separate it. 6 Currently the site is utilised as recreational open space with a number of sports pitches and amenity areas. Surrounding uses are characterised by recreational and leisure facilities such as the Pools on the Park leisure facility (Grade II listed and previously Richmond Baths), Richmond Athletic Ground (Grade II listed), and Royal Mid Surrey Golf Course.

Existing pitches layout and protected vista and views: Source- Applicant’s planning application documentation 7 The site is located on Twickenham Road (A316) which forms part of the Transport for London Road Network (TLRN). Richmond Station (National Rail, London Underground and London Overground services) lies 380m away and a wide range of bus routes are available in short walking distance from the site. Consequently the site benefits from an excellent level of public transport accessibility (PTAL of 6a on the Twickenham Road frontage, on a scale from 0 – 6b, where 6b is excellent). Details of the proposals 8 This planning application seeks a temporary planning permission for the use of part of Old Deer Park as a Fanzone during the RWC. The Fanzone will provide accommodation for screening RWC matches, other forms of entertainment as well as attractions and rides in order to attract families and increase dwell times. It will have a maximum visitor capacity of 10,000 people. 9 The temporary facilities will comprise the following:  A big tent comprising a large media screen to show matches (20-30 metres in height);  A stage/presentation area within the big tent;  Bars and food outlets;  RWC sponsorship activation areas;  Attractions/activities that could include rides (5m - 45m in height);  A rugby pitch and area of spectator seating; and  Toilets and first aid area.

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3D-illustrations of previous World Cup Fanzones: Source – applicant’s planning design and access statement (Appendix B) Case history 10 Old Deer Park has previously hosted a number of licensed temporary events including the Bounce Festival and In the Night Garden Live. Strategic planning issues and relevant policies and guidance 11 The relevant issues and corresponding policies are as follows:  World city role London Plan;  MOL London Plan;  Transport London Plan; the Mayor’s Transport Strategy; 12 For the purposes of Section 38(6) of the Planning and Compulsory Purchase Act 2004, the development plans in force for the area are the 2009 Richmond Core Strategy DPD and the 2011 Richmond Development Management DPD and the 2015 London Plan (consolidated with alterations since 2011). 13 The National Planning Policy Framework and Technical Guide to the National Planning Policy Framework are also relevant material considerations. Principle of land use: Rugby World Cup 2015 on MOL 14 The right to host the 2015 Rugby World Cup was awarded to in 2009. The Tournament will comprise 48 matches between 20 teams taking place at 13 stadiums in England and Wales. The overall tournament duration is 44 days. London Borough of Richmond Upon Thames, as a host city for the 2015 RWC, is obligated by the Rugby World Cup organising Committee to provide a Fanzone in the vicinity of Twickenham for the duration of the Tournament. The Fanzone is required as part of the Host City Agreement and RWC’s Fanzone Guidelines. The Rugby World Cup is now the third biggest sporting event in the world and it is anticipated that it will attract over 460,000 foreign visitors to the UK. 15 This planning application for temporary use of the site for the Rugby World Cup (RWC) related proposal is supported in line with the objectives of London Plan policy 2.1 which seeks ensure that London retains and extends its global role as a sustainable centre for business, innovation, creativity, health, education and research, culture and art and as a place to live, visit and enjoy. The proposal also complies with London Plan policy 4.6 which seeks to support the enhancement of arts, culture, sport and entertainment provision.

page 3 16 The proposal is located at Old Deer Park, which is designated as Metropolitan Open Land (MOL). London Plan policy 7.17 protects MOL from inappropriate development, except where very special circumstances can be demonstrated. Given the fact that the proposal is required to deliver a successful Rugby World Cup 2015 and its temporary nature, it is considered that there are very special circumstances to justify the inappropriate development in this instance. Therefore, the proposal is supported. 17 However, Richmond Upon Thames Council will need to apply adequate mitigation measures to reduce the impacts of the proposal on the public use of the Old Deer Park and ensure that the MOL is restored once the temporary facility is removed. Transport for London’s comments Trip generation 18 The application does not currently demonstrate a reasonable basis for substantiating the expected significant reliance upon patrons walking to the Event site. A full trip generation exercise needs to be undertaken and its outcome reviewed in concert with known RWC travel impacts, with local area /event travel plan targets accordingly addressing issues that are likely to arise. London Plan policy 6.3 requires that the impact of a development on transport capacity is fully assessed and that it, if necessary with appropriate mitigation, should not adversely affect the transport network. In addition concern exists over how travel modes can reasonably be managed and channelled in the absence of a need to pre-book tickets for events and consequently numbers of people travelling by each of the different modes. Car & cycle parking 19 No dedicated car parking is proposed within the site, though a number of public car parks are located in close proximity. The application material does not address what level of availability within these areas would be usable by patrons during event times, or what actual degree of reliance may be levied upon this capacity. The applicant must address how this matter has been considered and what management of this provision is proposed, especially in the context of the other RWC related activities on nearby sites which would also place pressure on these car parks. The applicant should also address the need to make appropriate provision for parking for Blue Badge holders and pick up/drop off of disabled people on or in close proximity to the site. The proposed form and level of visitor and taxi/private hire vehicle drop off and collection provision has not been provided and is required to assess the impact of development. Furthermore patrons may decide to travel by minibus or coach. TfL would expect an assessment to be made of the number of people who would travel by this mode and again the form and level of drop off/pick off by minibus/coach and associated on or off site parking for these vehicles. Temporary cycle parking is proposed, to form part of the proposed Heras fencing. Further details of the form, level of and management of this parking is required in order to assess the impact of the development. Public transport 20 The carrying out of a full trip generation exercise and consideration of the evidenced impact on all modes should be undertaken including assessment of the cumulative impact with RWC games at Twickenham in particular, but also alongside RWC related events in the area. Given the intended late finish time of 11.30 pm, assessment should also be made of travel home options and capacity at the end of an event including travel beyond central London and on a Sunday when there are reduced public transport services. Pedestrian environment 21 TfL is concerned that insufficient information has been provided in regard to pedestrian queuing and general obstruction of footpaths on Twickenham Road. Further, the suitability of entrance points is in doubt, due to the distance between these and formal crossings on Twickenham Road. Further consideration of these matters and of crowd control generally outside of the site is required in order to address London Plan policy 6.10.

page 4 Servicing and construction 22 Limited details have been provided in regard to event servicing contrary to London Plan policy 6.14, a (temporary) delivery and servicing plan (DSP) should be secured by s106/condition. This element may be incorporated within a wider event management plan, which again, should take account of the impacts of RWC games at Twickenham as well as those of other temporary events and activity in the site’s immediate vicinity. Details regarding construction logistics should also be incorporated within this plan. Conclusion 23 Whilst the principle of temporary events linked to the holding of Rugby World Cup are supported in principle, the application submission to date fails to reflect the very significant challenges that will be exerted on the road and public transport network during the World Cup. The concern regarding disruption to those networks is plainly more pressing around the times that matches are being held at Twickenham, TfL considers it essential that suitable assessment and management mechanisms should be developed and secured prior to the reaching of a decision on this application. It is therefore necessary for the applicant to substantially review the proposals and supporting information to fully address these issues, in consultation with Richmond Council (as planning authority) and TfL as the local highway authority, public transport operator and local traffic authority. Local planning authority’s position 24 Richmond Upon Thames Council planning officers have yet to confirm their position. Legal considerations 25 Under the arrangements set out in Article 4 of the Town and Country Planning (Mayor of London) Order 2008 the Mayor is required to provide the local planning authority with a statement setting out whether he considers that the application complies with the London Plan, and his reasons for taking that view. Unless notified otherwise by the Mayor, the Council must consult the Mayor again under Article 5 of the Order if it subsequently resolves to make a draft decision on the application, in order that the Mayor may decide whether to allow the draft decision to proceed unchanged, or direct the Council under Article 6 of the Order to refuse the application, or issue a direction under Article 7 of the Order that he is to act as the local planning authority for the purpose of determining the application and any connected application. There is no obligation at this present stage for the Mayor to indicate his intentions regarding a possible direction, and no such decision should be inferred from the Mayor’s statement and comments. Financial considerations 26 There are no financial considerations at this stage. Conclusion 27 London Plan policies on Land Use Principle, World City Role, MOL and Transport are relevant to this application. The proposed development complies with policies of the London plan on principle of land use, for the following reasons:  Principle of land use / World City Role / MOL: The proposal complies with London Plan policy 2.1 relating to London’s global role and also complies with London Plan policy 4.6 – support for and enhancement of arts, culture, sport and entertainment. These very special circumstances justify the inappropriate development on MOL.  Other planning issues can be dealt with by the Council including consideration to TfL’s comments as discussed above.  The application does not need to be referred back to the Mayor.

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For further information, contact GLA Planning Unit (Development & Projects Team): Colin Wilson, Senior Manager (Development & Projects) 020 7983 4783 email [email protected] Justin Carr, Strategic Planning Manager (Development & Projects) 020 7983 4895 email [email protected] Tefera Tibebe, Case Officer 020 7983 4312 email [email protected]

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