Agenda Item No.7
Committee: Planning and Highways Sub Committee
Date: 13 February 2002
Report by: Director of Transport and Environment
Proposal: Proposed community stadium with accommodation for class B1 business, educational, conference, club shop merchandise, entertainment and food and drink uses, together with associated landscaping and transportation facilities including road works, pedestrian and cycle links, coach/bus park and set down area, shared use of existing car park space at the University of Sussex and shared use of land for recreation and parking at Falmer High School.
Site Address: (a) Land north of Village Way, Falmer, Brighton. (b) Land south of Village Way, Falmer, Brighton.
Application No (a) BH/2001/02418/FP (b) BH/2001/02419/FP
Applicant: Brighton & Hove Albion Football Club Ltd.
Issues: · Justification for major development in the Sussex Downs AONB including social and economic impacts on East Sussex. · Environmental impact on character of landscape and local communities of East Sussex by way of scale, design and noise. · Transport impact. · Waste.
RECOMMENDATION:-
EAST SUSSEX COUNTY COUNCIL STRATEGIC REPRESENTATIONS
To resolve to inform Brighton & Hove City Council that whilst it is acknowledged that a new stadium serving the City could bring significant social and economic benefits to the local and wider community, Village Way, Falmer is an inappropriate location for a major football stadium and associated development and these applications should be refused as contrary to Structure Plan and local plan policies, for the following reasons: 1. The applicant has failed to submit adequate evidence as part of these planning applications that:
(a) a countryside location is necessary and that no suitable alternative sites exist elsewhere, contrary to structure plan policies S10, EN5, LT14 and Planning Policy Guidance Notes (PPGs) 6 and 7; and,
(b) alternatives to design and layout and meeting the need for the development by other means have been genuinely considered, contrary to
the requirements of PPG7 and Circular 2/99 (Environmental Impact Regulations);
2. The proposed schemes represent inappropriate development within this nationally designated AONB landscape at Falmer, specifically:
(a) because of their scale and nature they would adversely affect the character and quality of the AONB landscape and Falmer Village and the adverse impact could not be effectively mitigated, contrary to structure plan policies, S1 and EN1-3;
(b) the schemes are not compatible with the purpose of the AONB designation to protect the landscape and scenic beauty, contrary to advice found in PPG17 (1991) and draft revisions (March 2001);
(c) the proposals would erode the important countryside gap separating the village of Falmer and the City of Brighton & Hove, contrary to Structure Plan policy S1(k); and
(d) no compensatory measures have been proposed to offset the loss of designated landscape contrary to structure plan policy EN2(f);
3. Insufficient information has been provided to assess realistically the extent and severity of noise impacts on the tranquillity of the Downs and the village of Falmer, contrary to Structure Plan policies S1(b) and EN3;
4. The proposals would hinder the implementation of the "Academic Corridor” as the Village Way North proposal would involve the loss of land allocated (subject to strict tests) for university or business uses and both proposals would compromise the implementation of the permission for business use at Woollards Field, contrary to Structure Plan policy E14 and EP7 of the adopted Brighton Borough Plan; and
5. It is not clear that all appropriate transport services and infrastructure for access, parking and other non car means of access necessary to ensure safe access and highway safety can be put in place, contrary to structure plan policies TR1(i) and TR3 and the Transport Assessment does not include the potential traffic impacts on the Village Way/B2123 junction or those arising from other non-stadium uses.
6. Brighton & Hove City Council should also be informed that the proposals are considered premature as they could prejudice the outcome of the forthcoming local plan inquiry in to the Brighton & Hove Local Plan.
CONSIDERATION BY DIRECTOR OF TRANSPORT AND ENVIRONMENT
1. The Proposal
Introduction
1.1 The County Council has been consulted as a neighbouring authority on two separate applications for football stadia at neighbouring sites at Falmer, located within the Sussex Downs Area of Outstanding Natural Beauty (AONB). Although located in the City of Brighton & Hove, both have potential impacts on the western part of the County. Due to the marked similarity between the two schemes and sites, they are both considered in this report.
1.2 Applications BH/2001/02418/FP (land at Village Way North) and BH/2001/02419/FP (land at Village Way South) for full planning permission are in essence alternative proposals for development of a 22,000 seater football stadium on adjacent sites. The scale, bulk and form of the proposals and their composition of uses are similar. The key differences of the schemes arise from their respective locations, namely;
· The proposal north of Village Way proposes a stadium occupying part of the campus of the University of Brighton and would entail the demolition of university buildings to accommodate the scheme. This application does not, however, include proposals to replace any lost buildings other than indicating where replacements may be located. The site area spills over Village Way to accommodate the turning and parking areas.
· Land South of Village Way is located on the prominent downland slopes, but would involve the development of section of land north of Village way to enable access to the rail station and the underpass to Sussex University to take place.
1.3 The Village Way South proposal appears to be an alternative to avoid the demolition of the University of Brighton buildings.
1.4 Both proposals encroach on to the land owned by the County Council, at Woollards Field, in order to provide access to car parking.
Background to the Proposal
1.5 The “Taylor Report” (1989) recommended a number of crowd safety measures for football stadiums in the UK. This included the phased introduction of all seater stadiums at the 92 football league grounds in the country.
1.6 Brighton & Hove Albion FC (BHAFC) needed to relocate, as its original ground (Goldstone) was unsuitable for these regulatory improvements. However, the Goldstone Ground was sold before an alternative home was found, forcing the Club to enter into a ground sharing agreement with Gillingham FC.
1.7 The Club returned to the City in 1999 following the granting of a temporary permission to upgrade the Withdean stadium to football league standards. The return of the Club to Brighton, it is argued, has brought about an increased demand for tickets following poor attendance figures whilst playing at Gillingham.
Site 1.8 As noted in the introduction to this report, the sites of Village Way north and south are located within the AONB on the eastern edge of the City of Brighton & Hove. The landform falls from a height of 105 metres above ordnance datum (AOD) at the Village Way south site to approximately 70 metres AOD at the Village Way north site where the undeveloped downland meets the northern border defined by the Lewes – Brighton rail line. The downland forms an open north/south valley bisected by an embankment forming Village Way. The campus of the University of Brighton (forming part of the site area for the Village Way North proposal) lies to the west. The woodland known as the Westlain plantation forms the western boundary for the Village Way South site. There are no natural features defining a boundary to the east. 1.9 Village Way forms the access to the University of Brighton from the B2123 (The Drove). The Drove running north south links the A259 at Rottingdean to the A27 at Falmer. The easternmost part of the proposal site is some 70 metres from the junction of Village Way with the Drove.
1.10 The small downland village of Falmer, and its conservation area, lies less than 300 metres from the boundary of both sites.
1.11 Village Way north has a site area of 16.7 hectares, whilst the Village Way south proposal is 18.2 hectares in area.
The Proposal
1.12 The development proposals entail the development of a football pitch with four stands with ancillary facilities and parking and other associated development, including B1 office space and education facilities. This is proposed to take place over a period of 7 – 10 years and is divided in to four phases designed to accommodate an anticipated increase in crowd numbers.
1.13 Common elements of both schemes include:
· A two-tier west stand (to be built as part of the initial phase of development) providing the main accommodation for spectators (10,718 covered seats and hospitality boxes), ancillary facilities. The west stand would also incorporate:
o a banqueting/conference suite capable of accommodating 500 persons; o nursery/crèche and a homework club/learning hub for up to 50 students of 11-18 years of age and adult education programmes; and o 720 sq.m of teaching space (for use by the University of Brighton).
· A single tier temporary east stand (also built as part of the first phase) with 3,600 seats
· A permanent east stand with 6,888 seats to be built as part of the second phase increasing the stadium total second phase capacity to 17,606 seats, replacing the temporary stand. This stand would also include commercial floor space comprising 1,200 sq.m of hi-tech office space suitable for use as an “Innovation Centre” or for accommodating business starter units aimed at fostering employment linkages with the two nearby universities.
· A north stand with 2,384 seats, to be built as the third phase
· A south stand, also with 2,384 seats, to be built as the fourth phase, bringing total seating capacity to 22,374 · access and traffic arrangements directly affecting East Sussex involve: § a bus/coach park, set down area, parking for players, VIPs and disabled to be accessed from Village Way and the B2123 in East Sussex; § shared parking with the University of Sussex (accessed from East Sussex County Council’s highway network).
1.14 In addition to 30 football league matches the applicants indicate that the proposal may host other national sporting events, concerts and other “outdoor events”.
1.15 No indication is given as to the frequency of non football events following the first year of operation other than reference in the Environmental Statement (non technical summary – noise) to concerts not exceeding one a year for the first three years. 1.16 There is no doubt that the scale and form of the proposals are striking, the applicant states that the proposal should not conceal its function and that the underlying concept of the design is one of a flagship/gateway building to the City of Brighton & Hove. The design represents a partially sunken cylinder, lain on one side, the central section directly over the pitch is left open. The roof is braced and supported by two long span arches. Both ends of the cylinder are closed by the main stands (east and west). The stadium would be sunk into the downland thus the full bulk of the scheme would not be revealed. Nonetheless, the western elevation of both proposals rises some 40 metres above proposed ground level, and the eastern elevation rises approximately 25 metres.
1.17 Despite the considerable change in levels over each site area it would appear that the pitch of the Village Way North proposal would be at 77.5m AOD requiring cutting and filling between the 78m and 87m contours. Similarly, the Village Way proposal would involve cutting and filling to achieve a pitch level of 94m AOD between (approximately) the 90m and 105m contours. Excavation will not be restricted solely to the pitch area as both proposals will require cutting and filling throughout the site areas.
1.18 It is proposed that the roof is to be made of a pale green translucent polycarbonate shell supported by white superstructure. An earth bund rises some 12 – 18 metres from the main concourse level to meet the roof structure.
2. Comments/Appraisal
Issues
2.1 As a neighbouring authority the key issues surrounding these applications are:
· the justification for major development in the AONB entailing the assessment of need, social and economic benefits, and the search for alternative sites;
· the impact on the local and wider environment in terms of visual and noise impact on the AONB and on the village of Falmer brought about by the proposals; and
· the consideration of transport and highway infrastructure impacts and handling of waste generated by the proposal in both its construction and operational phases.
2.2 The potential for significant and permanent adverse impacts on the village of Falmer and surrounding Downland is of concern. The Parish Council is sensitive to the issues raised by proposals of this scale and nature and has itself provided detailed objections to both these applications.
Local Plan Context
2.3 The significant locational issue for both applications is the fact that they both constitute major development proposed in the nationally designated AONB and beyond development boundaries defined in the adopted local plan (Brighton Borough Local Plan 1995).
2.4 However, a site at Village Way North is allocated for development for university faculty use or for high tech uses linked directly to the Universities in the adopted Local Plan (see paragraph 2.11 below).
2.5 Brighton & Hove City Council are in the process of reviewing the adopted plan, proposing that a “community stadium” would be an acceptable use of the Village Way North site. Despite this, the Village Way North proposal occupies a greater area than the proposed site allocation. Furthermore, the Brighton & Hove Local Plan Second Deposit Draft (2001) does not discount the Village Way South site as an potential alternative to Village Way North, although the plan states that the City Council’s preferred site remains Village Way North.
2.6 Nonetheless, these draft provisions are the subject of objections lodged by the County Council and, consequently, have little material weight when assessing the two applications. The local plan inquiry will discuss objections to the deposit draft proposals. This is due to be held in September 2002.
2.7 The timing of the local plan review and the submission of these applications raises the issue of prematurity and whether the applications should be determined in advance of the local plan inquiry. Considering the substantial nature of the proposals and their potential impact on the environment and transport infrastructure it is important that the principle of development on this site for this use be discussed in a wider strategic context.
Justification for Major Development within the AONB
2.8 An important element of the Structure Plan’s strategy is to focus the bulk of development and change within the defined settlements of the plan area. Beyond these settlements the predominant land use will be agriculture and forestry with other development subject to strict control (policies S4 and S10). Any application is, therefore, required to demonstrate that a countryside location is necessary and that a town or village location would not be suitable (S10a). This “countryside test” is considerably strengthened when considering development in the AONB, Planning Policy Guidance note (PPG) 7 (The Countryside: Environmental Quality and Economic and Social Development) governs major development in AONBs and Planning Policy Guidance note (PPG) 6 (Town Centres and Retail Developments) promotes the sequential test for large scale leisure developments.
2.9 Structure Plan policies S1 (j), EN2, EN3 and EN4 afford a high level of protection to designated landscapes. Policy EN5 provides an exception to this if the proposal is justified by proven national interest and a lack of alternative sites. Moreover, any such proposal must demonstrate that adverse environmental impact has been kept to a minimum and that appropriate measures are taken to integrate the development within the landscape, reflecting the requirements of PPG7.
2.10 This is mirrored in local plan policy at paragraph 3.61 and policy ENV 54 of the adopted Brighton Local Plan, which requires a demonstration of need for the location and an overwhelming case for the development proposal judged against the acknowledged national importance of the AONB designation. Such restrictions also apply to development associated with the higher education establishments and the high tech uses allocated at Village Way.
2.11 Some land at Village Way North is allocated in the adopted local plan for development, but only development relating directly to the Universities and only in exceptional circumstances. The land is not allocated for any other development. Policy EP7 (Special Contingencies) provides the criteria that would govern development proposals for the site. Such development would be part of a planned expansion of the higher education establishments that could not be accommodated on the existing campuses, observing the strict environmental controls appropriate to the landscape and rural character of the location.
2.12 The Structure Plan reflects this and states in policy S13 (Area Policies – Brighton & Hove) that in order to protect the City’s landscape setting:
“no further outward expansion of Brighton & Hove will be allowed beyond the limits of the built up area or other areas currently identified in the currently adopted local plans” (ie the Brighton Borough and Hove Borough Local Plans 1995).
2.13 The development boundary of the City (in the adopted local plan) excludes the proposal sites from the developed area of the City. In combination with the particularly strong local plan policy on development at Village Way, the local and strategic policy framework provides an unambiguous statement of protection for the Village Way sites.
2.14 Furthermore, the Structure Plan promotes the concept of the Academic Corridor (E14) along the A27/A270 Lewes Road (Brighton town centre to Falmer). This supports the development of the higher education and research functions of the universities, within the environmental constraints imposed by their AONB and conservation area locations.
2.15 The objectives of the adopted Local Plan and Structure Plan are compatible, in that development at Village Way North should relate directly to the expansion of the Universities and that the environmental constraints of the location should prevail, and that Village Way south is protected from inappropriate development. In the absence of adopted policies on the development of either site for a stadium use, these proposals for stadia at these locations are contrary to the adopted local plan.
2.16 Since the adoption of the Structure Plan by the County Council and Brighton & Hove City Council, the Government has altered the provisions of PPG 7 insofar as they relate to development within AONBs. This clarified that equivalent planning protection is given to AONBs as National Parks.
2.17 This, however, introduces the public interest test when dealing with major developments in the AONB, and entails an assessment of:
o the need for the development, in terms of national considerations, and the impact of permitting it or refusing it on the local economy;
o the cost and scope for developing elsewhere outside the area or meeting the need for it in some other way; and,
o any detrimental effect on the environment and the landscape, and the extent to which that should be moderated.
2.18 Despite this rewording, the provisions of the Structure Plan still hold true as, a demonstration of need, an assessment of alternative sites and an assessment of environmental impact and mitigation are all required.
2.19 In considering development proposals within the AONB, planning authorities must assess the need for the proposal in terms of national objectives and also in terms of the local economic impact of permitting or refusing the proposal.
National Considerations
2.20 The national objectives for sport and recreation are expressed in PPG17 (Sport and Recreation) and its revised draft version published in March 2001. The latter places an emphasis on the role of sporting facilities and their accessibility in promoting social inclusion and supporting an urban renaissance, thus contributing to the quality of life of the population as a whole. This approach is reflected in Structure Plan policy LT1. The applicant emphasises the Club’s commitment to the community and the initiatives it sponsors aimed at the disadvantaged children of the City.
2.21 However, such social objectives necessarily have to observe the wider policy framework such as the priority placed upon protecting designated landscapes and ensuring that the bulk of development takes place within defined settlement boundaries. Structure Plan policy LT14 (major sporting venues) seeks to balance these competing needs by providing a range of criteria, all of which must be satisfied. Indeed the proposed schemes meet aspects of the policy requirement in that they are capable of a number of uses, and close to a major public transport corridor and trunk road and would be accessible to existing and new markets. However, the sequential test remains in the form of LT14(f) and the analysis of the applicants approach to this exercise is set out below at paragraph 2.30.
2.22 Furthermore, both versions of PPG17 express the principle that in the case of major recreation proposals in a designated area, the purpose of the designation will define the suitability of a proposal. National guidance considers that, large scale, noisy and intensive uses will be incompatible with the AONBs purpose of protecting the landscape and scenic beauty.
2.23 The applicant puts forward the case for the development in the planning statement which states that the development proposals are driven by local priorities. The proposals are seen as essential to the image of Brighton & Hove City Council, forming part of the local strategy to promote the City as a centre for sporting excellence and of course to provide a home of BHAFC.
Social and Economic Benefits
2.24 The concept underpinning the proposal is one which not only provides a permanent home for Brighton & Hove Albion FC (BHAFC) but also seeks to promote recreation and sport within the community via links with local and national programmes of social inclusion and education.
2.25 The applicant promotes the proposal in terms of the benefits it would bring to Brighton & Hove. These are summarised as:
· some 646 jobs (fulltime or full-time equivalents), above those already employed by the football club, to be created in management of the finished scheme, this includes the management of the stadium the learning hub and the Club itself. 300 are estimated as being engaged in the construction of the proposal over the phased 7 – 10 year construction period; · the provison of a training centre in partnership with the City College of Technology and the Learning and Skills Council to establish a skilled construction work force. This would subsequently provide a permanent training centre for building management training as part of the learning hub; · a reduction in the local unemployment rate in the order of 9%. (including the temporary construction workforce); · a secondary spend effect of (assuming 450,000 visitors per annum) an estimated £1.8 million (20% of visitors spending an additional £20 each, within the City) this assumes capacity attendances throughout the first year; · an estimated turnover of £7.9 million of the completed project contributing to the local GDP; and
· significant local and sub regional multiplier effects on the tourism, catering and food sectors arising from (it is assumed) companies servicing the scheme.
2.26 The proposal includes the promotion of community initiatives through participation in sport and establishing links with local schools and community groups. The applicant states that this work will extend to work focussed on the deprived areas of East Brighton, and by providing educational opportunities through the provision of a “learning hub”.
2.27 The applicant has promoted the scheme only in terms of benefits for the City of Brighton & Hove, but has not considered the beneficial impacts of the scheme in East Sussex. However, I consider the proposals would offer job opportunities for residents in the west of the county. It is also notable that the applicant has not included an assessment of the impact of the 1,200 sq. m of office space. Although this would add to the economic benefits and opportunities of the overall scheme, in the case of Village Way North it would result in the loss of the Brighton Borough Plan land allocation for uses associated directly with Universities and research and development as part of a wider strategy to promote high tech industries within the academic corridor along the A270 to central Brighton.
Conclusion
2.28 It is clear that BHAFC need a permanent ground, the temporary arrangements at Withdean make this a pressing need. This is not disputed, nor are the potential economic and social benefits that a successful major new stadium complex would confer on the local area and beyond the City of Brighton & Hove. Residents of East Sussex would benefit from both the recreational and employment opportunities presented by the proposal.
2.29 However, the proposals are driven by local needs and priorities and considering the sensitive nature of the AONB designation I believe that this is an insufficient justification for permitting the development at this location. A new stadium built elsewhere in the Brighton & Hove area could still offer social and economic opportunities for residents and businesses in East Sussex.
Assessment of Alternatives and Site Selection
2.30 The applicant has provided supporting information in the form of an Environmental Statement (ES). Within this statement (comprising seven volumes), it is asserted that the proposed sites are the only realistic options following an extensive sequential site assessment process. This process is outlined in the briefest terms and does not provide an insight into the methodology or the detailed conclusions of the exercise.
2.31 The applicant has referred out to, but not included, an earlier study commissioned by the club and presented to Brighton & Hove Members in February 1999. It provides a description of the site selection process which commenced in 1995 with a list of sixteen sites, eleven of which were discounted. No detailed documentation is available describing the detailed aspects of this first study.
2.32 The remaining five sites were analysed in more detail in the Sequential Site Analysis and comprised three urban brownfield sites;
· the Coral Greyhound Stadium (Hove), land adjacent to Brighton Station, Shoreham Harbour, and two peripheral greenfield sites:
· Falmer (Village Way North) and Waterhall (north of Brighton & Hove).
2.33 The Sequential Site Analysis (SSA) assesses the relative strengths and weaknesses of the candidate sites in terms of potential noise, light, visual, construction, traffic, ecological impacts. Consideration is also given to the level of accessibility afforded to non car modes of transport in each case. Land North of Village Way was seen as being the most appropriate location.
2.34 However, the SSA itself is a summary of a more detailed process and in most instances provides very little evidence of methodology or reasoning behind some of the conclusions drawn from the study. Of the evidence provided there are examples of inconsistencies and incomplete reasoning. Furthermore the exercise itself is somewhat dated as the SSA is three years old and is itself the culmination of a four year exercise,
2.35 Similarly the applicant has not demonstrated that alternative schemes or means of meeting the need in other ways have been genuinely considered. This being contrary to the requirements of PPG7 on development within AONBs and the Environmental Impact Assessment Regulations governing major development likely to affect sensitive environmental areas.
2.36 Crucially the SSA does not provide any assessment of Village Way South.
Conclusion
2.37 The applicant has failed to demonstrate that there are no suitable sites outside the AONB and that the proposal sites are indeed the best available sites for the proposed stadia, or that there other ways of meeting the need for the development. A far more transparent, consistent, detailed and up to date exercise needs to be undertaken in order to satisfy the requirements of Structure Plan policy EN5, LT14 and S10 and PPGs 6 & 7.
Environmental Impact
Landscape and visual impact
2.38 The proposals are adjacent to the urban edge of the City of Brighton & Hove. Despite this the proposal sites are in the undeveloped AONB and form part of a strategic gap separating the City from Falmer Village. The applicant states, the proposals would involve a change from the current mixture of the agrarian field, mature mixed woodland belt and distant urban form into one of a built form and a structured landscape, occurring over a site area of 17 –19 hectares.
2.39 The applicant argues that considering the poor urban environment provided by the Universities and a major public transport corridor, the proposed development would in fact improve the local environment by drawing attention towards an innovative and attractive building. This is further underlined by the applicant’s statement that the proposal would act as a gateway to the City of Brighton & Hove. However, this concept statement appears to contradict the evidence of the landscape impact assessment which concludes that the completed development would only be visible from a limited number of viewpoints. This contradiction is further emphasised by the design philosophy of the proposal which looks to create a flagship building at the eastern entrance of Brighton & Hove.
2.40 Whilst the proposals are clearly adjacent to the urban edge, I question the validity of an argument which promotes the development of nationally designated landscape as an improvement to the local environment. While the building is of striking modern design it is wholly out of character with its surroundings and inappropriate to the local character.
2.41 Viewed from greater distances, the urban edge is no less evident. Yet the “improving” nature of the proposals needs to be challenged. I would argue that rather than drawing attention away from an urban fringe, the impact of the proposals would merely add to the prominence of the urban area thus accentuating, rather than relieving, the existing visual impact.
2.42 This argument also runs counter to the conclusions of the SSA which discounted other countryside sites on the basis of visual impact.
2.43 The urban intrusion created by the proposals would also serve to erode the countryside gap between the village of Falmer and the City of Brighton & Hove contrary to Structure Plan policy S1(k).
2.44 The constrained design solutions offered (apparently set by the administrative boundaries and the requirements for pitch alignment) leave little opportunity for any effective landscaping of the proposals to mitigate their wider visual impact. Both proposals, for example, break the skyline from viewpoints beyond the immediate environs of Village Way. Their impact will also be evident from more distant viewpoints, as the applicant’s information suggests. I do not believe it is possible to mitigate effectively the impact of these proposals in this location, even if the site area were to be increased.
2.45 The applicant’s landscape impact assessment identifies zones of visual influence (ZVI). These zones within which the development proposals could be seen either continuously or intermittently are identified as being predominantly within a 5km radius of the site. However, this extends as far as 9km to the east, in the case of Village Way South which could be viewed from Cliffe Hill, Ranscombe Camp and Mount Caburn in Lewes.
2.46 The ZVI map for Village Way North indicates that the proposal would be continuously visible within the locality of the proposal (east and south). Intermittent views would be gained from the east of the B2123, parts of Balmer and the South Downs Way at Ditchling Beacon to the north.
2.47 Village Way South would be visible within the immediate locality and up to 1km away to the south-west, south east and south, Newmarket Hill (south east) and Balmer Down (north east) some 2 – 3 km distant. Nonetheless, intermittent views of the proposal would be achieved from Mount Harry, the western fringe of Lewes and to the east of the town. In all instances the views from the nationally important South Downs Way and other rights of way in the area would be adversely affected.
2.48 Considering the potential for extensive and severe impacts on the AONB and the neighbouring village of Falmer Structure Plan policies S1(b) and EN2(f) are of particular importance. These specifically require compensatory measures for any environmental resource lost as a result of the proposal. There is no evidence to suggest in the supporting information that this has been considered by the applicant. However, it is difficult to imagine what kind of environmental compensation could adequately compensate for a loss of resource of this scale.
Noise
2.49 It is an objective of Structure Plan policy and national guidance that noise generating and noise sensitive developments are kept apart and that unavoidable impacts are kept to a minimum. This principle is evident in Structure Plan policy S1 (a & b) and EN15. More specific guidance is expressed in policy EN3 stating that development involving the change or damage to AONBs including significant increases in noise arising from traffic or other activity will not be permitted.
2.50 An important feature of the AONB is the degree of tranquillity and remoteness which can be gained, although one may be relatively close to the City of Brighton & Hove. The information provided with regard to noise impacts appears to be limited to impacts on the immediate area and, as discussed below, somewhat selective in establishing an acceptable baseline from which to judge impacts. The limitations of the study and an absence of noise mapping is of concern considering the national importance of the location. It is anticipated that the proposals may have an adverse impact on the tranquillity of the Downs. Local meteorological conditions can have a significant impact on the manner in which sound travels. Although sound may be focussed upwards (in the finished scheme), it may be “dropped” further within the AONB. No indication is given on the immediate impacts on tranquillity arising from an incomplete stadium.
2.51 Clearly such a major development of this type will generate a substantial amount of noise whilst in use. The ES (non technical summary of both applications) notes that:
· there will be an increased impact from crowd noise during the initial stages of development when the main stand is complete but the others are not;
· with mitigating works in place, it is not anticipated that the residual effects will be of significance. However, the issue is raised that other events such as concerts may result in significant effects;
· the construction of the stadium will be a significant contributor to noise impacts in the area should mitigation measures not be employed,
· the contribution to noise levels provided by traffic visiting the proposals would be minimal, although there may be localised difficulties in Stanmer Park; and
· noise levels arising from the increased provision of rail services running on match days would have a minor impact on noise levels.
2.52 The non technical summary fails to adequately describe the anticipated impacts on Falmer.
2.53 Despite these limited reassurances, there are concerns that the calculations and monitoring arrangements outlined in the ES may not accurately reflect existing weekday evening noise levels in the vicinity of the proposal sites. The measurements appear to be unusually high. The accuracy of such readings are essential to providing an assessment of the noise impacts; the higher the existing background noise levels the lower the potential increase in noise impact will appear to be.
2.54 It would be necessary for more detailed readings to be made to gain an accurate picture of the existing situation and for the applicant to provide noise maps in order to graphically represent the extent of the noise impact. The submitted studies appear limited to the immediate vicinity of the proposal and do not address the issue of noise impacts on the tranquillity of the Downs.
2.55 The ES does not explore possible impacts should the phasing not progress as anticipated, or if the stadium is not fully completed.
2.56 The applicant indicates that, the stadium will not be fully enclosed until seven to ten years after development commences. The ES notes that this phased approach would adversely impact neighbouring areas, although it qualifies this view by stating, that such impacts would be infrequent (ie on match or event days).
2.57 A further consideration in determining the level of noise is the orientation of the stadium and the amount of enclosure afforded by the stands once the project has been completed. The design solution offered by both proposals result in an orientation, which, allied with the phasing of development, would not provide an effective barrier for the residents of Falmer. Furthermore, the EIA Regulations require that an applicant to demonstrate how the preferred scheme was arrived at over other potential schemes.
Conclusion
2.58 I consider that both proposals would engender a significant change in the character of the AONB within East Sussex, adversely affecting the character and quality of the AONB landscape, the remoteness and tranquillity of the Downs and Falmer village, contrary to Structure Plan policies S1, EN1, EN2 and EN3. I do not consider these adverse impacts can be effectively mitigated. Similarly, the methodology employed in the assessment of potential noise impacts and the conclusions drawn provide great cause for concern. I have yet to be reassured that the noise impact on Falmer has been accurately predicted and assessed, the apparent selectivity of baseline noise studies is of particular concern.
Transport
2.59 Despite the inadequacies of the SSA it is evident that the proposal sites are located in close proximity to a major transport corridor, including the A27 and the south coast rail line. In terms of strategic accessibility a location at Falmer has a lot to commend it. The general principle of ensuring major development is located in close relation to public transport routes is expressed in Structure Plan policies S1(c) S4 (j) TR1(h&i), TR3 and LT14. A range of transport and access arrangements are proposed as part of the development proposals, although the key features are limited to shared parking arrangements with Sussex University and Falmer High School and necessary highway works to access them, and a reliance upon public transport measures such as park and ride and the nearby rail station at Falmer.
2.60 The applicant considers that in the region of 21% of spectators will arrive by rail. This equates to 4,620 passengers when the stadium would be operating at full capacity. Despite the advantage close proximity to a main line rail line brings, there is no indication of a formal commitment between the applicant and the train operator to bring about the necessary increase in services. Furthermore, there are concerns that Falmer station is may not be fit to accommodate such significant increase in passenger numbers. To avoid overcrowding on trains the applicant has to demonstrate that the sufficient capacity exists. This needs to be established to avoid a consequent encouragement to use the private car as an alternative, which would have impacts on the amenities of East Sussex residents and the highway network. To this end, it will be necessary to ensure that the train operator can and will deliver the additional services and that there are positive inducements to those attending the stadium to use rail.
2.61 It should be noted that the provision of car parking which is directly within the control of the applicant is limited to some 140 spaces allocated for players, officials etc. The remaining car parking space relies on the cooperation of the High School and Sussex University. I am unaware of any public commitment made by these organisations to enter into an agreement with the applicant. Clearly, without the guarantee that these spaces will be made available in perpetuity, the proposed schemes run the risk of creating significant adverse impacts elsewhere on the highway network, on traffic safety and on the amenity of the residents of Falmer. The proposal already entails stewards preventing supporters’ cars from entering Falmer. Although designed to safeguard the amenity of the village, such arrangements would result in considerable inconvenience for residents and visitors on match days. Without adequate parking this inconvenience would be exacerbated.
2.62 The key concerns of the County Council as Highway Authority are limited to those parts of the road network in East Sussex affected by the proposals, notably the junction of the B2123 with Village Way and East Street and the junction of the B2123 with the A27. Coaches, buses and cars for VIPs players, officials and the disabled would access the stadium via Village Way. Sufficient capacity exists on the A27/B2123 junction to accommodate the additional flow arising from match days (when the phased development has been completed), as the peak times associated with the stadium will not coincide with the traditional rush hours. However, the impact on the junction of the B2123 with Village Way and East Street has not been included in the Travel Assessment, this oversight should be remedied in order to gain an impression of potential impacts on the junction and consequently the village of Falmer.
2.63 The travel assessment deals exclusively with the stadium operating in its primary role as a major sporting venue. It has not assessed the impacts of the site during other periods and ignores significant elements such as the 1,200 sq.m of office space and the conference, banqueting events. Activity surrounding the stadium beyond its core purpose may not be subject to the same incentives to use public transport. This will have implications for the surrounding highway network as a B1 office use of 1,200 sq.m could generate an additional 136 vehicle movements per day to and from the site. From the plans provided access could only be gained via Village Way with the inevitable adverse impacts on peak time traffic flows at the above junctions within East Sussex.
Waste Issues
2.64 These applications have major waste generation implications as both locations will involve considerable excavation of downland, and Village Way North will require the demolition of a number of Campus buildings. Also as a use that will attract large numbers of visitors, large volumes of waste will be generated over the lifetime of the proposal.
2.65 The applicant has identified various measures for minimising waste (such as incorporating excavated material in the landscaping) and for providing recycling facilities. Yet these measures have, in the main, been referred to as matters for consideration. However, the potential impact of these development proposals on waste management facilities within East Sussex and Brighton & Hove could be significant, as the construction phase would generate vast quantities of excavated material. For the applications to be acceptable, they must demonstrate that appropriate sustainable waste management principles have been incorporated into the design, and such measures should be secured by condition or agreement attached to any permission granted.
Woollards Field
2.66 Woollards Field in Brighton, adjacent to the A270 to the west of the application site, is owned by the County Council. It currently enjoys planning permission for the development of 5,000 m2 of business uses (B1) and potentially forms part of the Academic Corridor concept supported by the Structure Plan (policy E14). The permission provides for access from the A270 at the eastern end of the site, adjacent to an existing narrow track under the railway. However, the proposals for the stadium at Village Way involve the creation of a significant junction at this point on the A270 and a widening of the track as far as the railway to three lanes to take traffic into the proposed parking area at Falmer High School. This proposed access, would appear to involve the development of land owned by the County Council. While the landowning interests of the County Council are not relevant to the consideration of this application by it as Strategic Planning Authority and will be pursued separately, the proposal has wider planning implications.
2.67 First the stadium car park access would compromise the permitted access to the proposed business use development, which in turn could jeopardise an important element of the Academic Corridor initiative. Second, as with the use of other existing car parks at Sussex University, unless access can be secured to enable this proposed car park to be used by the stadium development, it may not be able to cater for the demand for access it generates. This in turn could lead to traffic problems on the wider network.
3 Conclusions
3.1 It is clear that the Football club requires a permanent home ground if it is to have the opportunity to prosper in the football league. Its current arrangements rely on the use of Withdean stadium in Brighton on a temporary planning permission and the current capacity of that ground is limited.
3.2 These proposals develop the concept of a community stadium with a 22,000 all seater capacity that would have all the ancillary facilities one would expect of a modern football stadium. It also proposes additional facilities for leisure, business and educational uses, which extend the role and opportunities offered by the scheme. The applicants also have ambitious plans to extend the range of their community involvement and this would meet economic and social inclusion objectives. Although the applicants describe their proposals largely in terms of the positive benefits to Brighton & Hove, there is no doubt that there would be the opportunity for social and economic benefits for residents and businesses in East Sussex, although it is difficult to quantify. I would support the principle of a new stadium for the football club with the additional facilities it proposes, provided a suitable site can be found. However, the main strategic issue raised by these applications is whether Village Way, Falmer is the best location for this and whether the impact is or can be made acceptable.
3.3 From the evidence seen I am not convinced that the applicants have demonstrated that this is the only and best location for such a stadium. I have reservations about the site selection study, which in any case is now out of date, and I do not consider it justifies this location in the AONB to override national, structure plan and local plan policies that give strong protection to the AONB. Although some development is allocated in the adopted local plan for high-tech or university uses, it is as a last resort site and subject to strict environmental tests. The stadium proposals would cover a larger site and are of such a scale that I do not consider the stadium could be satisfactorily accommodated at either site.
3.4 Despite proposals to cut the stadium into the downland, the proposals would be visible from both near and distant views and would adversely affect the character and quality of the AONB landscape and that of Falmer village. The applicants indicate that planting would take many years to mature and then only provide partial screening. The proposals would erode the strategic gap between the city and Falmer village. The issue of noise has been insufficiently considered and I remain concerned at the potential impact on the residents of Falmer village and the tranquillity of the downs.
3.5 There are some transport advantages in locating a stadium at Falmer, but the transport arrangements for both stadia rely upon both high levels of public transport usage and the applicants gaining the use of existing and new proposed car parks. In such circumstances the capacity of highways in East Sussex could accommodate the scale of stadium traffic indicated as only limited parking and bus/coach car parks are accessed from the County Highway network and peak times of stadium use would not coincide with other peak use of the roads. If permanent parking arrangements are not secured and appropriate capacity of the rail infrastructure and services cannot be made available, then the transport impact would spill over a wider area into East Sussex. Some aspects of the travel assessment are missing such as the impact on the Village Way/Falmer Road junction and the traffic impact of other associated uses such as the business space.
3.6 These applications would compromise proposals for economic development at Village Way North and Woollards Field that would contribute to the Academic Corridor strategy supported by structure plan and local plan policies.
3.7 The proposals are clearly contrary to the adopted Brighton Borough Plan and the Structure Plan. As such they would need to be referred to the Secretary of State as departures. He may decide to call them in for his own determination, which would probably lead to a public inquiry. I do not believe the emerging local plan for the city is at such an advanced state and without relevant objections that it would carry much weight. Furthermore seeking to determine these applications in advance of the emerging local plan could prejudice the local plan process.
3.8 I do not believe this is the right location for a new stadium and consider these applications should be refused.
BOB WILKINS Director of Transport and Environment 21 February 2002 P&HSUB:ProposedStadiumFalmer-Para7
Contact Officer: Nick Claxton Tel No. 01273 481407 Local Member: David Neighbour
BACKGROUND DOCUMENTS
East Sussex and Brighton & Hove Structure Plan 1991 – 2011 Brighton Borough Local Plan Towards 2000 Brighton & Hove Local Plan second deposit draft 2001 Memo from Senior Engineer Development Control (Transport Strategy) 23rd November 2001 Memo from Environmental Assessment Officer (Transport Strategy) November 2001 Memo from Principal Landscape Architect 20th November 2001 Memo from Built Form Manager 20th November 2001 Memo from County Archaeologist 12 November 2001 Memo from Development Minerals and Waste Group 16 November 2001
Environmental Statement submitted as part of each application, comprising:
Volume 1 Planning Statement Volume 2 Environmental Impact Assessment (plus 2 appendices) Volume 3 Landscape Impact Assessment Volume 4 Transportation Assessment Volume 5 Architectural Design and Landscape Statement
Volume 6 Economic, Social Impact and Business Case Summary Volume 7 Executive (non technical) summary