MUNICIPAL YEAR 2006/2007 REPORT NO.

MEETING TITLE AND DATE: AGENDA – PART: 1 ITEM: Planning Committee SUBJECT: 11 th July 2006 Application reference: TP/06/0735 submitted by Tottenham Hotspur FC REPORT OF: proposing the construction of a football training centre at land to the rear of

Assistant Director Myddelton House, , Enfield (Planning & Transportation)

Contact officer: David Snell

REPORT CONTENTS

Section Page

Recommendation 1

Note for Members 4

1. Site and surroundings 4

2. Proposal 5

3. Relevant planning decisions 6

4. Consultations 7

4.1 Public 7 4.2 Groups and Associations 13 4.3 Statutory consultees 18 4.4 Conservation Advisory Group 19

5. Relevant Policy 20

5.1 The Plan 20 5.2 Unitary Development Plan 21 5.3 Interim UDP Amendments 22 5.4 Other material considerations 22 5.5 Relevant National Planning Policies 22 5.6 National and local sports policy 22

6. The Applicant’s submissions in support of the application 23

7. Analysis (Officers) 29 8. S.106 Agreement 42

9. Conclusions – reasons for recommending that planning permission be granted 43

1 Appendix 1 Comparison of the training facilities of other football clubs that have been permitted in the Green Belt

Appendix 2 Minutes of the Planning Panel

Appendix 3 The response of the applicant to Planning Panel questions

Appendix 4 Application site location plan

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MUNICIPAL YEAR 2006/2007 REPORT NO.

MEETING TITLE AND DATE: AGENDA – PART: 1 ITEM: Planning Committee SUBJECT: 11 th July 2006 Application reference: TP/06/0735 submitted by Tottenham Hotspur FC REPORT OF: proposing the construction of a football training centre at land to the rear of

Assistant Director Myddelton House, Bulls Cross, Enfield (Planning & Transportation)

Contact officer: David Snell

Recommendation: That subject to the completion of a S.106 Agreement to secure the establishment, management and funding of the Community Programme, Including funding of any appropriate capital schemes, funding for highway and traffic control measures, a Green Travel Plan and a site management/car parking management plan as detailed in Section 8 of this report, any modifications and additions required to the conditions set out in the recommendation, and subject to the views of the Government Office for London and any direction of the Mayor for London, the Assistant Director (Planning & Transportation) be authorised to grant planning permission, subject to the following conditions:

1. C7 Details of materials

2. C9 Details of hard surfacing

3. C12 Details of parking and turning facilities

4. C13 Details of loading, unloading and turning facilities

5. Details of all means of enclosure, including ball stop netting shall be submitted to and approve in writing by the Local Planning Authority before that part of the development is commenced. The works shall thereafter be implemented and maintained in accordance with the approved detail.

Reason: To ensure a satisfactory appearance having regard to the Green Belt location.

6. C17 Details of landscaping

7. Prior to the commencement of the development details of measures to protect existing trees and hedgerows shall be submitted to and approved by the Local Planning Authority. The approved measures shall be introduced prior to the commencement of works and shall be maintained throughout the building period.

Reason: To protect existing planting in the interests of amenity.

8. C14 Details of access and junction

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9. C16 Private vehicles only parking areas (insert ‘,coaches and mini buses’)

10. C19 Details of refuse storage

11. C30 Restriction on open storage

12. C46 No subdivision

13. C48 Restricted use (Sports Training Facility within use Class D2)

14. The development shall not commence until a summer survey and a further detailed assessment of the impact of the development on bats and bat roosts has been completed and this together with a scheme of mitigation has been submitted to and approved in writing by the Local Planning Authority. The scheme of mitigation shall thereafter be implemented in accordance with the approved detail.

Reason: To ensure that the development does not adversely impact on bat habitats.

15. The development shall not commence until details of the proposed energy efficiency and renewable energy measures consistent with the agreed strategy to incorporate either the combined heat and power plant and associated infrastructure with ground source heat pumps, or the tri-generation plant and associated infrastructure with the biomass boiler have been submitted to and approved in writing by the Local Planning Authority. The applicant should demonstrate the carbon dioxide savings from the energy efficiency measures and demonstrate that the renewable energy technologies reduce carbon emissions by at least 10%. The applicant should also demonstrate that the power heating and cooling infrastructure is incorporated. The approved details shall thereafter be implemented and retained unless otherwise agreed in writing by the Local Planning Authority.

Reason: In the interests of sustainability having regard to the sustainable design and construction policy of the Council and Policies 4A.7 – 4A.9 of the London Plan.

16. C57 Sustainability (Sustainable Design and Construction Assessment received 12 th April 2006)

Reason: To comply with the Council’s adopted Sustainable Design and Construction Policy.

17. Surface water drainage works as identified in the Flood Risk Assessment (Buro Happold, April 2006, 009294 Final Rev 01) shall be carried out in accordance with details that shall be submitted to and approved in writing by the Local Planning Authority before the development commences. Reason: To prevent increased risk of flooding.

18. Surface water source control measures, as identified in the Flood Risk Assessment (Buro Happold, April 2006, 009294 Final Rev 01) shall be carried out in accordance with details that shall be submitted to and approved in writing by the Local Planning Authority before the development commences.

4 Reason: To prevent increased risk of flooding and to improve water quality. 19. A five metre buffer zone shall be provided alongside the full length of all drains and ditches on the site. The zone shall be measured from the top of the bank, and shall be free of structures, hard standing and fences. Formal landscaping shall not be incorporated into the buffer zone which shall be left as a natural area for wildlife.

Reason: Buffer zones along watercourses are important for maintaining and/or enhancing the natural character of the water course and providing undisturbed refuges for wildlife using the river corridor.

20. The development shall not commence until the applicant has secured a programme of archaeological work, in accordance with a written scheme of investigation, which shall be submitted to and approved in writing by the Local Planning Authority.

Reason: To prevent undue damage to archaeological remains.

21. The development shall not commence until details of the number and design of the cycle parking spaces have been submitted to and approved in writing by the LPA. The approved details shall thereafter be installed and permanently retained for cycle parking.

Reason: To ensure the provision of cycle parking in line with the Council’s adopted standards.

22. That development shall not commence until a construction methodology has been submitted to and approved in writing by the LPA. The construction methodology shall contain:

i) a photographic condition survey of the roads, footways and verges leading to the site ii) details of construction access, associated traffic management and vehicle routing to the site iii) arrangements for vehicle servicing and turning areas iv) arrangements for the parking of contractors vehicles v) arrangements for wheel cleaning vi) details of the site compound and the layout of temporary construction buildings vii) arrangements for the storage of materials viii) hours of work

The development shall then be undertaken in accordance with the approved construction methodology unless otherwise agreed in writing by the Local Planning Authority.

Reason: To ensure the implementation of the development does not lead to damage to the existing highway, to minimise disruption to neighbouring properties and to safeguard the amenity of the Green Belt.

23. Before the development hereby permitted is occupied and the facility is brought into use the highway works and measures detailed on drawing number N40434_09 Revision A or an alternative scheme approved in writing by the Local Planning Authority shall be implemented.

5 Reason: In the interests of maintaining safety on the adjoining highway. 24 Prior to the installation details of the detailed design of the floodlighting shall be submitted to and approved in writing by the Local Planning Authority. The approved detail shall thereafter be implemented and maintained.

Reason: In the interest of appearance and amenity.

25. The football pitch floodlighting shall not operate beyond 21.00 hours on any day unless otherwise agreed in writing by the Local Planning Authority.

Reason: In the interest of the amenity of the Green Belt, ecological interests and the amenity of surrounding residential occupiers.

26. Prior to installation details of any external lighting, including hours of operation proposed shall be submitted to and approved in writing by the Local Planning Authority. The approved detail shall thereafter be implemented and maintained.

Reason: In the interest of the amenity of the Green Belt, ecological interests and the amenity of surrounding residential occupiers.

27. Prior to its installation details of the artificial pitch covering shall be submitted to and approved in writing by the Local Planning Authority. The approved detail shall thereafter be implemented and maintained.

Reason: In the interest of appearance and amenity.

28. Prior to the commencement of works to erect the Academy building the existing sports pavilion shall be demolished.

Reason: To enhance the setting of Myddelton House and in the interests of the openness of the Green Belt.

29. C51A Time limited permission

Note for Members

The application follows from the previously withdrawn application TP/05/1741. The application was the subject of a Planning Panel held on the 5 th June 2006. The minutes of the meeting are attached as Appendix 2 to this report. The applicant’s have set out their responses to the questions asked in a letter dated 26 th June 2006 this is attached as Appendix 3.

1. Site and surroundings

1.1 The Academy and First Team facilities would be accommodated on 23.4 ha of land to the north and east of Myddelton House, Bulls Cross and to the south of Whitewebbs Lane comprising existing sports fields and agricultural land. The site currently comprises 9.3 ha of existing sports pitches used by the applicant and 14.1 ha of agricultural land.

6 1.2 The site is bounded to the north by sports grounds with an associated sports pavilion and residential, properties fronting Bulls Cross and Keepers Cottage, to the east by Myddelton House (a grade II listed building) and an office building which is under construction, to the south by woodland (Archers Wood) and (a grade I listed building and its associated parkland) and to the west by Whitewebbs Lane.

1.3 This site lies within the Metropolitan Green Belt, a designated Area of Special Character and partly within the Conservation Area.

1.4 The topography of the site is generally flat but the land slopes gradually to the south towards Turkey Brook.

1.5 A site location plan is attached as Appendix 4.

2. Proposal

2.1 Construction of a football training centre involving erection of a building to provide football academy facilities with indoor football pitch, together with a total of 12 ½ external pitches (1 x floodlit grass, 1 ½ x floodlit artificial, 10 x grass), installation of mesh fencing and associated pathways, together with erection of groundsman’s store, entry lodge with barrier and electricity sub- station. Construction of an access road off Whitewebbs Lane with associated car and coach parking, and landscaping.

2.2 The Academy building would comprise 11, 806 sq.metres of floor space. The building would be sited towards the northern half of the centre of the site.

2.3 The Academy building would form a reversed L shaped block comprising two flat roofed wings 8 2 metres in height surrounding the indoor football pitch dome which rises to a height of 10.5 metres.

2.4 The site would be accessed via a new access road off Whitewebbs Lane past a small security lodge building (52 sq.m) and control barrier. Two car parks are proposed, one to the north of the building and one to the Academy to the west of the building. The car parking proposed is 98 spaces (including 9 disabled spaces). The proposed structured reinforced overflow parking provision on the western boundary of the site has been omitted.

In addition 5 coach parking spaces are proposed.

2.5 The building would accommodate the following facilities:

Basement

Indoor pitch, changing rooms and plant

Total 4,592 sq.m

Ground Floor

Reception Changing rooms

7 Gym and medical treatment area Laundry Away Team Changing rooms First Team medical treatment and pool area First Team and coaches changing area First Team gym Press areas First Team reception

Total 4,029 sq.m

First Floor

Academy offices/admin Community offices/admin Academy education area Kitchen, dining and recreation area Plant First Team offices/admin First Team tactics areas

Total 3,185 sq.m

Overall total 11,799 sq.m

2.6 A groundman’s store building accommodating, a plant vehicle storage area, store, locker rooms, kitchen/dinner, office and irrigation pump room is to be located in the southeast corner of the site. The building would comprise 605 sq.metres of floor space and would be 4.2 metres in height. Adjoining this building would be located two irrigation water storage tanks. The site will be maintained via a structured route around the site and pitched and buildings. A small entry lodge building (52 sq.m) would be located near the northern boundary of the site.

2.7 The existing sports pavilion sited to the west of Myddelton house is to be demolished. The associated existing tennis courts will also be removed.

3. Relevant planning decisions

3.1 The site

3.1.1 None.

3.2 Relevant decisions relating to football training facilities in the Green Belt

3.2.1 There have been a number of planning applications and appeals relating to football academy development in the Green Belt over recent years as follows:

i) Chelsea FC were granted planning permission for a combined First Team Training Centre and Academy on the former Imperial College Sports Ground site at Stocke D’Aberon, Elmbridge BC. The application was dated 15 th October 2004.

8 ii) Sunderland AFC were refused permission by Tyneside MBC for a combined First Team Training Centre and Academy at Whitburn Moor Farm following a Public Inquiry the Secretary of State granted planning permission. The decision was dated 2 nd February 2000.

iii) Derby County FC were granted planning permission by the Secretary of State on appeal for a Football Training Centre and Academy at Moor Farm, Erewash District Council. The decision was dated 13 th August 2001.

iv) Manchester United FC First Team Football Training Centre at Carrington, Trafford MBC. Planning permission was granted and on referral the Secretary of State declined to call-in the application. The decision was dated 7 th November 1997.

v) Arsenal FC First Team Training Centre at London Colney, Hertsmere DC. Planning permission was granted and on referral the Secretary of State declined to call-in the application. The decision was dated 7 th July 1998.

vi) Aston Villa FC planning permission was granted for a combined training centre in October 2005

vii) Planning permission was refused in February 2003 by Epping Forest District Council for a football academy proposed by Tottenham Hotspur FC at Epping Lane, Theydon Mount. This decision was not the subject of an appeal.

3.2.1 Relevant aspects of these cases are discussed further in the ‘Appraisal’ section of this report.

4. Consultation

4.1 Public

4.1.1 Consultation on the application has been undertaken in the form of approximately, 485 letters to the public, notices in the press and notices posted in the vicinity of the site on Whitewebbs Lane and Bulls Cross.

4.1.2 595 letters of objection have been received.

The responses include 94 proforma letters from residents of Enfield and 13 from elsewhere objecting to the proposal in the following terms:

I object to the proposals by Tottenham Hotspur Football Club to develop land west of Bulls Cross on the grounds of inappropriate development within the Green Belt and Conservation Area

The responses include 347 proforma letters from residents of Enfield and 33 from elsewhere which object to the proposal in the following terms:

I object to the development on the grounds that it is:

9 • Inappropriate development in the Green Belt and Area of Special Character. If this application were to go ahead, the excavations needed to provide footpaths, road, drainage for all pitches plus all weather pitched would cause irreparable damage to the land. This development is now for the sole use of THFC and their guests. The erection of a three storey building, large enough to house a full size football pitch, an entry lodge, electricity sub-station etc. plus ancillary works such as the floodlighting, fencing, road and parking system make this application unsuitable for this location. • Change of Use. This development is a change of use from Green Belt/conservation/historic interest land to brownfield, which would lead the area open to full development. • Damage to the environment. Due to the proposed loss of farmland in the Green Belt and disruption to wildlife this development would cause adverse effect on the local environment. • Traffic Congestion. This area is already heavily congested. Whitewebbs Lane is very dangerous. Accidents cause the road to be frequently closed. It is also gridlocked every weekend. To allow THFC to have vehicle access to this road will compound the problem.

The responses include 39 proforma letters from residents of Enfield objecting to the proposal in the following terms:

• THFC have not shown that other sites are not suitable • The land is special because of its designation as Green Belt, Special Character and its location next to a Conservation area, listed buildings and historic estates • The development will seriously disturb and in some cases displace wildlife including rare bats • The access of Whitewebbs Lane is dangerous • The development would be contrary to PPG 2 and PPG9 • The development will detract from views from the surrounding area and public footpaths • The could be damage to water supply which may cause subsidence and damage to ancient woodland • This is a commercial development not a sports facility that benefits many

The responses include 67 individually written letters from residents of Enfield and 2 from elsewhere raising the following objections:

Green Belt issues

• Invasion of the Green Belt and inappropriate change of use of the land • Inappropriate development in the Green Belt contrary to the UDP, London Plan and PPG2 • The building would compromise the permanents and openness of the Green Belt • Green Belt should not be developed for commercial purposes • The use is not recreational and should not be permitted in the Green Belt • There are no special circumstances by which the development should be permitted • Detriment to the rural character of the area

10 • The level of hard surfacing, access road, parking area and synthetic pitches will be of further detriment to the Green Belt • Major threat to the Green Belt • The development would detract from the open character of the Green Belt • Contrary to UDP Green Belt policy and PPG2 (scale of buildings and visual amenity) • Contrary to UDP policy in respect of the Area of Special character in that the form of development is at variance with the natural form of the landscape • Hedges will be no replacement for the loss of agricultural fields • The reasons for refusal of the previous application for development on Bulls Cross Open Space are as appropriate to the current application as they were 26 years ago, in fact more so, on account of the ever increasing pressure on the Green Belt • Detriment to the integrity and well being of the rural landscape • Commercial development in the Green Belt should not be permitted • Alternative sites have only been rejected because of cost

Conservation issues

• Inappropriate development in the conservation area • The proposals do not “preserve or enhance” the conservation area • The development would be contrary to the Conservation Area Character Appraisal • The proposals detract from rather than enhance the conservation area • Major threat to the conservation area • The boundary treatment proposed on the Myddelton House boundary would be an eyesore and of detriment to the garden • Adverse impact on the hamlet of Bulls Cross • Impact on heritage trail from Forty Hill Park to Whitewebbs Lane • The building would be a totally inappropriate structure in the historically significant Area of Special Character • Ancient woodland would be in danger from water borehole extraction

Design issues

• Design of the buildings is out of character with the environment • Excessive scale of building • The design and massing of the buildings is unsuitable in this location • Industrial looking high tech building would be out of character with its surroundings

Traffic issues

• Increased traffic on Whitewebbs Lane, Bulls Cross and Lane which is already a dangerous road • Additional coaches and mini buses using local roads • Lack of public transport routes to the site • Impact of traffic on the Manor Farm Road area • There are existing coach and lorry restrictions applicable to Whitewebbs Lane and Bulls Cross

11 Amenity issues

• Use of floodlights should be restricted to 20.00 hours to reduce light pollution • Floodlighting in the western part of the site will have a significant impact on the most sensitive area of the site • Loss of open outlook • Increased noise and nuisance • Adverse impact on the peace and tranquillity of the area that residents have a right to enjoy • The use of the facilities would intrude on the local rural environment • Artificial pitches, fences and floodlighting would be out of character

Wildlife issues

• Adverse impact on wildlife • The area is a habitat for large numbers of bats and the development would result in a moderate level of disturbance to the bat population • It is recommended that a bat survey be carried out to determine impact and what mitigation measures should be taken. • Impact on bird habitats

Other issues

• Loss of pre-school facility which occupies the existing sports pavilion • The land allocated for housing at Innova Park would be a more appropriate site • A similar application was refused by Epping Forest District Council • Disruption during construction • If pitches are used for competitive matches additional parking should be provided • The development is not sustainable • Impact of high water usage on the water table and ecology. Using water from the Aquifer could affect future water supplies • Loss of right of way/access over the site that has been enjoyed for many years contrary to S.53 of the Wildlife and Countryside Act 1981 • Adverse impact on Keepers Cottage including impact on access to that property • The reasons given for rejection of alternative brown field sites are not satisfactory • The Green Belt of the borough should be reserved for the enjoyment of residents not an external football club • The community benefit would benefit only the gifted not the community • Loss of farmland

A petition signed by 63 residents of Enfield and 113 from elsewhere objects to the proposal in similar terms.

Members are advised that a large volume of correspondence objecting to the proposal has also been received by the Leader of the Council Councillor Michael Rye. Councillor Rye has responded advising that the application falls within the remit of Planning Committee and that he is not involved in the decision making process for planning

12 applications. In responding Councillor Rye advised writers to forward their objections to the to the Council’s consultation on the application. A proforma letter has been received by Councillor Rye from 26 residents of Enfield and 6 from elsewhere requested that their objections be forwarded to the Planning Committee. The grounds of objection are as follows:

• There are no special circumstances that would deem the commercial development acceptable • The area has historic significance and has been recommended for inclusion in the conservation area • There is a public right of way across the land • To house the community outreach programme in the proposed building will have no benefits to the local community

Members are advised that a large volume of correspondence objecting to the proposal, including that sent to the Councillor Rye has also been received by the Chairman of Planning Committee Councillor Prescott. Councillor Prescott has responded to the effect that he must remain impartial until Planning Committee consider a report on the planning application. He advised writers that they should sent their objections to the planning application consultation, if they had not already done so.

4.1.3 259 letters of support for the development have been received.

The responses include 176 proforma letters of support for the development from persons that are residents of Enfield and 36 from elsewhere , in the following terms:

I am writing to register my support for the latest planning application submitted by Tottenham Hotspur FC for the development of a football training centre at Bulls Cross, Enfield.

The revised plans demonstrate that the Club has listened to the views of local stakeholders and, in my own view, will deliver a much improved scheme. My reasons for supporting the revised application are as follows:

• The revised design of the training centre will create a building of significant architectural merit. • The reduction of the training centres footprint by 900 sq.m and the reduction in hard surfaces such as car parking areas will further reduce its impact on the landscape. • The revised plans enhance the sustainability of the training centre through the greater use of renewable energy. • The site selected by the Club is an appropriate location for a football training facility. It has been used for sporting activity for the past 120 years, and for the last three years has been used by the Club’s Academy. • The plans will deliver a major community programme for the Borough of Enfield that will benefit thousands of local school children through the provision of first class sport and learning opportunities.

I believe that the Club’s proposed training facilities will be a major asset for Enfield.

13 The responses include 39 individually written letters of support from residents of Enfield and 8 from elsewhere raise the following points:

Comments relating to the scheme

• It will enhance the area • The Green Belt is not a no go area for development. Strict controls are merely in place to stop unnecessary sprawl. • The proposal is sympathetic to its location and they would have minimal effects on the environment • The centre will not be an eye sore as most of the site will be kept open as playing fields with enhancements to the setting of Myddelton House • The site is an ideal location for the sports development • Amendments to the application have reduced the impact on the landscape • The building now proposed is smaller and more eco friendly • The building now proposed has significant architectural merit and it is more sympathetic to its surroundings • Impressed with the way Tottenham Hotspur have considered the environment and residents and adapted their plans

Comments relating to the Community Programme

• The community programme will enable the young people of Enfield to enjoy a unique sporting experience which is not available elsewhere in the borough • Sport is a fantastic activity for the youth of our country and should be encouraged at all times • The Community Football Programme will benefit thousands of school children • Access to the facility will provide a real boost to schools and community organisations committed to ensuring that the young people of Enfield have the best chance of achieving their goals and ambitions • Tremendous opportunity for the borough and its residents bringing Enfield into the fore of sporting development and culture • Benefit to the community and its youth • Now that the Bulls Cross Open Space proposals are not included there is no logical reason to refuse the application • The application submissions prove that it will cause minimum disruption • It will be a major asset to Enfield • This is not about building a supermarket on fields but it is about the future of sport in the Borough for generations • The existing successful community programme run by the Club on the Ferry Lane Estate in Haringey is an example of what could be achieved in Enfield

Other points

• The proposal will create many new jobs in the local area • The application represents a tremendous opportunity for Enfield

The Headteacher of Suffolks Primary School, Brick Lane, Enfield supports the proposals.

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The Headteacher of Edmonton County School supports the proposals commenting that her staff have attended a recent briefing session and they are keen to get involved in the community programme. This kind of programme greatly supports the work at the school. The ‘Every Child Matter’ national agenda is about pupils becoming rounded adults with a positive attitude to learning and a healthy and safe approach to life. Any sport activity which teaches self-discipline, positive teamwork and responsibility towards others will contribute significantly to the growth of the youngsters involved.

A teacher of Eastfield, Primary School, Eastfield Road, and a resident supports the proposal and advises that Eastfield School has benefited greatly from THFC’s Community Football Scheme.

6 letters of support have been received from football coaches working in the Club’s community training programme.

4.2 Groups and Associations

4.2.1 The Green Belt Forum is fundamentally opposed to the proposal Football Academy. There are no substantiated special circumstances for a development of this magnitude in the Green Belt. The development is inappropriate and out of character with this historic and pastoral setting of Area of Special Character.

4.2.2 Enfield Preservation Society welcome the omission of the Community Partnership Building at Bulls Cross Open Space, but otherwise they find the changes relatively minor and the objections detailed in their letter of 4 th December 2005 stand. The proposed development in the Green Belt is contrary to national, London Plan and UDP Policy as follows:

• The proposal does not promote the beneficial use of the land in relation to green belt objectives and does not secure environmental improvement • It exacerbates the conflict of the land use of the garden of listed Myddelton House and adjoining sports pitches by intensifying the density, extent and impact of the pitches • It does not promote public access • It only meets one of the six objectives for the use of green belt land detailed in PPG2 namely to provide opportunities for outdoor sport and recreation. The balance is very mush contrary to achieving the objectives: To provide access to the open countryside for the urban population; and To retain attractive landscapes and enhance the landscape near to where people live; and to secure nature conservation interest; and to retain land in agriculture, forestry and related uses. • The development is inappropriate development in the Green Belt providing more than essential facilities for outdoor sport contrary to PPG2 and UDP policy. It contains administrative offices and an indoor sports hall and must be considered wholly inappropriate. It does not reflect the best aspects of the existing area nor does it have general compatibility with adjoining properties as required • The inappropriately large buildings and high lighting columns, paths, fences, ball stop fences and artificial surfaces injure the visual amenity of

15 the Green Belt and cannot be counteracted by reinstating or planting a few hedgerows • The development is contrary to PPG2 in that it should have no greater impact than the existing development on the openness of the Green Belt and the purposes of including land within it and where possible less. It should not exceed the height of the existing buildings or occupy a larger area of the site. PPG2 warns against the adverse impact on the character of the Green Belt of dispersal over a larger part of the site compared to current development. In this case the development is brought into the agricultural western part of the Forty Hill estate • The development is contrary to the UDP in that it damages the appearance of the Area of Special Character • The proposals do not fulfil the statutory requirement and the requirement to preserve or enhance the character of Forty Hill Conservation Area. The planting of hedges, although welcome, is no substitute for the open bird feeding and nesting grounds on the parts of the site which are not currently pitches • The existing maize growing area at the north west corner of the site, valuable to wildlife would be lost • The woodland to the south is a grade 1 site of importance for nature conservation. The fields and woodland are important habitats for bats, birds and small mammals, including birds on the list of high conservation concern • The proposed floodlighting would be intrusive and stray light is a pollution concern and an evening cut off time is not stated • The proposal will increase traffic on local roads and the A10 • The conclusions of the applicant’s Landscape Assessment fly in the face of its findings. The proposals are not similar to the pitches that already exist, many are artificial or surrounded by fences and lighting columns, compared to the uncluttered state of the existing pitches. The assertion that the man modified landscape does not display the man attributes of the Area of Special Character are contested and it is disingenuous to claim that the proposal will not damage its character and appearance • It is ludicrous for the applicant to describe the development as neutral or minor, by any reasonable criteria the development must be considered significant and harmful

4.2.3 Forty Hill and Bulls Cross Study Group object to the proposal and raise the following concerns:

• The proposal represents a departure from the UDP Green Belt policies and PPG2. The development would fail to contribute to Green Belt objectives. • The Council must be satisfied that the alternative sites has been assessed correctly. • The proposal is also contrary to the UDP in that it requires the protection and enhancement of the Area of Special Character. • The proposal is contrary to the UDP in that seeks to protect the character and interest of the historic landscape. The site is a rare survival of a deer park and pre-enclosed land. • The proposal is contrary to UDP policy which seeks to protect the curtilages of historic buildings and views from them which will be further intruded upon when floodlights are in operation. It will degrade the character of the historic estates.

16 • The development will conflict with the existing pattern of development and give an urban feel to a currently agricultural area. • The intensity of use of the site will lead to increase disturbance, noise and traffic. • The use of the site will be detrimental to the enjoyment of users of the adjacent public footpath network. • By its nature, design and location the development is inappropriately located and contrary to UDP policies • The scheme will have a significant negative impact by introducing many alien and out of character features such as fencing and barriers, swales, specialist grass surfaces, artificial surfaces, fencing, floodlighting and bunds. • The site is of ecological significance and no suitable mitigation measures have been identified in the application. • The majority of the site is Forty Hill Farm which is managed as an organic farm under the Countryside Stewardship Scheme. This best practice will be lost if the schemes goes ahead. • The proposed access is unsafe and the change to the character of the road by the introduction of the access and street furniture will produce an urban feel to a country lane. • The Group would like confirmation that security measures (CCTV) will not be an extensive and intrusive form of development. • The Group raise questions about the long term sustainability of the development should the status of the club change • The cumulative harm from the proposals far outweighs the special circumstances claimed by the applicant. • There is only a 10 year commitment to the community programme and no firm management plan. • The Arsenal precedent is much smaller and the building is adjacent to an industrial estate. There is currently no indoor pitch and the site is kept open and is devoid of fencing. The Sunderland and Derby facilities are farmsteads and are adjacent to urban residential houses. These are different situations to this application site. • Users of Forty Hall Park and the local footpath network will have their enjoyment impacted upon by a reduction in open views. • The travel plan is inadequate and insufficient.

4.2.4 The Hertfordshire & Bat Group points out that the area contains many bats, in particular they know of a bat roost at Myddelton House. Apart from the building work, the proposed floodlights would certainly be a cause of disturbance to bats. It is essential that a bat survey be carried out in order to obtain a DEFRA licence for the development, which may specify various mitigation measures.

4.2.5 The Federation of Enfield Residents and Allied Associations (FERAA) consider that the development is inappropriate in this Green Belt location adjacent to the Forty Hill Conservation Area. This has recently been the subject of a Character Appraisal which stresses the rural nature of the area. The parking provision for 90 cars and 5 coaches implies that there will be considerable traffic movement which is not acceptable along narrow lanes. The flood lights and fences are proposed and when viewed from the surrounding countryside this would give the impression of a ‘Stalag’.

17 Fox Lane & District Residents Association have advised that the above comments incorporate their views.

4.2.6 Friends of Forty Hall Park object to the proposal on the following grounds:

• It will represent the break up of the historic Forty Hall Estate that has been ‘complete’ for 300 years (and part of Elsyng Palace before that) • The proposal will detrimentally effect the views from the adjacent footpaths • The scheme will effect the ongoing restoration and enhancement of the landscape grounds of Forty Hall. Projects such as opening up the vista from the grade 1 house along with the avenue of limes beyond Turkey Brook will have to be abandoned, as this development will have a negative impact on the view (the proposed location is already visible from several locations near the Hal) • For these reasons the proposal is inappropriate and harmful in this location.

4.2.7 Willow Residents Association r aise the following:

• Additional traffic over Maidens Bridge past the existing school • The junction at Bullsmoor Lane, the next corner and the twisting lane are narrow for coaches • Extra traffic using Bullsmoor Lane • Already a lot of construction traffic in the area arising from the Holmesdale Tunnel works and factory development beyond • Will the parking be adequate? • We are in favour of an Academy for youngsters to play football etc. especially if it keeps them off the streets, out of trouble and fit • We do not want further increase of traffic in Willow Estate or Baker Street the smaller roads are already used as a rat run

4.2.8 Action Group Association raise the following objections:

• Buildings and additional land loss is not in accordance with the Green Belt status or rural nature of the area • The area has been the subject of a Conservation Area Appraisal to place such a commercial venture in the area is totally untenable • It will result in increased car and coach traffic on already slow roads due to their restricted nature • Innova Park would seem to be a more appropriate venue

4.2.9 Enfield Local Football Partnership would not support the development in isolation but strongly supports the development which will provide Community Football Facilities. This will enable football to be more accessible to all sections of the community. The presence of Tottenham Hotspur in the borough will raise the profile of football and inspire those with an interest. The building and structures appear to be in proportion to their setting and well designed. Pending a decision on the location of the Community Facility a S.106 contribution equivalent to the capital cost of the previously proposed Bulls Cross facility should be sought.

4.2.10 The London Green Belt Council objects to the proposal for the following reasons:

18

• Very special circumstances have not been proven notwithstanding that cases of a similar nature in other parts of the countryside present evidence to the contrary. It is inappropriate development that has no justification • The land is Green Belt, Area of Special Character and Conservation Area How many designations does it need to have in order to be protected? • The provisions of PPG2 alone should be sufficient protection against inappropriate development • The development fulfills none of the aims of the Green Belt • The historic estates surrounding the site preserve between them some of the last relics of the historic landscape north of London • The proposal is a commercial development no matter how “green” it hardly constitutes the small changing facilities and unobtrusive spectator provision described in PPG2 • The land is not a major development site • Evidence of other similar developments in the Green Belt elsewhere have been cited. But are they similar?. All have one remarkable similarity in that the Secretary of State did not see the need to call in the applications with the exception of Sunderland which was allowed on appeal. The views of the Secretary of State cannot be taken without argument. The present government, as all previous governments, continue to publicly support the Green Belt and its continued protection unequivocally • London has 10 major football clubs and if they all have the same academy ambitions then we can look forward to a loss of about 200 ha of 486 ha (41%) of Green Belt around London • If we accept football academies we must accept other sports of Olympic status putting further strain on the Green Belt • The very special circumstances do not outweigh the demonstrable harm and Enfield should not be beguiled by the blandishments of the applicant or be led by decisions in other parts of the country • Every application should be considered on its merits and here we have a unique situation which should be preserved

4.2.11 The Myddelton House Society object to the proposal on the following grounds:

• The water usage of the site will exceed that which can be collected or recycled, use of boreholes will have a significant impact on the water table and ecology • A 2 metre high fence is proposed cutting through the curtilage of the listed building and heritage garden. This will be to the detriment of the garden. At present there a tall hedge on the boundary and confirmation is required that this will not be removed • The efforts THFC have gone to to recognise the heritage importance of Myddelton House is appreciated but the two pitches to the east of the house are too close and should be omitted • Noise from the site will be to the detriment of the peaceful enjoyment of the gardens • Fencing and ball stop fencing will be intrusive when viewed from the garden

4.2.12 The Enfield Sports Advisory Council comment that the land has long been

19 under the control of the LVPA and the use of the pitches is at the discretion of the authority. They have not been available for public hire so there will be no loss of public recreation facilities and the ESAC has no grounds for opposing the application. It is understood that the Community Partnership Facility is now to be built elsewhere in the Borough. On the assumption that THFC would control this facility the ESAC would oppose it. The facility is unlikely to be available to the public generally but would have as its prime objective spotting talent in schools for the benefit of THFC. As such it would be elitist and would probably exclude girls. If planning permission is granted THFC should make a S.106 contribution to grass roots football in the community to fund improvements to public football facilities across the borough.

4.3 Statutory consultations

4.3.1 The Mayor of London has a statutory remit in connection with the application by virtue of the strategic importance of the Green Belt and the size of the site. The Mayor has the authority by virtue of the Town and Country Planning (Mayor of London Order) 2000 to direct refusal of the application.

The Mayor has concluded that whilst a robust ‘very special circumstances argument has been made to justify the inappropriate development of the Green Belt the Mayor requires the applicant to make a stronger commitment to ensuring that the development also delivers significant benefits to the community.

The previous scheme included the provision of a new, dedicated community sports facility which does not form part of the current proposal. The current scheme must also include an equivalent commitment to the development of community facilities in Enfield. Accordingly, Enfield Council should seek an appropriate financial contribution to be put towards the development of community facilities. This should be agreed and secured via a S.106 Agreement before the application is referred back to the Mayor for further consideration. In addition the Mayor seeks further assurance that the Club’s activities will not unduly inhibit the use of the facilities for the proposed 20 hours per week.

The level of parking currently proposed is unacceptable both in Green Belt terms and in respect of the Mayor’s overarching sustainable transport objectives. Further thought should be given to how the two distinct parking areas can be managed more effectively, negating the need for overflow parking and reducing the overall quantum of parking as a whole. TfL cannot support the claim that the development will have an acceptable impact on the TfL road network from the information provided and requires further assessment of the impacts on the A10 Bullsmoor Lane junction, in line with the TfL modelling guidelines.

Given the poor level of public transport accessibility the preparation of a robust travel plan is essential to maximise the use of more sustainable transport options.

Two potential options for delivering the Mayor’s energy policies have been put forward and both are consistent, in principle with London Plan policies. Conditions are suggested which would enable the necessary technical work

20 to be carried out during the detailed design phase and ensure the adoption of the most suitable scheme.

Conditions should be imposed to ensure that the proposed sustainable design measures and the proposed landscape master plan are implemented.

4.3.2 The Countryside Agency does not consider that the application affects any priority interests of the Agency within and accordingly they do not wish to make formal representation. This response is neutral and neither supports or objects to the proposal.

4.3.3 English Heritage comment that the current application represents a significant reduction from the previous proposal. The main building has also been redesigned in an attempt to lessen the impact on the surrounding environment. The removal of the 1970’s sports pavilion is positive and improves the setting of the listed buildings, but the principal concern remains the intensification of semi-urban land on the wider setting of the conservation area.

The recently published LBE conservation appraisal summarises the issues affecting the conservation area, and specifically identifies the semi-urban character of municipal playing fields and the use of chain link fencing around open land and playing fields as detrimental to its character. The proposal will increase this sense of erosion into the wider landscape. Despite revisions to the design the proposal remains a very significant development into what is essentially a rural setting and in its wider context must be considered detrimental to the appearance and character of the conservation area.

The proposed development should also be viewed within the light of the recommendations for strengthening the management regime for the Forty Hall landscape and the possibility of extending the conservation area, as previously recommended by the Paul Drury Partnership.

4.3.4 The Environment Agency advise that the flood risk assessment is acceptable and raise no other objections subject to the imposition of conditions.

4.4 Conservation Advisory Group

4.4.1 The Group maintain their objection and consider that the revised proposal raise proposal does not address these.

• The proposal is inappropriate in the Green Belt and did not satisfy PPG2, (an unsuitable use not accessed by the general urban population, but is exclusive). Some of the uses and floor space in the building are not essential (in terms of supporting open recreational use of the land).

• It will not retain the agricultural landscape. The proposal is inappropriate in the Enfield Chase area of special character and detrimental to the Forty Hill & Bulls Cross Conservation Area. The municipal looking playing fields will have a detrimental impact on the locality. There will be 5m high ball stop fence behind the goals, 1m high fencing around each pitch and 2m high fencing around the site. It will have an urbanising effect. There will be line side seating. It will be visible from Forty Hall (the pitches will be

21 seen from Forty Hall at the end of the Lime Avenue. There will be light pollution, reflected light above the tree line and noise. The impact on the landscape will be contrary to the character of the rural hamlet of Bulls Cross. The landscape character assessment submitted with the application is considered to be wrong in places.

• It is detrimental to local ecology (water extraction). The fallow field is a wild life habitat.

• The design/mass is unsuitable and the aesthetics are alien. The car parks and sub-stations etc. associated with the pitches all introduce urban clutter, which will have a negative impact.

• The site is inaccessible to public transport.

• Brownfield sites have been rejected as uneconomic.

5. Relevant Policy

5.1 The London Plan

The following policies of the London Plan (GLA)- Spatial Development strategy for Greater London (2004) are also relevant:

Green Belt Policy 3D.8(Green Belt) Built Heritage Policy 4B.10 (London’s built heritage) Policy 4B.11(Heritage conservation) Urban Design Policy 4B.1(Design principles) Policy 4B.2 (Architecture & design) Policy 4B.4 (Enhancing quality of public realm) Policy 4B.7 (Respect local context/communities) Access Policy 4B.5(Creating an inclusive environment) Transport Policy 3C.2 (Development to transport capacity) Policy 3C.3 (Sustainable transport in London) Policy 3C.20(Improving conditions for walking) Policy 3.C21 (Improving conditions for cycling) Parking Policy 3C.22 (Parking strategy) Sport Policy 3D.5 (Sports facilities) Open space Policy 3D.7 (Value of open space) Biodiversity Policy 3D.12(Biodiversity/nature/conservation) Agriculture Policy 3D.14 (Agriculture in London) Air quality Policy 4A.6 (Improving air quality) Waste Policy 4A.2(Spatial Policies for waste) Sustainable design Policy 4B.6 (Sustainable design & construction) Policy 2A.1(Sustainability criteria) Energy Policy 4A.7 (Energy efficiency/renewable energy) Policy 4A.8 (Energy assessment) Water Policy 4A.11 (Water Supplies)

22 5.2 Unitary Development Plan

5.2.1 General development considerations

(I) GD1 Appropriate regard to surroundings (I) GD2 Improve environment in terms of quality life/visual amenity (II) GD1 New developments appropriately located (II) GD3 High standard of aesthetic and functional design (II) GD6/7/8 Traffic generation, parking standards, servicing requirements (II)GD10 Measures to ensure satisfactory integration into the community (II) GD11 Access for people with disabilities in all new developments

5.2.2 General Environmental Considerations

(I) EN1 Protect & enhance quality of environment (I) EN3 Regard to nature conservation (I) EN6 Minimise environmental impact of all developments (II) EN8 Nature conservation (II) EN10 All Developments, especially in Green Belt take account satisfactory retention, protection & enhancement of existing features (II) EN22 Encourage full use of energy conservation (II) EN30 Matters relating to pollution (II) EN33 Environmental assessment of developments

5.2.3 Conservation, Historic Buildings & Trees

(I) C1 Buildings/Landscape features of historic interest together with character and setting preserved/enhanced (II) C2 Archaeological assessment (II) C18 Ensure that curtilages of buildings of historic interest retain their form character & use (II) C19 Historic landscapes (II) C28 Development proposals within conservation areas don’t result inappropriate development (II) C30 New Buildings in Conservation Area replicate, reflect, or complement traditional characteristics of area (II) C31 Removal of features, which detract from Character & appearance of Conservation Area

5.2.4 Green Belt

(I) G1 Resist inappropriate development in Green Belt (I) G2 Seek improvement and enhancement of environment in Green Belt (II) G1 Resist in Green Belt except in very special circumstances proposals for new buildings for purposes not normally appropriate in Green Belt (II) G5 Restore, manage and enhance landscape of Green Belt (II) G6 Areas of Special Character (II) G11 New Developments in Green Belt do not act to its detriment (II) G12 Highway improvement in Green Belt incorporate suitable landscaping

23 5.2.5 Transport

(II) T13 Improvement of access (II) T14 Contribution for highway works (II) T16 Adequate access for pedestrians & people with disabilities (II) T17 Needs of pedestrians where they cross traffic routes (II) T19 Greater priority to needs & safety of cyclists (II) T20 Consideration to needs of cyclists in all road junction improvements (II) T32 Parking facilities take account of people with disabilities.

5.2.6 Open space

(II)O11 Loss of public open space

5.2.7 Planning obligations

(II)GD10 Integration of development into the community

5.3 Interim Unitary Development Amendments

(II) SDC1 Sustainable Design & Construction (II) T19 Cycle parking

5.4 Other material considerations

Forty Hill Conservation Area Character Appraisal (Emerging new document)

5.5 Relevant National Planning Policies

PPS1 Delivering Sustainable Communities PPS9 Biodiversity and Geological Conservation PPS 22 Renewable Energy PPG 2 Green Belts PPG 13 Transport PPG 15 Planning and the Historic Environment PPG 17 Planning for Open Space, Sport and Recreation

5.6 National and local sports policy

National strategy for sport entitled “A Sporting Future For All”.

Enfield Sports and Physical Activity Strategy 2005 to 2008.

24 6. The Applicant’s submissions in support of the application

The applicant has made submissions in support of the application which are detailed in the following section of the report. Officers analysis of the application follows at Section 7 of this report.

6.1 The need for the development

6.1.1 The applicant’s have submitted a statement as to their need for the development.

6.1.2 The provision of a top quality Football Training Centre is entirely consistent with the Football Association’s strategy and with the Government’s sports policy as set out in “A Sporting Future for All” and in PPG 17 which notes the valuable social and economic role of sport and how promoting sporting excellence can help foster civic and national pride.

6.1.3 The Club currently have a combined first team and academy facility at Spurs Lodge, Chigwell. This facility is of poor quality, particularly in terms of fitness training and medical support. The facility has to be supplemented by other facilities. Training is split between Spurs Lodge, White Hart Lane and Myddelton House and three privately owned gyms Esporta, Repton Park, David Lloyd, Chigwel and Holmes Place, Chigwell are also used by the Club.

6.1.4 The Club’s Youth Academy currently operates under a temporary license granted by the Football Association (FA) from Spurs Lodge, White Heart Lane and Myddelton House. These facilities fail to meet the FA’s licensing requirements in a number of respects including:

• Insufficient grass pitches for the number of age bands within the Academy

• Inadequate medical facilities • Inadequate changing facilities

• Inadequate homework and study areas

• No provision of indoor training facilities of an appropriate size

6.1.5 The club has been granted a temporary license extension by the FA due to the length of time it has taken to find a site for establishing the required facilities. If the Cub is unable to satisfy the licensing requirements it will lose its academy status.

6.1.6 The proposals would provide for:

• The integration of all training and support facilities on a single site in place of the current dispersed arrangements;

• The provision of a facility that provides the standard of training support and facilities needed comparable with the very best in Europe; and,

• The provision of a facility which will be a symbol of the Club’s commitment to excellence

25 6.1.7 At present the club has limited training and support facilities split between its Chigwell (Spurs Lodge) and White Hart Lane sites. The development would provide facilities that are vital to a modern training regime and which are typical of what is provided at the training centres of most leading English and European clubs.

6.1.8 Concentrating activity on one site the proposal would satisfy the needs of the club and requirements of the FA. It would also reduce the need for staff and players to travel between training sites. It would provide enhanced training facilities, including the provision of on-site fitness training facilities and medical support.

6.2 Site search

6.2.1 The Club submit that the application site has been selected following an exhaustive site search undertaken over a period of six years.

6.2.2 The existing training ground at Chigwell is not large enough to accommodate either the number of additional pitches or the size of building that would be necessary. An investigation carried out in 1998 into land surrounding the Chigwell site proved that there were insurmountable difficulties.

6.2.3 Agents were also instructed to search for a site, which could accommodate a self-contained Academy under the following parameters:

• Sites of at least 10 hectares;

• Within 5 to 7 miles of Spurs Lodge;

• Already in use as sports grounds or capable of such use subject to planning considerations.

6.2.4 This process identified 16 sites which were seriously investigated:

• Myddelton House, Enfield • Whitewebbs Sports Ground, Debden • Bank of Sports • • William Girling Reservoir • Redbridge Treatment Works • Ramney Marsh • Land adjoining Epping Golf Club • Land at Hobbs Farm • Deephams • Sports Centre • Epping Lane, Abridge • North Weald Airfield • North Weald Golf Club • Carterhatch Lane • Theydon Boss

6.2.5 Two options involving the use of previously developed urban land were seriously investigated. The New River Sports Centre was not large enough and the need for shared public use was unworkable. Deephams was

26 potentially large enough but had the benefit of planning permission for development and its commercial value was prohibitive.

6.2.6 All of the remaining sites were in the Green Belt and only one proved to be realistic either because of restrictive site area, shared use or site specific conditions (ground conditions flood risk etc).

6.2.7 The only suitable site, prior to the current option, land close to Abridge Village, was eventually refused planning permission by Epping Forest District Council.

6.3 Suitability of the application site

• Large enough to accommodate the facilities needed within a setting which enables an appropriately “collegiate” character of development to be achieved;

• Close enough to the Club’s White Hart Lane HQ;

• Satisfies the locational criteria of the FA;

• Available without onerous infrastructure or other practical constraints;

• Permits an outstanding design solution without leading to unacceptable impact:

• Already in use for Academy matches and the facilities and environment have proved to be very popular with the Club.

6.4 The Community Partnership

6.4.1 This application does not include proposals for a Community Partnership building at Bull’s Cross Open Space. The site of a Partnership building remains under discussion but the Community Partnership proposals remain part of the wider scheme. The proposal creates an unprecedented opportunity to take forward the Spurs in the Community Programme which was founded some six years ago. The programme established in 1986 helps to build links between football clubs and their local communities;

6.4.2 The coaching programme is active in 75 schools reaching some 170,000 children. Education programmes are also provided with football being used as a tool to increase literacy, numeracy and ICT standards. Crime diversion activity focusing on reducing anti-social behaviour and drug use among 10 to 16 year olds. The scheme would add to the success of the programme and would serve at least 20,000 people a year in and around Enfield and the wider community and creates an opportunity for school children to access first class football coaching.

6.4.3 Every primary or secondary school in the Borough could be offered dedicated use of the facility for one and a half days per year and a holiday programme would be established.

27 6.5 Planning policy considerations

6.5.1 The applicant’s consider that the provision of outdoor sports facilities and the change of use of agricultural land to this purpose is consistent with an objective of Green Belt policy (PPG 2 para. 1.6). Therefore, this part of the development is “appropriate development” in the Green Belt”.

6.5.2 Further PPG 2 (para. 3.4) identifies that the construction of buildings to provide “essential facilities” for outdoor sport and recreation as “appropriate”, adding that to be “appropriate” such uses should be “genuinely required” for uses of land which preserve the openness of the Green Belt and do not conflict with the purpose of including land within it. The examples of small changing rooms or unobtrusive spectator accommodation are quoted.

6.5.3 Applying this approach to the application the proposals include appropriate development. Specifically, all the outdoor facilities and many of the indoor facilities are consistent with PPG 2 (para. 3.4). The extent to which the remaining indoor facilities should be considered “inappropriate” is dependent upon how those facilities are genuinely required, preserve the openness of the Green Belt and do not conflict with the purposes of including land within the Green Belt.

6.5.4 The applicant advises that the same issue was considered in a decision taken by Elmbridge Borough Council in relation to a new two-storey football academy building for Chelsea FC at a site in Cobham, Surrey in 2003. This application proposed outdoor pitch facilities supported by a building accommodating changing facilities, medical and treatment rooms, gym facilities, hydrotherapy pool, teaching rooms, dining rooms and a groundsmans flat. In respect of this application the planning officer’s report concluded that the development was appropriate in the Green Belt. The major use of the site was for outdoor sport and the built development would be ancillary to that use. The aims of Green Belt policy would be met. The application was approved and a subsequent application in 2004 to extend the building and facilities provided by the provision of a basement was also approved.

6.5.5 In assessing the degree of impact of the buildings it should be borne in mind that the vast majority of the development provides outdoor sports facilities, accounting for 96% of the land take, which can only be considered as being “appropriate”. A further consideration is that the existing sports pavilion building will be demolished.

6.5.6 The amount of parking to be provided is considered to be very modest having regard to the overall scale of the development and number of pitches proposed.

6.5.7 The adoption of a design solution for the buildings which preserves the openness of the Green Belt makes the scheme as a whole appropriate in Green Belt Terms; or it mitigates considerably the harm by reason of inappropriateness.

28 6.6. Harm to the Green Belt

6.6.1 The applicant’s consider that in determining whether “very special circumstances” apply, the first consideration is what degree of harm the proposals will have on the Green Belt.

6.6.2 The applicants submit that:

• The major part of the development is taken up by appropriate outdoor development consistent with the objectives of the Green Belt

• The other elements are by comparison small scale

• The scale and design of the buildings preserves the openness of the Green Belt

• The development causes little harm to the Green Belt

6.7 Other harm

6.7.1 Landscape and countryside

A Landscape Assessment has been submitted with the application.

• The proposals provide for new planting and green roofed buildings which will not damage the character of the Green Belt or Area of Special Character. The landscape master plan seeks to enhance the woodland blocks and existing hedgerows to reinforce the historic field patterns and reinforce parkland clumps so as to enhance the setting of Myddelton House.

• The proposals will remove an unsightly building (existing sports pavilion)

• The proposals will remove alien plant species and new tree and hedgerow planting will enhance the character of the area

6.7.2 Heritage

A PPG15 Statement of Justification has been submitted with the application which since part of the site is located within a conservation area and the development is within the setting of a listed building this concludes that:

• The siting and design of the building and landscape treatment mitigate the impact of the development

• There will be some enhancement of the setting of Myddelton House and the Registered Historic Park and Gardens which will improve the immediate environment and outlook from the house including reinstatement of historic boundaries and historic parkland, removal of the existing sports pavilion and related parking, removal of a hard surfaced tennis court, removal of sports traffic through the house access

29 • The new buildings have been sited and designed to have minimal impact on the Historic Parks and Gardens of Myddelton House and Forty Hall and the setting of the Conservation Area.

6.7.3 Transportation

A transportation assessment has been submitted with the application. This demonstrates that the accesses at Whitewebbs Lane and Bullsmoor Lane meet the relevant standards and that they would operate satisfactorily. It also demonstrates that the impact on the wider highway network would be acceptable taking into account the intention to operate in accordance with a Green Travel Plan. The proposed parking provision also takes into account green travel measures.

6.7.4 Other issues

A number of other issues are addressed in supporting information to the application including:

Drainage and flood risk report

The site is within the Zone 1 Risk Category wherein there is little or no risk of flooding. The report concludes that the development would have no adverse impact and that it would not present a flood risk.

Archaeology

The desktop assessment concludes that there is a relatively high potential of significant remains being present. There will be varying impacts on archaeology across the site and a suitable scheme of works should address any issues arising.

Ecology

A Phase 1 Habitat Survey has been carried out using accepted methodology. The survey concludes that the development will have little impact upon ecology, subject to suitable mitigation measures.

Lighting impact

A report has been produced to assess the impact of floodlighting on the surrounding environment. The report concludes that there will be no practicable light spillage reaching properties that are closest to the site or contiguous environmentally sensitive areas of natural habitats surrounding the site. The proposed new buildings and planting screens will block or mitigate light spill to the most vulnerable areas. The report concludes that the floodlighting will not have an adverse impact on the local environment.

6.8 The applicant’s conclusions

6.8.1 The applicants submit that to utilise Green Belt land on the fringes of Greater London to provide training facilities that will contribute to the success of the First Team and widen opportunities for young people to enter professional football and be associated with a Premier League Club, is entirely consistent with the basic objectives of Green Belt Policy.

30

6.8.2 The development would cause little harm to the Green Belt and it would give rise to no other planning harm. This qualifies the degree of “other factors” needed to satisfy the balancing exercise set out in PPG 2 para.3.2 to establish very special circumstances.

6.8.3 In this case the other factors are compelling and comprise:

• The need for the development;

• The proposal would make a significant contribution to the development of football both nationally and regionally, benefiting professional players and young people beginning or hoping to begin a career in football. Such contribution would be in accordance with Government policy for Sport and Recreation;

• The lack of alternative sites that are available, suitable or preferable in planning terms;

• The contribution of the development to meeting key Green Belt objectives

• The contribution of the development to restoring the heritage of the historic environment of the locality

• The contribution of the development by creating a dedicated community facility that will benefit the local and wider community

7. Analysis

The following section details officers analysis of the application and the planning issues raised.

7.1 Key Issues

7.1.1 It is considered that the key material planning considerations are as follows:

• The principle of the development having regard to its Green Belt location • The impact of the development on the open character of the Green Belt • The impact of the development on the Forty Hill Conservation Area, Area of Special Character and the setting of listed buildings • The traffic impact of the development • The layout of the development and design of the buildings • Building design and sustainability issues • The impact of the development on adjoining occupiers • General compatibility with development plan policy

7.2 The Principle of the development - Green Belt issues

7.2.1 The site is located within the Metropolitan Green Belt and National guidance for development is set out in Planning Policy Guidance Note 2 –Green Belts (PPG2) 1995.The fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open. The most important attribute of

31 Green Belts is their openness. PPG2 sets out the five purposes of including land in Green Belts, which include;

• checking the unrestricted sprawl of large built up areas • preventing neighbouring towns merging into one another • safeguarding the surrounding countryside from further encroachment • preserving the setting and special character of historic towns • and assisting in urban regeneration.

There is a general presumption is against inappropriate development within the Green Belt such development is, by definition, harmful to the Green Belt, and should not be approved, except in very special circumstances unless it for the following purposes:

- Agriculture and forestry. - Essential facilities for outdoor sport & outdoor recreation: for cemeteries; & for other uses of land, which preserve the openness of the Green Belt. - Limited extension alteration or replacement of existing dwellings - Limited infilling or redevelopment of major existing sites identified in adopted local plans, which meet the criteria of Annex C of PPG2

7.2.2 PPG2 also states that the use of land within Green Belts has a positive role to play in fulfilling the following objectives:

- To provide opportunities for access to the open countryside for the urban population - To provide opportunities for outdoor sport and recreation near urban areas - To retain attractive landscapes, and enhance landscapes, near to where people live - To improve damaged and derelict land around towns - To secure nature conservation interest - To retain land in agricultural, forestry & related uses

7.2.3 The Green Belt policies within the Unitary Development Plan (UDP) follow these principles. The UDP was adopted in March 1994. Policy (I) G1 states that the principle of the Green Belt will be strongly supported and inappropriate developments resisted. Policy (II) G1 adds that within the Green Belt, except in special circumstances, the construction of buildings for purposes not normally appropriate in the Green Belt will be resisted. These Policies accord with the general presumption against inappropriate development in the Green Belt, as set out in Planning Policy Guidance Note 2. Policy (II) G11 provides that development in the Green Belt should not be detrimental to landscape interests. It also requires the siting, scale, height & bulk of new development to be compatible with its landscape setting & for new schemes to display a high standard of design.

7.2.4 The London Plan also states that the protection of London’s Green Belt should be maintained and it points out that there is a general presumption against inappropriate development in the Green Belt, and such development should not be approved except in very special circumstances (Policy 3D.8). The reference to ‘inappropriate development’ directly flows from PPG2.

32 7.2.5 Paragraph 3.5 of PPG 2 provides that small scale buildings that are “essentially” required and “genuinely” needed to support outdoor sport and recreation facilities are not inappropriate.

7.2.6 PPG2 presents a general presumption against inappropriate development within Green Belts, except where justified by very special circumstances under which the harm caused by reason of inappropriateness is outweighed by other considerations.

7.2.7 Having regard to this planning policy context it is considered that the open sports ground development would not constitute inappropriate development within the Green Belt. It is also considered that a proportion of the ancillary facilities within the buildings (for example changing rooms) would be essential supporting facilities to the outdoor sports facilities.

7.2.8 However, it is considered that the large scale of the supporting buildings and the totality of facilities could not be considered essential support. The totality of the application thus would constitute inappropriate development in the Green Belt. Accordingly the application was advertised as a departure from the UDP. This approach is consistent with the Manchester United, Arsenal, Sunderland and Derby cases.

7.3 Need and exceptional circumstances

7.3.1 PPG 2 indicates that inappropriate development should not be approved, unless very special circumstances outweigh the harm caused by the inappropriateness of the development and any other harm.

7.3.2 The applicant’s very special circumstances case is as follows:

• The need for the development • The extensive search undertaken for alternative sites • The proposal would make a significant contribution to the development of football both nationally and regionally, benefiting professional players and young people beginning or hoping to begin a career in football. Such contribution would be in accordance with Government policy for Sport and Recreation; • The benefits of the scheme in terms of the demolition of the existing sports pavilion and reinstatement of historic hedgerows around Myddelton House • Local benefits to the wider community through access to the facility and implementation of the Community Partnership programme

7.3.3 In consulting with residents the Council’s attention has been drawn to the Epping Forest DC decision detailed at section 3 (vii) of this report wherein that authority determined that the Academy then proposed was inappropriate development and that there were no very special circumstances to outweigh the harm to the Green Belt. This decision was not tested at appeal and the application was not considered by the Secretary of State.

7.3.4 As a general principle, each planning application must be considered on its individual merits. However, having regard to the other previous planning decisions relating to football academy applications, detailed in Section 3 and

33 Appendix 1 of this report, it is considered that the following considerations put forward by the applicant do amount to very special circumstances:

• The proposal would make a significant contribution to the development of football both nationally and regionally, benefiting professional players and young people beginning or hoping to begin a career in football. Such contribution would be in accordance with Government policy for Sport and Recreation;

• The land requirements of the applicant’s Football Academy proposals (site search in excess of 10 ha) provides that there will be little opportunity of securing a brown field site which would be capable of accommodating the development.

7.3.5 It is considered that Tottenham Hotspur’s need for the new combined first team and academy facility has been clearly demonstrated. Need, of itself, would not constitute very exceptional circumstances unless it was supported by evidence that alternative sites were not available. The applicant has submitted an assessment that demonstrates that no suitable alternative sites are available within a realistic time frame. The information provided is assessed as being comprehensive.

7.3.6 It is noteworthy that the majority of potential sites that were identified were also within the Green Belt. This may also serve to demonstrate that the land requirements are unlikely to be satisfied by a site located within the urban area. It is also the case that the combined facility approach avoids duplication of facilities and limits the physical impacts of a development to a single site. The requested analysis of the facilities developed by other football clubs demonstrates that the use of green belt locations is the norm rather than the exception.

7.3.7 The need for the facility is accepted. The existing facilities available to the Club are limited and it is acknowledged that professional football requires the provision of dedicated and sophisticated training facilities in order to compete effectively at national and international levels. It is therefore accepted that the combined Academy and First Team training facility is essential to the Club’s development strategy.

7.3.8 It is also acknowledged that the applicant’s special circumstances case recognises the contribution that the facility would have on meeting the Green Belt objective of providing opportunities for outdoor recreation and recreation. This would be brought about by the provision of sports training both to professional footballers and emerging young players via the Academy. In addition, the application proposes limited access to the facility by the community through the implementation and management of a Community Football Partnership (comprising the Club, The Tottenham Hotspur Foundation and Enfield Council).

7.3.9 An approval of the application would be subject to a S.106 Agreement which would establish the Partnership tasked with managing and agreeing with the Council a programme of sports based community activities within the Academy facility and within the community of the London Borough of Enfield and wider Lea Valley.

34 7.3.10 Use of the Academy facility by the Partnership would amount to 20 hours per week.

7.3.11 The community based programme would have the following objectives:

• Improving health through exercise • Encouraging healthy eating • Crime diversion – through increased activities to divert children away from crime • Community development – through maximising the number of trained sports coaches, administrators officials etc. • Wider educational objectives to increase sporting and academic achievement and inclusion.

7.3.12 It is concluded that the applicant’s very special circumstances case is robust and that this is a material consideration which need to be weighed against the physical impacts of the development.

7.4 Harm to the Green Belt

7.4.1 It is considered that the outdoor football pitch development can be regarded as appropriate development which is consistent with the principles of the Green Belt.

7.4.2 In addition it is acknowledged that some of the facilities provided within the building can be regarded as essentially supporting the outdoor sporting facilities.

7.4.3 The proposed Football Academy and First Team building is a very substantial building comprising some 11,806 sq. metres of floor space and a maximum of 8.2 metres high (Academy) and maximum of 10.5 metres high over the indoor pitch. In the context of impact on the open character of the Green Belt this is very significant development. Significant work has been carried out by the Applicant to rationalise the proposed development and to reduce the level of duplicated floor space arising from the separation of Academy and First Team facilities and the building resulting in a reduction in the size of the building from that which was originally proposed (12,491 sq.m). This represents a reduction in floor area of 685 sq.m. In addition it is no longer proposed to located the community partnership building (2080 sq.m) on Bulls Cross Open Space.

7.4.4 Whilst the building is substantial 96% of the site will remain open and being relatively flat land the creation of the outdoor pitches will not involve significant earthworks. Design initiatives have been introduced to reduce the visual scale and impact of the building. The building has been sunk into the ground and the two wings are limited to two stories in height above ground level. The indoor pitch has been designed to be a transparent lightweight structure with the aim of minimising its visual impact and reducing the impact of its bulk on the openness of the Green Belt. The ends of the wings have also been designed as glassed entrances thus reducing the apparent weight of the building. The design of the building is considered to be of high quality.

7.4.5 The existing sports pavilion comprising approximately 700 sq.m in floor area will be demolished providing for an improved environment in the vicinity of

35 Myddelton House and a benefit maintainance of the open character of the this part of the site.

7.4.6 Whilst the openness of the Green Belt will be physically reduced by the new buildings it is considered that overall the impact on the openness of the Green Belt is acceptable.

7.4.7 Hard surfacing of the car park and the cars parked on it would be more characteristic of an urban area. However, given the fact that the car parking will be screened by buildings and hedgerows and the fact that parked cars would not be permanent it is considered that this element would not significantly harm the openness of Green Belt. Furthermore the level of parking proposed has been reduced by the deletion of the overspill parking.

7.4.8 The table at Appendix 1 to this report compares the current application with that of some of the Academy/Training Centre developments of other clubs which have been permitted in the Green Belt as detailed in paragraph 3.1 above. Whilst planning applications must be considered on their individual merits having regard to the particular circumstances in each case the information serves to indicate that this type of development has been permitted in the Green Belt by Local Planning Authorities and by the Secretary of State. The developments included in the table are of variable scale and the current proposal would be at the top end of the range. Whilst the Academy building is not considered to be of small scale (para 3.5 of PPG2), it is considered that its scale relates to the scale of outdoor sporting activity that it supports.

7.5 The Impact on Forty Hill Conservation Area, Area of Special Character and the historic environment

7.5.1 The eastern part of the application site in the vicinity of Myddelton House lies within Forty Hill Conservation Area. Myddelton House is a grade II listed building and its gardens which are included on the English Heritage Register of Parks and Gardens forms part of the immediate eastern boundary of the site. To the south lies Forty Hall a grade I listed building and its registered historic park. The site also lies within the UDP designated Area of Special Character (AOSC).

7.5.2 A detailed landscape assessment, visual analysis and conservation appraisal was submitted as part of the application. The analysis rightly concludes that the site is visually contained due to the presence of hedgerows and dense tree belts and woodland.

7.5.3 The views of consultees regarding the impact of the proposed development on Forty Hill Conservation Area, Area of Special Character and listed buildings have been carefully considered. It is assessed that immediate impact of the development site on the surrounding historic landscape are limited.

7.5.4 Much of the proposals involve development that is outside the existing boundaries of the conservation area. In that regard they have no direct impact. Those elements that fall within the conservation area comprise existing pitches. In that sense there is no fundamental change to the character of this part of the conservation area. However, in concluding that there is no, in principle, objection on conservation grounds it is important that

36 the proposals do not, in any meaningful way, harm the significance of the surrounding heritage assets.

7.5.5 Clearly the proposal will have greater or lesser impact on individual heritage assets. The factors for consideration will largely be:

• Proximity • Visibility • The compatibility of the proposal within the context and setting of the asset • The importance of the asset • The sensitivity to harm of the asset

7.5.6 In respect of impact on Myddelton House, the distancing between the building and the house at some 340 metres, and partial screening by existing planting, provides that it will not give rise to significant visual impact on the setting of the listed building. The area in the immediate environs of Myddelton House is already laid out as sports pitches and the impact of the proposed development would be comparatively modest. The layout of the proposed pitches works within the grain of the historic landscape, and specifically, it would re-establish the boundary of Elsyng New Park where it has been lost largely in the modern adaptation of the Myddelton House parkland to playing fields. This would be an enhancement but care will be needed to ensure that the ball stop fences, so far as is possible, blend into the landscape by ensuring that they are an appropriate weight and colour.

7.5.7 The proposals result in local improvements to the historic setting of Myddelton House. As a result of previous development in the form of the sports pavilion, tennis courts and football pitches, the western aspect of the setting of Myddelton House has previously been degraded. The application proposes the removal of the pavilion and tennis courts and the reinstatement and strengthening of historic hedgerows in the vicinity of the house. This will serve to enhance the setting of the listed building.

7.5.8 The development will have limited visual impact on Forty Hall and park as it is substantially screened from view not least by planting in the park itself but also by Archer’s Wood. The one visual linkage is the Avenue extending from the house to Turkey Brook but the siting of the building behind Archers Wood provides that the development has no significant impact on this view.

7.5.9 The proposed development would extend and intensify the recreational uses and sports pitches in the Green Belt and Area of Special Character and would leave Forty Hall and its park separated from its historical agricultural context other than towards the west. To this extent it is acknowledged that the change of use of the part of the site currently in agricultural use will have an impact on the current wider agricultural context of the Forty Hall Estate and its perceived character as a landscape park providing a transition to the countryside. However, such a change would be subtle, in the sense that standing in the park, it would only be obvious if conditions were such that light spillage from the flood lighting made it so. A condition controlling floodlighting detail and limiting hours of use to 21.00 hours is recommended.

37 7.5.10 The introduction of the Community Partnership building into an area of Bulls Cross Open Space proposed in the previous application had substantial impact on the Conservation Area which planning policy seeks to preserve or enhance. The omission of this part of the proposal from the current scheme is therefore welcomed.

7.5.11 The demolition of the existing sports pavilion and provision of an access from Whitewebbs Lane will negate traffic entering the environs of Myddelton House for the purposes of the use of the site for sport.

7.5.12 It is recognised that the draft management proposals arising from recently published Forty Hill Conservation Area Appraisal recommends the extension of the Conservation Area to a point where it would include the whole of the application site. The Appraisal carries some weight given the process by which it has been carried out, but the proposal to extend the Conservation Area boundary is contained in the draft management proposals which are at an early stage and it is considered therefore that this draft proposal can carry little weight in the consideration of this application.

7.5.13 The historical and existing wider contexts of Forty Hall Park are acknowledged. However, it is considered, however, that the proposals have limited immediate impact on the character of the Forty Hill Conservation Area and that they serve to preserve the immediate setting of Forty Hall and park and preserve and to some extent enhance the immediate setting of Myddelton House.

7.6 Building design

7.6.1 Policy (II)G11 of the UDP requires that development within the Green Belt should not be of detriment to the quality of the landscape and that it should display a high standard of design.

7.6.2 The Academy building has been redesigned following discussions between the applicant and officers of this Council and officers of the Greater London Authority.

7.6.3 The buildings have been designed to have regard to its context in a number of ways:

• The main entrance and parking have been located to the north/northwest an area which is heavily screened by the existing boundary hedge line and the buildings within the adjoining Whitewebbs Sports Ground.

• The materials have been chosen to respond to the character of the locality as follows:

- The use of dark stained timber cladding to the groundsman’s building - The use of stone cladding to the main building

• The roof of the covered pitch uses material which is as transparent as possible providing a lightweight structure and the walls around the indoor pitch are glazed above ground level which assists in minimising the apparent bulk of the building

38

• The building is to have a basement floor and the covered pitch level will be 3 metres below ground level in order to reduce the potential for skyline impact. The provision of a basement level also enables a reduction in the footprint area of the building.

• The building is designed as two accommodation wings surrounding the covered pitch which are two storeys in height above ground level.

7.6.4 The proposed building is an innovative lightweight structure designed as two interlocking wings wrapping around the lightweight and transparent pitch enclosure. The reception areas at the end of the wings also have a high degree of transparency enabling views through to the landscape beyond. The roofline of the wings maintains a strong continuous line creating the building frame. The use of a water feature to separate the First Team wing entrance and the facilities on the remainder of the site maintains openness and views from the Academy area. To contrast the transparent areas planes of natural stone are contained within the building frames providing colour, texture, solidity and warmth. The architectural response to concerns raised about the originally submitted design is a building of high quality design.

7.7 Sustainability

7.7.1 The applicants have indicated that the development will be highly sustainable and two potential options have been put forward. These are either a combined heat and power system (CHP) along with ground source heat pumps to provide under soil heating, and cooling to the buildings, or a tri- generation system (combined heating, cooling and power) (TGS) complemented by a biomass boiler. The two measure proposed in the first option will reduce carbon emissions by 5% and 10% respectively. The TGS requires detailed work to ensure that it can be sized accurately. The biomass boiler would deliver a 10% reduction in carbon emissions.

7.7.2 An energy assessment report has recently been submitted which considers the energy needs of the development this recommend that a gas fired boiler be used sized on hot water demand. Renewable energy will need to be capable of offsetting emissions by 10%. The assessment concludes that the following are capable of satisfying that requirement:

• Biomass boiler • ATES (borehole scheme

7.7.3 The proposals will require further assessment and considerable design detailing and refinement but they are consistent with the Council’s sustainable design and construction policy and with Policies 4A.7 and 4A.8 of the London Plan.

7.7.4 The scheme attracts a high score in respect of the submitted sustainable design and construction assessment.

7.7.5 It is recommended that conditions are imposed to address sustainability, energy efficiency and emissions reduction detailing.

39 7.8 Traffic and highway considerations

7.8.1 Whitewebbs Lane/Road is an unclassified road connecting Bullsmoor Lane and Theobalds Park Road. Recent surveys (April 2006) indicate that the road carries a 24 hour, two-way flow in the region of 5720 vehicles on an average weekday, 5583 on a Saturday and 4644 on a Sunday. As indicated in the table below, the vast majority of vehicle using Whitewebbs Lane/Road are cars and other light goods vehicles. However, a relatively small but significant number of HGVs also use the route to access the garden centres.

Cars/Light Medium GVs Heavy GVs GVs No. % No. % No. % Weekday 5375 94.0 321 5.6 24 0.4 Saturday 5429 97.2 142 2.5 12 0.2 Sunday 4582 98.7 51 1.1 11 0.2

7.8.2 Most of Whitewebbs Lane/Road is derestricted and the national speed limit of 60mph applies. To the west of the proposed site access (approximately 100m east of the King and Tinker public house), the 85 th percentile speed was recorded as 43.5mph. To the east of the site access (approximately 150m from the junction with Bulls Cross Ride) the 85 th percentile speed was 38.8mph.

7.8.3 Bulls Cross (south) and Bullsmoor Lane form part of the A105 Principal Road and provide a link to and from the A10. Congestion at the A10/Bullsmoor Lane junction can result in queues on Bullsmoor Lane, particularly in the evening peak. On occasions, this queue can extend back into Bulls Cross. Despite the layout of the Bulls Cross/Bullsmoor Lane junction, there has only been one injury accident in the last 3 years. However, there have been a significant number (14) of accidents on Whitewebbs Lane/Road in the 3 year period ending December 2005, all of which involved slight injuries. Two vehicle activated warning signs and improvements to the road markings have recently been introduced in response to this accident record.

7.8.4 The site is not readily accessibly by public transport, the nearest bus services being on the A10 (routes 217, 317) and the Elsyng Estate (route 327). Turkey Street Station, which provides access to services between Liverpool Street and , is some 1.5 km from the site (assuming a pedestrian route to the site via Myddelton House).

7.8.5 Pedestrian and cycle access to the site is via Whitewebbs Lane, which has a segregated footway on the southern side of the road but no cycle facilities. In addition, a secure route via the grounds of Myddelton House could be provided, which would provide a more direct pedestrian access to the site. A suitable condition should be attached requiring submission of further details of this route.

7.8.6 The Council’s Definitive Map of public right’s of way shows that there are no public rights of way that pass through the site.

40 7.8.7 The anticipated level of traffic generation has been calculated with reference to the existing facilities at Myddelton House, Spurs Lodge and White Hart Lane that are expected to transfer to the new facility. The tables below summarise the level of traffic each of the critical time periods on a weekday, Saturday and Sunday:

Weekday - First team + Academy teams on site during day + 8x schoolboy ` teams training in the evening

Time Period In Out 2-Way 0900-1000 31 11 42 1000-1100 16 3 19 1700-1800 36 8 44 1800-1900 40 43 83 1900-2000 5 40 45

Saturday - Two homes games + 4x schoolboy teams training

Time Period In Out 2-Way 0900-1000 61 4 65 1000-1100 52 21 73 1200-1300 5 63 68 1300-1400 2 45 47

Sunday - Three schoolboy matches

Time Period In Out 2-Way 0900-1000 68 6 74 1000-1100 54 7 61 1200-1300 8 70 78 1230-1330 7 126 133 1300-1400 3 67 70

In addition, 20 delivery vehicles are likely to be generated per week, plus vehicles associated with the removal of grass (due to pitch scarification), delivery of fertilisers and fuel. Approximately 3 deliveries of sand will also take place each week between April and July.

7.8.8 The levels of traffic generated by the use are relatively low for most periods of time. However, the main concern relates to the weekday evening peak period, when traffic on the adjoining network is high and the Sunday lunchtime period, when flows generated by the site are relatively high.

7.8.9 The main cause of congestion in the area during the evening peak is the junction of the A10 and Bullsmoor Lane. Transport for London (TfL), who are the highway authority for the A10, have therefore required that extensive modelling is carried out to demonstrate the impact of the additional traffic will not exacerbate this problem. Queues on Bullsmoor Lane can sometimes extend back from the A10 to the junction with Bulls Cross. Whilst this is not an every day occurrence, such queues affect the capacity of the junction by making it more difficult for traffic to turn left from Bulls Cross (north) into

41 Bullsmoor Lane. In addition, unless a gap in the queue is maintained, traffic turning right from Bullsmoor Lane into Bulls Cross (north) can also be delayed.

7.8.10 During the critical 5-6pm period the proposal is estimated to increase the left turn from Bulls Cross (north) into Bullsmoor Lane by some 8 vehicles. The right turn from Bullsmoor Lane into Bulls Cross (north) is estimated to increase by some 34 vehicles. Providing that a gap for right turners can be maintained if a queue on Bullsmoor Lanes builds up and extends past the junction, this volume of traffic is unlikely to have an adverse impact on the operation of the junction. However, the need for additional markings to prevent queuing vehicles from blocking the junction will need to be considered. Although flows to and from the site are higher during the 6-7pm period, the flows on Bullsmoor Lane into the A10 junction are significantly lower.

7.8.11 Traffic generated by the development on weekdays is largely new to the network. However, Sunday schoolboy matches are currently played within the grounds of Myddelton House and are therefore not new. Clearly, the pattern of traffic movements will be different, with a significant increase in the turning movements from Bullsmoor Lane to and from Bulls Cross (north). On the other hand there will be a significant reduction in movements using the Myddelton House access, which has severely restricted visibility. The Bulls Cross/Bullsmoor Lane junction has been modelled with the anticipated flows and shown to operate satisfactorily.

7.8.12 The above conclusions about the impact of the scheme are predicated on a number of assumptions about the way that the site will operate. It is therefore important to ensure that timings of the matches and training sessions will be consistent with the way set out in the Applicant’s Transport Assessment. In order to minimise the traffic impact during peak times, a condition or obligation should therefore be attached requiring the applicant to submit a detailed management plan setting out, amongst other things, the number and times of schoolboy matches and training sessions.

7.8.13 The application proposes the creation of a new means of access onto Whitewebbs Lane. Visibility at the junction is sub-standard given the current recorded speeds on this section of Whitewebbs Lane. The proposed access is therefore only acceptable if measures can be introduced to effectively reduce speeds. A preliminary scheme (illustrated on drg. N40434_09/A) has therefore been developed in conjunction with officers with a view to reducing speeds via a combination of additional signs (including vehicle activated warning signs), road markings and a reduction to the speed limit along the length of Whitewebbs Road/Lane to 40 MPH. With these measures in place, and the localised trimming back of the hedge either side of the access, visibility would be adequate to enable vehicles to safely emerge from the site. These highway alterations are therefore essential to enable safe access to the site and must be secured by way of a suitable legal agreement. The geometry of the junction has been assessed to ensure that a large (15m) coach can complete the turn into and out of the site. Whilst it is clear that coaches and other large vehicles can complete this manoeuvre, the detailed design of the junction will be further refined as part of the S.278 to ease this movement.

42 7.8.14 The parking standards in the UDP and London Plan do not easily relate to the proposed use of the site. In such circumstances the level of parking needs to be assessed on an individual basis. Important considerations in this instance include the need to prevent parking on the adjoining roads, the low level of public transport accessibility, the effectiveness of the proposed travel plan and opportunities for dual use of spaces etc. In the light these considerations, the S.106 Agreement will include a requirement for a car park management plan setting out a strategy for managing and monitoring car park usage in the light of the actual demand. Coach parking for 5 coaches is provided within the site, which appears reasonable to cater for the anticipated demand.

7.8.15 Secure cycle parking for 20 cycles is proposed, although no details of their design or location has been provided. This will need to be covered by a suitable condition.

7.8.16 The applicant’s Transport Assessment sets out a number of measures to try and reduce the number of single occupancy car trips generated by the use. These measures include the provision of a minibus to transport Academy scholars to and from the site, coaches for Academy and schoolboy matches at weekends, car-sharing initiatives etc. The mechanisms for establishing and monitoring the Travel Plan will need to be set out as part of any S.106 agreement.

7.8.17 Subject to the following obligations and conditions, the proposed development is acceptable in terms of traffic generation, access and parking and therefore in accordance with Policy 3C.22 of the London Plan and Policies (II) T13, (II) GD6, (II) GD7 and (II) GD8 of the UDP.

7.9 Ecology/Biodiversity

7.9.1 Immediately to the south of the site lies Forty Hall Park and Estate, a site adopted as a Site of Importance for Nature Conservation and site of Borough Importance, Grade 1. The applicant has submitted an ecological impact assessment which usefully informs the evaluation of the likely biodiversity issues resulting from the scheme.

7.9 2 The assessment identifies a number of impacts on biodiversity as follows:

• Significant land take • Potential disturbance to birds and bats

7.9.3 The most significant aspect with respect to birds is the denial of potential breeding and wintering habitat to two nationally declining species; skylark Alauda arvensis and lapwing Vanellus vanellus. The potential permanent disturbance to bats and bat roosts is significant because they are protected under UK and European wildlife legislation (Wildlife and Countryside Act 1981, as amended and Habitat Regulations 1994).

7.9.4 The assessment identifies that the site is of likely importance to up to six species of bats, one of which is nationally very rare (Barbastelle Barbastellus barbastellus). The proposal includes the construction of three floodlit pitches which could threaten any bat roosts within their vicinity. The impact assessment for bats was undertaken at an unfavourable time of year to ascertain the locations of actual roosts and the applicant is undertaking further surveys this summer. The information to be provided will be critical in

43 assessing the adequacy of the proposed mitigation measures and whether additional mitigation is required. The requirement for the surveys and re- assessment of mitigation is therefore the subject of a recommended condition.

7.9.5 In regard to impacts on birds the GLA have advised that the mitigation proposed appears to be adequate and achievable.

7.9.6 A condition is proposed limiting the use of the floodlighting to 21.00 hours

8. S.106 Agreement

8.1 Revised heads of terms for the Section 106 Agreement have been put forward by the applicant. The heads of terms make the following provisions:

8.2 Restrict the use of the Academy building

The use of the building will be restricted to a training facility and football academy.

8.3 Community Partnership Management

A Community Football Partnership Management Board will be established responsible for managing and agreeing with the Council a programme of sports based community activities as follows:

i) Within the indoor area and classroom facility at the Academy facility;

ii) Within the community in the London Borough of Enfield and the wider Lee Valley.

8.4 Community use of the Academy

As a component of the agreed programme of sports based community activities the Academy facilities will be made available for a period equivalent to 20 hours per week.

8.5 Community Football Partnership activities

The Cub shall be obligated to create and maintain a community based programme for 10 years. The programme will be formulated in conjunction with the Community Football Partnership, schools and other community organisations. The objectives of the programme shall be:

• The promotion of community participation in healthy recreation, in particular by the provision of facilities for the playing of football;

• The advancement of the education of the public in the subject of physical education, literacy, numeracy, personal, social and health education and leisure and tourism;

44 • The promotion for the benefit of the public of urban or rural regeneration in areas of social and economic deprivation (in the Lee Valley including the LB of Enfield) by all or any of the following means:

i) The advancement of education, training or retraining, particularly among unemployed people and providing unemployed people with work experience;

ii) The promotion of public safety and prevention of crime;

iii) Such other means as may be from time to time be determined.

• To develop the capacity and skills of members of the disadvantaged community in such a way that they are better able to identify and help meet their needs and to participate more fully in society

8.6 Financial provisions

The Cub will fund the Community Programme to the maximum value of £2,000,000 by way of revenue support of the outreach programmer and, as appropriate, contributions towards agreed capital projects over the 10 year period.

8.7 Green Travel Plan

Prior to the implementation of the development the Club will prepare and submit to the Council for its approval a Green Travel Plan. The principle aim of the plan will be to achieve an appropriate balance between the use of car based and non-car based forms of transport by staff, agents of the Club and (if appropriate) lawful visitors to the development. The plan will also need to investigate the potential for improvements to pedestrian access to the site.

8.8 Site/car park management

Prior to the occupation of the development the Club will prepare a plan for car park management in response to actual parking demand together with a strategy for monitoring the use of the car park.

8.9 Off site highway works – financial provisions

Prior to the occupation of the development the Club will make a financial contribution to the Council in relation to the funding of off-site traffic calming and signage works and works and orders relating to the imposition of a speed limit on Whitewebbs Lane.

9. Conclusions - reasons for recommending that planning permission be granted

9.1 The proposed development will further the development of football at a national level by providing Tottenham Hotspur with training facilities that will enable the Club to compete nationally and abroad. This support for the provision of exemplary sporting facilities is consistent with the government’s national strategy for sport – A Sporting Future for All and with Policy 3.D5 of

45 the London Plan. The development of world class sporting facilities also supports the development of London as a world city.

9.2 Having regard to the provisions of the UDP, The London Plan and PPG2 it is considered that the applicant has put forward a robust argument demonstrating that very special circumstances exist to outweigh the harm caused by reason of the inappropriate development in the Green Belt.

9.3 The development maintains 96% of the site as open. Whilst the building is large a number of design elements have been introduced to reduce its visual impact and bulk. The building is of high quality design that reflects its use as a sports training facility. The overall impact on the openness of the Green Belt is considered to be acceptable.

9.4 The Academy building is of striking design and architectural merit and sustainable design quality is proposed in accordance with Policy (II)SDC1 of the Interim UDP Amendments and Policies 4A.7 – 4A.9 of the London Plan.

9.5 The proposed development is appropriately located, have appropriate regard quality of life and visual amenity and has appropriate regard to its surroundings consistent with Policies (I)G1, (I)G2 and (II)G1 of the UDP.

9.6 The scheme has limited immediate impact on the Forty Hill Conservation Area and its immediate historic context. It responds appropriately to this setting and offers the opportunity to reinstate historic hedgerows and to enhance the setting of a listed building (Myddelton House) by the removal of the existing sports pavilion and tennis courts. The immediate setting of Forty Hall and its estate are preserved.

9.7 Subject to obligations and conditions, the proposed development is acceptable in terms of traffic generation, access and parking and therefore in accordance with Policy 3C.22 of the London Plan and Policies (II) T13, (II) GD6, (II) GD7 and (II) GD8 of the UDP.

9.8 The development has appropriate regard to ecology and biodiversity issues.

9.9 The proposal provides for appropriate planning obligations consistent with Circular advice and Policy (II)GD10 of the UDP.

46