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NPPF Revision to Westminster's Core Strategy

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NPPF Revision to Westminster's Core Strategy NPPF Revision to Westminster's Core Strategy: Hearing Statement 9th May 2013 41-43 Maddox Street, London, W1S 2PD Tel: 0207 493 6693 E-mail: [email protected] Westminster Core Strategy MCC Hearing Statement 9th May 2013 1.0 Introduction 1.1 This Statement has been submitted by Turnberry Planning Ltd on behalf of Marylebone Cricket Club, specifically in relation to Lord's Cricket Ground in St John's Wood. 1.2 This Statement concerns the original Representation dated 14th September 2012 and amplifies the matters raised in response to the Inspector's Main issues (Appendix 1). 1 Westminster Core Strategy MCC Hearing Statement 9th May 2013 2.0 Main Matter 1: Legal and Statutory Requirements Question 2: 2.1 With 18,000 Full and 5,000 Associate Members, MCC qualifies under paragraph 5 of General Consultation Bodies in Appendix 1 of the Statement of Community Involvement i.e. bodies representing the interests of persons carrying on business in the authority's area. MCC should also be regarded as a major landowner within the context of Other Consultee. 2.2 We consider that insufficient regard has been had to MCC during this process and that no informal discussions have taken place specifically in relation to the preparation of the Core Strategy and its impact or relationship to the MCC's interests. Question 4: 2.3 Related to the above Question, although Westminster City Council (WCC) have collaborated with MCC in relation to its emerging masterplan for Lord's for which MCC is grateful. However we consider that there needs to be recognition within the Core Strategy of the desire to retain and enhance Lord's international status as the 'home of cricket' and its associated status as a designated heritage asset within the Conservation Area. This matter should be regarded as a Strategic Priority under paragraph 156, in light of the likely spatial implications of the masterplan (paragraph 154) and therefore, earlier and more substantive engagement should have taken place in respect of these issues. We therefore consider the Core Strategy to be inconsistent with the NPPF on those points. Question 7: 2.4 We have argued in our earlier submission that the plan is not in conformity with the London Plan: Policy 2.4 C - The 2012 Games and their legacy As an Olympic Venue, Lord's must be promoted as an international visitor destination for sport, recreation and tourism. This is a positive requirement on Local Authorities preparing their LDF documents and the WCC Core Strategy is clearly deficient on this point. Policy 4.6 C - Support for and Enhancement of Arts, Culture, Sport and Entertainment In respect of LDF preparation (g), Local Planning Authorities are instructed to, 'enhance the economic contribution and community role of arts, cultural, professional sporting and entertainment facilities.' Again, the Core Strategy is silent on this issue in relation to Lord's as a professional sporting and entertainment facility. 2.5 It is therefore apparent that the Core Strategy is not in conformity with the London Plan. The clear instruction given to Local Authorities in preparing their LDFs under both policies suggests the omission is significant and therefore the plan cannot be considered to be in 'general conformity.' 2 Westminster Core Strategy MCC Hearing Statement 9th May 2013 2.6 We therefore reaffirm our suggested change (Appendix 1), but remain open to suggested alternatives or other variations and would welcome dialogue with the Council on this issue in advance of the Hearings. 3 Westminster Core Strategy MCC Hearing Statement 9th May 2013 Appendix 1 4 Westminster Core Strategy MCC Hearing Statement 9th May 2013 Head of Spatial Planning & Environmental Planning Westminster City Council 11th Floor, Westminster City Hall 64 Victoria Street London SW1E 6QP 14 September 2012 Our ref L WCC 14.09.12 MCC Your ref Marylebone Cricket Club – Core Strategy Representation Further to your recent request for representations regarding the current National Planning Policy Framework revisions to the Westminster Core Strategy, please find our response below. The Significance of Lord’s Founded in 1787, Marylebone Cricket Club (MCC) is the world's most famous cricket club. The Club retains the unique position as the custodian of the Laws of cricket and Lord’s as the home of cricket. No other ground anywhere else in the world comes close to matching the historical and cultural significance of Lord’s in relation to the game of cricket. Lord's is the home of Middlesex County Cricket Club and the England and Wales Cricket Board (ECB), as well as the European Cricket Council (ECC). Furthermore it is the setting for the MCC Cricket Academy, the unrivalled MCC Library and the world-famous MCC Museum - where exhibits include the Wisden Trophy and, of course, the Ashes Urn. Above all, Lord's is the setting for some of the best cricket in the world, hosting npower Test matches and NatWest One Day Internationals plus the domestic limited overs final and most of Middlesex's home games. As such, Lord’s clearly makes a significant contribution to the City’s visitor economy, providing benefits for local residents and businesses, as well as the London-wide economy. In 2007, an analysis of the economic impact of major cricket matches at Lord’s concluded that the effect of the 2007 West Indies Test match equated to an aggregate economic impact of between £9.5 million and £10.8 million on the local economy and between £8.9 and £10.5 million on the wider London economy (see Appendix 1). This contribution should be recognised, protected and supported through the Core Strategy. 5 Westminster Core Strategy MCC Hearing Statement 9th May 2013 As an internationally significant sporting venue Lord’s directly contributes to the wider profile of the City and has become synonymous with St. John’s Wood; enriching the character and reputation of the area. Core Strategy Policy 26 Whilst it is recognised that the Core Strategy intimates its support for Lord’s through Policy CS26 – Buildings and Uses of International and National Significance – MCC is of the opinion that the significance of Lord’s should be specifically expressed, in light of its status as an international heritage asset and contribution to the local economy of St John’s Wood and the wider City. Consistency with the National Planning Policy Framework and the London Plan Whilst the National Planning Policy Framework states at paragraph 70 that in order to deliver the social, recreational and cultural facilities and services the community needs, planning policies and decisions should “plan positively for the provision and use of shared space, community facilities (such as local shops, meeting places, sports venues, cultural buildings, public houses and places of worship) and other local services to enhance the sustainability of communities and residential environments” the Westminster Core Strategy remains surprisingly silent regarding the importance of sports facilities and venues. MCC therefore make representations to the Core Strategy on the grounds that it is not consistent with National Policy and does not plan positively for future requirements. It should also be noted that the London Plan emphasises the importance and prominence of sports and recreation facilities. This commitment to sporting venues is reflected in many other London Council Plans, such as the Richmond Core Strategy [Twickenham]: Policy CP20 – Visitors and Tourism – “the Council will support the sustainable growth of the tourist industry, for the benefit of the local area by…encouraging the enhancement of existing tourist attractions, such as Kew Gardens, Hampton Court Palace, Ham House and the River, including sports stadia particularly those of RFU and Harlequins”; the Merton Council Core Strategy [Wimbledon]: Policy CS13 – Open space, nature conservation, leisure and culture – “Based on assessment of need and capacity, opportunities in culture, sport, recreation and play will be promoted by…safeguarding the existing viable cultural, leisure, recreational and sporting facilities and supporting proposals for new and improved facilities”; and the Hammersmith and Fulham Core Strategy [Chelsea and Fulham Football Clubs]: Policy CF1 – Borough Wide Strategic Policy – “The Council will work with its strategic partners to provide borough wide high quality accessible and inclusive facilities and services for the community by…supporting the continued presence of the major public sports venues for football and tennis, subject to the local impact of the venues being managed without added detriment to local residents”. Sport and the Core Strategy It is therefore proposed that the Westminster Core Strategy include a Policy which recognises the importance of sporting facilities within Westminster and in particularly plans positively for the future Lord’s masterplan; emphasising the contribution that Lord’s makes as an internationally significant sporting venue. As such it is suggested that the sub-section 6 Westminster Core Strategy MCC Hearing Statement 9th May 2013 of the Core Strategy which is presently titled Tourism, Arts and Culture be rewritten under the heading “Tourism, Arts, Culture and Sport” and includes the following Policy: “The Council will support the continued presence and enhancement of sporting facilities, including Lord’s Cricket Ground which makes a significant contribution to the local and City economy” We would welcome the opportunity to further discuss the aforementioned concerns with you and develop a Core Strategy which is both consistent with national policy and positively plans for the future sustainable growth of Lord’s Cricket Ground. Yours sincerely, Christopher Pattison Turnberry Planning 7 .
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