Open letter on Proposed Community Stadium project
To: Members of WDC Cabinet cc: Members of WDC Improvement & Review Commission
I note with interest that the Proposed Community Stadium project is included in the agenda for Tuesday 1st March Cabinet Meeting (“4 – Referral from IRC on the ‘Call-in’ of the Cabinet decision made on 17th January”). I have concerns that I would like to raise about how the Cabinet will consider the Call-in recommendation and also what various council members have acknowledged as the first major hurdle – that of development on Green Belt adjacent to the Chilterns Area of Outstanding Natural Beauty.
Appendix A of the meeting agenda, which purports to provide supplementary information, seems to be inconsistent with the IRC’s recommendations (point 1 below). The text states:
“This gives background about the issues and explains that in a future planning application “very special circumstances” would have to be demonstrated to justify building in the Green Belt. Whilst Cabinet has to be mindful of this test it will be for the ‘planning applicant’ to develop it and make the case and for the decision maker e.g. the Planning Committee to actually apply it, not for Cabinet.
Cabinet, at its meeting on 17 January 2011 concluded that, on the evidence submitted, there is good potential for such a case to be made. This is an early stage for the project and Cabinet’s decision highlighted the range of strategic issues that would need to be investigated by the ‘applicant’ to further develop the case, ultimately for scrutiny by the Planning Committee. ”
Concern 1 – Call-in The ‘Call-in’ by IRC is based on Cabinet Decision – Minute 82(iii), i.e. the very special circumstances required to override the Green Belt and Area of Outstanding Natural Beauty Policies as the first test before proceeding any further with the Community Stadium project; and (ii) the Council investigates the split site options before pursuing the single site option.
To this end, I believe that IRC is recommending that evidence is provided by Cabinet, before any further work or expenditure is incurred on the project, to explain how the “very special circumstances” will be met. This is not consistent with the description above, which states that building on Green Belt would need to be justified by the planning applicant.
The interpretation of the IRC recommendation has a major consequence on the funding of the proposed project. The IRC, in simple terms, is stating that the Council should not spend any more money or time on the project until sufficient justification is evident, whereas Cabinet seems to be stating that the Green Belt justification is something that will be dealt with if the project reaches a planning application stage. This would mean many more thousands, or even tens of thousands of pounds of Council funding will be expended on something that could later be cancelled.
Concern 2 – Use of Green Belt /AONB impact This is addressed in the IRC Recommendation 1 which states that “In the absence of evidence to show that very special circumstances exist that might override Green Belt and AONB policy, to carry out further work to demonstrate the sporting, business and environmental cases to justify a proposal of this nature”.
Having read the various consultancy reports that have been commissioned by WDC, I would suggest that it is clear that there is insufficient evidence under ANY of these themes to warrant a case to go against national Green Belt policy PPG2 or local Green Belt strategy in accordance with GB9 & GB10. Specifically:
(i) Sporting Case – the proposal is that deficiencies in local sports needs are addressed through a Community Sports Village. However the “Issues and Options Consultation – Way Forward” document produced for the Cabinet meeting on 17th January consistently stated that the facilities within the “Sports Village” (as part of ‘Option-D’) would be self-funding. The sporting needs justification for building on Green Belt through ‘enabling development’ is therefore inapplicable.
(ii) Business Case – It is unclear whether this relates to the professional clubs’ business case or that of the Council’s. I would therefore suggest that consideration is given to each of them:
• The primary business case from WWFC appears to be that their tenant, London Wasps, is looking to relocate unless a new stadium is provided. Fundamentally this is a private matter between a landlord and a tenant which should not involve WDC. The nomadic nature of rugby clubs in general, and London Wasps in particular, was mentioned at the IRC meeting that supported the call-in. This would suggest that perhaps the best alternative for WWFC would be to investigate if another rugby club would wish to take up the tenancy rather than destroying Green Belt.
• The London Wasps business case is that a larger capacity stadium will allow them to become profitable. As the existing capacity is underutilised it hardly seems a viable business proposition to simply state that higher attendance will be achieved with a higher capacity. As a comparison, Darlington chairman Raj Singh has suggested that a long-term solution to their club's stadium issue could be to relocate to a smaller venue (this was after they relocated to a larger stadium which they were unable to make profitable).
• For WDC the business case for Council funding is not evident. If it were viable and represented such a good investment then the expectation would be that private funding would be easy to secure for the entire project and would not require any contribution from WDC.
(iii) Environmental Case – I have not seen anything produced to date by the Council, or the consultants engaged on the project, which would provide any justification on environmental grounds.
Can I please urge you to give proper consideration to the Green Belt and AONB issues. There has not yet been any evidence of justification, let alone “very special circumstances”, to override national and district strategies.
IRC has recommended that no further time or money should be spent on this project unless sufficient justification can be provided. To date, I believe that up to £500,000 of direct costs have been used up on this project and no doubt significant further costs have been incurred by WDC personnel working on the proposal. I would suggest therefore that before any further money is spent, that the IRC’s call-in proposal is accepted and that the project is subject to additional scrutiny in order to receive and review the proposed business case and establish whether there really is justification for overriding Green Belt policy.
Kind regards Gary Nuttall – Chairman GASP (Groups Against Stadium Proposals)