Update on Welsh School Planning Application ahead of tonight's decision

During the day new information and clarifications have been received over the London Welsh School/King Edward VII Park planning application.

First, following so many comments extolling the virtues of the Welsh School and the achievemnts of its pupils, I asked if they would be taken into account. Normally there are strict guidelines about what counts as a 'material consideration' for planning purposes. Residents in the main are not questionning the quality of education offered but are objecting on planning grounds which would apply to any non-sports/park use for the premises.

This is what the Case Officer wrote in response:

The planning application will be considering the planning considerations of the scheme including the site, traffic  impact etc. The main committee report does consider the education need but the quality of the education itself would not be a material planning consideration.

The Supplementary Report going to Committee  clarifies issues around the submissions:

Reference has been made to a letter of support being registered to the incorrect address. To clarify, a letter of support was received from 23 Toley Avenue. The letter was incorrectly registered to the wrong address 28 Princes Court when it received by the Council. This administrative error was rectified with appropriate letter sent to 23 Toley Avenue providing detail of the Planning Committee meeting and site visit. There has been no letter of support received from 28 Princes Court or letter purporting to be from this address.

I still don't think how this 'error' could have happened with a different number and street and no submission at all from the address that was erroneously posted on the Planning Portal. I am sure the Planning Committee will seek further clarifcation.

The Report goes on:

  Concerns have also been raised with potential false addresses being provided by those wishing to support the planning application. Your officers can confirm that a total of 7 representations (of a total of 27) supporting the application have been received by residents in Brent, and that it has been verified that the names provided are connected to the relevant addresses. A number of the other representations have been received from outside the Borough. Whilst officers have not been able to verify these addresses, given the specialist nature of the Welsh School, it is not considered unrealistic that representations from outside the Borough could be provided. There is no evidence to suggest that false details have been provided.

Sport England have sent in a response that suggests in the last paragraph that deferral may be appropriate:

Sport England aims to ensure positive planning for sport, enabling the right facilities to be provided in the right places, based on robust and up-to-date assessments of need for all levels of sport and all sectors of the community. To achieve this, our objectives are to seek to protect existing sports facilities from loss as a result of redevelopment; to enhance existing facilities through improving their quality, accessibility and management; and to provide new facilities that are fit for purpose to meet demands for participation now and in the future.

Sport England seeks to ensure that the needs of sport are given appropriate consideration and significant weight in the development management process. The Government’s National Planning Policy Framework (NPPF) makes the need for such consideration clear in its requirements to:

·      deliver community and cultural facilities to meet local needs;

·      protect existing sports and recreational buildings and land;

·      guard against the unnecessary loss of valued facilities and services;

·      promote mixed developments;

·      plan positively to provide opportunities for outdoor sport in the Green Belt; and

·      ensure that decisions are based on robust, up-to-date and relevant evidence.

In this above context, Sport England would support the ongoing use of the site for sport. Whilst we accept the findings of paragraphs 9 and 10 of the committee report, it is not clear what proactive attempts have been made by the Sports and Parks Service to promote the site and encourage a viable and ongoing sporting offer at the site. Sport England would advocate that the site remain in sporting use and that other sporting uses should be considered ahead of non sporting uses.

Strictly speaking, the application does not demonstrate full conformity with para 74 of the NPPF:

Existing open space, sports and recreational buildings and land, including playing fields, should not be built on unless:

·      an assessment has been undertaken which has clearly shown the open space, buildings or land to be surplus to requirements; or

·      the loss resulting from the proposed development would be replaced by equivalent or better provision in terms of quantity and quality in a suitable location; or

·      the development is for alternative sports and recreational provision, the needs for which clearly outweigh the loss.

As indicated, whilst we do not dispute that the Bowls Club disbanded in 2013, this in itself does not mean that the site has no future purpose in serving the ongoing strategic needs of the bowls community.

The other consideration, which is not within the red line of the application boundary, is the bowling green itself. Sport England has not commented on the loss of the bowling green as this does not form part of the application red line boundary. The bowling green should therefore remain in D2 Use. The red line only extends around the pavilion and does not include the bowling green. We would therefore like to clarify that the bowling green does not  form part of this application and should remain available for ongoing community use.  This is an important point which needs to be explicitly made.

I trust you will find the above helpful, which gives a better understanding of Sport England’s position. In light of the above, it might be helpful to understanding current sporting needs in more detail before making a determination of this application. It may be appropriate to defer this application from determination until a fuller understanding of sporting need is undertaken.