AELTC Planning Consultation Response

AELTC Development of Wimbledon Park Golf Course Land

Merton Ref: 21/P2900

 We are the Councillors for Wimbledon Park Ward, Samantha MacArthur, Jil Hall and Tony Reiss, and are submitting our objections to the above planning proposal by AELTC

The proposals in question relate to land in Wimbledon Park , a Capability Brown designed, Grade II* Listed Heritage parkland, which is designated Metropolitan Open Land (MOL).

We would note that in their updated application, the AELTC do not appear to have substantively changed the plans from their original submission. They still wish to build a  large stadium, 9.4 kilometres of road and 38 grass courts on the site. This is disappointing as it seemingly fails to address the many concerns raised, and suggestions proposed, by the community in their responses to the first consultation.

We support the objections raised in the submissions by the Wimbledon Society, the Capability Brown Society and the Friends of Wimbledon Park, and would further make the following comments.

Development on Metropolitan Open Land

The land is designated as Metropolitan Open Land (MOL) which is afforded strong protection under both local planning rules and national policy frameworks. Merton’s Core Planning Strategy states that the Council “will continue to protect MOL from inappropriate development in accordance with the London Plan and Government guidance” (CS13 & also at Merton Sites and Policies DM01-02). Furthermore, under the London Plan, MOL “ should be protected from inappropriate development in accordance with national planning policy tests that apply to the Green Belt” (G3).

The National Planning Policy Framework (NPPF) declares that a local planning authority should regard the construction of new building as inappropriate in the Green Belt subject to certain listed exceptions (s.149).The AELTC appeared to accept in their initial application that the development did not fall within any of these exceptions, but their later submission seems to suggest s.149(b) might be applicable. However given the sizeable structure being planned, the loss of openness and the fact that it does not facilitate outdoor sport/recreation we do not think this should be given serious consideration.

It follows that the application can only be approved in “very special circumstances” (s.148). In considering applications under this criteria the Local Authority must ensure “substantial weight” is given to any harm to the Green Belt and we would draw attention to the many potential harms to the biodiversity of the area, loss of green space and felling of mature trees which are further detailed below.

‘Very special circumstances’ will not exist unless the potential harm to the Green Belt is clearly outweighed by other considerations (s.148).  The other considerations that the AELTC are relying on are that there is a pressing need for this development and that it cannot take place elsewhere. They also contend that  the development would secure public and heritage benefits.  We would firstly question whether there is such a need. Wimbledon is a unique tennis tournament, one of the four Grand Slams, which continues to attract large audiences  and does not need to compete with larger satellite tournaments on other Continents. Furthermore we would question whether the scale is proportionate to the need. The present plans encompass a stadium 28 metres in height & 104 metres wide, 38 grass courts (which are far greater in number than those currently used for the qualifying tournament) and 9.4 kilometres of road.

We would further argue that if there is a need, then there are other options for expansion which should be considered before MOL is built upon. The AELTC still have the potential to develop within their current site and other suggestions have been made which do not appear to have been given due consideration. These include looking at other locations in the area, which already have grass courts, for the qualifying tournament.

The AELTC accept that “harm” (both long and short term) will occur if the development proceeds, but that it would be outweighed by the public and heritage benefits. One of the benefits that they are relying on is the new green space on the golf course. However this is a “permissive” park and does not guarantee automatic access to the public, notwithstanding any planning conditions that might be imposed (as they can be subsequently relaxed or removed). There is no certainty that the permissive park will not be closed or built upon in the future and, as part of a weighing up consideration, should be treated with caution. The park will also have a 30,000 square feet maintenance hub built upon it which will further reduce the green space available to the public. There appears to be little in the additional documents regarding sporting opportunities for the community at the development, apart from an imprecise offer to provide limited public access to the new courts, which raises questions as to the true extent of the public benefits promised.

Finally we would draw attention to s.200 of the NPPF which requires that any harm to, or development within, a heritage asset should require clear and convincing justification. At s.200(b) it states that substantial harm to assets of the highest significance (which include grade II* registered parks) should be “wholly exceptional”. We do not believe that this development could be regarded as such.

Environmental Impact

In 2019 Merton declared a climate change emergency with the aim of decarbonising  the borough and protecting green spaces. Local policies require  “protection of the natural environment” (CS13), and commits to “improving the environment, tackling climate change, reducing pollution” (CS15).

We would contend that this development by the AELTC would not be consistent with these policies and would negatively impact the environment and the efforts to combat climate change. 

In the Merton Sites and Policies Plan, Merton commits to “protect and enhance biodiversity [t]o protect trees” (DM02)  but under the AELTC proposals 300 mature trees would be felled, others moved, and an estimated 500 younger trees will be uprooted in the excavations. Whilst the AELTC claim that there will be a net gain in the number of trees, this will not make up for the loss of mature trees and the consequent loss of carbon capture.

The NPPF  state at s.174(d) that planning policies must minimise impact on and provide net gains for biodiversity. The AELTC’s claims in this area have been challenged by expert analysis, which predicts habitat losses and questions the underlying assumptions regarding the bird census and grassland evaluation. Furthermore the necessary excavation and infilling required to level the ground would threaten protected priority habitats.

There will be extensive traffic movement over the next 6 or 7 years which, according to the Wimbledon Society, will involve over 20,000 extra lorry movements. This is not compatible with the ‘emergency climate change’ declared intent to decarbonise and would adversely affect the air quality of the area.

In conclusion we think that this application, in its current form, should be rejected. We have chosen to focus our objections on two areas of concern but are aware of  many other objections raised by individual residents, local groups and environmental & heritage associations. This includes much work done examining the environmental & ecological impact, which we endorse and ask that their valid criticisms are given due consideration. As local Councillors we are aware of the strength of opposition in the community to these plans, the concern over the damage that will be caused to historic parkland and the precedent that this risks setting for further development on this Metropolitan Open Land.

Regards

Councillor Samantha MacArthur (on behalf of Councillor Jil Hall and Councillor Tony Reiss)

Wimbledon Park Ward

Merton Council

Liberal Democrat Group