THE Campaign Group have now submitted our detailed response to the latest Brandon Estates planning application.
Our deadline was Wednesday August 18, and on that day we sent an 86-page document to the Principal Planning Officer Erica Buchanan.
The response was necessarily lengthy as naturally we registered the strongest possible objection to the plans, which are wholly deficient for a quite staggering list of reasons.
This revised application was prepared by new consultants, DPP Planning, and Knight, Kavanagh & Page (KKP), after Brandon Estates sacked their original consultants.
We responded specifically to the covering letter filed by DPP Planning, DPP’s Planning Statement, KKP’s 3G Artificial Grass Pitch Feasibility Study, and KKP’s Coventry Stadium Speedway Viability Appraisal.
Each of these documents contained a catalogue of statements worthy of challenge, and many have already been proven to be completely untrue. Quite incredibly, the planning application also contains several statements which had already been disproved via the initial application but were still repeated this time around!
We would like to put on record our grateful thanks to every member of the public who registered their own objections earlier this month. We do not yet know the confirmed total of responses, but we do know again that it was a very significant number.
Our thanks also to the various official bodies of both speedway and stock car racing (BSP Ltd, SCB, ACU, FIM, BriSCA, ORCi etc) who once again registered their strong objections to the plans, as well as the input of Sport England.
It was remarkable that the Independent Report commissioned into the original application criticised the developers for not consulting with the sports’ governing bodies, yet the revised application carries exactly the same basic failing, despite a furtive and deeply unprofessional attempt to imply that such consultations had taken place – which they had not!
We would also like to thank the CEO of Belle Vue Speedway, Adrian Smith, for his help and evidence to disprove a section relating to the National Speedway Stadium in Manchester, as well as the various secretaries and managers of existing 3G pitch facilities in our local area – who painted a very different picture of Brandon Estates’ approach than the one put forward in the planning application.
Our full response will go into the public domain at some stage in the future, but we do recognise that within 86 pages there is a huge amount of technical detail which, whilst entirely relevant, may be ‘tough going’ for the general public to read!
Therefore, below, we reproduce the ‘Executive Summary’ section which is published at the front of the response.
Brandon Estates failed to get their plans incorporated into the Rugby Borough Local Plan, they failed with their initial speculative application in 2018, and our Executive Summary will give you an idea of the multiple reasons why we firmly believe the revised planning application should also fail.
We will keep you in touch with the timeline of what happens next, with the next confirmed date being Monday October 11, when Brandon Estates will stand trial for breaches of the Community Protection Notice originally served on them in September 2017.
EXECUTIVE SUMMARY Brandon Estates’ (BE) evidence is very well presented but Save Coventry Speedway & Stox Campaign Group (SCS) plead that this should not mislead the reader. Their documents are riddled with untruths and falsehoods, many of which are repeated from the original application despite being disproven and are exposed in this SCS response.
BE are solely responsible for evicting Speedway and Stock Car Racing from Brandon Stadium at the end of 2016. This was despite a continuing need for both sports to remain at the stadium.
BE's decision to redevelop and close the stadium was made without due consideration of Government national planning policy requirements which protect sports and recreation facilities from redevelopment.
BE have consistently ignored the extent of opposition to their proposals not only from the racing communities but also the local community. SCS contend the abject failure by BE to secure the stadium has been a deliberate tactic to wear down those residents who live in close proximity to the stadium.
BE clearly misinterpret Para 97c of the Government's National Planning Policy Framework by suggesting the proposals are for an appropriate alternative sport or recreation development when the reality is that a sports development ancillary to the main housing proposals is advanced. The sporting benefits would duplicate and compete with existing provision for a sport that is well catered for already.
The site lies within confirmed Green Belt and SCS believe that a development of 124 new dwellings cannot possibly be regarded as being compatible with this designation.
BE had their chance to promote the site for redevelopment through the review of the local plan, including attendance at the public examination before an independent, Government appointed Planning Inspector. Their case failed yet they continue to pursue to charge ahead with the proposals contrary to the Local Plan.
SCS disputes BE's contention that the site is brownfield. We accept that parts of the site are brownfield but most of the site should be considered greenfield since those elements have only been used over the years for parking and do not have tarmac or concrete surfaces. These areas could easily be restored to agricultural use in the event the stadium were not reopened.
SCS consider that the affordable housing provisions of BE's proposals are inadequate. It should not be treated as a solely brownfield development. Provision of affordable provision at the appropriate level and mix would have a significant impact on viability. A non-policy compliant proposal should not be entertained in order to justify demolition of the much-needed sports stadium.
The open space benefits of the proposed development should not be over-estimated as the areas affected were already open and publicly accessible when the stadium was operational.
BE's own assessment of their proposal conveniently forgets to include reference to some of the most important elements of the Local Plan and Neighbourhood Plan.
The applicant suggests the development would have many benefits and represent a sustainable development, but the housing and pitch proposed are either planned to be built elsewhere or, in the case of sports pitches, already exist. The net benefits would therefore be limited and in certain aspects, such as social impacts on the users of Brandon Stadium, negative.
The stadium is not surplus to requirements. It remains in an ideal central location with a near century of established use for motorsports. The limited amount of development that has taken place close to the stadium has been in full knowledge of this position.
The deterioration of the physical condition of the stadium buildings results directly from BE's mismanagement of stadium security. They have flouted their responsibilities under the Occupiers Liability Act 1984 to secure the site and now disgracefully attempt to use the resultant vandalised condition of the stadium to their advantage.
Several proposals to reopen the stadium have been made but in the view of SCS none have been taken seriously by BE and, furthermore, there is no indication that BE ever intended the situation to be any different.
There is no mention of the fact that an offer to buy the stadium by a highly credible businessman remains on the table and has been neither accepted or rejected by BE.
The 3G Artificial Pitch Feasibility Study is fundamentally flawed and both the Football Foundation and Birmingham FA ‘believe the proposed location may be too rural to attract sufficient demand’. Despite the inference in the Study, no contracts or agreements are in place for an operator or users of the facility.
Both the Programme of Use and the Financial Projections are unrealistic and the projected marginal profit is highly likely in reality to be a significant loss.
KKP, authors of the 3G Pitch Study, emphasize how ‘it is imperative that clubs are kept informed’ but BE has done the exact opposite of this – having latched onto two clubs who showed an interest, enabling them to be referenced in this application, included in a pitch usage chart and financial projections, they have been dropped like a stone. They have been shamelessly ‘used’ by unscrupulous developers.
Should this application be approved and a 3G pitch installed, there would be a detrimental impact on other clubs offering similar facilities, in particular the nearby Wolston Leisure and Community Centre.
The new floodlit all-weather football pitch proposed requires intensive use to achieve viability, yet the floodlighting will significantly affect nearby residents as well as contributing to urbanisation of a site that forms part of the rural countryside.
Despite having more than two years to work on updating the proposals in important respects they remain unacceptably vague, for example in the form of details for the 3G pitch, floodlighting and associated facilities.
The Coventry Stadium Speedway Viability Appraisal is poorly researched, littered with embarrassing errors and untruths, is flawed in almost every respect and is biased in the extreme.
BE have failed in both the original application and this revised version to provide a shred of evidence which relates to Coventry Stadium viability. Throughout the appraisal the profitable nature of Stock Car Racing events is ignored.
BE's analysis of alleged decline in speedway and stock car racing is only correct in one respect. As venues, including some of the most important, have been lost to developers then it is hardly surprising that there will be an impact. This is not an argument that supports the loss of a further venue. It is precisely the opposite case meaning that Brandon should be restored as a major stadium for motorsports.
In an attempt to add credence to Viability Appraisal, BE claim to have spoken to several people associated with Speedway racing yet none of these individuals are actually named, and none of the ‘findings’ which follow are attributed to any of those individuals.
The Appraisal attempts too, to show a decline in the sport based on the number of fixtures raced, number of teams and television viewing figures. Every aspect of this analysis is riddled with embarrassing errors or is disingenuous.
The authors of the Coventry Stadium Speedway Viability Appraisal, KKP, proudly state (on the cover of the document) their values to be “Quality, Integrity, Professionalism”. SCS contend the Appraisal is poorly researched, riddled throughout with errors and untruths, makes fanciful assumptions and omits information which if disclosed would paint a different picture and damage the case put forward by the developers.
The proposals and supporting evidence are substantially based on dishonest analysis to address the loss of the stadium and in respect of the alternative proposals advanced.
SCS recognise that the Council are required to enter in discussions on planning applications however, we believe that too much flexibility has been given if BE's claims are to be believed. The Council could and should have refused the original planning application and negotiations over a two-year period do not appear to be justified.