SUSSEX DOWNS CONSERVATION BOARD Agenda Item No. 9(a)

PLANNING COMMITTEE

12 NOVEMBER 2001

BRIGHTON & HOVE

REPORT BY THE SUSSEX DOWNS OFFICER

Applications Nos. BH/2001/02418/FP and BH/2001/02419/FP: Proposed community stadium with accommodation for class B1 business, educational, conference, club membership merchandise, entertainment and food and drink uses, together with associated landscaping and transportation facilities including road works, pedestrian and cycle links, coach/bus park and set down area, shared use of existing car park space at the University of Sussex and shared use of land for recreation and parking at Falmer High School — land north of Village Way and land south of Village Way, Brighton.

1.0 Introduction
    1. Two applications have been submitted for a community stadium by Brighton & Hove Albion FC on two neighbouring alternative sites, described below. As there is a considerable amount in common between the two applications, both are the subject of this one report, with the differences between the proposals and their effects identified. There is a substantial amount of supporting documentation with the applications which is taking time to digest.
    2. The exact timescale for the determination of the application is not known by the Council Officers at this stage, but they consider it very unlikely that the applications will be presented to the Council’s Committee this year. Both Lewes District Council and East Sussex County Council anticipate considering the applications in December.
    3. There might, therefore, be an opportunity for the Planning Committee to refer the application to the full Board meeting in January if it wishes, although it would be desirable to submit comments at an earlier rather than later stage in the consideration of the applications. It is recommended, therefore, that this Committee agree comments to be submitted to Brighton & Hove Council and that the Board be asked to endorse that resolution in January. There will be an opportunity for a further report to the December Executive Committee to consider the issues further or other matters that are raised if necessary.

2.0 Background

    1. The Planning Statements submitted with the applications explain the background to the present proposals. This section is based on these Statements.
    2. The Taylor Report, published in 1989, put forward a number of crowd safety recommendations including the progressive removal of spectator standing areas at all 92 Football League grounds. During the early 1990’s the Albion FC considered the implementation of these recommendations, but was constrained by financial difficulties, the cost of the necessary works and the loss of revenue from the resulting reduced crowd capacity.
    3. The Club’s then home, The Goldstone Ground, was considered unsuitable for any expansion or development due to its confined nature and poor pedestrian circulation and general access. Congestion was a problem. The Club therefore decided to relocate and to sell the Ground. Planning permission was subsequently obtained for the development of the site for non-food retail warehousing. The Club sought permission for a new stadium (with "enabling" commercial development) at Toad’s Hole Valley (also within the AONB) but this was refused.
    4. In May 1997 the Club, having entered into a binding commercial agreement, vacated the Goldstone Ground and entered into a ground-sharing arrangement with Gillingham Football Club in Kent. This was obviously unsatisfactory for the Club’s supporters and attendances fell from an average at the Goldstone Ground of 19,172 to an average of 2,000. In June 1998 Brighton & Hove Council granted permission for the upgrading of Withdean Stadium in Brighton to League standards and the Club starting playing there at the beginning of the 1999/2000 season.
    5. Withdean has a licensed capacity of 6,067 seats and permission exists to increase this to 7,045. However, the Club considers that this is insufficient (given the demand for tickets for each home match) and that a new, purpose-built stadium is necessary to ensure the long-term future of the Club.
    6. Consideration had been given to the question of an alternative site for a permanent ground in 1995, when the former Borough Councils of Hove and Brighton commissioned consultants to examine the feasibility of providing a community stadium for the shared use by the Albion FC. 16 potential sites were identified and each one analysed against a set of criteria. Following further refinement, the shortlist (which had included, inter alia, Shoreham Cement Works, Toad’s Hole Valley and Stanmer Park) was reduced to five potential sites:
    1. The site selection report was considered by Brighton & Hove Council’s Policy and Resources Committee in February 1999. The Committee accepted their officers’ initial views that the Falmer site was likely to best meet the needs and priorities of the Council, subject to due consideration of a planning application.
    2. The Sequential Site Analysis report was duly presented to the Council by the Club in April 1999. It concluded that ‘Falmer offers major advantages. It is acknowledged that it is environmentally sensitive, but on the south side of the A27. Development in the AONB may be permitted under the Brighton Borough Local Plan provided that it is linked with the Universities. The location close to both Universities and Falmer School creates realistic opportunities for shared use and sport development. It has good road and rail links which can be realistically improved to minimise the use of private car travel and the restricted nature of the site naturally limits the space available for car parking with consequential environmental benefits. The proposed scheme appears to be financially viable and opens up additional opportunities for acceptable development in the Sussex Academic Corridor. It is on this basis that Falmer is recommended for selection as the site for a new stadium…’

3.0 The Proposed Sites
    1. The alternative sites for the stadium and associated development are located adjacent to each other, to the south of the A27 and railway, and west of the B2123 at Falmer. Both sites are within the AONB. Access to the University of Brighton campus is obtained via Village Way, which runs off the B2123, approximately parallel to the A27 some 280m to the south.
    2. Village Way bisects the site described as Village Way North (BH/2001/02418) with the stadium to the north and coach parking and drop off zone to the south (a total of 9ha for these elements and approximately 17ha including access facilities). Additional parking would be provided between the railway and the A27.
    3. Village Way forms the northern boundary of the site called Village Way South (BH/2001/02419), with the stadium, coach parking, drop off zone and some car parking all to the south (a total of 9ha for this main part of the development, with a total of 18ha overall).
    4. Both sites are clearly downland in form, although currently in arable use, with the land generally rising from the A27 and railway in the valley bottom. Village Way North would be bounded to the north by the railway line embankment and the vegetation thereon and to the west partly by the existing university campus and partly by a belt of woodland (Westlain Plantation). There are no existing boundary features to either the south or the east of the proposed development. Village Way South would be bounded to the north by Village Way and to the west by Westlain Plantation. Again, there are no existing boundary features to either the south or east.

4.0 The Proposals
    1. The proposals include a number of elements, a summary of which is given in the description of the applications above. The centrepiece of the scheme would be the stadium itself, comprising a pitch and four stands built in four phases. The first phase would take 12-18 months to construct, and the Albion FC hope to be able to use the new stadium sometime during the 2004-2005 season. The Club hopes to complete the development within 7-10 years of the first phase ie 2010-2014.
    2. Details of the proposed development are as follows:
    1. The Architectural Design and Landscape Statements submitted with the applications state ‘Recognising that the site lies just within the Sussex Downs Area of Outstanding Natural Beauty, the design of all building elements seeks to respond as sympathetically as possible to its contextual environment whilst providing a new community stadium as a source of civic pride for the whole of Brighton and Hove.’
    2. It continues ‘The natural sloping contours of the site in a south west to north east direction provides the opportunity for the bulk of the stadium to be cut into, and merge with the landscape, to minimise the visual impact of the development. The stadium is therefore cut into the ground to a maximum dig of approximately 10 metres to the south west and merges with existing ground levels to the north east.’
    3. ‘The roof form is deliberately simple and clean employing two long span shallow arches to both brace and support the plane of the roof. The roof plane is part of a cylinder with a rectangle cut out over the playing area. The roof follows the ground contours and arches majestically and then dives back into the ground in a form and orientation to complement and enhance the natural undulations of the site.’
    4. ‘The main aim of the design has not been to ‘hide’ the stadium but to produce a building (to be constructed in four phases) which not only respects the immediate landscape and topography of the site but also provides an exciting structure to form a flag ship building at the eastern entrance to the City of Brighton and Hove.’
    5. ‘It is intended that the stadium will be viewed locally as an important iconographic representation of the sporting excellence and aspiration of the City. As such, it will be a focal point and source of considerable civic provide, therefore the proposal does not seek to disguise its function. The cut into the hillside and suspension arch/inclined plane roof form produce an elegant and dramatic architectural form.’
    6. Further details of the stadium itself are also given in the Statements ‘The roof plane of the stadium adopts the form of a part cylinder with a cut out which is sloped to reflect the natural slope of the site, down to a bunded bank around the perimeter. The junction of the roof plane where it meets the bunded ground to the south will appear virtually seamless from viewpoints at ground level.’
    7. ‘Roof construction is of a cellular multi-wall polycarbonate roof panels fixed to steel purlins on trusses that are cable/rod suspended from an inclined tubular steel arch. All structural steel members are white and the polycarbonate panels are tinted pale green. The underside of the stadium upper tier seating will be expressed pre-cast concrete panels.’
    8. ‘As the north and south stands have landscape bunds up to the wall face, [see below] the stadium has only two primary elevations: these are to the rear of the east and west stand…… Of the two principal elevations, the west provides the main accommodation. The façade has been designed as a simple curved wall, with a two-storey high seamless curtain-wall glazed element folding itself around the entrance. This glazing is flanked either side by dark slate grey cladding which wraps itself back to at high level to a main central entrance block that rolls over the top of the stadium. The flank cladding zones are banded in 1 metre deep interchangeable panels, which are either solid clad, louvred to the plant zones, or solar glazed to the accommodation areas.’
    9. ‘The east stand adopts the same architectural language as the west stand……Both east and west elevations are clad at ground floor level up to 3 metres high with polished block architectural masonry, colour dark green, due to the practicality of durability in use.’
    10. The actual maximum height of the proposed stands is difficult to ascertain, given the changes in ground level, both existing and proposed, around the stadium. However, the eastern elevation of the east stand, perhaps the most exposed part of the stadium, would appear to be up to 44m above the ground level for the stadium at Village Way North and about 41m for that at Village Way South. From the south, the west stand of the Village Way South stadium would rise about 26m above ground level.
    11. As regards landscaping associated with the development, the Architectural Design and Landscape Statement says ‘The landscape proposals seek to minimise the impact of the development respond sympathetically to the existing landscape character, in particular to its sensitive location at the edge of the built up area within the Sussex Downs AONB. The landscape design seeks to develop effective solutions which are appropriate for both use and the setting, as well as offering opportunities for enhancing local distinctiveness.’
    12. ‘The stadium scheme has been designed in a form which respects the surrounding landscape in its downland setting, while providing a gateway development within a transport corridor on the eastern approach to Brighton and Hove. The proposed landscape has been similarly designed with these principles in mind……The proposals have been designed to harmonise satisfactorily into the landscape setting.’
    13. ‘The smooth contours of the proposed earth works are designed to complement the characteristics of the surrounding landscape and assist the integration of the development with the landform. The proposed ground modelling gently flows from the surrounding landscape, to visually connect with the profile of the stadium roof.’
    14. ‘The planting proposals recognise and seek to retain significant existing landscape features such as woodland belts and hedgerows. The proposed woodland planting strengthens the existing landscape pattern and further reinforces the beneficial effects of the ground modelling.’
    15. ‘Native indigenous species are proposed for the woodland and hedgerow boundary treatments. Areas of ground modelling will be sown with a calcareous grass and wild flower seed mix. The planting proposals seek to enhance existing habitats, such as extending tree and hedge planting along cycle routes creating ecological corridors.’
    16. ‘The design, colour and texture of the hard landscape finishes have been selected based upon the practicality and durability requirements. Where possible the use of local building materials are employed, for example in the construction of the gabion walls. Subject to the contents of the spoil material, the proposals seek to reclaim flint stones from the chalk excavations to use as dressing for the gabion walling.’
    17. The main area of new planting proposed for the Village Way North site is around the south/west and east sides of the bus drop-off and coach park area on the south side of Village Way. In time, it is hoped that this new planting would be viewed as an extension of the existing Westlain Plantation. The Village Way South site would have thin belts of new planting to the east and west and clumps to the south-east and south-west of the stadium
    18. The development of the site at Village Way North would necessitate the demolition of some of the buildings on the University of Brighton campus, including three staff bungalows, the University gymnasium and three teaching/accommodation buildings. The Planning Statement accompanying the applications states that ‘the demolition of these buildings would not be significant as the accommodation lost will be replaced as part of the restructuring and redevelopment proposed by the University of Brighton’. This redevelopment is to be the subject of a future separate planning application by the University.

5.0 Assessment
    1. The proposals raise a number of very significant issues:

Need

    1. Brighton & Hove Albion FC had a football ground, but deemed it to be unsatisfactory and entered into a binding agreement to sell it before having gained planning permission for a replacement. The Club currently has a home within the City limits at Withdean, but deem this to be too small and otherwise unsatisfactory. In order to be able to continue playing home games within the Football League’s requirement of 8 miles maximum from the Pavilion, therefore, the Club considers that a new stadium is required.
    2. Whilst the desirability of a new stadium from the Club’s perspective can be appreciated, given that they are currently apparently able to satisfy the Football League’s requirements with the stadium at Withdean, the "need" for a new stadium has to be questioned.

      3. Alternative sites
    3. As noted above, 16 potential sites for a new stadium were identified in the report on alternative sites commissioned in 1995. Of these, eleven were eliminated as suitable contenders for the following reasons:
    1. The remaining five sites, the Coral Greyhound Stadium, Brighton Station, Shoreham Harbour, Falmer (Village Way North) and Waterhall, were analysed in more detail in the Sequential Site Analysis.
      2.
    2. The Greyhound Stadium already has a football pitch within the track, but in order to achieve the 5,500 capacity required by the Football League, an existing office building would have to be acquired and demolished. An application in 1999 for its demolition was refused by the Council as being contrary to policy and a subsequent appeal dismissed as it would have resulted in the loss of an important employment site. Other problems identified with the use of this complex include the ‘considerable’ distance of spectators from the pitch and clashes between football and greyhound operating times.
    3. The only "problem" identified with Brighton Station is that ‘the land availability will severely restrict the opportunity for other uses on the site’. The only "problem" identified for Shoreham Harbour is that the expensive stabilisation retaining works necessary for the site ‘will result in the need for substantial ‘enabling development’ comprising commercial leisure, retail and residential development for the project to become financially viable’.
      4.

5.8 The Sequential Site Analysis does not identify any problems as such with the potential development of Village Way North at Falmer. It notes that the development site is designated an Area of Outstanding Natural Beauty, but that it is allocated within the Brighton Borough Local Plan for employment use associated with the Academic Corridor and University.

5.9 The Site Analysis considers two potential sites at Waterhall. It is noted that the development of the easternmost of the two sites would result in the loss of a large number of playing fields which would have to be replaced in other areas of Brighton and Hove.
    1. It would appear that the analysis of these alternative sites is not consistent. For example, Toad’s Hole Valley was eliminated from the list because, inter alia, it is within the Sussex Downs AONB and would require enabling development contrary to policy (with which the Board would agree), but these constraints are not acknowledged for Falmer! Brighton Racecourse was eliminated, inter alia, because it is "of high landscape value", although it is not part of the designated AONB whereas Falmer is.
      2.

5.11 The development of the greyhound stadium was considered to be unsuitable partly because it would result in the loss of an employment site, but there is no mention of the employment that the stadium would generate. The "problem" with Brighton Station that the development would severely restrict the opportunity for other uses on the site — but the development of the stadium anywhere is surely going to restrict the opportunity for other uses! Shoreham Harbour as a location is seen as constrained by the need for substantial enabling development, but the Harbour would appear an ideal place for such a mixed commercial/leisure/residential development and the need for enabling development isn’t seen as a constraint for Falmer.

5.12 Overall, whilst some of the sites considered can be accepted to be unsuitable from the Club’s point of view or from the Board’s, such as Toad’s Hole Valley and Waterhall as being within the AONB others, such as the greyhound stadium, Brighton Station or Shoreham Harbour would appear to be potential alternative sites.

5.13 It should be noted that the 16 sites analysed did not include either Withdean Stadium or Village Way South. Withdean was dismissed in the Analysis because it was deemed unsuitable for a permanent development bringing it up to the standard of the Football League for clubs in Divisions 2 or 3, which require seating for a minimum of 6,000 spectators, of which 2,000 must be under cover. Yet, as noted above, the licensed capacity of the ground is 6,067 and planning permission has been granted for extra capacity to raise it to 7,045.

5.14 Village Way South has simply not been considered previously, If it had been, and the Analysis was being consistent, it should have dismissed it as a potential site, as being in the AONB and contrary to policy, having a high environmental impact, requiring enabling development etc.

Policy context

5.15 In national terms, the proposals are subject to the advice of PPG7. Paragraph 4.1 ‘In those parts of the countryside where special designations apply, planning policies and development control decisions should take full account of the specific features or qualities which justified designation of the area, and sustain or further the purposes of that designation.’

5.16 Paragraph 4.7 states ‘The primary objective of designation [of AONBs] is conservation of the natural beauty of the landscape. Local authorities should reflect this objective in their structure and local plans and development control. AONBs differ from National Parks in that the promotion of recreation is not an objective of their designation, though these areas should be used to meet the demand for recreation so far as is consistent with the conservation of natural beauty…’

5.17 Paragraph 4.8 states ‘In general, policies and development control decisions affecting AONBs should favour conservation of the natural beauty of the landscape. In all cases the environmental effects of new proposals will be a major consideration, though it will also be appropriate to have regard to the economic and social well-being of the areas.’

5.18 In June 2000 Nicholas Raynsford, then Minister for Housing, Planning and Construction, announced that ‘In relation to major projects, it is the Government’s view that, henceforth, the assessment required in paragraph 4.5 of PPG7 in National Parks should also apply to proposals for major development in AONBs.’

5.19 Paragraph 4.5 states, in part, ‘Major developments should be demonstrated to be in the public interest before being allowed to proceed. Consideration of such applications should therefore normally include an assessment of:
    1. the need for the development, in terms of national considerations, and the impact of permitting it or refusing it upon the local economy;
    2. the cost of and scope for developing elsewhere outside the area or meeting the need for it in some other way;
    3. any detrimental effect on the environment and the landscape, and the extent to which that should be moderated.

Any construction or restoration should be carried out to high environmental standards.’

5.20 Whether or not the proposed stadium and associated development is "in the public interest" is surely debatable. Whilst the supporters of the Albion and those who would use the facilities in the development would benefit, the enjoyment of the downland landscape in this locality and the amenity of local residents would be seriously degraded. It surely cannot be in the "public interest" to provide a facility for a particular and specific sector of society, even with a "community stadium" at such a cost to a more general sector.

5.21 The local "need" for the development has been considered above. As indicated, this is also arguable. At a national level, as required by PPG7, there can only be, at best, a very weak argument that providing a new stadium for a Division 2 football club is in the "national interest". Indeed, the Planning Statements submitted in support of the applications admit, in paragraph 6.31, that ‘the community stadium scheme may not give rise to ‘national considerations’’.

5.22 The Statements add that ‘the proposal is clearly of more than local importance as it will serve a sub-regional/regional area’. This, however, is not what is required by PPG7. Whilst the proposal is of more than local importance in that it is proposed within a nationally important landscape, the claim that it would serve a regional area is debatable. There may be supporters of the Club that live elsewhere in the region, but it is considered unlikely that they are of sufficient number to give the proposal regional or even sub-regional weight.

5.23 When the Club shared a ground in Gillingham (a 150-mile round trip) the Statements note that attendances fell to an average of 2,000 — if the ability or desire of supporters from the team’s home town to travel a relatively short distance in regional terms is so low that attendances fall by nearly 90%, it is difficult to see how the proposed stadium can have a regional significance. Even if it did, that would not justify the development of the stadium in an Area of Outstanding Natural Beauty.

5.24 As regards the second main element to be assessed for proposed major developments, as noted above a number of potential alternative sites have been considered for the proposed stadium. Although the site at Falmer may be cheaper to develop than the greyhound stadium, Brighton Station or Shoreham Harbour, identified in this report as being potentially suitable sites for the stadium, and given that it is a greenfield site and owned by Brighton & Hove Council, the costs per se of developing the alternative sites have not been put forward as reasons for their rejection. No rigorous assessment of the costs of developing any of these sites compared to that of Falmer has been submitted with the planning application. The "need" for a new home for the Club could also be met at Withdean. Accordingly, the second part of the test in PPG7 is failed.

5.25 The third element to be assessed is any detrimental effect on the environment and the landscape. This is considered in detail later in this report and it demonstrated that the proposals also fail to satisfy this part of the test for major development.

5.26 PPG17 "Sport and Recreation" is also particularly pertinent. Paragraph 2 states, in part, ‘It is the policy of the Government to promote the development of sport and recreation in the wider sense; to enable people to participate in sport, whether as players or spectators, and to encourage the provision of a wide range of opportunities for recreation, so that people can choose those which suit them best. Such opportunities should, wherever possible, be available for everyone, including the elderly and those with disabilities for whom access to facilities is especially important.’

5.27 Paragraph 3 adds ‘It is part of the function of the planning system to ensure, through the preparation of development plans, that adequate land and water resources are allocated for both organised sport and informal recreation. It is part of the planning authorities’ responsibilities to take full account in their development control decisions of the community’s need for recreational space……and to resist pressures for the development of open space which conflict with the wider public interest.’

5.28 Paragraph 4 continues on the theme of "open space"; ‘Local planning authorities need to take into account the value of open space not only as an amenity but also as a contribution to the conservation of the natural and built heritage of the area. Policies for open space have to be set within a planning framework which takes full account of the community’s needs for development and conservation of all kinds; local planning authorities should therefore balance very carefully the competing claims of different land uses and the community’s long-term requirements for open space.’ A footnote to this paragraph confirms that this guidance is intended to apply to all types of open space of public value.

5.29 Of course, the proposed site at Village Way North is largely undeveloped and that at Village Way South completely undeveloped. Given its landscape quality, it can be argued that this contributes to the natural heritage of the area and is open space of public value.

5.30 PPG17 contains guidance on Football League stadia. Paragraph 45 states, in part, ‘The Government has accepted Lord Justice Taylor’s recommendation in his final report on the Hillsborough stadium disaster that all-seater accommodation should be introduced at all Football League grounds for reasons of safety, public order and spectator comfort.’

5.31 Paragraph 46 continues ‘To achieve this, Football Clubs will need to develop their grounds to varying degrees, possibly enlarging the stadium/site, or in some cases transferring to new locations. Many grounds are outdated, lack amenities, and are unsuitably situated in residential areas where access by public transport is poor and parking space inadequate.’

5.32 Paragraph 47 states, in part, ‘Local planning authorities are asked to give sympathetic consideration to development proposals designed to achieve the aim of all-seater accommodation at Football League grounds.’

5.33 Paragraph 49 states ‘The adequacy of existing football stadia and the need for improvement should be taken into account in preparing and reviewing the local plan. Account will need to be taken of all normal planning considerations, such as traffic, parking, access to public transport, and possible conflicts with neighbouring uses……Local planning authorities should also have regard to the extent to which proposals incorporating multi-use and non football leisure facilities will be of benefit to the community as a whole. Considerations of particular relevance to the relocation of football clubs will include the possible use of reclaimed or derelict land, especially in the urban fringe, including former mineral sites…’

5.34 PPG17 also contains guidance on recreational provision in Areas of Outstanding Natural Beauty. Paragraph 37 states in part ‘Areas of Outstanding Natural Beauty may also be important for sport and recreation but the main statutory purpose here is the protection of the quality of their natural beauty’. The following paragraph has advice on recreational provision in National Parks, ‘In National Parks, whilst conservation and recreation provision are equal objectives, where there is an irreconcilable conflict between these purposes, the conservation and enhancement of the Park’s natural beauty must prevail.’

5.35 Paragraph 39 states in part ‘Sport and recreation activities in the countryside should be appropriate and in harmony with it.’ The construction of a large football stadium and associated development is quite clearly not in harmony with this area of downland and the proposal is therefore considered to fail to accord with the guidance of PPG17.

5.36 In March 2001 the then DETR published a revised version of PPG17 for consultation (this was reported to the Planning Committee in June). In relation to stadia and major developments the draft guidance states in paragraph ‘It may be difficult to find sites for large sports developments like stadia in or close to town centres, particularly where these are to accommodate large numbers of spectators. Where a sporting or recreational use requires a large site, and where it is not practicable to separate out uses into a number of smaller sites which can be fitted into the preferred locations, then a site on the edge of the town may be the best alternative. This applies equally to outdoor facilities such as playing fields and racecourses.’

5.37 The advice of the draft PPG17 in relation to recreation provision in designated areas is contained within paragraphs 50-51. Part of the former states ‘Land which has a special designation, for example an Area of Outstanding Natural Beauty, will have inherent qualities or features which will determine the range and type of recreational uses for which it may be suitable. Sporting and recreation demands should only be met insofar as these are consistent with the statutory or other purposes for which areas have been designated……Designation does not of itself preclude the use of land or buildings for sport and recreation, although large-scale, intensive, noisy or other forms of intrusive use will often be inappropriate.’

5.38 As noted above, ‘The primary objective of designation [of AONBs] is conservation of the natural beauty of the landscape.’(PPG7). The development of a large formal sports stadium would not conserve the natural beauty of the landscape in the locality; indeed, such a large-scale, noisy and otherwise intrusive use would quite clearly be inappropriate. The proposed development therefore fails to accord with the draft guidance in the draft revised PPG17.

5.39 Turning to the regional level, Regional Planning Policy Guidance for the South East (RPG9) was revised in March 2001. In Policy E1 it states ‘Priority should be given to protecting areas designated at international or national level for either for their intrinsic nature conservation value, their landscape quality or cultural importance.’ There is no mention of a stadium for Brighton & Hove Albion FC, thus further undermining the applicants’ claim that this proposal is of regional importance. In accordance with this policy, the proposed development does not gain support from RPG9.

5.40 At a local level, the proposals have been carefully designed to fall within the boundaries of Brighton & Hove, the eastern boundary of the development site being the boundary between Brighton & Hove and Lewes District. Accordingly, the development plan against which the proposals are to be considered against comprises the East Sussex and Brighton & Hove Structure Plan (adopted in December 1999) and the Brighton Borough Local Plan (adopted in 1995).

5.41 The Structure Plan confirms the need to conserve and enhance Areas of Outstanding Natural Beauty. Policy S1 sets out 21 criteria for the 21st Century. Of these, the tenth is ‘according with the objectives of and not causing damage to the Sussex Downs and High Weald Areas of Outstanding Natural Beauty.’ Policy S10 states ‘Outside defined town and village boundaries agriculture and woodland will remain the main land uses and development and change in the countryside will be strictly controlled……Proposals for new development in the countryside will be required to demonstrate that a countryside location is necessary and that a town or village location would not be suitable.’

5.42 Policy S13 is an area policy relating specifically to Brighton & Hove. It states, in part, ‘To protect the landscape of its setting, no further outward expansion of Brighton & Hove will be allowed beyond the limits of the built up area or other sites defined in the currently adopted local plans except for any allocations made in accordance with Policy E10 in this plan for the early release of land for high quality business development.’ (Being the Structure Plan, Policy E10 makes no specific site allocations).

5.43 Policy E14 relates to the academic corridor along the A270/A27 Lewes Road and supports the promotion and development of the corridor through, inter alia, ‘supporting the development of the higher education and research functions of the universities, within the environmental constraints imposed by their AONB and conservation area locations.’

5.44 Policy LT14 concerns major sporting venues and supports the relocation of facilities where necessary improvements cannot be accommodated on-site ‘subject to complying with Policy S1, other relevant policies and the following criteria’. Those criteria include ‘it being demonstrated to the satisfaction of the local authorities that, where a location is proposed outside a town or village development boundary, there are no alternative sites available and that there is a compelling justification to warrant overriding other policies.’

5.45 Given that the proposal would not accord with the objectives of the Sussex Downs AONB and would cause damage to it (see later in this report); the site at Village Way North appears to lie outside the built-up area boundary identified in the Brighton Borough Local Plan, and that at Village Way South quite clearly does; that alternative sites within the built-up area are considered to be available and suitable; and business development forms only a small part of the overall proposals, the proposed development is considered to be contrary to the adopted Structure Plan.

5.46 The Brighton Borough Local Plan contains a policy relating to the Area of Outstanding Natural Beauty — ENV.54. This states, in part, ‘Development will normally be refused in the Area of Outstanding Natural Beauty which it is proposed to conserve and enhance.’ The majority of the site of the stadium itself at Village Way North is subject to Policy EP.7 ‘Only in very exceptional circumstances will land at Village Way, Falmer, be considered for development. The criteria against which its release would be considered are:
    1. Any planned expansion of the Falmer higher education campuses, but excluding any research and development or high technology uses which are not related to the higher education establishments.
    2. Any such development not being able to be satisfactorily accommodated on sites within the existing campuses.
    3. The design, massing, layout and landscaping of any such development will be required to respect and enhance the sensitive downland location and setting of Falmer conservation area, and
    4. Development will not be permitted which generates traffic which in terms of type and quantity is alien to the rural location and materially damages the amenities of Falmer village enjoyed by residents and visitors.’
      5.

5.47 Land at Village Way South, which would be required either for parking in association with the development of Village Way North or for the alternative site, is subject to AONB/countryside policies. As the proposed development would not conserve and enhance the AONB, would be partly or entirely outside the built-up area boundary and would not be for the planned expansion of the Falmer campuses, it is, therefore, clearly contrary to the adopted Local Plan.

5.48 Brighton & Hove Council published the Brighton & Hove Local Plan First Deposit Draft in September 2000. This contains a policy protecting the AONB by presuming against development within or adjacent to the AONB unless it complies with other policies of the Plan and ‘conserves and enhances the landscape quality and character of the AONB.’

5.49 The First Deposit Draft also contains a policy and an allocation for a new community stadium on the Village Way North site, to which the Board (and others) raised a strong objection. Notwithstanding those objections, the policy and allocation have been carried forward into the Second Deposit Draft, published in September this year.

5.50 A new paragraph has been inserted in the Second Deposit Draft which reads as follows:

‘the development of a community stadium at Village Way North would involve joint working and agreement between Brighton University and Brighton & Hove Albion FC. Since the allocation in the First Deposit plan of the site for a community stadium, negotiations between the two parties have called into doubt whether agreement can be reached in securing a viable scheme. In 2001, shortly before publication of this second deposit plan, the club announced its desire to secure the development of the stadium on a different site, located to the south of Village Way and further into the Sussex Downs AONB. The view of this Council is that, following a number of selection exercises, Village Way North is still the Council’s preferred site. If necessary, however, further consideration to the possibility of alternative sites could be given, including the site proposed by the club to the south of Village Way. Policy SR19a sets out a framework for dealing with proposals for major sporting and recreational facilities on sites that are not allocated in the Plan, and would be applied in respect of any proposal for a community stadium on a site other than Village Way North.’

5.51 Policy SR19a reads ‘Major sporting and recreational facilities which serve Brighton and Hove as a whole should be located within the built up area boundary in a location which is either well-served by public transport or where measures to ensure this can be taken. Any development proposals must be accompanied by an environmental impact assessment; a transport assessment; and a business plan. Any proposal outside the built-up area boundary must be supported by convincing evidence that the proposal was of significant cultural and recreational importance to Brighton and Hove and that no alternative sites were available to warrant a departure from other policies.’

5.52 The Board raised a strong objection at the First Deposit Stage to the implication of this policy that a major development to meet the local needs of Brighton and Hove could outweigh the national importance of the Sussex Downs AONB. This objection will be vigorously pursued at the Public Inquiry into the Local Plan next year.

5.53 The Second Deposit Plan also contains policies seeking to protect the Sussex Downs AONB. Under the terms of Policy NC7, development will not be permitted within or adjacent to the AONB except where ‘the proposal conserves and enhances the visual and landscape quality and character of the AONB and complies with Policy NC6 "Development in the countryside/downland" and other relevant policies in the Development Plan or it can be demonstrated that the development is in the national interest and that there are no alternative sites available elsewhere.’ The policy continues ‘in considering development proposals within the AONB, particular attention will be paid to……avoidance of noise disturbance and light pollution……opportunities to enhance or reinstate the natural beauty and distinctive character of the area and wider landscape.’

5.54 Policy NC6 allows development outside the built up area boundary as defined on the Proposals Map as an exception, inter alia, where the proposal is specifically identified as a site allocation elsewhere (eg SR25). Where development is permitted, ‘it will be required to be unobtrusive, and must respect the form, scale and character of the landscape. For example, through careful siting, design and use of materials……Furthermore, proposals will not be permitted if they result in a level of light pollution, noise, traffic or activity which is out of keeping with its countryside location.’

5.55 The development proposals at Village Way North thus accord, in principle at least, with policy SR25, although not with the policies relating to development within the AONB. The development proposals at Village Way South also fail to accord with the AONB policies and would only accord with Policy SR19a as drafted if it was to be accepted that there were no alternative sites, which it is not.

5.56 In fact, although the Second Deposit Draft represents a stage further in the process of local plan adoption than the First Deposit Draft, the policies of the Second Deposit Draft are still the subject of public debate and opposition/support, and have yet to be tested at the Local Plan Inquiry.

5.57 PPG1 "General Policy and Principles" gives guidance on the weight to be attached to policies as they go through the statutory procedures towards adoption. ‘The weight to be attached to such policies depends on the stage of plan preparation or review, increasing as successive stages are reached.’ Accordingly, the draft policies of the Second Deposit Draft should be accorded less weight than the policies of the adopted Local Plan,.

5.58 PPG1 also contains advice on the determination of applications in relation to emerging policies. It advises that ‘Questions of prematurity may arise where a development plan is in preparation or under review, and proposals have been issued for consultation, but the plan has not yet been adopted or approved. In some cases, it may be justifiable to refuse planning permission on grounds of prematurity. This may be appropriate in respect of development proposals which are individually so substantial……that to grant planning permission would prejudice the outcome of the plan process by predetermining decisions about the scale, location or phasing of new development which ought properly to be taken in the development plan context……a refusal might be justifiable where a proposal would have a significant impact on an…important area, with an identifiable character. ’

5.59 Given this advice, it would be entirely appropriate for these applications to be refused on the grounds of prematurity as well as a number of other grounds.

Visual impact

5.60 Both planning applications are accompanied by Landscape Impact Assessments. As part of these Zones of Visual Influence (ie the areas within which the visibility of the proposed development would potentially have an effect on the character of the view) have been identified extending to a radius of 5 km from the site for Village Way North and 5 km to the west and 9 km to the east for Village Way South. (a 5 km radius from the site extends to Plumpton on the north side of the Downs escarpment).

5.61 Views of the proposed development within the ZVIs are dependent on topography and intervening vegetation. The Landscape Impact Assessments include maps showing the ZVIs and the areas from which the proposed development would be visible, either continuously or intermittently.

5.62 The map for the Village Way North site indicates that it would be continuously visible from the area immediately to the east and from rising land to the south, including from a public right of way leading off the B2123. It would also be visible from a stretch of the A27 just to the east of the junction with the A270 to the junction with the B2123.

5.63 Intermittent views of the development would be gained from the south-east and south-west; the University of Brighton campus immediately to the west (including a public footpath) and Hollingbury, within the AONB, further to the west; Stanmer Park, the University of Sussex campus and the land immediately to the north of the campus to the north-west; Ditchling Beacon, part of the road to the Beacon and Home Brow, Western Brow and Streat Hill along the top of the Downs escarpment where the South Downs Way runs to the north; and The Ridge and Balmer Farm, where there are rights of way to the north-east.

5.64 The main viewpoints are identified as the bridge over the A27 at the junction with the B2123; the junction of the B2123 with Village Way; the bridleway which passes along the north facing slope of Falmer Hill to the south; and, further away, Ditchling Beacon and the South Downs Way.

5.65 The map showing the areas from which the proposed development at Village Way South would be visible demonstrate that the stadium would be considerably more visible than a stadium at Village Way North. Uninterrupted views would be available from an extensive area immediately to the south, south-west and south-east, including the bridleway on Falmer Hill; another extensive area further to the south-east around Newmarket Hill, with a number of rights of way; and areas to the north close to Balmer Farm and to the north-west of the University of Sussex campus. From further afield there would be generally uninterrupted views from the higher parts of the Downs dip slope from the Ditchling Road in the west over to Mount Harry in the east.

5.66 Intermittent views would be available, according to the map, from the campuses of the Universities of Brighton and Sussex, Stanmer Park; a series of ridges on the south side of the A27 to the east; a footpath just to the west of Lewes; a ridgeline about 4 km to the north-west (south of Mount Harry); the South Downs Way at Buckland Bank, 3-4 km to the north-north-east; various high points on the Downs to the north; Green Broom to the north-west; and the east face of Hollingbury encampment to the west.

5.67 Interestingly, the map does not show a stadium at Village Way South being visible from Ditchling Beacon, although as one at Village Way North would be, it would be surprising if it was not and, indeed, the written text confirms it as one of the main long range viewpoints.

5.68 The other main viewpoints are identified as the slip road from the A27 up to the University of Sussex; the junction of the B2123 with Village Way; the bridleway which passes along the north facing slope of Falmer Hill to the south; and, further away, the South Downs Way and Balmer Hill.

5.69 The Landscape Impact Analyses are deficient in that they do not assess the severity of the visual impact of the proposed development from these or any other viewpoints. However, it is quite clear that the impact will be particularly severe from some viewpoints. From the B2123 bridge over the A27, the slip road from the A27 to the University of Sussex, Village Way to the east and Stanmer Park, the proposed stadium at Village Way North would be clearly visible and would break the skyline of the Downs in the background, currently unbroken, as shown in the photomontages submitted as part of the Landscape Impact Analysis, by any existing development. As such, the stadium would have a dramatic and detrimental effect in these views.

5.70 With the exception of the view from the bridge over the A27, which is framed by existing vegetation close to the side of the road to the south of the bridge, the proposed stadium at Village Way South would also have a dramatic detrimental effect on these views, even when the proposed planting has matured.

5.71 For either of the proposed stadia, the Planning Statements submitted with the applications consider that ‘The creation of an innovative and attractive building would better mark the entrance to Brighton and Hove and would help draw attention away from visual harm resulting from the A27T road improvement works’. However, the contrary view is that a development of the scale proposed, unlike anything else in the vicinity in form, bulk or design, would have a greater detrimental impact than the road improvement works and would significantly compound the existing visual and environmental damage suffered by this locality. The redeeming feature of either site is its relationship to the downland, both immediately adjacent and at a distance. Either of the proposed developments would significantly destroy that relationship.

5.72 The sheer scale of the proposed development, plus the white-painted steelwork, means that either stadium would be conspicuous in medium (eg from the bridleway on Falmer Hill) or longer-distance views (eg from the South Downs Way at Ditchling Beacon for either stadium and from Newmarket Hill, Mount Harry and Balmer Hill for Village Way South. A stadium on this site would also be visible from as far afield as the higher slopes of Cliffe Hill, Ranscombe Camp and Mount Caburn to the east of Lewes, some 9 km away.

5.73 As regards the other elements of the proposals, the new link road to the University of Sussex would require the removal of trees from the mature woodland of Tenantlain Plantation, which lies between the University of Sussex campus and the A27, although the proposals also include the reinstatement of a woodland understorey and new tree planting to enhance the existing woodland.

Noise, light and air quality impact

5.74 Construction of the stadium would generate significant noise, particularly during the earthworks. Working would be confined to weekdays, with no work at weekends or Bank Holidays. Following construction, the arrival of spectators and pre-match activities is likely to generate noise. The Environmental Impact Assessment’s noise calculations indicate that increases in noise levels will be difficult to detect, although the new traffic will be perceived as the most significant contributor to noise levels at some locations eg the Lower Lodges at Stanmer Park.

5.75 The Assessment states that during the early stages of development of the stadium, when the main stand is complete but the other stands are not, increases in maximum noise levels will occur during matches. Such increases will, of course, also occur when all the stands have been built, although the effect outside the stadium could be less. Public address systems can be extremely noisy and, although only likely to be used sporadically during a match, could be potentially disturbing if being used continuously before the start of a match. The volume of this could, however, be relatively easily controlled, as could the positioning and use of speakers, for example, any loudspeakers on the exterior of the stadium to be used only for emergency announcements.

5.76 It is considered likely that the bridleway to the south of either stadium would experience an increase in noise levels when the PA system is in use or when the crowds responds to an occurrence during a match. These noises would only occur on match days, and then, apart from 30 minutes or so before a match and 10 minutes or so after the finish, only sporadically. However, the suddenness of the noise could be disturbing. Noise emanating from concerts held in the stadium would be more prolonged.

5.77 As regards lighting, many parts of the proposed development will be lit during events held at the night and in low light conditions. There is existing lighting on the University of Brighton campus, but the lighting of the stadium would, it is believed, be noticeable. Other lighting would be associated with the bus drop-off and coach park and the circulation areas around the stadium.

5.78 The Environmental Impact Assessments consider that for a stadium at Village Way North, the effect on the currently "dark landscape" to the south and south-west of Westlain Plantation would be minor negative, whilst the effect of a stadium at Village Way South would be moderate negative.

5.79 The floodlighting would be designed to minimise spillage out of the stadium, but it would still appear as a bright pool of light when seen from higher ground, particularly as the roofs over the stands would be translucent. It is considered that this pool of light would be a most incongruous feature, unlike any other lighting in the vicinity.

5.80 Impacts on local air quality are anticipated to occur during both the constructions and the 4 operational phases. A slight increase in concentrations of the three main pollutants associated with road traffic; Nitrogen Dioxide, Particulate Matter and Carbon Monoxide, is predicted to at locations adjacent to the surrounding road network as a result of changes in traffic flows. It is stated that these increases are still well within the Government guidelines.

Traffic

5.81 A Transportation Assessment report has been submitted with each application, considering the transportation impact of both a 14,000 capacity first phase and a 22,000 capacity fourth phase stadium development. It is assessed (in the report) that for the first phase approximately 16% of spectators will walk or cycle to the stadium, including those who bus to within two miles of the stadium and then walk from there. Approximately 21% of spectators are anticipated to travel by rail, with a further 23% using the bus services direct to the stadium, 3% coming by taxi or "kiss and ride" and 8% by coach, leaving 29% (4,060) using cars or other private motorised transport.

5.82 For the complete stadium, the modal split is anticipated to change to 16% by walking/cycling/bus and walk, 14% by rail, between 3% and 4% by bus direct to the site, between 16% and 18% by park and ride services, between 15% and 16% by coach, 3% by taxi/"kiss and ride", leaving 29%-33% using cars or other means of motorised public transport (6,380 — 7,220 spectators). The station at Falmer currently accommodates up to four coaches so to achieve the anticipated proportion of rail-users, (3,080 spectators) the four trains each way currently calling at Falmer on what would be match days may have to be increased to six.

5.83 The report proposes a Transportation Management Strategy comprising measures to be secured through planning conditions and a Section 106 planning agreement forming part of any planning consent for the development to address potential traffic issues. These include, for the 14,000 phase:

5.84 Further measures are proposed for the later development of the fourth phase;

5.85 In addition, a package of proposals is proposed to prevent supporters visiting the stadium using the B2123 (The Drove) including non-statutory parking regulations enforced by stewarding and event day signage along the road; advisory signs clearly identifying to spectators that parking and access to the stadium cannot be accessed from The Drove; and extensive publicity advising supporters about the various modes of public transport that can be used to get to the stadium.

5.86 Notwithstanding the proposed use of stewards, there might still be a danger of spectators trying to park along the verges of the B2123, perhaps in the car park on the north edge of Woodingdean, or in Stanmer Park. If the Club is successful and attendances reach the eventual maximum capacity of the stadium, there could well be pressure for additional (general) parking provision at the stadium itself, particularly if either or both of the agreements between the Club and the University of Sussex or Falmer School to use land at both for parking are terminated.

Financial Viability

5.87 Although the costs of and income from a proposed development are not always proper planning considerations, they can be material considerations in the determination of a planning application. They are also of concern with this application, in that if the capital and revenue costs of the proposed development are not met through gate receipts and other activities in the stadium complex, there may be pressure for further development to make the scheme financially viable.

5.88 The proposals include a range of other activities for which the stadium would be used throughout the year, in addition to use on six occasions during the first year by other sports clubs and six other sporting events, such as pop and classical concerts, outdoor shows and participation events. One of each of these are proposed during the first year, but if the demand existed, it is unlikely that the Club would be willing to turn down opportunities to raise further revenue. The potential disturbance associated with the use of the stadium would not, therefore be confined simply to the proposed 30 match days.

6.0 Conclusion
    1. Either of the proposed stadium developments represent one of the biggest developments ever to be proposed within the Sussex Downs Area of Outstanding Natural Beauty, with perhaps only the Brighton bypass being bigger in terms of impact.
    2. It is considered indisputable that the proposals are contrary to national planning policy guidance in respect of development in general, and major development in particular, within AONBs. The Club’s own supporting statement acknowledges that the provision of a new stadium is not a "national consideration" as required by PPG7 and the claim that it is regional is both irrelevant to this test and also highly debatable. It is not accepted that there are no alternative sites — Shoreham Harbour, Brighton Railway Station, the Coral greyhound stadium and the existing "temporary" home at Withdean are all considered to be potential suitable alternative locations for the home of the Albion FC. As such, the test for major development in AONBs set out in PPG7 is not satisfied.
    3. It is also considered that the proposals are contrary to regional planning guidance, which seeks to protect Areas of Outstanding Natural Beauty, and which makes no mention of a stadium for the Albion FC. Similarly, the East Sussex and Brighton & Hove Structure Plan contains policies intended to protect the AONB from unjustified development, which the proposed stadium is considered to be.
    4. Although Policy LT14 concerns major sporting venues and supports the relocation of facilities where necessary improvements cannot be accommodated on-site, given that the proposal would not accord with the objectives of the Sussex Downs AONB and would cause damage to it; the site at Village Way North appears to lie outside the built-up area boundary identified in the Brighton Borough Local Plan, and that at Village Way South quite clearly does; that alternative sites within the built-up area are considered to be available and suitable; the proposed development is considered to be contrary to the adopted Structure Plan.
    5. The Brighton Borough Local Plan seeks to conserve and enhance the AONB, within which ‘Development will normally be refused’. Although part of the site of the stadium itself at Village Way North is the subject of a policy potentially allowing some development, this should be ‘only in very exceptional circumstances’ and only for ‘any planned expansion of the Falmer higher education campuses’, neither of which the proposed development is. The proposed development also fails to comply with the other criteria of that policy. Accordingly, both proposed alternative locations are contrary to the adopted Local Plan.
    6. The allocation of the site at Village Way North in the First Deposit Draft of the Brighton & Hove Local Plan and the indication in the Second Deposit Draft that consideration would be given to a site at Village Way South should carry little weight in the determination of this application as the policy is the subject of objections that have yet to be heard at a local plan inquiry.
    7. Either of the proposed developments would result in a building of a scale, form and design unlike anything else in the locality. It would dominate views of this entrance to the city, destroying the current relationship between the sites and the downland of which they form part in the immediate vicinity, and downland in more distant views. Far from being a benefit in diverting attention away from the A27T, the proposed development would significantly add to the existing discrete areas of urban clutter in the locality. The size, form and design of the proposed stadium would make it intrusive and incongruous when viewed from significant public viewpoints from further afield, such as Ditchling Beacon and the South Downs Way, particularly that at Village Way South.
    8. It is considered that the proposed development would lead to increases in light and noise pollution which, although only related to times when the stadium is in use and, in the case of noise, partly only at sporadic intervals, would themselves be intrusive and detract from the amenity of the locality and, in the case of light, from further afield.
    9. The proposed development would lead to an increase in vehicles using The Drove (the B2123) and Village Way (buses, coaches and disabled spectators; vehicles) to the detriment of the amenity and safety of other users of these routes and the locality.
    10. There is a concern that further development will be sought in time to provide additional revenue for the Club, to the further detriment of this part of the AONB.
    11. Overall, therefore, there are very significant concerns with either of the proposed developments, and it is recommended that very strong objections be lodged to both applications. In addition, it is recommended that the Board’s right to be heard be retained in respect of both applications, and that the Secretary of State be requested to call the applications for his own determination following a public inquiry.

7.0 RECOMMENDATION

It is recommended that, subject to discussion at the Committee:

1. Brighton and Hove Council be advised that:
    1. The Board considers that both of the alternative proposed developments, at Village Way North and Village Way South, are contrary to national planning policy guidance on development within Areas of Outstanding Natural Beauty as set out in PPG7. In particular, the Board considers that the proposals fail to satisfy the tests set in the Guidance Note for major developments within AONBs (and National Parks) in that the Board does not consider the provision of a football stadium for Brighton & Hove Albion FC to be a matter of "national consideration" (unlike the protection of the AONB, which is), and in that the Board considers there to be potentially suitable alternative sites outside the AONB.
    2. The Board also considers the proposed developments to be contrary to Regional Planning Guidance, which seeks to protect AONBs, and to the approved East Sussex and Brighton & Hove Structure Plan, including Policy LT14. The proposed developments are contrary to the adopted Brighton Borough Local Plan which, together with the Structure Plan, forms the development plan for the purposes of this application. The Board notes the policies in the Second Deposit Draft of the Brighton and Hove Local Plan, but considers that these should carry little weight, certainly less than those of the approved/adopted development plan, in the determination of these applications, as they are the subject of outstanding objections which have yet to be discussed at a Local Plan Inquiry. In this respect, the Board considers that these proposals are premature and that the granting of permission would prejudice the proper local planning process.
    3. The Board considers that a proposed stadium, of the scale, form and design, would be unlike anything else in the locality and that it would dominate views of this entrance to the city, destroying the current relationship between the sites and the downland of which they form part in the immediate vicinity, and the downland in more distant views. The Board believes that, far from being a benefit in diverting attention away from the A27T, the proposed development would significantly add to the existing discrete areas of urban clutter in the locality. The size, form and design of the proposed stadium would, in the Board’s view, make it intrusive and incongruous when viewed from significant public viewpoints from further afield, such as Ditchling Beacon and the South Downs Way, particularly that at Village Way South.
    4. The Board considers that the proposed development, however well-designed, would lead to increases in noise and light pollution which, although only related to times when the stadium is in use and, in the case of noise, partly only at sporadic intervals, would themselves be intrusive and detract from the amenity of the locality and, in the case of light, from further afield.
    5. The Board is concerned that some spectators, wishing to access the stadium by car, would seek park elsewhere than in the designated parking areas, leading to congestion, loss of amenity and potential hazard to road safety. The Board also believes that there could be pressure in the future for additional, general, car parking adjacent to either stadium.
    6. The Board is also concerned that the financial commitment of the Albion FC to this development could be such that further development will be sought in time to provide the necessary income to cover capital and revenue costs, leading to the further degradation of this part of the AONB.
    7. Accordingly, for these reasons, the Board objects most strongly to either of these proposed developments.
    1. The Board’s right to be heard be reserved in respect of both applications.
    2. The Secretary of State be requested to call both applications in for his determination following a public inquiry.
    3. A further report be presented to the Planning Committee in December, if necessary, updating the Committee on the situation and seeking to clarify any issues identified by the Committee.
    4. The endorsement of the Board of the Committee’s resolution be sought at the next meeting of the Board in January.

Martin Beaton

Sussex Downs Officer

Contact: Martin Small 01903 741234

e-mail: msmall@southdowns-aonb.gov.uk