OSLPF User Group ‘Messages’ v.5 (16/04/14)
These Environmental and Sporting messages will be updated/enhanced during the
period of public consultation, which runs until 30th April. You are welcome to
use any of the information and opinion recorded below in voicing your opposition to
the proposed development via the E&EBC Planning link.
Environmental Impact
1. Representations have now twice made objecting to proposals under the
Development Management Policies Consultation exercises, expressing concern about
potential weakening of protection of strategic open spaces, playing fields and open
spaces , and Conservation Area in the borough (Ewell Village Conservation Area
Review 2009 : “The existing open green spaces, mostly in private ownership, such as
the playing fields, will be protected from future development by the strict imposition
of existing policies.”) ;
These Playing Fields were rejected for building under Council SHLAA. The Council has
designated 20+ sites in the Borough for housing building over next eight years. Why
choose a site for a Care Home – perhaps to be more appropriately described as a
‘retirement village’ that has been considered and specifically rejected because it is a
Strategic Open Space in the Borough Plan?
2. The proposal, which will result in the loss of approx. 40% ( - as opposed to the 25%
quoted in the proposal) of the existing playing area, seems totally contrary with
targets related to obesity and Olympic legacy.
3. The proposal will result in the loss of Strategic Open Space, that of grass sports
pitches – for which there is a recognised scarcity, and the loss of a ‘jewel’2 of the
village fundamental aspect of village life – open space – quality of life/safe & secure
area, sports ‘club’ (- as opposed to merely an open space), … only sports club
(soccer/cricket/rugby) in the village. The current facility is an ideally located,
proportioned and protected sports area.
4. The playing fields have been register as ‘Community Asset’ by the appropriate
number of local residents which affords them the ‘Right to bid’ for the playing fields
and for them to be retained in their entirety as playing fields
5. As a Strategic Open Space the site is automatically Registered as ‘Green
Infrastructure’ or ‘Heritage Site’ in current ‘Other site Allocation’ Council
Consultation.
6. Part of the sports field is a designated flood plain and an area of natural springs. The
applicants assure us that existing natural drainage in areas to continue as sports
fields will be improved. We rely upon … to confirm that this can be achieved as we
will seek assurance as to how the increased hard landscaping can lead to anything
but increased potential for flooding.
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The existing range of grass pitches facilitates rotation of use of pitches and avoidance
of overuse enabling recovery and maintenance/repair.
7. The access point to the sports fields via Old Schools Lane is unsuitable1 for any
increase in vehicle traffic, which would inevitably be the outcome of a successful
planning application. Even current access arrangements are inadequate ie. which
barely afford sufficient protection for pedestrians, the majority of whom on a daily
basis are children attending a local primary school (St Clements) or pupils of a
secondary/primary school (Ewell Castle). Ewell Castle pupils are the indeed the main
users of the facility, five days a week, and all traffic is by foot. To this number we add
visitors and employees at the existing care home (Priory Court) in Old Schools Lane,
nd local residents. This traffic is primarily vehicle traffic and already contributes to
the vulnerability of other users and leads to congestion and illegal/over parking. Old
Schools Lane is a narrow lane with a ‘blind bend’. Hence the development proposal
would only increase risk. Our conclusion is endorsed by the former EVRA
architect/advisor – see below.
We are advised that any increase in traffic for sports use will not be a matter for planning
concern as there is an existing sports facility! This apparent loophole is a concern as there will
inevitably be more vehicle traffic under the proposal.
8. There remains also a query as to the ratio of units and occupants, and therefore the
number of cars, to the parking spaces provided.
The Care home/Retirement accommodation is to provide for 60 self-contained units,
40 2-bedroom flats and 20 1-bedroom flats. Occupancy is estimated by Abbeyfield,
based upon their experience at c.80 persons, and provision is made for some parking.
However, occupancy capacity is actually far higher and parking for residents and
visitors appears inadequate.
9. The ‘building mass’ – three stories, will be overwhelming for the environment. The
building has been described1 as a ‘Victorian institution’!
10. There are two protected trees, which could not according to the first proposal, be
removed. It is hoped that this condition is not relaxed.
11. In such an area, there are inevitably other aspects of potential environmental
impact eg. bats & other wild life.
Furthermore, we seek confirmation of the impact upon services and amenities incl.
healthcare, utilities (eg. sewage), …’
We acknowledge that it is incumbent upon the planning committee to satisfy
themselves in this regard.
cont’d/...
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.../cont’d
12. It is known that a separate application has been made for a care home on another
site in the village. If it is deemed that the borough requires extra care
home/retirement accommodation why cannot direction be given by planners to
seek to meet both needs on the alternative, or indeed another site.
Sporting impact
1. A comparison (metres) of that existing and what is proposed is :
The proposal provides in winter for:
 one artificial (hockey) pitch
 one* grass pitch for soccer/rugby pitch (96x60/94x55) – which is well short of full
size FA (119x91), of FA standard for level of football (FA Vase - top amateur)
currently played (100x64) and of FA ‘norm’ (101x66), although recognised as
above FA minimum ( 91x46), and short of RFU standards (112-122x68) in respect
of size.
 some junior/practice areas.
In summer there is space for:
 a cricket circle – boundary diameter 107 rather than 137 (full size) which is not
desirable for adult championship cricket
 an ‘under-size’ athletics track, as well as the
 artificial hockey pitch
The existing provision in winter, is for:
 three designated soccer pitches 104x68m, 100x57m, 92x63m ie. all three larger
than the one grass pitch proposed above.
 one rugby pitch (91x57m) and,
 practice/junior play areas.
and in summer there is:
 an ‘adult size’ cricket circle with 10 playing ‘strips’
 a 400m athletics track
2. The current facilities have extensive daily School and Local Community usage in spite
of claims to the contrary in the planning application.
The proportion of playing area to be potentially lost is c.33%.
It is understood that the proposal seeks to meet Sport England criteria of no ‘net loss
of sporting provision’, by introducing an artificial surface with the capacity for more
daily /weekly use than a grass pitch, albeit at the expense of grass (match) areas.
[Sport England, who cover the relevant sports governing bodies, ie. FA, ECB, RFU
were consulted in 2013 and concluded that “... the proposed care home is not a
sports facility and therefore does not accord with any of Sport England’s exceptions
for development on playing fields. Sport England’s policy does not support enabling
development.”]
cont’d/...
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.../cont’d
3. It is also proposed only one* grass area be used for soccer and rugby. This is totally
unrealistic as, not only is different grass length sought for the games, but one pitch
can certainly not withstand regular use throughout the winter months.
4. The area that may be lost to sport is indeed the best playing area on the site ie. that
which is not landfill as the remainder of the site, and for football is recognised as one
of the best surfaces in the Southern Amateur League. This area of loss currently
provides for a 1st XI soccer pitch and floodlit youth pitch/adult training area (winter)
and cricket square and outfield (summer)
5. It is worthy of note and somewhat ironical, that the first proposal (Nov. 2013)
provided for more soccer pitches, at the expense of cricket, and cited the need
locally, as identified by sports & recreation officers, for more soccer pitches! In this
latest proposal soccer is forfeited in favour of hockey.
The latest Sport England age 16+ participation data for year ending October 2013
reveals little case for hockey over soccer with football participation is 20 times larger
than hockey.
Football - 1,838,600
Hockey - 86,900
Rugby Union - 160,000
Cricket - 148,000
Athletics - 2,016,000
6. The potential ‘sports partner’ in the development is a local and highly regarded club
who have themselves identified the need for ‘their own’ hockey pitch. This is in spite
of the fact that there are four artificial hockey pitches within ten minutes drive of
the location of the club, and some of which they currently make use.
It is also regrettable that one sports club of over eighty years standing, is to be
evicted in favour of another club seeking to acquire further sports facilities.
7. The existing cricket facility is the only ‘square and circle’ of a reasonable (adult)
playing standard (and size) in the borough, other than Priest Hill (Glyn School), Epsom
College and Epsom CC. The latter two being of good and not surprisingly privately
owned. It is recognised that cricket is rarely self-financing given the maintenance
and preparation demands of the playing surface, hence it tends to be only private
clubs that can offset the costs. That the facility is used by a Cricket Club (Worcester
Park) out of borough reflects upon the paucity of pitches even beyond the immediate
borough. Indeed, although the Worcester Park club is situated in the London
Borough of Sutton, LBS does not provide any cricket pitches for hire. They therefore
have to move outside the Borough to hire cricket pitches. Old Salesians is probably
the nearest venue of a suitable standard for the club to hire for their Surrey
Championship league games. The other user is the only other secondary school
(Ewell Castle) in the area playing any ‘serious’ cricket.
cont’d/...
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.../cont’d
8. There has been significant financial investment in the facilities over many years, in
spite of claims to the contrary in the planning application – although acknowledged
not of the magnitude now proposed in the development ‘package’, albeit at a ‘cost’
in other terms that we believe to be detrimental. Indeed the benefits of the proposal
from a sporting perspective, ie. primarily a new purpose built clubhouse
incorporating changing and social facilities, do not outweigh the losses described
above, and there is even a perfectly adequate current Pavilion and Social Club
buildings
Indeed, the Old Salesian FC constructed and run their own social club, and more
recently, the pitches and changing rooms have been upgraded and refurbished
respectively. On the question of community facility, it seems unlikely that a social
facility will exist at the venue under the proposal, as the ‘sports partner’ have their
own social club in Epsom and hence facility at Old Schools Lane will become a
‘satellite’ ground.
The existing facility represents a safe and secure environment as well as a fine sports venue. A
‘clubhouse’ ensures indirect security and a greater sense of ownership and responsibility.
9. Not only are the proposed pitches (soccer) reduced in size from current dimensions, the
orientation and positioning of pitches means they are too close to the railway line and
woodland with inherent issues of safety. It is acknowledged that a 3m fencing is proposed due
to proximity of the cricket pitch to the new pavilion. However the prospect of further protective
fencing/netting will negatively impact upon the environment and potentially on wildlife.
Those responsible for the planning of the sports provision do not appear to be understanding or
sympathetic to an outdoor sporting environment, rather perhaps they are restricted by the
space allowed to them due to the priority of the building development. One cannot squeeze
natural grass pitches as one can say an artificial grass pitch or indeed a tennis court, ‘within a
fenced perimeter’. There is a ‘natural’ area/setting sought for soccer, rugby and cricket which
ideally is also aesthetically pleasing and allows for rotation of use of the natural surface for short
and longer term benefit.
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Notes/Appendices:
1. Richard Evans – Ewell resident and former architect/advisor to EVRA has
conveyed (in a private capacity) in November 2013:
 Old Schools Lane is too narrow to provide an adequate vehicular access for any further
development. It has a blind bend and a footpath on one side only. Unfortunately, this was
not shown on the drawings. It is used by children from the neighbouring school.
 The adjacent properties in Spring Court are close to the boundary and will suffer from
the noise of vehicles using the car parks. The plan is reminiscent of a Victorian institution
and at three storeys would have a visual impact that would not be in keeping with
neighbouring development.
 A significant proportion of the flats will receive no sunlight.
 There are other sites in the village that would be more suitable – part of the recreation
ground between Beggars Hill and London Road.
 Any future presentation should include a Location Plan showing where the site is in the
village and its relationship with adjacent development etc.
 A tree and ecological survey of the site needs to be carried out.
2. The EVRA committee observed the proposal in December 2013 as :
 “The land wasn't featured as part of the the Strategic Housing Land
Availability Assessment and are designated playing fields.
 Existing access lane is too narrow and would be unable to cope with the
additional volumes of traffic for 90 residences, staff, visitors and suppliers.
 Adjacent properties will suffer from the vehicles using the car parks.
 Sunlight access will be an issue for the flats
 Ewell Castle (and other parties) currently use the playing fields.
 With plans for Ewell Grove to possibly develop into a Primary School, they
too would need access to playing fields.
 The current green space approaching Ewell West by train from London is
viewed as a positive aspect.
 Have the opinions of local residents directly impacted by the proposals been
canvassed?”
and concluded
“Therefore, the views of the committee are not to support the application for the reasons
above.”
adding:
As an add-on to the above I would like to suggest a further point 9 to the next committee
meeting:
In a Ewell Village conservation area review conducted about three years ago the
Borough Council formally adopted a review document which contained:-
cont’d/...
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Character Area 1 - Kingston Road, the mills and water and Bourne Hall.
“ To the West of the watercourse are extensive playing fields, owned privately.
Together with Bourne Hall and its park, the trees, water features and green spaces
give this part of the conservation area a more rural quality despite the busy traffic
along Kingston Road.
“Summary of issues……(relevant to this subject)
Protecting the open green spaces, such as the playing fields from development.
3. The proposed development appears to fail to satisfy Epsom Borough Council's
core strategy for the following reasons :
Core Strategy
For many people the provision of community facilities and access to open space are key
concerns. Some areas are deficient in leisure or recreational provision, or in access to open
space. In other areas there is a surplus.
This is not proven in the documentation and no reference made to a PPG17 Audit or
relevant up to date Playing Pitch Strategy which is encouraged in all Councils.
Policy CS 13
The loss of community, cultural and built sports facilities, particularly those catering for the
young or old, will be resisted unless:


It can be clearly demonstrated there is no longer a need for such a facility in either its
current use, or in any other form of community use, or there is an appropriate
alternative means of providing an equivalent facility.
The provision of new community, cultural and built sports facilities, and the upgrading of
those existing, will be encouraged, particularly where they address a deficiency in
current provision, and where they meet the identified needs of communities both within
the Borough and beyond.
The current proposals do not meet Policy CS13 as :
 Current usage is extensive ie. the need exists for the particular range of (grass) soccer
and cricket facilities;
 The alternative proposed is not ‘equivalent’
 There is no deficiency in current provision – exemplified by the potential sports partner
already having access to several other artificial grass pitches for hockey;
 An identified need in the area are for grass soccer pitches pitch, indeed in Abbeyfield’s
own words : "The proposal has been discussed with the Recreation and Leisure
Manager for Epsom & Ewell Borough Council who has indicated the greatest need is
for more football provision."[Nov 2013]
Obviously their current proposal to reduce four adult grass pitches and one junior
football pitch to just one shared football/rugby pitch totally conflicts with this
statement.
ie. these facilities are in demand and will not be suitably upgraded in terms of quality or
quantity to mitigate the loss.
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cont’d/...
.../cont’d
Policy CS 4
Provision of the amount and type of open space within the Borough will have regard to the
standards identified in the most recent Audit of Open Space, Sport and Recreational Facilities
and Assessment of Local Needs. The required quantity and range of open spaces will be
rigorously maintained, and focus will be given to the creation and maintenance of an
accessible network of green spaces within the built up area of the Borough.
Development which results in a deficit of open space provision will not be permitted.
There is little evidence to support that the current facility is now surplus to demand.
Borough's Community Strategy
The Sustainable Community Strategy (2010-22) has children and young people, community
safety, health, housing and well-bring and environment and sustainability as priority themes.
The two overarching themes adopted by the Local Strategic Partnership are – creating
opportunities for all, and supporting a society that recognises the needs of future
generations.
Seven further sub-themes are developed which reflect the priorities of the LSP:
 a caring society and thriving economic community
 a protected and improved environment
 a safe society
 a healthy society
 a harmonious and inclusive society
 communities working together
 supporting the voluntary and community sectors.
The proposal would go against supporting the voluntary sector and a healthy society by
reducing playing pitch availability.
In 2005 the LSP adopted a more focussed approach to the community strategy work it
oversees and monitors. It developed an annual action plan for its five priority areas which
are:
 young people
 anti-social behaviour
 transportation and congestion
 quality of the environment
 health
Again the proposal would go against those objectives listed above.
Extensive support for options that generally protect the Borough’s green spaces was given
in response to the ‘preferred options’ consultation. Improving their environmental quality is
a specific objective of the Community Strategy which recognises their social, recreational
and environmental value.
cont’d/...
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.../cont’d
Planning Policy Guidance 17: Planning for Open Space, Sport and Recreation,
requires local authorities to undertake robust assessments of the existing and future needs
of residents and visitors in relation to open space, sports and recreational facilities.
Consultants were appointed by the Council to undertake a comprehensive audit and review
of recreational open space needs in accordance with PPG17. They reported in March 2006
and identified the types of open space and their distribution and size in relation to locally
identified needs, and suggested the standards of provision that should be set locally. The
study identified where deficiencies exist and also where land did not contribute significantly
and was potentially surplus to needs.
In the absence of a Playing Pitch Strategy or an accessible link to a PPG17 Audit for Epsom
Borough this is impossible to determine.
Leisure Development Strategy 2012-16
(Adopted Leisure Committee item 04 [18 January 2012]
The Place Survey (2008) stated that 43% of residents perceived that young people hanging
around on the streets was the biggest problem with regards to anti-social behaviour.
Furthermore 45% of residents believe that activities for teenagers needed improving within
the Borough.
The Department of Health have recognised that physical activity and sport are fundamental
to achieving lowering obesity, reducing coronary heart disease, helping with anxiety and
depression and has many more health benefits. ‘Be active, be healthy’ (Department of
Health, 2009) is a new framework for the delivery of physical activity alongside sport.
The Sport England Strategy 2008 – 2011 expresses a clear shift in focus and direction for
sport in the country. Sport England’s three key objectives are:



Excel – developing and accelerating talent
Sustain – ensuring current levels of participation have a high quality experience with
specific actions to target the post 16 ‘drop-off’
Grow – one million more people doing sport by 2012-13.
In particular
Aim 1 - Maximise usage of local facilities for sports and leisure activities

Objective 2 - To work in partnership with local facility providers to support and develop
activities
The current users are local but have only been offered partnerships by the developer with
reduced/inferior facilities, whereas:
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.../cont’d
Aim 2 - Maintain and develop sport and leisure activities for the local community



Objective 1 - To maintain the delivery of existing sport and leisure activities
Objective 2 - To develop new sport and leisure initiatives
Objective 3 - To provide support to allow individuals and clubs to maximise their sporting
potential
4. ………………….
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16th April 2014
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