Local developments

Email from Sport England to Merton 20/P3237

Email from Sport England to Tim Lipscomb (Merton Planning Officer)

Subject:  App Ref: 20/P3237 -  Land South of Meadowview Rd (LESSA) - Sport England Ref: PA/20/L/MR/57140

Date: 23 February 2021


Dear Tim, 

Further to my previous response, Sport England has been provided with significant further information regarding sporting demand for this site. I immediately forwarded this to the relevant NGB colleagues and asked them to investigate it, which they have now done and revised their responses accordingly. As such, Sport England wishes to update its response to this planning application. Please consider that this response supersedes any previous responses. 

Sport England –Statutory Role and Policy 

It is understood that the proposal prejudices the use, or leads to the loss of use, of land being used as a playing field or has been used as a playing field in the last five years, as defined in The Town and Country Planning (Development Management Procedure) (England) Order 2015 (Statutory Instrument 2015 No. 595). The consultation with Sport England is therefore a statutory requirement. 

Sport England has considered the application in light of the National Planning Policy Framework (in particular Para. 97), and against its own playing fields policy, which states: 

‘Sport England will oppose the granting of planning permission for any development which would lead to the loss of, or would prejudice the use of: 

  • all or any part of a playing field, or
  • land which has been used as a playing field and remains undeveloped, or
  • land allocated for use as a playing field 

unless, in the judgement of Sport England, the development as a whole meets with one or more of five specific exceptions.’ 

Sport England’s Playing Fields Policy and Guidance document can be viewed via the below link:


The Proposal and Impact on Playing Field 

The proposal is for 89 dwellings and associated infrastructure, plus 2 tennis courts with associated floodlighting, storage and car parking. This will involve the loss of the entire existing playing field. 

Assessment against Sport England Policy 

This application relates to the loss of existing playing fields. I understand that the applicant has suggested it mitigate this loss by contributing towards playing fields in the area in order to significantly increase their use, and that the Merton Playing Pitch Strategy would be supportive of this. It therefore needs to be considered against exception 4 of the above policy, which states: 

‘The area of playing field to be lost as a result of the proposed development will be replaced, prior to the commencement of development, by a new area of playing field: 

  • of equivalent or better quality, and
  • of equivalent or greater quantity, and
  • in a suitable location, and
  • subject to equivalent or better accessibility and management arrangements.’ 

I therefore assessed the existing and proposed playing fields against the above policy to determine whether the proposals meet exception 4. 

The element of the proposal which includes the tennis courts was assessed against exception 5, as these have the potential to be considered an alternative sports facility of sufficient benefit to the community so as to outweigh the loss of playing field. 

Assessment of Existing Playing Fields 

The existing playing field (also known as the LESSA playing field) comprises 2.27 hectares. A quantity of playing field to the north was lost some years ago when a portion of the field was redeveloped for housing. Historic aerial photography shows that in previous years it has been used for both cricket and football. I understand that in recent years the site has been closed and unavailable for sport. 

Merton has a Playing Pitch Strategy (PPS) which states that this site should be bought back into use (if viable) to meet current sporting needs and future demands. These sites should be subject to thorough investigation by the steering group and the landowners, to understand whether a club or community group would be able to purchase and viably deliver part, or all of the site, for sporting use. This investigation is subject to a time limit of no more than six months from the date this PPS is adopted by the council. Should the site not be delivered for sporting use, a Section 106 financial contribution will need to be agreed as part of any development on the sites, to reinvest in other sport facilities in the Borough. 

Following Sport England’s previous assessment of this application, it has since been in receipt of a letter dated 11th February from the West Barnes & Raynes Park Residents. This letter contained further information which highlights that there remain parties that are interested in using the site for cricket and have the resources to redevelop it. I understand that these parties attempted to contact the applicant’s agent and the local authority to make them aware of this. While these parties were referenced in the Sports Needs and Viability Report originally submitted as part of the application, this document ultimately concluded that neither of them had ‘viable bids’, however it would appear the situation has moved on since the submission of this report. 

Following receipt of the above letter, I requested that NGB colleagues investigate this. The ECB and Surrey Cricket Foundation have confirmed to Sport England that they last week undertook meetings with the following two groups this week to explore their interest further and summarise these conversations as follows; 

Consortium - Willington School, AJ Academy & Wimbledon United CC 

  • The school currently rents Drax Playing Field and would like to secure their own “home” playing field
  • They have previously explored other playing field sites in the borough such as Raynes Park but haven’t been able to secure them for the school’s use.
  • The school aspires to access the site during weekday, daytime hours.
  • The school wrote directly to Merton Council to express their interest in the site
  • The school has stated that it has the resources available to invest in and redevelop the site for cricket activity.
  • AJ Academy also wrote to Bellway and their Agent in August/September 2020 to express interest in their site, which was acknowledged. They also wrote to Merton Planning officers.
  • The Academy would be seeking to utilize the site on evenings/weekends for junior activity, which would complement the school’s requirements in terms of access.
  • Wimbledon United CC plays Sunday friendly fixtures, currently at Cottenham Park and LESSA would be an ideal home for their club.
  • They also wrote to Bellway to express their interest, which was acknowledged, although they’ve had no further response.
  • The consortium would be keen to work collectively to redevelop and access the site, with their intended hours of use lending themselves to a collaborative approach. 

The Wimbledon Club (parent organization of Wimbledon CC) 

  • As a large cricket club, Wimbledon CC hire a number of pitches across the borough. They are at capacity and have been actively seeking a second site.
  • They have identified LESSA as an ideal opportunity to develop for lower XI cricket and junior academy use.
  • They’d be happy to make the playing field available to other sporting use outside of their access for senior and junior cricket activity, such as junior football.
  • They notified Stephen Hammond MP of their interest in the site. He has contacted Bellway directly on the club’s behalf to express their interest.
  • The club has stated that it has the resources available to invest in and redevelop the site for cricket activity. 

On receipt of this new information, the ECB would therefore like to amend its position to object to the proposed loss of the playing field, since there is clearly local cricket interest in accessing and redeveloping the site for the benefit of the local community. 

It also notes that both groups have contacted both Bellway and Merton Council to express their interest. Had the ECB been aware of the continuing interest of these groups, would certainly have objected to the redevelopment of the playing fields in the first instance. 

The RFU have also confirmed, that, following receipt of the letter highlighting their engagement with Old Emanuel RFC (OERFC) and the rugby club’s potential use of the site, the RFU has conducted further consultation with the club. In addition to its previous comments, the RFU has commented that the site was identified as not historically having been used for Rugby Union and, as such if new cricket demand has been identified, the RFU would support an amended position to object to the disposal of the site. The communication from the West Barnes & Raynes Park Residents Association makes specific reference to the needs of OERFC. It also highlights that the LESSA site would not provide a total solution to the OERFC requirements with the forthcoming vacation of their current base at Blagdon’s. The current priority for OERFC is to identify a site that can ideally accommodate all or the majority of their requirements i.e. Raynes Park, Taunton Avenue. This is a discussion that is underway with the council. The RFU position is that LESSA may provide additional pitch capacity should it be needed, once negotiations are concluded with LB Merton as to the Raynes Park site (and the capacity thereon) and subject to the needs of cricket as a priority. The RFU would also take the opportunity to re-iterate its original request for an holistic approach to understand the opportunities to address the shortfalls identified within the LB Merton PPS. 

Sport England’s previous position was predicated on full NGB agreement that there was no demand for this playing field. This further information, in particular with regard to cricket, makes it clear that there is in fact demand for this site for sport; furthermore at least one of the above parties state that it has the resources to bring forward the site for sport in a viable manner (as per the PPS requirements and the Viability Report submitted as part of the planning application). This being the case, it is therefore no longer considered that a financial contribution is an acceptable alternative in this instance, as protecting the existing playing field is a priority where there is clear demand. As there now appears to be viable and clear demand for this playing field, this application does not meet Exception 4. Sport England would expect to see the landowner work with these parties in order to ensure that the sites are brought back into use for sport. 

The tennis court element of the application continues to meet Exception 5 as it provides a new sport facility and I understand the LTA are supportive of this element and the additional funds proposed towards investing in the adjoining tennis club. However, considering that demand for the existing playing field has now been confirmed, this element alone is not considered sufficient to mitigate the loss of the remainder of the playing field. 

In light of the above, Sport England objects to the application because overall it is not considered to accord with any of the exceptions to Sport England's playing fields policy or with Paragraph 97 of the NPPF. 

Should your Council be minded to grant planning permission for the development then in accordance with The Town and Country Planning (Consultation) (England) Direction 2009, the application should be referred to the Secretary of State, via the Planning Casework Unit. 

In addition, the application is also considered to prejudice the use of a playing field of more than 2 hectares of land and is therefore development of 'potential strategic importance' (PSI) as defined by The Town and Country Planning (Mayor of London) Order 2008. As such, a copy of this application must be sent to the Mayor of London for consideration. 

If this application is to be presented to a Planning Committee, we would like to be notified in advance of the publication of any committee agendas, report(s) and committee date(s). We would be grateful if you would advise us of the outcome of the application by sending us a copy of the decision notice.  

If you would like any further information or advice please contact the undersigned at the address below. 

Yours sincerely, Laura Hutson, Planning Manager

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