as outlined in Planning applications 21/P2900 (LB Merton) and 2021.3906 (LB Wandsworth) July 2021
Parkside Residents' Association
(More information and detailed analysis of the points considered below and the wider context is available in our paper “Analysis of Community Benefits” dated 18 February 2023 which has been submitted to Merton and Wandsworth Councils as a planning objection.)
The application site, formerly the Wimbledon Park Golf Course, is part of the Historic Grade II* Listed parkland originally laid out by Capability Brown, it is within a Conservation Area and designated as Metropolitan Open Land (“MOL”) – the urban equivalent of Green Belt. Planning policy is clear that development in Green Belt/MOL is inappropriate, “Very Special Circumstances” (“VSC”) must be demonstrated to justify the grant of planning permission. This is a very high bar: Green Belt/MOL is there to be preserved.
The AELTC are offering a number of Community Benefits, described as “significant”, as a core element of their VSC case to justify planning permission for their “Wimbledon Park Project” (“WPP”). As the Analysis paper and summary below confirm, there are too many shortcomings to the package of Benefits to demonstrate that the requisite VSC case to justify planning permission has been met.
The headings below follow those adopted in the list of Benefits presented in the Statement of Community Benefits (“SCB”) submitted with the AELTC’s Planning Addendum in May 2022. Our Reply (R) in each case summarises the detailed points in the Analysis paper.
1. The proposals will “maintain the global appeal of the Championships and increase access”
R – The continuing global appeal of the Championships as the only Grand Slam Tournament played on grass is not contingent upon the provision of the proposed facilities in this location. Play on “Middle Sunday” since 2022 has already increased access. The expansion will not add more matches to the Championships schedule and the new courts will see just 2-3 weeks tournament use at most, some only for practice. The Qualifying event being transferred from Roehampton could be relocated elsewhere in the country to widen interest in tennis beyond SW19 but the AELTC are unwilling to consider this. The closure of the Roehampton centre will mean a loss of community tennis facilities which the WPP will not replace. The proposals prioritise commercial event opportunities and Members’ interests rather than year round community sporting opportunity and do so at the expense of community amenity.
2. The proposals will “Deliver Social and Economic Benefits”
R – The projected economic benefits linked to visitor numbers and their spending patterns are based on a modest survey sample from 2016 and speculative assumptions about the relocated Qualifying event. Claims for likely increased investment in local tennis via the Lawn Tennis Association (“LTA”) and additional funding for charitable initiatives are unsubstantiated and unsecured. Permanent employment opportunities are disproportionately modest given the scale of the project’s capital investment.
3. “A new AELTC Park” will be provided
R - The clue here is in the name: the new “AELTC park” will belong to the AELTC, not the public who will only have “permissive” access. It is located at the southern end of the site, planted with rough grassland and will have no typical public park type facilities such as play areas, courts or pitches for sports or leisure activities or even public toilets. As owners, the AELTC will control access – restrictions around the Championships period have already been stipulated but more could follow. The park’s long term availability to the public is vulnerable to the AELTC’s future expansion plans unless it is transferred into public ownership via a community trust.
4. The AELTC “will fund the cost of de-silting Wimbledon Park Lake”
R - The works to the Lake will support water sports but will also protect the integrity of the AELTC’s own Lake borders as well so there is vested self interest in this offer. The methodology of the works and supporting biodiversity analysis have also been challenged in expert reviews
5. “A new Boardwalk and Angling Pontoons will be provided”
R - The Lake Boardwalk is an important part of the overall benefits package being offered, and is presented as a new public access initiative. In fact the AELTC is already obliged under its purchase obligations from 1993 to “dedicate” a public walkway around the perimeter of the Lake once golf ceased to be played. The new Boardwalk has been criticised for compromising some views and follows a shorter route, mostly within the Lake boundaries, than that agreed in 1993. This enables the AELTC to retain for its private use perimeter land around the Lake which was due to be returned to public ownership. The AELTC also propose controlling access to the Boardwalk, contrary to the unrestricted public access and ownership envisaged by the 1993 commitment.
6. The proposals will deliver “Heritage Enhancements” within the WPP site
R - The proposals will impose a huge Stadium, 10 other buildings, 38 courts and complex infrastructure for a highly specialist sporting landscape onto protected Heritage parkland already designated as “At Risk”. This is hardly consistent with Capability Brown’s original vision. The density of the new courts is excessive in this protected landscape especially given the very limited tournament use proposed for them. The huge scale of the project requires extensive excavation and earthworks to level the site with a significant loss of valuable trees and their carbon capture which new planting could take over a century to replace.
7. A platform for delivering “World Class Architecture” and facilities
R – An ambitious claim which is difficult to justify with this hybrid application where the full design details for the Stadium and the larger buildings have not been disclosed. But it cannot be ignored that a 104m wide, 28m high 8,000 seat Stadium with a roof will be a substantial, visually intrusive structure on a heavily protected MOL landscape.
8. The “Parkland Show Court will look to provide interior spaces that can serve a multi- functional purpose” for use by the local community
R - Vague offers of possible public use of unspecified “multi-functional” facilities within the Stadium are still not clarified or evidence based despite repeated requests for details from planning authorities including the GLA. This is a dominant, obtrusive sports arena in an inappropriate location; offering limited public access does not change its core purpose or its negative, year round impact.
9. “The Golf Clubhouse will be converted into a space for wider community use”
R – As with the Stadium, vague offers of unspecified community uses are still not clarified, but should be if this offer is to be properly evaluated as part of the planning process. In the longer term this building is also vulnerable to future AELTC commercial expansion unless community use is safeguarded by transfer of ownership to a community trust.
10. There will be “Community access” to “up to seven” of the new grass courts
R - This is a derisory offer, belatedly presented after widespread criticism, for very limited access given that 38 grass courts are potentially available in the 8 weeks (max) post Championships until the end of the grass Court tennis season. There will be no “book and play” option for the public to play tennis on these courts; far from expanding public access to tennis facilities, the offer will mostly support existing community junior tennis initiatives. “Mothballing” most of the courts when they still have capacity for amateur use seems a very wasteful use of this extensive (and expensive) sporting resource.
11. Tours of the WPP site and learning programmes will be offered
R –Taking visitors on conducted tours of the site is not a justification for an aggressive overdevelopment of MOL which will have significant adverse implications for protected historic parkland. Wider public access should also be delivered by allowing use of the tennis courts which in season will otherwise only be “on view” and not “in play” on the tours. Tours and learning programmes can usefully report the history of the historic parkland and its biodiversity; but they should not be contingent upon the outcome of this application.
12. There will be “a daily allocation of 500 Parkland Show Court tickets for local residents”
R – This is another modest offer also belatedly presented in response to criticisms. In any event, the chance to buy a ticket to watch a day’s tennis does not justify the permanent visual intrusion onto a protected landscape of an unacceptable Stadium building which will be empty for most of the year
13. The AELTC will make “a financial contribution” to a “Wimbledon Park Heritage, Landscaping and Facilities Improvement Fund”
R – This is an offer which cannot be properly assessed (or taken into account for planning policy evaluation) until the contribution is quantified and the relevant improvements identified. If the offer is genuine, why are full details still undisclosed 18 months after the application was submitted? Given its substantial resources, if the AELTC wish to present themselves as a responsible co-landowner of the larger Wimbledon Park anxious to “provide year-round significant public benefit to [its] local community”, as noted in the SCB, they ought to be offering these contributions in any event and not contingent upon the successful outcome of this planning application.
14. “Sustainable Transport”; the AELTC’s vision is for the Championships and the Qualifying Event to be a ‘public transport event’
R- Proposed car parking reductions have already been announced and are not contingent on the delivery of the WPP so should not form part of the application evaluation. Proposals to put some remaining Championships parking on public land within the new park will deny public access.
A Footnote on “Legally Binding Obligations”
Central to the “deliverability” of the AELTC’s offers of community benefits is the question of how the key benefits can be secured on a permanent basis if planning permission is granted. Planning agreements with legal undertakings are proposed, but their long term continuation is not certain as there are statutory procedures whereby these agreements can be set aside. The unbuilt upon land within the new AELTC park, as well as the Golf Clubhouse, would be obvious expansion targets. When they bought the freehold of the Golf Club land from Merton in 1993, the AELTC gave legal undertakings in the form of restrictive covenants that the land would not be developed and which limited its use - yet the application’s proposals ignore those covenants. This apparent willingness to disregard legal undertakings for the sake of its business development priorities has undermined the community’s trust and confidence in the AELTC. As noted above, to safeguard community access, ownership of the new park and Clubhouse needs to be transferred to a community trust.
The above summary and the detailed assessment in our Analysis Paper identify important concerns about the package of benefits being offered. We have noted the lack of long term security for the ongoing deliverability of some key benefits. Other benefits are vague and unquantified, making an informed evaluation of their “significance” impossible. The benefits “offer” also includes existing commitments and initiatives repackaged as new benefits, contingent upon the application’s successful outcome.
Given the emphasis placed upon the provision of “significant” public benefits derived from the WPP, it seems clear that these shortcomings seriously undermine the AELTC’s claims that it has made the requisite planning policy case that there are Very Special Circumstances which justify planning permission. We do not believe that the requisite VSC case has been met.
The proposals have attracted an unprecedented number (2000+) of planning objections from the local community as well as a petition of over 8800 signatures to date all highlighting concerns. A substantially scaled back scheme, founded upon a more inclusive approach which properly addresses the community’s concerns, would be welcomed. Local residents’ associations remain willing to engage constructively with the AELTC to discuss options but it is disappointing that after 2 years since the first presentation of the scheme to the public the AELTC still appears unwilling to take up that opportunity.