WIMBLEDON PARK RIFLE CLUB & Allotments – Planning Considerations

Thank you for showing an interest in objecting to the planning application submitted by Mentmore Homes Ltd on behalf of its owner, Brian Peck, (who is also owner of ISC Properties Ltd, our Landlord).
Before we detail reasons to object to the application, we just wanted to set right a few statements made in the planning statement document.

Item 2.3 states that “site has no specific planning policy designation”. This is simply because the Wandsworth Local Plan 2020 (which has yet to take effect) makes clear that it focuses on sites of more than .2 of a hectare. The rifle club site is .19 of a hectare. The area of .26 hectare quoted in the application includes the access way which is not part of the clubs lease. The Council will still seek to protect all open space / sports land less than .2 hectares.

Item 5.48 has made a judgement on the number of allotments being tended based on an inspection during the pandemic when it was not always easy to attend and for most, the planting season was missed. This is misleading as it resulted in existing biodiversity figures which do not represent the normal situation on site and resulted in the application managing to show a small net gain in biodiversity. The site is largely natural / wild.

Item 5.80 - We strongly refute the allegation that the car park area “is currently a gathering place for antisocial behaviour and littered with nitrous oxide gas canisters”. Neither we nor our neighbours are aware of a single instance of anti-social behaviour in our car park nor have we ever seen a “littering of nitrous oxide canisters”. The police have certainly never asked to review our CCTV footage. I would however remind the council that the landlords planning permission from 20 years ago detailed a gate at the front of the access way which the landlord never installed.

We would also like to point out that we have tried engaging with the landlord to purchase the site. He was however not prepared to take us seriously and wouldn’t allow us time to raise funds. We even suggested that we could approach the Governments’ Community Ownership Fund to help meet some of the cost. The landlord however decreed that he did not think sports clubs like ours should be entitled to monies from the fund and “he would talk to his MP” to make sure we couldn’t.

The Wandsworth Planning portal now says comments can be made up to 16th May. Objections can be made using this link. Please do object on whatever matters are of concern to you whether they are detailed below or not. Please also make sure you personalise your objections and also refer to the planning policy (if relevant). Simply saying “you object” will not be taken into consideration by the planning department as they not only need to account for your personal view on the proposal but also reference the applicable planning legislation which you feel the proposal contravenes.

Please do not think your objection won’t make a difference. They all help and we value them all. If you have any questions, we would be happy to answer them at our open day on the 8th May.

Reasons to object to the application:
Loss of the Rifle Club

The Club, (its ranges and members allotments) is listed as an asset of community value and should be saved in its current form. The club has been on the site for nearly 120 years and its use has been well established during that time providing many county and international shooters during its history.

We currently boast two national shooters amongst our ranks as well as at least 6 that shoot for their county. It would be impossible to find an alternative site within the locality and where the club could both be guaranteed planning permission as well as Home office approval.

We are the only club in the area with space to store members and club kit the latter of which enables us to offer induction courses. The loss of our club would mean there would be nowhere in the locality for people looking to take up the sport to turn to. We are a thriving, growing club with a waiting list of over 100 to attend an induction course.

The loss of our club is one less team that other clubs can compete against which would permanently weaken both county and national league structures. Many members will be forced to give up the sport they love as, being Londoners, they rely on public transport / cycling and the fact that we are fairly unique in being able to store their bulky equipment so that they don’t need to travel with it.

The application implies that all of our members drive and can go to other clubs. They cannot. As the application points out that there is only ONE other rifle club within a 23 minute drive (with empty roads maybe!). The application then provides figures to demonstrate that there are 20 tennis clubs within an 11 minute drive of the club! At appeal twenty years ago, the other rifle clubs were deemed too far away to be of relevance.

The loss of our club would do nothing for the diversity of sport in the area.

Loss of the members allotments

There is a major shortage of allotments within the Borough and our members would not be able to continue tending their allotments without going on a very long waiting list. The Council states in its 2016 Adopted Local Plan that it is supportive of the provision of food growing spaces.

Whilst the loss of the allotments was deemed acceptable at appeal 20 years ago, we are now living in a much changed world where environmental considerations should rightly be given much greater weight and we are not convinced the Landlord would get the same determination this time round.

Our allotmenting members have already amassed a petition to save the allotments totalling nearly 25,000 signatures.

The local primary school, St Michaels, makes visits to the allotments to teach their pupils about nature, sustainable living and food growing.
Reference to some allotments being untended can be attributed to the Pandemic and the ones not being tended now, to planning blight. Bringing an allotment back to use now, following the pandemic is a lot of work for nothing if the landlord obtains planning.
The landlord claims his scheme will improve biodiversity. It will not. The only reason he obtained a percentage uplift is because his assessment of the current biodiversity took place during the pandemic when the allotments were understandably not being tended.
Where possible we try to keep the site natural, not contrived to try to appease planners. It already provides a natural habitat for a wide variety of flora, fauna, insects and bats (which use our land as a a feeding corridor). We are keen to maintain the nature conservation of the land.

Planning Policies

The proposal does not comply with policy S5 of the London Plan.
B1 – It does not enhance the provision of facilities. It merely seeks to substitute existing facilities.
B2 – The proposal no more maximises the use of the facilities than the existing use does. Indeed, the use proposed is restricted to Nursery Children up to age 5 and junior tennis coaching up to age 9. Our rifle club is open to anyone from age 12 upwards.
C3 – The development for an alternative sports and recreational facility does NOT in our opinion outweigh the loss the existing uses.

Development would be contrary to Policies DM01 and DM02 of the Wandsworth Local Plan 2016. Item 6.12 of the plan acknowledges that there is a huge waiting list for allotments and that the council is supportive of the provision of food growing spaces (note this does not state they have to be strictly classed as allotments).

The development would also be contrary to Sections LP53 & LP54 of the current Wandsworth draft Local Plan 2021. These relate to the Protection and Enhancement of Green and Blue Infrastructure (LP53) which seeks to protect existing sports grounds. Section LP54 relates to Open Space, Sport and Recreation and further advises that new applications will only be considered where it would provide additional open space and/or secure public access to private facilities in areas identified as deficient in open space, play space or sport and recreation facilities.

The National Planning Policy Framework (paragraphs 98-99) states that planning policies should be based on robust and up-to-date assessments of the needs for open space, sports and recreation facilities. It is clear there is good demand for our sport and Club. Replacing one need with another (disputed need in our opinion) will not provide a material gain in provision and will result in a loss of diversity of sport in the Borough.
As a prerequisite the NPPF states existing open space, sports and recreation sites, including playing fields, should not be built on unless:
  1. An assessment has been undertaken, which has clearly shown the site to be surplus to requirements. – The site is NOT surplus to requirements.
  2. The loss resulting from the proposed development would be replaced by equivalent or better provision in terms of quantity and quality in a suitable location. – 3 small tennis courts for a very limited section of society comes nowhere near replacing the loss of the rifle club and its allotments. There is also no demand for further nurseries.
  3. The development is for alternative sports and recreational provision, the needs for which clearly outweigh the loss – Clearly this is not met. There is already ample provision for tennis in the borough.
The application has asserted that the land is “under-used”. There is no scientific measure to prove this point. Like any amateur sports club, we exist to provide practice and training in the safe use of firearms and to enter local, county and national competitions. All our obligations in this regard are met. We make as much use of our land as just about any other sports club you could name. Cricket clubs for example, only generally operate in summer months and only then when it isn’t raining. Lords cricket ground for example only has 57 days cricket planned for the whole of this year. Outdoor tennis clubs are also subject to the weather. We by contrast operate throughout the year and in all weather. We would assert that this unqualified argument by the landlord has no merit.


Landlords’ proposals:

Lack of Demand - Two nurseries have recently closed in the area citing a combination of lack of demand and lack of staff. Furthermore, the Office of National Statistics shows that birth rate levels in Wandsworth have fallen year on year for the last 10 years. The pandemic has also led to many young families moving out of London for greener environments which will only lessen the demand for nursery spaces in the future.
Staffing - The application suggests a staffing level of 20-25 for the 100 child nursery (nursery guidelines suggest anything from a ratio of 1:3 to 1:5 so this could increase to 33). The application makes the assumption that only one member of staff will drive. That is unrealistic. There is a shortage of trained staff in the locality meaning staff will need to travel from further afield. Fewer spaces will cause further congestion for parent droppings children off.

Junior tennis courts
The 3 junior tennis courts are restricted to children aged 6-9 providing a very limited pool of potential users. This cannot be considered as a general benefit to the wider community. Furthermore, as detailed in the application, there is generally no requirement for specific junior courts to train children of this age.
There is also plenty of tennis provision in the area with the application detailing 20 clubs in an 11 minute drive. Southfields Lawn Tennis Club (a 2 minute walk away) has capacity for a further 70 children.
The proposed tennis operator is looking to RELOCATE from Wimbledon Park to smaller facilities on the site. This does not add to the provision for tennis in the area and only serves to reduce the number of accessible sports in the borough as the only other rifle club does not have the facilities to provide induction courses for people new to the sport.
Providing 3 small junior tennis courts comes no way close to providing “equivalent or better provision in terms of quantity and quality” over that of our historic thriving club as required by the NPPF (para.99). We would suggest that their provision in the application is simply a sop to get over this planning requirement and enable the development of the Nursery.

Access to the site
The application claims that the access way of 5m is sufficiently wide for a shared access. We would argue that shared access is not suitable in this setting and without a pavement, is too narrow. It is unsafe for parents with prams (and possible other children in tow) to share a roadway with vehicles. Furthermore, the accessway narrows to 4.4m to accommodate refuse bins and a meter cupboard and there is no protection for the wall to the side of 135 Granville Road.
The shared access will cause congestion on Granville road at peak times. Visibility, particularly leaving the site is poor and vehicles will end up queuing on the road to access the site.
The application assumes only one member of staff will drive. That is unlikely. We are aware of a lack of trained staff in the area meaning staff would need to travel from further afield. The trip rate profile provided in the application estimates that 33 cars will arrive in the 3 hour morning window yet only 23 will leave. This suggests that some of those cars entering will be staff.
The proposal assumes that drop-off and collection of children will be staggered over a 3hr window. That is unlikely. As the landlord asserted to our neighbours during his presentation “working ladies (sic) like to drop their children off at 7.30am on their way to work and collect them at 6.30pm on their way home”!

The application references the risk of fluvial and tidal flooding as “Low”. We fail to understand their logic in quoting this information. The Government website details nearly all the properties abutting our site as being at “high risk” of surface water flooding. There is no reference to this in the application. Concreting over more of the site will only make the situation worse. The land over which we shoot often floods during heavy rain (as we shoot over it, it does not present us with an issue).

The application tries to imply that the noise generated by the rifle club is undesirable. The council have undertaken sound checks in the past and the sound was within acceptable limits. The application then provides a detailed report on the noise generated by tennis and nurseries and how it will be mitigated. This simply proves that the proposed use creates a nuisance that needs to be addressed.

Aspect / Scale
The size of the proposed scheme is not in keeping with other properties in the immediate vicinity. The proposal details that our neighbours will be faced with 2.5m (8ft) high fences at the end of their gardens. Those neighbours backing onto the tennis courts would have a further 1m of mesh netting on top. The fencing will cause additional loss of light to our neighbours gardens which we do not think has been factored into the applicants calculations.