Friends of River Park have submitted their response to Winchester City Council’s consultation about the draft Local Plan. They claim that Policy W10, which proposes a change of use for the redundant River Park Leisure Centre site from public recreational use to ‘Learning and non-residential institutions’, is unsound and not legally compliant.
The principal objections to the policy are that it fails the all the ‘soundness’ tests under paragraph 35 of the National Planning Policy Framework (NPPF), in that there is no needs assessment of any kind; it is not consistent with achieving sustainable development; it is not justified: there is no appropriate strategy; no account has been taken of any reasonable alternatives, and it is not based on any proportionate evidence; it is not effective, as there is no evidence that any development would be deliverable over the plan period; it is not consistent with national policy as it is not accordance with the policies in the NPPF – moreover it is inconsistent with other policies in the draft Local Plan.
This is not a ‘brownfield’ site, nor is it ‘previously developed land’. The Council has not undertaken any assessment of the effect on the adjacent River Itchen (designated SAC and SSSI and of international importance), of the proximity to the South Downs National Park and Winnall Nature Reserve and of the landscape character, as well as the adjoining historic Hyde Abbey Garden, nearby Hyde Gate (Grade 1 scheduled ancient monument), St Bartholomew’s Church (Grade 11* listed) and the Hyde Conservation Area.
There is no up-to-date flood risk assessment, although there is an acknowledgement that the groundwater levels are less than a metre below the surface. This site is at a pivotal point in the formation of the flood plain which underlies the whole of the lower part of the City of Winchester. An Environment Agency report, commissioned by the Council in 2013, said that ‘The land mostly lies in a zone (3A) where floods are highly probable, and it is upstream of the City and the Cathedral’ . In the report, it is said that ‘a new design that increased the existing building footprint or the impermeable area within the floodplain would not be appropriate in this location’; also, ‘replacing the existing leisure centre buildings with open space might have a beneficial effect on downstream flood risk’.
The Policy conflicts with the Council’s Climate Emergency Action Plan and the associated Plan policies as well as the NPPF, which states that a Local Plan should provide access to a network of high-quality open spaces and opportunities for sport and physical activity, all of which is important for the health and well-being of communities and can deliver wider benefits for nature and support efforts to address climate change.
There is no mention or recognition, in W10, of the shortfall in the provision of public open space in the centre of Winchester, especially in St Bartholomew Ward which has incorporated the area of Winnall since the boundary changes in 2016. This is particularly of importance given the recent increase in young families in the area.
No account has been taken of the accessibility issues, of the effect of the extra traffic on the already overburdened road infrastructure in Winchester City, or of the serious parking difficulties. A large proportion of the W10 site is dedicated to car parking for users of River Park Recreational Ground. The proposed northern car park area (to which access is not clear) is totally inadequate to meet those engaging in activities such as rugby, football, tennis, cricket, the junior and senior Park Runs, the canoe club, the indoor and outdoor bowls club, the skatepark, and informal recreation such as dog-walking and ball games. To say nothing of the large-scale events enjoyed by a wide audience: four festivals have been held there this year and the Annual Round Table Fireworks display, which is Winchester’s biggest charity event, is held in the park, as are many runs for charities such as the Race for Life event and the finish point of the Winchester half marathon, and triathlon.
The Policy is predicated on a future agreement, to lease (“sell”) the land for 150 years, between the Council and the University of Southampton. There is no guarantee of this agreement ever coming into being. The Council made a decision on 4th March 2022 to grant a five-year option period to the University, for which no consideration has passed and there is no signed contract. There appears to be no legal obligation on the University to apply for planning consent or to take forward any plans to develop the site; and no development, as envisaged in W10, is assured before the end date of the Local Plan in 2040.
The five-year option period prevents any other party from putting forward alternative proposals for the site and the redundant leisure centre building is in an increasingly dilapidated and vandalised state. It is costing the taxpayer thousands of pounds to insure, to keep secure and to maintain. The Council has budgeted for its demolition but the Leader has said they will not undertake this until wider plans for the site have been determined 2 . There is no timeframe for those wider plans to be formulated, let alone determined.
Friends of River Park say that Policy W10 is therefore unsound. To overcome this failure and to ensure that the Plan is sound, the allocation W10 should be removed from the Plan.