Initial Options (Regulation 18) Response

Initial Options (Regulation 18) Response Retaining Speedway in Thurrock

Thurrock Hammers Ltd, submitted a detailed and comprehensive response to Thurrock Council’s Initial Options (Regulation 18) consultation on the 18th of February 2024.

This document, plus appendix, is shown below. We will continue to make the case for our long stated position that speedway is clearly and unequivocally included when the next stage in the Local Plan process is concluded.

We are also very grateful to all of the Hammers fans and speedway supporters in general, who wrote or emailed the Local Plan team to add their support and make their views known. Thank you!

1 Executive Summary 1
2 Introduction 2
3 Material Omission 3
4 Arena Essex site 4
5 Speedway’s Current Planning Permission 5
6 Arena Essex Planning History 6
7 Thurrock Green Belt Review 7
8 Thurrock Council Resolution 25 January 2023 9
9 NPPF 10
10 Current Thurrock Council Policies 11
11 Thurrock Local Plan 12
12 Speedway in Thurrock 13
13 Coventry Stadium Appeal 15
14 Conclusion 16

1. Executive Summary

1.1 Thurrock Hammers Limited makes this Response to Thurrock Council’s Initial Proposals (Regulation 18) Document approved by the Council on 6 December 2023 (‘the Initial Proposals’). The Initial Proposals fail to make any provision for Speedway. As a result there is a material omission and the Initial Proposals are defective.

1.2 Provision should be made for Speedway at the Arena Essex site and in the Thurrock Local Plan for the reasons outlined in this Response.

1.3 Those reasons include;

NPPF

the current green belt status of the Arena Essex site

the Planning Permission for Speedway on the Arena Essex site

current Thurrock Council policies to preserve sports facilities

the Thurrock Council Resolution of 25 January 2023 to preserve Speedway in Thurrock

the proposal at p.30 of the Initial Proposals that;

‘Any sports provision and open space that is lost through the redevelopment of Blackshots Estate must be reprovided.’

the Coventry Stadium Appeal Decision.

1.4 These reasons make a compelling legal, planning and policy case for the retention of Speedway at the Arena Essex site and its inclusion in the Thurrock Local Plan.

2. Introduction

2.1 This Response sets out Speedway’s position and heritage in Thurrock and states the legal and planning imperatives for Speedway’s retention at the Arena Essex site and its inclusion in the Thurrock Local Plan.

2.2 Since its introduction on 1984 Speedway has been Thurrock’s highest quality and best attended spectator sport. In that time Arena Essex / Lakeside Hammers teams have included riders who have won the world individual speedway championship 8 times, the world long track championship 7 times and who have won 29 national speedway championships.

2.3 In addition to its place in British Speedway’s league and cup racing competitions, the Arena Essex track was licensed to hold World Championship events and held the under 21 World Team Cup semi-final in 2012.

2.4 The legal and planning points have become more significant since the changes of ownership of the Arena Essex site, its closure to Speedway and the previous owner’s planning application to develop the site without making provision for Speedway.

2.5 This Response outlines why and how national and Thurrock Council policies should be applied.

2.6 On 25 January 2023 the members of Thurrock Council unanimously voted in favour of the adoption of a policy to preserve Speedway in Thurrock.

2.7 This resolution is in addition to the protection afforded by current Thurrock Council Planning Policies including PMD5 Open Spaces, Outdoor Sports and Recreational Facilities require that proposals;

that would result in their complete or partial loss or cause or worsen a deficiency in the area served by the space or facility will not be permitted unless:
conveniently located and accessible alternative facilities of an equivalent or improved standard will be provided to serve current and potential new users; …
any alternative and improved facilities should be available for use before an existing open space or facility is lost.
to ensure that where the Council considers that provision on-site is not feasible or appropriate, it will require developer contributions to improve existing, or provide new, spaces or facilities elsewhere.

3. Material Omission

3.1 Thurrock Council’s Initial Proposals Document fails to make provision for Speedway by failing to take into account;

(a) NPPF December 2023 paragraph 103

(b) Thurrock Council Policies;

CSSP4 Sustainable Green Belt
PMD6 Development in the Green Belt
PMD5 Open Spaces, Outdoor Sports and Recreational Facilities
CSTP9 Well-being: Leisure and Sports
CSTP22 Thurrock Design
CSTP23 Thurrock Character and Distinctiveness
PMD16 Developer Contributions

(c) Thurrock Council’s Resolution of 25 January 2023 ‘to use the Local Plan process to support the retention of Speedway in Thurrock’.

3.2

The Initial Proposals apply the relevant policies for the protection of sporting facilities in relation to Blackshots by suggesting that (p.30);

‘Any sports provision and open space that is lost through the redevelopment of Blackshots Estate must be reprovided.’

Significantly in relation to Arena Essex it is suggested on the same page 30 that;

‘A new employment site is proposed at Arena Essex which would be classed as a Tier 1 employment site providing a range of unit sizes and suitable for all employment uses. Consideration would need to be given as to how the recently ratified local wildlife site on part of the proposed employment site impacts on this site and how it could be designed into a development.’

The application of the relevant national and local policies requires that any sports provision that is lost through the redevelopment of Arena Essex must be reprovided.

And the requirement for the reprovision of sporting facilities at Blackshots must be applied to Speedway.

3.3

The Initial Proposals were published before the Coventry Stadium Appeal Decision dated 19 January 2024.

The review should take into account those parts of the Planning Inspector’s Appeal Decision relevant to the evaluation and preservation of Speedway.

4. Arena Essex Site

4.1 The Arena Essex Raceway site, A1306 Arterial Road, Purfleet, Essex, RM19 1AE is a 125 acre site situated to the north of the Lakeside Shopping Centre and contained by the A13 to the north, the Lakeside Shopping Centre approach road to the east, the A1306 to the south and the M25 Thurrock Services to the west (Appendix p1).

4.2 It is a greenbelt site bordering the Mardyke Valley.

4.3 It is a former quarry landfill site.

4.4 It is well connected to the local road, rail and bus network (Lakeside and Chafford Hundred station).

4.5 Figures indicate that a population of 3,494 is resident within 1km, 56,080 within 3km and 106,587 within 5km.

4.6 Speedway use is Green Belt compatible.

4.7 The Arena Essex site is perfectly suited for Speedway use.

5. Current Planning Permission

5.1 On 25 January 1982 on Application 77/00170A/FUL Planning Permission was granted for Speedway at the Arena Essex site (Appendix p2).

5.2 The Planning Permission granted is greenbelt compatible and consistent with the greenbelt status of the Arena Essex site.

6. Relevant Arena Essex Planning History

6.1 An application for planning permission for the development of 2,500 homes was made by London Strategic on 19 November 2018 (18/01671/FUL).

6.2 Thurrock Hammers Limited objected to this application and refers to and relies on its Submission dated 20 August 2019 in relation to the Initial Proposals.

6.3 This application failed to take into account the relevant national and local policies, relevant planning history, the Arena Essex site’s characteristics, its local context and sporting history and the Council’s Resolution of 25 January 2023.

6.4 The application was withdrawn on 5 September 2023.

7. Thurrock Green Belt Review

7.1 The Arena Essex site is assessed as Green Belt in the Thurrock Green Belt Review (Appendix p17).

7.2 It is identified as Strategic Parcel No.21 and assessed as follows (Appendix p16);

Thurrock Green Belt Assessment

8. Thurrock Council Resolution

8.1 On 25 January 2023 the members of Thurrock Council unanimously voted in favour of the adoption of a policy to preserve Speedway in Thurrock (Appendix p3).

8.2 That resolution states that ‘Thurrock Council resolves to use the Local Plan process to support the retention of Speedway in Thurrock’.

8.3 The Initial Proposals make no reference to this Resolution and fail to take it into account.

9. NPFF

9.1 In December 2023 the Secretary of State for Levelling Up, Housing and Communities published a new National Planning Policy Framework. This NPPF makes no material amendment to the Planning Policies to be applied but it should be noted that the relevant paragraph of the previous versions of NPPF are; 2012 (paragraph 74), 2018 (paragraph 97), 2019 (paragraph 97), 2021 (paragraph 99) and 2023 (paragraph 99). Paragraph 99 of NPPF 2021 and 2023 is reproduced without amendment as paragraph 103 of NPPF 2023 so that references to paragraph 99 in previous documentation should now be read as references to paragraph 103.

9.2 NPPF paragraph 103 provides that;

‘103 Existing open space, sports and recreational buildings and land, including playing fields, should not be built on unless:

(a) an assessment has been undertaken which has clearly shown the open space, buildings or land to be surplus to requirements; or

(b) 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; or

(c) the development is for alternative sports and recreational provision, the benefits of which clearly outweigh the loss of the current or former use.

10. Current Thurrock Council Policies

10.1 A number of current Thurrock Council policies support the retention of and provision for Speedway at the Arena Essex site and in Thurrock, in particular (Appendix p6);

(a)

CSSP4 Sustainable Green Belt
- to maintain the purpose, function and open character of the Green Belt in Thurrock in accordance with the provisions of PPG2
- to direct development to the following Urban Extension Broad Locations subject to the provisions of policies CSSP1, CSSP2, CSSP3, CSTP1
- the Council’s policy establishing that the constructive and positive use of the Green Belt for sports and leisure purposes is an essential component of the Thurrock Spatial Strategy that will underpin the sustainable development and regeneration of Thurrock to the long-term benefit of local people
- to reinforce the Green Belt boundary through structural enhancement of the local landscape features.

(b)

CSTP9 Well-being: Leisure and Sports
- to safeguard existing and future provision of leisure, sports and open space facilities
- to only allow the loss of a particular facility where appropriate alternative provision can be made elsewhere
- to work with relevant partners to progress the development of key flagship leisure and sports facilities at key locations to promote regeneration on the identified flagship sites including Leisure and sports facilities for Lakeside.

(d)

CSTP23 Thurrock Character and Distinctiveness
- the commitment to protect, manage and enhance the character of Thurrock to ensure improved quality and strengthened sense of place
- the identification of the Lakeside Basin as a key area where character is a key issue.

(e)

PMD5 Open Spaces, Outdoor Sports and Recreational Facilities
- to safeguard all existing open spaces, outdoor sports and recreational facilities
- to ensure that Development proposals that would result in their complete or partial loss or cause or worsen a deficiency in the area served by the space or facility will not be permitted unless:
  - conveniently located and accessible alternative facilities of an equivalent or improved standard will be provided to serve current and potential new users; or improvements to remaining spaces or facilities can be provided to a level sufficient to outweigh the loss
  - any alternative and improved facilities should be available for use before an existing open space or facility is lost.
- to ensure that where the Council considers that provision on-site is not feasible or appropriate, it will require developer contributions to improve existing, or provide new, spaces or facilities elsewhere.

(f)

PMD6 Development in the Green Belt
- to maintain, protect and enhance the open character of the Green Belt in Thurrock in accordance with the provisions of the NPPF
- to plan positively to enhance the beneficial use of the Green Belt by looking for opportunities to provide access to the countryside, provide opportunities for outdoor sport and recreation
- to retain and enhance landscapes, visual amenity and biodiversity
- to grant Planning permission only for new development in the Green Belt provided it meets as appropriate the requirements of the NPPF and other policies in the Council’s DPD

(g)

PMD16 Developer Contributions
- necessary to make the development acceptable in planning terms
- directly related to the development
- fairly and reasonably related in scale and kind to the development.

11. Local Plan 2011 (2015)

11.1 The Thurrock Local Plan 2011 (2015) allocated the Arena Essex site as Green Belt. Its consent is for sport and leisure activities.

12. Speedway in Thurrock

12.1 Speedway has been the highest quality, best attended and most popular spectator sport in Thurrock since its introduction at Arena Essex in 1984.

12.2 Speedway has raised the profile of Thurrock regionally, nationally and internationally since its introduction at Arena Essex in 1984.

12.3 Originally racing as Arena Essex Hammers and, since 2007, Lakeside Hammers, speedway racing has been enjoyed by tens of thousands of people in Thurrock. In that time Arena Essex Hammers / Lakeside Hammers;

won the Knock Out Cup in 1991 and 2009
reached the Elite League play off finals in 2008
regularly appeared on live broadcasts on Sky Sports.

12.4 Arena Essex Hammers / Lakeside Hammers teams have included riders who have between them;

won the individual world speedway championship 8 times
been runner up in the individual world speedway championship 3 times
won 22 Speedway Grand Prix
won the world best pairs championship once
won the world team cup 9 times
won the under 21 world speedway championship 3 times
won the British Championship 8 times
won the Swedish Championship 17 times
won the Polish Championship 4 times
won the British under 21 championship 5 times
won the world long track championship 7 times.

12.5 The Arena Essex track was licensed by the FIM, Fédération Internationale de Motocyclisme (motorcycle sport’s international governing body) to hold World Championship events and hosted the world under 21 team cup semi-finals in June 2012.

12.6 It hosted the British under 21 Championship in 2009, 2011 and 2012.

12.7 It also hosted the two best attended speedway meetings in the UK other than Grand Prix events in the last 30 years (Lakeside vs Poole (2008) and the Lee Richardson Memorial (2012).

12.8 Speedway in Thurrock was regularly broadcast live on Sky Sports. British Speedway is currently broadcast by Warner Brothers Discovery which is investing $100 million over a 10 year period in Speedway broadcasting worldwide. It is also broadcast by the streaming service British Speedway Network.

12.9 Speedway in Thurrock has supported and been supported by numerous sponsors, many of them local. The Royal Navy was the sponsor in the 2010 and 2011 seasons.

12.10 Speedway in Thurrock enjoys a significant social media reach. As at 16 February 2024 it had;

5,421 petition signatures
5,664 Facebook followers
983 Instagram followerx
190 LinkedIn connections
9448 Twitter followers.

12.11 Since January 2017 over 144,000 people from the UK, USA, France, Spain, Australia, Poland, Germany, Italy and Sweden, amongst others, have viewed the website and have enjoyed more than 965,000 page views.

12.12 Since 1 August 2018 there have been over 1.783 million views on Twitter.

12.13 The Thurrock Hammers January 2023 tweet about the Council Resolution had over 41,000 impressions and about the Initial Proposals, 24,076 impressions.

12.14 Thurrock Hammers will build on the legacy created by Speedway’s Community Liaison Programme, started in 2009. Its mission was, and remains, to provide methods, processes and structures to support:

Education
Inclusion
Enjoyment
Charity
Sport.

13. Coventry Stadium Appeal

13.1 An application for planning permission to demolish the Coventry Speedway Stadium, Rugby Road, Coventry, CV8 3GP was submitted to Rugby Borough Council by Brandon Estates Limited in 2018 (R18/0186) in which the Applicant sought to demolish the Speedway and Stock Car track and facilities for residential development and the construction of a 3G sprots pitch on the grounds that the Stadium was surplus to requirements and that motorsport operation was not viable.

13.2 This planning application was refused by the unanimous vote of the Rugby Council Planning Committee on 9 November 2022.

13.3 The Applicant appealed the Planning Committee’s refusal (Appeal ref.:APP/E3715/W/23/3322013).

13.4 The Applicant attempted to support its appeal by the arguments that;

(a) the motorsport facility was surplus to requirements

9b) Reinstatement of motorsport was not viable.

13.5 A Planning Inspector was appointed by the Secretary of State. The Appeal was heard in the Rugby Town Hall over 9 days between 19-21, 26-29 September and 27 -28 November 2023. The Planning Inspector inspected the Appeal Site on 19 September 2023 and heard evidence from 22 witnesses.

13.6 By the Appeal Decision of 19 January 2024 the Appeal against the refusal of planning permission was dismissed (Appendix p21).

13.7 In dismissing the Appeal the Planning Inspector held that;

(a) At paragraph 33;

‘The number of motorsports facilities is declining nationally. A number of tracks are under threat.

….. Four clubs have closed as the owners have seen an opportunity to realise their asset through redevelopment proposals. This does not indicate a sport in severe decline, rather it reinforces the need for existing stadiums to be retained.’

(b) At paragraph 75:

‘I acknowledge that the provision of a 3G pitch would be of significant local benefit. However, Coventry Stadium was not just a local facility but was a stadium hosting local, regional, national, and international events. The value of a 3G pitch, cannot compare to a facility, of which there are relatively few in the country, which can hold events generating such wide interest, with the social and wellbeing benefits for those that attend. I therefore conclude that the benefits of the alternative provision do not outweigh the loss of Coventry Stadium.’

13.8 The relevant parts of the Appeal Decision should be applied to any proposed allocation, application or development of the Arena Essex site which does not reprovide for Speedway.

14. Conclusion

14.1 For the legal and planning facts and matters in this Response, the Council’s Resolution of 25 January 2023 and the Coventry Stadium Appeal Decision Thurrock Council should make provision for Speedway at the Arena Essex site and must make provision in its Local Plan.

Thurrock Hammers Ltd

17th February 2024.

APPENDIX

Contents:

Arena Essex Site (1)
Arena Essex Site Planning Permission (2)
Thurrock Council Meeting Minutes 25th January 2023 (3)
Current Thurrock Council Policies (6)
Thurrock Green Belt Review (16)
Coventry Stadium Appeal Decision

1. Arena Essex Site

2. Arena Essex Site Planning Permission

3. Thurrock Council Meeting – 25 January 2023

Minutes of the Meeting of the Council held on 25 January 2023 at 7.00 pm

Present: Councillors James Halden (Mayor), Susan Little (Deputy Mayor), Qaisar Abbas, John Allen, Alex Anderson, Deborah Arnold, Paul Arnold, Gary Byrne, Adam Carter, Daniel Chukwu, Gary Collins, George Coxshall, Mark Coxshall, Jack Duffin, Robert Gledhill, Victoria Holloway, Andrew Jefferies, Barry Johnson, Tom Kelly, Cathy Kent, John Kent, Martin Kerin, Steve Liddiard, Ben Maney, Fraser Massey, Allen Mayes, Sara Muldowney, Srikanth Panjala, Maureen Pearce, Terry Piccolo, Georgette Polley, Jane Pothecary, Shane Ralph, Kairen Raper, Joycelyn Redsell, Sue Sammons, Sue Shinnick, Graham Snell, Luke Spillman, James Thandi, Lee Watson and Lynn Worrall.

Apologies: Councillors Chris Baker, Colin Churchman, Tony Fish, Shane Hebb, Augustine Ononaji, Elizabeth Rigby and Jennifer Smith

In Attendance:

Ian Wake (Acting Chief Executive) Les Billingham, Interim Director Adult Social Care Mark Bradbury, Interim Director of Place, Jackie Hinchliffe (Director of HR, OD & Transformation) John Jones (Director Law & Governance, and Monitoring Officer) Gareth Moss, Chief Finance Office, Julie Nelder, Assistant Director of Highways, Fleet and Logistics Ewelina Sorbjan, Interim Director Housing, Luke Tyson, Delivery and Strategy Manager, Karen Wheeler, Director Strategy, Engagement and Growth Matthew Boulter, Democratic Services Manager and Deputy Monitoring Officer, Jenny Shade, Senior Democratic Services Officer

Before the start of the Meeting, all present were advised that the meeting was being recorded, with the audio recording to be made available on the Council’s website.

111. Motion 3 submitted by Councillor J Kent

The Motion, as printed in the agenda was proposed by Councillor J Kent and seconded by Councillor Kerin. The Motion read as follows:

Thurrock Council resolves to use the Local Plan process to support the retention of Speedway in Thurrock and identify a new home for Grays Athletic, in the Grays area.

Councillor J Kent presented the motion by stating that Grays Athletic Football Club had lost their home ground in 2010 when the owner of the ground had sold it for development and since then had a variety of homes, sharing with East Thurrock United, with Rush Green and now sharing with Aveley Football Club. It was important to the town of Grays and for the club to be able to relocate to Grays. With changes being made to planning rules and the introduction of a policy that stated any sport club that had been displaced by a development would be found new land being identified in the borough. This had not happened for Lakeside Hammers who had been displaced by the potential development of Arena Essex. Councillor J Kent stated the motion requested that the planning process and the local plan process be used to identify suitable land for these two clubs that had brought only good to Thurrock.

Councillor M Coxshall welcomed this motion and as the local plan moved through the process it was important to include sports provision with leisure, entertainment, and sports provisions as they were a critical part of the local plan and for the residents of Thurrock.

Councillor Polley stated this was not the first time the Council had been asked to support Grays Athletic and would continue to support and questioned whether more negotiations by Grays Athletic with the landowner could have taken place. She noted the use of the local plan and that all football clubs and sports facilities now had to be profitable. She touched on the geographical area that a potential site could be offered and agreed that any activities and healthy living should be supported.

Councillor Mayes stated his support to the motion and the importance of the local plan. He also agreed for Grays Athletic to have a place to call their own home would be advantageous, not only for the football team but as a whole sports ecosystem, would be good for the whole community and youth set-up.

Councillor Gledhill stated his support to the motion and agreed there was a lot of interest in that Grays Athletic should return to Grays. In the past this had offered a lot of benefits to the area and had been an affordable day out for families. He agreed this should form part of the local plan and urged all residents to have their say. It should be a place where people want to come and spend their money because the sport, the facilities and entertainment were here in Thurrock for them to enjoy.

Councillor Ralph stated his support to the motion and agreed Grays Athletic needed a home of their own, it was great that local football teams helped and supported each other but this needed to happen quickly.

Councillor Jefferies stated his support to the motion as the local plan was not just about building new homes it was about providing a community with sports, leisure and entertainment with football and speedway being at the heart of that local plan.

Councillor Redsell as chair of the Local Development Plan Task Force had invited Grays Athletic to committee to talk about their aspirations and what they were looking for and needed and they were currently in discussions with Planning and LDF. It was important as part of that discussion, that a safe place be found, that would not interfere with too many people’s homes.

Councillor Redsell stated it was also important that support should be provided to all sports and coaches, some of which were coaching Thurrock children voluntarily.

Councillor Chukwu stated his support for this motion and urged all Members to support it.

Councillor Duffin stated the motion presented should not be just achieving to get the piece of the land but to have the facilities there that would generate income for the

club to sustain and to have facilities availability and revenue generators in place. It had previously been seen that it was those facilities that kept football clubs running, ensuring revenue for the whole year. Councillor Duffin supported the ethos of the motion but highlighted there was still a long way to go and eased caution but agreed to have something done would be great to see for all four teams around the borough having top quality venues that would benefit the community.

Councillor Byrne stated his support for this motion but reminded Members the importance to also support performing arts within the borough.

Councillor Kerin stated his support for Councillor J Kent’s motion and comments made this evening had demonstrated how important this was and the local plan should be the opportunity not just for housing but to identify the place that Thurrock should be and what activities, sports and entertainment should be available. With Grays Athletic surviving 13 years of homelessness had been down to the supporters and the community work they undertake. As the local plan progressed it had to be identified how it could support local clubs, cultural assets, and organisations. If the local plan can help to put Grays Athletic onto a surer footing, then there was no reason why the team could not continue into the future.

Councillor J Kent thanked Members for their support this evening and noted the support of Lakeside Hammers was equally as important.

The Mayor called a vote on the Motion.

With 42 votes for, the Mayor announced the motion carried.

The meeting finished at 9.16 pm

Approved as a true and correct record

CHAIR DATE

Any queries regarding these Minutes, please contact Democratic Services at Direct.Democracy@thurrock.gov.uk

4 & 5 . Current Thurrock Council Policies & Greenbelt Review

Click here to download the PDF of current Thurrock Council Policies and Green Belt Review

6. Coventry Stadium Appeal Decision

Click here to download the PDF of current Coventry Stadium Appeal Decision

Stadium renders credit: Ayshford Sansome