Application Details

Reference 19/01021/X
Address Gloucestershire County Cricket Club Nevil Road Bristol BS7 9EJ  
Street View
Proposal Application to vary Conditions No. 3 (Restricted number of days per year to use the floodlights), No. 4 (Floodlight usage) and No. 6 (Use carried out in accordance with Floodlight Usage Management Plan) and remove Condition No. 5 (Floodlight usage) attached to planning permission 14/05030/F - Proposed installation of 6 no. 45m tall permanent floodlights - now proposed to increase number of days the floodlights can be used to 17 days per year for 2019 only and to enable both competitive matches and practice sessions to be played within the 17 day limit in 2019 and 15 day limit in all other years.
Validated 28-02-19
Type Variation/Deletion of a Condition
Status Decided
Neighbour Consultation Expiry 10-05-19
Standard Consultation Expiry 10-04-19
Determination Deadline 25-04-19
Decision GRANTED subject to condition(s)
Decision Issued 17-05-19
BCC Planning Portal Application
Public Comments Supporters: 12 Objectors: 44  Unstated: 5  Total: 61
No. of Page Views 111

TBS response: NEUTRAL

Recommendation submitted 20-04-19

Public Comments

The Bishopston Society 

The Society has no objection to this application so long as the permission is granted for2019 only and the permission reverts to the original allowance of 15 days in 2020 and beyond. Wewould be very concerned if we thought that the Club was attempting to increase its originalpermission by stealth over time.

Ms Sue Lloyd 11 ARTHUR MIILTON ST BRISTOL   OBJECT

The further amendments to the Planning Application continue to request an increase in thenumber of floodlight sessions for 2019 only from 15 to 17 to allow 2 practice sessions for theWorld Cup.

However, more fundamentally, they also propose to include practice sessions within the allowed15 sessions for all future years, by both amending the original planning conditions and the FLUMP(Section 2.1).

My concerns raised about the recently amended application:

-Planning permission for the floodlights was originally granted because they were needed for

international cricket matches to ensure the viability of the Club and this outweighed residentialamenity. This does NOT apply to practice sessions.

-The change is likely to result in increased floodlight usage as unused sessions within the 15allowed may get filled up with practices (although the Club are likely to keep some to use for poorlight in end of season matches)

-More importantly, once practice sessions are agreed and established, there is a possibility of theClub requesting additional overall usage in future years to enable more practices. This would thenbe hard for the Council to refuse,if it had accepted the principle of practice sessions underfloodlights, and a precedent has been set. I object to this attempt to introduce a backdoor changeto the FLUMP.

-The FLUMP, section 4.5, says that the document should be amended ONLY after consultationwith local residents. This consultation has NOT taken place and the Cricket Club has made noattempt to consult on the latest changes.

-The amendment represents a fundamental change to the original planning permission granted,and the proposed changes should be submitted as a new planning application, not anamendment. This MUST then allow the appropriate resident consultations and for reasonedjustifications to be submitted for such changes.

Mr Simon Wilkinson  76 KENNINGTON AVENUE BISHOPSTON BRISTOL   OBJECT

I object to this scope creep, where will it end? Lights on 24/7/365??Pointless objecting though, the cricket club get whatever they want as the council just roll over anddo what they are told.

Mr Henry Moore 7 CRICKLADE RD BRISTOL   OBJECT

As a new resident of the area since January I was surprised by the approach seeminglytaken by the cricket club to this request.

In principle it seems a reasonable ask. However, the manner in which they have approached this,not truly engaging with local residents is disappointing. I noted our local councillor commented inthe local paper that they provided only one days notice for a consultation meeting.

Dr Sarah Hargreaves 2 LANCASHIRE ROAD 2 LANCASHIRE ROAD BRISTOL   OBJECT

Planning permission was originally granted for the floodlights as they were needed forinternational matches - to ensure the viability of the ground - and this outweighed the residentialamenity. This does not apply to practice sessions which have been proposed to be an additionalreason for the floodlight usage.

If granted, the council may find it difficult to refuse future applications for additional practicesessions once a precedent has been set.

Despite section 4.5 saying the document should only be amended only after consultation with localresidents. This has not been occurred and no effort made to arrange one by the Cricket Club.

Mr John Penny 39 NOTTINGHAM RD BRISTOL   SUPPORT

I have been alerted, by a group purporting to represent local residents, of thisapplication.

As far as I can gather from their literature, they are objecting.

Please be assured that their views are not shared by all local residents. I live a block away fromthe ground and am very fond of the floodlights; I think that they look great and enjoy seeing themon as well as admiring them during the day.

Increasing the number of evenings on which the lights are on makes perfect sense and can't reallybe said to cause too much interference to us residents. It's not as if they're on all night, keeping usawake, just for a few hours in the evening.

The Cricket club is a valued neighbour; I'm delighted to see it being successful and hope thatincreased light usage helps in that regard.

Mr Glen Monks 3 SURREY ROAD BRISTOL   OBJECT

Application Summary: No 19/01021/XAddress: Gloucestershire County Cricket Club Nevil Road Bristol BS7 9EJProposal: Application to vary conditions No. 3 (Restricted number of days per year to use thefloodlights) and No. 6 (Use carried out in accordance with Management Plan) attached to planningpermission 14/05030/F - Proposed installation of 6 no. 45m tall permanent floodlights - nowproposed to increase number of days the floodlights can be used to 17 per year for 2019 only.Case Officer: Natalie Queffurus

Thank you for your recent letter regarding the above planning application made by GCCC.

We oppose this application in full, and urge BCC to reject it, for the following reasons:

1. The application seeks to extend to the number of floodlight sessions for practice purposes. Thecurrent FLUMP does not permit use of the lights for practice purposes: just 15 professional matchuses maximum (and GCCC reassured residents repeatedly it would likely be far less). Anapplication is now submitted that wants to stretch this to 17, and magically include practicesessions that were specifically excluded in the original FLUMP. To agree this would be tofundmentally subvert the existing planning agreement, therefore. This itself was and is deeplycontroversial amongst local residents. It also risks creating a precedent that having subverted theoriginal agreement GCCC would feel justified to submit further applications that move even furtheraway from the original agreement.

2. This would fit with the broad modus operandi of GCCC which has been to push boundaries,disregard the views of local residents and very often seek to mislead us. I cite, as a clear example,that GCCC have stated the Afghanistan Cricket team having never played under floodlights asjustification for applying for 2 practice sessions, when in fact they have such lights at their nationalground and have played consistently under them since 2014. It feels that GCCC have operated atthe boundaries of truthfulness and reasonableness in their dealings with local residents and BCCfrom the outset.

3. Over and above switching the lights on, large scale events (including the Tom Jones concert on13/7/19) place a large burden on the local community and profoundly affect residential amenitywith light and noise pollution, crowd noise to and from the venue, parking issues and littering. Weare very concerned that large scale non-cricket events like the Tom Jones concert, for example,are really what underlies the need to apply for an increase to 17. Is this the thin end of a muchlarger wedge? Whilst these types of events are not covered by the planning permission, how elseare they to light the ground at 10pm whilst tens of thousands of people decant safely? Do youhave sight of those plans, and the necessary H&S reassurances?

4. Finally, you may have spotted we are amidst a Climate Emergency. The sheer numbers whodrive there, park locally or if they are a member on the grounds, or worse still taxi, is staggering.Last week there was a tailback at the Nevil Road entrance where at least 4 taxis were queueing,engines running, blocking the road so local, and others were driving to park at the grounds or inany space that wasn't coned off. BCC really do need to think very long and very hard beforegranting any extended use of lights or any additional events at that Ground when getting there in acar, as many thousands do, is adding entirely unnecessarily to carbon emissions. You are either aGreen Council in words and deeds, or you are not a Green Council at all. Do planning applicationsnow routinely need an environmental/carbon emissions impact assessment? Are there clearrules? There really should be.

5. In summary:

- To grant this application would be to fundamentally, retrospectively change the nature of theoriginal planning agreement and FLUMP.- If granted, BCC would be failing to protect residential amenity, choosing instead the commercialinterests of a company making profit at your residents' cost. You would in effect be jettisoning thespecific safeguards the Council cited as justifying the existing FLUMP number of use for 15matches maximum (itself still deeply opposed by many local residents).- Beyond the lights, there is marked nuisance from noise, not just at cricket matches but for popconcerts like Tom Jones. There is also a green angle.

Our strong plea, in light of our ground above, is for the application to be rejected.

Further, I would advocate that the Council refuse further change requests or fresh applications at

the GCCC Ground for 5 years to stop this perceived pushing of the boundaries and apparent 'badfaith' by GCCC. That period should be used to proactively assess the impact of the existingchanges you have granted on residential amenity, property values, noise pollution and air qualityon event days. GCCC's operation of the FLUMP and their management of local communityrelations should also be evaluated within this. The evaluation should be with a view to consideringwhether 15 floodlight uses, on top of other events, are in fact too many to protect residentialamenity, and so should be reduced, or kept at the same levels. Having granted a deeplycontroversial planning application for local residents, I think this a duty you owe us - and would bea positive and proactive stewardship approach to sustainable community development.

Yours sincerely,

No 3 Surrey Road.

Mr Ian Long 18 SOMMERVILLE ROAD BRISTOL   SUPPORT

I strongly support the proposed increase in the number of floodlit days - in order to keepthe cricket ground it is necessary for the management to raise as much revenue as possible whichnecessarily means more floodlit events. Light pollution and traffic considerations are minimal.

Mr Roger Ford 16 BRYNLAND AVENUE BRISTOL   OBJECT

This revised application is more hostile to the neighbourhood than the one it replaces.Approval would still allow the two additional uses (total 17) for this season, thereby setting aprecedent for further similar extensions in the future .

But in addition it would allow the club to extend use of the lights to practice sessions in any otheryear, subject to the limit of 15 uses. So the distinction between competitive matches and practicesessions, established in the original conditions of approval, would be abandoned. At the time ofthe original application (14/05030/F) the club was keen to tell us all that 15 uses was the absolutemaximum number of uses in a year, and that in most years it would probably be a lot less. If theynow gain general permission to use them for practice sessions as well as for matches, then (eventhough the limit of 15 uses might still be observed) it seems likely that in most years there will bean increase in overall usage, to the detriment of local residents. So we would see more usage thisyear, and almost certainly more usage every other year too.

The Council should uphold its original decisions on this matter, and refuse the new application andits associated Floodlight Usage Management Plan. If this is approved there will no doubt be morerequests for extensions in the future.

Mr Oliver iles 49 UPPER BELMONT RD BISHOPSTON BRISTOL   OBJECT

I object

See my comments below

Fundamentally, they also propose to include practice sessions within the allowed 15 sessions forall future years, by both amending the original planning conditions and the FLUMP (Section 2.1).

The concerns raised about this include:

1. Planning permission for the floodlights was originally granted because they were needed forinternational cricket matches to ensure the viability of the Club and this outweighed residentialamenity. This does not apply to practice sessions.

2. The change is likely to result in increased floodlight usage as unused sessions within the 15allowed may get filled up with practices (although the Club are likely to keep some to use for poorlight in end of season matches)

3. More importantly, once practice sessions are agreed and established, there is a possibility ofthe Club requesting additional overall usage in future years to enable more practices. This wouldthen be hard for the Council to refuse, if it had accepted the principle of practice sessions underfloodlights.

4. The FLUMP, section 4.5, says that the document should be amended only after consultationwith local residents. This consultation has not taken place and the Cricket Club has made noattempt to consult on the latest changes.

5. The amendment represents a fundamental change to the original planning permission granted,and the proposed changes should be submitted as a new planning application, not anamendment. This should allow the appropriate resident consultations and for reasonedjustifications to be submitted for such changes.

Ms Sarah Gillman 41 UPPER BELMONT RD BRISTOL   OBJECT

There has been no consultation. This is unreasonable.

Unknown   OBJECT

an increase to 17. Is this the thin end of a much larger wedge? Whilst these types of events are not covered by the planning permission, how else are they to light the ground at 10pm whilst tens of thousands of people decant safely? Do you have sight of those plans, and the necessary H&S reassurances?

4. Finally, you may have spotted we are amidst a Climate Emergency. The sheer numbers who drive there, park locally or if they are a member on the grounds, or worse still taxi, is staggering. Last week there was a tailback at the Nevil Road entrance where at least 4 taxis were queueing, engines running, blocking the road so local, and others were driving to park at the grounds or in any space that wasn’t coned off. BCC really do need to think very long and very hard before granting any extended use of lights or any additional events at that Ground when getting there in a car, as many thousands do, is adding entirely unnecessarily to carbon emissions. You are either a Green Council in words and deeds, or you are not a Green Council at all. Do planning applications now routinely need an environmental/carbon emissions impact assessment? Are there clear rules? There really should be.

5. In summary: • To grant this application would be to fundamentally, retrospectively change the

nature of the original planning agreement and FLUMP. • If granted, BCC would be failing to protect residential amenities, choosing instead

the commercial interests of a company making profit at your residents’ cost. You would in effect be jettisoning the specific safeguards the Council cited as justifying the existing FLUMP number of use for 15 matches maximum (itself still deeply opposed by many local residents).

• Beyond the lights, there is marked nuisance from noise, not just at cricket matches but for pop concerts like Tom Jones. There is also a green angle.

Our strong plea, in light of our ground above, is for the application to be rejected. Further, I would advocate that the Council refuse further change requests or fresh applications at the GCCC Ground for 5 years to stop this perceived pushing of the boundaries and apparent ‘bad faith’ by GCCC. That period should be used to proactively assess the impact of the existing changes you have granted on residential amenity, property values, noise pollution and air quality on event days. GCCC’s operation of the FLUMP and their management of local community relations should also be evaluated within this. The evaluation should be with a view to considering whether 15 floodlight uses, on top of other events, are in fact too many to protect residential amenity, and so should be reduced, or kept at the same levels. Having granted a deeply controversial planning application for local residents, I think this a duty you owe us – and would be a positive and proactive stewardship approach to sustainable community development. Yours sincerely, No 3 Surrey Road.

Mr Nicholas Short 32 LANCASHIRE ROAD BISHOPSTON BRISTOL   OBJECT

We do not support this application for an amendment. This would cause furtherdetriment to the wildlife who already will be affected by the increased light pollution. In addition, wehave a young family and manage their evening sleep times under the current arrangements.However, the club is seeking to extend beyond the original grant which will just make this aproblem for families such as us with young children who need to sleep. The club was granted thelights with conditions attached. If applications to change those conditions once an application hasbeen granted are successful, then this just questions the integrity of the planning process. Theclub were very clear at the public meetings that the lighting would be restricted to that stipulated inthe planning consent. At what point do the club intend on stopping the additional applications?

We do not support this application.

Unknown   OBJECT

Mr Joe Weitz 26 MORLEY SQUARE BRISTOL   OBJECT

I'm concerned about the planned increase of days per year to use the floodlights atGloucestershire County Cricket Ground for 2019.

I fear this will exacerbate the already extremely congested traffic and parking issues. Additionaluse of the grounds with floodlights will also cause noise in the evenings which is a concern as Ihave young children who go to bed early.

Regards,

Joe

Mr Clive Lewis 69 SEFTON PARK RD, ST ANDREWS BRISTOL   SUPPORT

Would support the extension as applied for. The current use limitations are restrictive.As a neighbour who does see the impact of light from this in their house, it is now clear that thebenefits to the Club, and thereby the community that in which the Club is located, outweigh anylikely impact of their use on the community.

Ms Alison Boulton 9 ARTHUR MILTON STREET BRISTOL  

The ICC World Cup is a positive event for GCCC and for Bristol, but inevitably it will impact onlocal residents. However, many of those residents are understandably disappointed about thelimited information made available by the club, including the lack of forewarning about thisapplication.

I have two concerns

1. The poor wording: It is a particularly badly worded application, talking as it does about'additional' practice sessions, when in fact there is no agreement to allow any practice sessions,so they are exceptional rather than additional. It suggests they are required by the ICC but doesnot give any evidence of this.

2. The possible consequences of consent being granted on the basis of such a poorly wordedapplication: Consent on the basis of this application could easily set a precedent, particularly withregard to future floodlight use for practice sessions.

I do not oppose the use of the floodlights exceptionally for two practice sessions, assuming this isa genuine requirement for the ICC World Cup. However, I would like to have assurances thatconsent would be granted only with conditions making it clear this is a one off for 2019, thatfloodlight use for practice sessions will not be allowed in future years and that there should be noincrease generally in floodlight usage above the 15 initially agreed.

it would also be helpful if the club could be reminded of its responsibility to consult with residentsin a timely fashion.

Dr Caroline Bartle 8 LANCASHIRE ROAD BRISTOL   OBJECT

I object to the application to extend the use of the floodlights to practice sessions. Theapplication effectively allows a fundamental material change to be made to the original planningpermission, which was granted for competitive matches only. Although this application is for 2019only, the risk is that it creates a precedent for use of the lights for practice sessions in the future,introducing further 'creeping' harm to residential amenity.

This application threatens to undermine the existing Floodlight Usage Management Plan becausethe proposed amendments to Conditions 3 and 6 of the planning permission contradict Condition 4(which restricts use of the lights to competitive matches). The effect could be to make Condition 4unenforceable.

Furthermore, BCC granted the original permission in 2015 on the grounds that the harm toresidential amenity of up to 15 floodlit competitive matches per year would be outweighed by theeconomic and social benefits to Bristol. By extension, if BCC were to approve the currentapplication, it would need to resolve that further harm to residential amenity through use of thelights for practice sessions would also be outweighed by economic and social benefits to the city. Iwould strongly question this and ask that evidence of such benefits be provided.

Finally, I find the informal justification provided by GCCC for this application (that the Afghanistanteam needs to practice under floodlights) rather spurious, given that they have considerableexperience of playing under floodlights, including at their home ground in India.

Unknown   OBJECT

Mr Adrian Stevenson 4 LANCASHIRE RD BISHOPSTON BRISTOL   OBJECT

I am a close neighbour of the Cricket Club and the floodlights continue to harm ourresidential amenity both in use and as dominating and unattractive additions to ourneighbourhood, if not Bristol, that we have never got used to.I object to the current application to extend the use of the floodlights to practice sessions. Theapplication effectively allows a fundamental material change to be made to the original planningpermission, which was granted for competitive matches only. Although this application is for 2019only, the risk is that it creates a precedent for use of the lights for practice sessions in the future,introducing further 'creeping' harm to residential amenity.This application threatens to undermine the existing Floodlight Usage Management Plan becausethe proposed amendments to Conditions 3 and 6 of the planning permission contradict Condition 4(which restricts use of the lights to competitive matches). The effect could be to make Condition 4unenforceable.Furthermore, BCC granted the original permission in 2015 on the grounds that the harm toresidential amenity of up to 15 floodlit competitive matches per year would be outweighed by theeconomic and social benefits to Bristol. By extension, if BCC were to approve the currentapplication, it would need to resolve that further harm to residential amenity through use of thelights for practice sessions would also be outweighed by economic and social benefits to the city. Iwould strongly question this and ask that evidence of such benefits be provided.Finally, I find the informal justification provided by GCCC for this application (that the Afghanistanteam needs to practice under floodlights) rather spurious, given that they have considerableexperience of playing under floodlights, including at their home ground in India.

Mr John Gilliard 15 MORLEY SQ BISHOPSTON BRISTOL   SUPPORT

In favour of increased use of ground lights. The County Ground is a centre of excellencedistinguished by these sunflower like structures which, when lit, create an atmosphere ofexcitement. Their use during the summer months means that they are turned off shortly aftersunset, minimising the intrusion.

Mr Simon Cox 137 SEFTON PARK ROAD BRISTOL  

I have no problem with the request as a one-off occurrence, but would not want it tobecome an annual request.

HOWEVER, I WOULD LIKE TO HAVE ADEQUATE TIME TO RESPOND TO SIMILAR MATTERSIN FUTURE. THE LETTER ABOUT THIS, DATED 22 MARCH, WAS ONLY POSTED THROUGHMY LETTERBOX ON 10 APRIL, GIVING JUST 2 DAYS TO RESPOND. THIS ISUNNACCEPTABLY SHORT. PLEASE ENSURE MORE TIME IS GIVEN IN FUTURE.

Mrs Elizabeth Faiello 10 LANCASHIRE ROAD BRISTOL   OBJECT

Dear Sir/Madam

I recognise and appreciate the reason Bristol City Council granted permission to GCCC in 2015 toinstall the floodlights, which was to allow the Club to host and play specific competitive cricketmatches up to 15 times per year. 15 was not randomly selected, but identified by GCCC as themaximum number they required to enable them to viably host important competitive matches. Infact, except for the World Cup year they felt it would be very much less.

These important competitive matches, (World Cup matches, ICC International matches and ECBmatches) are of economic and social value to Bristol. GCCC has access to hosting them andpermission to use the floodlights for them.

It was also recognised that the installation of large powerful floodlights would cause residentialharm, but the benefits (described above) outweighed the harm for these specific importantcompetitive matches. This is accepted.

It was not accepted by BCC in the planning permission granted that the lights are allowed to beswitched on for any other use (such as practice sessions or anything else). These types of use donot outweigh harm to the residential location. The Council concluded in 2016 "the use offloodlights for practice sessions goes beyond the intention of the condition 4 to limit the use of thelights to competitive cricket matches only". Conditions like these, along with the Management Plan(FLUMP) attached to the permission, help us all have a comfortable understanding of how, when

and why they are used.

The current planning amendment request is confusing. I believe the reason is for practice sessionsduring the World Cup, which on the face of it should be considered. However, the actualapplication seems to be badly worded and could cause a fundamental change to the originalplanning permission granted, potentially expanding the use of the floodlights for 17 practicesessions and competitive games throughout all of 2019. Once this is accepted BCC would thenfind it hard to refuse further such use beyond 2019.

Rather than being a fresh new planning application clearly setting out its need for practicesessions during an exceptional year, it's a bit of a muddle. It requests to not act in accordance withwith a number of current conditions, it introduces new conditions, these will then clash with oldconditions. The consequence is that the FLUMP is suspended. It requests to suspend theseconditions for all of 2019, not just the World Cup. It oddly refers to "additional" practice sessions.

I wish we has a simple clear fresh planning application which we could all see the reason andjustification stated and make an appropriate decision. With this we are being asked to sign up tototal confusion in the future with conditions clashing and practice session happening withoutevidenced justification and a management plan (FLUMP) which potentially becomesunenforceable. Due to these concerns I unfortunately have to object to this particular planningsubmission.

Regards

Liz Faiello

Mr Lewis Shobbrook 111 KENNINGTON AVE BISHOPSTON   OBJECT

We are concerned that GCCC are seeking permission for floodlight use for 2 practicesessions when the FLUMP makes it clear that floodlight use is for 'competitive cricket'. Practicesessions are not competitive cricket! Allowing this would set a precedent which could make it fareasier for GCCC to apply to vary floodlight use for future seasons.

The application also appears badly worded which is concerning as it could be open tomisinterpretation in the future.

It is positive that GCCC are part of the cricket World Cup but spare a thought for residents who willalready be affected significantly this year with many matches likely to draw large crowds. Therewill be the usual parking, traffic and antisocial behaviour issues to contend with plus likely use ofthe floodlights which are exceptionally bright for neighbouring properties. Using the light for 2practice matches feels excessive and unnecessary. These are international teams who surelyalready know what it is like to play under floodlights??

If BCC are minded to permit these practice sessions we would like it made clear that thispermission is genuinely a 'one off' granted for the exceptional circumstances of the World Cup andnot to be entertained for future seasons.

Lindsey & Lewis Shobbrook

Councillor Tom Brook CITY HALL, COLLEGE GREEN, BRISTOL BS1 5TR  

The existing permission for the floodlights was granted on the grounds that the adverseimpact on residential amenity due to the use (and presence) of the lights is outweighed by thewider positive socio-economic impact of having international cricket in Bristol (with the lights beinga prerequisite for that).

By extension, any further uses of the floodlights beyond the currently permitted fifteen uses peryear will have a further negative impact on residential amenity. Thus, the question arises whetherthe impact of the two additional uses is outweighed by other matters.

It should firstly be noted that the additional two uses will be for training sessions only, so there willnot be fans present, music played, etc. Therefore, the adverse impact of the additional uses islimited to light pollution and so reduces the overall negative impact on residential amenity.

However, within the extant permission fifteen uses per year was set as a definitive upper limit anduse for practice matches was not permitted.

That said, hosting the World Cup is an immense honour for our city and for the local area, not tomention the positive economic impact, and in the range of exceptional circumstances this isarguably the most exceptional circumstance possible.

My key concern, if permission is granted, is that it is clear that this is an exceptional circumstance,not to be repeated. That means that any permission should be a one-off and should not set a

precedent for future years, both in terms of the number of uses and in waiving the requirement toonly use the lights for competitive matches.

This is a key concern within the local community, and from reading the public comments it is clearthat many of those who have objected to this application do not object to the one-off additionaluses in principle, but object out of fear of the precedent it could set. Therefore, if a precedent canbe explicitly precluded then it would help to assure residents and would hopefully improve thecommunity's trust in the club's intentions. If this is not possible, then the application should berefused to prevent setting a dangerous precedent that could be exploited to the future detriment ofresidential amenity.

Similarly, it has been noted by some public commenters that the quality of the application is lowand is open to (mis)interpretation. I refer officers particularly to the technical issues raised byEarlsfield Town Planning Ltd (not to say I necessarily agree or disagree with their conclusions).These should be resolved, and if it is not possible to do so then the application should be refused,again to prevent setting of a precedent/loopholes.

Unknown   OBJECT

Mr C Sheard 93 KENNINGTON AVENUE BISHOPSTON BRISTOL   OBJECT

My property backs onto the Cricket Ground. I am pleased that the club are able toattract international cricket to the County Ground. However, being situated in a densely populatedresidential area I am not convinced that the cricket club always take the task of minimising theeffect of big matches on the residents consistently.

Practice sessions were never allowed in the original floodlight planning application (2015) andwere excluded in 2016 by the council when applied for.

The current application will extend the floodlight usage to potentially 18 not 17 (16 sessions are onthe published fixtures 2019 list which has been distributed). I am concerned that approving theapplication, unless there are clear conditions made that this a 'one off' situation, will mean that thesame could happen in subsequent years thus increasing the permitted number of floodlightsessions.

The affect the use of floodlights has is detrimental to residential amenity for residents living aroundthe ground due to the extreme blinding glare that comes from the lights.

I hope that the council will refuse the application or if not make it very clear that if approved it is forexceptional circumstances and must not be used in subsequent years as a green light to do thesame again.

Mr Royston Smith 62 KENNINGTON AVENUE BISHOPSTON BRIOSTOL   OBJECT

I object to the application as I feel it is a backdoor attempt to get practice sessionsadded to the allowed usage. A similar attempt was made in 2016 immediately after the light wereinstalled. From past experience, and as we were informed at the recent residents meeting, theClub never gets near it's allowed floodlight usage in which case it does not seem necessary toextend it for the World Cup season.

Mr Nick Dance 5 LANCASHIRE ROAD BRISTOL   OBJECT

I object to the extra days for the floodlights to be on, although it is for 2019 only, I think itcould set a precedence for the future. I consider the original days allowed sufficient.

Mrs Bridget Joyce 16 BRYNLAND AVENUE BRISTOL   OBJECT

The original application was for the use of the lights for competitive matches only. Thecouncil has ruled that the use for practice sessions is not covered by the planning consent and ifthis application to extend to practice sessions is approved this will obviously set a dangerousprecedent for future years. I therefore think the council should refuse this application and savelocal residents from further use of these intrusive lights.

Dr Alison Orton 91 KENNINGTON AVENUE BRISTOL   OBJECT

I live next to the Cricket Ground. My personal view is that I am pleased that the CricketWorld Cup is coming to Bristol and I welcome international cricket and cricket in general at theCounty Ground.However, the Ground is situated in a densely populated residential area and the Club and indeedthe Council need to work with residents to minimise the adverse effects of big matches and eventson the local area. So far this effort has been patchy and inconsistent.

Practice sessions under lights were not allowed by the original floodlight planning consent (2015)and specifically excluded by a decision by the Council in 2016 when applied for by the Club. Myunderstanding is that, while floodlights are essential for the viability of the Club as they are a pre-requisite for hosting international cricket etc and this outweighs the damage to residential amenity,the same does not apply to practice sessions.

The current application extends the floodlight usage to 17 and includes 2 practice sessions for theWorld Cup. While this seems,at first glance, to be proportionate and reasonable, as the sessionsare only for 3 hours before sunset and will not involve large crowds or entertainment, my concernis that they will set a precedent. I am worried that if approved, unless conditions make clear thatthis is a 'one off' situation,it will be cited as a reason to extend floodlight use to practices andincrease the number of floodlight sessions allowed, by an application for future years.

Even practice sessions in daylight under floodlights would be detrimental to residential amenity forresidents living around the ground, in terms of glare.

My concerns are also increased by the fact that the Club did not notify or consult with residentsbefore submitting this application, although this is specified in the Floodlight Usage ManagementPlan (FLUMP). The application also contains incorrect and misleading wording in that it asks forADDITIONAL practice sessions, when such sessions are currently not permitted.

I ask the Council to refuse the application, or to at least make clear if they approve it, that it is anexceptional situation for the World Cup ONLY and may not be used to set a precedent for futureyears.

Mr John Eacott 27 LANCASHIRE ROAD BISHOPSTON BRISTOL   OBJECT

I am concerned at the lack of detail in the application and am worried that if approved , itcould allow the Cricket Club to further amend the original application.

Although I have no objections to the Cricket Club per se , the provision of flooding lighting has hada detrimental impact on the quality of our life when in use. The light levels have a significantimpact on the front of our house and particularly affects the sleep of my daughter who has a frontbedroom. They also affect my sleep when I am working an early shift.

I also maintain that the provision of permanent flood lights has had a negative impact on the visualaspects of our neighbourhood although I accept there is now nothing we can do about it.

It worries me that if this application is approved , it could result in ever more usage.

I also maintain that we should have some form of residents parking on match day but this appearssomething the Council refuses to consider. The excessive double yellowing lining will not improvethings for residents.

Mr Richard Holden 11 SALTHROP ROAD BRISTOL   OBJECT

19/01021/X - Application to vary conditions No. 3 (Restricted number of days per year touse the floodlights) and No. 6 (Use carried out in accordance with Management Plan) attached toplanning permission 14/05030/F - Proposed installation of 6 no. 45m tall permanent floodlights -now proposed to increase number of days the floodlights can be used to 17 per year for 2019 only.

I wish to object to the proposal by Gloucestershire County Cricket Club (GCCC) to vary theircurrent planning consent for the installation and operation of floodlights by increasing the numberof floodlit matches in 2019 from 15 to 17 to include 2 practice sessions under floodlights.

Practice was specifically excluded from the conditions of use in the original planning consent and Ibelieve that to allow this variation will set a precedent that will enable further relaxations of thenecessary constraints on use of the floodlights placed there to protect residential amenity andminimise the disruption caused by operation of the lights.

As a local resident on a street adjacent to the ground, I objected to GCCC's original application forthe floodlights, primarily on the grounds of their year-round visual impact on the environment. Theyhave been a massive visual intrusion in the skyline. Residents were also concerned at the impactof the lights when in use - the glare and intensity causing disruption to the sleep of children anddetriment to the peaceful enjoyment of houses and gardens in the evening.

Despite the significant objections and concerns of the local community, the planning authoritywere persuaded that the installation of the floodlights was critical to the future viability of GCCC

local community and therefore outweighed the possible disruption caused to local residents,provided that their use was strictly limited to minimise that disruption. The local community workedwith GCCC and the Council's officers in defining the acceptable limits of that use.

In the Floodlight Usage and Management Plan (FLUMP) that was developed and subsequentlyapproved by the planning authority, limited GCCC to use of the floodlights for just 15 occasions inany year and that they should be used during competitive cricket matches only. Para 2.1 of theFLUMP states:

"Apart from essential maintenance (see section 4 below), the floodlights shall only be used forcompetitive cricket matches and shall not be used more than 15 occasions per calendar yearunless otherwise agreed in writing with the LPA."

GCCC also stated in the FLUMP (para 2.11) that the absolute maximum requirement in anyseason was for 15 occasions of use. This limit was set with the upcoming ICC World Cup to behosted by England and Wales in 2019 in mind.

During the planning process GCCC sought to revise the FLUMP to allow the use of some of those15 occasions for practice sessions. This was strongly challenged by the local community on thebasis that whilst it could be argued that ability to light competitive cricket matches was critical tothe viability of the club (being linked to the demands of new and more commercially successfulforms of cricket and also the televising of international matches), the use of lights for practicesessions was not critical to that viability - and indeed might simply maximise the disruption causedto local residents.

After due consideration of this challenge, and having taken legal advice, the planning authorityruled that they should only be used for competitive cricket matches. Confirmation of this was sentto the HowZat residents group by the planning officer:

"The City Council's legal team have reviewed the interpretation of Condition 4 of the approvedplanning consent. It is the City Council's view that the use of the floodlights for practice sessionsgoes beyond the intention of the condition to limit the use of the lights to competitive cricketmatches only.The proposed, revised floodlight usage management plan (including reference to practicesessions) will therefore not be agreed in writing by the Local Planning Authority."

There has been no material change to the situation which led to that decision, and as far as canbe seen from the scant information accompanying the current variation application, no justificationor supporting information has been provided by the applicant. Also, there has been no proposal tovary Condition 4 (and 5) of the original consent which stipulates that the lights are only to be usedfor competitive matches, and no proposed amendment to the FLUMP submitted. Therefore, toallow additional occasions of floodlight use, seemingly specifically for practice purposes, would be

to now go against the legal advice the Council has received, would depart from Condition 4 (and5), thereby introducing ambiguity in future interpretations of the original planning consent and theaccompanying FLUMP, and would set a precedent, making it harder for the planning authority toresist further relaxations of the conditions of use of the floodlights.

During meetings with the club following their submission of the current variation application,residents were told that the practice sessions were to give the Afghanistan and Australian teams achance to practice under lights because the Afghan team in particular weren't used to playingunder lights and it made for a fairer competition. This justification seemed disingenuous when wesubsequently learned that Afghanistan's national team are based at the Dehradun stadium in Indiawhere they have floodlights. Apparently also, all ICC World Cup matches in 2014 and 2016 inBangladesh and India respectively (including Afghanistan) were played under floodlights with noproblem.

The disingenuousness displayed by the club extends also to the submission of the variationapplication itself. Para 4.5 of the FLUMP states:

"In the event that any part of this Plan requires review or revision such revisions will be undertakenin consultation with residents and officers of the Council at the appropriate time."

The local residents group HowZat only learned of the club's submission of a variation applicationthrough a standing alert on the Planning Portal. During February and March, Howzat maderepeated requests to the club to set a date for a meeting with residents to discuss the upcomingseason and the various measures being deployed to minimise disruption to residents - especiallygiven the number of International matches in the World Cup year.

The club's lack of openness and reluctance to engage with their neighbours, and the group ofvolunteers who are trying to represent their interests does not inspire confidence in their generalcare and concern for future relationships with the local community.

I moved to this area over 20 years ago in the full knowledge of the presence of the cricket club. Ihave accepted and (mostly) cheerfully put up with the occasional disruptions and inconvenienceson match days and on the run-up to big international events. However, the level and intensity ofdisruption has increased significantly in recent years, so it is all the more important for the club tobe open and honest with the local community and be sensitive to their impacts.

Although the City can take pride in having a first class cricket team based here, and there may bewider economic benefits from that relationship, the planning authority also have a responsibility toprotect residents from the impacts of development, and particularly where future intensificationmight incrementally increase the detriment caused to residential amenity. I would therefore urgethe planning authority to refuse the proposed variation of the consent, to allow the numbers ofuses of the lights to be increased to 17 and for the use for practice sessions.

Richard Holden11 Salthrop Road, Bristol, BS7 9DP

Ms Beverley Leonard 11 KENT ROAD BRISTOL   OBJECT

Over the past 40 years GCCC has transformed from an inclusive, friendly, considerateneighbour into an arrogant, profit-driven enterprise with no interest at all in the way its actions canadversely affect the community which surrounds it.

We understand the current management of the Club assured residents and BCC PlanningCommittee that they would not apply to increase use of their highly intrusive floodlights above 15days a year when they last applied for permission to use them. This latest application is a furtherexample of their duplicitous behaviour. We have no faith whatsoever in the Club's statement thatthis request is for the 2019 season only. We feel certain they will use any permission granted as aprecedent in future applications for both practice and actual matches.

The people living in the vicinity of GCCCs ground (many of whom have young families) alreadysuffer from increased traffic, vandalism, loud music, constant tannoys, glass and paper debris inour streets, drunken behaviour, street urination, extreme difficulty parking, light pollution etcwhenever a major match or event is held.

To allow GCCC to further disrupt its neighbours, having previously placed strict limits on floodlightuse, would be an insult to residents. We therefore urge the Planning Committee to say 'No' to thisapplication.

Beverley and Richard Leonard

Mr Jeffrey Cliff 14 THERESA AVENUE BRISTOL   OBJECT

I would like to object to the 2 extra days of floodlit practice sessions that GloucestershireCricket Ground has applied for.As with the grounds initial planning application, flood lights should be limited to matches andadding two more floodlit evenings for practice sessions would set a precedent which would allowthe cricket club to abuse in the future.I am sure that all the international teams are well used to playing in floodlit conditions all over theworld and would not need to practice at the Gloucestershire cricket club.I therefore object to any extension of the flood light allowance.

Ms Sue Lloyd 11 ARTHUR MILTON ST BRISTOL   OBJECT

At present the Floodlight Planning Agreement Conditions and Floodlight ManagementPlan (FLUMP) do not allow any usage for practice sessions. The Club applied to vary the FLUMPin 2016, at the beginning of the first season when floodlights wereused, to allow practice sessions.After representations from HowZat? and many residents the Council's planners concluded, aftertaking legal advice, that "the use of of the floodlights for practice sessions goes beyond theintention of the condition (4)to limit the use of the lights to competitive cricket matches only" andthis was not allowed. My understanding is that the distinction was drawn because whilst theinstallation of the floodlights was allowed because they were needed to play International andother matches to ensure the viability of the Club and this outweighed the damage to residentialamenity, such factors did not apply to practice sessions..

5. The current application is very badly worded - It is:

-To amend the condition 3 "The floodlights shall be used on no more than 15 days in any calendaryear" and adds "with the exception of 2019 where 2 additional practice sessions are required forthe ICC World Cup and thelimit is increased to 17 days for that year alone. From 1 January 2020onwards usage shall revert to to no more than 15 days in any calendar year"Practice sessions are not currently allowed so 'additional practice sessions' is incorrect andpotentiallymisleading wording.

-Condition 4 /5 of the Floodlight Planning Agreement made in 2015 state that "Apart from essentialmaintenance the floodlights shall only be used in connection with competitive cricket matches"(This condition is not mentioned at all in the current application.)-To amend condition 6 which currently reads "The floodlights shall only be used in accordancewith the Floodlight Usage Management Plan submitted with the application" and adds "with theexception of 2019 as detailed inCondition 3 ". The FLUMP, in addition to talking about thefrequency of usage of the lights and usage only for competitive cricket matches, contains details ofthe time of usage, maintenance and liaison with residents. I hope that these aspects are not alsoto be suspended for the whole of 2019!6. Concern was expressed at the recent meeting with residents at the Cricket Ground, that whilethe practice sessions applied for seem reasonable in the context of the World Cup coming toBristol, this could easily set a precedent which allows further practicesessions or increased usageof floodlights in future seasons to be applied for and approved.

Mr Robert Duff EARLSFIELD TOWN PLANNING LTD 74 KEWSTOKE ROAD KEWSTOKE   OBJECT

I am instructed by nearby residents to make a formal objection against application forplanning permission 19/01021/X.

I attach a detailed assessment of the application which I request you would take into account indetermining the application.

In summary, I object to the application for the following reasons;

1. The application proposes that two 'additional' Practice Sessions are held under Floodlights toaccommodate Practice Sessions for ICC World Cup Teams playing in June 2019;

2. It seeks to secure this by requesting amendments to Conditions 3 and 6, but not condition 4/5;

3. The impact of this would be to approve the use of the Floodlights for Practice Sessions up to theend of 2019;

4. Planning permission 14/05030/F approved the use of Floodlights only for up to 15 specifiedcompetitive matches because the Planning Committee resolved that the economic & socialbenefits of holding those competitive matches outweighed the significant harm to residentialamenity caused by the Floodlights;

5. The ICC World Cup competitive matches were specifically included within the 15 maximum

matches and are mentioned in the approved Floodlight Usage Management Plan (FLUMP);

6. When 14/05030/F was determined residents were advised that the planning permission wouldbe for up to 15 competitive matches, which is the maximum that would be required during theWorld Cup year of 2019. The implication being that during other years there are likely to be fewerthan 15 competitive matches;

7. Although initially applied for, Planning permission 14/05030/F did not approve the use ofFloodlights during Practice Sessions because it was resolved that the use of the Floodlights forPractice Sessions does not outweigh the significant harm to residential amenity caused by theFloodlights;

8. No information has been presented with the application to justify the proposed significantmaterial change to planning permission 14/05030/F;

9. If 19/01021/X is approved, it will confirm that holding practice sessions outweighs the significantharm to residential amenity caused by the use of the Floodlights. Once this is accepted by BCC, itwill be a materially change to the planning permission that BCC will not be able to defend againstin the future. It will thus affectively allow the use of the Floodlights for Practice sessions for evermore;

10. If the use of the Floodlights for two practice sessions is determined to outweigh the significantharm to residential amenity, how could BCC argue that three, four, five or any number of practicesessions held under Floodlights would harm residential amenity?

11. This is a fundamental and significant material change to the planning permission 14/05030/Fthat will be harmful to residential amenity;

12. Planning permission should therefore be refused due to the significant harm to residentialamenity.

The submitted application proposes a significant material change to the planning permission that Ibelieve should not be considered through a S73 application, because such an application can onlyconsider the changes to the specific conditions. The proposed change from the use of theFloodlights only for specified competitive matches (in the FLUMP controlled by condition 6) to onewhich allows use for practice sessions during the whole of 2019 is significant and requires fullconsideration of all material considerations.

GCCC has advised residents that the Floodlights are required for practise sessions becauseAfghanistan, who will play in a ICC World Cup game at GCCC on 1st June 2019, do not normallyplay under floodlight and thus need some practice under them.

GCCC are mistaken in this regard, as Afghanistan have Floodlights installed at their home groundand play all of their home Twenty/20 matches under Floodlights, played every match in the lasttwo ICC World Cups under Floodlights and are currently playing Ireland in a 6 match ICC seriesunder Floodlights. I have been unable to find any ICC Twenty/20 matches since 2014 thatAfghanistan has not played under Floodlights.

It is quite clear that Afghanistan do not require any additional practice under Floodlights and thatthis reason does not outweigh the substantial harm the use of the Floodlights will cause toresidential amenity.

If GCCC wishes to secure planning permission to use the Floodlights for two Practice Sessionsrelated to the ICC World Cup, they should make a separate application for full planning permissionand present detailed justification for the significant departure to the extant planning permission thatoutweighs the significant harm to residential amenity.

The Planning Assessment prepared by me and submitted by email expands upon the aboveobjection.

For all of the above reasons and for the reasons set out in the Planning Assessment (to follow byemail) I hereby request that application for planning permission 19/01021/X be refused.

ETP.1078 19/01021/X – Planning Assessment 28th March 2019

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The application provides no justification for the proposed change at all. I am aware that

residents have been told that this is to allow Afghanistan to practice playing under Floodlights,

but this is not mentioned in the application.

I am concerned that the, possibly unintended, consequences of BCC approving the

application would be;

1. Their will be a direct conflict between Conditions 3 and 6 which allow the Floodlights to

be used for Practice Sessions and older Condition 4 which restricts use of the Floodlights

to specific (defined in the FLUMP) Competitive Matches only.

The impact of this will be that Condition 4 will no longer be enforceable and the

Floodlights will be able to be used for Practice Sessions throughout 2019;

2. For permission to be granted BCC will have to accept that the benefits of using the

Floodlights for Practice Sessions during 2019 outweighs the harm to residential amenity.

This is a significant change to the existing planning permission.

If this is accepted, especially without any justification, BCC will not be able to stop the

use of the Floodlights for Practice Sessions in the future. If they are not harmful for 17

Practice Sessions, why would they be harmful for 18 a year, 19 a year, etc., beyond the

end of 2019.

3. The approval of the application will therefore fundamentally change the planning

permission to use the Floodlights from one that allows up to 15 specific Competitive

Matches per year and probably far less than this in most years, to one that allows the

use of the Floodlights 17 times per year without the controls imposed by the FLUMP.

4. Afghanistan’s Home Ground which is in India has Floodlights, they played every match

of the last two ICC World Cups under flood lights and are currently playing Ireland in a

6 match series under floodlights seemingly without any problem at all. As they play

almost every Twenty20 match under floodlights and have done so for many years, I do

not understand why they need to practice under them.

I am firmly of the opinion that approving the application will fundamentally change the

planning permission to use the floodlights to the significant detriment of the residents.

My recommendation is that an objection be made against the application for the reasons I

summarise above and set out in greater detail below.

ETP.1078 19/01021/X – Planning Assessment 28th March 2019

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Existing Planning Permission

Permission 14/05030/F approved on 5th May 2015 allows the erection of the Floodlights subject

to a number of conditions, including;

3. The floodlights shall be used on no more than 15 days in any calendar year.

Reason: In the interests of protecting residential amenity.

4./5. Apart from essential maintenance the floodlights shall only be used in

connection with competitive cricket matches.

Reason: In the interests of protecting residential amenity.

(I list this as Condition 4/5 as it was mistakenly attached to the planning

permission twice)

6. Floodlight Usage Management Plan: The floodlights shall only be used in

accordance with the Floodlight Usage Management Plan submitted with the

application. Any proposed amendments or revisions to the Floodlight Usage

Management Plan shall be submitted to and approved in writing by the Local

Planning Authority.

Reason: In the interest of protecting residential amenity.

The Floodlight Usage Management Plan (FLUMP) restricts the height of the lights, the maximum

hours of operation (to be switched off 30 minutes after end of the match), limits the illumination

once a match has finished to 10% (unless televised then 50% whilst de-rigging), requires

consultation with residents and states that the Floodlights can only be used for specific

competitive matches: It does far more than restrict the use of the Floodlights to 15 days.

The permission as granted is quite clearly limited to use for specified Competitive Matches (plus

maintenance) only. To change this would be a substantial amendment to the permission.

The Application

I have looked at application 19/01021/X made by Gloucestershire CCC.

The application seeks to continue the use of the Floodlights not in compliance with existing

Conditions 3 and 6 referred to above, and then proposes new Conditions 3 and 6 as stated

below.

The application form states;

‘Amendments sought to increase the number of floodlight uses from 15 per calendar

year to 17 for the year 2019 alone. This is required at the stadium in the context of the

ICC World Cup which is to be hosted in England and Wales in 2019. Associated

games/practice sessions mean 17 floodlight uses will be needed in 2019. This will revert

to 15 uses per calendar year from 1 January 2020.

Condition 3 to read:

ETP.1078 19/01021/X – Planning Assessment 28th March 2019

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The floodlights shall be used on no more than 15 days in any calendar year with the

exception of 2019 where two additional practice sessions are required for the ICC World

Cup and the limit is increased to 17 days for that year alone. From 1 January 2020

onwards, usage shall revert to no more than 15 days in any calendar year.

Condition 6 to read:

Floodlight Usage Management Plan: The floodlights shall only be operated in

accordance with the Floodlight Usage Management Plan submitted with the

application, with the exception of 2019 as detailed in Condition 3. Any proposed

amendments or revisions to the Floodlight Usage Management Plan shall be submitted

to and approved in writing by the Local Planning Authority.’

The application states that GCCC propose to hold ‘additional practice sessions’. This is unusual

because Practice Sessions are currently are not allowed to take place under the Floodlights,

which is controlled by Condition 4 and the FLUMP.

The proposed alternative conditions are very unclear on their face and will be in conflict with

Condition 4, which does not allow the Floodlights to be used for any purpose other than for

Competitive Matches and maintenance. If approved, the resultant permission would be a

nonsense because new conditions 3 and 6 would clash with condition 4/5.

More importantly, the application seems to propose a fundamental material change to the

planning permission, moving from a permission which allows the use of the Floodlights for

specific Competitive Matches only, to one which allows the use of the Floodlights for both

Competitive Matches and Practice Sessions: An application to continue development not in

accordance with a condition should not be used to fundamentally and materially alter a

permission.

The above changes to Conditions 3 and 6 could reasonably be interpreted to allow 17 days

use of the Floodlights for either Competitive Matches and/or for Practice Sessions. Once this is

permitted and accepted, it will be very difficult to stop the permanent expansion of the use

of the Floodlights for both Competitive Matches and Practice Sessions.

Reference to the FLUMP being amended in accordance with new Condition 3 is also

potentially very harmful because new Condition 3 will allow the use of the Floodlights for both

Competitive Matches and Practice Sessions. I am of the opinion that the change will make

the FLUMP, along with Condition 4/5, unenforceable.

ETP.1078 19/01021/X – Planning Assessment 28th March 2019

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Reason for Application

Application 19/01021/X is not supported by any reasoned justification.

Three ICC Cricket World Cup matches, involving Afghanistan, Australia, Pakistan, Bangladesh

and Sri Lanka, are being played at GCCC on 1st, 7th and 11th June 2019.

GCCC have explained to residents that Afghanistan are not used to playing under floodlights

and wish to practice under them prior to their ICC Cricket World Cup match on 1st June, and

to be fair to both teams GCCC will also allow Australia to practice under the Floodlights.

I find this argument a little unusual as the first floodlit ICC one day international was held in

Australia in 1979. In fact, all 27 of the 2014 ICC World Cup matches (held in Bangladesh) and

2016 ICC World Cup matches (held in India) were day/night matches under floodlights, in

which all 5 of the above teams took part, seemingly without a problem.

In relation to Afghanistan, I attach below a photo of Dehradun Cricket Stadium in India where

the team is based, which clearly illustrates their Floodlights.

Dehradun Cricket Stadium in India where the Afghanistan Cricket Team is based

Afghanistan are currently playing Ireland in a series of ICC Twenty20 matches, all 6 of which

are being played under these floodlights. I refer to the following link showing the extended

highlights of Afghanistan playing Ireland in one of the recent matches; where they seem most

comfortable under floodlights.

https://www.youtube.com/watch?v=0wY5lB2-xDs

In light of this, I can find no justification for playing any Practice Sessions under the Floodlights

at GCCC. The harm to residential amenity created by using the Floodlights is not outweighed.

ETP.1078 19/01021/X – Planning Assessment 28th March 2019

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Recommendation

I recommend that you object to the application for the following reasons;

1. Planning Permission 14/05030/F was considered at Committee and is subject to

condition 4/5 (the condition is listed twice) which limits the use of the lights to use for

Competitive Matches only, plus maintenance, in order to protect residential amenity,

and by Condition 6 which requires compliance with the FLUMP which restricts the use

of the Floodlights to specified Competitive Matches to protect residential amenity.

This is a fundamental part of the planning permission that should not be altered by a

simple amendment to a condition.

If GCCC wishes to use the lights for Practice Sessions, this should be considered by way

of a new fully justified application for planning permission explaining why the benefits

of such activity outweigh the significant harm to residential amenity.

Objection because it is inappropriate for the fundamental basis of a planning

permission to be changed by a simple amendment to a condition. To do so would be

harmful to residential amenity. And because the application, if approved, will remove

the restriction of the use of the Floodlights to specified Competitive Matches and will

instead allow the use of the Floodlights for unrestricted matches and Practice Sessions.

If the applicant wishes the LPA to consider the use of the Floodlights for purposes other

than Competitive Matches, they should submit a separate application for planning

permission proposing such.

2. The application does not propose an amendment to Condition 4/5.

If approved, the planning permission would be a nonsense because Condition 4/5

would resist the use of the Floodlights for Practice Sessions, but Condition 3 would allow

such activity.

The conditions attached to the planning permission, in particular Condition 4/5, could

therefore not be enforceable due to the conflict with the more recent Conditions 3 and

6, and the Floodlights could be used at any time, for any purpose, for as many days of

the year GCCC wishes.

Objection because the application is a legal nonsense that would result in the planning

permission being subject to two conditions that are directly contradictory and possibly

result in Condition 4/5 not being enforceable, resulting in a material change to the

planning permission and significant harm to residential amenity.

3. The application does not propose a specific change to the FLUMP.

Instead, it allows for Condition 6 to be altered in accordance with new Condition 3. The

impact of this will be that the FLUMP will no longer be enforceable.

ETP.1078 19/01021/X – Planning Assessment 28th March 2019

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Objection on grounds that removing the enforceability of the FLUMP will result in

significant harm to residential amenity.

4. The application as submitted therefore does not justify in any way harming the

residential amenity of residents and should be refused.

Members of the GCCC have advised residents that two Practice Sessions are needed

prior to the match on 1st June because Afghanistan do not normally play under

floodlights and need practice under them.

A quick internet search, however, illustrates that Afghanistan play all of their home ICC

Twenty20 matches under floodlights, played in the last two ICC World Cups (2014 and

2016) under floodlights and are currently playing Ireland in a series of 6 ICC Twenty20

matches under floodlights, the first of which have been played and can be

downloaded from the internet. In fact, I have been unable to find any ICC Twenty20

matches Afghanistan has played in recent years that were not under floodlights.

No justification for the proposed development and the resultant harm to residential

amenity has been put forward with the application and that which has been put to

residents does not stand up to even the most basic scrutiny.

Objection because the approval of the application without justification will make it

impossible for BCC to resist any future use of the Floodlights. Therefore, the proposed

development will harm residential amenity.

5. The application does not seek the use of the Floodlights for two Practice Sessions in May

2019, but instead seeks to allow the amended activity until the end of 2019.

Once the unjustified use of the Floodlights for Practice Sessions is accepted by BCC as

outweighing the harm caused to residential amenity, BCC will be unable to resist future

proposals to use the lights for Practice Sessions in addition to Competitive Matches.

Objection because the effect of the permission would be to allow the use of the

Floodlights for both Competitive Matches and Practice Matches to the detriment of

and harm to residential amenity.

6. The application proposes the relaxation of the FLUMP and Conditions 3 and 6 for a

period of 9 months, yet the residents have been advised that the proposed Practice

Sessions are required only for teams playing a Competitive Match on 1st June 2019.

If the applicant seeks only 2 Practice Sessions for 2 specific dates before1st June 2019,

why are they seeking permission for such activity for the whole of 2019?

This is of concern because the impact of the permission if granted, would be for new

Conditions 3 and 6 to outweigh previously attached Condition 4/5 and the FLUMP, thus

removing any restriction to the activity under which the Floodlights can be used.

ETP.1078 19/01021/X – Planning Assessment 28th March 2019

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Objection because the application proposes an amendment to the planning

permission which will allow then future use of Floodlights for Practice Sessions which will

harm residential amenity.

7. The application is worded in such a way that it could reasonably be interpreted to allow

the use of the Floodlights for Practice Sessions that will be harmful to residential amenity

at any time during 2019.

The proposed change to Condition 3 states;

“with the exception of 2019 where two additional practice sessions are required”

It would be a reasonable interpretation that the above wording, by the inclusion of the

word ‘additional’, amends the planning permission as a whole to allow the use of the

Floodlights for Practice Sessions at any date during 2019.

Whilst the application seeks only two additional days use of the Floodlights and must be

considered on its merits, the fact that it fundamentally alters the planning permission

granted in 2016 from one restricted to specified Competitive Matches to one that does

not include such a restriction, means that it is should be refused as such alteration would

be harmful to residential amenity.

Objection because the effect of the proposed change to Condition 3 would be to

fundamentally alter the planning permission to allow for the use of the Floodlights for

reasons other than Competitive Matches, which would not outweigh the harm to

residential amenity.

8. The proposed alteration to Condition 6 is vague and ambiguous to the point that it

cannot be lawful.

The application does not propose any additional wording or alteration to the FLUMP,

but instead refers only to the proposed alteration to Condition 3.

As explained above, the effect of the propose change to Condition 3 would be to

make the FLUMP unenforceable and therefore allow the use of the Floodlights at any

time for purposes not in connection with Competitive Cricket Matches.

The proposed new wording of Condition 6 seems very simple but is in fact very harmful

to the meaning of the planning permission and therefore residential amenity.

Objection, the proposed change to condition 6 will allow the use of the Floodlights for

Practice Sessions throughout 2019 and will thus extend their use beyond that for

specified Competitive Matches to the detriment of and harm to residential amenity.

The fact that the application seeks planning permission for a temporary period does not in any

way alter or lessen the weight of the above objections as any use of the Floodlights harms the

residential amenity of neighbouring occupiers.

ETP.1078 19/01021/X – Planning Assessment 28th March 2019

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Conclusion

The application does not only introduce two days of Practice Sessions in 2019 but could quite

reasonably be interpreted to amend the planning permission in its entirety, removing the

previously imposed restriction to the use of the Floodlights only in connection with specified

Competitive Matches for the entirety of 2019.

Should such a planning permission be granted, it will be very difficult to refuse an application

to make this change permanent as the principle that the benefit of allowing Practice Sessions

under Floodlights outweighs the harm to residential amenity would have been established.

It was accepted by BCC and has been accepted by the neighbouring residents that

important competitive matches, such as the ICC Cricket World Cup, which was discussed

when the original planning permission was granted, deliver economic and social benefits to

Bristol that outweigh the harm to residential amenity caused by the use of the Floodlights on

those limited occasions.

It was not, however, accepted by BCC or by the neighbouring residents that any other use of

the Floodlights, including use for Practice Matches that was discussed in detail when the

original planning permission was determined, outweigh the harm to residential amenity. It is

for this reason that Condition 4/5 was attached to the planning permission and the FLUMP

amended to refer to specific Competitive Matches and not to refer to Practice Sessions.

The submitted application does not change this position and does not introduce any evidence

to indicate that it should be changed.

Should GCCC wish to use the Floodlights for two specific Practice Sessions and should they

have evidence to confirm that such activity is necessary and outweighs the clear harm caused

to residential amenity, it should make a fresh and independent application for planning

permission for such development. An application to continue development not in

accordance with conditions is certainly not a suitable vehicle to consider such a fundamental

change to a planning permission.

For the above reasons, I am strongly of the opinion that the application for planning permission

19/01021/X should be refused.

Rob Duff

Director

Mr Ross Opie 417 HAMMOND APARTMENTS COLLEGE ROAD BRISTOL   SUPPORT

I would support the application.

The opportunity to host World Cup games now and possibly similar events in the future is afantastic opportunity for Bristol.

It is a prestigious event and will not only bring in significant income to local businesses, it alsoshows Bristol as a City of in a very positive light.

Mrs Sarah Skeen 109 KENNINGTON AVENUE BRISTOL   OBJECT

I support the Club in its desire to hold international cricket matches and in particular the2019 World Cup. Therefore in principle I do not object to the use of the floodlights for 2 practicematches for 2019 only, subject to the restrictions on the times they can be used as outlined in theapplication. However I would like it noted in the permission granted that the use of the lights forpractice matches is genuinely exceptional and for this year only solely because of the exceptionalcircumstances in which the Club is hosting the World Cup. It is important to note that the Councilmade clear in 2016 that the permission to use the floodlights extended to competitive cricket onlyin order to reduce the harm caused by the floodlights to local residents enjoyment of their property.If permission is granted for the Club to use them in practice matches beyond this year this wouldhave a detrimental impact on residential amenity. The original permission was granted becausefloodlight usage for competitive matches was required to ensure the viability of the Club. Thisrationale does not extend to practice matches.

Mr Christopher Bailey GROUND FLOOR FLAT 16 SURREY ROAD BRISTOL   OBJECT

As the original planning application was very clear in there being no need for more than15 uses per year of the flood lights I am very concerned that such an application is being madebecause it sets a precedent for further incremental increases in future years.If the club claims that it is a one off, then surely there is another route that could be used to gainconsent for this rather than a permanent change to the terms of the application.

Mr Ben Harris 53 SEFTON PARK ROAD BRISTOL   OBJECT

These lights have a huge negative impact on the area. They cause significantdisturbance and should never have been approved as permanent structures.

This application is a cynical attempt to overhaul the original conditions under which the initialconsent was given and must not be approved.

Mr David Thomas FLAT 29. ALLEN HOUSE ARTHUR MILTON STREET BRISTOL   SUPPORT

Gloucestershire C.C.C. is hosting several important matches in 2019 including CricketWorld Cup and International matches. Some may require additional use of the floodlights andsome will be televised. This will not only be good for the cricket club but also for Bristol and, notingthat the proposal specifically refers to 2019, I would like to support the application.

Mr Peter Probyn 318 HAMMOND APARTMENTE COLLEGE ROAD BRISTOL   SUPPORT

I do not see any problem with light pollution as it is largely daylight hours and earlyevening and will bring footfall to the area and thus extra trade to local businesses and GCCC withincreased employment opportunities

Mr Peter Tovey 10 UPPER BELMONT RD BRISTOL   SUPPORT

My understanding is the application to increase the number of days when the floodlightscan be used is linked to the 3 cricket world cup games, the women's T20 international and othermajor games in the coming season. There is therefore a rationale that the application is for a timelimited change.

I would support the application for two main reasons. Firstly the option to use the floodlights for afew more days increases the likelihood that high profile games can be completed during theexpected timescale. This is to the benefit of local people and those travelling from elsewhere inEngland or other countries, and these people contribute to the local economy through theirspending in local cafe's and pubs, and those travelling a longer distance are likely to stay for anight or more in a local hotel.

In addition during matches from June to mid August, the floodlights are often switched on whenvisibility is good in the sunlight and therefore the lights have a minimal impact on the light levelexperienced in nearby properties. Hence this application should be supported as the effect onresidents who live close to the ground is minimal on most days.

This is a small change which benefits the club and also brings financial benefit to traders andbusinesses in the local area and across Bristol. I would therefore urge the committee to approvethe application.

Unknown   OBJECT

Also the Council's parking wardens need to start doing their job and ticketing all the vehicles parking on corners and pavements and stop just walking away saying its a police issue, as they currently do. People will soon stop parking irresponsibly if they get a parking ticket.

When the lights are turned on the top of our house is day lit, which is ridiculous. The lights are far too bright and the light pollution to the surrounding area is huge.

Finally the parking issues which are made considerably worse by the Cricket matches is mainly caused by the council allowing so many houses to be converted to HMOs. The parking space available is proportional to the width of the houses that haven't converted their front or rear gardens to parking. Last year the house next to use had 4 people in it with 5 cars.

I've even changed my working hours to try and get home earlier to find parking and that doesn't work most days.

regards

Mike Bull

Virus-free. www.avast.com

Dr Peter Box 11 LANCASHIRE ROAD BISHOPSTON BRISTOL   SUPPORT

As a resident in a road adjacent to the ground I can honestly say that since installed, thefloodlights have caused no inconvenience whatsoever.I therefore have no objection to the requested extension of their use during 2019 only.

Mrs Angela Probyn 318 HAMMOND APARTMENTS COLLEGE ROAD BRISTOL   SUPPORT

In Cricket World Cup Year GCCC should be allowed extra floodlit games to promote theclub and the City. The world will be watching these games and it is important to put Bristol on tothe world stage at every opportunity.

Unknown   OBJECT

Mr Robin Kellett-Navellou 21 CRICKLADE ROAD BRISTOL  

I am neutral on this application but wish to state that I will object in the strongest terms ifthe club wishes to use this as a precedent for increased floodlight activity in future years.

I appreciate that it is a world cup year and so I think they have a need to make sure all goes wellas best as they can to ensure that Bristol is not embarrassed on a global stage.

However the club has a habit of incremental encroachments (and sometimes much bigger onesthan that) and I and many others will be extremely annoyed and very critical if the club andsubsequently the council make the argument that far more extensive floodlight use is OK with theresidents because they agreed to it in 2019.

In the case that the club do not attempt this and there is a future world cup where the club hostsagain, I would not object for again a one-off case.

Mrs Harriet Batten-Foster 1 SURREY ROAD BRISTOL   OBJECT

I oppose this application. The installation of the floodlights has been hugelycontroversial and opposed by the majority of local residents. This application to increase their useis indicative of the cricket ground's total disregard for the interests of the neighbourhood and itsresidents.

Mr oliver iles 49 UPPER BELMONT RD BISHOPSTON BRISTOL   OBJECT

I would like the original conditions to remain - An increase in the number of usages ofthe floodlights is not acceptable

Also the use for Practice Sessions is also not acceptable

Extra nights using the lights has a negative impact on residents.

Mr James Magness 203 GRAVENEY APARTMENTS COLLEGE ROAD, BISHOPSTON BRISTOL   SUPPORT

We live on the cricket ground and have one of the floodlight right outside of ourapartment so in one sense are amongst the most affected neighbours. We have no problems withthe application since it is a one off request to meet the requirements that come with holding thecricket world cup. Also the lights will only be on for three hours before the sun goes down.

Mrs Kate Edmondson 24 NOTTINGHAM ROAD BRISTOL   OBJECT

I strongly object to this application. The club was clear in its original application that thelights would only be used 15 times per year and they should stick to this commitment. Allowingextra use of lights for practice sessions would set an unwelcome precedent which the club is likelyto take advantage of making it harder for future applications to be refused.

Mrs Emma Geale 19 KENT ROAD KENT ROAD BRISTOL   OBJECT

I strongly object to this application. There is NEVER any support from the GCCC re bigmatches. Despite numerous meetings and suggestions from neighbours this club does not everhelp/support us. They do not police this properly, they do not provide enough stewards. They justcontinue to want to get bigger without putting any resources into the community. Until such time asthey involve the neighbours and start improving match days for those of us in the area. Enough.They will not get anymore support from me.

Mr Barry Geale 19 KENT ROAD BRISTOL   OBJECT

I strongly object to this application. There is NEVER any support from the GCCC re bigmatches for neighbours.

Ms Ceri Jones 54 ARTHUR MILTON STREET BRISTOL   OBJECT

The flood lights are already an intrusive and unsightly stain on the view from our flat.When they are on, they light up the flat like it is day light. We have to wait until they are completelyoff before going to bed because of the light pollution. It may only be up to 15 times a year but it isnever welcome, as the lights take along time to switch off completely.I also feel that the cricket ground does not care for those living in the surrounding area on bigevents. I once looked out of my bedroom window to find a drone flying at eye level, facing the flat.Why was it even near here?! This intrusion is not ok, with the lights or anything else. As othershave commented, it's a slow incremental taking of power that they stated a little over 2yrs ago thatthey wouldnt need.

Mr Arthur Taylor 35 SEFTON PARK ROAD BRISTOL   OBJECT

I strongly object to this application as it further degrades the local residentialneighborhood through unwarranted increased light pollution.The original application was robustly contested and at the time the GCCC gave assurances thatthe number of floodlit uses would be strictly limited. The club are now attempting to change thoseagreements and will seemingly disregard the local community once again.The lights themselves are totally dominating in terms of the neighborhood skyline and when lit,they cast light onto a huge number of houses and are disruptive for many families.I ask the council to take a firm line on this as it seems the club are attempting to flout the previousagreements made, and will continue to do so if allowed to increase the sessions when floodlightscan be used.The club have failed to produce effective support and resource for the community during busymatches. (traffic management etc) this application should be refused as it further erodes thecommunity.

Mr anthony huszlicska 145 MAPLE ROAD BRISTOL   SUPPORT

Happy to support proposal as it will bring in money & visitors to Bristol attending highprofile international matches. Putting Bristol on the worldwide map.

Mr Roger Ford 16 BRYNLAND AVENUE BRISTOL   OBJECT

The original application to install the floodlights, which was itself hotly contested by localresidents, was for a maximum of 15 uses per year, for actual cricket matches. The club hasalready tried to extend this constraint to cover practice sessions as well as matches, and this hasrightly been refused by the Council. While the present application says it is to cover additionalpractice sessions for the 2019 session only, granting permission to this would plainly establish aprecedent which would lead to further similar applications in future years, and would make theseharder to refuse. The lights are very intrusive for local residents, and the Council should hold itsline on this matter.

Mr simon hall 20 NOTTINGHAM ROAD BRISTOL   OBJECT

This application is contrary to the very clear limitations set out in the original highlyunpopular planning permission. If the cricket club wish to accommodate the practice sessions thenI suggest they reorganise their other evening games to daylight hours.

Any relaxation of the very clear instructions given by the planning permission when granted, willonly encourage the applicant to make more and more applications. This is the thin end of thewedge, the cricket club has proved through the building of the flats and subsequent building of thelights that they progress their developments in stages, stating the previous development as ajustification for the next.

I urge the committee not to allow any further degradation of the immediate residentialneighbourhood.

Ms ann stobbs 9 MELBOURNE ROAD BRISTOL   OBJECT

I am very concerned that such an application is being made because it sets a veryworrying precedent for future years. Despite a firm promise by the club when the arrangementswere initially made that they would never exceed the agreed 15 times for floodlight use (andindeed they claimed that it would rarely use the full 15 times allowed) it is now trying to do that. Itis NOT allowed under the present arrangements and should therefore be turned down. If the clubclaims that it is a one off, then I would remind you that the club did not inform the local group- whothey claim to work closely with- about this application as they heard about it from other means. Ifthe club does this when it knows what a contentious issue it would be , then I have absoluteconfidence that the club will try to push up the times again and again. The floodlights cause hugeproblems for residents in the area because of extreme light pollution.