24/5650/OUT

The proposed development, by virtue of its scale, layout, and use as a professional football stadium, would result in the unacceptable loss of protected public open space and would significantly undermine the delivery of strategic sports and recreation infrastructure identified in the Barnet and King George V Playing Fields Masterplan. The development fails to provide equivalent or better replacement provision in terms of quality, quantity, or accessibility and does not demonstrate that the benefits of the proposed alternative recreational use outweigh the loss of the current use. As such, the proposal is contrary to the National Planning Policy Framework (paragraphs 98 and 103-105), London Plan Policies GG3, G4, and S5, and Policies BSS01, GSS13, CHW01, CHW02, and ECC05 of Barnets Local Plan 2025.

The proposed development, by reason of its location and its excessive footprint, represents inappropriate development within the Green Belt which would cause substantial harm to the fundamental intention and purposes of including land in the Green Belt and the applicant has failed to demonstrate very special circumstances necessary to warrant an exception to the National Planning Policy Framework (NPPF) (paragraphs 187-195), Policy G2 of the London Plan 2021 and Policies ECC05 and ECC06 of Barnet's Local Plan 2025.

Insufficient ecological information has been provided to determine the impacts of the proposed development on protected species, including bats and otters. In particular, the proposed stadium layout and lighting strategy have been developed without confirming the presence or likely absence of key European Protected Species, resulting in inadequate assessment of potential disturbance or harm. This omission risks contravening the Conservation of Habitats and Species Regulations 2017 and is contrary to Policy G6 of the London Plan 2021 and Policies ECC02, ECC05, ECC06 and ECC07 of Barnet's Local Plan 2025.

Insufficient information has been submitted to assess the potential impact of the proposed development on heritage assets of archaeological interest. In the absence of an archaeological desk-based assessment, the application fails to demonstrate that the development would not result in harm to archaeological remains. The proposal is therefore contrary to paragraph 207 of the National Planning Policy Framework, Policy HC1 of the London Plan 2021, and Policy DM06 of Barnet's Local Plan 2025.

Insufficient information has been submitted to demonstrate that the proposed development would not result in unacceptable levels of on-street parking stress in the surrounding area. In particular, no parking stress surveys have been undertaken, and there has been no meaningful engagement with the Council regarding the implementation of a Controlled Parking Zone (CPZ) to mitigate the impact of displaced spectator parking. In the absence of this information, there is a clear risk that the development would cause harm to the operation of the local transport and highways network, including impacts on residential amenity and highway safety. The proposal is therefore contrary to Policy T6 of the London Plan 2021 and Policy TRC03 of Barnet's Local Plan 2025.

The proposed junction design, by virtue of the omission of a pedestrian refuge island at the widened bell-mouth access, unresolved conflicts between pedestrian, cyclist, and vehicle movements along the internal access road, would result in unacceptable harm to highway and pedestrian safety. The development would therefore be contrary to Policy T2 of the London Plan 2021 and Policy TRC01 of Barnet's Local Plan 2025.

The application does not include a formal undertaking to secure the planning obligations which are necessary for the development to be found acceptable. Page 144 of 147 The application is contrary to Policy DF1 of the London Plan 2021 and Chapter 12 of the Barnet Local Plan 2025 and the Barnet Planning Obligations SPD (adopted February 2025).