Folkestone Invicta Football Club has tabled the following comments to Shepway District Council in response to the planning application submitted for redevelopment of the Polo Ground sports facility.  These comments should be reviewed against relevant parts of the Design and Access statement constituent to that application, and accompanying documents, maps and plans, all of which are accessible on-line via www.ukplanning.com/shepway by entering the planning application reference Y10/0075/SH

1.  Management Plan . 

In its introduction, the design and access statement makes this claim:

“The new facilities will be available for public hire at competitive rates similar to other venues in the area to keep sport accessable (sic) and affordable.  The grass pitches will also remain available for hire so that generally, existing users will continue to enjoy their sport at Cheriton Road.

The introduction of a second artificial turf pitch (ATP) will greatly benefit the community because there is a high demand for this type of multi-use surface.  The additional pitch time available will benefit all including Invicta and Invicta Youth football clubs who are high users of the existing ATP.”

This is a disingenuous statement for a number of reasons.  There is no attempt to analyse or commit such pitch hire rates as would be applied and the entire proposition is founded on subsequent and vague assertions about the introduction of a “Managing Body”.  That issue is revisited further into these comments.  Current users of football pitches in particular could be forgiven for being deeply sceptical since the hire rates already applied by Shepway are by some distance the highest in Kent and, for instance, more than triple the equivalent rates in Dover.  How can rates be competitive if there is no competition?  The implied continuance of current football facilities is then completely contradicted by subsequent references in the document to football being over-provided for; and it will be received with contempt by the real users who know that the pitches on the bottom (Pent Stream) end are invariably out-of-commission because of intractable drainage problems, and how readily the SDC groundstaff resort to declaring all the football pitches unfit in preference to having to prepare them when the ground state is marginal. 

The subsequent references to third-party use of the second artificial turf pitch (ATP) are equally objectionable.  Both of the ATPs are specified first and foremost for hockey.  The first is water-based and is exclusively for hockey, the second is sand-based.  A sand-based ATP is not suitable for football.   It is not sufficiently cushioned, leading to trauma and abrasion injuries, and is therefore a hazardous environment which would almost certainly contradict this club's health & safety and PL insurance obligations.  Invicta further understands that such surfaces are not encompassed by FIFA standards to which this club is bound by its FA charter status.  The second ATP is therefore of no prospective value to Invicta and its senior and youth teams other than for non-competitive training sessions for which we might just as well use an empty car park.  The Consultants framing the planning application will know very well how unsuited to football are both of the proposed ATPs, and it is disgraceful that as purported experts they have attempted to present otherwise.

In mentioning Invicta and its youth section these introductory comments are both mischievous in implying that we are two clubs rather than one; and they are deceptive in inferring that Invicta has somehow been integral to the planning process when in truth it has been arbitrarily excluded.

2.  Tennis Courts.

One of the reasons the football club has been so anxious to establish a strategic dialogue with SDC has been that we saw in the public consultation presentation last year that the strip of ground running between the Grammar School and the football club had been earmarked for the renewal of outdoor tennis facilities.  Invicta's view was then, and it remains, that of all the space that is now being reorganised within the Polo Ground plan, this was the single most critical area to which the Club and the school could reasonably stake a claim.

This implies no intent on our part to disadvantage tennis. We established contact in November with the CIC tennis club which makes use of the present ill-maintained courts, and it was telling that they were not even aware that their sport featured in the de Haan Foundation's plans.  The fact that their club currently has only six members is not a reason to discount it, more it underlines how far another mainstream national sport has been allowed to decline because of the lack of investment in facilities in Folkestone.  We see in the planning application no recognition of tennis as an entity, it seems to be provided for more as an afterthought, and to deny development space to others.  Think of it in year round all-weather terms.  What intensity of use will be achieved by developing a space equivalent to nearly two football pitches exclusively for tennis?

Invicta's view is that tennis, like perhaps basketball, volleyball and other court-based outdoor sports should be bracketed with junior and five-a-side football and served by a multiple sports surface with a versatile barrier and marking solution developed down that strip of land so that it serves a wide range of clubs and sports which are presently suppressed by a lack of facilities.  Such an imaginative approach would surely attract local patronage and external funding (not least from the LTA) without any dependency on the de Haan Foundation's selective patronage.  It should be excluded from the current Polo Ground plan and addressed separately by those of us who have the wider community interest at heart.

We should also point out that at the Cheriton Road end of the land in question, low-level lighting was installed some time ago with the aid of the Football Foundation so that the area could be used for junior soccer.   It has not been used for grass-court tennis for more than a generation, and for all Invicta's genuine good intention towards tennis it will vigorously contest any moves to reappropriate that piece of land. 

3.  Mini Soccer Pitches

The originators of the planning application are of course consultants who are accomplished at exaggerating what they need to get across and glossing over that which they would wish to conceal.  There is plenty of the latter in the planning documentation.  The term MUGA is widely used as though to represent some wondrous new-world sports surface that we should all be impressed by.  Let no-one be deceived by that term.  The mini soccer pitches juxtaposed to the lower side of the ATPs are nothing more than plan-delineated areas of plain turf, and in winters that are anything like this one they will stand idle for months on end.  These proposals represent nothing that is not already in place, and they carry with them no undertakings as to preparation, maintenance, availability, control, accountability or cost.  

4.  Changing Facilities

In paying such comprehensive lip service to the requirements of the football community, the planning case fails altogether to address the need for dedicated “dirty sport” changing facilities.  It is a fundamental planning omission which underscores the extent to which football is nothing more to this proposal's originators than an incidental to be discouraged and neglected.

5.  Managing Body

In Section 17 of the Design and Access Statement, the following text is offered to introduce the concept of a Managing Body:

“The intention is to create a new charitable body, CRSG Trust, formed with members of the Hockey and Cricket Clubs who will lease the land at Cheriton Road from Shepway District Council .  This body will develop the new facilities and operate them on behalf of the local sporting community.  It will be a not-for-profit organisation meaning revenue generated will be used to maintain and improve the facilities ensuring their availability for future generations.  Please refer to Clubs' management plans.”

This begs some very far-reaching questions.

First, interpreted literally this passage states that the land in question will be leased to the hockey and cricket clubs.  Is that so, or does this wording intentionally disguise the council's pre-determined intention to lease it to the de Haan Foundation?  And has Kent County Council been consulted relative to the critical needs of the Harvey Grammar School?

Whatever, my Club will vigorously oppose any land that is primarily dedicated to football (plus the strip between Invicta and HGS) being leased to any entity which does not integrate Folkestone's community football interest and accept due and proportionate football representation within itself.

Secondly, it is breathtaking in its insincerity for this passage to speak of acting on behalf of the local sporting community when the applicant has acted so brazenly in its selective promotion of one sport over another.  No Council in its right mind will allow that to happen and once again it will be fiercely resisted by this Club.

Thirdly, the generalised assertions to the effect that the Hockey and Cricket Clubs will effectively control the Polo Ground through this supposed not-for-profit shell is absurdly naïve in its convenient supposition that this would see other sports being treated equitably.  Any individual sport put in that position would be bound to prioritise its own interests above others and this is a certain recipe for feudal relationships between clubs and sports.  And anyone who thinks the not-for-profit label somehow excludes scope for money to be wasted or misappropriated should reflect further.  Such organisations have a way of getting very bloated.  We will absolutely not accept it.

Finally and perhaps most tellingly of all, Folkestone Invicta believes that the Hockey and Cricket Clubs themselves do not want to be used as a means of inflicting disadvantage on Invicta and the wider community football interest.  Many if not all of us in sport share interest and commitment across these artificially induced boundaries.  Plenty of the Optimists and cricketers play or watch football and have youngsters in our youth section.  And many of us in the Invicta camp are correspondingly involved in and supportive of hockey and cricket.  None of us wants to be in a position where we have administrative dominance over the other(s). 

Invicta's position, and it will not change, is that we want to see the proposed improvements for hockey and cricket go ahead .  They are marvellous for those sports and for the town, and that is good enough for us.  But none of us, Hockey and Cricket Clubs included, wants to be any part of a divisive and dictatorial wider administration.  Those Clubs want the planning lines to stop at the edge of their new facilities and so do we.  It is for SDC to talk to Invicta and the Grammar School about the rest of the site, and for all of us to work constructively with FA, LTA, UKA, Sport England etc to engineer just as attractive and achievable a plan on the Cherry Garden Avenue side and at the bottom end of the Polo Ground for football, athletics, tennis and other sports.  We do not need the de Haan Foundation's involvement in that.

6.  Claims as to Benefit to Folkestone Invicta .

A further extract from Section 17:

“The present proposals have been developed independently of the football club but they will benefit by them.  The new facilities will be available for hire by the club and with the addition of an extra artificial pitch, football will enjoy a greater availability of pitch time use.  The proposed increase in car parking will also be of obvious benefit to them.”

The planning proposals have indeed been developed independently, to the extreme that there has been no communication or consultation with this Club at all aside from a scurrilous endeavour by the engaged consultant to obtain privileged information on youth section activity with a view to detaching the Invicta youth section from its parent club, and in order to attract Football Foundation funding for the now-abandoned inclusion in the Polo Ground plan of third-generation football pitches.  As already explained, Invicta and its 300+ youngsters and disability footballers will gain absolutely nothing from the final proposals.  The second artificial pitch is unsuited to football and anyway will be primarily dedicated to hockey.  And suggestions about improved car parking are so clearly contrived to decorate a spurious argument as to be absurd.

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Football is the nation's first sport and that which is of most inspiration to our community at all levels and especially to our youth citizens.  Invicta already provides an outlet for 300+ youngsters and disabled people to play the sport, develop their skills and learn the benefits of teamwork and commitment.  That number only scratches the surface of latent demand in Folkestone, and of course there are then all of the other clubs in the area who are similarly hamstrung by a lack of facilities.  And they are all supported by an army of coaches, helpers and sponsors who together represent a beacon of light in the social gloom.  They give everything and, unlike the force behind the Polo Ground proposal, they take nothing .  It is high time the District Council championed them instead of leaving them marginalised.

This Club is striving proactively to contribute meaningfully to wider interests in the community.  To actively support health promotion by facilitating participation in sport and promoting exercise; to providing facilities which encourage youngsters to get in off the streets and reverse the depressing social decline; to play our part in redressing Folkestone's pockets of acute disadvantage ; to offer facilities that salvage and enable young offenders and uneducated/unemployed young people; to participate actively in government funded initiatives like the Modern Apprenticeship scheme; and to make Folkestone a more attractive place, period.  We are not just talking about this, we are doing it, and to so many of these people football is their one common and unifying interest.

Between us, all of the youth-level, amateur and representative footballers in Folkestone need at least two dedicated third-generation football pitches to satisfy current demand, and it is vital that the football community - including the schools - is supported proactively by the Council to make that a reality.  Invicta is prepared to give it leadership and to collaborate with anyone and everyone properly committed to a partnership endeavour, but such ambition must be in command of its own destiny.  That is why SDC must resist the Polo Ground plan in its present form and confine the planning footprint strictly to the space needed so that the developments for hockey, cricket and netball can go ahead.