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Hillingdon Planning Committee – 21st April 2026
PART 1 – Members, Public & Press
Report of the Head of Development Management and Building Control
Committee Report – Application Report
Case Officer: Michael Briginshaw 2382/APP/2023/2906
Date Application
Valid:
14.11.2023 Statutory / Agreed
Determination
Deadline:
30.04.2026
Application
Type:
Full Ward: Ickenham &
South Harefield
Applicant: Hillingdon Council Capital Programme Works Service
Site Address: Broadwater Lake, Moorhall Road, Harefield
Proposal
(Summarised):
Redevelopment of the site to create the Hillingdon
Watersports Facility and Activity Centre including
demolition of existing Broadwater Lake Sailing Club
(BSC) clubhouse at the north of the lake and erection
of a building including changing facilities, meeting
rooms, storage, Workshop and seasonal worker
accommodation (sui generis), activity shelters;
installation of pontoons and slipways; boat shed;
equipment storage huts; boat parking and racking
areas; camping area; outdoor activity areas;
ecological enhancement throughout the site; new
pedestrian routes through the peninsula;
landscaping including new woodland, dense
vegetation screens and boundary treatment; access
road; localised dredging and land reclamation;
relocation of existing sailing area and creation of
floating reedbeds within the lake; coach drop off and
turning area; vehicle parking; cycle parking; and
associated works.
Summary of
Recommendation:
GRANT planning permission subject to section 106
legal agreement and conditions
Reason Reported
to Committee:
Required under Part 1 of the Planning Scheme of
Delegation (Major application recommended for
approval)
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Summary of Recommendation:
GRANT planning permission subject to the completion of a
satisfactory section 106 legal agreement to secure the heads of
terms set out below, and subject to the conditions as set out in
Appendix 1.
Mayor of London Stage 2 Referral & S106 Legal Agreement Heads of Terms
It is recommended that delegated powers be given to the Director of Planning
and Sustainable Growth to grant planning permission subject to the following:
A) That the application be referred to the Mayor under Article 5 of the Town
and Country Planning (Mayor of London) Order 2008.
B) That the application be referred to the Secretary of State under Article 12
of the Town and Country Planning (Consultation) (England) Direction 2024.
C) That the Council enter into a legal agreement with the Applicant under
Section 106 of the Town and Country Planning Act 1990 (as amended) or any
other legislation to secure the following:
i. Community Centre Delivery Plan: Planning obligation to prevent any
development (including demolition) at the site until the Hillingdon
Outdoor Activity Centre (HOAC) and Broadwater Sailing Club have
entered into a lease for long term occupation of the development.
ii. Healthy Streets/Active Travel Zone Contribution: A financial
contribution of £177,800 for health y streets and active travel zone
measures.
iii. Carbon Offset Contribution: A fi nancial contribution of £42,821. The
obligation shall include monitoring measures (be seen).
iv. Section 278 Agreement: A Section 278 agreement to implement the
highways works on Moorhall Road.
v. Employment Strategy and Training Scheme: A financial contribution of
£66,736 towards the delivery of an Employment Strategy and Training
Scheme, secured in accordance with the Council 's Planning
Obligations SPD.
vi. Project Management & Monitoring Fee: A Project Management and
Monitoring Fee, equalling 5% of th e total financial contributions to be
paid under this agreement.
D) That in respect of the application fo r planning permission, the Applicant
meets the Council's reasonable cost s in preparation of the Se ction 106
Agreement and any abortive work as a result of the agreement not being
completed.
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E) That officers be authorised to negotiate and agree the detailed terms of
the proposed agreement and conditions of approval and agree any changes
requested by the Greater London Authority.
F) That, if the Legal Agreement has not been finalised within 6 months (or
such other time frame as may be agreed by the Director of Planning and
Sustainable Growth), delegated authority be given to the Director of Planning
and Sustainable Growth to refuse planning per mission for th e following
reason:
'The Applicant has failed to mitigate the impacts posed by the proposed
development (in respect of the Carbon Emissions, Highways Safety, and
Employment). The scheme therefore conflicts with Policies DMCI 7 of the
Hillingdon Local Plan: Part 2 (2020) ; the adopted Planning Obligations
Supplementary Planning Document (2014); Policy DF1 of the London Plan
(2021); and paragraphs
56-58 of the National Planning Policy Framework
(2024).'
G) That if the application is approved, that the permission is subject to the
Conditions as set out in Appendix 1.
1 Executive Summary
1.1 The former Hillingdon Outdoor Activity Centre (HOAC) site located on land owned
by Hillingdon Council, at Dews Lane in South Harefield, sits on the direct route of
the High Speed Two (HS2) Phase One train line connecting London and
Birmingham. As the new line passes directly through the HOAC site, it has been
subject to a Compulsory Purchase Order and has been closed since October
2020. Construction of the Colne Valley Viaduct required permanent safety buffer
zones and ongoing HS2 access and maintenance rights through the site, while
the viaduct itself makes the lake unsuit able for sailing, meaning that even after
construction
, the land and waterbody cannot function as an outdoor activity centre.
Following a considered site selection process, Broadwater Lake was identified as
the location for a replacement facility.
1.2 At the national level, Broadwater Lake was notified as part of the Mid Colne Valley
Site of Special Scientific Interest (SS SI) under the Wildlife and Countryside Act
(1981) in 1985. The site forms part of a functional flood plain and is designated as
part of Flood Zones 2 and 3 by the Environment Agency (EA). At the local level,
the site is designated under the Hillingdon Local Plan as Green Belt land.
1.3 The planning application proposes redevelopment of the site to create the
Hillingdon Watersports Facility and Activity Centre, providing a replacement for
the former Hillingdon Outdoor Activity Centre (HOAC), previously owned by
Hillingdon Council and operated by the Colne Valley Youth & Community
Association to support outdoor and environmental education for young people,
particularly those who are disadvantaged or disabled. The scheme includes
demolition of the existing Broadwater Lak e Sailing Club clubhouse, construction
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of new operational, safety and camp facili ties with accessible amenities, activity
and support spaces and seasonal accommodation, installation of pontoons and
slipways, camping and outdoor activity areas, new access routes, parking and
coach facilities, and the relocation of the sa iling club to the south of the lake. It
also delivers landscaping, woodland planting, ecological enhancements including
floating reedbeds, safeguarded ecological land, and localised dredging and land
reclamation.
1.4 Since the planning application was first submitted in October 2023, statutory
consultees have provided comments, and the scheme has been redesigned in
response. The development has been reduced in size, and all technical
documents have been updated. The site boundary remains substantially the
same, and the overall principle of develo pment is consistent with the earlier
scheme.
1.5 Hillingdon Council (the Applicant) undertook a comprehensive review of 71 lakes
within a 20 Ǧkilometre radius of the former HO AC site to identify a deliverable
location for the replacement outdoor activi ty and water sports facility. This
assessment applied criteria, including lake size and depth, land availability,
accessibility for schools and vulnerable us ers, environmental constraints, site
security, and financial viability. Five si tes were shortlisted, including Broadwater
Lake, Ruislip Lido, Bury Lake, Aldenham Reservoir and Denham Quarry. The
evaluation concluded that Broadwater Lake is the only site capable of
accommodating the full range of required land and water
Ǧbased activities,
providing suitable sailing conditions, of fering safe and secure access, and being
deliverable within the £26.5 million HS2 funding agreement. All other sites were
discounted due to constraints such as inadequate lake depth, public access that
could not be secured, insufficient land, environmental designations, poor access,
incompatible existing uses, or costs far exceeding the approved budget. The
Alternative Sites Assessment concludes that no other reasonable or available
alternative site exists, and that Broadwater Lake is the only viable and appropriate
location for the proposed facility. Office rs agree with the overall conclusion and
can therefore confirm that the harm posed to the SSSI cannot be avoided entirely,
although it is proposed to be avoided to a degree, mitigated and compensated for.
1.6 Alongside the National Planning Policy Framework (NPPF) (2024), local and
regional planning policies require planning decisions to apply the biodiversity
mitigation hierarchy, refuse developm ent where significant harm cannot be
avoided, mitigated or compensated, and generally resist development affecting
Sites
of Special Scientific Interest (SSSIs) unless the benefits clearly outweigh
both siteǦspecific and wider network impacts, while also supporting schemes that
conserve or enhance biodiversity. Although the proposal lies within the Mid Colne
Valley SSSI and would result in some harm, it has been designed to be
ecologically and environmentally sensitive, following the mitigation hierarchy in
full. Harm is avoided where possible by locating development on areas of existing
hardstanding and concentrating activity within the less sensitive south
Ǧeast of the
site, alongside a significant expansion of the quiet Ǧwater refuge from
approximately 3.42 ha to approximately 14.72 ha secured through buoyed noǦsail
limits. Harm is further mitigated through targeted access control and screening,
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directional low Ǧspill lighting, seasonal island vegetation management, and
localised dredging limited to achieving safe sailing depths. Where impacts cannot
be fully avoided or mitigated, compensation and enhancement measures are
secured through re Ǧprofiling Island 02 to create two sheltered bays, removal of
Island 07 to open the Eastern Channel, knotweed eradication on Island 06,
wetǦwoodland infill along disused tracks, native grassland, scrub and tree planting
(including reptile and invertebrate earth mounds), a new wildlife pond and sensory
garden, tern rafts, bird and duck boxes, and underwater willow planters to define
refuge edges while preserving sightlines. These measures are secured through
conditions requiring a Mitigation, Enha ncement & Management Plan (Condition
15), an Operational Management and Activities Plan (Condition 41), and a
Monitoring, Reporting & Adaptive Management Plan (Condition 5
5), ensuring
ongoing management and adaptive monitoring for the lifetime of the development
in agreement with statutory stakeholders. Taken together, the scheme delivers a
net ecological benefit, improves the long Ǧterm management of the SSSI,
enhances inclusive access to nature, and provides significant social, educational
and community benefits which clearly outweigh the identified harms, in
accordance with the Development Plan.
1.7 It is important to compare the impacts of the proposed scheme to the “Do Nothing”
scenario. If no development is undertaken, the former HOAC site will remain
permanently closed with no viable replacement facility. This would result in the
continued loss of
outdoor activity provision for schools, Special educational needs
(SEN) groups, PRUs, community clubs a nd families. The Broadwater Lake Site,
part of the Mid Colne Valley SSSI, would also remain in an “unfavourable
condition” (as confirmed by Natural England) without any management plan,
meaning no biodiversity enhancements, habitat restoration, or ecological
mitigation would occur, and existing issues such as invasive species and
degraded habitat would persist. In this scenario, no improvements to accessibility,
safety, landscape quality, flood resili ence or community infrastructure would be
delivered, and the significant social, educational and environmental benefits
associated with the proposed development would not be realised.
1.8 The site is designated as Green Belt land and would not constitute Grey Belt. By
virtue of the associated planning poli cy definitions, the development would
constitute inappropriate development wi thin the Green Belt. Accordingly, Very
Special Circumstances are required and will not exist unless the potential harm to
the Green Belt by reason of inappropriateness, and any other harm resulting from
the proposal, is clearly outweighed by ot her considerations. As explained within
the main body of the Committee Report, the development is considered to have
significant social , community and public benefits, including economic and
environmental benefits. More specifically, the proposal reinstates a much Ǧvalued
facility used by schools, colleges, SEN gr oups, scouts, guides, cadets, families,
Broadwater Sailing Club, and local emergency services. It provides year Ǧround,
accessible land and water Ǧbased activities, tailored support for disabled users,
and dedicated provision for Pupil Referral Units (PRU) students and vulnerable
young people. Evidence from Natural England, Defra and educational bodies
demonstrates significant mental Ǧhealth, physical Ǧhealth, behavioural and
educational benefits derived from outdoor learning and nature Ǧbased activity, all
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of which the new facility is designed to maximise. It is therefore concluded that the
harm to the Green Belt, and all other harms posed, are clearly outweighed by the
benefits and as such, Very Special Circumstances are deemed to exist.
1.9 In terms of townscape and landscape visual impact, it is assessed and considered
that the proposal would not significant ly alter the skyline as perceived from
surrounding areas. From a visual persp ective, views of the development are
contained, in the main, within the site itself. The design and elevational treatments
are considered to be of sufficient high quality which soften its impact on the setting
of the SSSI and Green Belt. Subject to se curing further details by condition, the
proposal is supported from a design perspective.
1.10 Planning obligations are proposed to be secured to ensure that the development
is acceptable. Significantly, it is pr oposed that no development, including
demolition, at the site shall occur unt il HOAC and Broadwater Sailing Club have
entered a long term lease for occupation of the development. This is proposed to
ensure that this specific site is, with out doubt, required to replace the former
HOAC facility, as set out within the Alternative Sites Assessment. It also ensures
that
significant community and s ocial benefits are realised because of the
development, and that existing community groups are not disadvantaged as a
result of the development, namely HOAC and Broadwater Sailing Club.
1.11 Planning obligations are also proposed to secure net zero-carbon compliance,
encourage more sustainable forms of transport through delivery of active travel
zone measures and highways works, and deliver an employment and construction
training scheme.
1.12 Subject to the planning conditions and obligations recommended, the proposed
development is considered acceptable in principle and with respect to design,
heritage, residential amenity, environmental issues, transport, and sustainability.
1.13 Due regard has been given to the comments received as part of the consultation
process and it is concluded that the proposal complies with the Development Plan.
Section 38(6) of the Planning and Compulsory Purchase Act 2004 states that
planning applications should be determined in accordance with the development
plan unless material considerations indica te otherwise. For the reasons outlined
above and within the main body of the repo rt, this application is considered to
comply with the Development Plan and is recommended for approval, subject to
securing the planning conditions set out in Appendix 1, securing the necessary
planning obligations via an appropriate leg al agreement, Stage 2 referral to the
Greater London Authority and referral to the Secretary of State.
2 The Site and Locality
2.1 The former Hillingdon Outdoor Activity Centre (HOAC) site is located at Dews
Lane in South Harefield, on a 22.2 ha site owned by Hillingdon Council. HOAC's
location at Dews Lane, sits on the direct route of the High Speed Two (HS2) Phase
One train line connecting London and Birmingham. As the new line passes directly
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through the HOAC site, the land has been subject to a Compulsory Purchase
Order and has been closed since October 2020. To date HS2 have permitted a
decommissioned HOAC to remain at Dews Lane.
2.2 The HS2 route crosses the Mid Colne Valley Site of Special Scientific Interest
(SSSI) to the west of the lake, on a viaduct bisecting the Herts and Middlesex
Wildlife Trust's managed Broadwater Lake Nature Reserve.
Figure 1: View of Broadwater Lake from the Old Orchard Public House
2.3 Broadwater Lake (as shown in Figure 1 abov e) is the subject of this application
and comprises a large area of land and water. The site forms part of the Colne
Valley Regional Park, the Mid Colne Valley SSSI, the Denham Quarry and Pits
Nature Conservation Site of Metropolitan Grade Importance (SINC) and Colne
Valley Archaeological Priority Zone. The site also forms part of designated Green
Belt land, a functional flood plain and Flood Zones 2 and 3.
2.4 There are a small number of residential properties located along the existing
access to the site, which connects to Moor hall Road to the south. Further afield,
neighbouring residents are located in South Harefield to the east (40m away at
the closest point) and Denham Garden Village to the West (300m away at the
closest point). The south
-east corner of the site is made up of secondary
woodland, beyond which is the Widewater Lock Conservation Area which
encompasses part of the Grand Union Can al, Moorhall Road, the Widewater
Place Business Park, Harefield Marina and the River Garden Public House. Only
a small stretch of Moorhall Road forms part of the red line site boundary and would
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form part of the Conservation Area designation. The Grand Union Canal runs
north/south to the east of the site and is designated as part of a SINC. The Public
Transport Accessibility Level (PTAL) is very low and sits between 0 and 1b.
2.5 The site is located on the western bo undary of Hillingdon Borough, adjoining
Buckinghamshire district to the west and Th ree Rivers District Cou ncil district to
the north.
Figure 2: Location Plan (application site edged red)
2.6 More specifically, the site subject to the application measures circa 80 hectares in
area and comprises a waterbody and two main land parcels, these being
Broadwater Lake, the peninsula to the south of the lake and land to the north of
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the lake occupied by Broadwater Sailing Club, located in South Harefield within
the north of Hillingdon borough. Whilst these locations are where the main
elements of development would be located, two secondary land parcels also form
part of the site and are to be safeguarded as ecological sites, located off Moorhall
Road to the south and Broadwater Lane to the east. Please refer to Figure 2 above
which shows the site location plan and defines the application boundary.
3 Proposal
Figure 3: Operations Zone Entrance - Visualisation (please note – a larger
version of the visualisation can be found on document ref. 1329-HAV-Z1-ZZ-DR-
A-S2-2311 P01)
3.1 This planning application seeks permission for redevelopment of the site to create
the Hillingdon Watersports Facility and Activity Centre. This includes:
x Demolition of the existing Broadwater Lake Sailing Club clubhouse.
x Construction of new buildings, including:
o Operations Zone building
Changing rooms, WCs, showers, and accessible provisions
Accessible camping and support room
Ancillary reception space, office space and training rooms
Observation deck
Seasonal worker accommodation (sui generis)
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o Safety Zone building
Workshop and repairs area
Safety equipment store and boat store
Secure yard
Energy centre and plant room
Transformer and switch rooms
o Camp zone building
Changing rooms, including accessible provisions
Food preparation area
Activity shelter
o Two Angler’s Huts (one to the north and one to the south of the lake)
Equipment and hand wash facilities
Tea point
Accessible WC
Store
x Installation of pontoons and slipways.
x Provision of camping areas and outdoor activity zones.
x Ecological enhancements across the site, including north of the lake in
place of the Broadwater Sailing Club and including floating reedbeds.
x Safeguarding of land for ecology:
o Land off Moorhall Road: Safeguarded ecological site measuring
circa 1ha
o Land off Broadwater Lane: Safeguarded ecological site measuring
circa 0.8ha
x New pedestrian routes through the peninsula.
x Landscaping: new woodland, dense ve getation screening, and boundary
treatments.
x Construction of an access road.
x Localised dredging and land reclamation.
x Relocation of the existing Broadwater Sailing Club from north of the lake to
the south.
x Coach drop-off and turning area.
x Vehicle parking and cycle parking.
3.2 Please see Figure 4 overleaf which shows the overall site plan for the proposals.
This shows the concentration of physical development on existing hardstanding
within the southern peninsula and removal of the Broadwater Sailing Club
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buildings from the north of the lake. Within the lake, Island 02 is proposed to be
re-profiled to create two sheltered bays, Island 07 is proposed to be removed to
open the Eastern Channel, and knotweed is to be eradicated on Island 06.
Proposals also incl ude wet Ǧwoodland infill on disused tracks, native
grassland/scrub/tree planting (including reptile / invertebrate earth mounds), a
new wildlife pond and sensory garden, tern rafts, bird/duck boxes, and underwater
willow planters to define refuge edges while preserving sightlines.
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Figure 4: Proposed Ecological Mitigation and Enhancement Plan (please
note – a larger version of the plan can be found in the Committee Plan Pack)
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Proposed Activities and User Groups:
3.3 As a replacement facility is required, the proposed development will support the
following water based activities, all of which formed part of the operation at the
former HOAC facility:
x Maintaining existing Broadwater Sailing Club uses;
x Dinghy sailing;
x Kayaking/canoeing;
x Two dragon boats;
x Stand up Paddleboarding;
x Raft building and use;
x Windsurfing; and
x Angling (this is also an existing use).
3.4 The proposed development will also support the following land based activities,
all of which formed part of the operation of the former HOAC facility:
x Indoor fencing (in the Main Building);
x Activity shelter for outdoor team building activities;
x Bird watching;
x Camping; tents, sheltered camping (for disabled children / adults,
underneath shelter on hard surface near to toilet facilities) and indoor
camping (for disabled children / adults inside Main Building);
x Orchard and foraging;
x Pond dipping;
x Artificial above-ground caving system; and
x Environment training and educat ion including bird watching.
3.5 The proposed development will provid e land and water based activities and
overnight accommodation facilities for a di verse range of user groups, but it will
predominately serve children and young people. The proposed user groups are
set out in Table 1 below.
Table 1. Proposed User Groups
User Group Description of Needs
Schools School groups, including children aged six and above
with a wide range of physical, mental, social and
educational needs, will use the facility for day visits and
overnight stays. Because many groups are first
Ǧtime
visitors and may vary in size, age, ability, gender and
religion, the site must be simple to navigate, while
smaller PRU and SEN groups may use the facility more
regularly.
Guides and Scouts Guide and scout groups will use the facility, often in
large numbers of up to 120 children, plus 12 adults, at
one time. They may visit the facility for the day or for
overnight stays. Their gender and age split may be
mixed or one-sided.
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Cadets Sea cadets include children aged 10 and above and
army and air cadets include children aged 12 and
above.
Children, young
people and adults
with additional
needs
Children, young people and adults with additional
needs, including those with autism, multiple learning
disabilities and / or physical impairments will use the
facility. These users need to be able to use all the
same facilities as the peers with no disability.
Families Families will require frequent access and use of the
facility throughout the year. Children may be
accompanied by their parents or guardians who could
have other children with them of different ages.
Families will need to have the ability to change
together, and consideration should be given to how the
changing rooms are accessible and comfortable for
different needs.
Ecologists The proposed developments should have the option to
operate as a Field Study Centre as part of the Field
Studies Council national offering. This will allow those
training as ecologists to study together.
Permanent
Staff
Staff will be hired, so the facility should be an exemplar
workplace in line with the employment law under the
Equality Act 2010.
Seasonal
live-in staff
/ those in
training
Seasonal, overnight staff will form a large part of the
operational staff at the proposed development during
peak times. These positions are often taken up by
young people training to become professional activity
instructors. Staff will require basic accom
modation,
access to food preparation, private living space and
their own shower facilities. Some of these users may
be aged 16, where safeguarding will have to be
considered.
Broadwater
Sailing
Club (BSC)
Members
Formed in 1972, BSC is an inland sailing club which
supports those who enjoy sailing, from young people
learning the basics in Optimist and Topper boats, to
experienced sailors. The club has approximately 240
family and junior members who use the lake for club
sailing on a Wednesday and Sunday (in the evening in
the summer months and the mornings in the winter
months). Sailing
regattas are held on Sundays
throughout the year and an additional six are held on
various Saturdays.
Anglers Anglers are identified as a planned and managed user
group with a defined need for controlled access to
Broadwater Lake to undertake recreational fishing
within a regulated framework.
Angling is a permitted
waterǦbased activity and provides for it in specific,
limited locations along the northǦeastern and eastern
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shores of the lake and within the lagoon, reflecting the
need for shoreline access while protecting sensitive
habitats and bird refuge areas. Anglers’ use is intended
to be subject to clear rules, a defined code of conduct,
and a dedicated angling biosecurity regime, ensuring
that fishing activity is accommodated in a way that is
compatible with statutory SSSI duties, lake
management objectives and the overall operational
management of the site.
Proposed Operation:
3.6 The proposed Hillingdon Watersports Facility and Activity Centre is centred
around the Operations Zone building and Safety Zone building , supported by an
ancillary activity shelter and angler huts. The Operations Zone building functions
as the operational hub of the site and accommodates reception, administration,
changing facilities, equipment storage, training and education spaces, welfare
facilities, and limited seasonal accomm odation for staff only. The sleeping
accommodati
on is strictly for seasonal staff during the months of April to
September each year and is integral to ensuring effective site supervision,
safeguarding, and early Ǧmorning operational readiness. I t is not visitor
accommodation and is not available for hire or general overnight stays.
3.7 The site operates on a clearly defined and restricted basis. Land and waterǦbased
activities are limited to the period 1st April to 31st September, with activities taking
place between 10:00 and 15:00, seven days a week. Staff may be present on site
between 08:30 and 17:30 to allow for preparation, supervision and site
management. Overnight use is tightly controlled . Camping is permitted only on
Friday and Saturday nights and is limited to supervised youth and educational
use, with defined maximum numbers and designated camping areas. The
accommodation within the
Operations Zone building for disabled users (indoor or
sheltered camping) is ancillary to the functional operation of the centre and is not
used independently of supervised activity programmes.
3.8 Operational management is governed by a detailed Operational Management
Plan proposed to be secured by planning condi tion. This includes a robust code
of conduct, defined activity zones, strict controls over noise, lighting, access to the
lake and shoreline, safeguarding protocols, flood risk procedures, biosecurity
measures, and pollution prevention. All users must sign in and out at the
Operations Zone building, access is controlled by staff, and unauthorised
activities
, including amplified music, firewor ks, drones, or unsupervised access,
are expressly prohibited. The Operational Management Plan also establishes an
adaptive management framework, overseen by a Site Manager and an advisory
group involving statutory bodies, enabling operational practices to be reviewed
and adjusted in response to monitoring or any emerging issues.
3.9 Importantly, the Operational Management Plan does not permit the unrestricted
hiring out of facilities for events. Any future use of the buildings for group activities
must remain consistent with the defined ope rational parameters, activity types,
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hours of use and environmental protections. The buildings are intended to support
structured outdoor education, water spor ts, and community activity only. Any
departure from this, including commercial events, late Ǧnight use, or intensified
hire, is not permitted and would require separate planning permission.
Acceptance of Amendments:
3.10 Legal advice was sought regarding whether the proposed changes to the planning
application can be treated as amendments or whether it would require a new
planning application. The key legal test, drawn from R (British
Telecommunications plc) v Gloucester City Council [2002] 2 P&CR 33 and
confirmed in R (Holborn Studios) v Hackn ey LBC [2018] PTSR 997, is whether
the changes are so substantial that the development is no longer, in substance,
what was originally applied for. This is a matter of planning judgment for the Local
Planning Authority, subject to review only on grounds of unreasonableness. Case
law demonstrates that even significan t amendments can lawfully be accepted,
provided this substantive threshold is not crossed and procedural fairness is
maint
ained. If amendments are pursued, adequate re-consultation will be required
to protect third-party rights, but this is not in itself a barrier. As explained within the
main body of the report, and the application is materially similar in substance, and
the proposed changes are not inherently impermissible, meaning that
amendments were accepted and re -consulted on. Please see Section 6 of the
report which sets out relevant detail on the consultation process.
3.11 The document titled ‘Table Comparison of Original and Revised Development’
helpfully summarises the differences between the original 2023 application
submission and the amended 2025 application submission. In summary, the
revised scheme is significantly reduced in scale and intensity, with reduction in
land reclamation, dredging, building footprint, parking, boat storage, and water
activity areas.
3.12 Specifically, the revised Description of Development removes explicit reference to
HOAC and BSC occupying the new develo pment in order to follow planning
application best practice, rather than to preclude those user groups from
occupying the development.
The proposed activity range has been consolidated
and outdoor structures and land reclamation have been substantially reduced.
The two iterations of the scheme are compared by their built development features
and operational characteristics in Tables 2 and 3 below.
Table 2. Comparison of Built Development by Scheme Iteration
Built Development Original Scheme (2023) Revised Scheme (2025)
Total Floorspace (GIA) 4,274 m² 3,474 m²
Total Floorspace
(GEA)
4,644 m² 3,844 m²
Max Building Height 10.98 m ridge 10.5 m ridge
Activity Shelters 7 1
Angler’s Hut 1 2
Dredging 47,356 m² 7,094 m²
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Land Reclamation 16,114 m² 2,884 m²
Sailing Area 33.3 ha 29.46 ha
Water Activity Zones Shared multiǦuse zone Eastern channel only
Undisturbed Water 3.42 ha 14.72 ha
Peninsula Extension 16,151 m² 2,892 m²
Island Removal 2 islands (2,187 m²) 3 islands (3,608 m²)
New Islands Created 8 islands (4,308 m²) 0 islands
Net Increase in Open
Water
0 716 m²
Floating Reedbeds 0 800 m²
Beach Launch Area 324 m² 382 m²
Car Parking Total 83 50
Standard Parking 62 36
Blue Badge Car 5 6
EV Active 4 6
EV Passive 4 0
Blue Badge Minibus 3 2
Brown Badge 3 0
Coach Spaces 2 0
Cycle Parking 42 42
Boat Parking 425 260
Table 3. Comparison of Operation by Scheme Iteration
Operation Original Scheme (2023) Revised Scheme (2025)
Land-Based Activities Fencing, archery, pedal
karting, caving, big swing,
high/low ropes
No pedal karting; new
indoor/sheltered
camping; revised activity
mix
Water-Based Activities Sailing, kayaking,
canoeing, rowing, stand
up paddleboarding,
dragon boating, raft
building, windsurfing
Activities relocated to
eastern channel,
including dinghy sailing,
kayaking / canoeing,
stand
Ǧup paddleboarding,
dragon boating, raft
building, windsurfing, and
angling
Maximum No. Users 200 children + 20 adults 120 children + 12 adults
OnǦWater Users Up to 100 children 72 children + 8 adults
Sailing Use – Peak 12 children + 2 adults 12 children + 2 adults
Angling Children only in late
July/August
Children only in late
July/August
LandǦBased User
Assumptions
Up to 100 indoor Peak 60 children + 6
adults
Ecology/Education
Users
Not specified Included within total
users
Camping 25–50 children 25–50 children (Fri–Sun)
Staffing 8 permanent, 14
seasonal, 10 volunteers
6 permanent, 14
seasonal, 10 volunteers
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Opening Months Apr–Sept (HOAC); BSC
all year
Apr–Sept (HOAC); BSC
all year
Hours of Operation Mon–Fri 08:30–17:30; no
weekends
10:00–15:00 daily;
shorter weekday hours
but now includes
weekends
3.13 In summary, the revised 2025 scheme is smaller, more constrained, and more
environmentally moderated than the 2023 proposal. The proposals have been
amended to reduce ecological effects, operational intensity, and physical impact
on Broadwater Lake. Key c
hanges include reductions to:
x Physical footprint
x Dredging and lake modification
x User capacity
x Water activity areas
x Land Ǧbased structures and intensity
x Parking and boat storage
3.14 Furthermore, there are increased provision of:
x Undisturbed water area
x Environmental mitigation (e.g., floating reedbeds)
x Accessible / inclusive camping options
3.15 Plans are shown overleaf to demonstrate the concentration and distribution of
activity and disturbance across the southern peninsula and wider waterbody.
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3.16 Please see Figure 5 below for the land activity heat map. No access or activity is
shown in green, low noise is shown in ye llow, medium noise is shown in orange,
and frequent noise is shown in pink.
Figure 5. Land Activity Heat Map (please refer to document ref. HWSFAC-COL-
XX-XX-DR-L-6190 Rev. 11).
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3.17 Please see Figure 6 below for the water disturbance plan. Activity is concentrated
in the less sensitive southǦeast of the site and the quietǦwater refuge is expanded
from c. 3.42 ha to c. 14.72 ha with buoyed noǦsail limits.
Figure 6. Water Disturbance Plan (please refer to HWSFAC-COL-XX-XX-DR-L-
6189 Rev. 06)
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4 Relevant Planning History
4.1 Broadwater Lake was originally created through extensive sand and gravel
extraction carried out from the 1960s until the late 1990s, with the quarry formally
decommissioned in 1992. The southern peninsula functioned as a gravel washing
and processing plant containing silt lagoons, hardstanding and associated
industrial structures, remnants of which st ill remain on site to day. Following the
cessation of mineral working, the former pi ts filled with water to form the present
lake, which later became part of the Mid Colne Valley Site of Special Scientific
Interest (SSSI) and has since been used primarily for recreational activities,
including the Broadwater Sa iling Club and angling. The site is therefore shaped
by its quarrying legacy but long transitioned into a recreational and ecological
landscape.
4.2 A list of the relevant planning history related to the property can be found in
Appendix 2. In particular, the permissions referenced in Table 4 below are
highlighted.
Table 4. Summary of Planning History
Planning
Permission
Description
November 1986
Planning
permission ref.
2382/X/85/739
Granted for the retention of planning permission (ref.
02382/820098(P)). This permission allowed the
continued use of northern part of the lake for sailing.
This application was subject to 6no. conditions.
November 1986
Planning
permission ref.
2382Z/Y/86/1291
Granted for the relocation of sailing club shore facilities
involving erection of clubhouse and dinghy enclosure
with associated parking and access road at north end of
Broadwater Lake. This application was subject to 5no.
conditions.
May 1992
Planning
permission ref.
2382/AL/92/0464
The wider Broadwater Lake area had been worked for
sand and gravel extraction from the 1960s until the late
1990s, and the quarry was decommissioned in 1992.
Planning permission ref. 2382/AL/92/0464 (dated May
1992) confirms that Hillingdon Council has registered
and formally recognised the continued legal existence of
a historic 1948 Interim Development Order (IDO)
permission allowing the excavation of minerals by
surface working at Broadwater Lake Quarry, Harefield.
This registration does not allow quarry
ing or mineral
extraction to resume. Before any extraction could have
lawfully taken place, the operator was required to submit
and obtain approval for a modern scheme of planning
conditions, required under the Planning and
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Compensation Act 1991. There is no record of these
conditions being submitted for approval.
June 1993
Planning
permission ref.
2382/AK/92/0872
Granted for the renewal of planning permission ref.
2382/Y/86/739 for continued use of northern part of the
lake for sailing.
August 1999
Planning
permission ref.
2382/AM/98/2306
Granted for the erection of single storey extension to
clubhouse.
October 1999
Planning
permission ref.
2382/AN/99/0609
Granted for the renewal on a permanent basis of
planning permission ref. 2382/AK/92/0872 for continued
use of northern part of the lake for sailing.
5 Planning Policy
Development Plan
5.1 Planning law requires that applications for planning permission be determined in
accordance with the development plan, unless material considerations indicate
otherwise. The statutory development plan for the London Borough of Hillingdon
comprises the following documents:
x The Local Plan: Part 1 – Strategic Policies (adopted 2012)
x The Local Plan: Part 2 – Development Management Policies (adopted
2020)
x The Local Plan: Part 2 – Site Allocations and Designations (adopted 2020)
x The West London Waste Plan (adopted 2015)
x The London Plan (adopted 2021)
5.2 In accordance with national policy, due weight is to be given to development plan
policies according to their degree of consistency with the National Planning Policy
Framework (NPPF), with reduced weight being afforded where inconsistency is
identified, within the statutory framework established by Section 38(6) of the
Planning and Compulsory Purchase Act 2004.
Material Considerations
5.3 The NPPF (2024) is a significant material consideration in the determination of
planning applications and must be taken into account alongside the development
plan. This is particularly relevant whe re elements of the development plan are
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outǦofǦdate or inconsistent with national polic y, although national policy remains
relevant in all cases. In such circum stances, proposals are assessed having
regard to the most upǦtoǦdate national policy position, alongside all other relevant
material considerations, including supplementary planning documents and
guidance.
5.4 The NPPF (2024) provides updated national policy on Green Belt land, including
the identification of Grey Belt land and circumstances in which development may
be considered appropriate. These provisions do not alter the fundamental
purposes of the Green Belt or the substantial weight that must continue to be
afforded to Green Belt harm. The development plan remains the statutory starting
point for decision
Ǧmaking, however, where relevant local policies pre Ǧdate or do
not reflect the Grey Belt framework, the NPPF constitutes a material consideration
that informs the assessment of proposals. The statutory and national protections
afforded to Sites of Special Scientific Interest remain fully applicable and are
unaffected by the age of the development plan.
5.5 A list of planning policies relevant to t he consideration of the application can be
found in Appendix 3.
6 Consultations and Representations
6.1 As the planning application is subject to an Environmental Impact Assessment,
the consultation requirements for the application are set out under both the Town
and Country Planning (Development Management Procedure) (England) Order
2015 and the Town and Country Planning (Environmental Impact Assessment)
Regulations 2017. This requires that co nsultation is carried out for a period no
less than 30 days. For robustness of approach, Officers determined that the
application should be consulted on by letters, site notice and advertisement in the
local paper for a period exceeding 30 days to account for overlap with public
holidays. The approach is detailed in the report below.
6.2 Two formal rounds of consultation were carried out during the application process
to account for the original planning application being submitted in November 2023
and the amended application being submitted in November 2025.
6.3 During the first round of consultation, a total of 3,357 consultation notifications
were issued on 15 th November 2023. This figure includes hard- copy letters sent
to Harefield residents and emails sent to statutory and internal consultees. Site
notices were also displayed on public roads surrounding the site, and an advert
was published in the local newspaper. All forms of consultation expired on 20
th
December 2023, totalling 36 days of consultation.
6.4 During the second round of consultation, a total of 5,630 consultation notifications
were issued on 26 th November 2025. This figure includes hard- copy letters sent
to Harefield residents and emails sent to statutory consultees, internal consultees
and consultees who had previously comm ented on the application. Site notices
were also displayed on public roads surrounding the site, and an advert was
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published in the local newspaper. All forms of consultation expired on 9th January
2026, totalling 45 days of consultation.
6.5 More than 3,000 comments were received across both consultation periods, and
a comprehensive exercise was undertaken to review and categorise the
comments received. Any duplicate comments submitted were discounted to
provide an accurate representation of the number of
comments received on both
the first and second rounds of consultation. For clarity, duplicate comments were
considered and discounted as follows:
x Multiple comments submitted by the same individual were counted as one
comment. For example, 5 comments received from an individual in the
November 2023 consultation were counted as 1 comment.
x If an individual submitted one comment in the November 2023 consultation
and one comment in the November 2025 consultation, it was counted as
one comment in each consultation period.
x If comments were submitted by two individuals of the same household, it
was counted as two comments. This accounts for members of a household
that have differing views.
6.7 During the first round of consultation commencing in November 2023, a total of
578 no. comments in support and 1,092 objections were received. A petition in
objection was also received with 50 valid signatures.
6.8 During the second round of consultation commencing in November 2025, a total
of 41 no. comments in support and 484 objections were received. A petition in
objection was also received with 121 valid signatures.
6.9 During the application process, it was confirmed that a freshwater ecology survey
was omitted from the amended Environmental Statement submitted in November
2025. This related to biodiversity and water resources which are matters scoped
into the Environmental Impact Assessment. As a result, it was deemed necessary
to advertise the “further information” submitted as per Regulation 25 of the Town
and Country Planning (Environmental Impact Assessment) Regulations 2017.
The further information was advertised
in the local paper on 4 th March 2026 and
the consultation period expired on 4 th April 2026. During this period, two further
comments in objection to the scheme wer e received, expressing concern for the
impact on the environment and wildlife.
6.10 Representations received in response to the public consultation exercise are
summarised in Table 5 (below). The statutory and internal consultee responses
received are summarised in Table 6 (below). Full copies of the responses have
also separately been made available to Members.
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Table 5. Summary of Public Consultation Responses
Representations Summary of Issues
Raised
Planning Officer
Response
Comments in Support
First Consultation
(November 2023):
578 no. letters of
support received.
Second
Consultation
(November 2025):
41 no. letters of
support received.
Third
Consultation
–
Newspaper only
(March 2026):
No comments
received in
support.
Individual Comments in
Support:
The comments of support
are summarised below.
1) The development will
have social, community and
educational benefits and will
allow residents to
experience nature.
2) The former HOAC was
lost to HS2.
3) The development will
provide better facilities than
that at the former HOAC.
4) The development will be
accessible and inclusive.
5) The development will
meet the need for sport and
recreational provision.
6) The development will
benefit the health of
residents.
7) The development will be
to the benefit of
ecology/biodiversity/SSSI.
All comments raised in
support of the
development are taken
into consideration as
part of the assessment.
Please refer to
paras
7.12 to 7.51 of the report
for consideration of the
social, community and
public
benefits of the
scheme, including
ecological and economic
benefits.
Comments in Objection
First Consultation
(November 2023):
1,092 no. letters of
objection received.
Petition in
objection received
Individual Objections:
The individual objections
raised are summarised
below.
1) Harm and insufficient
mitigation of harm to
ecology/biodiversity/SSSI
All comments raised in
objection to the
development are taken
into consideration as
part of the assessment.
Each point is addressed
in turn below:
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with 50 valid
signatures.
Second
Consultation
(November 2025):
484 no. letters of
objection received.
Petition in
objection received
with 121 valid
signatures.
Third
Consultation
–
Newspaper only
(March 2026):
Two comments
received in
objection.
during construction and
operation.
2) Broadwater Lake is not
the right site for the
replacement HOAC facility.
3) The development sets the
wrong precedent of
development in a SSSI.
4) The development is for
profit.
5) The development will
cause traffic.
First Petition:
The petition in objection
received under the first
consultation is summarised
below:
6) Birds: Broadwater Lake is
one of only two lakes in the
Colne Valley where wildlife
is a priority user and is a key
contributor to the area's
SSSI designation. The lake
provides important habitat
for nationally significant
wintering bird populations.
Dre
dging and winter
construction works would
cause unacceptable
disturbance to resident and
migrating birds.
7) Eels: The lake supports a
uniquely large and
longǦestablished population
of European eels, a
Critically Endangered
species. Eels migrate to
breed at sea, and
Broadwater Lake’s
connection to the River
Colne makes it a valuable
1) Please refer to paras
7.21 to 7.51 of the report
for the assessment of
impact to
the SSSI and
biodiversity.
2) Please refer to paras
7.5 to 7.11 of the report
for the assessment of
alternative sites.
3) Please refer to the
main body of the report
for consideration of the
scheme as a whole.
4) The development is
proposed to replace the
former HOAC facilities
lost as a result of HS2.
The facility was
previously operated by
the Colne Valley Youth
& Community
Association which is a
youth charity prioritising
outdoor and
environmental education
for young people,
especially those who are
disadvantaged or
disabled.
5) Please refer to paras
7.
168 to 7.188 of the
report for consideration
of transport impacts.
6) Please refer to paras
7.21 to 7.51 of the report
for the assessment of
impact to the SSSI and
biodiversity. Conditions
15
, 16, 41 and 55 are
proposed to secure a
Mitigation,
Enhancement &
Management Plan
(MEMP), Construction
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source of breedingǦage eels.
Dredging is likely to damage
or destroy essential eel
feeding, resting and
hibernation habitat,
threatening the species’
survival.
8) Algal blooms: Dredging
may also release stored
nutrients that could worsen
severe blue
Ǧgreen algal
blooms, posing risks to
human health and causing
prolonged lake closures.
Second Petition:
The petition in objection
received under the second
consultation is summarised
below:
9) The petition requests that
Broadwater Sailing Club
(BSC) remain in its current
northern location rather than
being relocated to the new
facility at the southern end
of Broadwater Lake.
10) Safety concerns: The
proposed new facility lacks
clear visibility of the sailing
area from the clubhouse
and shoreline.
11) Difficult launch
conditions: Trees in the
Eastern Channel mask wind
directions and create narrow
access to open water,
making sailing in/out unsafe.
12) Reduced sailing and
racing area due to willow
tree growth shading the
southern end of the lake (up
Environmental
Management Plan,
Operational
Management and
Activities Plan
and a
Monitoring, Reporting &
Adaptive Management
Plan.
7) Whilst the original
2023 scheme proposed
47,356 m² of dredging,
this was substantially
reduced to 7,094 m² as
part of the amended
2025 scheme. The
amended submission
addresses concerns
regarding dredging and
habitat loss, confirming
that impacts are limited
and will be offset
through measures that
increase shallow,
structurally diverse, and
refuge
Ǧrich habitat,
alongside longǦterm
protection and
monitoring secured
through the MEMP and
OMAP. It is concluded
that the survey evidence
is robust, mitigation is
secured, and the
proposed development
will not harm water vole
or European eels.
8) Regarding algal
blooms, the
Environmental
Statement assesses
potential nutrient release
during dredging and
concludes that, with
mitigation, significant
adverse effects on algal
bloom formation are
unlikely. This is
Hillingdon Planning Committee – 21st April 2026
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to ten times higher than
existing trees).
13) Reduced boat park and
rigging space, along with
insufficient car parking at
peak times.
14) Significant loss of BSC
facilities, including a major
reduction in clubhouse/crew
room floor area (from 50m²
to 32m²) and no BSC
Ǧonly
changing rooms.
15) No BSC safety boat or
equipment storage is
provided in the proposed
relocation.
16) Moving BSC southwards
increases disturbance
(activity and noise) within
the SSSI and bird
sanctuary, harming local
wildlife.
17) Financial implications:
Leaving BSC in place
avoids the costs of
demolition, clearing the
current BSC site, and
constructing replacement
facilities.
proposed to be secured
by condition for the final
and detailed
Groundworks and
Dredging Methodology
(Condition
18),
Construction
Environmental
Management Plan
(Condition
16), and the
Monitoring, Reporting &
Adaptive Management
Plan (Condition
55).
9) to 17) A
representation has been
received from Trustees
and Main Committee of
the Broadwater Sailing
Club. The comments
acknowledge that
Natural England will not
allow the Hillingdon
Water Sports Facility
and Activity Centre and
BSC to operate together
on the north and south
of the lake due to the
disturbance to wildlife.
The comments also
confirm that Broadwater
Sailing Club support the
application and intend to
occupy the development
should permission be
granted. As such, whilst
there may be some
concerns by some
members of Broadwater
Sailing Club, it is
understood that t
he
facilities proposed are
fit-for-purpose and safe,
subject to necessary
controls and
management practices.
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It is also understood that
Broadwater Sailing Club
currently have no long
term right to occupy the
existing premises and
that the best way to
secure the long term
use of the site by
Broadwater Sailing Club
is through the proposed
development, which has
to
be sensitive to
constraints on the site
including its SSSI
status.
UU HoT i is proposed to
ensure that no
development occurs
until HOAC and
Broadwater Saling Club
enter into lease to
occupy the
development.
In summary, it is
considered that the
proposal successfully
balances both the
operational needs of
Broadwater Sailing Club
with the ecological
sensitivities of the site.
The proposal is deemed
to be fit
-for-purpose and
will be occupied by
Broadwater Sailin
g
Club.
Table 6. Summary of Statutory and Internal Consultee Responses
Consultee and Summary of Comments
Planning Officer
Response
Statutory Consultees
Affinity Water (Dated December 2023):
Site lies within Source Protection Zone 1
(SPZ1) for public water supply boreholes.
Planning conditions are required to prevent
The Affinity Water
comments are noted and
taken into consideration as
part of the planning
assessment.
Hillingdon Planning Committee – 21st April 2026
PART 1 – Members, Public & Press
contamination during excavation, piling, and
dredging.
Affinity Water (Dated December 2025):
Confirmation that their response remains
unchanged.
Please refer to Conditions
16, 18, 19, 20
, and 21.
British Rowing (Dated December 2023):
British Rowing supported the original
proposal, noting the inclusion of rowing which
aligns with its strategic plan for West London.
British Rowing (Dated January 2026):
British Rowing expressed disappointment that
rowing is not included as part of the amended
proposal. British Rowing encouraged HOAC
to promote health and wellbeing in
Hillingdon,
which should include rowing.
The British Rowing
comments are noted and
taken into consideration as
part of the planning
assessment.
It is noted that rowing no
longer forms part of the
proposal. Formal rowing
lanes were removed from
the planning application due
to the length required for a
rowing lane (750 metres - 1
kilometre). Such a proposal
would have extended into
the ecologically sensitive
part of the lake to the south
west and would not have
been acceptable. The
reduction in size of the
boatsheds, required to
reduce green belt and
ecology impacts, was also a
consideration as rowing
boats are longer in length
than dinghies used for
sailing.
Broadwater Sailing Club (BSC) (Dated
January 2026):
The original proposal from October 2023 was
supported because it aimed to create a
worldǦclass water sports activity centre, but
the revised version from November 2025 is
viewed as a significantly diluted plan that no
longer delivers on that ambition. There is
concern that BSC has been largely omitted
from the updated planning documents, with
unclear definitions of its access rights and the
space it would be allocated. Further worries
The Broadwater Sailing
Club comments are noted
and taken into consideration
as part of the planning
assessment.
Whilst Broadwater Sailing
Club’s original comments
regarding the safety and
feasibility are noted, their
follow
-up set of comments
acknowledge the site
constraints and sensitivities.
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