On 29th August 2019, Blackpool Council sent out a joint press release with Holmes Investment Partnership, in which they state that they would be seeking to develop the land to the east of East Park Drive.
This development would see the land used to build a massive leisure warehouse called “Adrenaline World” along with 250-holiday lodges on this site.
Blackpool Council have cleverly used their process and procedures to deliver an outcome which appears to have been open and transparent, through selection by procurement of a preferred bidder for the concession to develop this site, Holmes Investment Properties (HIP)
In actual fact, the process was predetermined and driven not by a democratic process but by a small number of elected members and senior officers within the council, but mainly by David Lloyd and Adrenaline World, who is a partner with HIP, using a skilful and experienced legal group (Devonshires) who have expertise in delivering developments such as this for their clients.
So we are up against their experts!
Why Did Blackpool Council Select HIP Over the Community Benefit Bid?
The Procurement Outcome Report June 2020
On 22nd July 2019 Blackpool Council wrote to confirm that we were unsuccessful in our bid they identified several key areas where our bid failed to meet their requirements.
The panel felt that the overall quality of the proposal was acceptable, however there were certain areas where you could have provided more information and demonstrated how you would fully meet the aims and objectives of the specification.
Based on the evaluation criteria set out in the bid document CBS scored as shown in the table below.
|Price 40%||40%||39.3%||– 0.07%|
|Quality 40%||15.6%||24.4%||+ 8.8%|
|Social 20%||4%||8%||+ 4%|
This element did not disclose the winning bidders offer as this is supposedly confidential.
The Society Bid was an average rent of £ 65,000 p/a = £ 650,000 over ten years!
We understand that HIP offer was in two parts, for a 175-year lease.
|HIP 175 Year Lease||Total||P/A||10 Years||Diff +/-|
|Golf Course NO Planning Consent||250,000||£ 1,429||£ 14,290||-£635,000|
|Golf Course with Planning Consent||2,000,000||11,428||£ 114,280||-£535,720|
It may appear strange that Blackpool are prepared to lose so much in lease payments, but their press release says that the 42 million pounds that HIP will invest will outweigh any lease arrangements.
What is not clear is how this benefits the residents of Blackpool?
The simple fact is that the site is grossly undervalued, if the reported numbers are in fact correct?
Qualitative Criteria 40%
2.1 Business Proposal
The panel considered that the proposal had been well developed with due consideration given to the creation of a not for profit organisation and how this would be governed and managed on a day to day basis. The financial model submitted was detailed but over-reliance on pledges and increased patronage to ensure the organisation remained financially sustainable in the medium to long term came with a high degree of risk.
Considering the trading background of HIP directors and the management team the risk of a not-for-profit community interest organisation, pales into insignificance against business failures and insolvencies as reported to the Council in March this year.
Pledges by local people in a community project is surely far more secure and risk free when compared with stock market investments, and the possibly of corporate failure!
Blackpool Council simply refuse to accept that the current low patronage is due to the poor condition of the golf course and their mismanagement of the previous contractor Mack Trading, allowing them to take all the receipts from the course but invest very little in return, and at the same time not paying the £75,000 per year rent some £ 600,000 over the eight years of their tenure.
Just for clarity HIP are now operating under a Short-Term Operating Licence and like Mack Trading they are keeping the receipts but not paying any rent?
2.3a Relevant Experience
The panel appreciated the work undertaken to develop Articles of Association and rules upon which the CBS would operate, however, CBS has no track record of managing a golf course and this presents a significant risk.
The Founder Members of the CBS were described in detail within our business plan. This was made up of an: –
Independent Chairperson Local Educationalist
Financial Manager Local Business
Society Secretary Local Sporting Organization
Infrastructure Manager Director Local Building Business
Course Development Manager Retired Agronomist Myerscough College
Community Development Manager Project Manager Energy Conservation
Everyone had their CV’s and backgrounds outlined in the business plan.
Yes, it is true that none of this group has ever run a golf course.
They do though individually and collectively have a depth of knowledge in running successful businesses across a range of disciplines. Moreover, they do have a passion for the game of golf and the Golf Course and Club.
We also gave great detail on the support which would be forthcoming form Golf England, in both course management and development of the patronage, following an individual report produced for the CBS on those demographic and sociographic groups in our area, which identified key groups in our area.
The only evidence we could find of HIPs involvement in golf was the appointment of a Golf Consultant, and a link to a golf driving range, pitch and put adventure golf set up in Croydon!
2.5 Innovation and Integration
The Panel accepted that the basis of the proposal is to continue to operate and 18-hole golf course and increase the patronage through a variety of Initiatives. Whilst growth targets appear reasonable there is little evidence in the proposal to support delivery of the targets and no adjustment appears to have been taken into account for course closure during winter periods and any inclement weather and poor conditions in the main golfing season.
They say that there was no evidence which supported the growth in patronage, yet Appendix G of our business plan covered this in detail.
They also state that there was no adjustment in our business plan to address the loss of patronage during the winter months, yet there is a complete section within the business plan that charts the daylight playing hours across the year and adjusts the numbers accordingly?
Once again they completely fail to recognise that had the right investment been put back into the golf course, it would have made the course more resilient to inclement summers and extend the playing season into the winter months, as do other clubs in the area.
Mack Trading robbed the course of this investment, and Blackpool Council allowed this to happen, they call it MALADMINISTRATION.
Social Value Criteria
3 The panel accepted that the response addressed the key principles of the Supplier Charter, however felt that the response lacked any specific and measurable social value proposals. The score would have improved if CBS had identified measurable actions relating, for example, to engagement with schools and other community groups to launch a junior membership scheme, develop proposals how they could work alongside other community and voluntary groups such as Friends of Stanley Park, and worked SPGC member to enhance the use of the clubhouse for events resulting in increasing income and greater employment opportunities for local people.
They informed us that our bid lacked social inclusion in respect of community groups and developing youth schemes and wider social assets?
This despite sections of the business plan devoted to the Junior Golf Foundations “Golf Passport” and Golf England’s “Get into Golf”, program for adults, and golf on prescription through GPs. We also supplied a letter of support from Tee Time Golf Range Cleveleys, who were prepared to extend their junior program and work with the CBS to provide a wider opportunity for young people of the town.
They tell us that the HIP introduced an innovative proposal through investment with the potential for economic growth, but is difficult to see how a theme park and holiday lodges built around turnover in numbers from visitors to the attraction, can have any reasonable community value, or links to development of sporting growth in the youth population of the town.
The residents of Blackpool unfortunately are consistently in the top ten charts for deprivation across the country, its residents cannot afford £ 75 per person, per session, treats on the zip wire or, on the go carts and they have no spare cash to be renting holiday lodges!
HIP have no links to any community groups, nor do they appear to have any program or links to schools which would result in increasing numbers of young people taking up the game.
Formal Complaint Re: – Procurement Process
Following receipt of the notification we responded with a letter of complaint dated 31st August 2019.
Our complaint starts by acknowledging the reason why we were unable to challenge the decision, at the time, and we understand that there is no redress now other than a possible Judicial Review?
It then goes on to address several issues which we believe made the process unreliable!
1 Unfair Advantage
3 Risk of Completion
4 Analysis of the Bid
5 Social Value Criteria
Blackpool Council responded to our complaint on the 19th of September, declining our request to deal with this matter as a Corporate Complaint and their letter ends with the following comment from the Chief Executive: –
We trust this letter clarifies misconceptions which we understand to have been widely circulated in relation to this matter. We hope that the CBS will work with HIP and the Council in relation to the future of Stanley Park Golf Course and will accept the outcome of the procurement without further attempts to disrupt the Council’s progress in relation to this site.
It is worth noting the tone of the CE wording as they clearly consider any challenge to their authority in this matter as unwelcome.
Significantly after the date of this letter specific items within the complaint that Blackpool Council did not consider worthy of investigation, have subsequently been confirmed.
Specifically, the unfair advantage which the successful bidder Holmes Investment Properties had over other bidders, in so much as having been privy to private discussions with Blackpool Council, and they did gain insider knowledge, prior to the procurement process commencing.
Blackpool Council have confirmed that they were in discussions with David Lloyd of Adrenaline World, as associated with Holmes Investment Properties, back in 2017/18, and have stated that David Lloyd himself selected this site, despite being offered an alternative location at the South Shore Sports Village.
An important part of the procurement process is to ensure that those bidding are fit and proper.
Following a request under the FOI, a section of HIP’s bid document was provided.
Section 3 Deal’s with Grounds for discretionary exclusion: –
3.1d states: –
Bankrupt or is the subject of insolvency or winding-up proceedings, where the organisation’s assets are being administered by a liquidator or by the court, where it is in an arrangement with creditors, where its business activities are suspended or it is in any analogous situation arising from a similar procedure under the laws and regulations of any State?
We wrote to Blackpool Council and provide a catalogue of business failures and dealings, to which HIP management, and associates were a party too. Their response to question 3.1d was NO, when the answer clearly should have been YES. In which case they then would have been required to declare their positions and provide mitigation against exclusion.
Despite this damming evidence, Blackpool have written to confirm that they are satisfied with their due diligence and they will uphold the selection of HIP as the preferred bidder.
Blackpool Council are prepared to extend all kinds of leeway to HIP in order to push this development through the system, the next stage is planning which has got underway with and Environmental Impact Assessment, when the formal planning submission is made lets hope Blackpool Council Planning officers will be more open and transparent than their senior management team.
A formal complaint has been registered with the Local Authority Ombudsman, but COVID-19 as currently restricting their workload, and it may be some time before we know if they will take any action against Blackpool Council.
Who chose to develop this site?
During a meeting with Blackpool Council Representatives on the 7th of October 2019 it was confirmed by the officers present that David Lloyd Adrenaline World Selected the site.
Was this the only site available to David Lloyd Adrenaline World?
At the meeting on the 7th October 2019, officials from Blackpool Council confirmed that David Lloyd Adrenaline World turned down the offer to consider an alternative site on the proposed Sports Village South Shore Blackpool.
How many companies bid to run the concession which includes this green open space?
Although Blackpool Council still refuse to provide any details about the organisations who bid we know the HIP have been awarded the concession, that the Stanley Park Golf Course Community Benefit Society were the only other bidder to get through to the interview stage.
We believe that bids were also submitted by Blackpool Zoo, and Blackpool NHS Teaching Hospitals although these failed to pass stage one of the bid process.
Isn’t this land part of a conservation area?
This document identifies the following areas within the conservation area; however, the map shows that the land to the east of East Park Drive is not within the conservation area.
- Stanley Park
- Blackpool Model Village
- Blackpool Cricket Club
- Stanley Park Golf Course
- NorthPark Drive
- East Park Drive
- West Park Drive
- South Park Drive
- Northern end of Whinney Heys Road
What is Green Open Space?
Jan 2019 saw the publication of the: – Blackpool Local Plan Part 2, Proposed Site Allocations, and Development Plans and Policies.
Policy DM35: Open Land meeting Community and Recreational Needs
Development of land shown on the Policies Map as open land meeting community and recreational needs will not be permitted unless:
a. the development enhances community or recreational use; and
b. the development maintains the open character and function of the land.
These lands identified in Figure 8 include substantial open lands owned by or on long term lease from the Council comprising golf courses, cemeteries and other uses. Development of these sites will be resisted except where redevelopment of the site will enhance sports or recreational provision whilst maintaining the open character of the land.
This designation also contains areas of nature conservation value protected under Policy DM33.
Page 26 shows a map which shows the area identified for development as open land for recreational needs.
A quarter of the town’s open space is provided in and around Stanley Park, which is one of the largest parks of its kind in the country, providing a full range of recreation facilities that are of more than town-wide significance.
Within the Town Centre and the inner areas however there is very limited provision of open space of all types.
Is Public Open Space Protected?
Blackpool Nature Conservation Statement April 2008, Updated May 2012
Protection of Public Open Space
2.43 Current Local Plan allocations of Protected Public Open Space cover a wide range of recreational facilities across the Borough – safeguarded by policy BH5 and BH6 of the Blackpool Local Plan. (BH5/6 may now be surpassed by the current local plan part 2)
2.44 A quarter of the town’s open space is provided in and around Stanley Park, which is one of the largest parks of its kind in the country, providing a full range of recreation facilities that are of more than town-wide significance. There are eight other principal parks, and numerous playing fields and other small recreation grounds distributed through the town. Provision has been significantly increased in recent years with the laying out of new areas of open space in north east Blackpool and around Herons Reach. Within the Town Centre and the inner areas however there is very limited provision of open space of all types.
2.45 Open Space within the urban area has important recreational, sports and visual amenity benefits and is highly valued by local communities. Open space provides opportunities for enhancing nature conservation and is beneficial to biodiversity. This Council will therefore safeguard all existing open space from inappropriate development.
Is this Site of Special Scientific Interest?
No; presently there is only one such site within Blackpool at Marton Mere. Marton Mere was declared an SSSI by the Nature Conservancy Council in 1979 and re-notified in 1984 under the revised legislation contained in the Wildlife and Countryside Act 1981.
What about Nature Conservation?
Due to the highly built up nature of Blackpool, there are a limited number of sites of nature conservation interest which increases the importance of protection of any sites where nature conservation interests are identified.
Biological Heritage Sites make a significant contribution to the biodiversity of Lancashire and will be conserved and protected. Blackpool’s Biological Heritage Sites are identified in the Nature Conservation Paper (2012).
Table 4 Marton: Identifies East Park Drive 13.5 Hectares as Protected Open Space.
The majority of the defined sites within Blackpool are within public open space or other areas of land allocated to remain open, many being ponds located on the periphery of the Borough along the town’s eastern boundary.
The Council is committed to maintaining the biodiversity and local distinctiveness of sites of nature conservation interest and will endeavour to safeguard, conserve and enhance any further sites that are identified as adding to the wildlife and amenity value of the network of Biological Heritage Sites.
Development that could damage or destroy ponds or other local conservation sites will only be permitted if it can be clearly shown that the benefits of development outweigh both the nature conservation value and amenity value of the site. Where in exceptional circumstances development is to be approved which could affect a conservation site, appropriate mitigation measures will be required to conserve, as far as possible, the biological value of the site and to provide for replacement habitats where damage is unavoidable.