With the Evening Standard anticipating Brent planners statement on the Wembey Stadium application for additional full capacity soon, ahead of the March 23rd Planning Committee. I thought it worth publishing this submission from a resident of Corringham Road, addressing the applicant's Environmental Statement. 
LINK
In addition I publish the supporting submission from Haringey Council at the end of this article. 
Comments on the Environmental Statement 
(January 2017) to the Temporary Variation to the Event Cap at Wembley 
Stadium - Document Chapter C - Socio-Economics 
There are
 a number of points to make with reference to the Environmental 
Statement (ES) accompanying the Planning Reference 17/0368 - the 
application by Wembley National Stadium Limited (WNSL) - and in 
particular to the Socio-Economic aspects.
The most important points are as follows:
1.
 It has almost no economic or quantitative analysis at all, as opposed 
to just assumptions, and its conclusions cannot be supported in the 
absence of further work and also a properly produced cost-benefit 
analysis. 
2. It does not deal with any likely costs, and
 has only skimmed over the so called "beneficial socio-economic" 
impacts. The coverage and the quality of the analysis are far from 
adequate.
3. The conclusions under the heading "Potential
 Effects" are not robust, and there has to be much further and more 
careful work done to look at the likely negative impacts on the local 
economy. 
4. What about the economic costs of congestion,
 stress and strain on the local services and population, the crowding 
out of other economic activity, the inconvenience caused by hugely 
larger attendances at more much larger scale events at the Stadium? 
5. There is inadequate analysis of the location of possible additional expenditures, either within or outside the stadium? 
How
 much extra and additional economic benefit accrues to the local area 
and population as opposed to just within the stadium? This is certainly 
not clear from the application documents, and is vitally important in 
coming to any decisions. 
6. The figures in the 
conclusion in the summary of socio-economic benefits that expenditures 
of £43.5m and £14.5m (excluding traffic) can be expected locally are 
based not on calculations done at the Wembley site but are based on a 
primary survey by THFC of spectators to White Hart Lane. 
It
 is stated in the application documents in paragraph C5.14 of the ES 
that "if this expenditure profile ..... were to be transferred to 
Wembley Stadium during the 2017-18 season, this could support (my bold) 
£43.5 million of expenditure.......this would mean £14.5 million of 
expenditure would be available for spending on food, drink and other 
ancillary items at Wembley". 
However, these figures are purely 
assumptions. There is no robust analysis or justification that these are
 likely to be appropriate, and are certainly not accompanied by any 
corresponding costs which should have been taken into account.
7.
 Paragraph C5.16 of the ES states that "On this basis, taking into 
account employment and visitor expenditure effects, it is assessed that 
the impact of the temporary variation of the event cap will result in a 
moderate positive impact on the local economy for the duration of the 
2017-18 football season" (my bold). 
How can any conclusion follow from the implausible assumptions in paragraph C5.14 stated above?
8.
 In the document entitled "Temporary Variation to Event Cap at Wembley 
Stadium..." written by Nathaniel Lichfield & Partners, it is clear 
from paragraph 6.5 that the conclusions of the environmental impact 
assessment should have covered all four aspects namely (1) 
Socio-economic (2) Transportation (3)Air Quality and (4) Noise and 
Vibration. 
However, in the summary to this document, in 
paragraph 9.7, it is stated that "this Statement demonstrates that the 
proposals accord within planning policy and will not result in any 
unacceptable effects in terms of transport, noise and vibration and air 
quality impacts". 
But, where is the reassurance about 
socio-economic impacts? It is strange that it should be omitted if there
 was a clear conclusion that this was also acceptable. 
9.
 There is no clear analysis of which geographical area the claimed 
benefits are supposed to support. The definition of the area around the 
Stadium is important to identify, especially if the costs as well as 
benefits are to be assessed. The costs are likely to be spread around 
the wider neighbourhood via aspects such as traffic congestion, parking 
problems, noise and safety. Why have these not been included? It is 
common practice to include some valuation for these impacts in a 
properly worked cost-benefit analysis.
10. There is very 
little understanding of the scale factors associated with increasing the
 numbers of visitors to the Stadium from a maximum of 51,000 to 90,000 
on an extra 31 days a year. A proper analysis would have shown a much 
better awareness of the huge impacts such large crowds will have. The 
various comments in the papers accompanying the planning application 
imply that all impacts will be minor. 
11. As an example 
of the lack of understanding of the likely impacts of scale is paragraph
 G6.4 in the Summary and Conclusions of the Environmental Statement, 
which states that: "Minor negative residual effects remain in relation 
to specific sensitive recepto
                                                    
                                                 
                                            
                                        
                                            
                                                
                                                
                                                    
                                                        Comments on the 
Environmental Statement (January 2017) to the Temporary Variation to the
 Event Cap at Wembley Stadium ? Document Chapter C ? Socio-Economics 
There
 are a number of points to make with reference to the Environmental 
Statement (ES) accompanying the Planning Reference 17/0368 - the 
application by Wembley National Stadium Limited (WNSL) - and in 
particular to the Socio-Economic aspects.
The most important points are as follows:
It
 has almost no economic or quantitative analysis at all, as opposed to 
just assumptions, and its conclusions cannot be supported in the absence
 of further work and also a properly produced cost-benefit analysis.
It
 does not deal with any likely costs, and has only skimmed over the so 
called 'beneficial socio-economic' impacts.  The coverage and the 
quality of the analysis are far from adequate.
The conclusions 
under the heading 'Potential Effects' are not robust, and there has to 
be much further and more careful work done to look at the likely 
negative impacts on the local economy. 
What about the economic 
costs of congestion, stress and strain on the local services and 
population, the crowding out of other economic activity, the 
inconvenience caused by hugely larger attendances at more much larger 
scale events at the Stadium? 
There is inadequate analysis of the location of possible additional expenditures, either within or outside the stadium?
How
 much extra and additional economic benefit accrues to the local area 
and population as opposed to just within the stadium? This is certainly 
not clear from the application documents, and is vitally important in 
coming to any decisions. 
The figures in the conclusion in the 
summary of socio-economic benefits that expenditures of £43.5m and 
£14.5m (excluding traffic) can be expected locally are based not on 
calculations done at the Wembley site but are based on a primary survey 
by THFC of spectators to White Hart Lane. 
It is stated in the 
application documents in paragraph C5.14 of the ES that 'if this 
expenditure profile ..... were to be transferred to Wembley Stadium 
during the 2017-18 season, this could support (my bold) £43.5 million of
 expenditure.......this would mean £14.5 million of expenditure would be
 available for spending on food, drink and other ancillary items at 
Wembley'. 
However, these figures are purely assumptions. There is 
no robust analysis or justification that these are likely to be 
appropriate, and are certainly not accompanied by any corresponding 
costs which should have been taken into account.
Paragraph C5.16 
of the ES states that 'On this basis, taking into account employment and
 visitor expenditure effects, it is assessed that the impact of the 
temporary variation of the event cap will result in a moderate positive 
impact on the local economy for the duration of the 2017-18 football 
season' (my bold). 
How can any conclusion follow from the implausible assumptions in paragraph C5.14 stated above?
In
 the document entitled 'Temporary Variation to Event Cap at Wembley 
Stadium...' written by Nathaniel Lichfield & Partners, it is clear 
from paragraph 6.5 that the conclusions of the environmental impact 
assessment should have covered all four aspects namely (1) 
Socio-economic (2) Transportation (3)Air Quality and (4) Noise and 
Vibration. 
However, in the summary to this document, in paragraph 
9.7, it is stated that 'this Statement demonstrates that the proposals 
accord within planning policy and will not result in any unacceptable 
effects in terms of transport, noise and vibration and air quality 
impacts'. 
But, where is the reassurance about socio-economic 
impacts? It is strange that it should be omitted if there was a clear 
conclusion that this was also acceptable. 
There is no clear 
analysis of which geographical area the claimed benefits are supposed to
 support. The definition of the area around the Stadium is important to 
identify, especially if the costs as well as benefits are to be 
assessed. The costs are likely to be spread around the wider 
neighbourhood via aspects such as traffic congestion, parking problems, 
noise and safety. Why have these not been included? It is common 
practice to include some valuation for these impacts in a properly 
worked cost-benefit analysis.
There is very little understanding 
of the scale factors associated with increasing the numbers of visitors 
to the Stadium from a maximum of 51,000 to 90,000 on an extra 31 days a 
year. A proper analysis would have shown a much better awareness of the 
huge impacts such large crowds will have. The various comments in the 
papers accompanying the planning application imply that all impacts will
 be minor. 
As an example of the lack of understanding of the 
likely impacts of scale is paragraph G6.4 in the Summary and Conclusions
 of the Environmental Statement, which states that: 'Minor negative 
residual effects remain in relation to specific sensitive receptors in 
relation to bus services impacted by additional vehicular traffic in the
 immediate periods prior and post matches. The additional mitigation 
measures proposed to encourage public transport will assist in 
minimising this effect as far as possible. These adverse impacts should 
be balanced against the beneficial socio-economic effects arising from 
the proposal.' 
Well, this is not good enough. What does 'as far 
as possible' mean? Why have these, as well as lots of other negative 
impacts, not been costed? 
Furthermore, why has there been the 
assumption that they 'should be balanced' against some inadequately 
analysed socio-economic benefits? Where are the figures to accompany 
this sort of comment in the Conclusions?
As an indication of
 how little account has been taken of the scale factors associated with 
the proposed changes, and the overall lack of coverage of issues that 
cause detriment or negative impacts, the Environmental Statement 
contains in its Summary & Conclusion the following key points:
Paragraph C8.5: in relation to local air quality 'No mitigation measures are required'.
Paragraph
 C8.6: comments 'In terms of noise and vibration, it is considered that 
crowd noise from the additional sporting events would have a negligible 
impact.....
There are no further mitigation measures that are required other than those considered or already implemented'. (My bold)
Paragraph
 C8.7: comments in conclusion from the ES that 'The proposed variation 
to the event cap to allow THFC to use Wembley Stadium for the 2017-18 
will bring significant additional expenditure and employment to Wembley 
and its surrounding area'. (my bold)
Finally, in my view the 
analysis done for this Environmental Statement, which is a crucial input
 into any decision as to whether to allow the Planning Application 
17/0368 to get approval, is not sufficiently robust to form the basis 
for any decision. 
There are sufficient problems, gaps and 
inconsistencies in its coverage to require a further and better piece of
 work to be undertaken and provided in writing to the Brent Council 
Planning Department before any decision is taken.
The impact on 
the geographical area close to the Stadium of the proposed changes 
embodied in the Planning Application is so considerable that this 
information must be supplied.
Meanwhile Haringey Council has submitted its support for full capacity matches to be played at Wembley.
 
Leisure Services, Haringey Council, Alexandra House, 10 Station Road, Wood Green, London, N22 7TR
We have seen considerable benefits for our community from Tottenham Hotspur's work in our Borough with their Foundation having spent time for example working with employers in the area, the Job Centre as well as in schools across the area.
Through an increase in the number of people attending and the size of the events, we believe there will be increased opportunities for local business, greater employment benefits on events days and a general bump to the local economy.
Additionally, having engaged with the Tottenham Hotspur Foundation, we are pleased that this application outlines a further commitment to enhancing their programme of activity in the borough of Brent and expanding it during their year in the borough. Through this work, we believe there will be some real opportunities to develop employment and skills opportunities beyond just event days and not just in industries you would associate with Wembley Stadium or football. We look forward to working with them to develop these programmes.
With regard to the event's themselves, while event days do come with issues for the community, we believe from our own experience that the additional mitigation measures put in place to manage them at 90,000 will make them considerably better run events than we currently have at the stadium. We welcome the extra efforts being made by the Club and Wembley to address the issues which arise regardless of the stadium capacity and hope that by accepting this application we will see the benefit of those measures positively impacting the area on event days.