More residents associations oppose Spur's Wembley Stadium application

Wembley Park Residents' Association is oppposing the Spur's planning application to increase the number of full capacity events at Wembley Stadium. This is noteworthy as it covers many residents of flats recently built in the Quintain regeneration areas around the stadium.

Residents in Kings Drive, Wembley (next to the old Brent Town Hall) have added their voice to the objections:

Objection on behalf of Kings and Carmel Courts Residents' Association (170 Flats on Kings Drive Wembley)

Kings and Carmel Courts Resents' Association object to the planning application 17/0368 on the following grounds:

1) Parking: Kings Drive is in the Event Day Parking Zone and whilst the permits required to park in the road limit the cars parked on event days it is becoming apparent that more cars have permits during recent events. The number of cars parking is steadily increasing and the application does not address this important issue which impacts on the daily lives of those living on Kings Drive. Consideration should be given to permits having an expiry date and residents having to reapply to ensure that those parking are doing so on a valid permit. The cost of this must not be passed on to the local residents and should be borne by the Stadium or Council.

Kings Drive is already used for daily commuter parking, the new local schools and ASDA shoppers which impacts heavily on residents who wish to park close to their home. Event Day parking used to weed out these users allowing residents to park easily but this is no longer the case.

2) Anti-social behaviour: Kings and Carmel Courts have extensive gardens adjoining the corner of Forty Lane with Kings Drive. Fans use these private grounds to throw litter, picnic, drink and urinate in. This is unacceptable behaviour and furthermore the Leaseholders of Kings and Carmel Court then have to pay for the clean-up operation after event days. This is particularly bad when rival teams are playing against each other and customers from the Torch and local supermarkets selling alcoholic drinks sit along the walls and grass banks on Kings Court.

The planning application does nothing to address the disruption to local people yet it seeks to impose further disturbance and expense to residents.

Residents need to be protected from the invasion of drunk fans who have little care for other peoples' property and the Stadium/Council need to take responsibility protecting private property from trespassers and cover the cost of all associated cleaning.

Please note that Kings and Carmel Courts Residents' Association is known to Brent Council however it was not consulted on this proposal.

We are happy to meet with the Council or Stadium to suggest ways in which Event Days can be managed in an acceptable way to the residents of Kings and Carmel Courts.

Brent Planners recommend approval of Spurs' bid to increase number of full capacity events at Wembley Stadium

Brent Planning Committee will decide the application to increase the number of full capacity events at Wembley Stadium on Thursday March 23rd. The planners recommend approval 'on balance' and in the face of opposition from local residents and Barry Gardiner MP and Bob Blackman MP. After discussions the number of additional major events proposed has been reduced from 31 to 22. The planning commitee will be held at the earlier time of 6.30pm at Brent Civic Centre.

This is the officers' conclusion:

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123.    The objections received indicate that there is a level of impact currently experienced by events at the stadium. Comments received suggest that these mainly fall under the headings of anti-social behaviour and transport. Some impacts are expected, as it is a large stadium in a location with residents and businesses nearby.

124.    Additional events can take place at the stadium irrespective of the outcome of the application. However, those events that are beyond the existing cap would be limited to a capacity of approximately 51,000.

125.    The original cap on events was imposed to manage the impacts until such time as specific transport improvements had been made. Whilst most of these have taken place, not all of them have been realised. Circumstances have changed since the original planning permission in 2002, which suggest that the final piece of transport infrastructure (the Stadium Access Corridor) will not be provided in the originally envisaged form, but will be a variant of this. A further change is the level of development within the area, which has increased the population and will continue to do so. Therefore, the Council considers that the cap remains relevant, and any further impact associated with the additional events must therefore be assessed.

126.    Clearly, to increase the number of events to accommodate Tottenham Hotspur would imply a commensurate increase in the impact, albeit that it is proposed to be temporary for 12 months. In addition, following discussions the number of additional major events has also been decreased from 31 to 22, which would reduced the number of instances within which those impacts are apparent over that 12 month period.

127.    In analysing the impacts there has been some concern about the level of economic

benefit which would result, and this is primarily centred on visitor expenditure. In any event it seems common sense that there would be winners and losers on event days, dependent on the type of business. This makes it all the more important that the social impacts on event days are further mitigated. A number of additional measures have been secured to deal with some of these issues.

128.    Transportation issues have been extensively raised, and there are ongoing efforts to reduce the number of vehicles on a match day. A number of mitigation measures are proposed to continue this work. Some of these allow for existing work to continue, and others are new or updated. The pirate parking initiative is considered particularly important. On an individual event basis, Tottenham Hotspur do have the ability to influence their supporters’ behaviour over the course of a year, which is more difficult than for visitors on a one-off basis such as the FA Cup final. Addressing transport issues will also contribute to reducing noise and air quality issues.

129.    In summary, it is recognised that there is a level of impact being caused by major events now, and that this would increase with an increase in the number of high capacity major events. However, the measures proposed would ensure that this is mollified as much as is reasonably achievable. All are considered necessary to mitigate the increased number of matches which this application proposes. A further consideration is that Tottenham Hotspur could use the stadium for major events up to 51,000 now without restriction, and were they to do that then no additional mitigation measures would be formally secured. The proposed additional mitigation would apply to Tottenham Hotspur events, and with some of these being within the existing cap would represent a theoretical improvement for these major events.

130.    The proposal is, on balance, recommended for approval. 

Full Report HERE

Inadequacy of Spur's Wembley Stadium Environmental Statement exposed

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 

Haringey Council Parks & Leisure Services support the application for Tottenham Hotspur to play all of its games at Wembley at full capacity.

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.