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.
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.