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17/0368 | Proposed variation of condition 3 (event cap, to allow 31 additional full capacity events) and removal of condition 33 (temporary traffic management) of planning permission reference 99/2400, which was for: Full planning application to consider the complete demolition of Wembley Stadium and clearance of the site to provide a 90,000-seat sports and entertainment stadium (Use Class D2), 4750m2 of office accommodation (Use Class B1), banqueting/conference facilities (Use Class D2), ancillary facilities including catering, restaurant (Use Class A3), retail, kiosks (Use Class A1), toilets and servicing space; re-grading of existing levels within the application site and removal of trees, alteration of existing and provision of new access points (pedestrian and vehicular), and parking for up to 458 coaches, 43 mini-buses and 1,200 cars or 2,900 cars (or combination thereof) including 250 Orange Badge parking spaces. As approved, condition 3 stated that for two years following completion of the stadium, subject to the completion of specific improvement works to Wembley Park Station and construction of roads known as Estate Access Corridor and Stadium Access Corridor, the number of major sporting events held at the stadium in any one year was restricted to no more than 22 (to exclude European Cup and World Cup events where England/UK is the host nation), and the number of major non-sporting events to 15. After this, additional events over and above this were permitted subject to the number of spectators being limited to the capacity of the lower and middle tiers of the stadium. The proposal would allow for up to an additional 22 major sporting Tottenham Hotspur Football Club (THFC) events between 1 August 2017 and 31 July 2018. A major event (which may or may not include THFC) would be considered to be an event in the stadium bowl with a capacity in excess of 10,000 people. The application includes the submission of an Environmental Statement. | Wembley National Stadium, Olympic Way, Wembley, HA9 0WS
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  • Comments Received: 177
  • Objections: 166
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43 Corringham Road, Wembley, HA9 9PX (Objects)

Comment submitted date: Tue 28 Feb 2017

T



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

Comment submitted date: Mon 13 Mar 2017

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.



Dr Ruth Kosmin

28 February 2017










ADDITIONAL POINTS ON THE ENVIRONMENTAL STATEMENT CHAPTER C ? SOCIO ECONOMICS

There are a number of additional points to make ? some general and some specifically relating to the actual paragraphs in the Socio-Economic document.

General points

This is a disappointing and inadequate paper for the various reasons set out previously and below.

The analysis of the Significance Criteria for the socio economic effects has a definition with 4 criteria (Substantial effect, Moderate effect, Minor effect and Negligible).

The one that the report's Conclusions found in almost all the areas looked at is the one called 'Negligible'. This is defined as 'where no discernible effect is expected as a result of the proposal on the existing population...' The next criteria is entitled 'Minor Effect' where there would be a 'slight, very short or highly localised effect on the existing population...'.

However, even on their own commentary, as in Paragraphs C5.20 and C5.21 , there would have to be a 'Minor Effect' and not a 'Negligible' effect.
It is clear that the document has at every stage minimised the likely impact on the local population and on the area, and without any analysis to back up the assumptions. How can virtually all the conclusions come out with a 'Negligible' definition? This is unrealistic, even within the report's own parameters.

The Summary and Conclusions section and paragraph 7.1 state that no mitigation factors are required. This cannot be realistic.
The table C8.1 set out in Paragraph C8.3 ? see below - is inaccurate, even on the basis of the methodology in the report.
Table C8.1 Summary of Socio-economic Impacts Impact Summary of Effect
Additional Spectators 1,209,000
Additional Steward Positions Required 15,500
Additional Catering Staff Positions Required 15,500
Additional Expenditure 43.5m
Additional Expenditure (excluding travel) 14.5m
Source: NLP analysis
The number of additional Steward positions should not be 15,500 but 12,400 (see my comment below on Paragraph C5.11). Furthermore, the additional expenditures figures are based on assumptions and not on any analysis (see my earlier paper)

Paragraph C7.1 states that 'no socio-economic mitigation measures are assessed as being necessary.' This is an astounding conclusion, and certainly not supported by any analysis. How can this possibly be the outcome given the scale and disruption of the additional events on the locality?

Surprisingly, the analysis relates only to the 2017-18 year. There is no indication or allowance for the likelihood that this application would provide a precedent for Wembley Stadium being opened up for increases in the number of large scale events in subsequent years. It is clear that Chelsea Football Club has an interest in doing the same as Tottenham Hotspurs (THFC) and using Wembley Stadium during the 3 years when their own Stadium will be rebuilt.

What is noticeable, however, is that, according to a report on page 2 of the Evening Standard newspaper dated 6 March 2017, Chelsea has significantly offered to contribute to Hammersmith and Fulham Council in their planning application for their new stadium. The application includes an investment of 12million in local community activities etc, as well as a contribution of 3.75million towards affordable housing in the borough.

Where is the equivalent offer from WNSL or THFC to make a similar contribution to Brent Council or the local community as compensation for the massive congestion, disruption and problems that will inevitably accrue from their increased usage of the Stadium if their application is successful? THFC have plenty of money to pay for players!
It is remarkable that THFC have made no offer to Brent Council of similar financial support. Nothing to this effect is referred to in the papers. This omission is glaring.

There has to be further analytical work done to produce a fully worked up and professional cost-benefit analysis before any permissions can be given by the Brent Planning Committee. Brent Council should not be satisfied with the information and reports supplied to date. Where are the costs? It is quite apparent that the conclusions in this ES document are not robust or adequate.


Specific Points
Paragraph C1.2 states: 'A study area boundary has been defined to incorporate the communities which are likely to be affected by the additional events.'
But this is not large enough. The area affected by the proposal will be much bigger. In addition, all the extra properties and flats that now exist in the area are not allowed for. Comparisons with the 1999 ES document are therefore difficult.

Paragraph C3.4 under 'Significance Criteria' states: 'Since there are no generally accepted criteria for assessing the significance of socio-economic effects, these have been assessed based on the scale of the increase over the baseline position, as well as the nature and context of the effects. Where possible, the location of the effects and their likely duration has been taken into account. However, in many cases this cannot be quantified or measured, so the nature of the effects is considered more generally.'
This is yet another example where proper analysis has not been provided. Of course it is possible to quantify socio-economic effects. Just stating that they 'cannot be measured' is not good enough. There are standard measures for this in a cost-benefit analysis, but the report has not calculated these.

Paragraphs C4.2 and C4.3 make it clear that the population figures used in the paper go only as far as 2011. What about the current 2017 population figures?
There has been a huge growth in population in the local area over the last 5 years since these figures. Even in the period from 2001 to 2011 that they cite, the population in the study area increased by 29%. That increase will be much higher now.

Under the section on Anti Social behaviour, Paragraph C4.17 states, again without any analysis, that 'There is therefore no indication that Wembley Stadium has any particular influence on anti-social behaviour.' This is another example of mere assertion without supporting evidence. Anti social behaviour on match days is a major problem for local residents.

Pure assertion rather than good analysis is evident in Paragraph C4.20 which states: 'The analysis shows that the current baseline socio-economic conditions of the study area are broadly consistent with those identified in the 1999 Environmental Statement.'
What does 'broadly consistent' mean? The paper already shows that this is not the case, especially on population factors.

Paragraph C4.21 states: 'Overall, whilst there has been a significant improvement to local socioeconomic conditions, there have not been any changes to the baseline characteristics of the study area which would suggest any particular sensitivity to the socio-economic effects of the proposed extra events to be held at Wembley Stadium.'
How can the paper state that there would be no sensitivity to the proposed extra events without doing any analysis?

Paragraph C4.29 states: 'Wembley National Stadium Limited (WNSL) commissioned an economic impact assessment in 2014 to assess the economic impact which Wembley Stadium has in general, and specifically on the local community and the London economy more widely. This report draws on detailed data analysis and surveys of visitors, businesses and hotels in the local area.'
If that was done in 2014, why does the paper use data from 2011? Why has the data not been updated?

Paragraph C5.6 states: 'As noted in the baseline analysis, Wembley Stadium has contributed significantly to the regeneration of the local area and generates a range of socio-economic impacts within the local community. These effects will continue over time as further development comes forward in the Wembley area and the Stadium continues to provide a high-profile asset for the area. It is not considered that this wider regeneration catalyst will be significantly impacted by the temporary variation to the event cap, although the additional fixtures will only further raise the profile of the Stadium.'
What does this mean? The paper seems more concerned with the 'profile of the Stadium' than on getting some data for further analysis. Moreover, regeneration has been achieved through housing developments and infrastructure, not the Stadium alone.
Paragraph C5.9 makes clear that there could be an additional 1,209,000 spectators at the extra events (31 x 39,000 extra people). In this context, how can the report assert so often that there is a 'Negligible' impact on the area.

Paragraph C5.11 has got the arithmetic wrong, which then impacts on the Conclusions of the paper. It states: 'For events using only the lower and middle tiers of the stadium, the number of stewards required is 600 ? 900. A full capacity event requires 1,100 ? 1,300 stewards, an uplift of up to 500 per event. Assuming all 31 additional events take place, up to an additional 15,500 steward positions would be required over the 2017-18 season.'
However, the uplift on the number of stewards should be 400 per event, not 500 (1,300 minus 900). This means that the number of places required would be 12,400, not 15,500, even on their own assumptions of requirements.

Paragraph C5.14 makes it clear that all the numbers on visitor expenditure are based on the general assumption that it is appropriate to use earlier analysis from White Hart Lane and then apply it to Wembley Stadium without modification. This is simply not good enough.

Paragraph C5.20 implies that all impacts will be 'outside peak hours'. This is not accurate and has not been supported by any robust analysis. It is in fact contradicted by the report's own statements elsewhere. Crowds arrive early for evening matches, at the same time as local residents are returning from work.
See the traffic analysis in the Comments of the person resident at 49, Empire Court, North End Road, Wembley, who has filed an Objection on the Brent Planning website. This resident states that he is a transport planner/modeller by profession, hence his detailed questions.
Those particular comments and questions must be addressed by the applicants before the Brent Planning Committee can reach a fully informed view of the application.





Conclusion

All in all, the economic analysis supplied in support of the application is of poor quality and requires substantial further work to be carried out along the lines suggested above.

Brent Planning Committee should be advised by their officers that on the basis of current information they cannot take a decision at this stage. There is huge local opposition to the increase in use of the Stadium.

There is also no justification for increasing the number of spectators to go above the 51,000 figure, especially since THFC's existing ground has a capacity of 38,500 and their proposed new ground will have a capacity of only 60,000. Why, apart from THFC's desire for further income generation, should there be a need for 90,000 capacity for each game held at Wembley?

Comment submitted date: Tue 28 Mar 2017

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.



Dr Ruth Kosmin

28 February 2017

21 Barn Hill, Wembley Park, Middlesex, HA9 9LD (Objects)

Comment submitted date: Tue 28 Mar 2017

Dear Sirs,
Re: Planning Application Reference: 17/0368
Wembley National Stadium Limited - Proposed variation of condition 3 to allow 31
additional full capacity events
I write to object in the strongest possible way to the above proposal.
Life for local residents is already made difficult on event days and the addition of these
proposed full capacity event days will make matters worse. Our freedoms are compromised
in every way, from people drinking in the streets around Wembiey Park Station, litter strewn
everywhere, men urinating in the streets or our gardens and non local traffic increasing the
load on already overcrowded streets. It becomes impossible to organise family gatherings on
event days, friends and family cannot park due to restrictions on parking or they get caught
up in the traffic chaos either before a match or after.
If Brent agrees to 57 event days it will mean that the local residents will be subjected to an
average of more than one event every week. This is not acceptable to most local residents.
I would like to refer you to the letter of objection written to Rt. Hon. Barry Gardiner MP by
the chairman of the Barn Hill Residents Association, Mr John Woods, on 17th January 2017.
I am sure a copy has been forwarded to Brent Planning Department as a matter of course by
Barry Gardiner and I trust you will have considered the points made by him seriously.
Brent has been my home for the past 40 years and sadly, I have watched Wembley lose much
of its character and become far too overcrowded as a result of Planners decisions taken over
the last 15 years. We all appreciate that time moves on and sensible development has to take
place but 1 believe Brent has exceeded the boundaries of sensitive development.
The traffic chaos and reduced quality of life generally as a result of Planners decisions are
everywhere to be seen. To now allow the further intrusion proposed upon local residents
would be to further add to those issues of life quality which it seems to me the Council cares
very little about. As long as Major Developers and others continue to make applications for
major works which the Planning Department seemingly approves without question, the
Council is gradually further eroding the quality of life in this Borough. I live in a conservation area, The Barn Hill Estate, and 1 fear for its future if these event days
are allowed and for the further future if they act as a precedent for allowing events to occur
with this frequency for all time.
I trust you will take my objection seriously and not allow this variation to the application to
be granted.
Yours faithfully
Anthony Ghibaldan

338, Preston Road, Harrow, Middlesex, HA3 0QH (Objects)

Comment submitted date: Mon 27 Mar 2017

Sir/Madam

As a resident of Preston Road I object most strongly to any increase in the number of 'Event Days' at Wembley Stadium and their accompanying restrictive parking regulations. Event days cause great inconvenience and nuisance ~ these restrictions have already played a major role in the decline of the Wembley Park Horticultural Society as visitors and exhibitors alike felt themselves ~ with reason ~ unable to trust parking officials, despite the provision of permits.
Signage is appalling, being both difficult to see and all too often inaccurate. No advance notice is given to residents, but it has become increasingly difficult to obtain permits for pre-arranged private or community based events.
All these factors curtail even further the few occasions on which residents are able to invite friends or engage workmen, unless they are willing to concrete over their front gardens.
For residents of the main Preston Road it is too often impossible to park anywhere near our houses. When visitors are old or in poor health these designated spaces are unusable as they are all sited on steep hills.

Event Days are an unmitigated blight on this community. There are already too many Event Days ~ in summer it seems that almost every weekend becomes an Event Day! At the edge of the zone residents are plagued by cars blocking driveways and causing great inconvenience, while inside the zone even loading our own cars at 8.30 on a Sunday morning [with a skip on the drive] becomes a problem ~
'3 minutes observation of the vehicle' as recorded on the ticket, was the limit I was allowed!

It has become increasingly evident that in Brent residents do not count, that the quality of their lives does not matter.

Yours Sincerely,

296 Tokyngton Avenue, Wembley, HA9 6HH (Objects)

Comment submitted date: Thu 23 Mar 2017

Wembley is already subjected to event days. These are days when we cannot leave our houses without getting stuck in traffic. Even travelling on the tubes at Wembley Park, the tubes are full of people and it's uncomfortable!
If the council cares about its residents it will not add any more event days as was agreed years ago. If they do, why not take the stadium outside London? We already have Twickenham Stadium as well whose traffic also impacts London and causes chaos as well.
The proposed plans would have many many health and safety issues. The construction would increase noise levels as well as all the extra waste filling the landfills when there is nothing working with the existing stadium. The stadium cost nearly a billion pounds to make. Money that could go to the Nhs, how can you even consider demolishing it when it's been made recently? There is no need to waste further money on building something just to accommodate football matches.
Extra event days would increase air pollution. Air pollution that is killing Londoners every year, air pollution that the mayor is trying to reduce. So why would you increase people coming in? They come in their cars and you can never ever stop that, ever.
If you increase the number of people in the stadium, how will london cope in case of emergency? A natural disaster such as fire, or terrorist activity? Where will the people assemble, you have built buildings all around the site!
London has so many issues due to overpopulation. Traffic, air pollution, lack of infrastructure to cope with emergencies. If anything or anyone was hurt directly or indirectly by any of the plans, the brent council is directly responsible. London councils should reduce traffic, chaos and noise and sound pollution not add to these problems. There's Been so much building work in London, you have just built the outlet. Any work near there will destroy the existing buildings and be very unsafe and unwise. Just leave wembley as it is and stop building here.

46 Brampton Grove, Wembley, HA9 9QU (Objects)

Comment submitted date: Wed 22 Mar 2017

We write to strongly object to the Application for the Proposed variation of
Condition 3 & the Proposed removal of Condition 33 in order to increase
the number of full capacity Event Days at Wembley Stadium, as listed at the
end of this letter.
We refer you to the letter of Mr John Woods, Chairman of our Bam Hill
Residents' Association, who has made a very strong case for residents'
objections in a well-researched and evidence-based argument of which Brent
must take serious note and with which we fully agree.
Ill addition we the residents would like to believe, indeed trust, that Brent
Council has a duty of care and responsibility for the public health, safety and
general well-being of residents and of our environment. All these issues will be
compromised by the increase in air pollution, the continuing unruly and
unchecked behaviour of fans, and the difficulties of freely moving around for all
local residents on Event Days.
Have the "goal posts" been moved from the original number of Event Days
as a pretext for Tottenham and as a significant increase for the future?
Proposed variation of Condition 3
Condition 3 of the original Wembley Stadium Planning Consent
has not yet been fully complied with. This Condition restricts the
number of full capacity events at the Stadium until various
transport improvements have been put in place. These include
the upgrade of one section of road within the Wembley Industrial
Estate which requires the purchase of a significant amount of
land. This purchase has not yet taken place, despite Wembley
Stadium having given Brent Council millions of pounds to facilitate
these works.
We believe that until such time as these works are completed in
their entirety, this Application should be refused.
Proposed removal of Condition 33
We do not agree with the lifting of this Condition as we believe
that many fans of Tottenham will travel to Wembley via the North
Circular Road despite it already being heavily used and subject to
constant traffic jams.

1 Barn Hill, Wembley, Middlesex, HA9 9JU (Objects)

Comment submitted date: Wed 22 Mar 2017

I am writing to object in the strongest possible manner the proposals which are being set out by
Wembley Stadium. This is in relation to Application Ref No 17/0368.1 also wish to strongly object to
planning conditions numbers 3 & 33 which are set out in the planning application.
The local area & the local infrastructure cannot & will not cope with a full Wembley Stadium crowd
capacity. Public transport in & around the area suffers terribly on football event days as it is & the
thought of football matches being played every other week & in some circumstances twice in one
week is completely unacceptable.
The fans have become very volatile in the past few years, heavy drinking in the streets in public view
which the Police do not enforce a ban even though it is against the law is also a major problem, not
to mention the litter in general from fast food places thrown & scattered everywhere which includes
the private properties of many residents myself included.
Urinating in the streets again in full public view is also very common practice & again in some
instances in residents private properties as well. Residents in general feel extremely intimidated in
going about their own business in the local area on full capacity event days & this cannot morally be
right. We realise that we live near a Stadium where football is the main sport played there however
we respectfully point out that it is a National Stadium & not a league club stadium, football on a very
regular scale being played there was never part of the original plans or agenda of the FA.
All us residents fully believe the only motivation for this is money driven. The FA because they need
to recoup as much money back as possible to pay for the Stadium which they vastly over paid for in
the first place & Tottenham to help fund their new stadium. There is no League club in the UK which
has the need for a 91,000 capacity to play football. Based on the above facts that I put in this letter I
again stress that I strongly object to these proposals put forward by Wembley Stadium & Tottenham
Hotspur FC.

42 Barn Hill, Wembley, HA9 9LF (Objects)

Comment submitted date: Wed 22 Mar 2017

Dear Sir/Madam,
Re: Planning Application ref 17/0368
Wembley Stadium
1 object to the above application, because of the impact the increased
event
days will have on the area and residents. The event days at the present
level
cause enough chaos and mess and disruption, without increasing it by a
massive
amount 31 days.
The traffic as it stands Is congested at the best of times due to the
changes
of buildings and the new Academy and all the new projects in Wembley
Park
all using Forty Lane. It is a nightmare to leave your home 37 days 5 weeks
2 days housebound. You can't push the wheelchair into the shopping mall
or
access the local amenities unless you go down at the times of the game
play.
I object to the council being inconsiderate and not thinking about the
detrimental Impact this will have on the Community.
I and my household strongly object to this application.

98 Uxendon Hill, Wembley, Middlesex, HA9 9SJ (Objects)

Comment submitted date: Wed 22 Mar 2017

We wish to object to the above planning application to remove conditions 3 and 33. Also a variation
of condition 3 for the following reasons:
The upgrade of the road system around the stadium has not been completed as part of the original
planning application. It is quite obvious from the leaflet I have been sent, in condition 3, that there
is a substantial amount of land that needs to be purchased to satisfy this condition. I cannot see
anywhere where you state that the Council will purchase this land. Surely the Council will be in
breach of its own condition in the original planning permission for the stadium.
Tottenhams many fans will use the North Circular as the route to the stadium and should not be
removed.
Tottenham Hotspurs average home game attendance is 36,824, an increase to 51,000 would give an
additional 14,176. The 91,000 would give an additional capacity of 54,176 and if agreed this would
have a detrimental effect on Brent residents and local businesses and also it would flood the market
with tickets for the derby matches i.e. Arsenal/Chelsea/West Ham matches. This would increase the
risk of fan violence and increased policing commitments. The 51,000 would satisfy both Chelsea's
and Tottenham's existing stadium capacity.
We believe Brent Council is not taking seriously the impact that event days have on the local
residents for the following reasons:
Notice of event days of Premier League, FA Cup and European matches change at short notice due
to TV rights.
Difficulty in gaining access or leaving Wembley Park Station due to large volumes of users of the
transport system. Police do not allow local residents access to the station other than joining the
queues of fans leaving the stadium.
Anti-social activities, street drinking and using the streets as a toilet. Police do not enforce the law|.
on match day concerning these activities.
Difficulty in arranging family gatherings due to parking and public transport travelling restrictions.
Rubbish is left behind for days after event days.
Due to afore going I hope that Brent Council rejects this planning application.

29 Basing Hill, Wembley, HA9 9QS (Objects)

Comment submitted date: Wed 22 Mar 2017

I strongly object to your proposal to increase the number of event days at Wembley
Stadium. As a long standing resident of Basing Hill, I have seen the disruption, pollution and
traffic congestion increase since the stadium was built and, if I remember correctly, we
were told then that no further events would be approved. It now seems that you are
ignoring that promise and going ahead, regardless of the inconveience, health issues from
increased pollution and interest of your local residents.
The Wembley area has had so much poorly planned development that some residents are
finding the whole experience too much and moving away. I do not believe that people
should be driven from their homes to accommodate propery developers, or any other
developments, and increasing the number of event days will, certainly, add to residents
dissatisfaction with the area.
The original plans had a condition (condition 3) which limited the number of event days
until certain condition were met, for example the purchase of additional land. If you go
ahead with your plans and ignore your own stipulation for increased events, then you are in
breach of your own condition for the stadium.
I hope you will listen to the people whose lives will be affected by this proposal and
reconsider this proposal.

28 Uxendon Hill, Wembley Park, Wembley, HA9 9SL (Objects)

Comment submitted date: Wed 22 Mar 2017

I write regarding the Planning Application 17/0368, Event Day
Increase.
On "Event Days "Brent CounciCdo not enforce the no drinking zone
around^emStky and we have peojjk drinking and urinating in the
streets.
'The Buses and tubes are overcrowded on these days and I cannot
understandkow the counciCare wanting to aCQjw more of the same,
which is detrimentaCto the environment andfocaCresidents.
These days are not very well policed, and our streets are not safe.
There is littering everywhere.
'When I read through thej^aper you put through my door i noticed
that you said that in order to pass this appCication a sizeaBtk amount
of tandwouCdneedto Be Bought for roadirmprovements, I cannot find
anything to say that this Iknd is/has Been Bought and therefore ffaiC
to understand how you can put forward this pCanning application.
It is quite laughable that what is stated regarding Condition 33. This is
a road that 75% of the time the traffic on it is either crawCing or at a
standstiCC
Until such time as the improvements described in condition 3 are
implemented this application shouts not proceed
Please take this as my objection.

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