Flickr Image : David Breslin @ b3ta
Not content with having four very similar Planning Applications overturned previously in quiet, suburban Highams Park, London E4, (including one taken to a Public Inquiry), nothing seems to be able to stop Tesco trying again, with a remarkably unchanged plan for a mega-superstore with crowded urban-style blocks of adjacent flats.
Only this time it’s got a “travellator”, you know, the kind of moving walkway normally found at airports, to take you from the ground floor car park atrocity to the first floor store.
This is their attempt to design the plan into our hearts. But not even a brilliant architect can make a catwalk model out of this bloated parasitical plan :-
The local residents are up in arms, flexing their telephone dialling fingers, and furiously typing letters and electronic mails about this abomination of a Planning Application :-
If you yourself live in London E4, you can submit a comment on this plan yourself very easily on the Council’s website, quoting the Application Numbers 2008/1490 and 2008/1491 :-
Here is my letter to the Planning Officer.
To: Kevin Herring
Environment and Regeneration
Waltham Forest Council
London Borough of Waltham Forest
Re: Tesco Store Planning Application 2008/1490 and 2008/1491
15th August 2009
Dear Mr Herring,
I am writing to object to the Planning Application from Tesco Stores for the Jubilee Avenue/Larkshall Road site in Highams Park.
It is my view that this development would not satisfy the objectives of the complete planning strategy of the London Borough of Waltham Forest.
Any development pursued under the new Local Development Framework must incorporate full adherence to the objectives of the Sustainable Communities Strategy, the Climate Change Strategy and the direction of the overall Sustainability Appraisal.
Any plan accepted under this new Local Development Framework must also satisfy the requirements of the London Plan and the national planning guidance, including the reports of the Competition Commission and Ministerial direction.
1. The Plan Contravenes Borough’s Climate Change Strategy
The London Borough of Waltham Forest : Climate Change Strategy :-
The Climate Change Strategy clearly states : “The climate change strategy seeks to produce a scenario by which Waltham Forest can attain an 80% CO2 emissions reduction on 2005 levels by 2050 to mitigate climate change.” This covers all sectors : homes, workplaces, commercial, transport; not just the Council functions.
This policy is in line with the national Climate Change Act 2008 which sets Carbon Budgets for each Government Department and economic and social sector. The Carbon Budgets will be implemented as a series of gradually decreasing steps in Carbon Emissions, via a diverse raft of measures.
The logical conclusion is that no development should be permitted that creates an overall increase in Carbon Emissions.
The Borough’s Climate Change Strategy Executive Summary :-
The Climate Change Strategy Executive Summary makes clear that the Borough Action Plan should be to “Minimise the amount of consumption; Maximise the efficiency; Minimise harm from whatever remains.”
The proposed development would increase consumption of Energy in the Borough and so contravene the Climate Change Strategy.
Supermarkets rely heavily on road transport to manage the logistics of food delivery, sometimes transporting goods hundreds, or even thousands, of miles unnecessarily. Supermarkets use high levels of electrical power for heating, chilling and lighting their retail stores, far above normal household consumption for a similar size of buildings.
The added Carbon Emissions from this development would be attributed to the Borough and its citizens. In future, under international treaty and national law, we will all be required to reduce our local Carbon Emissions, or pay a tax (or buy a credit) to enable others to reduce their local Carbon Emissions.
By allowing this development with its inherent added Carbon Emissions, the Borough would be placing a future financial burden on the people who live here.
Let me give a parallel example : the people who live in the Borough are often reminded of the amount of packaging waste they dispose of; and we are required to pay for the collection and disposal of this packaging waste through our Council Tax.
But the source of much of this packaging waste is the wide array of supermarkets in the Borough, and it can be argued that it should be the responsibility of the supermarket companies to reduce their packaging of products in order to answer the problem. It would cost them little and save us a lot.
In the same way, if the Highams Park supermarket development were permitted as its plans indicate, the Borough as a whole would be made responsible for the Carbon Emissions of the supermarket by default, because there is no commitment from the developers to mitigate more than a minor proportion of the expected Fossil Fuel Energy use.
The citizens would end up paying extra Council Tax to meet the Carbon Bill of the new supermarket.
I do not think that any development should be permitted on this site unless the Developer makes explicit and contractual agreements to make this store completely Zero Carbon, (as Tesco have done in Ramsay, Peterborough).
I would strongly urge that at the very least this planning application is subject to Zero Carbon obligations on all transport of goods to and from the development, and include Zero Carbon requirements for the construction and operation of the development.
In the London-wide guidance from the Mayor of London, “The London Plan : Spatial Development Strategy for Greater London : Consolidated with Alterations since 2004” :-
We find these policies relating to Climate Change that should be addressed by any plan for Highams Park :-
“4.9 : Policies 4A.2 – 4A.16 include targets that developments should meet in terms of the assessment of and contribution to tackling climate change. The targets should be applied to developments in an integrated fashion so that the fullest and most appropriate contributions can be identified in the context of each particular proposal. There will be a presumption that the targets will be met…In all cases, the most important contribution will be to the achievement of reductions in carbon dioxide emissions.”
“Policy 4A.2 : Mitigating climate change : The Mayor will work towards the long-term reduction of carbon dioxide emissions by 60 per cent by 2050. The Mayor will and boroughs and other agencies should seek to achieve the following minimum reduction targets for London against a 1990 base; these will be monitored and kept under review: (*) 15% by 2010; (*) 20% by 2015; (*) 25% by 2020; (*) 30% by 2025.”
There is discussion of Renewable Energy technologies, in a preferential “Energy hierarchy” which should be used by any plan. Until recently, the inclusion of Renewable Energy is normally the only measure that new developments undertake, as is cited in Policy 4A.7 : “4A.7 Renewable energy Associated with energy assessments, major developments should show how the development would generate a proportion of the site’s electricity or heat needs from renewables, wherever feasible…”
But even applying the “Merton Rule” of 10% Renewable Energy, or the more ambitious 20% of the more recent national and London plans, this does not accord with the overall aim of Carbon Emissions reductions.
This proposed development would still be net Carbon Positive, even with its nicely designed “Renewable Energy Centre” powered by forestry and farming waste brought in by Heavy Goods Vehicle. A facility which may be judged “unfeasible” and drop out of the plan after outline planning permission is granted, to be replaced by a 24 hour petrol station competing with the garage across the street.
There is other guidance in the London Plan that would help make a development Zero or Negative Carbon, discussion of guidance for natural cooling, ventilation and passive solar heating, all of which should be incorporated in any plan, little of which seems to be included in the Highams Park plan under consideration :-
“4.27 : …Developments not initially incorporating solar technologies should, where practicable, be of a suitable design and orientation to support them later. Applications proposing prestige cladding should incorporate photovoltaics wherever feasible.”
“Policy 4A.10 : Overheating : The Mayor will, and boroughs should, strongly encourage development that avoids internal overheating and excessive heat generation and contributes to the prevention of further over-heating, especially where the urban heat island is most intense. Developers should demonstrate how development could be made heat resilient in design, construction and operation…”
“4.33 : Development should maximise opportunities to orientate buildings and streets to minimise summer and maximise winter solar gain; use trees and other shading; green the building roof, envelope and environs; maximise natural ventilation; expand green networks to create ‘breathing spaces’…”
“4.34 : Developments will need to be adaptable to allow for additional shading or cooling requirements as the climate changes. Certain building materials also have a role to play in reducing heat absorption…”
“Policy 4A.11 : Living Roofs and Walls : The Mayor will, and boroughs should, expect major developments to incorporate living roofs and walls where feasible and reflect this principle in DPD policies. It is expected that this will include roof and wall planting that delivers as many of these objectives as possible: (*) accessible roof space; (*) adapting to and mitigating climate change; (*) sustainable urban drainage; (*) enhancing biodiversity; (*) improved appearance. Boroughs should also encourage the use of living roofs in smaller developments and extensions where the opportunity arises.”
The documents for the London Plan include the Consultation of April 2009 by Mayor Boris Johnson :-
This sets an even steeper target for Carbon Emissions reductions, which should be met by the Borough taking into account all new developments :-
“In reviewing the London Plan the Mayor proposes to: (*) set challenging C02 emissions reduction targets to reflect the contribution the London Plan can make towards the wider reduction target of 60 per cent by 2025…”
The planning application from Tesco in its current form, if granted permission to proceed with development, would reverse, or totally wipe out, any other measures being taken to reduce Carbon Emissions in Waltham Forest.
2. Contravenes the Sustainable Communities Strategy
The Local Development Framework must be treated as fully integrated with the Sustainable Communities Strategy.
“The alignment of the LDF with the SCS will also provide a unified mandate for development management.”
The planning application under consideration would clearly impact the local economy because of its vast size.
The Borough’s Sustainable Communities Strategy :-
The Sustainable Community Strategy makes it an objective to “Retain more wealth in the borough”. When answering why this is important, the strategy says “it means people spending more of their income in Waltham Forest rather than elsewhere…”
Spending ones income in a big chain supermarket does not retain the wealth in the London Borough of Waltham Forest. Only a small part of the profits made from a supermarket would be returned in salaries to people living in the Borough. The rest of the profits would be returned to the supermarket shareholders, wherever they happen to live in the world.
The Sustainable Communities Strategy has the aim to : “Create wealth and opportunities for residents”. However, the “Full employment and increased prosperity” and “Higher skills levels” objectives could not be met by the small number of unskilled new jobs in supermarket retail from the proposed development.
It is not guaranteed that the business units incorporated in the plan would generate new employment as they are unlikely to host entirely new enterprises.
As the Sustainable Communities Strategy makes clear : “A sustainable community must be able to generate sufficient resources to sustain itself. Our residents have the huge advantage of living close to highly paid jobs and almost unlimited opportunities…However, the extent to which the borough is sharing in the wealth of London is very limited.”
The proposed development would not mitigate this issue, by design. Tesco is a multinational, transnational corporation whose wealth is managed outside of the control or influence of the Local Authority in Waltham Forest.
In its Sustainability Appraisal of its planning and policy documents :-
Waltham Forest has identified objectives that include “22. Improve the local economy by attracting inward investment”.
The problem with supermarkets is that although they are funded by “inward investment”, they also remove wealth from the area because they are not locally owned.
The most recent consultation on planning dated May 2009 from Margaret Beckett includes a reference to a report from the nef, the New Economics Foundation “Clone Town Britain”, which should affect judgement of this planning application :-
p95 Annex A : “We note in this context that the New Economics Foundation’s Clone Town Britain report, for example, flags the dangers of a failure to achieve a balance between multiple retailers and independent retailers, and the consequences that this can have for vitality and viability.”
The nef document “Plugging the Leaks” is worth consulting in regards to this :-
Here is the Clone Town report :-
From my point of view, Tesco offers unnatural and unhealthy competition.
The implantation of this very large development would make the supermarket the dominant retail player in the area. The management of Tesco supermarkets is so powerful that it can do such things as undercharge for essential food products in order to win customers, reduce its margins on goods that are sold by other local retailers, and can impose low-paying contracts on farming suppliers.
This makes the food look cheap to the consumer, but it is unfair trade in my view, and has negative ecological, economic and social impacts.
The scale of the supermarket planned for this development would be much larger than any other food retail outlet in the immediately local area, and backed by its national organisation and international funds, would find it very easy to “out-compete” with local businesses.
There is the obvious risk that this would damage the functioning of local businesses. The net result could be a reduction in variety and choice for the local food customer, the closure of local businesses and the resulting “Clone Town” would go against the Sustainable Communities objectives on diversity.
Tesco is already a destination for several London Bus routes, such as the 275 that goes to Barkingside from Highams Park.
I do not want to live in a Tesco Town, a town dominated by one retail giant, which takes wealth out of the area but doesn’t put wealth in.
3. Stress on Local Environment, Local Transport, Social Provision
The housing section of this development plan would draw over 250 new residential households into the area. There would be considerable added stress on the local schools, health services and transport, both public and private.
This development would rapidly and sharply increase the population of Highams Park without offering essential new services to cater for them. The new housing required in Waltham Forest should best be built or developed in dispersed locations to avoid such problems.
It appears that in this plan, much of the new housing required in the Borough would be co-located on one single site, highly detrimental to integration.
The supermarket section of this development would markedly increase local traffic and worsen congestion in the area. There would be a significant increase in Heavy Goods Vehicles in a residential area with several major schools and nurseries.
This would all have knock-on effects on air quality, health, road safety and the transit of essential emergency services.
All the people of Highams Park currently have enough to eat. We do not ourselves need more food provision. The supermarket would therefore only succeed by drawing retail from other Boroughs of London, as admitted by the plan’s designers.
Besides the traffic problems that this would cause, this will also inevitably affect cohesion and security of the local community, adding insecurity through the increased presence of people who do not live here.
I do not accept that the London Borough of Waltham Forest should be required to support the business activities of Tesco by allowing local environmental and social indicators to become negative.
The citizens of the Borough should be protected from worsening traffic congestion, worsening health prospects, degraded security and over-subscribed local cultural and health services.
The London Plan is specific about Air Quality. In the London-wide guidance “The London Plan : Spatial Development Strategy for Greater London : Consolidated with Alterations since 2004” :-
page 232 :-
“6 Improving air quality : Policy 4A.19 Improving air quality : The Mayor will, and boroughs should, implement the Mayor’s Air Quality Strategy and achieve reductions in pollutant emissions and public exposure to pollution by: (*) improving the integration of land use and transport policy and reducing the need to travel, especially by car (see Policy 3C.1)…(*) ensuring at the planning application stage, that air quality is taken into account along with other material considerations, and that formal air quality assessments are undertaken where appropriate, particularly in designated Air Quality Management Areas; (*) seeking to reduce the environmental impacts of transport activities by supporting the increased provision of cleaner transport fuels, including hydrogen, particularly with respect to the refuelling infrastructure…”
The London Plan Consultation of April 2009 is also concerned with tackling traffic congestion, from businesses as well as private vehicles :-
“Freight : 177 : The Mayor believes that an efficient logistics system and related infrastructure is essential to London’s competitiveness, and that the new Plan should facilitate freight distribution in a way that minimises congestion and any adverse environmental impact…”
These very serious transport-related issues have not been properly and completely addressed by the Planning Application under consideration.
4. A Full Impact Test is Required before Planning Consent
The Waltham Forest Local Development Framework will not be fully adopted until 2010. Yet this does not mean that any development agreed before then can forego meeting the environmental and social objectives in the Local Development Framework.
Consultation on the Government’s Planning Policy Statement PPS4 and PPS6 Consultation document should therefore be taken as meaning that a full impact test will be needed for any new development :-
page 67 : “In terms of assessing overall impact, it is important to bear in mind that the proposed changes only affect new development not in accordance with an up to date development plan…”
So, in other words, a full impact test is required by any planning application made now in Waltham Forest, while the local development plan is being finalised. It would require detailed reports and assessments on projections of local traffic congestion, air quality, Carbon Emissions, quality of life and public safety as a minimum.
Until now the reports on Traffic, Air Quality and Economic Assessments connected with the Planning Application under consideration are inadequate for a Full Impact Test in my view.
5. Local Food Production
There is evidence that there has been poor management of the land considered under this Planning Application.
Tesco contractors have bulldozed the buildings that were previously on the site, and have left the land fenced off and unused, thereby devaluing it, having taken it out of economic activity.
My recommendation for the land is that it should be compulsorily purchased from Tesco at a preferential price, to provide for the real needs of the community, as determined by the commuity, and not an international retail business, according to the Planning and Compulsory Purchase Act of 2004 :-
The disused land currently owned by Tesco would I feel be best used as space for local businesses, including those facilitating local food production and provision from the Greater London area :-
From the Mayor’s London Plan :-
“3.130 : Boroughs may also wish to consider measures to promote land ownership and long-term community involvement in the ownership and management of public and other facilities, in line with the recognition of the advantages of asset-based community regeneration.”
page 205 : “Policy 3D.18 Agriculture in London : The Mayor will and boroughs should seek to encourage and support a thriving agricultural sector in London. Policies in DPDs should provide for the protection of the best and most versatile agricultural land in accordance with national guidance…Such policies should be consistent with the other policies of this plan, such as having regard to sustainable development and transport, tackling climate change and the presumption against inappropriate development in the green belt.”
“3.326 … The development of farmers’ markets in London is one good example of this. In accordance with national guidance, appropriate farm diversification should be encouraged, particularly where wider community and environmental benefits would result. Examples include protecting landscapes, the production of bio-fuels and promoting access and enjoyment. The cultivation of bio fuels can both assist in addressing climate change and contribute to the agricultural economy.”
I can imagine the land being used to accommodate buildings for a food cooperative, weekly fresh food markets sourced from local farms, and food-related small enterprises, such as a garage for bicycle delivery schemes.
I trust that the Planning Committee will reject this [ over-sized, energy-hogging, congestion-inducing retail and rabbit-hutch housing ] application from Tesco.
We deserve better.
Ms J. Abbess BSc
Related articles from The Guardian newspaper :-