Executive Summary of Objections at 9th July 2012 to:
MO/2012/0234 PLAMAJ – Proposal for Tesco Metro, Ashtead Village
This provides a summary of the objections, with links to the more detailed objection letters and data where the full analysis is laid out. An appendix also lists all these detailed objections with links.
1. SIGNIFICANT ERRORS IN TRAFFIC FLOW RATES ON THE A24 THROUGH ASHTEAD AND IMPACT ON THE ALREADY SUBSTANDARD WOODFIELD LANE/A24 JUNCTION – Contravenes MOV2 (MVDC Local Plan 2000).
There are two significant issues with the traffic flow rates in Tesco’s application:
- The A24 at Ashtead is currently operating at significantly above Surrey County Council’s evaluated capacity (‘Transport Statistics for Surrey, Movement and Monitoring Report’ 2008).
- Tesco has made a significant number of errors in assessing the traffic impacts at the already sub-standard Woodfield Lane/A24 junction. The cumulative impact of these errors is that Tesco understates the additional traffic resulting from the development at the junction by Tesco by 60%.
Tesco’s errors are:
- Understatement of current traffic flows.
- Incorrect forecast for future years.
- Underestimate of additional traffic resulting from the development.
- Incorrect PICADY modelling of the junction, i.e. for a wider rather than narrower road.
- No allowance for goods vehicles.
Each of these issues results in Tesco’s figures being far more favourable than they should be. This would introduce significant safety and congestion issues at the already dangerous junction. We have provided photographic evidence of existing problems at the junction.
Tesco acknowledge that there is already peak hour congestion along the A24, but claim to demonstrate that the additional traffic and reduced junction capacity will not cause any traffic flow problems. This is clearly a contradiction.
Our analysis shows that the figures for traffic flows on the A24 in Tesco’s application are lower than the figures published by SCC in its document ‘Transport Statistics for Surrey: Movement Monitoring Report 2008’. Thus, the credibility of the traffic flow figures in Tesco’s application is once again questionable.
The reports produced by Tesco from its PICADY analysis should not be relied on to demonstrate that the junction will operate safely if Tesco’s application is approved.
|Links to Detailed Objection ReportsSAVE Objection No. 2: Tesco’s Underestimation of Traffic Need Based on Surveys at Existing Stores|
2. INSUFFICIENT CAR PARKING IN ASHTEAD VILLAGE – Contravenes MOV2 (MVDC Local Plan 2000)
Tesco have provided no customer parking and only 5 spaces for staff parking in a secret location although 30 staff will be working in the store at any given time.
We have carried out parking analysis across all of the parking available in the village and compared with Tesco’s submission. Tesco claims that even at peak times there will be at least 28 parking spaces available. However, Tesco’s figures palpably misrepresent the actual position, which will be a shortfall of 100+ spaces. Our conclusion has been proved by three different methods of analysis, all of which produce similar results. The three methods are:
- The identification of, and appropriate adjustments made for, numerous significant errors and omissions in Tesco’s figures,
- A comparison to Tesco’s previous application (where the Planning Inspector imposed a condition of 74 extra parking spaces in addition to the 24 additional spaces that Tesco was providing through a car park extension), and
- By reference to current parking standards for food retail developments.
It is important to note that the analysis takes into account:
- parking across the whole of Ashtead village i.e. the APMH car park, the Grove Road car park and on-street parking; and
- the reduced parking time estimated for top-up shopping, as this is now a basket store.
Lack of parking was a key condition from the Public Inquiry on Tesco’s previous proposal. The Planning Inspector imposed a significant condition that an additional 74 spaces were required before the store could proceed.
Our analysis shows that this position has worsened as demand will significantly exceed space available by even more than 74 spaces. Moving long term parking to Grove Road will not mitigate the shortfall.
Errors in Tesco’s parking figures include:
- Tesco understates existing parking demand. We have carried out Car Park Counts in March 2012 across the APMH and Grove Road car parks. This provides up-to-date parking data. Tesco’s data was collected at least three years ago. Use of this updated data changes Tesco’s conclusion regarding car parking availability.
We have provided photographic evidence of the current parking at near and full capacity in the APMH car park in April and May 2012.
- Tesco omits known future demand for long-stay parking, including 22 spaces for its own staff.
- Tesco significantly underestimates vehicle trips/customer parking demand from the store.
- Extensions to the APMH car park proposed previously are no longer to be carried out.
In addition, there are significant contradictions in Tesco’s assumptions. The method that Tesco uses to generate trip rates in this application directly contradicts the methods they use in other planning applications lodged elsewhere, e.g. Stoke-on-Trent. These trip rates are used by Tesco to generate parking demand. If the assumptions used in this proposal are replaced with Tesco’s own assumptions for other applications, then traffic generation for this store is shown to be underestimated by 40%. This evidence raises serious questions about the credibility of Tesco’s parking figures. Tesco’s analysis from other stores results in similar conclusions to our own analysis.
Our conclusion is supported by survey evidence that shows that Tesco habitually underestimates traffic generation and parking need. Traffic counts carried out at Tesco stores that have already been built demonstrate that traffic generated (and hence parking need) is much higher than the figures Tesco use in their planning applications. In some stores, the resulting traffic has been shown to be as great as 4 times higher than Tesco predicts in its planning applications.
The very significant difference between Tesco’s parking figures and those resulting from the counts/detailed analysis outlined above brings into question the credibility of Tesco’s parking figures as a sound basis for determining there will be no parking problems from its proposed store. The Planning Inspector confirmed that there is no capacity to absorb any further on-street parking. The counts/analysis demonstrate that severe parking problems in Ashtead village and an inevitable huge increase in on-street parking will arise if Tesco’s application is approved.
|Links to Detailed Objection ReportsSAVE Objection No. 2: Tesco’s Underestimation of Traffic Need Based on Surveys at Existing Stores|
- FAILURE TO MEET MVDC AND NATIONAL SUSTAINABILITY TARGETS – Contravenes CS19 (MVDC Core Strategy, October 2009)
All new developments must meet certain specific targets for environmental sustainability set by the Government and MVDC (Policy CS 19.1). It is understood the majority of developers do so, and we understand that MVDC required recent supermarket developments in Dorking to meet the targets. However, Tesco’s current application (and in fact its previous application) does not meet these targets. Instead, Tesco relies upon the submission of evidence to demonstrate that “compliance is not technically … achievable having regard to the type of development involved and its design” (Policy CS 19.2).
The Planning Inspector’s decision to approve (subject to conditions) Tesco’s previous application does not set any kind of precedent for the current application. He did not determine MVDC should not require Tesco to comply with CS 19.1. He did not determine that MVDC could not require Tesco to comply with CS 19.1 in relation to any future application.
Tesco’s current application should comply with CS 19.1. MVDC should therefore not grant an effective exemption from environmental sustainability targets to Tesco under CS 19.2. Tesco would be able to meet the specified targets if the size of the development were to be reduced.
|Links to Detailed Objection ReportsTransition Ashtead: Objection to the Tesco Metro Proposal for The Street, Ashtead|
4. DELIVERY VEHICLES AND PEDESTRIAN SAFETY ISSUES
Diagrams contained in Tesco’s application show that articulated delivery vehicles cannot avoid mounting the kerb or overhanging the pavement in front of and to the side of the proposed store in order to enter/exit the narrow access lane off the A24/The Street. These manoeuvres imply that the access lane is not wide enough for the size of vehicles proposed by Tesco. This raises serious pedestrian safety issues and will increase traffic congestion on the A24. Phillip Rust, Tesco’s transport consultant, confirmed this at a meeting with SAVE and others on 23rd February 2012.
To overcome these problems, Tesco should:
- Considerably increase the width of the access lane; or, preferably
- Construct a purpose built entrance/exit of suitable width directly into its own site from The Street. Thus all delivery/service vehicle activities can be contained within Tesco’s own site. This would help to alleviate residents’ concerns arising from the noise of manoeuvring vehicles at the store’s delivery/service area immediately adjacent to residences at the rear of the site.
|Links to Detailed Objection ReportsPCRG Submission No 2: Various Issues, including Section 6 (Pedestrian Safety)|
5. LOSS OF COMMUNITY FACILITIES CONTRARY TO MVDC POLICY CS 17 – Contravenes CS17 (MVDC Core Strategy, October 2009)
Policy CS 17 of MVDC’s Core Strategy states that “the Council will resist the loss of key services and facilities (including community facilities)”. There can be no dispute that the Ashtead Peace Memorial Hall (APMH) and the adjacent APMH car park are key community facilities. APMH is at the heart of Ashtead community life and is heavily used by numerous groups and for events. The hall has recently been improved (planning application number MO/2009/048, approved 8th October 2009) to make it more attractive to users, which has increased demand even further. The planning application states that “utilisation of the complex is very high and a number of the meetings fill the adjacent car park to capacity”. It is important to note that this improvement to the APMH has occurred since Tesco’s previous application.
Tesco’s proposal would frequently result in no available parking for APMH users due to the demand for parking from customers/staff of the store. This is clearly shown from our Car Park Counts and Parking Analysis. This would inevitably result in a reduction in use of the APMH and threaten its viability. The parking conflict between APMH users and Tesco’s customers/staff will occur throughout the day and evening as parking need for the APMH is not limited to a specific time.
Links to Detailed Objection Reports
- CONTRAVENTION OF ASHTEAD VILLAGE S5 LOCAL SHOPPING Centre Boundary in THE Mole Valley Local Development Framework Proposals Map, adopted October 2009
The Mole Valley Local Development Framework Proposals Map designates the older Ashtead Village Shopping Centre astride the A24, as where policy S5 of the Mole Valley Local Plan (2000) and policies CS1 and CS2 of the Mole Valley Core Strategy apply.
Policy S5 (MV Local Plan p. 119) relating to Ashtead shopping centre(s) as defined on the Proposals Map states that “proposals involving minor (our italics) increases in shopping floor space in relation to the centre as a whole, will be permitted”. We understand that when the Proposals Map was adopted in October 2009 , MVDC knew that the old Esso site had been purchased by Tesco with intent to develop a supermarket. (Tesco submitted their first proposal in August 2008). However, MVDC only designated the front portion of the site as retail. This indicates a guideline for the size of any proposed store. The boundary of the S5 local shopping centre clearly cuts right across the old Esso site, dividing it approximately in half, i.e. excluding the more northern half of the site from S5 Local Shopping Centre. However, Tesco’s current proposal uses the entire site for retail.
This contravention by Tesco demonstrates that their current proposal is far too large for the site. The S5 map supports our recommendation for a much smaller store i.e. on the front part of the site only.
Links to Detailed Objection Reports
7. NEGATIVE RETAIL IMPACT ON LOCAL FOOD SHOPS & THEIR PROTECTION WITHIN MVDC’S CORE STRATEGY – Contravenes para 6.2.23 of MVDC Core Strategy ”Vision for Ashtead” (October 2009)
Tesco’s proposal directly contravenes MVDC’s Core Strategy Vision for Ashtead, which includes “making provision for an increase in convenience shopping floor space that is appropriate to the scale, nature and function of the centre and complements its existing provision”, wording which is clearly designed to protect Ashtead from inappropriate convenience (food) retail development.
Tesco’s proposal would have a substantially worse retail impact on Ashtead village than Tesco’s previous application. This is because this store is now basket-only for top-up shopping, not a main food shopping destination as in their last proposal. Tesco’s application makes it clear that the store now proposed is very different from previous applications in that it is primarily aimed at capturing top-up shopping from local residents.
Since it is accepted that the turnover of the existing village food shops consists almost entirely of top-up shopping by local residents, what Tesco is actually saying is that the turnover of the new store is intended to be captured from the existing local food shops. The question is, how much turnover will the existing local food shops lose to the proposed Tesco store?
An analysis prepared by PCRG concludes that the existing local food shops will lose approximately 45% of their turnover to the proposed Tesco store. This analysis uses the methodology adopted by MVDC’s own consultants (R Tym & Partners 2007 report) in relation to Tesco’s two previous applications. This will inevitably lead to closure of the existing local food shops.
The word “complements”, which is a crucial part of MVDC’s strategy for Ashtead, is defined as ‘completes or makes perfect’ or ‘adds to (something) in a way that enhances or improves it’. If the existing food shops close as a consequence of the store, how can it be said to add to and improve the existing food shopping floor space when existing food shopping floor space will disappear?
|Links to Detailed Objection ReportsSAVE Objection No 9: Retail Issues in Relation to Contravention of Mole Valley Core Strategy 2009 for Ashtead Village|
8. NOISE LEVELS
Overall noise levels will be greater than in the previous proposal because of (i) new office and residential developments adjacent to the site and (ii) lorry reversing manoeuvres into the delivery/service area at the rear of the store caused by the new access arrangements.
There is at present little or no noise in the residential premises adjacent to the rear of the Tesco site, including Pound Court and the new residential (and office) development at Hascombe House (built since the last Tesco proposal) from commercial activities elsewhere in Ashtead village. There is also minimal ambient noise.
The proposed store will result in significantly increased peak and ambient noise levels and fumes in adjacent residences, due to:
- Customer and staff parking
- Delivery/service vehicles reversing.
Since Tesco’s previous application, new planning applications have been submitted for:
- Residential units at the rear of the Curry House (approved on appeal).
- Conversion of offices on the 1st floor of Hascombe House into residential units (awaiting decision).
Both these residential developments will be situated only a few metres from the delivery/service area and will suffer significant disturbance from noise and fumes, particularly at noise-sensitive times in the early mornings and evenings.
|Links to Detailed Objection ReportsSAVE Objection No 8: Noise Levels|
9. VIEWS OF ASHTEAD RESIDENTS AND TRADERS
Despite claims to the contrary in its planning application, Tesco made no attempt at genuine consultation with residents prior to submission of its application. In meetings with SAVE, Transition Ashtead and PCRG, Tesco simply presented its application, discussed its contents and answered questions. The same approach was taken at the subsequent public exhibition. Tesco’s application was lodged within days of the latter.
Since residents have become aware of the details of Tesco’s application, they have clearly and consistently expressed their views. By 6 July, MVDC had received approximately 840 letters of objection (and only 25 in support). 97% of representations object to the proposal. The overwhelming majority of representations (90%) come from Ashtead residents.
This level of opposition supports the views expressed by 2252 residents who responded to a survey by the Ashtead Residents’ Association in December 2010 when:
- 96% considered that Grove Road should continue to be available for short-term parking;
- 91% considered that long stay parking needs should continue to be provided in the APMH car park;
- 78% believed that any new retail development should be restricted to a small convenience store.
45 Ashtead traders and businesses have submitted a petition opposing Tesco’s proposal, which includes 24 businesses in The Street. The petition covers Ashtead’s three retail areas, i.e. The Street, Craddocks Parade and Barnett Wood Lane (the latter two in Lower Ashtead). At least 12 traders have submitted individual objection letters.
The traders object on the grounds that the development “is still too large for the site because:
- It would adversely affect the financial viability of the businesses due to :
- direct retail competition from a large multinational supermarket that is predicted to take trade away from many local businesses from all three retail areas;
- inadequate parking availability in the village making it difficult for customers/clients to find somewhere to park and therefore discourage them from using the existing local shops and businesses;
- inadequate parking at the Ashtead Peace Memorial Hall Car Park which services the Hall events, which could lead to loss of visitors to the Hall and therefore to businesses in The Street.
- It would destroy the unique character and village environment of Ashtead, especially if independent shops were forced to close.
- Increased traffic congestion in The Street and resulting increased danger at the Woodfield Lane/A24 junction could drive existing customers/clients away, to shop and use businesses outside Ashtead.
- Probable increases in rents and business rates.”
The stores most concerned by the proposal include those with which Tesco would directly compete. These thriving businesses are at the heart of Ashtead’s village character. This is acknowledged in the Roger Tym 2007 report that largely underpins MVDC’s Core Strategy. In contrast, a much smaller Express store would encourage complementary shopping. One of the reasons that Craddocks Parade thrives is that the Tesco Express there complements existing local shops such as the butcher, greengrocer, baker and wine merchant.
Links to Detailed Objection Reports
The overwhelming majority (97%) of representations from residents to MVDC oppose Tesco’s current application. They feel that this store is too large for Ashtead village and have indicated that a smaller convenience Express-type store would be more appropriate. On-site parking would help to cope with parking demand.
Detailed analysis of Tesco’s current application has identified numerous instances of errors and omissions. The magnitude and frequency of these errors and omissions destroy the credibility of Tesco’s application and, of themselves, provide ample reasons for refusal of the application due to severe negative impacts on parking and highways.
The detailed analysis of the application has produced a number of additional reasons why MVDC should refuse the application.
The matters identified in the analysis are of such consequence that it is essential they are fully addressed in the Planning Officers’ written report so that Members of the DCC and Ashtead residents can be satisfied that the matters have been appropriately dealt with in the planning process.
For the reasons identified and analysed in detail and summarised above, in our opinion it is apparent that Tesco’s planning application MO/2012/0234 PLAMAJ should be refused.
APPENDIX – LINKS TO OBJECTIONS AND SUBMISSIONS REFERRED TO IN THE EXECUTIVE SUMMARY
All of the documents listed below are on the Mole Valley District Council Planning website.
POUND COURT RESIDENTS GROUP Submission 2 – Various Issues including Parking, Traffic Noise, Retail, Impact on Community Facilities, Pedestrian Safety, Size of Store, Lack of Consultation, Sustainability
9th July 2012