Re: planning application MO/2012/0234
Tesco have submitted a revised planning application for a supermarket in the centre of Ashtead. Part of the application relates to parking and traffic generation, which is set out in the Transport Assessment contained within the application.
Following the rejection of the previous two planning applications by Tesco (MO/2008/1127 and MO/2009/1322), Tesco appealed the decisions. On appeal, the Planning Inspector refused the first application, but allowed the second application with the condition (inter alia) that no development should take place until arrangements have been made for the relocation of the 74 long-term parking spaces in the APMH car park.
The analysis below shows that Tesco have understated the additional parking demand that would be generated by the proposed supermarket, and that the shortfall of parking spaces due to this application is higher than that identified by the Planning Inspector when allowing the appeal for the previous application.
In the Planning Inspector’s report, he made the following statements in relation to parking:
- “But of course Ashtead Peace Memorial Hall car park is already shared by others, many of whom have prior claims upon it.”
- “That still leaves the crucial question of what to do about displaced long-term parking spaces. … There is no immediate answer. I saw for myself that there is limited space at Grove Road car park, and that kerb-side parking already contributes to congestion in and around The Village. The Character Appraisal confirms it. Any heavy and additional burden of kerbside parking would be unacceptable.”
- “If existing long-term parking is removed, it is evident that the car park could provide enough short-term spaces day to day, even during medium to large events at the Memorial Hall. The total, agreed for the purposes of the final scheme, would be 181 car parking spaces. This capacity would rarely be stretched.”
- “On that basis, the proposed supermarket should provide a maximum of 102 parking spaces (including employees’ spaces, and those reserved by condition for disabled).”
- “On the basis of available evidence, the shortfall would amount to 74 parking spaces. I conclude that permission should be granted only on condition that development is not commenced until proper provision has been made for the relocation of 74 long-stay parking spaces to mitigate the problems of further on-street parking, and to ensure adequate short-stay parking for the supermarket, those attending Peace Memorial Hall [sic] and for other users of Ashtead centre.”
As a consequence of the above, the Inspector imposed the following condition on the allowed planning application:
- “No development hereby permitted shall commence until the District Council has confirmed in writing that it has made arrangements for the relocation of the existing 74 long stay parking spaces in the Peace Memorial Hall Car Park and that all 181 proposed parking spaces shall be short stay spaces to be retained thereafter.”
In summary, the Planning Inspector found that the shortfall of parking spaces in planning application MO/2009/1322 was 74 spaces, and that this shortfall would have to be made good prior to the proposed supermarket being developed.
Parking calculations in new application
Tesco’s new planning application is for a supermarket with Retail Floor Area of 685 sq.m., a 9% reduction on the previous supermarket size. Tesco have undertaken revised parking calculations to seek to demonstrate that there will be sufficient parking, and this is set out in the Transport Assessment.
The revised calculations have a number of errors, as set out below.
- Hascombe House Development
The Officers’ Report for planning application MO/2006/0494 identified an additional demand of 30 spaces in the APMH car park from the extended Hascombe House, and this has been omitted from Tesco’s calculations. This parking need was recognised by the Planning Inspector.
- Curry House
The additional parking demand of 8 spaces in the APMH car park from the approved extension to The Curry House (planning application MO/2009/0963) due to the loss of existing spaces has been omitted. This parking need was recognised by the Planning Inspector.
- Linked trips
Section 9.2(2) of the Transport Assessment refers to linked trips, and that Tesco estimate 20% of trips will be linked trips. By this, Tesco mean that 20% of the trips to the proposed supermarket will be linked to existing trips to other shops in The Street. This is completely at variance with what was stated in the planning application MO/2009/1322, where linked trips were new trips to the proposed supermarket that would generate linked trips to other shops, thereby creating additional trade for the existing shops. Furthermore, whereas it is understood that trips linked to existing trips will not create additional traffic movements, it is quite clearly nonsense to suggest that such linked trips will not generate additional parking demand, since shoppers will need additional time in order to visit the Tesco supermarket as well as the shops they were already visiting. Therefore, the 20% reduction in parking demand due to link trips is invalid, and needs to be removed.
The Planning Statement at paragraph 5.12, and the Retail Assessment from
MO/2009/1322, on which Tesco relies for this application, both state that shopping trips to the Tesco supermarket will generate linked trips to other shops. There is therefore a need to make an allowance for the additional parking duration of these linked trips, and it therefore seems reasonable to use Tesco’s figure of 20% linked trips, but to add this as additional parking demand.
- Duration of stay
Paragraph 5.10 of the Planning Statement states “Customers generally spend around 20 minutes in the shop”, which contradicts the statement at paragraph 9.2(4) of the Transport Assessment, which states “with the duration of stay (including visits to other shops) of around 20 minutes”.
Tests have been conducted of how long it takes from arriving in a parking space, including the time to purchase the parking ticket, return to the car to leave the parking ticket, and walk to the proposed supermarket, and likewise for returning from the supermarket to the car park.
|Car park||Time from parking to supermarket||Time from supermarket to leaving|
|APMH||3 minutes||2 minutes|
|Grove Road||4½ minutes||3 minutes|
These figures show that somewhere between 5 and 7½ minutes, say 6 minutes, needs to be allowed on top of shopping time in the supermarket for the total parking duration. If 20 minutes were to be the total parking time, as suggested in the Transport Assessment, then this would leave 14 minutes for both the shopping in Tesco, and the time for visiting other shops. This is highly unrealistic, and so the figure of 20 minutes from the Planning Statement for the time in the proposed supermarket should be used.
The addition of the 6 minutes to the 20 minutes adds an extra 30% to the total parking time.
- Staff parking
Tesco have identified that 20% of the trips to the supermarket will be the new style linked trips, i.e. 20% of the trips to the new supermarket will be linked to existing trips. At paragraph 8.12 of the Transport Assessment, Tesco state that this will result in a 20% reduction in the number of trips generated, and take the 20% reduction into account in their calculations. For the 20% reduction to apply to the number of trips, all the trips must be customer trips, since linked trips have no effect on staff journeys. The only conclusion that can be drawn is that the trip rates, and hence parking demand, do not include staff journeys and parking, and that therefore due allowance for these must be added.
Planning Statement paragraph 3.31 states that the proposed supermarket will provide employment for approximately 60-65 staff, and Tesco have stated that up to 50% of the staff will be working at a time. Paragraph 7.9 of the Travel Plan states that 72% of people working in Ashtead Village ward drive to work, and Tesco use this figure for the proportion of staff that will drive to work. Allowing for 30 staff to be working at once, and 72% of these to drive means that parking for 22 staff needs to be provided. However, this figure does not take into account the additional parking that would be needed at shift change times, nor that driving rates are likely to be higher for non daytime employment. The figure of 22 must therefore be taken as an under-estimate of actual need, and would need to be increased for any “robust” calculations.
Furthermore, Tesco have taken no account of the approximately 5 or 6 spaces staff parking spaces they have arranged (see below), which further reinforces that the parking figures do not include staff parking.
- Staff parking (5/6 spaces)
Paragraph 5.16 of the Planning Statement states “Tesco are pleased to confirm they have arranged a private agreement with a local business for approximately 5 or 6 spaces ”, and paragraph 3.62 states similarly “Tesco are pleased to confirm that they have managed to secure a private agreement with a business in the Street which has parking to use 6 spaces for Tesco staff .”
Not only do Tesco appear to be uncertain about the number of spaces, but the lack of information about the location and the nature of the agreement means that there can be no certainty that the spaces would continue to be available in the medium to long term. For example, these spaces might be the spaces behind The Curry House (which currently has parking for about 8 cars), but the approved development of new flats behind The Curry House means that those spaces will be lost.
Based on the above, and the fact that Tesco have not taken them into account in their calculations, it would be unsafe to make allowance for those spaces now.
Revised parking calculations
Tesco’s calculations show that when there is not event at the APMH car park, on a weekday there will be a minimum of 81 public parking spaces available in the village. The table below shows the adjustments that need to be made due to the issues identified above.
|Reason||Reduction in available spaces||Net available spaces|
|Hascombe House demand||30||51|
|Curry House displaced spaces||8||43|
|Correction of “new style” linked trip parking||14||29|
|Additional linked trip demand||14||15|
|Addition of 6 minutes parking time (30% x 57)||17||-2|
The above shows that, far from there being at least 81 available spaces when there are no events in the APMH, there will be an over demand of 24 spaces at the peak time, and an excess of demand over supply throughout the middle 4 hours of the weekday.
The addition of parking demand for a medium sized event, such as the Ashtead Flower Arranging Group, which creates an additional demand of approximately 48 spaces, results in a shortfall of 72 spaces. For a large event, such as ADFAS, the over demand would be even greater.
Comparison to previous application
At appeal, the Planning Inspector allowed MO/2009/1322 on the condition that an additional 74 parking spaces were provided.
The current application does not seek to extend the APMH car park as was previously the case, and this results in a loss of the 24 additional spaces that were previously to have been provided.
The previous application showed that the SCC2 traffic profile created a peak parking demand of 62 spaces, whereas Tesco state in the current application that the generated parking demand is 43 spaces. This is a reduction in demand of 19 spaces.
The effect of these changes is that 19 fewer spaces are required, but that 24 fewer spaces are to be provided (thereby creating a further increase in demand over availability of 5), and therefore the overall need for additional parking spaces increases by 5 from 74 to 79.
This is consistent with the approach taken in the previous section showing a shortfall of 72 spaces, and that therefore, these analyses taken together must represent a sound analysis of the true parking situation.
Parking Standards Requirements
Current parking standards for food retail developments in excess of 1000 sqm Gross External Area are 1 space per 14 square meters. Based on a Gross External Area of 1,370 sqm in the current proposal, the requirement is for 98 car parking spaces. Although the proposed Dorking Lidl development (MO/2011/1307) was recommended to be allowed with fewer spaces than the standard sets out (see Officers’ Report 16/12/2011 paragraphs 8.6.2 to 8.6.6), since Lidl as a deep discount store has a lesser need for parking spaces, the Officers’ Report specifically sets out the need for 1 space per 14 sqm in relation to supermarkets like Tescos and Sainsburys.
Tesco’s application states a need for 43 spaces for the currently proposed supermarket, but when that figure is corrected by the reinstatement of the 14 removed linked shopping spaces, the addition of 17 spaces to allow for the additional 6 minutes parking time and the 22 spaces for staff parking, the total need becomes 96 spaces, which is extremely close to the 98 spaces based on the parking standards (the 14 spaces for the additional linked shopping have not been included, since that is not parking for Tesco purposes, although it is additional parking demand generated by the proposed development).
That the figure of 98 spaces identified by the parking standards is such a close match to the parking needs analysis undertaken above gives very strong credibility to the calculations and further verifies that Tesco have significantly understated the parking requirements, by some 56% over the overall need, or alternatively the need is more than 2¼ times the figure Tesco states.
The 3 different methods of analysis above, which all give a very similar result, demonstrate that Tesco have significantly underestimated the additional parking demand that would be generated by the proposed supermarket. The additional parking requirements for this proposal, due to the removal of the 24 additional spaces, is now higher by 5 spaces than the 74 spaces identified by the Planning Inspector in respect of the previous application, and the planning application should only be granted if it is conditioned that approximately 80 extra parking spaces are provided.
P Quentin Armitage
BA Hons (Oxon) Mathematics