Written evidence submitted by Sophie Howard et al

1. Introduction – Who We Are

1.1.  Our evidence relates to the Royal Borough of Greenwich (“RBG”), the Greater London Authority (“GLA”) and the Mayor of London, Boris Johnson.

1.2.  We are residents of the Royal Borough of Greenwich, giving up our spare time to hold Greenwich Council, Boris Johnson and the GLA to account for a series of decisions with potentially very serious implications for our neighbourhood which borders on to the UNESCO World Heritage Site of Greenwich Park, home to the Meridian Line and the Royal Observatory, so iconic a feature of the 2012 Olympics’ equestrian events.

1.3.  Greenwich is a place of historical extremes, from Greenwich Park, likened to Versailles and the birthplace of Henry VIII to the O2, formerly the “Millennium Dome”, built to commemorate entry to the 21st Century. These two extremes sit within 1-2 miles of each other along the River Thames. We live in different parts of the borough, two of us in East Greenwich, one in Greenwich Millennium Village on the Peninsula, and another further east in Plumstead.

1.4.  We are proud of our neighbourhood, in which we have all lived for many years. One of us was born in the borough and we are raising our children here.

1.5.  However, the greatest problem Greenwich faces is traffic, which separates our communities. One resident of Greenwich Millennium Village recently commented that it takes as long to cover the 1 mile distance from Greenwich Peninsula to Greenwich town centre as it does to travel to the West End.

1.6.  We are concerned at recent planning decisions made by RBG, and endorsed by the GLA and Boris Johnson. These decisions are likely to cause traffic gridlock in Greenwich, with further impact on air quality which is already very poor in many parts of the borough. We have the support of several councillors and local residents associations who share our concerns. Our evidence relates to three recent connected developments and proposals in Greenwich which we present as a case study for the Committee.

2. Executive Summary

2.1.  In RBG, developers and retailers have become adept at using national and regional planning policies to their own advantage, to maximise development to the detriment of the local environment.  Unfortunately, these planning policies, or RBG and GLA’s interpretation of them, are producing the unfortunate side effect of increasing congestion and pollution in the most congested parts of RBG. In particular, national policy aimed at regenerating town centres has been interpreted by RBG and GLA in such a way as to invite retail giants to construct superstores in town, encouraging more traffic into town.

2.2.  RBG and GLA apply policies across the board, paying insufficient attention to differences between retail models. Developers are able to submit reports which quote at length from policies which support the accessibility of public transport. RBG and GLA then base decisions on public transport accessibility ratings (referred to by the acronym PTAL). They accept ambitious targets for the use of public transport as a basis for estimating traffic generation without sufficient evidence that customers will in fact use public transport to visit these retailers.

2.3.  We have carried out a detailed analysis of a recent Transport Assessment submitted on behalf of one developer in RBG and can provide evidence on how this was manipulated to produce the developer’s desired outcome of satisfying RBG and GLA that their scheme would have no impact on traffic or air quality. Long reports full of tables and manual traffic counts give the appearance of science, but are in fact only as reliable as the assumptions which underlie them. These assumptions need to be tested with common sense, local knowledge and also reference to the impact of other similar schemes. In our view, RBG and GLA are no match for developers who drown them in paper work which the planners have to digest in a matter of weeks.

2.4.   Developers and retailers appear to be able to satisfy RBG and GLA of their commitment to public transport by providing low-cost installations, such as bike racks, and offering to make payments in “mitigation” should public transport targets not be achieved.  Developers and retailers are being measured on steps they take to “promote” public transport, with no consequences if customers travel by private car, leaving local communities to suffer the consequences and ultimately the tax payers to pay for extensions to the road network to cope with over-development.

2.5.  This is particularly inappropriate in RBG, which is an AQMA, where recent readings of NO2 emissions were as high as 104 micrograms per cubic metre. http://www.silvertowntunnel.co.uk/our-study/2014-silvertown-tunnel-pollution-study-results/

2.6.  There is a failure to learn from past developments. RBG and GLA do not appear to examine existing stores and developments to see whether public transport policy works. Retailers are being allowed to build superstores in dense residential areas throughout RBG, without regard to road capacity, pollution levels and impact on local residents.

2.7.   Both RBG and the GLA appear to lack the will or the capacity to challenge developers, putting new jobs over traffic and environmental concerns, accepting developers’ own transport and air quality reports with inadequate scrutiny.

3. Case Studies

3.1.  Tesco have recently opened a superstore in the heart of Woolwich Town Centre, involving the demolition of a Grade II listed Victorian façade. This photograph of the bike racks in the Tesco car park was taken on Sunday 1 June at 2 pm (a peak shopping time for Tesco). It is a perfect illustration of how the aspirations of planners to reduce car use do not match reality. The only bike parked in the racks appeared abandoned (with a flat tyre), to the rear of the picture. A banner can be seen above the bike racks advertising Tesco’s current “fuel deal” offering discounts off Tesco petrol. The car park was full.

3.2.  Apparently concerned by the large foothold of Tesco in nearby Woolwich, not wanting to lose competitive advantage, Sainsbury’s then decided that it needed a bigger store too, so planning consent has been granted by RBG and GLA for a new Sainsbury’s Superstore (13,189 sq.m.) and Marks & Spencer (on Woolwich Road, Charlton). Sainsbury’s already has a store only 600m away. The building has won awards for its innovative design and environmental sustainability and is on Greenwich Peninsula, the site of one of London’s most important regeneration areas, near the O2, where residential units are to increase from 10,000 to 25,000. It is conveniently located for use as a local supermarket and many local residents walk there to shop or visit the café. Here is an aerial view of the existing store:

3.3.  The store was purpose built for Sainsbury’s as a supermarket and was opened by Jamie Oliver less than 15 years ago. Although Sainsbury’s decided it needed a larger store, it did not want a competitor to occupy this purpose-built store, so has negotiated a restrictive covenant prohibiting use of the building as a supermarket after it vacates. It is not clear who agreed to this anti-competitive covenant, but the freeholder of the land is the GLA.

3.4.  More recently, in March this year, RBG granted outline planning consent for IKEA to demolish this store and the store next to it, to construct a 33,000 sq.m. IKEA store, almost 4 times the size of existing. The nature park, community orchard and pond to the rear of the store are to be concreted over to make way for an IKEA service delivery yard. This park was offered as mitigation land to the community when Sainsbury’s was originally granted planning consent to build on this GLA land which used to be used for playing fields. 

3.5.  We have chosen to give evidence in relation to the proposed IKEA store as we have studied the planning application in detail and have reviewed the Transport Assessment produced on behalf of IKEA to support the planning application. We present it as a detailed case study, illustrative of problems in the planning system which we believe are likely to exist throughout Greater London.

4. Facts relating to IKEA Greenwich

4.1.  IKEA stores have a history of opposition and controversy because of the amount of traffic they create. In 2004 John Prescott ordered an inquiry into a proposed new IKEA store in Stockport and ultimately denied planning consent. The GLA also rejected a proposed IKEA store in Bromley in 2004. More recently, Sainsbury’s issued judicial review proceedings against a proposed IKEA store in Reading and Sheffield county council has been resisting plans for a new IKEA. All share the same concerns: traffic.  

4.2.  In Greater London, there is wide-spread knowledge of the traffic problems caused by IKEA stores. For example, it is widely known that there are regular tailbacks on the North Circular, particularly at weekends, due to the number of vehicles driving to IKEA’s Tottenham store.

4.3.  IKEA's planning application in Greenwich was approved was on the basis of the Transport Assessment, produced by IKEA’s own transport consultant, which concluded that the store would actually reduce traffic and improve air quality. IKEA made the same claim in Stockport and John Prescott dismissed it out of hand.

4.4.  Although IKEA’s Transport Assessment is lengthy (it fills a lever-arch file) and is filled with scientific looking traffic counts and modelling,  IKEA’s figures are in fact based upon an assumption that 35% of customers will visit the store by public transport. This has not been achieved by any other IKEA store in London, including IKEA Tottenham and IKEA Wembley, which both have train or Tube stations considerably closer than the Greenwich site. The highest % of public transport achieved by any IKEA store, on IKEA’s own figures, is 21% (Tottenham), so planners have accepted what can only be an ambitious target (and 66% increase on the closest comparable store) as the basis for projecting traffic impact.

4.5.  It is particularly surprising that this target was accepted so readily, given that IKEA claim that the main form of public transport proposed to be used by customers will be bus. Department for Transport’s own figures record that only 2% of traffic on the roads of Greenwich is by bus.

http://www.dft.gov.uk/traffic-counts/area.php?region=London&la=Greenwich

4.6.  Having accepted IKEA’s own traffic estimates, both the GLA and the local council's air quality officers then decided to waive the usual controls (including an Environmental Impact Assessment) because they accepted IKEA’ argument that a net reduction in traffic would lead to a net reduction in emissions.

4.7.  Proposed public transport incentives to be offered by IKEA include:

4.7.1.      The ubiquitous bike racks (ever tried to get a Billy bookcase on a bike?) – IKEA in fact accepts that 0% of customers are likely to visit by bicycle.

4.7.2.      An information board in the store to advise passengers about public transport links and services.

4.7.3.      Targets for staff to use public transport.

4.7.4.      Measures to encourage the use of public transport, with no financial mitigation if customers in fact choose to travel by car.

4.8.  These measures will not incentivise customers to travel by public transport, as IKEA’s business model is based upon the sale of low-cost flat-pack furniture which IKEA encourage customers to collect by car to save costs. A question to IKEA’s online virtual shop assistant “Anna” about why IKEA delivery charges are so high elicits the following answer:

Anna said: "Free" or "subsidised" delivery usually means the cost is hidden within product prices. At IKEA we prefer to offer our products at the lowest possible price so if you are able too [sic] fit the products in your vehicle you are not paying for hidden delivery costs that you may not be using.”

4.9.  Here is a snapshot of information about the proposal:

4.10.                    The traffic generation figures in IKEA’s transport assessment do not stand up to scrutiny. This is of more than local significance as the proposed site is adjacent to the A102 Blackwall Tunnel Approach Road, at a stretch where the road narrows and there are already significant capacity issues and regular tailbacks. IKEA expects 38% of traffic to the store to come south through the tunnel. When there are events at the O2, there are already regular tailbacks through the Blackwall Tunnel. These tailbacks go as far back as Stratford (site of the Olympic regeneration zone), through Tower Hamlets, where pollution levels are even higher than in the AQMA in Greenwich.

4.11.                  GLA’s approval of an IKEA in this congested regeneration zone conflicts with GLA's views 10 years ago when they rejected the proposal of a new Ikea store in Bromley, just off the A20, a site far less congested and polluted than Greenwich and only 8 miles away. Source: http://legacy.london.gov.uk/mayor/planning_decisions/strategic_dev/2004/oct2704/ikea_klinger_works_report.pdf

4.12.                  GLA's report in 2004 was damning and urged Ikea to consider scaling back their model for congested urban areas, as they have done in Australia and Hong Kong. Why was this store welcomed in Greenwich, a decision endorsed by the GLA?

4.13.                  In part this could be due to the national and local policy forcing retails giants into town. See this commentary on IKEA’s thwarted plans to open a store in Stockport (a rejected out of town site) http://www.planningresource.co.uk/article/449079/prescott-puts-kibosh-stockport-ikeas

5. How our Planning Policies (or RBG and GLA’s implementation of them) are failing to improve Air Quality

Policy of Discouraging Out of Town Shopping Centres

5.1.  While the intention of this policy is good (re-generating town centres), there is a failure by planners to consider the business model of the stores they are encouraging into town. For example, IKEA’s business model is to sell flat-pack furniture cheaply and encourage customers to collect it by car. Such a business model has no place in an AQMA in Zone 2 London.

5.2.  The first two developments referred to above (construction of the large Tesco store in Woolwich and the new Sainsbury’s and Marks & Spencer in Charlton) are achieving the very opposite of regenerating the High Street. Marks & Spencer recently announced that it is closing its store on Woolwich High Street, leaving the ailing High Street without its only landmark retailer.

5.3.  If IKEA arrives in Greenwich, not only will the congestion damage local High Streets, but customers who might otherwise buy scented candles and pictures from Greenwich Town’s famous market, are likely to go to IKEA for cut-price products. In 2004, GLA described the retail effect of IKEA as a “potential category killer”.

Policy that Restricted Car Parking will Discourage Car Use

5.4.  Another contributing factor is the policy, enshrined in the London Plan, that restricted car parking will discourage car use. The IKEA store in Greenwich would have between 1/3rd to half of the parking spaces of other IKEA stores in Greater London. However, for a store which positively encourages customers to come by car, this is likely to lead to tailbacks and stationary traffic queuing for spaces. Stationary traffic of course causes the highest levels of NO2 emissions.

Policy that Development must be maximised to create Job Opportunities

5.5.  The other planning policy leading to over-development and environmental damage in RBG is the belief that the creation of jobs is the paramount concern. IKEA has offered to provide up to 400 new jobs. However, the new Sainsbury’s superstore and Marks and Spencer, 600 metres away, will already provide 850 jobs.

5.6.  Whilst we recognise that new jobs are a benefit to the borough, these jobs could of course be provided in various forms. A sustainable new occupier whose business model is not based upon car use, would bring these jobs too. Responsible planning should not put jobs above congestion and pollution. RBG’s policy is leading to traffic grid-lock in RBG. A balance has to be struck.

6. Influence of Large Developers

6.1.  Finally, the influence of large corporations pressuring planners to agree to ever larger developments in Greater London, and in particular RBG, is plain to see. A developer, LXB RP (No.20) Limited, has been pushing for every retail space to be developed to maximum capacity on Greenwich Peninsula, a major regeneration area where the number of residential units is increasing from 10,000 to 25,000.

6.2.  IKEA, of course, is a developer in its own right. It has also won the lease to develop “IKEA town” near Stratford (estimated to make £750 million in profits). Developers who are making so much money out of our booming property market contribute relatively little towards the enormous costs borne by our local authorities to deal with the resulting pressure on our infrastructure and roads.

7. Boris Johnson’s Decisions on Planning and Transport Put Air Quality Last

7.1.  It is possible that RBG and TfL did not much care if traffic increases due to recent developments because Boris Johnson and RBG, under the leadership of the recently retired Chris Roberts, have been lobbying for an additional tunnel from Silvertown to Greenwich.

7.2.  This proposal has been personally advocated by Boris Johnson and has been included in the London Plan, although it is unfunded at an estimated cost of up to £1billion. In a recent radio interview, Boris Johnson admitted that a Silvertown tunnel would bring increased traffic and pollution to this already polluted area. http://www.boriswatch.co.uk/2014/04/02/more-lbc-transcripts-east-london-river-crossings/

7.3.  These are the questions we would like the Committee to put to Boris:

(1)   Where does he rank air quality in his planning priorities?

(2)   Why did Boris waive through an IKEA store, which draws such legendary traffic jams, in Greenwich, a UNESCO World Heritage Site and an AQMA with emissions of Nitrogen Dioxide almost 3 times European limits?

(3)   Why is Boris lobbying for an additional tunnel from Silvertown to draw more traffic into Greenwich?

We close with an image of the impact of the IKEA store in Bristol when it opened. We sincerely hope that Greenwich residents will not have to suffer this fate in our special, historical borough, in Zone 2 of our capital city.

8 June 2014