Haven’t got time to read all 845 pages of the transport assessment submitted as part of the AFC Wimbledon/Galliard Homes planning application for Plough Lane? You’re in luck!
Someone at Wimbledon Park Residents Park Association has waded their way through the tome and pulled out some very interesting facts. For example, the developers use inadequate modelling data, offer no parking for casual users of the stadium (eg parents dropping off kids for training sessions, squash club visitors etc), and propose zero upgrades to the area’s transport infrastructure.
Full info can be read in read below, in a document that we reproduce from the Wimbledon Park Residents’ Association website wimbledonpark.com. Its conclusions are pretty damning…
“Traffic Assessment and the AFC / Galliard Homes Planning Application
The subject of traffic, transportation and access to and from the proposed development is covered in a number of the application documents including: Design and Access Statement, Environmental Statement, Transport Assessment Statement of Community Involvement and the Planning Statement.
The Statements have been drafted to support the Planning Application which, if approved, will provide housing for 1491 new residents and a stadium for 11/20,000 people on a site without any upgrades to transport infrastructure.
We believe the Transport Assessment to be flawed and as a result, many of the supporting
statements in the Environmental, Design and Access and Planning Statements concerning
transportation are therefore misleading.
We consider the frequent reference to the “robustness” of this Transport Assessment as a disingenuous attempt to justify the proposed development, falsely inflate the scheme’s sustainability credentials and play down the impact it will have on the residents, businesses and infrastructure in Merton, Wandsworth and Tooting.
Whilst the Transport Assessment extends to 845 pages, instead of being a thorough and realistic assessment of the sustainability and impact that the 11,000/20,000 stadium attendees, new housing, retail and a private sports club will have on the surrounding community and its infrastructure, the report draws its conclusions from inappropriate data, flawed assumptions and fails to consider whether or how the existing roads, pavements and public transport infrastructure are currently coping with existing usage.
The Principal Inadequacies and Failings of the Transport Assessment:
- The Applicants have not carried out their surveys during a period of normal traffic conditions and have therefore not used realistic data for their Transport Assessment. They carried out their surveys during the period, 12th July – 18th July 2012. Some school holidays had already begun and many road users would have taken their holidays early, prior to the London Olympics commencing on 26th July 2012.
- The Applicants have ignored the TFL guidance contained on their website (Trip Generation –
Committed Development and Traffic Data) as follows: In most cases, TfL expects traffic
surveys to be undertaken during school term times, a neutral month and neutral weekday;
the observed local highway peak should form the basis of your TA. It is good practice to use
validation data when collecting traffic survey data. The impact of using an abnormally light traffic count is that any transport modelling that PBA has undertaken where this data has been used will produce misleading, incorrect and unreliable outputs. In this case they’re pretending the roads are quieter than they are which will falsely reduce the impact of the development on the road junctions and the network as a whole.
- Not assessing the impact on Wimbledon town centre, the railway station or local residential
streets before and after matches when supporters will be naturally be visiting the local bars
and restaurants coinciding with peak shopping/leisure time on a Saturday. The supporters
are unlikely to travel to and from a game without at least a proportion of them visiting a pub
or restaurant. This will apply to all supporters and therefore needs to be considered for
those supporters parking cars in residential areas and also those travelling by public
There is a potentially very significant impact on the character and quality of the
environment of the town centre if 11,000/20,000 fans are visiting the pubs and
restaurants pre- and post- matches on Saturdays and weekday evenings. This point seems
to have been ignored by the Applicants in terms of the anticipated pedestrian movements
between transport hubs and the stadium. Routes will depend on the venues frequented
and will mean movement of fans through the residential streets outside of the routes
considered by the Applicants.
- The Applicants will not provide any car parking for their supporters within the development and assume all football supporters and event attendees travelling by car will find parking spaces in residential streets within walking distance of the stadium. They also assume that the supporters will walk directly to the stadium and not into the bars and restaurants of Wimbledon, Tooting or Earlsfield centres before and after a game. These streets are already subject to the parking restrictions in favour of residents and their visitors on Mon –Saturdays because they could not cope with commuter parking and visitors accessing the shops from these streets before the CPZs were introduced.
This assumption on the part of the Applicants is very concerning for residents in any street
that has unrestricted parking on Saturdays and weekday evenings. The Applicants have
undertaken a survey of all local residential streets within walking distance of the stadium
and identified the streets could provide 5544 spaces for their supporters. Therefore, the Applicants are proposing that their supporters travelling by car should be able to find adequate opportunities to park in residential streets within walking distance to the stadium. Residents and their visitors in these streets (children’s parties, church groups, shoppers etc) will be unable to park whenever there is an event at the stadium. Residents will naturally lobby for more extensive restrictions to protect their streets and the impact of supporters driving around looking for a space to park in before a match will have a large impact on congestion in the road network. The robust conclusions reached by the applicants insofar as the capacity of local residential streets being able to accommodate the parking for supporters are therefore unable to be made.
- Not considering or assessing the existing capacity of local public transport infrastructure and therefore ignoring the impact 20,000 supporters and 1491 new residents it might have. It seems extraordinary that the Applicants appear to ignore the fact that the local stations and buses are already well utilised by the public on Saturdays and weekday evenings and have failed to study what capacity actually exists to accommodate either 11,000 or 20,000 stadium visitors. There appears to be a presumption that the capacity exists and 11,000 or 20,000 supporters will just fit onto the trains and buses, and that they’ll flow through the stations as part of a normal flow. What happens if there is not enough capacity when the match/events are taking place; and surely they should have tested a scenario during Wimbledon Tennis Championship?
- Despite the scoping exercise identifying a need to use specific software, VISSIM, for traffic modelling, the Applicants have failed to do so. Their assessment already acknowledges the queuing traffic along Plough Lane which interferes with other junctions during weekday peak hours, but they have not undertaken appropriate transportation modelling studies that consider how the entire local road network functions currently and how it will function once the additional burden of traffic and pedestrians from an 11,000/20,000 seat stadium and 602 housing units are added to that network. The modelling the Applicant has undertaken (Arcady8) takes no account of this and the true effect of additional traffic on Plough Lane is therefore not assessed accurately. Instead, they’ve chosen to study individual road junctions on a standalone basis which will not provide a realistic picture of the ability of the wider road network to cope with the impact of the development.
The consequence of not considering the network of roads and junctions as a whole is that the Traffic Assessment will present an inaccurate assessment of the impact of the development. It is relying on incorrect data and therefore producing false results. Anyone living and working in the area or travelling from Haydons Road/ Gap Road to Garrett Lane will appreciate that queues are a regular problem at peak times already. We believe the modelling software and the methodology are wrong. Instead of Arcady 8 software, the
applicants should have used an alternative such as the Tfl model or Vissim because the
modelling needs to take account of traffic queuing and the timing of signals at junctions
which will require different programmes when 11,000 pedestrians are arriving and leaving
- Page 10, Cl.4.11, Stadium Management Plan Strategy Appendix Q clearly states that it will
be necessary to close some roads on match days to facilitate the movement of 11,000
football supporters. It is stated Plough Lane, Summerstown Rd and Riverside will need to close for 30 min periods on match days. This does not appear to have been tested in any modelling scenarios.
The impact of this will be considerable for residents, businesses and any road users on
every occasion the stadium is used. Plough Lane is a main thoroughfare for emergency
vehicles and South London traffic and no account or impact of this extraordinary
requirement appears to have taken by the Applicants in their Traffic Assessment. This has
also been ignored in the Environmental Statement and will clearly have a major impact on
existing road users on the wider network and commuters and anyone living nearby with
increased pollution levels and gridlocked traffic.
- The Applicants have adopted unrealistic modelling assumptions to assess traffic flows namely: (i) Despite road closure being identified as a likely and necessary measure to facilitate the movement of supporters and stadium attendees, the modelling does not test the impact of this on traffic flows on the surrounding road network. The impact of this omission of such a major factor from the testing and modelling is that the Traffic Assessment is incomplete, and its conclusions are fictitious. ‘Hey let’s just close a few roads!’ (ii) The Applicants assume that supporters travelling by car will not drive across any junctions around the stadium on match days because they’ll find spaces beforehand. Not only does this assumption ignore the likelihood of supporters making their parking location choice linked to which restaurants and bars they’ll visit before and after the game, human nature will ensure anyone driving to the stadium will try to park as close as possible to the stadium. Some will inevitably end up on the junctions in the vicinity of the stadium, adding to the congestion and compounding the risk of queues. This scenario appears to have been ignored and the impact will be the model is not reflective of realistic scenarios. Increased congestion and pollution will result. Local residents will ensure restrictions are increased and supporters will be unable to use these streets to park. This scenario has not been tested and is a likely one. (iii) The stadium once built, is very likely to be used by a second club (possibly rugby) and for other events such as music concerts in order to provide the financial sustainability. The Traffic Assessment has been drafted in consideration of football only and the behaviour of their fans in relation to parking and walking habits. This is an unrealistic scenario and assumes a lower frequency of stadium usage. Music events operate on different time scales to football matches and the behaviour and patterns of crowds attending events will be different. The impact of these alternative events and a more frequent use of the stadium has not been tested and further highlights the inadequacy of the Traffic Assessment and Environmental Statement. (iv) The Applicants have not tested a scenario that assumes all the parking spaces in the 602 new flats will be used. The traffic generation of the flats were estimated from the nearby flats on Plough Lane which themselves have under-utilised car parking. by doing this, they have assumed a similarly under-utilised car park for this scheme. The results of a model based on this assumption are unlikely to demonstrate the true impact of the development. Either the traffic generation of the 602 proposed flats is an underestimate, or the Applicants are providing excess car parking for the flats. If the traffic generation from the flats is an underestimate, then the junction capacity assessments are not robust. If they are providing excess car parking, then this is against Government policy and they should reduce the number of car parking spaces provided – if they refuse to do this and maintain car parking as they have proposed, then they should undertake additional junction capacity assessments which assume full occupation of the car parking spaces and demonstrate the true impact. Again, the Traffic Assessment appears to be flawed and Environmental Statement is therefore also inaccurate.
Other Inadequacies and Failings Identified
- The Applicants propose that a 1000 sq. m. supermarket fronting Plough Lane that derives trade from passing motorists will not require any customer parking. This is unrealistic and the impact of not providing customer parking is that cars are likely to stop on the carriageway and cause an obstruction resulting in queues on an already congested Plough Lane. 10,000 sq m is a reasonably large store, more than just convenience and as such will be targeting a wider catchment than just the proposed development. The existing Tesco Express in Summerstown adjacent to the site has customer parking and this is regularly full. This store is approximately 200 sq m and has 16 customer parking bays, which is a ratio of 1:12.5sq m. We note that a 1000 sq m retail unit in the location proposed could be expected to provide up to 30 spaces if it is to comply with LB Merton’s Sustainable Transport Policy. Notwithstanding the impact on the road network, a store of this size with no customer parking in this location seems commercially unrealistic from an occupier perspective.
- Similarly, there is no parking proposed for the leisure use in the Squash Club – the leisure use is already in place and would relocate as a result of these proposals; given that there is an existing parking demand, this has not been provided for.
- The Applicants propose transport mitigation works which will negatively impact on
established local businesses and they cannot provide any guarantee that these can be
delivered or are feasible ie the removal of parking on Haydons Road and narrowing of the
carriageway on Plough Lane. The transport mitigation proposals designed to improve the flow of traffic in the vicinity of the stadium are the permanent removal of the parking bays outside the shops, restaurants, mini cab office and showrooms on Haydons Road between the station and Plough Lane junction. This proposal, if implemented will have a detrimental effect on these businesses. ‘Missed opportunity to boost local economy’
- On a similar note, it is proposed to introduce parking restrictions on Summerstown. There is no proposal as to where this existing demand would be relocated or if it could be accommodated. It appears that a large proportion of the existing demand is associated with the existing businesses on Summerstown. If demand is high (there is no evidence to suggest demand is not high), then such a displacement may result in a severe impact.
- Similarly, narrowing Plough Lane to provide a widened cycle lane for use by the football
supporters and other attendees of the stadium events has been presented as a solution to
an overburdened pedestrian pavement. The Applicant provides no comment as to
whether this can actually be achieved. The impact of this is likely to be the prevention of
emergency vehicles using Plough Lane to reach St Georges Hospital effectively and again
likely to be unacceptable.
- The Applicants have not tested whether the coaches can access the stadium for drop off in Riverside Rd or whether the delivery vehicles can actually service the 1000 sq. m. retail unit thereby risking additional congestion and an unworkable traffic plan.
Visiting fans will arrive by coach and need to be dropped safely at the stadium without
blocking roads. The impact of the coaches and service vehicles not being able to physically
turn and manoeuvre on and off the site safely is a highly likely scenario and will cause a
chaotic traffic management scenario in the vicinity of the stadium unless it is addressed as part of the overall design of the scheme.
- Not assessing the existing utilisation of pavements and current pedestrian movements
between train/tube stations and the development, thereby ignoring the impact that 20,000 football supporters and 1491 new residents might have on both match and non-match days.
Other than looking at the condition of the pavements, again, there has been no account
taken of how many people are currently utilising the pavements between public transport
sites, the restaurants and pubs likely to be used as pre/post match venues. There is a
presumption that streets have the capacity to accommodate whatever footfall increases
the stadium brings but no account is taken of the shoppers, cinema goers, and visitors to
the shopping areas on a Saturday who will still expect to be able to go about business on
- A report prepared by RPS in 1996 on behalf of the London Borough of Merton and the
Greyhound Racing Association Ltd (‘Wimbledon Greyhound Stadium Feasibility Study’)
considered in detail the redevelopment of the stadium for a number of options. It
concluded, due to the inadequacies of the existing transport infrastructure serving the site,
that a fixed public transport link (an extension to Croydon Tramlink) would be required to
serve a new football stadium.
Since 1996 there has been no change to the public transport infrastructure serving the site,
the former football ground at Plough Lane has been developed into residential apartments
and the Haydons Road Station alone has seen a huge increase in passenger usage (320%
between 2004/5 and 2006/7). It seems extraordinary that the Applicants can now
conclude that the road network and public transport infrastructure should simply absorb 11/20,000 supporters without any impact on the local businesses and residents.
- The Applicants state that the site is categorised as a Public Transport Accessibility Level
(PTAL) rating of 3 when previous reports have stated 2.
The Applicants appear to be overstating the site’s PTAL rating and as a result are
exaggerating its sustainability credentials and the suitability of the site for a 20,000 seat stadium.
- The Applicants have not acknowledged the prospect of Crossrail 2 in Wimbledon and
Tooting, how it might impact and fact that the two development programmes coincide. There is clearly going to be significant impact of both these proposals and the cumulative impact should be included with the Environmental Statement and the impact tested.
On account of the inadequacies of this Transport Assessment and the fact that it is this document that is being used to underpin the Applicant’s justification for establishing an 11,000 /20,000 seat stadium with over 600 new housing units on this site, we consider there’s a strong risk that the traffic and transportation impact has been grossly understated and therefore compromises the Environmental Statement, as a result.
Further, we consider the Environmental Statement and its references to transportation / traffic to be incomplete and its conclusions inaccurate. The ES includes an assessment of the magnitude of change in traffic but it is unclear over what period or on which days this has been carried out. If it has been undertaken on weekdays in peak hours then it is probably not representative of the periods of maximum magnitude of change for the proposed uses on site. The Environmental Assessment considers the magnitude of change but there is a high risk the results are misleading because the Traffic Assessment assumes existing site traffic remains in the baseline data. If existing trips were removed from the baseline, the magnitude of change will undoubtedly be higher and the impact will be greater – further evidence that the impact of this development proposal is understated.’
Reproduced with the permission of Wimbledon Park Residents’ Association. Visit their site wimbledonpark.com