Grounds for objection (2007 applications)

If you write to the planning officer to object to the Tesco plans for the Wilco site, remember that you can only object to the proposed changes outlined in the plans, not to the idea of a Tesco store opening at this site. The three planning applications made by Tesco are:

Planning application ref. 07/0811/FUL [PDF scan]
“Single story rear extension and installation of plant”

Planning application ref. 07/0809/ADV [PDF scan]
“Installation of one double sided illuminated fascia sign”

Planning application ref. 07/0810/FUL [PDF scan]
“Installation of a new shop front including an ATM”

When you write, be clear about which application you are objecting to. We think that the most serious problems are with the planned extension at the back of the site, so we suggest that you write to oppose that application. If you have points you want to make about the other two applications, you will need to write separate letters for each of them.

Objection sheet/briefing

We have created an objection sheet/briefing note which may be useful for any objections still being submitted.

Grounds on which to object

There are two types of issue that the planning authorities will take into account when they consider these planning applications. All the points made below are objections to the planning applications made on one or both of these grounds:

  1. The specific changes proposed in the planning applications;
  2. Important factors that are relevant to Tesco’s application but which are not necessarily addressed directly in the planning documents themselves. These are called material considerations. Exactly what a material consideration is will vary from case to case, so there is quite a lot of room for interpretation by the planners, but they include things like objections from members of the public, and the compatibility of planning applications with central and local government policy. A very important policy document for the planning process in Cambridge is the Cambridge Local Plan 2006 (http://www.cambridge.gov.uk/ccm/navigation/planning/growth-policy/). Cambridge City Council say that ‘the Local Plan sets out policies which will shape development in the City’, so any planning application needs to be compatible with it. As you will see below, the Tesco applications are not.

There are a number of grounds for objection to Tesco’s planning applications and obviously different people will find different points they want to make. Below, we have listed grounds for objection, but of course that doesn’t mean that there aren’t other grounds for objecting, if you want to make different points. They all relate to the proposed changes to the rear of the Wilco site that will take place if Planning application ref. 07/0811/FUL (“Single story rear extension and installation of plant”) is approved.

1. Changes to the rear of the site

The application relaxes the conditions for deliveries and parking placed on the existing building. The current building was given permission in 1971 (ref C/71/0826). Conditions on this permission included the requirement that:

The loading and unloading area and parking spaces shown on drawing no 71/258/1 shall be permanently maintained for that purpose.

In the 1971 application, provision was made for four parking spaces in the rear yard for visitors to the premises plus other parking for the use of employees. Currently, there are fifteen car parking spaces in the rear yard of 163 – 167. (Ten spaces are shown on Tesco’s drawing of the existing site, [P]500, omitting the five spaces immediately behind the building where their new extension is proposed.) Tesco plans indicate six proposed car parking spaces (07/0811/FUL section 6), including one disabled car parking space. Adding these to the three spaces reserved for the accountants on the upper floor of the Wilco site means that there is a proposed reduction of six car parking spaces, or over one third of the existing total.

In addition, the tenants of 169 Mill Road have a right of way across the yard to the parking area at the rear of their premises in their lease. Tesco appear not to be maintaining this right of way, as a fence is shown on their plans. As the tenants of 169 are an estate agent and require their cars to attend viewings this will force another 3 cars to park in adjoining streets.

Finally, the total space in this parking and loading/unloading area will be very significantly reduced by the proposed extension, which will expand the current building to cover more than a quarter of the existing parking/loading space.

Therefore, the new extension does not maintain the loading, unloading and parking areas required under the previous planning consent.

2. Waste Disposal

According to their applications, Tesco have no plan to increase the on-site facilities for waste disposal. This is unrealistic for two reasons:

  1. Because of the difference in the nature of their business, supermarkets generate far more waste than bicycle shops;
  2. In application 07/0811/FUL Tesco is planning to greatly reduce the size of the car park and delivery area at the rear of the site, where waste is held until collection. It is also presumably expecting the use of this area to increase significantly through visitor and staff parking, and possibly deliveries.

So, Tesco are saying that they want to put a lot more waste into a much smaller and busier space.

3. There is nowhere for them to unload their deliveries

The original, 1971 planning consent for the building (C/71/0826) required all loading and unloading of goods to take place within the limits of the property itself (the limits of the property are the area between the bollards and the store at the front, and the car park/delivery area at the back).

The Cambridge Local Plan, which is one of the criteria against which planning applications have to be judged, says

Development proposals will make suitable provision for any required access and parking by service and delivery vehicles’ (Local Plan, 8/9: Commercial Vehicles and Servicing)

It also says that:

Service and delivery vehicles that park on the highway can cause an obstruction to other road users. Therefore, any development that will require regular loading or servicing must avoid causing illegal or dangerous parking, by providing appropriate off-street facilities. (Local Plan, 8.21)

Tesco are not planning to knock down the bollards to enable deliveries at the front (this would, in any case, require them to make changes to the road and pavement, which they don’t have permission for). They can’t make deliveries to the car park at the back because the street is one way and lorries are unable to follow the one way system around from Catherine Street to Sedgewick Street.

So,Tesco have nowhere to unload their deliveries.

4. Road Safety and Traffic Congestion

Of course, if Tesco were able to unload their lorries at the back, this would be very bad news for the residents and users of the streets concerned. Tesco make several deliveries every day, and large lorries driving down these narrow, residential streets several times a day and reversing out of the car park would be dangerous, noisy, and would greatly increase traffic congestion. Mill Road is already very congested, as we all know, and adding several lorries a day trying to park on or near Mill Road would make the problem significantly worse.

Another factor causing even more congestion in Mill Road and surrounding streets would be the increased car traffic created by Tesco customers driving to the store and parking near the store. In their planning application for changes to the rear of the site, Tesco have given no estimate for the number of cars (or lorries) expected to use the site, even though the form asks them to do so (07/0811/FUL, section 4). Although Tesco will probably say that they expect most customers to arrive on foot, any convenience food store – especially one located on one of the main roads into and out of the city centre – is going to attract extra car traffic. Since they have over 500 of these stores, Tesco must have some idea of how many customers they expect to arrive by car every day, but they have decided not to include this information in the relevant section of the plans.

As mentioned above, according to 07/0811/FUL section 6, Tesco plan to have six car parking spaces, including one disabled car parking space; this means it is very likely that a lot of customers would park in the surrounding streets, or increase congestion on Mill Road even further by illegally parking on the kerb (which would also be dangerous to pedestrians).

So, not only is the opening of a Tesco store going to increase traffic and therefore congestion (and would do so even if they opened with no changes to the site), but this congestion will be made worse by the fact that the plans (07/0811/FUL) reduce the size of the car park, forcing more customers and other visitors to park on the narrow residential streets behind the site, or to try to park on the kerb at the front.

The Cambridge Local Plan says that:

Applications for retail developments will, where appropriate, be subject to the demonstration […] that transport and environmental matters have been considered. (paragraph 6.17)

and that:

In areas of the City where traffic congestion is particularly high, the council may seek a zero increase or reduction in car traffic generation through any proposed redevelopment. (paragraph 8.7)

And that:

The extension of existing buildings will be permitted if they: […] c – retain sufficient amenity space, bin storage, vehicular access and car and cycle parking; (Section 3/14: Extending Buildings)

Since the planning application 07/0811/FUL fails to address matters of transport, will certainly increase traffic congestion, and reduces the size of the car park, it contravenes all three of these aspects of the Local Plan.

5. No provision for bicycle parking

As we all know, there are a lot of bicycles in Cambridge and it would be reasonable to expect that many of the customers who don’t arrive by car will arrive on bicycle. As section 3/14 of the Local Plan quoted above states, provision for cycle parking is a requirement where approval for extensions are sought. Despite this, there is no provision in the plans for bicycle parking, and Tesco do not say how many visitors they expect to arrive by bike. As the points above make clear, the reduction in overall space and in car parking at the rear of the site and the increase in use caused by greater demands on waste storage and by possible deliveries mean that cycle parking will be difficult and probably dangerous at the back of the store. No cycle parking provision is proposed at the front of the store.

The City Council’s Cycle Parking Standards require specific amounts of cycle parking per amount of floorspace, and that “Short stay cycle parking, e.g. for visitors or shoppers, should be located as near as possible to the main entrance of buildings […]”.

So, Tesco’s application fails to meet the requirements regarding bicycle parking.

Who to write to:

Mrs Angela Briggs <angela.briggs@cambridge.gov.uk> (01223 457173)
AND Sarah Dyer <sarah.dyer@cambridge.gov.uk> (Angela Briggs is on holiday around this time.)

Angela Briggs / Sarah Dyer,
Environment and Planning,
Cambridge City Council,
The Guildhall,
Cambridge,
CB2 3QJ.

Objections can normally be submitted via the City Council’s planning portal, but we understand there are problems with this at present.

When you write, be clear about which application you are objecting to. We think that the most serious problems are with the planned extension at the back of the site, so we suggest that you write to oppose that application. If you have points you want to make about the other two applications, you will need to write separate letters for each of them.

DEADLINE: Friday 19th October 2007.

The deadline has been extended by the City Council, seemingly due to technical difficulties with their planning database and the postal strikes. However, please write as soon as possible.

Remember to take account of any postal strike taking place.

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