Tuesday, 10 September 2013

Deadline for the Mill Street supermarket swamp

Supermarkets and their wasteful packaging

Application A130640 Mill Street: Tesco and M&S. Deadline for comments on the application: Wednesday 11th September 2013. If you have views on this, you can make them known to the Council.

"You can only comment or make an objection on 'planning' issues such as; the planning history of the site, the visual impact of the development, affect on public amenity, access, traffic and highway considerations or the impact on listed buildings, conservation areas, or protected trees." 
CCC page. (You can search applications here; online form here).

You can see all our posts about the proposed supermarket glut at Mill Street, Aberystwyth, here.



If you want to get more ideas have a look at these letters we've seen.

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Mill Street Development proposals Aberystwyth – A130640

I am writing to object to the proposals in planning application A130640.  Please could you ensure inclusion of this letter in your report to the Development Control Committee by the closing date, 11 September 2013, or to the Welsh Assembly Government - should the application be referred to the latter.

The grounds on which we wish to object are largely those contained in CCC’s own Local Development Plan (LDP), approved in April 2013 (statements in italics are quotations from the LDP):

Generally the LDP Objectives were found to be compatible with the Sustainability Objectives, the few exceptions usually reflect an uncertainty on how the objective might be expressed in particular circumstances. Some question marks as to the compatibility of objectives also arise from the fact that pursuing one LDP or Sustainability Objective, without heed to the others could result in success in one to the detriment of another. For instance goals for meeting housing and economic growth in the County may result in harm to landscape and biodiversity if development is allowed to become too great.

We consider the Mill Street development proposals to be a perfect example of the incompatibility of objectives recognised in the LDP.  Conflicting needs have already emerged (destruction of property before development can proceed) and will continue if the development in its present form is accepted by the DCC.

The Mill Street site is quoted specifically by CCC in its LDP as a brown-field site, MO302, ripe for development. Brown-field is defined as ‘reclaimed industrial property which has some level of contamination … reusable from industrial or commercial companies after under-use or abandonment.’
Parts of Park Avenue in front of the football field between the Arriva depot and the Police Station, are indeed brown-field sites. We hold that the Mill Street car park site cannot be defined as a brown-field site because valuable amenities at the site did, and still do remain in use. These are:
the Daycentre building within its enclosed garden surrounded by mature trees, plants & shrubs inside two lengths of mature stone walling, containing a 30 years old purpose-built healthcare/elderly/disabled services facility. Because of the proposed development needing vacant possession, CCC has forced the operation within this building to move to inferior, dark, difficult-to-access basement premises;
the 1902 Drill Hall of high architectural and historic value, used as a storage facility but attractive enough to be adapted to provide housing or a leisure amenity;
Glyndwr Road, a street of valuable and established Edwardian houses accessible to town to accommodate approximately 40 people, and still tenanted or in owner-occupation. CPOs are to be used by CCC to enforce their acquisition in order that they be demolished;
Scottish Power property, in use but also under the CPO threat;
The ‘Lucas depot’ used by a small trader, recently vacated to yield possession.
The present car park, still in use.

These will all have to be deliberately destroyed before the site can be defined as a brown-field site.
LDP Objective 3: To encourage the growth of a sustainable retail sector to maintain and enhance vibrant town centres and to protect and enhance local and community retail facilities throughout the County.
Research has shown that the presence of a Tesco superstore in a town centre, rather than ‘enhance’, threatens the sustainability of the local and community sector. Tesco has been very low-rated by consumer watchdog Which in a stores survey conducted in 2011 (placing Tesco 84th out of 100) and in a supermarkets’ survey that same year, Tesco comes next to last for customer satisfaction, after Morrisons and Lidl.  ‘Maintaining and enhancing community retail facilities’ does not therefore describe the proposals under consideration.
[See the APPENDIX at the end of this document for UK govt retail considerations]

LDP Objective 6: To sustain and enhance a high quality built environment which allows for innovative design, reflects a sense of place, is easily accessible, useable, safe to live in and helps improve the health and wellbeing of its communities.

LDP Objective 11: To conserve and enhance Ceredigion’s landscape (townscape) encompassing the visual, historic, geological, ecological and cultural environments.

5a To understand, value, protect, enhance and celebrate Ceredigion’s landscape (townscape), historic environment, diversity and local distinctiveness, historic and cultural heritage

7.9.10 New development could potentially have a negative effect on landscape (townscape); however the magnitude of the effect is dependent on the scale, nature and location of the development. Synergy, in regard to landscape (townscape), may also be found within the long term aims of policies

Synergy, in regard to landscape (townscape), may also be found within the long term aims of policies relating to development densities and the reuse of existing dwellings

All the above statements appear in CCC’s LDP.  None seem to have been followed in this instance. We hold that the Mill Street scheme is ‘development allowed to become too great’.
“Tesco store comprising some 25,000 sq ft of net food sales space and 12,000 sq ft of non-food net sales area together with a three storey Marks & Spencer unit fronting Park Avenue, comprising 36,000 sq ft of sales area”  [Tesco statement to Mark Williams MP]

The CDF plans present a development out of kilter with its surroundings.  The proposed towering three-storey construction will face the low-rise mature and attractive Alexandra Road school buildings, the much smaller terrace houses in Rhyd-yr-afon, Riverside Terrace, Greenfield Street, Mill Street, and even the row of larger Park Avenue terrace properties adjoining the proposed entrance.  A three-storey block of eight residential private flats is to be added at the west end.  This, according to CDF, is partly there to hide the Tesco store from the Bridge approach. Between these flats and and Riverside Terrace is recycled wooden cladding to hide the ramp into the roof-level car park.  If all this is deemed necessary, the development can hardly be said to ‘enhance’ that area of town; indeed it will detract from and dominate it, causing:
‘a negative effect on landscape (townscape); however the magnitude of the effect is dependent on the scale, nature and location of the development’(LDP).
Compared with the in-town Sainsbury development in Lampeter, a low-rise, well-hidden, more sympathetic construction, Aberystwyth will be overwhelmed by an overpowering structure totally out of keeping with its residential and office surroundings, a visible eyesore from the Penparcau, Penglais, Constitution Hill, Penygraig, National Library and other viewpoints of the town.  We urge DCC members/WAG to imagine what a high-rise Sainsbury’s would have looked like in the middle of Lampeter.

LDP Objective 9: To ensure development assists in minimising Ceredigion’s greenhouse gas contribution, both singularly and cumulatively. To ensure that all developments are adaptive and resilient to the changing nature of climate and work towards reducing the risk from flooding.
Furthermore, the Mango report (on waste management) quotes Planning Policy Wales Edition 5 (“PPW”) which outlines at paragraph 4.1.1 that the goal of sustainable development is to “enable all people throughout the world to satisfy their basic needs and enjoy a better quality of life without compromising the quality of life of future generations”.

This development is in no way ‘to satisfy basic needs’. Many of those needs have been compromised and the needs of the development placed above all others.  With the Park Avenue road outside the Gas Gallery changing to make three lanes, the bus stop will move dangerously closer to the roundabout; the dedicated disabled parking spaces there will be scrapped, making the public toilets more inaccessible for blue-badge-holders who have severe walking difficulties, upper limb disabilities and people registered blind. Replacement disabled bays proposed will be further away and inside the development, only eight of the 16 provided are on the ground floor.

Lorries turning into the proposed M&S yard will hinder traffic flow at the main entrance point where more vehicles will be idling/waiting, creating hold-ups at least as far as the station and the bridge, possibly much further at the busiest times.

We hold that up to 376 cars and 6-8 articulated trucks a day entering the site will increase and not minimise greenhouse gases, ‘singularly and cumulatively’ as will the refrigeration plants for both retail stores causing constant humming noises and disturbing the peace of the neighbourhood, exemplified already at housing above the Terrace Road Spar.

There are no solar or photovoltaic panels to be seen anywhere and no wind turbines.

LDP 7.9.4   Flood Consequences Assessments will be required to identify what the risks are (if any) and demonstrate how they might be managed
7.9.7 The construction of new developments will inevitably lead to an increased pressure on water resources, which may have some negative effects on water quality and quantity.
1c To reduce flood risk the amount of development (units and ha) permitted in C1 and C2 floodplain areas as defined by TAN 15.
Amount of new residential development (units and proportion) permitted with SuDS.
Amount of new non-residential development (floorspace and proportion) permitted with SuDS.

Pollution contribution and risk of flooding will be crucial considerations by the DCC in assessing this proposed development.  TAN 15 was updated in March 2013, much later than this development was proposed.  The summary report from Waterman [sic] included in the application admits that the site is an area at risk of flooding and goes on to say that demolition of Glyndwr Road will cause a lessening of this risk … the reason given because the houses will no longer be there!  Instead there is to be a pedestrian walkway around Tesco to Rhydyrafon built above what is the diverted medieval mill leat.

The main part of the proposed retail development is to be raised on stilts, the architect and the Waterman report recognising that it will be built on land in the vicinity quite recently proven liable to flooding, with the next flood predicted to occur in 2015.  The cars in the lower parking area will be at the greatest risk, together with the low-lying residential properties in surrounding streets.

The ground underneath the site suffers from serious contamination, evidenced by a report in the application pack showing higher levels of remaining chemicals than are safe.

LDP Objective 18: To provide for the sustainable management of wastes and recovery of resources, aiming to minimise adverse environmental, human health, social and economic impacts, maximise social and economic opportunities, and meet the needs of communities and businesses.
We urge the DCC to be informed of how much food waste will be created each day from both proposed retail outlets as ‘sell-by’ and ‘best before’ dates expire in a constant stream. Will CCC be responsible for its disposal?  Farmers claim that meat sourced in Wales by Tesco travels for processing to plants England and back before being presented at Welsh stores.

Already adverse effects on ‘human health’, ‘environment’, ‘needs of communities’ have happened (by previous Daycentre individual users and groups, by residents of Glyndwr Road, by the ‘Lucas depot’ small trader, by the loss of use of the Drill Hall) and will happen to ‘businesses’ (all town centre small traders listed).  More adverse effects will occur before, during and in the aftermath of the development’s demolition and reconstruction.  Are surrounding areas to be protected and compensated for the great disturbance caused during the demolition and reconstruction period? Where is rubble to be disposed of?

Traffic snarl-ups already exist in Aberystwyth.  In the mornings traffic approaching town from the south can be held up from four miles away. If the development goes ahead, parking space will double and the hoped-for increase in numbers of consumers to the superstores will seek to drive into them from new traffic lights on Park Avenue from both directions. Future traffic congestion will inevitably become much worse, as has happened in Newtown in Powys.

The threat to peace and quiet, human health’, ‘environment’ in streets on the town approach roads by huge delivery trucks (estimated at 6-8 per day) through Penparcau and Trefechan, the strain on the Bridge structure itself, on lower Bridge Street, South Road, Spring Gardens, Mill Street and from the extended three lanes on Park Avenue will be enormous. No trucks this large or in such great numbers have ever before used these constricted routes but the disruption can easily be imagined and feared. Constant noise created by large vehicles’ arrivals and departures will cause ‘adverse effects to human health and wellbeing/quality of life’ both ‘singularly and cumulatively’ and will continue not only through the years of the construction period but forever afterwards.

Encourage a vibrant and diversified economy (LDP)
Experience and research at other towns has shown that the opposite of ‘a vibrant and diversified economy’ happens with the arrival of Tesco.  Aberystwyth is already well-provided for by 10 large food-stores:  Spar (x4), Co-op (x2), Morrisons, CKs, Lidl, Iceland (one of each of these) and an 11th in a planned Aldi on Park Avenue’s existing brown-field site (an ‘out of town’ development).  Two more food/clothing stores at the Mill Street development will threaten all these. CDF itself predicts that Morrisons will be adversely affected but that Tesco will absorb its ‘overtrading’, causing no risk to CDF as it owns both sites.  Eight existing single small in-town independent traders will be threatened – a greengrocer, a fishmonger, three butchers, three health food stores, as well as the numerous cafes. All will be adversely affected by two superstores providing identical commodities to their own, causing future limiting of consumer choice as the smaller providers go out of business.

A CACI marketing survey, used as justification for another supermarket, was carried out by interviewing 900 people in 2007 and as such bears little resemblance to today’s situation with the increase in online trading in the six years since.  Already, there are examples of failed larger retail ventures at Parc y Llyn and Parc Siopa’r Ystwyth: MFI (presently not occupied), Focus, Bathstore (replaced by B&Q and Mountain Warehouse respectively).

The question of loss of revenue to CCC/taxpayers may not strictly be a planning issue but we ask the DCC to consider that:

Only £3m is to be paid by CDF to CCC in exchange for a huge area (still ‘tight’ according to a CDF representative at a meeting recently) to provide 250 extra parking spaces and two commercial retail units. What was previously mostly publicly-owned space is now to become totally privately-owned, its profits going to CDF and out of Ceredigion.  Parking revenue presently received by CCC/taxpayers is to be forfeited for the length of the 105 years lease.  In exchange are an extra 250 parking slots, and around 300 of the 550 giving totally-free three-hour stays to benefit mainly the two stores. CDF has stated that the cost of providing each parking space is £10,000. Does replacement revenue in business tax receipts to CCC from these two retailers recompense CCC/taxpayers for loss of the present and future parking revenue?

Finally, the full loss of Park Avenue Day Centre is not evident in A130640. It is considered ‘in vacant possession’ able to be demolished and of no concern.

However, elderly and lesser-able members of society had an excellent provision in Park Avenue Daycentre Aberystwyth: a building with easy ground level access surrounded by a garden with mature trees, shrubs, a sitting-out covered shelter and 20 parking spaces. It was centrally placed and a part of the community.

Its replacement in Canolfan Alun Edwards Centre, an existing municipal building containing the Library & Archive, is in an inadequate space in a cellar below ground with no natural light and no outlook.  Access to it is down a ramp with a 360 degree turn, its patio area inaccessible.  It is out of the community area of town, its attendees hidden away from society. With CCC responsible for an increasing ageing population and retired people a large council tax contributor, this was an odd CCC decision.  Services at the ‘basement’ have shrunk and the number attending will dwindle by upping severity-of-need criteria.  For this poorer replacement facility (an afterthought of CCC) CDF will pay £1.2m when the Mill Street retail park is complete. CCC meanwhile borrows to cover its cost. No tenders were invited for this work but the work was allocated to the existing on-site building contractor.

We dispute the Equalities Impact Assessment (EIA) conducted by CCC Social Services Dept on this displacement and has pointed out CCC’s non-compliance with the Equalities Act.

A health and safety consultant in north-east Wales told us:
“wherever else Tesco build supermarkets Councils and planning authorities are generally aware enough to require suitable alternative premises and installations to try and benefit as many people as possible on the back of the application. I would have expected the Council to simply make the provision of a new day centre a purpose built part of the deal.”

This was not done for Aberystwyth.  The proper remedy would be the original Park Avenue Daycentre secured or a ‘like for like’ replacement provided. Replacing PADC with a ‘like for like’ facility and ‘like for like’ services in an equally good position in the future would be financially prohibitive, if not impossible.

We believe plan A130640 to be an example of a public benefit sacrificed to the pressure of commerce.

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RE: A130640 Mill Street Development proposals Aberystwyth

I wish to object to the above proposal for the following reasons:

Economic
Incompatibility; The size and scale of the proposal are incompatible with the surrounding area, economy, built environment and population. It will dominate the landscape, and not in a good way, and will dwarf other low-rise surrounding buildings. The square metre space for Tesco is also out of alignment with the local needs.
Adverse impact on the local economy; There are six other supermarkets operating in Aberystwyth: Morrisons, Co-op, Iceland, Lidl, Spar and CKs. Several of these chains have multiple sites. This is in addition to all the independent food shops. The local population, and those of travelling distance, are limited in number and it is unlikely that a seventh supermarket can really be economically viable. It is possible that at least one of the current food chain outlets would close following the opening of Tesco, and it’s more than likely that the independent shops whose product lines are covered by Tesco (greengrocer, baker, three independent health food shops, butchers and fishmonger) will lose considerable custom and ultimately close down.
The presence of a supermarket in a town does not necessarily lead to greater economic prosperity for the town – the money spent inside the supermarket goes out of the county and into the pockets of shareholders. This is unlike money spent in an independent shop as the profit made by the local business is more likely to be spent within the area.
Loss of historic cultural amenity in the form of the 1902 Drill Hall which is of high architectural and historic value, currently used as a storage facility but could be adapted to provide housing or a leisure amenity.
Adverse impact on the town centre: A vibrant town centre is not one with a Tesco on the edge of it. Many other towns with Tesco shops have seen large loss of footfall in the areas furtherst away from Tesco and loss of independent shops.
Adverse traffic implications: The proposal could lead to serious traffic problems on an already busy road and already congested approach roads. Problems could occur with the large delivery lorries as well as volume of traffic coming to the car park. In addition, there appears to be little provision or forethought given to cyclists.
Employment; The jobs that will be created are likely to be low-paid, part-time, and with poor conditions. This is not the sort of employment that will tempt graduate students to stay and is not the sort of employment that will keep young locals here. If any current local shops or current supermarkets close the job ‘creation’ will be minimal.

Sustainability
Adverse impact on housing and environment: Demolishing 12 habitable houses, with c. 40 people to be re-homed, is a waste of resources. Housing is at a premium in Aberystwyth and removing housing from the housing pool seems a rather peculiar step.
Adverse impact on the local biodiversity and environment: issues include loss of the enclosed garden of mature trees, plants and shrubs inside stone walls (former Day Care centre); waste of resources in the 12 homes and other buildings that would be demolished; loss of gardens of Glyndwr Road houses.
The Mill Street site is quoted by CCC in its LDP as a brown-field site (MO302). Yet a brown-field is defined as ‘reclaimed industrial property which has some level of contamination … reusable from industrial or commercial companies after under-use or abandonment.’ This site is currently an active car park and residential area with habitable homes, and previously had the purpose-built day care centre on site. It cannot be considered brown-field.
Adverse impact on the environment: in creating 500+ car parking spaces, the development will encourage car use. This will lead to increased congestion, increased air pollution, increased greenhouse gas emissions, increased fossil fuel use, and a detrimental impact on the environment. This is out of step with Welsh Government policies of decreasing car use and encouraging more active travel such as walking, cycling, or using public transport, and their goal of a carbon neutral Wales.
There appears to be no consideration of green energy production e.g. There are no solar or photovoltaic panels proposed or small scale wind turbines.
The proposed development is on a floodplain.

Moral
I personally do not believe it is morally acceptable to implement compulsory purchase orders on people’s home to make way for a large multi-national supermarket. There is no necessity for the proposed scheme to need this land.
The issue of the enforced closure of the day care centre for elderly people was also poorly handled, and unnecessary.

Democratic
The process and decision making has been far from transparent. The specific problem is that the Council apparently asked for tenders without including Glyndwr Road in the footprint, and yet the winning contract decided to include this street in their proposal.

Thus it seems that this proposal is incompatible with Ceredigion County Council’s Local Development Plan: pursuing this proposal would be at the detriment of various objectives as set out in the LDP, namely the Sustainability Objectives and others e.g. LDP Objective 11 (‘To conserve and enhance Ceredigion’s landscape (townscape) encompassing the visual, historic, geological, ecological and cultural environments.’).

It will have an adverse impact on the environment, the local economy, local inhabitants and local businesses and should not go ahead.

Please ensure a copy of this letter is sent to the Welsh Government should they call the proposal in.

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