Environmental Statement | November 2018 Volume 1: Non-Technical Summary - IEMA

Environmental Statement | November 2018 Volume 1: Non-Technical Summary - IEMA

Environmental Statement | November 2018
Volume 1: Non-Technical Summary
Environmental Statement | November 2018 Volume 1: Non-Technical Summary - IEMA
Temporary Variation to Event
Cap at Wembley Stadium
Environmental Statement
(November 2018)
Non-Technical Summary
Wembley National Stadium Limited

Environmental Statement | November 2018 Volume 1: Non-Technical Summary - IEMA
Temporary Variation to Event Cap at Wembley Stadium : Environmental Statement (November 2018)

1.0            Introduction and Methodology
1.1            This document is a summary in non-technical language of an Environmental Statement (‘ES’)
               prepared on behalf of Wembley National Stadium Limited (‘the applicant’). It accompanies an
               application submitted under Section 73 of the Town and Country Planning Act 1990. The
               application seeks to for to provide for any additional home games that Tottenham Hotspur
               Football Club (‘THFC’) may have to play at Wembley Stadium whilst they await certainty on the
               exact opening date of the new stadium. As such this new application seeks to enable up to 17
               additional ‘major sporting events’1 between 15 January 2019 and 12 May 2019 at the Stadium
               where the available spectator capacity is increased from circa 51,000 to: up to 62,000 for 10
               events and full capacity for up to 7 events.

1.2            The original planning application for the current Wembley Stadium (submitted in November
               1999) was accompanied by the Wembley Stadium ES (1999). In January 2017, an application
               (ref: 17/0368) was submitted to facilitate THFC’s occupation of the Stadium during the 2017/18
               football season. That application was accompanied by the ‘Temporary Variation to Event Cap at
               Wembley Stadium ES (January 2017) (‘the 2017 ES’) that was prepared pursuant to the (then)
               Town and Country Planning (EIA) Regulations 2011 (as updated).

1.3            This s73 application is a ‘new application’ in the context of the Town and Country Planning
               (Environmental Impact Assessment (‘EIA’)) Regulations 2017 (the ‘2017 EIA Regulations’) (as
               amended). For such applications, guidance states that the local planning authority should
               consider if further information on potential environmental effects may be required.

1.4            For this s73 application, it has been agreed with officers of London Borough of Brent (LBB) that
               it would benefit from relevant up to date environmental information on those aspects that could
               be affected by the proposal. The scope of the EIA has been agreed with LBB.

1.5            This document includes the following information: -
               •     Section 1.0 – background to the proposal;
               •     Sections 2.0 – background to, and scope of, the assessment process;
               •     Section 3.0 – a description of the site and the proposal;
               •     Sections 4.0 to 7.0 – a topic by topic review of the findings of the EIA;
               •     Section 8.0 – a review of whether other direct or indirect effects may arise when the scheme
                     is considered with other schemes in the area;
               •     Section 9.0 – summary of mitigation and monitoring identified through the EIA process;
               •     Section 10.0 – details of how to obtain a full copy of the ES.

               The EIA Process
1.6            The ES sets out the findings of an EIA of the proposed development.

1.7            The EIA process aims to ensure that any significant effects arising from a development are
               systematically identified, assessed and presented to help a local planning authority, statutory
               consultees and other key stakeholders in their understanding of impacts arising. If measures are
               required to minimise or reduce effects then these are clearly identified.

                 ‘Major sporting events’ are those where the spectator capacity at the stadium is increased from c51,000 to either 62,000 or

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1.8            For this development, EIA has been carried out to consider the likely significant effects that may
               arise during proposed temporary variation to the cap at Wembley Stadium and due to its
               potential relationship to future developments in the area. There are no physical works proposed
               and therefore no consideration of effects during construction or decommissioning is required.

1.9            The assessment has been completed with regard to best practice and relevant legislation and has
               addressed the following matters agreed with LBB as being required to assess the impacts of the
                 1. Socio-Economics                                      3. Air Quality
                 2. Transportation                                       4. Noise and Vibration

1.10           Likely effects are identified based on current knowledge of the site and surroundings, desktop
               assessment, survey and fieldwork and information available to the EIA team. All those matters
               that could be reasonably required to assess the effects of the proposals are set out in the ES. The
               assessment has had regard to the requirements of the 2017 EIA Regulations.

1.11           The EIA has had regard to planning and environmental policy and legislation at national,
               London and local level that is relevant to the development and the assessment process.

1.12           There were no significant difficulties in compiling information and testing impacts or the
               assumptions that have been adopted but examples of some of the matters experienced include
               information being unavailable to the team or the necessity to rely on reasonably available data
               or assumptions in carrying out the EIA and/or there being no accepted methodology to assess
               particular impacts (and therefore a need to rely on professional judgement and experience).

1.13           The applicant has assembled a team to undertake the EIA who, it has confirmed, has sufficient
               expertise and the necessary credentials to ensure the quality of the ES and that it is complete.

               Background to the scheme
               Tottenham Hotspur F.C.
1.14           THFC, founded in 1882, is one of England’s most successful and well supported football clubs.

1.15           Up until demolition commenced in May 2017, the Club’s home stadium was White Hart Lane
               Stadium in Haringey, where it had been based since 1899.

1.16           Planning permission was granted by the London Borough of Haringey in April 2016 for the
               ‘Northumberland Development Project’, which comprises the demolition of the White Hart Lane
               Stadium and construction of a replacement 61,000 capacity football stadium to act as the new
               home of THFC alongside associated non-football development. The stadium will be known
               initially as “Tottenham Hotspur Stadium”.

1.17           Through a series of subsequent non-material amendments, the capacity of Tottenham Hotspur
               Stadium has been increased to 62,062.

1.18           Construction of the new stadium commenced in the summer of 2016. Due to the siting of the
               new stadium relative to the old, a significant amount of construction works were undertaken
               throughout the 2016-17 season whilst the existing White Hart Lane Stadium remained in situ
               and in use, with the exception of one section of the North Stand which had been demolished.

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               Figure 1 - Aerial Photo of Northumberland Development Project

               Source:        THFC, October 2018

               2017-18 Season
1.19           To complete the Northumberland Development Project, including the new stadium, THFC
               needed carry out full demolition of the old White Hart Lane Stadium. THFC reached agreement
               with WNSL to play all its home fixtures at Wembley Stadium during the 2017-18 season.

1.20           Brent Council granted planning permission (LPA ref: 17/0368) on 18 October 2017 under
               Section 73 of the Town and Country Planning Act 1990 to vary the Wembley Stadium event cap.
               This enabled up to 22 additional major sporting THFC events between 1 August 2017 and 31
               July 2018 at Wembley Stadium under a new Condition 1. The permission was subject to a
               package of enhanced mitigation measures for THFC home games.

               2018-19 Season
1.21           At the time the previous application was made and determined, THFC expected its new stadium
               to be fully operational for the start of the 2018-19 season. Completion of the new stadium,
               however, has been delayed with the Club issuing further details through press releases in June,
               July, August and September 2018. On 26 October 2018, THFC released a statement which
               confirmed that it will continue to play its home games at Wembley Stadium for the remainder of
               2018 – the final game of 2018 being a Premier League fixture against Wolverhampton
               Wanderers on 29 December.

1.22           Table 1 below sets out all of the home games THFC has played and is currently scheduled to play
               at Wembley Stadium during the current season.
               Table 1 - Current Indicative Schedule of THFC Games for 2018/19 Season

                Date           Day             THFC Schedule
                18/08/18       Saturday        THFC V Fulham
                15/09/18       Saturday        THFC V Liverpool
                03/10/18       Tuesday         THFC V Barcelona
                06/10/18       Saturday        THFC V Cardiff
                29/10/18       Monday          THFC V Man City
                06/11/18       Tuesday         THFC V PSV
                24/11/18       Saturday        THFC V Chelsea

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                Date            Day              THFC Schedule
                28/11/18        Monday           THFC V Inter Milan
                05/12/18        Tuesday          THFC V Southampton
                15/12/18        Saturday         THFC V Burnley
                26/12/18        Wednesday        THFC V Bournemouth
                29/12/18        Saturday         THFC V Wolves
                05/01/19        Saturday         FA Cup R3
                07/01/19        Monday           Carabao Cup SF
                13/01/19        Sunday           THFC V Man Utd
                22/01/19        Tuesday          Carabao Cup SF
                26/01/19        Saturday         FA Cup R4
                30/01/19        Wednesday        THFC V Watford
                02/02/19        Saturday         THFC V Newcastle
                09/02/19        Saturday         THFC V Leicester
                12/02/19        Tuesday          Champions League R16 L1
                16/02/19        Saturday         FA Cup R5
                19/02/19        Tuesday          Champions League R16 L1
                02/03/19        Saturday         THFC V Arsenal
                07/03/19        Thursday         Europa League R16 L1
                14/03/19        Tuesday          Europa League R16 L2
                16/03/19        Saturday         FA Cup Quarter Final
                16/03/19        Saturday         THFC V Crystal Palace
                06/04/19        Saturday         THFC V Brighton
                09/04/19        Tuesday          Champions League QF L1
                13/04/19        Saturday         THFC V Huddersfield
                16/04/19        Tuesday          Champions League QF L2
                27/04/19        Saturday         THFC V West Ham
                30/04/19        Tuesday          Champions League SF L1
                07/05/19        Tuesday          Champions League SF L2
                11/05/19        Saturday         THFC V Everton
               Source: THFC

               Note: Does not include other ‘non-THFC’ matches scheduled to take place all of which assume attendance of 90,000
               Note: Those matches identified in bold are those that may operate at the full capacity of up to 90,000 as a result of higher ticket
               demand and safety matters. This is for indication only.

1.23           As outlined in its 26 October 2018 statement, THFC has highlighted that various factors beyond
               its control as well as possible unforeseen issues mean it is adopting a cautious approach in
               respect of the new stadium opening timetable. As a precautionary measure, therefore, and
               acting prudently, THFC has reached agreement with WNSL to provide for any additional home
               games that THFC may have to play at Wembley Stadium in the event that there is further delay
               in the Club’s occupation of its new stadium.

1.24           All of the additional THFC home fixtures could be played at Wembley Stadium at a capped
               capacity of 51,000 within the scope of the existing planning permission. Subject to WNSL’s
               event scheduling requirements, it is possible that additional full capacity events can be taken out
               of the pre-existing allocation also within the scope of the existing planning permission.

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1.25           Brent Council previously granted permission to allow an additional 22 uncapped games for
               THFC during the 2017-18 season (i.e. up to the maximum theoretical capacity of 90,000). The
               application was assessed and considered to be acceptable based upon the theoretical impacts
               arising from every one of the 22 games being played at the full capacity of 90,000. Actual
               attendances naturally varied quite widely depending upon a range of factors, including for
               example the opposing team and the away following; the day and time of kick-off; whether the
               game was televised; prevailing weather conditions; and home and away fans segregation.

1.26           The 51,000 cap figure was exceeded for 9 of the 29 competitive THFC fixtures at Wembley
               Stadium during the 2017-18 season. The maximum published attendance figure was 83,782
               versus Real Madrid FC in the UEFA Champions League on 1 November 2017, which was an
               effective sell-out. The average attendance across the season was approximately 62,000
               correlating coincidentally with the new THFC stadium capacity.

1.27           The capacity of THFC’s new stadium is 62,062, which represents the contractual commitments
               to season ticket holders and corporate hospitality spectators; away spectators; and game by
               game general admission spectators. THFC would therefore need to be able to cater for at least
               62,000 spectators (rounded) at Wembley Stadium for any additional home games that THFC
               may have to play at Wembley Stadium in the event of their new stadium not becoming
               operational in time. This would mean an increase of 11,000 spectators above the 51,000 cap.

1.28           Based upon corresponding attendances during the previous 2017-18 season, and the new
               capacity at the new stadium, THFC is seeking the majority of any further home games to be
               permitted at 62,000 - rather than the previously approved maximum capacity of 90,000.

1.29           There are however several higher profile fixtures where ticket demand is likely to be significantly
               higher and safety issues need to be taken into account. These fixtures could potentially include
               Premier League derby matches (e.g. Arsenal and West Ham), European competitions
               (Champions or Europa League) and domestic cup competitions (FA and Carabao Cup). Which of
               these higher profile fixtures will need to operate at full capacity is not known at this stage and
               will be dependent upon (a) progression in the competitions; (b) nature of opposition drawn and
               (c) whether cup fixtures are drawn at home or away. The ability to play a few games above
               THFC’s contractual minimum of 62,000 also allows the Club to continue its programme of
               issuing free match tickets to local community groups.

1.30           THFC is, therefore, seeking up to a maximum of seven games at an uncapped capacity, with the
               remaining ten games capped at a capacity of 62,000.

1.31           THFC’s use of Wembley Stadium as the home ground for all domestic and European games for
               one season continues to be the most fitting solution as there remains a lack of suitable
               alternative stadiums that are available, have appropriate spectator capacity and are located
               within a reasonable distance for the majority of THFC’s fan base.

1.32           If THFC reach games already scheduled to be held at the Stadium under the Condition 1 cap, e.g.
               the 2019 FA or Carabao Cup finals, then such games would be held under the existing cap.

1.33           Detailed scheduling work has been undertaken by both THFC and WNSL to confirm that THFC
               fixtures and Wembley Stadium’s existing event commitments can be accommodated.

               THFC supporter profile
1.34           THFC has a growing fan base across London, including in Brent, and has a paid-for season
               ticket waiting list of 76,600 (as of September 2018). Hosting games at Wembley Stadium at full
               capacity is considered a great opportunity to provide more supporters with a chance to see their
               team play live, especially for those living in Brent and West London.

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1.35           A combined 266,925 people attended the four THFC European fixtures held at Wembley
               Stadium last season, including over 2,500 residents from Brent have purchased tickets to attend
               at least one game. The Police, British Transport Police, other emergency services and the
               Stadium Operators viewed those events as operationally successful with no major incidents or
               problems reported. All THFC events have been subject of ongoing review and discussion at the
               Wembley Stadium Safety Advisory Group and the Transport Operations Group (“WSTOG”).

1.36           THFC fans are also viewed as generally well behaved with no history of regular fan related
               violence at home or away over the past 10 years in domestic and European competition.

1.37           In addition, the atmosphere in and around Wembley Stadium has been very different with
               THFC in situ as the home team in comparison with a 50/50 supporter split that is typically
               encountered at Wembley during cup finals.

               THFC operational policies
1.38           THFC takes the safety and stewarding of fans extremely seriously. The Club’s full-time safety
               team work closely on a day to day basis with all emergency services, both to develop and deliver
               best practice but also as part of the Safety Advisory Group, which provides a forum for
               discussing and advising on public safety at White Hart Lane. All THFC fixtures at Wembley
               Stadium are planned and managed according to the risk rating assigned to the fixture by the
               Metropolitan Police. This guides both THFC and WNSL in terms of operational planning for the
               event and importantly the required number of stewards and police to be on site.

1.39           THFC’s approach to safety and building control has been one of pro-active management,
               developing strong relationships with the Haringey Building Control team and establishing the
               ‘Fanbassador’ Programme. The Fanbassador Programme introduces stewards focussed on
               customer service and providing support and information to supporters in the environs in local
               streets and the areas outside the stadium.

1.40           THFC’s commitment to safety and stewarding extends beyond the management of their own
               stadium in Tottenham. THFC is one of the only football clubs who send stewards to every away
               game regardless of opposition or venue, providing continuity for fans but also helping to
               reassure each team and venue of the responsibility the Club is taking for its own fans behaviour.

1.41           THFC has worked extremely closely with WNSL and the FA safety teams to ensure that the
               standards set at White Hart Lane Stadium are delivered at Wembley. Many of the measures the
               Club carry out have been put into practice during THFC recent tenure at the Stadium, e.g.:-
               1     Bringing up to 150 of its Stewards to Wembley to act as part of match day operations. Many
                     of these are customer service trained and part of the Club’s Fanbassador programme. By
                     deploying THFC stewards at Wembley, it provides Tottenham Hotspur supporters with
                     familiarity and a more direct ‘home from home’ approach;
               2     An ongoing knowledge-sharing programme between the THFC and WNSL teams with both
                     visiting each other’s venues, attending events and regularly updating on emerging issues;
               3     THFC working with the Metropolitan Police to make use of the Dedicated Football Officer
                     at Wembley, given his knowledge of THFC’s match day operations;
               4     Ongoing use of the THFC Safety and Security Team Text Service which allows fans to
                     anonymously alert the team to any issues which occur inside the ground;
               5     The Club’s Safety Officers and their team will continue to be a constant presence for every
                     discussion around THFC matches at Wembley alongside the Club’s Supporter Liaison and
                     Community Relations Teams. The THFC Safety Officer is present at every match; and,

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               6     The Club will also continue to have representation on the WSTOG, which is attended by
                     transport operators and key stakeholders, including Brent Council.

2.0            Site and Surroundings
2.1            The Wembley Stadium site has been in use for major events since the opening of the original
               Wembley Stadium in 1923. The original stadium hosted major international and domestic
               footballing games and significant non-footballing events such as the 1948 Olympic Games and
               major musical events. It was also used occasionally as the home stadium for domestic football
               teams, including for Arsenal during their 1998-9 and 1999-2000 Champions League seasons.

2.2            The original stadium became outdated and no longer met the standards in terms of facilities
               that were expected at a major venue. In December 1996 the Sports Council confirmed Wembley
               as the preferred location for a new English National Stadium catering for a wide range of sports
               and entertainment uses. This was followed by the submission of a planning application for a
               new Stadium which was submitted in November 1999.

2.3            Permission was granted in August 2002 and the new Wembley Stadium was constructed and
               opened in 2007. It is now recognised as a major international and local sporting and non-
               sporting venue and has also acted as a catalyst for redevelopment and as a means of attracting
               new investment to the Wembley area. The area surrounding the stadium has been, and
               continues to be, the subject of significant development activity of a range of commercial,
               residential, leisure and community facilities.

2.4            The Stadium is run by the Wembley National Stadium Limited (‘the applicant’), which is a
               subsidiary of the Football Association.

               Site Description
2.5            The stadium complex comprises the stadium building itself surrounded by an elevated
               concourse, ground level car parking to the north east and multi-storey parking to the south west.
               Figure 2 - Aerial Photograph showing the Site and Surrounding Area

               Source:        Google Earth

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2.6            The site is broadly bounded by: -
               •     Leisure, employment, hotel and retail uses alongside ground level parking and the Brent
                     Civic Centre situated either side of Olympic Way (which runs north from the Stadium to
                     Wembley Park Station). To the immediate north of the stadium are a number of
                     construction works with information indicating that these are due for completion in 2020;
               •     Wembley Park Employment Area to the east;
               •     The residential area of Tokyngton, is located to the south of the site, and is separated from
                     the stadium by the main Chiltern rail line;
               •     The Wembley Arena and retail and leisure uses developed under the Quintain Estates urban
                     renewal project to the west.
2.7            There are very limited residential properties within the immediate vicinity of the Stadium or on
               the key linkages between the Stadium and the key public transport connections.
               Figure 3 - Key Landuses Surrounding the Stadium

               Source:        Lichfields

2.8            The Stadium is well served by public transport including:-
               1     Wembley Central Station (to the south west of the stadium);
               2     Wembley Park Station (to the north of Olympic Way);
               3     Wembley Stadium Station (adjacent to the south west of the Stadium); and
               4     50 bus stops located within a 20 minute walk which provide access to 18 bus services.
2.9            The Stadium is also well connected with the main trunk road network. There are currently three
               vehicular routes serving the Stadium, two of which connect with the six lane North Circular
               Road (NCR/A406). The NCR serves the north London area. It provides links with main axial
               routes into central London and out onto the motorway network, including the M25.

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3.0            Description of Proposal
3.1            The amendment to Condition 1 of planning permission LPA ref: 17/0368 would allow THFC to
               use the Stadium for up to 17 additional major sporting events. This would be for a temporary
               period between 15 January 2019 and 12 May 2019 to cover the period up to the end of the
               domestic football season where the available spectator capacity is increased from c. 51,000 to
               62,000 for 10 of the events (i.e. potential additional 11,000 spectators per event) and up to full
               capacity for up to 7 events. These would be in addition to the 22 full capacity sporting events
               currently allowed per season.

3.2            There could be up to 28 THFC home fixtures in all competitions over the 2018-19 season (from 1
               November 2018 to 12 May 2019). In practice however, and based on recent averages, the total
               number of THFC games likely to be hosted at Wembley Stadium is expected to be below this
               number. The proposed “temporary cap” figure of 17 allows for the possibility that THFC is first,
               very successful in all cup competitions and secondly, drawn at home for all its games (with up to
               4 further games to be accommodated under the existing full capacity sporting events cap) and
               the remaining games falling under the capacity cap.

3.3            For the avoidance of doubt, because the “temporary cap” relates to THFC events, in the
               anticipated situation where fewer home games than the maximum are drawn, the temporary cap
               does not allow for additional full capacity events for other purposes to be hosted by Wembley
               Stadium. This was the case during the previous 2017-18 season where only 14 of the 22
               additional full capacity THFC events were required.

3.4            It should also be recognised that the Wembley Stadium schedule for the 2018-19 season allows
               for up to four THFC events to be hosted within the existing full capacity event cap (of up to 22
               major sporting events and 15 major non-sporting events), thereby minimising the overall
               number of additional full capacity events hosted in the 2018-19 season (while maintaining
               commercial and contractual obligations).

3.5            Within the period of the proposed THFC events (15 January 2019 to 12 May 2019), Wembley
               Stadium’s event schedule is currently expected to contain at least 8 further sporting events
               utilising the full capacity of the stadium.

3.6            Given Wembley Stadium is unrestricted in terms of the number of events for up to circa 51,000
               spectators, the application is, in effect, seeking permission for additional events where up to an
               additional circa 11,000 (for 10 games) or circa 39,000 (for up to 7 games) spectators are in
               attendance; although not all matches would be expected to be fully attended to these levels, as
               was the case in the 2017-18 season.

3.7            Following pre-application discussions with Council officers, the amendment is sought under
               Section 73 of the Town and Country Planning Act 1990 by way of a variation of Condition 1
               attached to planning permission LPA ref: 17/0368. As discussed with officers in advance of
               application submission, the condition is suggested to be amended to read as follows (text in bold
               indicates amendments):

               That until the following works are completed to the satisfaction of the Local Planning
               Authority and written confirmation as such is given to the applicant or owner or occupier:

               1. Improvements to Wembley Park Station to achieve a capacity of 50,000 persons per hour

               2. Construction of roads known as the Estate Access Corridor and the Stadium Access Corridor

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               and unless alternative details are submitted to and approved in writing by the Local Planning
               Authority and the approved details are thereafter implemented in full, the number of major
               sporting events held at the stadium in any one year shall be restricted to no more than 22 (to
               exclude European Cup and World Cup events where England/UK is the host nation) and the
               number of major non sporting events shall be restricted to 15. This shall be described as the
               cap. Up to three additional major sporting events shall be permitted in any one year provided
               that for each additional sporting event there is a reduction of two non sporting events in the
               same year.

               Up to 17 additional major sporting THFC events shall be permitted between 15
               January 2019 and 12 May 2019 including up to 7 full capacity THFC events.

               If after two years following the completion of the stadium the works specified above have not
               been completed, and until such time as the works have been completed, then additional events
               over and above the cap specified above shall be permitted subject to the number of spectators
               being limited to the capacity of the lower and middle tiers of the stadium. leaving the upper
               tier unoccupied.

               Note: for the purposes of this condition major event means an event in the stadium bowl with
               a capacity in excess of 10,000 people which may or may not involve Tottenham Hotspur
               Football Club and major sporting THFC event means an event involving Tottenham Hotspur
               Football Club with a capacity up to 62,000 people. Full capacity THFC event means
               an event involving Tottenham Hotspur Football Club where the stadium can be
               utilised to its full capacity.

3.8            The THFC major sporting events will be managed in accordance with the arrangements already
               used for other major events as was the case in the 2017-18 football season.

3.9            In addition to the amendments to Condition 1, a Deed of Variation to the S.106 agreement will
               be prepared and refined based on the experience gained during 2017-18 season). These include:
               1     Implementation of a Tottenham Hotspur Foundation Programme which included activities
                     in the following areas - employment/skills, education and health;
               2     Payment of an ‘Initial Contribution’ to cover matters including Pirate Parking, Radio
                     Systems and protective clothing for traffic management staff;
               3     Implementation of a Stewarding Strategy and Supporter Communications Plan;
               4     Payment of ‘Per Event Contributions’ for each Major Sporting THFC Event covering, for
                     example, street cleansing, anti-ticket tout initiative and temporary traffic management;
               5     Implementation of a scheme to tackle illegal street trading for THFC Events;
               6     Employment of a Community Engagement Officer for the temporary period;
               7     Payment of a ‘Parking Enforcement Cost’ for each Major Sporting THFC Event; and,
               8     Compliance with Travel Plan.
3.10           WNSL, THFC and Brent Council are in discussions regarding the S.106 agreement.

               Alternatives Considered
3.11           It is good practice to consider alternatives for the proposed development. This helps in
               clarifying the main advantages for taking forward the current scheme, taking account of the
               environmental effects.

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3.12           The temporary requirement for THFC to relocate from its home stadium at White Hart Lane is
               subject to a series of key parameters including relocating to a stadium of a scale able to host
               THFC games, availability of the stadium for THFC matches during the 2017/18 season and a
               location within a reasonable travelling distance for THFC fans. The identification of Wembley
               for this purpose has been identified as the most appropriate and reasonable location which
               meets the identified parameters. It is therefore not considered necessary to consider any other
               alternatives as part of the EIA process.

4.0            Transport
4.1            An assessment has been carried out of the effect of the proposal on transport conditions around
               the stadium on event days. Impacts have been assessed with a focus on any effects caused by
               the temporary increase in the frequency of event days over the defined period.

4.2            In respect of current highway conditions and public transport provision, the following can be

               Existing Conditions
               Official Car Parking
4.3            During the 2017/18 football season, four official car parks were utilised by spectators on
               Wembley Stadium Event Days. Overall, the extant Wembley Park Masterplan planning
               permission (reference: 15/5550) allows up to 3,380 commercial car park spaces to be provided
               at any one time and WNSL has the use of up to 2,900 of these spaces on an event day.
               Figure 4 - Official Stadium Car Parks

               Type of Travel
4.4            A total of 27 THFC games were played in the study period, with the club using Wembley as its
               home stadium for the 2017/18 season. The average mode share for spectators across the
               monitored THFC matches was as follows:-

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Temporary Variation to Event Cap at Wembley Stadium : Environmental Statement (November 2018)

               Table 2 - Average THFC Football Spectator Mode Share

                   Mode of Transport                                   Mode Share
                   Car                                                 7.0%
                   Coach                                               2.7%
                   Motorcycle                                          0.0%
                   Blue Badge                                          0.4%
                   Minibus                                             0.2%
                   Mainline Rail & London Underground                  80.5%
                   Other                                               9.2%
                   Total                                               100.0%

               Highway Network
4.5            The following key points are relevant in respect of current conditions on event days:-
               1      Ingress - Event day traffic management measures begin on the morning of an event,
                      however road closures only begin approximately four hours before the start of an event. The
                      vast majority of spectator ingress is observed to take place in the two hours before kick-off.
                      On event days, part of Great Central Way operates as a tidal flow system with arrival
                      providing two inbound lanes and one outbound.
               Figure 5 - Official Ingress Routes

               2      Egress – generally occurs in the two hours following an event finish. By this time, the
                      official car parks will be mostly empty and the traffic management schemes are removed
                      shortly after this time. The tidal system that operates on Great Central Way is reversed to
                      provide two outbound lanes and one lane inbound. Egress from car parks is supported by
                      marshals which stop traffic attempting to travel eastbound on Royal Route.

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Temporary Variation to Event Cap at Wembley Stadium : Environmental Statement (November 2018)

               Figure 6 - Official Egress Routes

               3     Reverse Flow Scheme - The above ingress and egress arrangements to the east of the
                     stadium represent the normal traffic management for events days. For a number of events
                     (where traffic congestion is expected), Wembley Stadium operates a ‘Reverse Flow’ traffic
                     scheme on South Way to provide a direct route to Great Central Way from Green Car Park.

               Mainline Rail
4.6            Access to mainline rail services are available from both Wembley Stadium station and Wembley
               Central station. Wembley Stadium station offers access to Chiltern Railways and has a capacity
               of approximately 7,000 people per hour. On event days where the stadium is expecting over
               40,000 spectators, the station operates a Disney style queuing system. This involves laying
               barriers on White Horse Bridge that create a zigzagging queue to each platform.

4.7            Wembley Central station offers access to London Midland, London Overground and Southern
               Railway. To cope with the passenger demand of this station on an event day, Wembley Central
               station operates an ‘event bridge’. The aim of this is to form a queue on London Road without
               impacting High Road. Spectators are directed to queue (on London Road) to the east of the
               station before using the event bridge to cross the railway tracks and access their desired

               London Underground
4.8            Access to London Underground services is via Wembley Park station and Wembley Central

4.9            Wembley Park station provides access to both Metropolitan and Jubilee lines that allow for
               connections to Central London, Amersham, Chesham, Uxbridge and Stanmore. Wembley Park
               station is heavily used on an event day, often recording total usage figures of 40,000 spectators,
               with southbound services towards London accounting for a large proportion of this figure. This
               station has a capacity of approximately 50,000 people per hour.

4.10           Wembley Central Station provides access to the Bakerloo line that allows for connections to
               Central London and Harrow and Wealdstone. This station has a capacity of approximately
               12,000 people per hour.

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Temporary Variation to Event Cap at Wembley Stadium : Environmental Statement (November 2018)

               London Buses
4.11           There are 50 bus stops located within a 20 minute walk of Wembley Stadium, which provide
               access to 18 bus services.

4.12           On event days, there are a number of road closures and traffic management measures in place to
               ensure the safe moment of Wembley Stadium spectators and client vehicles. Some of these
               measures have an impact on bus routes and require route diversions. These service diversions
               have been agreed with TfL London Buses and LBB.
               Figure 7 - Public Transport at Wembley Stadium

               Cycling and Pedestrian
4.13           Olympic Way is a pedestrianised route which provides the main spectator access from Wembley
               Park station to Wembley Stadium. On event days, during the ingress and egress periods,
               spectator access from Olympic Way to Wembley Park station is coordinated by WNSL stewards,
               the Metropolitan Police, British Transport Police and London Underground. During high
               capacity events at WNSL, traffic management measures are put in place to segregate pedestrians
               and vehicles on Olympic Way, which may include the closure of Engineers Way and Fulton

4.14           During event egress, South Way is closed to traffic from the junction with Wembley Hill Road to
               Harrow Road to ensure the safety of pedestrians accessing Wembley Central station.

4.15           Wembley Stadium has 40 cycle parking spaces situated within the Stadium at level B2 that are
               managed by WNSL and available for staff and visitors.

               Existing Traffic Management Measures
4.16           In addition to those identified above, a range of traffic management measures are already in
               place on event days that will continue during THFC’s temporary occupation of Wembley

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Temporary Variation to Event Cap at Wembley Stadium : Environmental Statement (November 2018)

               1     Event Day Public Transport Overlays (additional services on underground and overground
               2     Implementation of controlled parking zones and event day signage;
               3     Crowd retention measures to extend the period over which spectators depart the stadium;
               4     Promotion of public transport through ticketing and the provision of information online;
               5     Enforcement against illegal car parking.
4.17           Furthermore, following recommendations in the previous S73 application (ref: 17/0368) a
               Community Fact Sheet was circulated to local businesses and resident groups and the cap
               preventing the number of lane drops on the A406 to no more than 30 was removed.

               Summary of Effects
4.18           The assessment of effects on event days has shown that the existing measures (identified above),
               operate effectively and have helped improve the transport conditions around the stadium since
               it opened in 2007. In addition to this it also presents the proposed mitigation measures that can
               be used to reduce any impact caused by the additional sporting events which will reduce the
               overall minor adverse effect in transport terms of these proposals.

               Mitigation and Monitoring
4.19           The mitigation measures proposed include the continuation of the spectator communication
               strategy imposed by THFC, LBB and WNSL during the 2017-18 season; amendments to the
               existing Wembley Stadium Protective Parking Scheme; implementation of a traffic management
               scheme at the junction of Fulton Road and Olympic Way and also the submitted Spectator Event
               Day Travel Plan.

5.0            Air Quality
5.1            An assessment has been carried out of the potential air quality effects arising from the proposal
               with particular regard to up to date legislation and methodological approaches to assessment.

               Existing Conditions
5.2            From LBB’s review and assessment work, eight air quality monitoring sites close to the proposed
               development measured concentrations of NO2 which were above the annual mean objective
               between 2013 and 2017. Additionally, the proposed development is located within the LBB
               AQMA designated for exceedances of the annual mean NO2 objectives and the 24-hour mean
               PM10 objective. Recent monitoring of PM10 undertaken near the proposed development, found
               exceedances of the daily PM10 objective but that annual PM10 concentrations were below the
               respective air quality objective.

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Temporary Variation to Event Cap at Wembley Stadium : Environmental Statement (November 2018)

               Figure 8 - Air Quality Monitoring Locations

               Summary of Effects
5.3            The air quality effects of the operation of the proposed development have been considered at
               sensitive receptors, using an atmospheric dispersion model. The model has been verified against
               air quality monitoring data and has been used to estimate the air quality effects of the proposals
               using detailed traffic forecasts.

5.4            The proposed development results in negligible changes in the concentrations of all modelled
               pollutants at all receptors. In accordance with the IAQM significance criteria adopted for the
               assessment, effects are concluded to be not significant. This same conclusion was found in the
               previous air quality assessment undertaken for the previous cap extension in 2017.

5.5            The proposed development is not considered to conflict with any national, regional or local
               planning policy within LBB. No mitigation measures will be required.

6.0            Noise
6.1            An assessment has been carried out of the potential for effects on noise arising from the
               temporary variation to the cap at Wembley Stadium. It was informed by a review of existing
               data sources and noise monitoring during January 2017.

               Existing Conditions
6.2            The assessment has shown little change in the noise climate over the last 17 years since
               consideration of this issue as part of the ES submitted with the application for the current

6.3            The existing noise sensitive premises around the stadium already experience noise from football
               matches and have done so for many years. Furthermore, residential properties constructed
               after the completion of the new stadium are subject to additional acoustic requirements which
               required that the buildings should be designed to have adequate sound insulation to minimise
               the noise impact from all sources.

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Temporary Variation to Event Cap at Wembley Stadium : Environmental Statement (November 2018)

               Figure 9 - Noise Monitoring Locations

6.4            Typically, noise from football matches is intermittent in nature (around 30 seconds when a goal
               is scored) and over a shorter period of time (approximately 3 hours including pre-match and
               half-time) than that of a music event or construction noise for example. Given that Wembley
               Stadium has been used for sporting events since construction of the stadium in 1924, the
               character of the noise from the proposed activities in terms of level and duration would be no
               different to what is experienced currently and has been for many years.

6.5            Activity noise from a football event consists of crowd noise and PA noise. Typically, the hour
               before the match consists of music, adverts and announcements from the stadium PA system.
               During the match itself the dominant noise source is crowd noise. At half-time the dominant
               noise source is typically announcements and entertainment from the stadium PA.

6.6            Concerts are generally considered to have a greater noise impact on the local community than
               sporting events.

               Summary of Effects
6.7            The proposals for additional football fixtures consist of discrete events of a relatively short
               duration (3 hours on each occasion), within which there would be intermittent, short term-noise
               events (i.e. goals etc) lasting for around 30 seconds. It is proposed that these events will occur
               on an additional 17 occasions over a maximum period of 4 months. Given the short-term nature
               of the events on a temporary basis and the finishing times, it may be considered that the noise
               impact would be slight or negligible based on the increase in the number of matches alone.

               Mitigation and Monitoring
6.8            Whilst mitigation measures are not considered necessary, it is recommended that monitoring of
               the noise from events could be carried out in the event that concerns arise during the operation
               of the temporary variation in the cap.

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Temporary Variation to Event Cap at Wembley Stadium : Environmental Statement (November 2018)

7.0            Socio-Economics
7.1            An assessment has been carried out of the effect on socio-economic characteristics associated
               with the temporary variation to the cap. An analysis of existing land uses and the population
               characteristics of the area has been undertaken. A study area boundary has been defined to
               incorporate the communities which are likely to be affected by the additional events.
               Figure 10 - Study Area for Socio-Economic Assessment

7.2            The analysis identified that the proposed temporary cap at Wembley Stadium will have a minor
               beneficial socio-economic impact on the study area and across the London Borough of Brent.

               Existing Conditions
7.3            The key features of the demographic and economic conditions of the study area surrounding
               Wembley Stadium can be summarised as follows:
               1      A relatively young population, with a large (71%) proportion of adults of working age and a
                      low proportion of people of retirement age (11%);
               2      Significant Asian and Black/African/Caribbean populations, higher than Brent or London;
               3      Levels of economic activity (67%) and unemployment (7%) that are consistent with the
                      Borough and London;
               4      A lower level of people in managerial and professional work, with a higher proportion
                      employed in processing or elementary occupations; and
               5      Home ownership levels that are consistent with London, with lower social renting levels but
                      higher private renting levels.

               Summary of Effects
7.4            The socio-economic effect of the proposed temporary variation to the event cap identifies the
               following assuming the occupation of THFC at the stadium up to the maximum identified:-
               Table 3 - Summary of Socio-economic Impacts

                   Impact                                                           Maximum Case
                   Additional Spectators                                            383,000
                   Additional Steward Positions Required                            18,100
                   Additional Catering Staff Positions Required                     8,500
                   Additional Expenditure                                           £9.96 million
               Source: - Lichfields analysis

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Temporary Variation to Event Cap at Wembley Stadium : Environmental Statement (November 2018)

7.5            The proposed variation to the event cap to allow THFC to use Wembley Stadium for the 2017-18
               will bring additional expenditure and employment to Wembley and its surrounding area. No
               mitigation measures are considered necessary in respect of the proposal.

8.0            Cumulative Assessment
8.1            The table below reviews whether effects may arise when the temporary variation to the cap is in
               place at the same time as the construction of development in the area surrounding the stadium.
               Table 4 - Summary of Effects with Mitigation in Place

                   Environmental Topic       Effects during Temporary Variation to Event Cap    Cumulative Effects
                   Socio-Economics           Minor beneficial                                   No change
                   Transport                 Minor adverse                                      No change
                   Air Quality               Not significant                                    No change
                   Noise                     Negligible                                         No change

8.2            Based on information available, the above cumulative assessment shows that there are unlikely
               to be any additional adverse impacts on, or as a result of, the construction of schemes in the area
               surrounding the stadium taking place at the same time as the temporary variation to the cap is
               in place. There will be an ongoing reduction in areas available for informal parking as
               construction works in the surrounding area progress but the existing transport management
               measures in place are considered adequate to address any issues.

8.3            Beneficial effects have been identified on socio-economic conditions in the area during the
               temporary period in which THFC would operate from the stadium.

8.4            Given the short term temporary nature of the development, there are no additional mitigation
               measures required to address cumulative impacts that have not been previously identified in
               this ES or already in operation on match days at the stadium.

9.0            Delivery of Mitigation and Monitoring
9.1            The EIA process has identified a need for mitigation measures which can be secured via
               planning condition or via legal agreement should planning permission be granted that will
               ensure the conclusions of the ES can be secured and that effects will be negligible or kept to an
               absolute minimum.

9.2            A legal agreement (s106 Agreement) will be put into place in any event to provide a number of
               financial contributions to various other measures including those identified in the transport
               assessment and associated with the management of the development during its operation.

10.0           Availability of the Environmental
10.1           A paper or electronic (CD Rom) copy of the full ES can be obtained from:-
               •     Lichfields, 14 Regent’s Wharf, All Saints Street, London N1 9RL (Tel: +44(0)20 7837 4477)
10.2           Information on the planning application and the ES can be viewed on the website of LBB at:-
               •     http://www.brent.gov.uk/.

10.3           All comments on the ES (and planning application) should be issued to LBB directly.

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