BSCF's comments on Aldi's plans to enlarge premises and car park
East Herts District Council
|23 March 2015|
Dear MartinYOUR REF:3/15/0343/FUL
Extension to foodstore and extension to car park and landscaping.
Aldi, London Road, Bishop's Stortford
1. I am writing on behalf of the Bishop's Stortford Civic Federation to comment on these proposals to expand the car park and the floor space of the Aldi supermarket in Bishop's Stortford.
2. The site is within the Bishop's Stortford conservation area and some of the buildings on it appear to be an interesting relic of the town’s more industrial past. However, they have been a derelict eyesore for many years and it is difficult to see how they could be adapted to the business of their present owner. The applicant’s proposals are far more in scale with the surrounding area and a more suitable use of the site than previous suggestions that apartments should be built there. The Civic Federation therefore welcomes the approach and intended use embodied in this planning application.
3. We do however, have some concerns, and these are related entirely to the traffic congestion implications of the proposals.
History of the Development
4. Planning permission was granted for the current use of the site in 2011. At that time, the applicants argued that the traffic it would generate would amount to no more than the previous use of the site some years before as a car showroom and garage. Herts Highways’ advice on the assessment was as follows:
‘Whilst I do not formally accept the rational [sic] behind the figures, I am content that, after carrying out my own TRICS assessment, there will not be a significant increase in traffic generation as a result of this development.’
5. To outside observers, Herts Highways’ conclusion on traffic generation always seemed implausible, based as it appeared to be on the notion that this would be akin to the kind of store attached to a petrol filling station or a Tesco Express where you might pop in for a pint of milk. In our view, a developer would not have provided a 74 space car park unless it was expected to be fully used.
6. And that indeed has proved to be the case. The car park, as shown in the assessment accompanying this application, has a very high occupancy ratio (over 100% on occasions). Moreover, observation suggests that these are not in the main casual or opportunistic shoppers, but customers who use Aldi as their main or sole provider of food and groceries. While significant traffic generation might have been expected anyway, the problem has been compounded by the development of Aldi’s business model to position itself as a major competitor to the big four supermarket chains, a development which has occurred largely since planning permission was granted in 2011. The most recent data show that Aldi’s sales nationally have risen by 19.3% in the last three months alone, giving it a market share of 5%, and there is no reason to suppose that this trend is suddenly going to stop or go into reverse.
The Traffic Assessment
7. In looking at the traffic impact of the proposed extension, it is therefore necessary to look at the potential demand generated as though it were another Tesco or Sainsbury – not as a slightly larger Spar or Nisa. This means that it will not simply intercept traffic that would otherwise have gone to the town centre. It will be taking traffic from the Bishop’s Park Tesco, for example, which would not necessarily otherwise have been on this part of the road network at all. And it will also draw in traffic which would not otherwise have come to Bishop's Stortford. The nearest alternative Aldi or Lidl stores are in Harlow and Welwyn Garden City – some considerable distance away – and so this store will be a new attraction for people living in places such as Stansted or Dunmow.
8. However, the traffic assessment has not done this. Instead it takes as its reference point (para 4.3.2) the TRICS data for all such stores from 2000 to the present. This will of course substantially underestimate the demand for two reasons. Firstly it accumulates the data for all such stores, the great majority of which will be of the filling station or Tesco Express variety. Secondly, by averaging the data from 2000 to the present it masks the very recent increase in market share gained by Aldi and Lidl at the expense of the traditional supermarkets. For most of the period in question their combined market share would have been less than 1%.
9. The assessment expresses surprise (para 4.3.4) that the traffic using the Bishop's Stortford store is almost off the scale compared with the TRICS data. It concludes nevertheless (para 4.6.1) that the proposed extension would not substantially affect the traffic generation of the store even after an ‘arbitrary’ uplift of 20% to reflect demand which may currently be suppressed by inability to find a parking space. Indeed their preferred outcome is that traffic congestion will actually reduce because there will be no extra demand but customers will find it easier to park.
10. They rely for this remarkable conclusion – a larger store and car park leads to less congestion – on the disingenuous assumption that the store does not intend to increase the product range on sale, but instead improve the internal circulation in the aisles. Since Aldi’s product range only amounts to 2500 items (only a tenth of what a traditional supermarket would stock), this store may well sell most of the range already. And even if it does not, how long this would remain Aldi’s intention will no doubt depend on future sales performance, and could hardly be enforced as a planning condition. Once it is accepted that Aldi has become a substitute for the large supermarket chains, there is no reason to suppose that it will not continue to attract increased patronage and no evidence has been advanced to suggest that it will not do.
11. The most prudent assumption to make therefore is that the car park occupancy ratio will continue to be much the same as now and that the traffic movements into and out of it will be 35% higher, in line with the increase in parking spaces and sales floor area. It does not take transport modelling expertise to require the applicants to use prudent assumptions rather than those on which the traffic assessment is based. But it does mean that they need to do the assessment again.
12. It is particularly important that the impact should not be understated as it was with the original planning permission, because this part of the road network is the most congested in the town and the subject of an AQMA. It should also be noted that while assessments typically concentrate on morning and evening peaks and Saturday for retail, the store also causes problems at other times. On a personal basis, on a recent Sunday at midday it took me 10 minutes to drive from Hockerill traffic lights to the first junction with Crescent Road (about 800 metres), solely because of delays caused by vehicles trying to get into and out of the Aldi car park.
13. As I said in the introduction to this letter, the Civic Federation supports the principle of the proposed expansion. Anticipating that a realistic traffic assessment will show the need for mitigation measures, in contrast to the applicants’ offer of nothing, we have a proposal to make.
14. We believe that the best way of alleviating current and prospective traffic congestion arising both from this development and traffic conditions in the area more generally would be to have this area controlled by traffic lights and linked through the SCOOT system to the traffic signals at Hockerill cross roads and at Tanner’s Wharf. The new traffic signals would need to cover the access to the Aldi car park, the access to the small station car park, the existing signal controlled pedestrian crossing and the northern junction between Crescent Road and London Road. The area controlled by signals would be quite extensive, in a similar way to the signals controlling Tanners Wharf. This area has far more conflicting traffic movements and pedestrian crossing movements than Tanners Wharf, for which Herts Highways concluded that a fully signalled junction was necessary.
15. I understand that part of the reason for requiring signal controls at Tanners Wharf is the existence of a blind bend where the London Road crosses the railway. However, this bend is more than 100 metres away from the exit from Tanners Wharf and the sight lines for traffic leaving the site are very good in both directions. By contrast, the sight lines for traffic seeking to join London Road from Crescent Road are appalling in both directions and, even after nosing out into the carriageway, do not exceed 50 metres. The whole site is much busier too than Tanners Wharf which has 130 apartments and an office block. This is because
- It is a popular drop off point for the railway station
- It has heavy pedestrian and car traffic going to the Herts and Essex School in Warwick Road, with pedestrians using the pedestrian crossing
- It is the principal access route for traffic from the south heading for the main station car park
- The Aldi store has now become a significant generator of additional traffic and conflicting movements.
16. In short, the whole area is an accident waiting to happen, and if no serious one has occurred yet, it is probably because traffic queues often bring road speeds down to walking pace. Properly integrated traffic controls could both make the area safer and improve traffic flows through this most congested part of town. At the moment, the Tanners Wharf lights in particular seem simply to be an unnecessary obstruction for most of the day.
17. We hope therefore that any planning permission granted will be conditional upon the applicants making a financial contribution towards a properly integrated traffic control scheme and that Herts Highways will be pressed to implement it.
18. I am copying this letter to Cllr Barfoot since the issues it raises are primarily for Hertfordshire County Council and to James Parker, Chief Executive of Bishop's Stortford Town Council.