MSG Proposal – Summary of the proposal and outline of main impacts

The proposal, located on Angel Lane in Stratford, consists of two elements/two separate planning applications as set out below:

1. Planning application for a development of a multi-use entertainment and leisure venue with a total capacity of 25,000 people, comprising the main sphere, terraces, podium, plaza, smaller music venue/night club, a restaurant / members’ lounge / nightclub, further bars, restaurants, cafés, retail and merchandising, hospitality and catering facilities, and external terraces with landscaping and café, bar, retail and open air entertainment facilities, and the supporting facilities. The construction of new pedestrian and vehicular bridges, highway and access works. The building would consists of:

• The main arena/ball called the MSG Sphere, with capacity of 21,500 people

• Music club/Night club – 1,500 people capacity (Opening hours until 4.00 am)

• Restaurant/Members’ lounge/night cub/bars- 1,000 people (Opening hours until 3.00 am)

• Staff, 1000 people

The main structure is 120 meters wide and 90 metres tall. The proposal has a total floorspace of 80,744 sq. m (gross internal area).

Use: A range of events would be hosted in the main venue, including but not limited to concerts, award shows, residences, “immersive experiences”, product launches, corporate events and sporting events.

Opening hours of the main arena/MSG Sphere

The venue would operate up to 365 days per year, with approximately 300 ‘event days’ (i.e. when events will be held within the main venue –the MSG Sphere) per year. It is expected that there would be more than one event per day in the main arena, and for smaller events (the night clubs, bars, restaurants and other ancillary commercial spaces to run simultaneously). Planning application documents state that “The timing of the events in the main venue will vary, but will typically be matinee, evening and overnight events.” The opening hours are set out below.

Page 18, MSG’s Concept of Operations document.

Vehicular access: Primary access to the venue for delivery and servicing will be from two new access points/junctions to be created off of Leyton Road/Angel Lane, near the junction with Windmill Lane.

2. An application for an advertising contest

The whole surface of the main Sphere would be an LED advertising surface, projecting moving images, video feeds, commercial adverts and so on. If allowed, this would be the biggest advertising surface in the UK and probably in Europe. The proposed three new bridges and other structures within the site would also be illuminated adverts.

Site context

First and foremost, we do not consider that the vacant land at Angel Lane is a suitable site for the development of this scale and nature. The site is surrounded by housing on three sides. Whilst the site is currently vacant and should be put to best use, it is closely surrounded to the north and south-east by high-density residential development including Legacy Tower, Unite Student halls (Angel Lane), the Stratford Eye development, and most recently, Chobham Farm. To the east of the site is a housing estate, where some of the most deprived residents of Newham live, most of whom are still unaware of exactly what the proposal entails.

Beyond these sites are thousands of other residential homes in the wider area from East Village to the north-west, and stretching towards Maryland to the east and Leyton to the north. To place a building of this scale, comprising a host of uses renowned for creating noise disturbance, air pollution from millions of additional car trips per year, extreme light pollution from the largest illuminated advertising surface ever seen in the country, anti-social behavior and crime, would blight the lives of thousands of residents in the area.

It is worth stressing that MSG’s planning application ignores the fact that the site is surrounded by housing, and they deliberately adjusted the baselines for undertaking various impact assessments to reflect “the non-residential character of the site”. This artificially adjusted starting point which does not reflect the reality on the ground, in effect makes all the impact assessments flawed.

We are aware that the parcel of land the Proposed Development is planned to be located on is included in Site Allocation SA3.1 (Stratford Town Centre West). This parcel is referred to in the supporting policy text as being earmarked to provide a large-scale town centre use with supporting elements. This is set out in both the adopted and emerging Local Plans. However, the policy wording itself states that the site allocation should deliver ‘a range of town centre uses and residential accommodation appropriate to the scale and form of the Metropolitan Centre designation’. Given that the height and scale of the Proposed Development is significantly greater than the surrounding built context, and would be incompatible with the predominantly residential form of this part of Stratford, the proposed uses would not be suitable for development on the site.

BREIF OUTLINE OF THE MAIN NEGATIVE IMPACTS

Transport

Stratford Station

Stratford Station is currently running well beyond its capacity and has becoming less and less safe. There are numerous other development projects, which have been permitted already or are currently at the planning stage, which will be built near the Stratford Station over the next few years. These include new large-scale office and residential buildings, as well as a whole new cultural complex, East Bank¹. East Bank will include a new 550-seat Sadler's Wells theatre and a new choreography/hip-hop academy, a new large UAL's London College of Fashion campus (accommodating 6,500 students), a new UCL campus (for around4,000 students), a new V&A gallery and a new museum, a BBC music studios hub, and a range of other supporting facilities. East Bank alone will bring an additional 1.5 million visitors to the Park and surrounding area each year.

We know from personal experience that Stratford Station already operates well beyond its capacity, particularly on days when West Ham FC matches are on, and is becoming increasingly unsafe. It is a disaster waiting to happen. There have already been incidents where people were trampled in the station tunnels due to heavy overcrowding following an incident.² It is no exaggeration that the additional crowds for MSG concerts could potentially result in casualties, including fatalities.

MSG’s planning statement suggests that there could potentially be three events at the main Sphere on each event day. This means over 70,000 people arriving to the venue on a single event day, and there would be approximately 300 event days per year. This means 21 million people per year. The venue would also be used on the remaining 65 days per year, and if only 3000 people per day visit the venue, that gives a further 195,000 people per year.

Even if two main events rather than three are held on each even, that is still 50,000 additional visitors per day, and a total of 15 million people per year.

Stratford Station simply cannot cope with such large additional crowds, particularly given the number of other venues in the area including the London Stadium with the capacity of 60,000 people, not to mention the number of shoppers/visitors to Stratford Westfield.

MSG planning application suggests that when there are clashes with other events in and around the Olympic Park, they would not use their venue to full capacity where a clash with other events is “reasonably foreseeable”. Given the number of venues around the area, as well as the Olympic Park itself which holds events, clashes will be unavoidable.

There would be nothing short of mayhem at Stratford Station every day. Over 20,000 people will be arriving to the venue during the day and leaving the venue after the matinee event in the late afternoon/early evening during peak hours when the station is very overcrowded in any case. Then a further 25,000 people would be arriving later to attend the evening concerts. They would leave the venue late at night. Then a further 25,000 people would be arriving to attend the overnight events which are scheduled to go on until 5.00 am.

There are very few details about how crowds and clashes of big events would be managed, other than the MSG’s planning documents suggesting they would work with other venues and agencies to come up with the crowd management strategy. During the West Ham matches, crowds are held in the Olympic Park and outside Westfield, and allowed into the Station in small groups, and crown dispersal takes a very long time.

With the MSG proposal, there is very limited amount of space between the proposed venue and the Stratford Station for a holding area to accommodate such large crowds.

MSG documents state that crowd management will evolve over time once the venue is operational.

Stratford Station, even if it were to be expanded, cannot cope with additional venue of this size. The area around the proposal cannot cope with managing such large crowds of people.

It is worth noting that Newham Council and the LLDC have been given new housing targets by the Mayor of London, which require them to deliver over 60,000 new homes in the next ten years. Extreme additional pressures would be put on the public transport infrastructure, particularly Stratford Station due to the future housing growth. It is accepted by all that housing is a priority as there is desperate need for more housing. However, there is no need for something like the MSG proposal.

Maryland Station

It is suggested that a small percentage of visitors to MSG would use Maryland Station. This still means large crowds moving through a quiet residential area late at night, causing noise and disturbance, and resulting in serious harm to the residents’ quality of life on a daily basis. MSG’s own documents state there would be “significant adverse” impact along Windmill Lane with crowds leaving the venue at 00.30 – 00.45 hours.

Further, it is suggested that, on days when Stratford Station is unable to cope due to other events at other venues in the area, Maryland Station will be used as a contingency. This means on some nights most of the MSG crowds will be directed to Maryland. It is simply unacceptable that such large crowds would be directed through the residential area. Further, Maryland Station is too small for large crowds and it is likely the station would have to be closed regularly due to safety concerns.

Parking pressures

The MSG proposal would cause very serious additional parking pressures on the wider area, particularly on the residential streets to the East and North East of the proposal. It is suggested that only 12% of visitors would arrive by private car. However, this is simply an estimate. It is not possible to predict with any certainty the proportion of people arriving by car, nor is it possible to control human behavior. In reality, a greater proportion of people are likely to travel by car, as the public transport would be overwhelmed every day.

Even with only 12% driving to the venue, and if we assumed only two big events per event day (50,000 people in total), that is still 6,000 people per day. If we assume two people per vehicle, that is still 3,000 vehicles arriving to and leaving the area, which is equivalent to 6,000 car trips per day. This comes to a total of 1.8 million additional private car trips to the area.

MSG suggest that people will park in the Westfield carpark (capacity 4,127 spaces) and the Stratford multi-story car park (430) . However, these car parks are already well used and will not be able to accommodate all the additional parking demand particularly on busy days. This will result in many of the visitors to MSG parking on residential streets around the wider area. It is likely that the parking pressure would affect not only the residents in the wider Stratford and Maryland area, but also residents further afield such as Forest Gate, Layton as well as those to the west of the Olympic Park in Tower Hamlets.

As a result, thousands of local residents would be impacted, not only as they will have to buy visitors’ parking tickets, but also due to the disturbance caused by MSG visitors dispersing late at night going back to their vehicles parked in residential areas.

In addition to the private car, a significant proportion of visitors would travel to the venue by taxi/Uber/PHV. If 8% of visitors is assumed to be traveling by taxi/Uber etc, that gives a further 4,000 trips a day at least if only two events are held one each event day. This is equivalent to a further 1.2 million car trips per year.

This figure is likely to be much higher as the vast majority of visitors attending the overnight events which end at 5.00 am, the night clubs and other venues which will operate until 4.00 am will leave either by private car or taxi/Uber/PHV. This will cause noise and disturbance on a very wide area. Page 45 of Concept of Operations document state that Uber/PHV etc “would pick up passengers at numerous undesignated curb-side locations ensuring their impact is dispersed across wide area”.

Air pollution

The proposal would cause a significant increase in air pollution on the area which already suffers from poor air quality. Newham Council has recently declared climate and health emergency. Seven out of 100 deaths in Newham are a result of poor air quality. The Stratford area has the highest levels of pollution in Newham, which would get much worse if the MSG proposal is allowed as it would generate millions of additional car trips to the area.

MSG estimate that, in addition to 12% of visitors travelling to the venue by private car, a further 8% would travel by taxi and private hire vehicles (PHV). Based on simple calculations set out above, the proposal would result in at least 3 million additional car trips per year. These figures is likely to be much higher if the venue is used for three rather than two large events per event day.

Therefore, the proposal would seriously undermine the objectives to reduce air pollution, set out in the Newnham’s as well as the Mayor Sadiq Khan’s policies, including the Ultra Low Emissions Zone (ULEZ) designation and Newnham’s policies to tackle climate change.

Danger to public safety

Illuminated adverts, if located close to roads, can pose danger to public safety because they can distract drivers and result in accidents. Small illuminated adverts up and down the country are refused planning permission on this basis. For example, a small illumined advert/signage by Big Yellow Storage at their site at 400 Wick Lane, located to the west of the Olympic Park (within the LLDC area), was refused permission three times on the grounds of public safety as they would pose danger to road users on A12, and each time the refusals were upheld on appeal. ³ The biggest of these refused proposals was 7.45 metre by 5.25 metre.

The MSG Sphere is proposed next to a very busy road (includes a bus lane), where the roads bends sharply, and near a busy junction. The whole sphere, its full surface which is 120 metres wide and 90 metres tall, will be an advertising surface, displaying LED illumined adverts, with flickering lights, moving images, video feeds etc.

This will pose a very significant danger to public safety, not only to road users but also to train drivers operating the trains on the busy rail lines which run along the proposal site.

MSG’ s own assessments, which accompany the planning application, state that the Sphere would cause distraction to drivers, but they play down the impacts by suggesting the distraction will be “only for a few seconds” and “not more than five minutes”.

Noise from the crowds (and the venue)

• As can be seen from the Opening Hours stated in the planning application submission, there will be more than one big event on each event day (including overnight events which end at 5.00am) and 300 event days proposed per year.

• In addition, night clubs, bars and restaurants proposed within the venue would be open until 3.00 and 4.00am.

• Tens of thousands of people would be leaving the venue late at night and into the early hours of the morning, and thousands of taxis/Uber/PHV will be picking up passengers close to the venue but also within a wide radius around the area. The noise and disturbance from people and vehicles will have very negative impact on residential amenity and wellbeing of the residents in the area.

• Windmill Lane will be particularly affected, as stated in the planning application documents

• There will also be significant noise from the venue itself, as it contains terraces and podiums, and open-air events are proposed. This will impact very significantly on the residents living in nearby properties.

Extreme light pollution, glare and over shadowing -

• The size of the media façade applied to the MSG sphere is unprecedented in the UK. Becoming one if not the largest advertising screen in the country. It will cause very severe light pollution, particularly on residents living in homes adjacent to the site.

• The mitigation measures fail to adequately protect the local residential buildings.

• The emission of light into the already polluted night sky is significant, the environmental impacts of which are poorly understood.

• The video screen will show moving and static images, creating flicker, movement as well as traditional static advertising. This will cause distraction to roads and train lines.

• The façade design is designed to become a revenue generator, rather than adding aesthetically to the local architecture.

• The building will be 2-3 times brighter than a traditionally lit building in the same location.

• Most severe impacts will be on the Unite Student Accommodation block to the southeast of the proposal. Documents submitted with the planning application dismiss the severity of the impacts by stating that it is not as important for the students because they use their rooms ‘sporadically’⁴

Crime and anti-social behavior

• Most people are well behaved, but given the size of the crowds visiting the venue on daily basis, it is inevitable that there will be an increase in anti-social behavior (noise, public disorder,

public urination) which will affect the lives of residential communities in the area.

• One of the big concerns for local residents is that the proposal would lead to an increase in drug dealing and other types crime, including knife crime. The area, particularly to the east of the proposed MSG site, is already plagued by drug dealing. If this venue is built, 25,000 to 50,000 strong crowds coming to the venue on a daily basis (or even over 70,000 on some days) potentially could attract drug dealers, and is likely to fuel an ongoing turf war, with local gangs fighting for a share of this lucrative new market at their doorstep.

• As you might be aware Newham has some of the worst statistics for violent crime, including stabbings. Violent crime, such as knife crime, is of course a complex, multi-faceted problem with many roots. However, there is no doubt that drug dealing plays a major part in fueling this type of crime. If permitted, the MSG Sphere will attract millions of music event goers to the area each year, and even if a small percentage source drugs locally, that would inevitably lead to very significant deterioration of the existing serious and wide spread crime problems, which the local communities have to cope with.

• These are very important issues, which affect the quality of life, and health and well-being of the local communities.

• In addition, all large scale venues require police resources to ensure safety and security, not least because large music arenas are considered to be a potential terrorist target. If built, this venue would add significant pressure on already stretched police, and draws resources away from dealing with other types of crime in the area. The costs of such policing are expected to be covered from the public purse.

MSG Sphere claim that the proposal is likely to reduce the high levels of crime in the surrounding area because there will be a “lower levels of visual deterioration” and “a greater ‘pride of place’ (para 5.228, Chapter 5 Socio-Economics and Health, Environmental Statement Main Report)

Overshadowing, loss of sun light and daylight

Due to its size, height, shape, bulk and massing, the proposal would have severe impacts in terms of overshadowing, and loss of sunlight and daylight to residential properties nearby. Residents in the new Garden Quarter development would be particularly affected.

The residents of new Garden Quarter development were told nothing about this proposal when they were moving in. In fact, the sales brochure and the hoardings around the site, show the site of MSG Sphere proposal as a green open space with trees.

Design

The proposal is overbearing and would tower over the whole area. Its design in terms of the size, shape, bulk and massing and the luminosity are alien and out of place in the area.

Impacts on emergency services

- The planning application documents state that there would be additional impacts on the Accident & Emergency Services. The MSG dismiss these impacts by saying the current situation is already bad

- Similarly, there is likely to be additional pressure on the Fire Service resulting from the proposal

Community Infrastructure Levy

Most development proposals, from a single additional home to large scale projects, are required to pay Community Infrastructure Levy. Such payments go towards building new and/or improving existing infrastructure in the area (public transport, roads, health infrastructure etc), because developments create additional pressure on infrastructure. Very substantial CIL payments are secured from large projects, often many millions of pounds.

The MSG Sphere proposal will not pay any CIL, because the entertainment venue use is classed as sui generis use and therefore there is a nil charge. Para 12.2, page 3 of the Draft Section 106 Agreement states: “These heads of terms have been prepared on the express assumption that the proposed use of the Development will be classified as sui generis and that in accordance with the LLDC's current CIL Charging Schedule, no CIL will be payable to the LLDC in respect of the Development.” (The Development will be liable for Mayoral CIL.)

Therefore, despite the fact that the proposal would put substantial additional pressure on different types of infrastructure locally, there will pay no CIL. For illustration, if a retail development (or hotel or student accommodation scheme) of this size was proposed on this site, the developer would be required to pay approximately £8 million in local CIL.

POTENTIAL POSITIVE IMPACTS

It is suggested that 1,000 -1,100 full time equivalent (FTE) jobs (1,200-1,300 part-time jobs) could be created at the venue. According to MSG’s own estimates only approximately 20% of jobs are considered to be high skilled jobs. This means that 80% of the jobs would be low skilled, low paid, insecure jobs such as bar staff, cleaners, glass porters, security wardens or similar. MSG suggest that they would endeavour to achieve a target of 35% of all jobs at the venue once it is operational to be occupied by Newham residents, but “excluding specialist jobs”. (Draft Section 106 Agreement)

It is worth noting that a large number of similar jobs have been created in the area in recent

years as part of the Westfield Stratford City development, in the numerous large sports

venues in the Olympic Park (greatest concentration of sports venues in the country), as well

as other recent developments in the area. All job opportunities are important and should not

be discouraged, particularly in a deprived area like Newham, but there is no shortage of low

paid jobs in the area.

Given the scale of the venue, there will be a very small number of jobs overall, and a very small number of highly skilled jobs. There is, of course, no guarantee that any of the higher end jobs would go to local people.

For illustration, a proposal of this size (over 80,000 square metres of space) in office use would generate approximately 5,500 full time jobs. Or to put it another way, a relatively small office block, less than a fifth of the floorspace proposed by MSG can accommodate 1,000 jobs.

Alternative uses

• Housing: The site could accommodate a large amount of housing, potentially up to 1400 new homes. Given the low existing use value of the site, it would be financially viable to provide a large proportion of homes as social housing. This would make significant contribution towards meeting acute housing need in Newham.

• There is no need for this venue in this area. But there is an acute need for housing and affordable housing in the area. Newham’s new housing target, set by the Mayor of London, is by far the highest in London. Between 2019/20 and 2028/29 Newham is required to deliver 38,500 additional new homes. In addition, during the same period the LLDC is required to deliver a further 21,600 homes within the small territory under their control. The site of the MSG proposal could make a significant contribution towards meeting that housing target.

• Other potential development alternatives for the site: affordable workspace for SMEs and start-ups/”maker space”, production space for creative industries, artists’ studios in line with the Mayor’s London Plan policies; Office space, retail.

Transfer of public land – loss to public purse!

• Until recently the site was owned by London Continental LTD (Railway company owned by the Department of Transport), therefore public land!

• In 2012 - property consultants who advised London Continental LTD on the sale of the site estimated the value to be £6 - 10 million. Housing was identified as the main use suitable on the site. Westfield initially secured an “option“ to buy the site.

• In 2015 London Continental LTD sold the site to Westfield’s for £9 million.

• In 2017 Westfield’s sold to MSG for £60 million. (The MSG bought the site knowing it is surrounded by existing housing and the new housing scheme which were under construction at the time.)