Objection of the Wards Corner Community Coalition (WCC) to the planning application of Grainger plc (HGY/2008/0303).

Contents P2 P6 P7 Summary of WCC objections Background Detailed evidence Equalities and discriminatory destruction of ethnic minority businesses and social amenity P10 P13 P15 P17 P19 Lack of attention to Place Making and Heritage Failure to meet Housing obligations Deficits in sustainable environment obligations Destruction of jobs and local economic activity Crime myths

WCC here provides evidence that the Grainger plan cannot be passed by the planning committee as it fails to conform to a variety of key policy and legal planning requirements and obligations of both developer and Council. These are material objections on points of planning and other law as well as expressions of local sentiment. WCC is particularly disappointed that the Equality Impact Assessment and the Three Dragons Toolkit (regarding why affordable housing can or cannot be built on the site) have not been made available in advance of the confirmation of the planning committee date (which occurred only 9 days before the fixed date of 20 July 2011) despite repeated requests to the planning office for these documents to inform this objection. Supplementary objections will be raised once these are released.

Summary of WCC Objections

Equalities and discriminatory destruction of ethnic minority businesses and social amenity
i. The High Court ruling in June 2010 found the Council had acted unlawfully in not having due regard for its duties in respect of s71 of the Equality Act 2006. There is still no evidence that Haringey Council has met its duties to assess the equality impact of the Grainger scheme. In particular there has been no direct consultation with those individuals and communities on the site affected by the proposals. Given the devastating potential impact of these plans on specific ethnic minority groups and the High Court ruling expecting due regard for equalities issues - this lack of direct consultation must be seen as failing to meet the Councils equalities obligations.

ii.

Repeated failure to have due regard for the people on the site is evidence that specific ethnic minority businesses including those from a sizeable Latin 2

American community - are being removed from the area by a deliberate and systemically discriminatory process of lack of regard for their human rights and a desire to deliberately engineer a change in the demography of the area.

Place making and heritage

iii. The importance of Place Making - including continuity and conservation of the built environment and cultural artefacts that promote a sense of belonging and respect is central to modern policy obligations upon Local Authorities. This includes valuing both the heritage built environment and distinctive local activities. Most of the businesses and residents at Wards Corner have shown great commitment to creating valued activity on the site - over decades in many cases including substantial personal investment in buildings and businesses during decades of deliberate neglect and blighting by the main landlords: TFL, Grainger and the Council. Local businesses are looking for opportunities to further improve the site and their own wellbeing through a change process that facilitates their further collective effort. The site is also characterised by culturally specific and valued social amenity, particularly the indoor market. iv. The Wards Store corner building and other buildings on the site are locally listed. The site is in a conservation area and are part of the historic A10 corridor. PPS5 HE9.2 instructs local planning authorities to refuse permission to applications that cause substantial harm or loss of significance to a conservation area unless it can be demonstrated that no viable use of the heritage asset itself can be found in the medium term that will enable its conservation and conservation through grant funding or some form of charitable organisation or public ownership is not possible. Planning policy requires that buildings in a heritage/conservation area should not be destroyed unless lack of viable alternative use has been demonstrated. This has not been demonstrated as many people have wanted to occupy more the Wards Corner building and been prevented from doing so by TFL. v. WCC has identified that the Princes Regeneration Trust are prepared to find funding for the preservation and refurbishment of this site with immediate effect.

vi.

Following PPS5 HE9.3 we therefore invite the council and TFL to present evidence to prove that other potential owners or users of the site have been sought through appropriate marketing and that reasonable endeavours have been made to seek grant funding for the heritage assets conservation and to find charitable or public authorities willing to take on the heritage asset and that such reasonable efforts have failed.

vii.

Public opinion is against the Grainger proposal. There is predominant support for restoration and heritage continuity over wholesale demolition and rebuild. There are 1490 objections (inclusive of 301 petition signees) on the Council website. There also 450 online objections on the WCC website. There are only 40 expressions of support for Grainger on Haringey Councils planning pages.

Failure to Meet Housing Obligations

viii. There is no affordable housing within the scheme. More specifically, Council Cabinet members agreed the Grainger proposals and allowed for the creation of a Development Agreement on the basis affordable provision would be offset to the Apex House site at a meeting in 2007 (see evidence on page 13 below). This was on the basis of a planning covenant for that proximal development. No such covenant exists and there are no plans for developments at Apex House (see email exchange with Marc Dorfman on page 14 ). This means the cornerstone of the Development Agreement and Cabinet decision is now null and void and the plans breach housing policy.

Deficits in sustainable environment obligations

ix. The development is not fit to meet the expectations of the Council with regard to sustainable and low carbon construction and emissions in the Borough for the era in which it might be built. The details of this are given in page 16. x. The embedded carbon of the construction and materials of the proposed scheme has been calculated to be 150 times that of a retrofit upgrade of all buildings on the site, adjusted for average emissions over a period of 50 years. 4

Destruction of jobs and local economic activity

xi. At a time of economic recession, the Grainger proposal will destroy over 60 businesses and up to 400 jobs, most of which are of long standing and support both individuals and families. These are overwhelmingly businesses run by ethnic minority traders, serving minority and majority communities, hence the vital importance of equalities concerns. This contradicts the Councils policy with regard to supporting diverse businesses. It also is not in keeping with the Councils powers under the Local Government Act 2001 s2 to promote community wellbeing. The implication fo this is that a Council will be challenged if it is seen to be acting in a way that is actively detrimental to the wellbeing of local people and acting against their human rights. The Grainger plan meets neither the equalities aspirations of the London Plan nor the Councils equalities scheme. xii. The expressed intention to retain a market in the Grainger scheme is not deliverable and is not credible. As described in detail on pages 8 and 9 below, the current market will inevitably be destroyed by Graingers proposal.

Crime myths
xiii. There is no evidence that the criminal activity at Wards Corner is elevated compared to the rest of the local area and the crime rate is considerably lower than in chain-retail dominated places such as Wood Green to which the new scheme can be compared. xiv. In fact the presence of the indoor market is a direct crime deterrent. Local police have provided evidence on several occasions to attest that there is very little crime associated with the market compared to neighbouring streets and the place is renowned for being a safe place for children and young people.

Background
1.1 This document is the Wards Corner Community Coalition (WCC) objection to the planning application submitted by Grainger PLC. (HGY/2008/0303). The WCC is a broad based community group based in South Tottenham. WCC has existed since 2007 and has become a prominent and active force in the debate about the proposed redevelopment of Wards Corner, gaining both local and wider support. WCC has had London-wide and national interest because of its success in representing a community-driven vision for change at Wards Corner. 1.2 The WCC is made up of people from a wide range of groups including but not limited to: traders from in and around the Wards Corner site, members of the Tottenham Traders Partnership, Members Of Pueblita Paisa traders group, local residents associations, members of the Just Space Network, Tottenham Civic Society, members of Planning Network UK and many local residents from various professions from teachers to architects, artists to scientists. 1.3 We would like to emphasise that the WCC is not against change. But WCC is committed to ensuring Tottenham benefits from a positive development at the Wards Corner site, one that meets the aspirations of the community, takes account of the reality of economic conditions of the present and the future and draws on the investment, energy and commitment of the local community as well as external sources. WCC supports existing businesses at Wards Corner in their effort to make improvements to the physical fabric of the place and to the diversity of retail and other activities. WCC supports the alternative planning application submitted by traders on the Wards Corner site which aims to ensure the continuance and development of existing independent businesses which have shown great commitment to South Tottenham. 1.4 There are several key policy and legislative grounds for objection raised here. One of these is the equalities obligation on the Council. The planning committee and planning department are reminded that the planning permission gained by Grainger previously was overturned at Judicial Review on a failure by the Council to comply with Equalities legislation requirements. WCC has 6

seen no evidence that the requirement to have due regard to s71 Equalities obligations has been met this time around meaning passing the application is likely to be unlawful on this ground. We understand an equalities impact assessment has been done by the Council, but so far, the Council has declined to release it. We are aware that there has been no communication from the Council with residents and traders with regard to the impact of the proposal. Without meaningful communication with those impacted, the equalities impact assessment cannot be said to be sufficient to discharge the Councils duties.

Detailed evidence
2. Equalities and discriminatory destruction of ethnic minority businesses and social amenity 2.1 The previous decision of the planning committee to pass (to all intents and purposes) the same proposal from Grainger plc was overturned in the High Court because the Council had not had due regard for the race equality implications. WCC believes there has been no progress in this regard having had no evidence that the impact upon the people directly affected by the proposals has been properly evaluated and their views properly sought. 2.2 Wards Corner houses a unique and valued group of retail and service businesses that provide both for the wide community and for distinctive groups in the area and around London. It particularly houses: 2.2.1 2.2.2 35 Latin American retail and traditional food outlets 25 other ethnically distinct retail outlets longstanding (i.e. most shops of 10 - 25 years, most market stalls of 2 - 10 years plus) and established, self-financing and surviving/growing within the economic downturn 2.2.4 A whole foods and world foods independent supermarket 2.2.5 A successful street front caf 2.2.6 2.2.7 A unique Eye- care practice tailored to the needs of local diverse population The indoor market in particular provides a distinctive social amenity 7

2.2.3 A majority of businesses in shops and market stalls that are

for the diverse ethnic populations it serves and for the whole local community, offering a safe social space in the heart of Tottenham for children and adolescents as well as adults. 2.3 The London Plan (consolidated with alterations since 2004) in section 3A.17 when talking about addressing the needs of London's diverse population states that existing facilities that meet the needs of particular groups should be protected, and where shortfalls have been identified, policies should seek measures to address them properly. The plan put forward by Grainger would not only lead to demolition of existing facilities that provide for specific local groups but would simultaneously create a shortfall in provisions for said groups that would then need to be addressed. 2.4 In particular the plans would demolish the existing market which is both a retail and a social hub for Tottenham and further afield, particularly for the Latin American community. The destruction of this market would be an act of destroying an important cultural centre, a source of employment and 2.5 Proposals to reprovide a market at this site contained within the s106 conditions of the Grainger plan will NOT enable the existing valued market to return as: 2.5.1 2.5.2 rents will be immediately set higher than can reasonably be afforded by the current businesses at the point of proposed return to the site stalls will be offered on a non-assignable lease basis making them unattractive option for existing businesses 2.5.3 the provided space in the new proposed building is insufficient for the whole market group 2.5.4 Grainger will control the appointment of market management to create a type of market of its choosing, not the important cultural and retail role it currently provides. 2.5.5 the process of moving will destabilise the market trader group significantly as the provisions do not provide any certainty of return at an affordable rent within a realistic timescale

2.6 These arguments are laid out in the Urban Space management report commissioned by the NDC in 2008 to support the Grainger proposal. The following statement is made:

2.7 The document goes on to explain that given the economic and architectural paradigm being pursued by Grainger the market trader group will be broken up by the temporary relocation process and will not anyway be able to afford new rents and rates (ten times current levels) which Grainger will be bound to charge . It states: 2.8

2.9 This is relevant to the equalities agenda as it means these distinctive businesses are being deliberately removed from the area by a planned, discriminatory process. 2.10 The Haringey Council Equalities Scheme 2010 2013 adopts the statement that Haringey should be A place of diverse communities that people are proud to belong to. It goes on to state that social justice and equality of opportunity have a vital role to play in cohesion and integration. Adoption of Grainger's plan would be a step backward in achieving these worthy goals, removing equality of opportunity for the many families that are sustained through the existence of the Wards Corner site, dispersing the communities that congregate at Wards Corner removing the cohesion built over the years and leading to a worsening of relations between people of different ethnic groups. 2.11 In The Haringey Council Equalities Scheme 2010 2013 one of the Key Aims of Priority 2 of the Delivery Plan (appendix 2) is to ensure that all 9

procurement activities are fair, transparent and consistent, one of the Measures of Progress of which is increased use of small and medium enterprises, BME voluntary and social enterprises. Again the Grainger plan fails to meet the criteria for this policy, leading to a decline in the number of independent small and medium enterprises run mainly by BME groups in a key gateway to the borough, a place that should be a visible representation of Haringeys commitment to equality and diversity in an area with one of the most diverse populations in the UK. 2.12 Haringeys diversity should be part of its appeal for future new populations and businesses. Tottenham has a wonderful mixture of people and independent, niche businesses that create the local social ecology. Graingers proposal gives a message that diversity and the importance of specific community activities such as being a Latin American hub for London are not valued by the Council which is disabling and an affront to the existing communities and also will deprive the area of one of its most important unique selling points (USP) in the future. Such USPs or attractors - are crucial for London localities to attract investment of people and businesses in competition with other localities in the Capital. Tottenham has repeatedly lost out to neighbouring areas because it has not been seen to have such positive attractors. The development of independent businesses and diverse communities should be the basis of Tottenhams future. Lack of attention to place making and heritage 2.13 WCC has collected the opinions of thousands of people in Tottenham about the proposals, including the loss of heritage buildings. The rejection of the Grainger proposals by local people substantiated in objections by the Tottenham Civic Society and English Heritage has been very well documented in many objections on the planning website. Overwhelmingly, public opinion in the area supports a balance of continuity and change through restoration of existing buildings and creative, sympathetic new build. Public sentiment is important in planning decisions and is important to Councillors who wish to be seen to serve their constituents.

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2.14 Much of the proposed site for development is situated within the Tottenham High Road conservation area, an area with an important place in the history of the growth of London. Buildings 227 High Road (inc. 725 Seven Sisters Rd) and 1a & 1b West Green Road are locally listed as buildings of merit. The Tottenham High Road Conservation Area Appraisal states that numbers 255259 High Road, along with the previously mentioned locally listed buildings, are positive contributors to the streetscene and the overall character of the area (Tottenham High Road Conservation Area Appraisal 8.5 8.7)

2.15 When talking about demolition and potential for development the Tottenham High Road Conservation Area Appraisal goes on to say In accordance with the Councils UDP policies and planning guidance all future proposals for demolition of buildings that make a positive contribution to the Tottenham High Road Historic Corridor conservation areas will be resisted through the planning process. The High Road has suffered greatly from the demolition of many fine buildings of historic and architectural merit, and distinctive local landmarks have been lost. The visual coherence of much of the townscape has been significantly diminished as a direct result of this. 2.16 Planning Policy Statement 5: Planning For The Historic Environment (PPS5) states that local planning authorities should take into account the desirability of new developments making a positive contribution to the character and local distinctiveness of the historic environment. The consideration of design should include scale, height, massing, alignment, materials and use (HE7.5). 2.17 The proposed development will destroy the local distinctiveness and character of the site and replace locally listed buildings, some of which have been standing for over 100 years, with a development that is completely out of scale with the surrounding buildings and that has no reference in its design to the historic character of the buildings it replaced. This is the view held also by English Heritage who have expressed the view in a formal objection that the proposals do not have sufficient merit to justify demolition of the Wards Stores building.

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2.18 PPS5 HE9.2 instructs local planning authorities to refuse permission to applications that cause substantial harm or loss of significance unless it can be demonstrated that no viable use of the heritage asset itself can be found in the medium term that will enable its conservation and conservation through grant funding or some form of charitable organisation or public ownership is not possible. At various times over the years both businesses and charitable organisations have expressed an interest in using the site and bringing it back to health only to be rebuffed by Haringey Council. As recently as April 2011 The Princes Regeneration Trust has expressed continuing commitment and desire to engage in the regeneration process at Wards Corner and is ready to act with immediacy following a positive response from the council. 2.19 Following PPS5 HE9.3 we invite the council and TFL to present evidence to prove that other potential owners or users of the site have been sought through appropriate marketing and that reasonable endeavours have been made to seek grant funding for the heritage assets conservation and to find charitable or public authorities willing to take on the heritage asset and this has failed. 2.20 Furthermore Section 72.1 of the Planning (Listed Buildings and Conservation Areas) Act 1990 echoes the sentiment expressed in PPS5 stating that with respect to any buildings or other land in a conservation area... special attention shall be paid to the desirability of preserving or enhancing the character or appearance 2.21 Whilst some of the properties on the site are considered by the Tottenham High Road Conservation Area Appraisal to have only a neutral aspect on the overall character of an area PPS5 specifically addresses how do deal with this aspect of preserving heritage sites: Not all elements of a World Heritage Site or Conservation Area will necessarily contribute to its significance. The policies in HE9.1 to HE9.4 and HE10 apply to those elements that do contribute to the significance. When considering proposals, local planning authorities should take into account the relative significance of the element affected and its contribution to the significance of the World Heritage Site or Conservation Area as a whole. Where an element does not positively contribute to its significance, 12

local planning authorities should take into account the desirability of enhancing or better revealing the significance of the World Heritage Site or Conservation Area, including, where appropriate, through development of that element. This should be seen as part of the process of place-shaping. There is clear potential for rejuvenation of all buildings on the site and restoration of the heritage significance to the entire site, an option that will strengthen the local character and distinctiveness of the area rather than demolish it. Failure to meet Housing Obligations 2.22 The non-conformity of this plan to housing policy and legislation is very striking. It does not conform to the requirements for provision of affordable housing because there is no affordable housing provided on site, as required by the London Plan and the UDP. As the Head of Planning said in a report in 2007 (ref para 2.11 below) In planning terms the provision of affordable housing off-site is generally not acceptable. However, given the close proximity of the two sites, viability issues and regeneration benefits, the provision of affordable housing at Apex House instead of Wards Corner is acceptable in this case (p12). Thus, only a firm plan (a planning covenant) to redevelop the Apex House site next to Wards Corner rendered/renders the scheme suitable in planning policy terms. 2.23 Grainger has persuaded the Council and GLA that provision of affordable housing on the site is not commercially feasible for their scheme. The evidence for this from the GLAs Three Dragons Toolkit has never been made fully available despite Freedom of Information requests. WCC believes the planning committee must directly evaluate the Toolkit to clarify whether this conclusion has any validity as it has been drawn behind closed doors by the developer and Council officers to date. 2.24 On 20th February 2007, in a not-for-publication report of Justin Holliday, the Assistant Chief Executive (PPP&C) of the Council, to the Executive of Haringey Council , the recommendation was made and agreed that the comprehensive redevelopment of the Wards Corner site together with the Apex House site (Option 3) is now progressedwith separate delivery agents. The planning and regeneration department of the Council made the case for the affordable 13

provision requirement on the scheme to be offset by development at the Apex Corner site. This is proposed at the expense of the Council (in terms of providing the site) with costs of development going to an affordable housing developer yet to be identified. This proposal thence places no obligation on Grainger to contribute to the affordable housing provision in the Borough. 2.25 Haringey Council Executive took the decision to back the Grainger scheme out of several options before it by agreeing this proximal development of Apex House under the provision of a s106 planning covenant. The vital importance of this covenant being binding and effective to meet affordable planning requirements is clear from the Feb 2007 report. 2.26 However, there are not and never have been any real plans to provide affordable housing at the Apex House site. In recent communication, the Asst Director for Planning and Urban Environment states the site is identified in the Councils 2006 UDP as a possible development site for housing sometime before 2017.in terms of very detailed plans on this site we wont start until 2012-13 once we are clearer on economy, what housing assoc bus plans (sic) are for next 3 years (sept 11) and have reviewed councils asset plan in 2011 Marc Dorfman, May 17 personal communication 2.27 Furthermore, this lack of a plan to develop the Apex site means the premises upon which the Council entered into its Development Agreement with Grainger (in August 2007) have turned out to be false. A s106 covenant for Apex site development is a cornerstone of the Development Agreement but no such covenant exists. 2.28 It is also telling that within the Development Agreement, the following is stated (section 25) The Council agrees that, in consideration of the Developer entering into this Agreement with the Council, the Council will not commence development of Apex House for private residential purposes (here meaning the installation of 14

foundations) prior to the date 18 months after the Developer has commenced the development. The Council further agrees to use all reasonable endeavours to ensure that any development of Apex House is at a level of quality and design which is not detrimental to the Development 2.29 Essentially, this statement reveals the fact that Grainger see the provision of affordable housing adjacent to its property as potentially detrimental to the commercial value of its property, wishing to secure sales/leases before evidence of affordable housing construction nearby. This statement in the agreement flies in the face of expectations of mixed communities as it underscores the intention to create a private gated ghetto and an affordable/social housing ghetto on the other side of the street. Deficits in sustainable environment obligations 2.30 The Grainger plan represents a departure from current ideas of sustainable construction as the building proposed does not meet expected carbon reduction standards in the long term and, crucially, the process of construction will entail the creation of a huge carbon footprint, many times bigger than that of any plan based on restoration instead of demolition. The embedded carbon of the construction and materials of the proposed scheme has been calculated to be 150 times that of a retrofit upgrade scheme of all buildings on the site, when adjusted for average emissions over a period of 50 years. 2.31 It should be noted that the proposals from Grainger were in development in the period 2005-2008. Only modest modifications have been made on the first formally proposed designs. Grainger propose building from 2013 onwards at the very earliest by which time even more stringent new carbon reduction and sustainability standards will be in force and the building will fail to meet these. 2.32 If the Grainger building goes ahead in a few years time, Haringey Council would be in the unenviable position of watching its gateway to Tottenham being challenged for its lack of compliance with modern carbon reduction 15

expectations. 2.33 The table below outlines the ways in which the Grainger scheme fails to meet sustainable building requirements as laid out by Haringey Council policy, national and regional policy: Policy
LDF SP4 - Working towards a Low Carbon Haringey From 2011 onwards, all new residential development will achieve a minimum 44% reduction in total (regulated and unregulated) CO2 emissions in line with Code for Sustainable Homes Level 4 energy standards, and should aim at achieving Level 6. All new residential development shall be zero carbon from 2016 onwards Mayors draft London Plan requires 44 % (regulated) CO2 emissions reduction in 2010 2013, 55% in 2013 2016, zero carbon developments from 2016 for residential and from 2019 for nonresidential; *Energy assessments should set out emissions related to both regulated and non-regulated emissions along with a strategy of how nonregulated energy and carbon dioxide emissions will be reduced through the choice of efficient equipment and controls, good management practice including green leases, where feasible. LDF SP4 - Working towards a Low Carbon Haringey From 2011 onwards all new non-residential development shall be built to at least BREEAM very good standard and should aim at achieving BREEAM excellent or the current nationally agreed standard. Reduction attributable to renewable energy: LDF SP4 - Working towards a Low Carbon Haringey and the Mayors draft London Plan require 20% CO2 reduction from on site renewables.

Comment on Grainger scheme For residential developments, Graingers Energy

Strategy meets London and Haringey targets for carbon reduction and achieves 53% reduction over 2006 building regulations (Code for Sustainable Homes Level 4), but only for regulated CO2 emissions. There are no measures proposed for reduction of the unregulated emissions.

The building will not reach 55% reduction over 2006 building regulations that the draft replacement London plan will require from 2013-2016 and the scheme should aim to achieve a zero carbon development, which is going to be required by the GLA from 2016. Through poor architectural design, the scheme is unable to make more use of passive solar gain and natural ventilation to reduce need to heating and cooling. It is a missed opportunity to achieve the Passivhouse standard, which is already a commercially viable option in the UK. Compliance of non-residential element to BREEAM standards has not been addressed. Retailers such as M&S and John Lewis aim for excellent rating from 2010/2011.

In Graingers updated Energy Strategy only 6% of regulated emissions (down from 10.7%) are attributable to renewable energy, not reaching the 20% as specified by the LDF and the London Plan.

Offsetting: London Plan Policy 5.2 E The carbon dioxide reduction targets should be met onsite. Where it is clearly demonstrated that the specific targets cannot be fully achieved onsite, any shortfall may be provided offsite or through a cash in lieu contribution to the relevant borough to be ring fenced to secure delivery of carbon dioxide savings elsewhere.

There are no measures proposed to offset shortfalls in CO2 emissions reductions off site.

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Destruction of jobs and local economic activity 2.34 Planning Policy Statement 4: Planning For Sustainable Economic Growth (PPS4) in point EC4.1b encourages planning for a strong retail mix so that the range and quality of the comparison and convenience retail offer meets the requirements of the local catchment area, recognising that smaller shops can significantly enhance the character and vibrancy of a centre. 2.35 Currently the site houses a wide range of both comparison and convenience shops from specialised Latin American restaurants to fashion wear aimed at the youth of the area, from electronics retailers to beauty specialists all of which have evolved and grown over time to provide for the wide variety of specialised needs that come with such a diverse population. This natural growth of the area coupled with the amount of time many of the businesses have been here has lead to the development of a strong individual character in this local town centre, one that will be lost in the plan submitted by Grainger. 2.36 The planning committee should be in no doubt that the Grainger development will mean the absolute loss of longstanding businesses and squandering of decades of business effort and commitment to the local area. It is notable that very few retail and food outlets at and around Wards Corner are vacant. This indicates that, whilst no doubt local businesses could be grown further, the types of businesses succeeding here are able to withstand economic turbulence and continue to provide work and livelihoods for local families. It is expected that Graingers plan would draw in franchises and chain stores which would have no loyalty to the area and would vacate leases if profitability declined. 2.37 Existing businesses are developing their offer at the Wards Corner site. Notably, the Fairdeal supermarket, a freehold family live/work enterprise, is developing its offer to include whole foods and organic produce for the first time in Tottenham, serving an increasingly wide cross section of the population. This would be demolished under the Grainger plan.

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2.38 Mainstream comparison shopping opportunities for those who want them are easily available nearby at Tottenham Hale which is further developing its range of chain stores as part of its major redevelopment. The case for further developing a very different, distinctive shopping and social destination at Seven Sisters is strong given the likelihood of chain store outlets losing out to Tottenham Hale provision. 2.39 We believe that what is being offered to the current traders and residents of the site is wholly unsatisfactory and does not serve to limit or rectify any of the negative effects or disadvantage caused to the people affected by it. Our reasons for this are as follows: 2.40 Grainger have offered 144,000 in order to assist with the relocation costs (Planning Statement Addendum 5.18). When looked at in relation to the number of traders in the market the inadequacy of this amount becomes clear. With 31 businesses operating in the market (including the mechanic in the car park) there is only 4,645 for each business to cover the costs of moving out of the market, a long period of temporary displacement and then to move back to the site. 2.41 Furthermore, this suggested addition to the S106 agreement detailed at 5.91 of the Planning Statement Addendum makes no mention of any support or compensation being offered to the businesses outside the market. There are 12 businesses of varying sizes and uses that operate outside of the market making up about 20% of the businesses on the site, however, these businesses hold a much higher percentage of the total footfall and customer base. 2.42 The terms of the S106 agreement, as detailed in the appendix to the Planning Statement Addendum, state that the licenses offered will be for class A1 businesses. This will exclude a number of businesses that currently operate in the market, namely the 3 restaurants that are A3 class and the estate agent and 3 money transfer shops which are A2. The restaurants are one of the defining factors of the market and it will be impossible to retain the same character and same usage without them.

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2.43 The lease offered in the S106 agreement is an exclusive and nonassignable license. This provides no security of tenure for the market traders and ensures that they will be unable pass on their businesses to their successors, a process that is integral to the running of family business. 2.44 Whilst minor, and somewhat ineffectual, steps have been taken to attempt to alleviate some of the disadvantage inflicted upon the market traders as a result of this development nothing has been suggested or offered to the businesses and residents that live outside the market. Not only do we feel this to be unacceptable, but it also shows Grainger's lack of thought or planning for the people that live on the site. They have only recognised the market following an intervention by the Mayor of London.

Crime Myths 2.45 There is no evidence that the criminal activity at Wards Corner is particularly elevated compared to the rest of the local area and the crime rate is considerably lower than in chain-retail dominate places such as Wood Green. 2.46 In fact the presence of the indoor market is a direct crime deterrent. Local police have provided evidence on several occasions to attest that there is very little crime associated with the market compared to neighbouring streets and the place is renowned for being a safe place for children and young people. 2.47 Policy 4B.6 of The London Plan (Consolidated with Alterations since 2004) states that boroughs should seek to create safe, secure and appropriate accessible environments where crime and disorder, including terrorism, and fear of crime do not undermine the quality of life or community cohesion. We are very much aware of the desires of both the council and the local community to achieve this worthwhile goal, however we believe that the plan proposed by Grainger will neither reduce crime or fear of crime and will in fact greatly undermine both quality of life and community cohesion for the people that live there now and that would live in the proposed development. 19

2.48 It has been demonstrated in 2 reports, one published by Professor Peter Ambrose from Brighton University in 2010 and one by Madu Satsangi and Susan Murray from the School of Applied Social Science at The University of Sterling in 2011, that community ownership is able to reduce fear of crime and increase the willingness of residents to actively engage in improving their area. The reports examine surveys from the residents of Walterton and Elgin Community Homes Housing Association (WECH), a collection of 640 homes in Westminster that were transferred from council ownership to the community in 1991. Whilst the area differs from Wards Corner in that it is made up entirely of residential properties is has similarities in the levels of deprivation, furthermore one of the reports compares the changes seen at WECH with those seen in areas that have received funding from The Bridge New Deal For Communities. 2.49 The general sentiment of the findings in both reports is that The measureable benefits associated with empowerment through community ownership appear to mitigate the detriment to wellbeing caused by financial deprivation, physical illness and fear of crime. The reports are attached for reference.

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