Opposition to 20metre 5G Mast in Mapesbury Conservation area - consultation closes January 12th

 View of existing area where mast and cabinets would be installed outside 112 Walm Lane [Streetview] Note: Pole in foreground is not the proposed mast.

Mapesbury Conservation Area Border (Brent Council) - Site in red

 The placement of the mast and cabinets

 

The height of the mast against tree and 112 Walm Lane

Editor's Note: There has been a suggestion that there is a petition opposing this mast. I have not seen one and so do not have a link. If you know of one please send the link to wembleymatters@virginmedia.com  Individual responses to the Planning Portal LINK are more effective anyway as I understand petitions are counted as just one objection.

 

The latest controversy over the erection of a 5G roll-out mast is in Willesden Green, just within the Mapesbury Conservation Area border. Although the planning application gives the address of the Queensbury pub (due to be redeveloped) at 110 Walm Lane, the site is actually outside the block of flats at 112 Walm Lane, on the corner of Dartmouth Road.

The proposal sent to neighbouring residents and displayed nearby gives a closing date for comments of Thursday January 12th 2023.

Application Number 22/4004
Location Street Record, Walm Lane, London Proposal Prior approval for proposed 5G telecommunications installation comprising a 20m street pole and additional equipment cabinets on footpath adjacent to 110 Walm Lane, London, NW2 4RS (Part 16 of Schedule 2 to the Town and Country Planning (General Permitted Development) (England) Order 2015 (as amended) and is in accordance with the Electronic Communications Code (as amended))

You may comment on-line by using the ‘make comments’ tab or by e-mailing planning.comments@brent.gov.uk. Make sure you provide the application  number, your name and postal address. Your comments and address will be publically available, although your name won’t be. You may check what the final decision is by selecting “track application” on our website.

Please make your comment by 12/01/2023; after that we will make a decision on the proposal as soon as possible.

As with all such proposals the default position is approval to aid the roll-out of 5G transmission as part of the government's diginal vision. The applicant states:

The proposed installation supports the UK Government Digital connectivity vision and provide a basis for support from the local planning authority to speed up digital infrastructure rollout set by Ministers on 27 August 2020. Such development will facilitate educational benefits, providing access to vital services, improving communications with the associated commercial benefits for local businesses, enabling e-commerce and working from home as well as enjoying access to social, media and gaming for leisure time activities.
In accordance with the requirement set within National Planning Policy Framework (February 2019) guidelines; the proposed ‘Streetworks’ design has been selected to minimise visual impact upon the street scene by integrating with existing street furniture.

 

The applicant claims their proposal meets Brent Council's criteria for 5G installations but note the final point regarding Conservation Areas.

One local resident has submitted a comprehensive Objection:

This proposal is completely misguided and should be rejected.

It would create an unacceptably intrusive, overbearing and incongruous feature at a very prominent location, wholly out of scale and inconsistent with nearby buildings and structures, and would materially impact the character and appearance of the Mapesbury Conservation Area and the Willesden Green Conservation Area, as well as of Willesden Green Station and St. Gabriel's Church, both grade II listed buildings.

It's extraordinary that the applicant has managed to find a site for this 20 metre mast that would materially impact the character and appearance of not just one but two separate conservation areas and two separate grade II listed buildings.

Further, while the applicant asserts that the site is outside of the Mapesbury Conservation Area, according to the official map of the Mapesbury Conservation Area (https://legacy.brent.gov.uk/media/16402740/mapesbury-conservation-area-map.jpg) the boundary of the conservation area runs down the middle of Walm Lane and therefore the site is within the conservation area. In any event our comments are relevant regardless of whether the site is or not within the conservation area: if outside it would still be on the boundary of the conservation area and would have just as a material impact on the visual amenity and character of the conservation area as if it was inside it.

In more detail, my objection is based on the following:

(A) The mast would be very significantly taller than all surrounding housing. At 20 metres it would be almost double the height of the adjacent Westerly Court (11 metres), which itself is taller than all other surrounding housing on the north side of the railway, and more than double the height of street lighting and trees.

(B) The mast would be very close to the top of the hill, which would increase even more its actual and perceived height compared to the surrounding housing, including the two conservation areas.

(C) The mast would be located in a corner plot, increasing its visibility and prominence.

(D) The mast would be directly in line with the north face of Westly Court, meaning that its entire height would be visible from the whole north side of Dartmouth Road.

Factors (A), (B), (C) and (D) will exacerbate the visual prominence of the mast which will be seen over a wide area. It is likely that it would be visible from every first or second floor south facing window in the Mapesbury Conservation Area.

The streetview up and down Walm Lane between St. Gabriel's Church and the top of the hill where Willesden Green Station is located is a critical and integral element of the Mapesbury Conservation Area's character and appearance. Further, the northward streetview up Walm Lane and across the top of the hill in front of the Willesden Green Station is a critical and integral elements of the Willesden Green Conservation Area character and appearance. Both of these would be completely ruined by the mast, which would tower above and overbear all of these views.

(E) The mast would be in very close proximity (70 metres - 3.5 times its height) to Willesden Green Station, which is a Grade II listed building, and would significantly impact the appearance of the station and of the open space in front of it (which is part of the Willesden Green Conservation Area) when approaching from the north (from the Mapesbury Conservation Area) and the south (through the Willesden Conservation Area).

(F) The mast would be right in the straight line of sight between Willesden Green Station and St. Gabriel's Church, which is also a Grade II listed building and is located about 10 meters lower down the hill (meaning that it would tower above the church in the background when approaching the church southwards along Walm Lane).

The applicant has taken no account in its application of the fact that the visual amenity and character of two Grade II listed buildings will be materially impacted by the proposal, as set out in (E) and (F) above.

(G) Finally, given that the applicant has taken no account of the above factors in the design of the mast (other than to say that the site is outside of a conservation area, which appears to be inaccurate and in any event is immaterial), the proposal itself does not comply with the design principles set out in the Code of Best Practice on Mobile Network Development in England (2016 Edition) - in particular those set out in Appendix A.

While not directly relevant to my objection to the application, I would also like to highlight that:

- The area in the vicinity of the site is already very well served by broadband internet and further developments are currently ongoing (e.g. Hyperoptic is currently installing fibre underground throughout the conservation area), so there is no "critical need" for this 5g infrastructure, notwithstanding what the applicant says in its application. This should be taken into account when considering the balance between the need for this specific 5g mast and other public policy considerations (such as public amenity) when assessing this application.

- The proposed siting of the equipment boxes at the street level is completely irrational. It is proposed that they will be located in the middle of the public footpath, significantly reducing the available space for pedestrians and other users. What is the applicant's rationale for occupying so much footpath space and inconveniencing pedestrians, rather than siting the boxes beside the existing boxes on the east edge of the footpath?

- There is already a telecoms mast located along the train line on the south side of the Tube railway tracks, adjacent to Lydford Road. Given the presence of multiple conservation areas and listed buildings in the vicinity of the proposed mast, what consideration has the applicant given to reinforcing and/or sharing that mast, consistent with the requirements of the Code of Best Practice on Mobile Network Development in England (2016 Edition), or otherwise siting the mast along the railway at a suitable distance from the existing tower, where it would not be as much an eyesore?

- There is already a telecoms mast located along the train line on the south side of the railway tracks, adjacent to Lydford Road. Given the presence of multiple conservation areas and listed buildings in the vicinity of the proposed mast, what consideration has the applicant given to reinforcing and/or sharing that mast, consistent with the requirements of the Code of Best Practice on Mobile Network Development in England (2016 Edition), or otherwise siting the mast along the railway at a suitable distance from the existing tower, where it would not be as much an eyesore?

 Regarding alternatives, as suggested by some of the Objectors, including updating existing masts in the area, the Applicant states:

The very nature of installing new 5G mast infrastructure within such an urban setting requires a highly considered balance between the need to extend practical coverage reach with that of increasing risk of visual amenity intrusion. In this location, existing mast sites are not capable of supporting additional equipment compliment to extend coverage reach across the target area and prospective ‘in-fill’ mast sites are extremely limited.

There is an acute need for a new base station to provide effective service coverage and in this case, the height of the proposed street pole is the minimum required to bring the benefits of 5G to this area.

Mapesbury asphalt compromise?

A rather excited Cllr Dar has posted this on Twitter:

Although not mentioned in Cllr Dar's tweet the pavement survey LINK and petition must have been influential.

This is what the MaPRA circular says:

Pavements. Met with Council Officers today.  Faced with opposition from Cllr Lia Colacicco and also a residents’ petition against asphalting the pavements in 3 streets in the Mapesbury Conservation Area, the compromise they are offering is to give up their plan for wholesale replacement of the pavements with asphalt and instead (starting with Dartmouth Road) to carry out much-needed systematic repair. This would mean replacing/rectifying many cracked and defective paving stones with new paving stones (not asphalt) and providing a new treatment around the trees which is not yet defined/specified. There is an option for trees of either a surround made up of grey, recycled synthetic rubber balls, which are porous and don’t crack like tarmac or paving stones, or, if people want, there could be a built-up tree pit around each tree allowing residents to come together and plant and tend small plants around the base of the tree outside their home. The Council is open to suggestions from MapRA.

 

The proposal represents a good compromise; less cost than either wholesale replacement by paving or asphalt, lower environment impact, maintains the paving stone look in the MapRA area with less disruption while work is carried out. It should leave paving free of trip hazards. It may, however, not leave all of the pavements quite as smooth as new asphalt or completely new paving stones.

Brent Council accused of mendacity over trees/paving policy

Salmon Street, NW9 - August 2019

 From an email sent to Brent Council:

RE: Brent Council Announces Climate Emergency And Then Chops Down All The Trees

Are you still insisting we hold a meeting outside in the dark today, at rush hour, before most residents have got home ?

I am unsure exactly what you propose to convey to us with your "brief discussion" in these conditions; we obviously will not be able to see the trees you mention.

Is it your intension to try to confine this discussion only to these remaining eleven trees on Furness Road ?

As you know the systematic destruction of Brent’s wonderful & varied stock of mature trees has been ongoing for a decade. 

Many of us have correspondence with the council going back several years regarding the tragic culling of mature and healthy trees outside our homes.

Amid repeated broken promises of them being replaced, line upon line have been erased from our streets. Furness Road has suffered terribly. And it continues.

We would like them back.

Who is sending these chainsaw gangs around the borough and why?

Similar action by another council in a recent case was described by Michael Gove (then Minister for the Environment) as “Ecological Vandalism’.

At an impromptu gathering outside Furness Rd School last Monday, a council representative claimed that it is Brent Council’s intention to replace ALL paving stones throughout the whole borough with asphalt.

Can you confirm if this is true ?

If so, what volume of asphalt in tonnage is likely to be purchased by the council ? 

I’m sure rough estimates by quantity-surveyors were calculated before such a decision was made.

What calculations regarding carbon offsetting, to cancel-out the use of such a large quantity of petroleum-based bitumen/asphalt have been completed ?

And, how does the felling of thousands, of mature trees help in this offsetting?

Clearly, in spite of recent claims by Brent Council, that they are in some way concerned with the environment, their actions (historic & ongoing), and recent decisions regarding pavements and canopy cover (without consultation) demonstrate the opposite. Indeed, it shows utter contempt.

This amounts to a public relations disaster for Brent Council & current MP, and yet further anger & frustration for the borough’s long-suffering residents.

Finally, I understand Krupa Seth will be attending today.

I do look forward to Counciller Sheth's answers to our previously unanswered questions and outstanding FOI requests sent to her under separate cover.

And a response to the above email from a resident with whom it was shared:

Thank you for an intelligent and insightful email which rightly centres on Brent Councils casual disregard for its tree stock and the profligate waste of money caused by this approach to pavement works, that is compounded by the damaging use of the extensive amounts of a fossil fuel derivative.

Brent Council has a corporate responsibility to reduce the amount of fossil fuel use in the borough – not increase it steadily.

This is for obvious reasons – obvious to everyone else, except the officers of Brent Council.

Brent is fortunate in that it appears to have many intelligent, engaged people who really do care about their borough and the way it is managed – it is deeply shameful that Brent Council continues with its ruinous pursuit of degrading the public realm facilitated by a Council that views its environmental responsibilities as a minor inconvenience.

I see again, the mendacious line trotted out again that a replacement sapling is in anywhere near a reasonable replacement of a mature tree as regards the large environmental benefits provided by a mature tree.

It will take decades for the replacement sapling to reach the same amounts of carbon sequestration, the production of oxygen, reduction in solar gain and the ecological benefits for wildlife.

Anyone with common sense can see the lunacy and ignorance of that statement – any honest arborist would tell you exactly the same thing. 

You would think it should be incumbent for the officers of Brent Council to be aware of this basic fact – this is not a difficult of overly complicated concept.

If not, they are either ignorant or incompetent or just plain dishonest.

This is a borough wide issue regardless of Brent Council's opinion and residents will continue to fight this environmental degradation everywhere in the borough.

The road to Hell is paved with Brent's good intent (or asphalt)

 

Recent paving in the Barn Hill Conservation area - why not Mapesbury?

A Mapesbury resident who is a retired Civil and Structural Enginer (MIStructE and MICE) has carried out a pavement survey of Dartmouth Road where Brent Council wishes to replace the paving in this Conservation Area road with asphalt.

The survey has been forwarded to the  Council and members of the Mapesbury Residents Association.

The works have been temporarily suspended giving time for  review and it is hoped that in the light of the Council's Climate Emergency Declaration an assessment will be made of the comparative carbon footprint of renewing broken paving compared with taking paving up and replacing with asphalt.

Dartmouth Road Pavement Survey.

Carbon footprint of proposed replacement of paving slabs by asphalt

Date:  20.11.19

This report is based on a detailed survey of the pavements on both sides of Dartmouth Road:

A:  between nos. 103 to 131

B:  between nos. 60 – 92

Which is ¼ of the length of Dartmouth Road.

C:  between nos. 1 – 24.  This last section has recently been repaved and is in excellent order.  See appendix for the survey results for this section.

Pavements are on average 2700 mm. wide and are formed using 600 x 750 and 600 x 600 precast concrete paving slabs. The width consists of two of each size staggered: 

(2 x 750 ) + ( 2 x 600 ) = 2700.

Each property is approx. 10 m wide and so there are theoretically 16 ½ x 4 = 68 slabs per property. But many properties have vehicle crossovers which reduces the number of slabs. The crossovers are either of concrete or block paving construction or a mix of one of these plus paving slabs.  There are also a very few tarmac crossovers.

Where trees occur the paving is extended upto the tree or there is a resin gravel type infill upto the tree, or occasionally tarmac or nothing with the soil visible. Whatever has been installed next to the tree has usually failed in some way and is uneven.  These areas have the most trip hazards.

Concrete and concrete block vehicle crossovers have performed best and are often in good serviceable order. Any area of crossovers that is surfaced with paving slabs is in poor condition with on average over 1 / 3 of the paving slabs cracked.

Good condition slabs .			Cracked slabs .
Between crossovers	At vehicle crossovers	Total	Between crossovers	At crossovers	Total
1540	243	1783	129	72	201
			% of total 129/1540= 8.3 %	% of total 72 / 243= 29.6%
Whole length of Dartmouth Road pro-rata  (i.e. x 132 / 32 )
6350	1000	7350

It can be seen that paved crossovers contribute nearly 4 times the rate of cracking that occurs  in areas between crossovers.

It can also be seen that within crossovers there are 243 – 72 = 171 uncracked slabs which is comfortably more than the 129 cracked slabs within the paved areas between crossovers. So when the defective crossovers are replaced there will be sufficient uncracked slabs recovered to replace all the cracked slabs between the crossovers.

We can extrapolate this detailed survey to the whole of Dartmouth Road because a visual inspection indicates that the area surveyed in detail here is of the same configuration as the whole of Dartmouth Road and the total figures for the whole road are shown in the table. 

The plan proposed by Brent Council is to remove all the paving and replace the crossovers with block paving and to infill between the crossovers using asphalt.

Therefore the number of paving slabs to be removed from between crossovers and dumped is 6350 slabs.  The slabs are 50mm thick

The average weight of a slab is (.6m x .675m x .05m) x 2000 kg / m cube = 40.5 kg

Therefore the weight of slabs to be removed = 6350 x 40.5 / 1000 = 257 tons. These slabs have to be lifted, piled up and then grab loaded onto a lorry and taken to a dump. Such loading will achieve about 10 tons per typical 8 wheel lorry giving rise to 26 lorry movements. And the dumping will attract landfill tax. More seriously, these slabs will remain in landfill unchanged for centuries.

Asphalt requires a well compacted base layer of stone which will have to be imported because the sand / soil / clay found under the existing slabs when lifted will need improvement. 

The area of new asphalt will be the same as the paving removed = 6350 x 0.6 x 0.675 = 2570 m square. 

Allow for a restored formation thickness of 75mm, this will require the removal of 75mm of existing soft material ( to maintain existing levels) and reinstatement using 75 mm of stone material. So the volume of material removed and replaced will be 2 (1 removal and one replacement) x 2570 x 0.075 = 385 m cube = 770 tons. Which at 15 tons per lorry for this type of material gives rise to 51 lorry movements.

The amount of asphalt required if 20mm thick will be 2570 x .02 = 51 m cube = 100 tons at least, requiring another 10 lorry movements.

So the total weight of materials being lifted and moved is 257 + 770 + 100 = 1,127 tons requiring 26 +5 1 + 10 = 87  lorry movements. 

The lorries will have to travel to a dump outside London and the asphalte and stone will have to be brought in from a quarry, also well outside London.  This represents a lot of diesel at 10 mpg! And this is just Dartmouth Road. For the whole of Mapesbury Estate there will be at least 6 x these quantities, i.e nearly 7,000 tons of materials dumped or imported, involving 500 plus lorry movements. 

Furthermore, since Brent plans to change all the pavements in the Borough for asphalt, the quantities will become huge.

It is obvious that the proposed use of asphalt to replace existing slab paving is totally unacceptable on carbon foot print grounds for material handling and transport and the energy intensive manufacture of the asphalt itself, which is a heavy crude oil hydrocarbon based product. Levelling the slabs in situ would have minimal carbon foot print and lead to a pleasing durable solution appropriate for a Conservation Area. 

Appendix:  P

Appendix:

The section of Dartmouth Road between Mapesbury Road and Exeter Road has also been surveyed in detail as follows. This section was re-laid using slabs 5 years ago and is in very good condition and shows how successful slab paving can be when well laid.

Survey on Dartmouth Road between numbers 2 and 14 and the opposite odd numbers side which is in equally good condition
Good condition slabs .			Cracked slabs .
Between crossovers	At crossovers	Total	Between crossovers	At crossovers	Total
1043	No paved crossovers, all are conc. or blocks or tarmac	1043	19 *	No paved crossovers, all are conc. or blocks or tarmac	19
			% of total 19/1043 = 1.8 %		% of total 19/1043 = 1.8 %

About half of these cracked slabs are so finely cracked it is difficult to see the crack because they have not moved having been very well laid.

This table applies to only 15 % of Dartmouth Road and so would not affect the pro-rata totals used above very much and in fact further support the case for retaining all the existing paving in Dartmouth Road.