Guest post by Philip Grant
As I am “staying at home”, and not out and about to
notice what is going on, I usually have a quick look at the “Legal and Public
Notices” in the online edition of the “Brent & Kilburn Times” each week.
One entry in the planning notices last week caught my eye; an application (ref.
21/0379) for ‘Removal of condition 13’ from a planning application (ref.
17/4877) which was approved in February 2018.
Google aerial view, showing the site location, from
a planning application document.
The location turned out to be the Boxpark building,
at the junction of Olympic Way and Fulton Road. But what was the planning
condition they wanted removed?
‘Condition 13: Moving images shall not be displayed
on the Fulton Road façade and the northern section of the Olympic Way façade of
the building (within the area marked as ‘Zone A’ on drawing no. A00_MIC_01
P2007903) at times when Fulton Road is open to vehicular traffic, unless
otherwise agreed in writing by the Local Planning Authority.’
The applicant, Open Outdoor Media Ltd, wants that
condition removed, so that it can display ‘full-motion advertisements’ on the
large LED screen mounted on the north-east corner of the Boxpark building all of
the time. At the moment, the screen which they installed there in 2019 can only
be used to display static advertisements, apart from 90 minutes before and
after major Wembley Stadium events, when Fulton Road is closed to vehicular
traffic.
The LED advertising screen (‘I AM JD’) at the
corner of the building, from an application document.
Why was that condition there in the first place?
The answer is clear from the Report to the February 2018 Planning Committee
meeting:
‘Highway safety: The Council’s Transportation
Officers have expressed concern about the highway safety implications of
displaying moving images readily visible to drivers using adjacent roads. In
response to their concerns, a condition is recommended to ensure that moving
images are not displayed on the Fulton Road façade and the northern section of
the Olympic Way façade of the building at times when Fulton Road is open to
vehicular traffic.’
So what is different now? Planning agents on behalf
of the applicant have submitted a glossy report by the Manchester-based S-C-P
Transport consultancy (‘Driven by the desire to help clients achieve their
goals’). This looks at the highway safety aspects of the latest application,
both at the Fulton Road crossing, and with case studies of other sites (mainly
in the North and Midlands) where full-motion advertising screens have been
installed near roads.
Their thorough review includes research, such as
this:
‘In order to identify critical locations on the
network with a poor accident record, the personal injury accident data has been
obtained from the online resource CrashMap for the most recent 5-year period,
ending December 2019.’
They found that, during that five-year period, only
‘one accident took place at the Fulton Road / Olympic Way crossing, which
resulted in “serious” severity injuries.’ Their conclusion was:
‘Whilst all accidents are regrettable, the evidence
… suggests that the area in the vicinity of the site does not have any
recurring highway safety problems that could be affected by the development
proposals.’
Their report does admit that the LED screen was
only installed at the end of June 2019, and then was not displaying any moving
adverts while vehicles were using Fulton Road during the six months to December
2019. However, as the serious accident on the crossing took place during the
previous 4½ years, they claim it demonstrates that the LED screen
advertisements ‘have not led to any material increase in accidents.’
The view along Fulton Road towards the Olympic way crossing,
with the bright LED advertising screen (‘JD WE’RE BACK’) on the corner of the
Boxpark building, from the S-C-P report.
The case studies (as you might expect) show that
putting full-motion advertising screens near busy roads does not tend to increase
the number of serious accidents or injuries. But although the amount of vehicle
traffic along Fulton Road is not as great as a city centre road in Manchester,
Liverpool or Nottingham, the number of pedestrians walking up and down Olympic
Way, and crossing Fulton Road, is very large. It is also likely to increase
even further as more and more Wembley Park developments are completed.
It would only take one driver of a bus or heavy
lorry coming along Fulton Road, or one pedestrian walking up Olympic Way from
the station, to be distracted by a moving advert on that screen at the wrong
moment, for a serious accident to occur. In my opinion, even one such accident
would be one too many.
As advertising is involved, the screens also had to
obtain advertisement consent, and the approval of that application (ref:
18/1796) contained an identical condition to “Condition 13” in the Boxpark
planning approval. The agent’s covering letter with the latest application
acknowledges the reasons given in the Planning Report for that:
‘Concerns were previously raised with regard to
distraction of drivers from moving images along the Fulton Road frontage and
the northern end of the Olympic Way frontage, with road safety studies
undertaken by the Transport Research Laboratory highlighting the significantly
greater impairment to driving performance presented by moving images, as
compared to static displays.’
Despite this, the letter goes on:
‘The applicant is however of the view that the
provision of full motion images on the LED screens would be entirely acceptable
in terms of public safety and highway safety and that Condition 13 of 17/4877
should be removed and an amended application for advertisement consent be
issued.’
That view is unsurprising, because the application
would not have been made unless Open Outdoor Media Ltd thought there was a
chance that they might get that condition removed. And if it is removed, they
will, of course, be able to generate more profits by selling full motion
advertisements, rather than just static ones.
Surely, this latest application will be rejected,
on the same public safety grounds that saw the condition imposed in the first
place, won’t it? Having looked at Brent’s planning website, I do have some
concerns, including that the expected decision level is “Delegated Team
Manager”, rather than the borough’s Planning Committee which decided the
original application.
A greater concern is the amount of consultation on
application 21/0379. The list of those consulted on the application only contains
two addresses. The first is Brent Civic Centre (the Council’s Transportation
Unit has been asked to comment). The second is 180 Great Portland Street,
London W1W 5QZ. Puzzled? That is the registered office address of Quintain Ltd
(joint owners, through BPQW Ltd, of Wembley’s Boxpark business).
On the original application, consultee comments on
public safety matters had been submitted by the Metropolitan Police and by
Brent’s Public Safety Manager. Why were they not consulted this time? And what
about consulting Wembley Stadium, the residents’ associations for blocks of
flats whose leaseholders use the crossing on a daily basis, or the owners of
student accommodation buildings in the area? It’s almost as if Brent’s planners
wish to avoid there being any objections to this application – but that can’t
be right, can it?
In my opinion, the risk of death or serious injury
at this location is too great for this application to be approved, so I have
submitted an objection. If you agree with me, you can make your objection on
the Council’s planning website for application 21/0379.
Philip Grant.