A10 Electronic Interference: Application 2 - LBHF

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1 A10 Electronic Interference: Application 2 - LBHF Addendum to the Environmental Statement Volume I January 2012

2 Introduction A10.1 This Chapter of the Addendum to the June 2011 Environmental Statement (ES) (Volume I), hereafter referred to as the ES Addendum, considers the amendments that have been made to the Earls Court Development Proposals in the context of electronic interference. Consideration is given to the changes that have been made to the outline elements of the Earls Court Development Proposals in addition to the submission of details in relation to scale, appearance and layout of development plots WV01, WV02 and WV05 and their subsequent potential affect on the impacts to analogue, digital and satellite television (TV) reception; radio reception; mobile telephone signals, wireless networks; and emergency service communications, as defined within the June 2011 ES (Volume I). A10.2 In addition, as appropriate, additional information and clarifications are provided within this ES Addendum Chapter as a result of consultation responses received to date on this technical aspect of the ES. A10.3 This ES Addendum Chapter has been prepared by URS Scott Wilson (URS) in consultation with Tom Paxton (a specialist electronic interference consultant), who have together used professional judgment in determining whether the alterations to the Earls Court Development Proposals will result in any changes to the potential residual impacts of the Development Proposals on electronic interference. Summary of the Conclusions of the June 2011 Environmental Statement A10.4 Chapter 10: Electronic Interference of the June 2011 ES considers the potential impact of the Earls Court Development Proposals (Development Option (Site Wide)) to analogue, digital and satellite television (TV) reception. Consideration was also given to the potential impacts on radio reception, mobile telephone signals, wireless networks and emergency service communications. A10.5 The reception of mobile telephone signals, wireless networks and emergency service communications were not assessed within the June 2011 ES, as it was concluded that the relevant aerials were not in the vicinity of the site (wireless networks and emergency service communications) or the aerials were not close enough for transmission characteristics to be compromised (mobile telephone signals). A10.6 Chapter 10: Electronic Interference of the June 2011 ES summarises the relevant planning policy context (as of June 2011); describes the methodology used to assess the potential impacts arising from the Earls Court Development Proposals and the scope of the impact assessment; describes the baseline conditions currently existing across the Earls Court Site in terms of TV signals; and presents the required mitigation measures necessary to remove or reduce significant adverse impacts. A10.7 Prior to mitigation, it is predicted that there could be impacts to the reception of terrestrial TV services for up to 257 existing aerial installations. The Earls Court Development Proposals will have TV shadowing effects, which essentially block of signals and so TV pictures very quickly deteriorate into random blocks and then disappear altogether. Impact pre mitigation can therefore be considered as major adverse. However, suitable mitigation measures, as identified within Chapter 10: Electronic Interference of the June 2011 ES, are available in all cases (i.e. the impact is reversible), and as it appears that % of existing dwellings in the predicted shadow area use satellite TV, the 257 figure is likely to be much higher than is the actual case. June 2011 Summary of Residual Impacts to Electronic Interference A10.8 Following the successful implementation of an agreed programme of mitigation, it is anticipated that the identified impacts on electronic interference, specifically terrestrial TV reception, would be of negligible significance. A10.9 Table A10-1 summarises the residual impacts of the Earls Court Development Proposals (as defined within the June 2011 ES (Volume I)) on electronic interference. Table A10-1 The Earls Court Development Proposals - Summary of Residual Impacts, June 2011 Description Nature of Impact Geographic Scale Significance Impact to terrestrial TV reception Negligible Local, Regional Negligible Impact to satellite TV reception Negligible Local, Regional Negligible Impact to broadcast radio services, mobile telephone signals, wireless networks and emergency service communications June 2011 Cumulative Impact Assessment Negligible Local, Regional Negligible A10.10 The June 2011 ES considers the potential for cumulative electronic interference impacts. Cumulative impacts are those that result from incremental changes caused by other past, present or reasonably foreseeable actions, together with a proposed development. There is no established EIA methodology for assessing and quantifying cumulative impacts. A10.11 It is recognised that cumulative impact interactions occur as either interactions between impacts associated with just one project or between the impacts of a number of projects in an area. A10.12 As a result, two types of cumulative impact interaction have been considered within the June 2011 ES (Volume I) as follows: 1. The combined effect of individual impacts (or Type 1 impacts) on a receptor arising as a result of the Earls Court Development Proposals; and 2. The combined impacts (or Type 2 impacts) of several development schemes which may, on an individual basis be insignificant but, together (i.e. cumulatively), have a significant effect. A10.13 Details on the combined effect of individual impacts arising as a result of the Earls Court Development Proposals is presented in Chapter A18: Cumulative Impact Assessment of this ES Addendum. A10.14 A summary of the June 2011 combined impacts (or Type 2 impacts) of several development schemes (referred to as Cumulative Schemes ), is presented below. A10.15 The following Cumulative Impact Assessment Scenarios are considered: SCENARIO 1: The Earls Court Development Proposals with the other Cumulative Schemes; and SCENARIO 2: The Earls Court Development Proposals PLUS the Seagrave Road Development Proposals PLUS the other Cumulative Schemes. A10.16 Each of these scenarios are discussed in more detail below. SCENARIO 1: The Earls Court Development Proposals PLUS other Cumulative Schemes A10.17 The Cumulative Schemes considered are those located within the predicted shadow area of the Earls Court Development Proposals, as well as those located to the south-east that have the potential to block the TV signals to the Earls Court Site. A10.18 By applying the same assessment methodology as used to ascertain the potential impacts of the Earls Court Development Proposals, four surrounding Cumulative Schemes required further consideration. They were the Ibis Hotel at 47 Lillie Road, the Holiday Inn Express at 295 North End Road, 72 Farm Lane, and 100 West Cromwell Road. A10.19 A review of these Cumulative Schemes concluded that the Ibis Hotel and Holiday Inn Express could block incoming terrestrial TV signals, but will both be too low to have the potential to cause a cumulative effect. Further afield, 72 Farm Lane could block incoming terrestrial TV signals, however due to its height and given its distance from the Earls Court Site, it will not cause a cumulative effect. A10.20 Therefore, in terms of the surrounding Cumulative Schemes impacting the Earls Court Development Proposals, no cumulative impacts were identified. A West Cromwell Road Cumulative Scheme, to the north of the Earls Court Site, falls within the digital TV signal interference zone created by the Earls Court Development Proposals. Thus, digital TV signals will be blocked to this A10-1

3 Cumulative Scheme from the massing of the Earls Court Development Proposals. Those proposed residential dwellings affected would need to use cable or satellite TV instead of relying on digital TV signals, or use a remotely positioned TV aerial (outside of the Earls Court Development Proposals shadow). SCENARIO 2: The Earls Court Development Proposals PLUS Seagrave Road Development Proposals PLUS Other Cumulative Schemes A10.22 The same assessment methodology was used in assessing the Seagrave Road Development Proposals. Lying immediately to the south-east of the Earls Court Site, the Seagrave Road Development Proposals would block the incoming digital TV signals to the Earls Court Development Proposals. The TV shadow created by the Seagrave Road Development Proposals would however be blocked by the taller elements of the Earls Court Development Proposals and would not extend beyond this point, thus, the number of dwellings predicted to be adversely affected by the Earls Court Development Proposals alone would not change. It is worth noting that the lowest elements of the Earls Court Development Proposals, along its southern boundary, will lie within the predicted TV shadow of Seagrave Road and will not receive digital TV signals. Those proposed residential dwellings would need to use cable or satellite TV instead of relying on terrestrial TV signals, or use a remotely positioned terrestrial TV aerial (outside of the Seagrave Road shadow). Further Information and Clarifications as a Result of Consultation A10.23 The following section of this Chapter of the ES Addendum provides further environmental information and clarifications on the information presented within Chapter 10: Electronic Interference of the June 2011 ES. Full consultation comments on the June 2011 ES, along with and detailed responses are provided within the Addendum to ES Volume III: Technical Appendices, Appendix B. The distinction between the provision of additional environmental information or clarifications is made in the following sections of the ES Addendum Chapter. Clarification on Testing of the Maximum and Minimum Parameters A10.24 As described in Chapter A2: EIA Addendum Methodology of this ES Addendum, the likely significant effects of the Earls Court Development Proposals on electronic interference have been assessed, in both the June 2011 EIA and further, in relation to the revised Earls Court Development Proposals in this ES Addendum, using the maximum parameters. This is the maximum scale of development possible within the parameters shown on the Parameter Plans (disregarding those further limits on scale imposed by the Design Guidelines). This is considered to result in a robust assessment of the likely worst case electronic interference impacts; as a larger development massing leads to a greater extent of electronic interference. A10.25 As concluded in the June 2011 ES and, in relation to the revised Earls Court Development Proposals addressed within this ES Addendum, the likely effects of the revised Earls Court Development Proposals on terrestrial and satellite TV reception and impacts to broadcast radio services, mobile telephone signals, wireless networks and emergency service communications are assessed as being of negligible significance (post mitigation). A10.26 Neither the EIA presented in the June 2011 ES nor within this ES Addendum assesses the likely impacts of a smaller scheme within those parameters for two reasons. It is considered that the likely effects of a smaller proposed development will have a less significant impact (which is, in any event, negligible). Also, as noted in Chapter A2: EIA Addendum Methodology of this ES Addendum, the variation between the maximum and minimum parameters is minimal; therefore it is considered that the differences in electronic interference impacts between a maximum scale development and minimum scale development will not be material. Further Information to clarify the decision to rule out the need to assess the mobile telephone signals, wireless networks, and emergency services communications A10.27 As discussed within Chapter 10: Electronic Interference of the June 2011 ES (Volume I) (paragraph 10.25), radios use signals at lower frequencies than TV signals, which can bend to a greater extent around obstructions. Combined with an ability to make constructive use of reflected signals, radios are able to operate successfully in urban environments. There is therefore considered to be no significant risk to radio reception (both analogue and digital) from the construction of the Earls Court Development Proposals, and as such, radio reception was not considered further within the June 2011 assessment. A10.28 As discussed within Chapter 10: Electronic Interference of the June 2011 ES (Volume I) (paragraph 10.26) the reception of mobile telephone signals, wireless networks and emergency service communications should not be compromised unless their transmitting aerials are sited on top of nearby buildings at heights less than those of the Earls Court Development Proposals. Should that be the case, the affected transmitting aerials may have to be relocated. Only mobile telephone aerials were noted in the vicinity, however, none were close enough for their transmission characteristics to be compromised. A10.29 To expand on the text provided within Chapter 10: Electronic Interference of the June 2011 ES (Volume I) (paragraph 10.26), an inspection of the Ofcom database 'Sitefinder' (Ref. A10-1) was undertaken to ascertain whether there were any mobile telephone and emergency service communication transmitting aerials within the vicinity of the area. Only mobile phone transmitter aerials were identified in the area (refer to maps presented in Figure A10-1), therefore, emergency service communication transmitting aerials were not considered further in the June 2011 electronic interference assessment. A10.30 The location of these identified mobile phone transmitters was reviewed to ascertain the possibility of their operation being compromised by the proximity of elements of the Earls Court Development Proposals (i.e. new massing of a greater height, within (approximately) 10 metres (m) of a mobile transmitter). Those transmitter aerials that were considered to potentially be at risk were (visually) inspected during the March 2011 site visit, to more accurately place their positions on rooftops. Following this inspection, it was confirmed that no such transmitter aerials were located at a position or height where they would be at risk. It was, however, noted that three mobile telephone masts are currently sited on the roofs of the two Earls Court Exhibition Centres and they will have to be re-sited before demolition takes place. The present owners will inform the operators of these three masts. Mobile telephone signals were not considered any further within the June 2011 electronic interference assessment. A10.31 During the March 2011 site visit, through an inspection of the area, no wireless networks transmitting aerials were identified. Therefore wireless networks transmitting aerials were not considered any further within the June 2011 electronic interference assessment. A10.32 With regard to Metropolitan Police communications from the Empress State Building, there are two types of radiowaves used by police communications: Mobile communications whereby a transmitter/receiver on the roof is used to communicate with police on the ground in cars or on foot; and Secure microwave links from fixed point to fixed point i.e. from building roof to building roof. These are essentially line-of-sight communications i.e. the signals travel in a straight line and if they are blocked then they will not work. A10.33 With regards to mobile communications, the frequencies used can bend and be reflected, therefore the introduction of the massing related to the Earls Court Development proposals will not adversely affect this form of communication. A10.34 It is possible that there are microwave links on the roof of the Empress State Building that are being used by the Metropolitan Police. These are radiowave transmissions from one fixed point to another, very much like a torch beam of light from one rooftop to another rooftop. Technical information relating to these is not within the public domain. The revised Earls Court Development Proposals include two tall buildings at the same height as the Empress State Building (106.1m). Whilst these taller elements of the Earls Court Development Proposals are not tall enough or near enough to compromise other types of transmitters that might be on the roof, they could block microwave transmissions. A10.35 The ability to use microwave links in an urban environment depends on the ability to use several rooftops to bounce the signal around any obstructions before reaching the desired receiver. This is common practice when setting up a microwave network and, should elements of Earls Court Development Proposals block a particular microwave link, it would be for the Metropolitan Police to reconfigure their network to overcome the blockage. The Metropolitan Police are aware of the Earls Court Development Proposals, specifically the position and height of the proposed taller elements, so that their internal communications people can assess the risk and put measures in place if necessary. A10-2

4 Figure A10-1 Sitefinder Mobile Phone Base Station Database Review of Planning Policy Context A10.36 Chapter 10: Electronic Interference of the June 2011 ES summarises the relevant planning policy context (as of June 2011). Consideration is given to national and regional planning policy; and local planning policy of relevance to the LBHF. In addition, the Chapter considers the local policy context of the RBKC with respect to electronic interference. Whilst Application 2 is for the LBHF determination, the Earls Court Site straddles the borough boundary of the LBHF and the RBKC. National Planning Policy A10.37 The review of the national planning policy context (as presented in the June 2011 ES) remains valid and so applicable to the revised Planning Applications for the Earls Court Development Proposals. A10.38 In July 2011, a draft of the National Planning Policy Framework (Ref. A10-2) was issued for consultation. In relation to electronic interference, Page 24: Facilitate the growth of communications infrastructure states: construction of new buildings or other structures does not cause interference with broadcast and telecommunications services. Regional Planning Policy A10.39 The Replacement London Plan has been adopted. Of key relevance is Policy 7.7D of the 2011 London Plan (Ref. A10-3) which relates to tall buildings and electronic interference. Policy 7.7D states that tall buildings should not affect adversely their surroundings in terms of telecommunication interference. A10.40 Since June 2011, the Earls Court & West Kensington Opportunity Area Revised Draft Joint Supplementary Planning Document (SPD) (Ref. A10-4) is now out for public consultation (until the 23rd December). This revised draft SPD builds on the first draft SPD, published for consultation in March 2011, and where appropriate reflects comments made by consultees. A10.41 Key Principle UF25 of the revised draft SPD relates to telecommunications: proposals for tall buildings should indicate how their impact telecommunications interference will be mitigated. Local Planning Policy A10.42 The LBHF has adopted their Core Strategy. The LBHF Core Strategy (Ref. A10-5) was adopted on the 19th October There are no policies of relevance to electronic interference in the LBHF Core Strategy. A10.43 The LBHF UDP saved policy relevant to electronic interference, as referred to in the June 2011 ES Chapter, remains valid and so applicable to the revised Earls Court Development Proposals. A10.44 The review of the RBKC Core Strategy, 2010 (Ref. A10-6) (as presented in the June 2011 ES) remains valid and so applicable to the revised Planning Applications for the Earls Court Development Proposals. Review of the Baseline Conditions A10.45 The baseline as presented within the June 2011 ES remains valid and so applicable to the revised Earls Court Development Proposals. The transmitters providing TV signals to the Earls Court Site and surrounds remains as presented within the June 2011 ES. Review of the Impact of the Design Changes A10.46 The design changes and amendments to the form and content of the Planning Applications are described in full in Chapter 4: The Design Changes. A10.47 Changes to the massing and height of the maximum scale parameters of the Earls Court Development Proposals have the potential to impact upon the number of residential terrestrial TV aerial installations in the surrounds that are predicted to lose signal. The scale of the impact is dependent on the extent of the massing changes. A10.48 The key design changes made to the June 2011 Earls Court Development Proposals can be summarised as follows: A10-3

5 Changes to the nature of the Planning Applications insofar that there will no longer be parameters or guidelines associated with plots WV01, WV02 and WV05. The detailed layout, scale and appearance of development comprising these plots are submitted for approval. Changes to the parameter plans / maximum and minimum envelopes for a number of development plots as follows: The massing proposed specifically for development plots WK01, WK04, WV03, WV04, WV06, BW04, BW06 (bottom half), NE01, NE06, is more defined and fixed to a specific building form, i.e. a change from plot based parameters as presented within the June 2011 Planning Application, to building based parameters. The scale and massing of development plots WK01, WK04, WV03, WV04, WV06, NE01, NE06, BW04, BW06 and BW07 have been tightened and so revised parameters are submitted for approval in relation to these plots. Enhanced Design Guidelines (i.e. further detailed requirements are included) for the feature buildings at BW07, BW05, BW04, NE06, BW02, BW03, BW01 and NE02. A10.49 With regard to the electronic interference assessment, the most significant changes to the massing are the changes to plots BW04 and NE06. Within these plots, the taller elements of the Earls Court Development Proposals are located, which cause a longer interference shadow when compared to smaller plots. The massing of these plots has altered, with repositioning of the taller building in plot BW04, and general amendments to the positions and sizes of the blocks within the plots, as well as reductions in heights. A10.50 The proposed 6 key phases of the deconstruction / demolition and construction of the Earls Court Development Proposals remain as per the June 2011 ES. January 2012 Potential Impacts & Mitigation Measures A10.51 In light of the changes made to the massing of the Earls Court Development Proposals, the impacts to electronic interference aspects (and so the proposed mitigation strategy) remain unchanged and so are as discussed within the June 2011 ES (paragraphs ). A10.52 The massing alterations and reduction in maximum development plot heights do not alter the predicted shadow from the Crystal Palace transmitter. The predicted shadow would remain cast in a north-west direction from the Earls Court Site and would extend up to 0.7 km. As within the June 2011 assessment, beyond this distance, across Hammersmith Road, the existing buildings are of sufficient height so as to extend above the TV shadow, and dwellings beyond this point will already be in the shadow of these existing tall buildings on the north side of Hammersmith Road. A10.53 As the phasing of the deconstruction, demolition and construction of the Earls Court Development Proposals remain as per the June 2011 ES, the assessment of inter-phase analogue interference to parts of the Earls Court Site that still have existing residents in their original housing presented within paragraphs of the June 2011 ES remains valid and so applicable to the revised Earls Court Development Proposals. January 2012 Residual Impact Assessment A10.54 Following the successful implementation of an agreed programme of mitigation, it is anticipated that the identified potential impacts to TV reception as a result of the Earls Court Development Proposals are considered to be of negligible significance. As discussed within the June 2011 ES, it appears % of existing dwellings in this shadow area use satellite TV, therefore, in reality, the number of dwellings potentially affected and the amount of mitigation proposed is likely to be much less than what has been predicted in the June 2011 assessment. A10.55 The residual impacts to electronic interference remain as presented in the June 2011 ES (Chapter 10: Electronic Interference) and as presented within Table A10-1. Review of the Cumulative Impact Assessment Combined Effects of Individual Impacts (Type 1) A10.56 Type 1 impacts (or combined effects of individual impacts) occur when a single receptor is affected by more than one impact at any point in time. A10.57 An exercise which tabulates the residual impacts identified in the June 2011 ES (Volume I) and this ES Addendum against relevant receptors and so identifies the different individual impacts on each receptor has been completed. Reference should be made to Chapter A18: Cumulative Impact Assessment of this ES Addendum for further details. Cumulative Impacts with the Other Schemes (Type 2) SCENARIO 1: The Revised Earls Court Development Proposals with the other Cumulative Schemes A10.58 A review of the other Cumulative Schemes that were considered within the June 2011 Cumulative Impact Assessment has been undertaken. The following amendment (change in planning status from pending consideration to resolution to grant planning consent ) and two additional schemes are acknowledged: Amendment: Hammersmith Embankment residential led scheme 2011/00407/COMB, resolution to grant 23 September 2011; Additional Cumulative Scheme: Fulham Wharf, 51 Townmead Road, SW6 2SY 2010/02481/FUL resolution to grant 5 July 2011; Additional Cumulative Scheme: Westfield mixed use retail and residential led extension to the existing Westfield London shopping centre 2011/02940/OUT submitted for planning. A10.59 The June 2011 cumulative impact assessment considered those schemes that are located within the predicted shadow area of the revised Earls Court Development Proposals, as well as those located to the south-east that have the potential to block TV signals to the Earls Court Site. The additional cumulative schemes, Fulham Wharf and Westfield, do not fall within these areas, and are not considered further within this cumulative impact assessment. Therefore, the scenario 1 cumulative impact assessment as presented within the June 2011 ES remains valid and applicable to the cumulative impact assessment of the revised Earls Court Development Proposals. SCENARIO 2: The Revised Earls Court Development Proposals PLUS the Revised Seagrave Road Development Proposals PLUS the other Cumulative Schemes. A10.60 A revised Planning Application has been submitted in relation to the Seagrave Road Development Proposals. Revisions to the scheme that have the potential to affect the cumulative electronic interference assessment are changes in the massing. A10.61 There have been minor reductions of up to 1m on the heights of the buildings comprising the revised Seagrave Road Development Proposals (predominantly plant height reductions on the roofs of the buildings). The massing of building E has also been amended to improve its context and urban design, which includes a reduction in footprint of the building. A10.62 These changes are not deemed significant enough to alter the results of the cumulative impact assessment as presented within the June 2011 ES; therefore the June 2011 assessment remains valid and applicable to the cumulative impact assessment of the revised Earls Court Development Proposals. A10.63 The cumulative impact assessment of the revised Earls Court Development Proposals, plus the revised Seagrave Road Development Proposals plus the other Cumulative Schemes (including the amendment to the scheme on Hammersmith Embankment and the additional schemes at Fulham Wharf and Westfield, as noted above) remains as presented within the June 2011 ES. A10-4

6 Conclusions A10.64 The design changes made to the outline elements of the Planning Applications in addition to the submission of details in relation to scale, appearance and layout of development plots WV01, WV02 and WV05 have no material impact on the significance of the electronic interference assessment, and so the resultant mitigation strategy and overall conclusions presented within Chapter 10: Electronic Interference of the June 2011 ES (Volume I). A10.65 The June 2011 assessment of electronic interference impacts therefore remains applicable to the revised Earls Court Development Proposals. References Ref. A Ref. A10-2 Communities and Local Government, July 2011; Draft National Planning Policy Framework, July Ref. A10-3 GLA, 2011; The London plan Spatial Development Strategy for Greater London, July Ref. A10-4 Greater London Authority / LBHF / RBKC, 2011; Draft Earls Court and West Kensington Opportunity Area Supplementary Planning Document. Ref. A10-5 London Borough of Hammersmith & Fulham, 2011; Core Strategy. Ref. A10-6 Royal Borough of Kensington and Chelsea, 2010; Core Strategy. A10-5

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