A10 Electronic Interference: Application 1 - RBKC

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1 A10 Electronic Interference: Application 1 - RBKC 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 Development Option (RBKC) Proposals in the context of electronic interference. Consideration is given to the changes that have been made to the outline elements of the Development Option (RBKC) 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 Chapter of the ES Addendum 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 Development Option (RBKC) 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 Development Option (RBKC) Proposals to analogue, digital and satellite television (TV) reception. Consideration was also been 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 Development Option (RBKC) Proposals and the scope of the impact assessment; describes the baseline conditions currently existing across the Development Option (RBKC) 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 digital TV services for up to 60 existing residential aerial installations. The Development Option (RBKC) 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 80% of existing dwellings in the predicted shadow area use satellite TV, the 60 figure is expected 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 Development Option (RBKC) Proposals (as defined within the June 2011 ES) on electronic interference. Table A10-1 The Development Option (RBKC) 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: The combined effect of individual impacts (or Type 1 impacts) on a receptor arising as a result of the Development Option (RBKC) Proposals; and 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 Development Option (RBKC) 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: Development Option (RBKC) PLUS the other Cumulative Schemes; SCENARIO 2: Development Option (RBKC) PLUS the Seagrave Road Development Proposals PLUS the other Cumulative Schemes; SCENARIO 3: Development Option (Site Wide) - The Earls Court Development Proposals; SCENARIO 4: The Earls Court Development Proposals PLUS the other Cumulative Schemes; and SCENARIO 5: The Earls Court Development Proposals PLUS Seagrave Road Development Proposals PLUS the other Cumulative Schemes. A10.16 No Cumulative Schemes are in close enough proximity or of sufficient height to impact upon both the Development Option (RBKC) Proposals and the Earls Court Development Proposals. A West Cromwell Road Cumulative Scheme, to the north of the Development Option (RBKC) Site, falls within the digital TV signal interference zone created by both the Development Option (RBKC) Proposals and the Earls Court Development Proposals. Thus, digital TV signals would be blocked to this Cumulative Scheme from the massing of the Development Option (RBKC) Proposals and the Earls Court Development Proposals. Those proposed residential dwellings potentially 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 shadow area). A10.18 The Seagrave Road Development Proposal s predicted TV shadow will lie too far to the west to impact the Development Option (RBKC) Proposals; hence there is no potential for cumulative impacts to the Development Option (RBKC) Proposals or the shadow created by the Development Option (RBKC) Proposals. A10-1

3 A10.19 Due to the location of the Earls Court Development Proposals, although the Seagrave Road Development Proposals would not extend the predicted interference shadow of these proposals, the Seagrave Road Development Proposals will, however, block the incoming digital TV signals to the lowest elements of the southern boundary 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 and Seagrave Road shadow). A10.20 Each of the 5 cumulative scenarios are discussed in more detail in Chapter 10: Electronic Interference of the June 2011 ES. Further Information and Clarifications as a Result of Consultation A10.27 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. Figure A10-1 Sitefinder Mobile Phone Base Station Database A10.21 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 A10.22 As described in Chapter A2: EIA Addendum Methodology of this ES Addendum, the likely significant effects of the Development Option (RBKC) Proposals on electronic interference have been assessed, in both the June 2011 EIA and further, in relation to the revised Development Option (RBKC) 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. A10.23 As concluded in the June 2011 ES and, in relation to the revised Development Option (RBKC) Proposals addressed within this ES Addendum, the likely effects of the revised Development Option (RBKC) 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). A10.24 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 as 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 A10.25 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 Development Option (RBKC) Proposals, and as such, radio reception was not considered further within the June 2011 assessment. A10.26 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 Development Option (RBKC) 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. A10-2

4 A10.28 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 Development Option (RBKC) 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. A10.29 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. Review of Planning Policy Context A10.30 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 RBKC. In addition, and because the assessment of cumulative impacts includes an assessment of the revised Earls Court Development Proposals and the revised Seagrave Road Development Proposals, this ES Addendum Chapter also considers the local policy context of the LBHF with respect to electronic interference. National Planning Policy A10.31 The review of the national planning policy context (as presented in the June 2011 ES) remains valid and so applicable to the revised Planning Application for the Development Option (RBKC) Proposals. A10.32 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 A10.33 The Draft 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. A10.34 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. A10.35 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 A10.36 The review of the RBKC Core Strategy, 2010 (Ref. A10-5) (as presented in the June 2011 ES) remains valid and so applicable to the revised Planning Application for the Development Option (RBKC) Proposals. A10.37 Of relevance in the consideration of cumulative impacts, the LBHF has adopted their Core Strategy. The LBHF Core Strategy (Ref. A10-6) was adopted on the 19th October There are no policies of relevance to electronic interference in the LBHF Core Strategy. 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 Development Option (RBKC) Proposals. Review of the Baseline Conditions A10.38 The baseline as presented within the June 2011 ES remains valid and so applicable to the revised Development Option (RBKC) Proposals. The transmitters providing TV signals to the Development Option (RBKC) Site and surrounds remains as presented within the June 2011 ES. Review of the Impact of the Design Changes A10.39 The design changes and amendments to the form and content of the Planning Application are described in full in Chapter 4: The Design Changes. A10.40 Changes to the massing and height of the maximum scale parameters of the Development Option (RBKC) 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. A10.41 The key design changes made to the June 2011 Development Option (RBKC) Proposals can be summarised as follows: Changes to the nature of the Planning Application insofar that there will no longer be parameters or guidelines associated with plots WV01, WV02 and WV05. The detailed layout, scale, amount and use of development, access, 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 so that the revised Planning Application presents building based parameters for development plots WK04, WV03, WV04, and WV06. In addition, the scale and massing of these development plots (WV03, WV04, WV06 and WK04) have been tightened and so revised parameters are submitted for approval in relation to these plots. A10.42 With regard to the electronic interference assessment, the most significant changes to the massing are the changes to plots WV04 and WV06. Within these plots, the taller elements of the Development Option (RBKC) Proposals are located, which cause a longer interference shadow when compared to smaller plots. The massing of these plots has altered. There is an overall reduction in height and the buildings have been moved back from the Lost River Park by approximately 9 metres. A10.43 The proposed deconstruction / demolition and construction sequence of the Development Option (RBKC) Proposals remain as per the June 2011 ES. January 2012 Potential Impacts & Mitigation Measures A10.44 In light of the changes made to the massing of the Development Option (RBKC) 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 ). A10.45 The reduction of the heights and alterations to the massing of the plots, in addition to changes of plots to blocks/buildings, are insignificant with regards to the electronic interference assessment that was undertaken for the June 2011 ES. The existing buildings along Hammersmith Road block the interference shadow caused by the Development Option (RBKC) Proposals from extending any further, and when considering the revised Development Option (RBKC) Proposals, it is expected that the shadow will still extend up to this point. A10.46 Therefore, the predicted shadow would remain cast in a north-west direction from the Development Option (RBKC) Site and would extend up to 0.7 km. January 2012 Residual Impact Assessment A10.47 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 Development Option (RBKC) Proposals are considered to be of negligible significance. As discussed within the June 2011 ES, it appears 80% 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. A10-3

5 A10.48 The residual impacts to electronic interference remain as presented in the June 2011 ES (Chapter 10: Electronic Interference), and therefore remain as presented in Table A10-1. Review of the Cumulative Impact Assessment Combined Effects of Individual Impacts (Type 1) A10.49 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. A10.50 An exercise which tabulates the residual impacts of the June 2011 ES (Volume I) and this ES Addendum against relevant receptors, and so identifies the potential for combined cumulative effects, has been undertaken. 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 Development Option (RBKC) PLUS the other Cumulative Schemes A10.51 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; and Additional Cumulative Scheme: Westfield mixed use retail and residential led extension to the existing Westfield London shopping centre 2011/02940/OUT submitted for planning. A10.52 The June 2011 cumulative impact assessment considered those schemes that are located within the predicted shadow area of the Development option (RBKC) Proposals, as well as those located to the south-east that have the potential to block TV signals to the Development Option (RBKC) 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 Development Option (RBKC) Proposals. A10.53 The above is also applicable to Scenarios 2, 4 and 5, as the other Cumulative Schemes are considered within these cumulative assessment scenarios. SCENARIO 2: The Revised Development Option (RBKC) PLUS the Revised Seagrave Road Development Proposals PLUS the other Cumulative Schemes A10.54 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. A10.55 There have been minor reductions of up to 1 metre (m) on the heights of the buildings comprising the 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 these changes include a reduction in the building s footprint. A10.56 These changes are not deemed significant enough to alter the results of the cumulative impacts assessment for Scenario 2 as presented within the June 2011 ES; therefore the original assessment remains valid and applicable to the cumulative impact assessment of the revised Development Option (RBKC) Proposals. A10.57 As explained for Scenario 1, above, the additional other Cumulative Schemes do not fall within the shadow area cast by the Development Option (RBKC) Proposals, and therefore the Scenario 2 cumulative impact assessment within the June 2011 ES remains valid and applicable to the cumulative impact assessment of the revised Development Option (RBKC) Proposals. SCENARIO 3: Development Option (Site Wide) - The Revised Earls Court Development Proposals A10.58 Revised Planning Applications have been submitted in relation to the Earls Court Development Proposals. 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 within the predicted shadow area of the revised Earls Court Development Proposals. However, suitable mitigation measures, as identified within ES Volume III: Appendix I 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. A10.59 Following mitigation, impacts to TV reception from the revised Earls Court Development Proposals remain as presented within the June 2011 ES, of negligible significance. SCENARIO 4: The Revised Earls Court Development Proposals PLUS the other Cumulative Schemes A10.60 The other Cumulative Schemes considered within this cumulative impact assessment scenario are those schemes which are located within the predicted shadow area of the Earls Court Development Proposals, as well as those to the south-east that might block the TV signals to the Earls Court Site. The additional Fulham Wharf and Westfield cumulative schemes do not fall within these areas, and are not considered further within this cumulative impact assessment. As these two schemes do not affect the cumulative impact assessment undertaken in the June 2011 ES, and as Scenario 3, above, remains valid and applicable to this ES Addendum, the Scenario 4 cumulative impact assessment within the June 2011 ES also remains valid for this ES Addendum Chapter. SCENARIO 5: The Revised Earls Court Development Proposals PLUS the Revised Seagrave Road Development Proposals PLUS the other Cumulative Schemes A10.61 As discussed above, Scenarios 4 and 2 of the cumulative impact assessment as presented within the June 2011 ES remain valid and applicable to this ES Addendum. Therefore, Scenario 5 (the combination of Scenario s 4 and 2) also remains valid for this ES Addendum. Conclusions A10.62 The design changes made to the outline elements of the Planning Application 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). A10.63 The June 2011 assessment of electronic interference impacts therefore remains applicable to the revised Development Option (RBKC) 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 Royal Borough of Kensington and Chelsea, 2010; Core Strategy. Ref. A10-6 London Borough of Hammersmith & Fulham, 2011; Core Strategy. A10-4

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