Object to the erection of an 18.5m mobile mast and bulky cabinets in the Old Chiswick Conservation Area

System Reference: PA/2021/4816 Planning Reference: 00306/OPP58/COM1

Objection to Planning Application – December 2021

The main issue is the effect of the proposal on the character and appearance of the surrounding area having particular regard to the setting of the Chiswick House Conservation Area.
The second issue is the proximity to schools.
The third issue is the inadequate consultation with schools and local residents.

Specific Objections

1. The proposed development will have a major negative effect on the character and appearance of the surrounding area having particular regard to the setting being entirely within the historically significant Old Chiswick Conservation Area and the extension of that area created in 2019

2. The development would harm the character and appearance of the area and would be contrary to Policy EC4 of the London Borough of Hounslow Local Plan, which, amongst other things, requires the siting and appearance of telecommunications installations and any associated structures to minimise impacts on the visual amenity, context and character of the surrounding area and demonstrate that adverse impacts on conservation areas are avoided.

3. In addition, the proposed development would harm not only the setting of the Old Chiswick Conservation Area but also the adjacent the Chiswick House Conservation Area and therefore conflict with the conservation requirements of the National Planning Policy Framework

4. The site lies on the pavement adjacent to the wall of the historic “Chiswick Old Cemetery” and war memorial immediately adjacent to the five-limb roundabout that provides highway access to Corney Road, Edensor Road, Grantham Road, Pumping Station Road and Thames Crescent. The area surrounding the site is predominantly residential in character within the Old Chiswick Conservation Area. Owing to its position adjacent to the roundabout the site is prominent, particularly in views from Edensor Road and Thames Crescent

5. The proposed pole would be 18 meters high with dramatic obvious “antennae casings” at the top and a large “wrap around” casing at its base. The pole would be close to two mature trees. The mast would be considerably higher than the adjacent trees and the street lighting columns in the locality. This would make the mast overtly incongruous and visually overwhelming within the context of the historically important Old Chiswick Conservation Area within which it is situated.

6. The National Planning Policy Framework (the Framework) recommends in Paragraph 43 that where new sites are required, equipment should be sympathetically designed and camouflaged where appropriate. The proposed development is not sympathetically designed, nor has any part of it been camouflaged in a way that is sympathetic to the site, with particular regard to the site being wholly within the Old Chiswick Conservation Area.

7. Also, paragraph 45 of The National Planning Policy Framework requires evidence that the possibility of erecting antennas on an existing building, mast or other structure has been explored. No evidence has been supplied within the application to show any serious exploration of that possibility.

8. There are currently two cabinets on the section of pavement in the area of the proposed development. Whilst cabinets are an accepted part of the street furniture of the area, they are few and far between. A cluster of six, being the current cabinets plus three plus the mast base, would constitute excessive clutter and would be out of character with the general street scene of the Old Chiswick Conservation Area.

9. The proposed pole would be considerably higher than any other item of street furniture in the locality. The pole would appear stark and prominent in this junction position. It would clearly be visible in views from all other roads that adjoin the roundabout including views from and towards the adjacent Old Chiswick Conservation Area. Consequently, it would be quite visible to road users and pedestrians. This would be particularly stark in the winter months.

10. Owing to its position, height and diameter, the pole would appear as an incongruous addition to the street scene that would not be read within the context of existing street furniture within the Old Chiswick Conservation Area. The design means that it would have a ‘top heavy’ appearance that often characterises telecommunications masts, its height and width would set it apart from the nearby lighting columns. It would appear as fairly bulky and intrusive, particularly when viewed against the skyline. Against this background, the proposed mast would, particularly in views from Edensor Road and Grantham Road, and Pumping Station Road appear as an intrusive feature that would harmfully detract from the character and appearance of the area.

11. This proposal would have a detrimental effect on the setting of the Old Chiswick Conservation Area. In the context of the National Planning Policy Framework great weight should be given to the conservation of a designated heritage asset. Any harm should require clear and convincing justification. In this case the public benefits of sighting the mast opposite 58 Corney Road would not outweigh the harm to the designated heritage asset.

12. The public benefit in the range of the transmitter would be marginal given the current excellent standard of access to mobile and optical fibre provision in the area. The governments requirement of providing high speed internet access to residents is already well provided for. Specifically
All Residents, All Businesses have access to very high speed fibre broadband. Virgin are currently offering speeds of 362 Mbps in the area around 58 Corney Reach.
“Point Topic for its part claims that as of September 2020, the average 5G download speed across the UK's networks is 148 Mbps, with the median being 128Mbps”
https://5g.co.uk/guides/how-fast-is-5g/

13. The “through the air signal” to mobile phones signal strength is already more than adequate for full access to voice and 4G services. The strength of the signal was measured at the mast site on 26th December 2021 remained at stable average of nine micro watts per meter squared and 0.11Volts per meter. Easily showing full five bar signal and 4G connection on a phone.

14. It should be recognized that the need to provide additional telecommunications coverage within the locality and the Government’s support for telecommunication infrastructure needs to be carefully balanced against the visual impact of the proposal. In this case the operational and locational needs of the operators do not outweigh the significant harm that the siting of the pole in this particular location would cause.

15. The planning application fails to take into consideration the schooling of children in the educational facility that is the Chiswick Pier Trust. This lies only 150m from the mast site. Users are, for example, the “Thames Explorer Trust”. For planning purposes this facility should be considered a “School”

16. In the application site options D3 and D4 have been discounted because they are in the proximity of schools. This application should be discounted for the same reason, namely its proximity to the schools noted in the application (Cavendish Primary School, Dukes Meadow Community Centre, Poland Chiswick School) as well as Chiswick Pier Trust.

17. The consultation process with schools and the residents has been derisory and therefore the application should be dismissed and should only be re-considered once a proper consultation process has been followed.

18. From the application it can be seen that the total effort made by the applicant to consult with the schools named was a single email to each school just as they are breaking up for Christmas. This does not constitute a proper consultation. Sighting a “No Response” – “To the best of our knowledge no response was received” does not constitute a satisfactory consultation, nor can it be accepted as representing the views of the schools concerned or the parents and governors of the schools involved.

19. Virtually no consultation has been undergone within the ward. I have received no communication, electronic or otherwise. I have not seen any boards advertising the application.

System Reference: PA/2021/4816 Planning Reference: 00306/OPP58/COM1


I would like to take this opportunity of objecting to the planning application. I am aware that planers may have their hands tied in so much as they have been directed by government that they may not take into account the long-term negative effects to the health of the populations living near masts, who are therefore bathed in non ionising electromagentic radiation emitted from the masts. However, I take it as my public duty to present some basic information to them so that it can not be said in future that planners were unaware of the long-term effects on the public of their decisions.

For Reference:

Available on the following link is a copy of the “2020-Non-Ionising-Radiation-Consensus-Statement” prepared and signed up to by many people in the medical, scientific and public community from many countries.

https://phiremedical.org/2020-nir-consensus-statement-read/

My own statements:

Statement 1 – Non ionising Electromagnetic Radiation emanating from phone masts does have biological effect.

Statement 2 – The signs of the biological effect are many and varied

Statement 3 – The effects on humans vary between positive and useful to inconsequential to devastating to potentially lethal (cancer)

Statement 4 – Broadcasts from Phone Masts are forced upon people, they travel through buildings, so there is no escape from them. So unlike other dangerous substances the public can not avoid them. Here are two simple examples that show how unreasonable this is:
Smoking causes cancer – but smoke and smokers can be avoided.
Talcum powder (also on the WHO list of “ Category 2: probable causes of cancer“ could cause ovarian cancer – but only when applied to female genitalia over many years. Applying talc is a voluntary act so it could be avoided easily. Recognition of its dangers has lead to changes in formulation to mitigate the potential negative effects.

Statement 5 – The “Precautionary Principle” should be applied, and the building of this mast should be stopped until it has been proven beyond any reasonable doubt that the broadcasts from it will actually be “SAFE”

Useful References and Links to Peer Reviewed Studies

Thousands of good quality, peer reviewed, scientific papers going back many many years show the negative effects of Electromagnetic Radiation (Broadcast Radio Waves).

Dr Erica Mallery Blythe (UK)

This is a link to a very personal story from an English emergency and trauma doctor - Dr Erica Mallery-Blythe - giving some of her own experience of becoming sensitive to electro magnetic radiation (broadcasts from phone masts, mobiles and other wifi devices)

https://www.youtube.com/watch?v=gisvfVeRpr0

Phire Medical (.org) is an excelent resource run by many extremely well qualified and informed Medical Doctors and Scientists including Dr Erica-Mallery Blythe.  It provides information backed up by very many peer reveiwed scientific studies.

World Health Organisation, Electromagnetic Radiation as a cause of Cancer

This is a statement from the Phire Medical site explaining the World Health Organisation categorising of Electromagnetic Radiation as a “Probable Cause of Cancer” along with the research that may soon lead it to re-classify it to being a “Group 1 Known Cause of Cancer” – links to the pertinent research papers are provided on the Phire Medical site.

https://phiremedical.org/world-health-organisation-iarc-and-cancer/

“Cancer risk noted from human epidemiological research corroborated by largest new animal studies:

In 2011, the World Health Organisation (WHO) via the International Agency for Research on Cancer (IARC) classified RFR as Group 2B ‘Possibly carcinogenic to humans’.

Glioblastoma Multiforme (GBM), an associated rapidly progressive fatal brain cancer and acoustic neuroma, satisfy the Hill criteria for causality from RFR exposure based on human epidemiological studies.

Human epidemiological evidence continued to accumulate

In 2018 the largest animal study so far, published, from the highly credible US National Toxicology Program (NTP), declared the evidence for carcinogenesis ‘clear’, putting pressure on IARC to reassess urgently and elevate RFR to Group 1 ‘Known Human Carcinogen’.

Furthermore, the large-scale Ramazzini Institute study which used far field radiation designed to emulate base station type radiation was published shortly afterwards and independently confirmed promotion of carcinogenesis in cells of glial derivation.

Legal authorities continue to validate the causal link between RFR and tumours. The incidence of these kinds of brain tumours are rising in the UK, Netherlands, Australia and USA.” 

Reference studies to back up eash of the above statements are available through the PhireMedical link above.