HS/TL/23/00438
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Proposed 5G telecommunications installation: Proposed 15m H3G street pole and additional equipment cabinets.
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Pavement fronting Warrior Square Gardens, Warrior Square, St Leonards-on-sea
- Total Consulted: 0
- Comments Received: 138
- Objections: 134
- Supporting: 4
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Mr Bernard McGinley
Comment submitted date: Wed 05 Jul 2023
HS/TL/23/00438
I object to this street mast and boxes proposed for the front of Warrior Square as contrary to Policy EN1 of the Hastings Local Plan, Policies DM1, DM2 and HN1 of the Development Management Plan (2015), and paragraphs 115-17 of the National Planning Policy Framework.
The representation of what is proposed is insultingly inaccurate - false - and no effort has been made to explain why this 5G equipment intended for
GRAND PARADE
BOHEMIA
ST LEONARDS
is somehow more acceptable than HS/TL/22/00528 which was refused last year, in a slightly less prominent part of the Warrior Square apron.
Putting a 15-metre (nearly 50-foot) mast beside the statue of Queen Victoria is not acceptable. Don't you agree? Why is that not shown?
Comment submitted date: Fri 21 Jul 2023
Please see documents tab.
Ms Susan Jordan
Comment submitted date: Thu 20 Jul 2023
Whist common sense dictates that this installation should not be located here, due to the aesthetic impact and community health concerns, it also contravenes multiple planning rules. Choose somewhere that is not Grade II listed, and is not such a well used amenity for residents and tourists alike
Ms Rachel Brain
Comment submitted date: Sat 15 Jul 2023
I strongly object to the proposal for this mast. It is in the heart of a conservation area and more insensitively placed than the last proposal. Close to the statue of Queen Victoria and an intrusion for all all who live in the square it would fundamentally contravene conservation guidelines. There is abandoned ground at falsies which has no use and would provide suitable coverage.
Robert Waldron
Comment submitted date: Tue 11 Jul 2023
Ref HS/TL/23/00438
Planning application.
I only received the letter regarding this proposal today (11th July).
My only concerns are.
1) That the signal could affect FM broadcast reception
2) Interfere with other frequencies due to harmonics given the geometry of the Square.
Otherwise I am fine with a 5G network mast near the Victoria Statue.
As I am at the top of the Square, and given the inverse square rule of prorogation, I will not be affected by the mast.
Sincerely
Robert Waldron
Comment submitted date: Fri 14 Jul 2023
NB Hasting Council Planning Department.
Warrior Square is experiencing a massive loss of mobile phone coverage right now.
I suspect the 5 G mast just knocked out all other bandwidths in the area.
We no longer have mobile phones in Warrior Square.
II have spoken with my mobile provider O2 in the last 2 hours and was informed there is work being carried out today.
And that it should be completed by the weekend! This however is very disruptive and I am sure that the mobile signal provider did not expect the signal to be useless?
Given these facts, I thought I should bring it to your knowledge that if the mobile network does not come back on line, elderly people unable to call 999 would eventually come back to the local council rather than the contractor.
My guess is that the Local Authority in charge would be liable for any losses attributable to said role out!
Sincerely
R Waldron
Michael J Ryan
Comment submitted date: Fri 14 Jul 2023
Dear Sir or Madam
As a resident I object strongly to the placement of a 5G mast set up in or close to Warrior Square. My objection is based on appearance and studies of the health effects eg Khurana et al 2010.
With many thanks
Yours sincerely
Michael J Ryan
B Lowe
Comment submitted date: Thu 13 Jul 2023
CONSTRAINTS:
Local Plan Planning Strategy 2011-2028 Policy EN1 - Built and Historic Environment Adopted 19/2/2014
Local Plan Planning Strategy 2011-2028 Policy FA4 - Strategy for Central St Leonards Adopted 19/2/2014
Local Plan Planning Strategy 2011-2028 Policy FA6 - Strategic Policy for The Seafront Adopted 19/2/2014
Potentially within an Area of Surface Water Flooding (1 in 100 yearly chance) Environment Agency
GREEN District Licensing Scheme - Great Crested Newts Green Impact Risk Zone naturespaceuk.com/
Conservation Area Appraisal Consultation Draft Hastings www.hastings.gov.uk/planning/policy/consultations/future_developments/hastings-ccaa/ St Leonards - www.hastings.gov.uk/planning/policy/consultations/future_developments/
Local Plan Development Management Plan Policy CQ1 - Cultural Quarters Adopted 23/9/2015
Local Plan Development Management Plan Policy HN1 - Development Affecting the Significance and Setting of Designated Heritage Assets (including Conservation Areas) Adopted 23/9/2015
SITING AND APPEARANCE:
WITHIN CONSERVATION AREA - This is a conservation area, Warrior Square is identified as an Historic Park in the adopted Local Plan, the proposal is just metres away from the Grade II listed Queen Victoria Memorial Statue, and the Grade II listed St Mary Magdalene's Church in St Margaret's Road is nearby. Strict planning guidelines apply for all these categories and this proposal contravenes these guidelines:
Hastings Planning Strategy EN1 - Built and Historic Environment - states that "Particular care will be given to protecting the significance and setting of....heritage assets", including "listed buildings" and "conservation areas".
Policy EN1 also states that "Importance will be placed on new development making a positive contribution to the quality, character, local distinctiveness and sense of place of historic buildings and areas." and that "There is a presumption in favour of the conservation of heritage assets and their settings. As heritage assets are irreplaceable, any harm or loss will require clear and convincing justification." No such justification has been provided in this application.
Policy HN1 of the Hastings Development Management Plan - Development Affecting the Significance and Setting of Designated Heritage Assets (including Conservation Areas) - states that "Permission will be given for those schemes that show a full understanding of the significance of the asset and convincingly demonstrate how their chosen design sustains and enhances the significance of any heritage assets affected (including conservation areas)". This proposal completely fails to do this, on the contrary it introduces an out of character industrialising feature to the area.
Policy HN1 also states: "The topography of Hastings means that the Council will give consideration to the impact of development on the setting of heritage assets, including the impact upon more distant views and from across the other sides of the valleys" and that "Consideration will also be given to the impact of new development on the setting of the Hastings and St. Leonards seafront, almost all of which is covered by conservation area designation. This area currently enjoys relatively unimpeded long views, which are a key element of area character." This proposal, situated as it would be, in both Warrior Square and St Leonards sea front, contravenes these guidelines. It would also distract from the views of the Grade II listed Queen Victoria Memorial Statue, Hastings Pier, and St Mary Magdalene's Church, impacting negatively on the appreciation of them.
Extracts from the council's refusal for the 2022 Warrior Square 5G mast proposal, which also apply to this proposal:
"The appearance of this mast would be incongruous in this historical setting and would not harmonise with the period buildings and architecture, nor with the historic gardens and sea front."
"This would be compounded by being a standalone feature in the street scene, without the benefit of trees to soften its impact."
"In the context of the contribution the open space of the gardens and surrounding streets make to the conservation area, the appearance of the mast and ancillary equipment would fail to preserve and enhance the character and appearance of the conservation area. As such, the appearance of the proposed telecoms infrastructure, in the context of its historic setting, would be inappropriate."
This proposal is not compliant with Policy DM1 of the Hastings Development Management Plan and Paragraph's 115, 195, 199, 200, 202 and 206 of the National Planning Policy Framework (NPPF).
ICNIRP:
UKGOV requires an ICNIRP Declaration to 'self-certify' their installations:
Principles and commitments? - "18. Compliance with guidance laid out in the International Commission on Non-Ionizing Radiation Protection (ICNIRP) public exposure levels guidance: as required by spectrum licences, comply with international guidelines for limiting exposure to electromagnetic fields (EMF) - including, as set out in the NPPF, providing a statement that self-certifies that ICNIRP guidelines will be met with all applications (see Annex C)." www.gov.uk/government/publications/code-of-practice-for-wireless-network-development-in-england/code-of-practice-for-wireless-network-development-in-england#annex-b--supplementary-information-template-and-annex-c-icnirp-declaration-and-rooftop-deployment-constraints-and-solutions
INVALID ICNIRP DECLARATION:
1) The "Code of Practice for wireless network development in England" ('Code') provides the required ICNIRP Declaration in Annex C which states, immediately above the section to be signed:
"SHALL BE OPERATED TO BE IN FULL COMPLIANCE with the requirements of the radio frequency (RF) public exposure limit of the International Commission on Non-Ionizing Radiation Protection (ICNIRP)..."
2) However, The ICNIRP Declaration provided by the applicant states:
"IS DESIGNED TO BE IN FULL COMPLIANCE with the requirements of the radio frequency public exposure guidelines of the International Commission on Non-Ionizing Radiation Protection..."
The statement 'IS DESIGNED TO BE IN FULL COMPLIANCE' does NOT conform to the statement required by the 'Code' or the NPPF (also see 3) below) and is therefore INVALID.
3) ADDITIONALLY, see 'Code' Annex D para 53:
"...mobile operators should certify that the installation WILL OPERATE in full compliance with the requirements of the radio frequency (RF) public exposure guidelines of the International Commission on Non-Ionizing Radiation Protection (ICNIRP)"
THE APPLICANT'S ICNIRP DECLARATION DOES NOT CONFORM TO THE NPPF/ 'CODE' REQUIREMENTS AND THEREFORE, IT IS INVALID AND THIS APPLICATION SHOULD BE REFUSED!
Additionally, The Erroneous ICNIRP Declaration Certificate:
The ICNIRP "safety" certificate is based on guidelines which categorically DO NOT apply to, or protect anyone with metal in their bodies. Here is the relevant statement from ICNIRP regarding its EMF safety guidelines: "However, some exposure scenarios are defined as outside the scope of these guidelines. Medical procedures may utilize EMFs, and metallic implants may alter or perturb EMFs in the body, which in turn can affect the body both directly (via direct interaction between field and tissue) and indirectly (via an intermediate conducting object)".
Please also note ICNIRP's disclaimer on their website. They even say they're not accountable for their guidelines: "ICNIRP e.V. undertakes all reasonable measures to ensure the reliability of information presented on the website, but does not guarantee the correctness, reliability, or completeness of the information and views published. The content of our website is provided to you for information only. We do not assume any responsibility for any damage, including direct or indirect loss suffered by users or third parties in connection with the use of our website and/or the information it contains, including for the use or the interpretation of any technical data, recommendations, or specifications available on our website."
The fact that the ICNIRP certificate does not apply to a large proportion of residents with any form of metal in their bodies is an acute safety issue which needs to be taken seriously and addressed. Doing so would NOT result in setting health safeguards different from ICNIRP (as per NPPF) but is in fact applying ICNIRP exactly as stated from a safety perspective.
There are many scenarios in which metal is used in the human body for medical reasons:
Surgical - metal pins, plates, rods, discs, screws e.g. scoliosis surgery and joint replacement of knees and hips. Urinary, gynaecological and intestinal repairs - e.g. mesh repairs and copper contraceptive coils. Cardiovascular - implantable heart loop recorders, stents and pacemakers. Implants to treat and monitor health conditions, deliver drugs or to restore bodily functions e.g. diabetes related products. Magnetic cerebral spinal fluid shunts. Cochlear implants for hearing loss. Dental work - braces, implants, metal crowns, pins, denture arches, mercury amalgam fillings. What about body piercings?
HEALTH AND ENVIRONMENT:
Published research shows that health effects from living near masts can include higher levels of cancer, cardiovascular problems, diabetes, depression, anxiety, headaches, sleep problems, memory problems and blurred vision.
An independent review of ten epidemiological studies (Khurana et al, 2010) found that eight of the studies showed increased levels of cancer and neurological symptoms amongst those living within 500m of a mast.
A recent review by Balmori et al to update the knowledge on the effects of base stations on humans living around the antennas has found that 73.6% of the studies showed effects: 73.9% for radiofrequency sickness, 76.9% for cancer, and 75.0% for changes in biochemical parameters. https://www.sciencedirect.com/science/article/abs/pii/S0013935122011781
Ms Myriam Lengline
Comment submitted date: Thu 13 Jul 2023
An application to install a 5G mast in front of Warrior Square is totally out of order.
Warrior Square is on attractive historical Victorian square and that 5G mast (and boxes to go with it) will ruin it, as well as the fantastic view of the sea/seafront and the beautiful surrounding Victorian buildings.
That mast will only be a few meters away from Queen Victoria Grade II-listed statue, which is completely incongruous. Vic will not be amused.
Warrior Square is in Central St.Leonards, along the seafront, a highly touristic area, with many visitors and a highly-dense residential area with many flats.
This proposal is actually disrespectful for St.Leonards, its resident and visitors. An ugly modern pole and boxes have nothing to do in such a historical location of architectural interest, which I believe is a conservation area.
Mr Pawel Komor
Comment submitted date: Wed 12 Jul 2023
I hereby formally want to register my objection to this proposal.
This is a beautiful and historic square which I do not wish to be defaced by modern technology.
Why here, surely there are several alternative placed to consider placing this, if it is desperately needed.
Mr Simon Smith
Comment submitted date: Wed 12 Jul 2023
i as many others object to the continued assault on humanity of unsightly aswell as potential dangers to health & well bieng. tired of bieng railroaded by central & local authority over lack of care awell as questionable morals on many subjects, have little faith in the decision making.
Andrew Rees
Comment submitted date: Wed 12 Jul 2023
I am the owner of a flat in %comments redacted%. I strongly object to this planning application. It is a completely inappropriate location to site an 18m monopole in Warrior Square, which is a conversation area with Victorian architecture and a renowned statue of Queen Victoria. It is widely used by locals and visited by tourists. The presence of the mast would be unsightly, out of keeping and detremental to the use and enjoyment of the Square.
Please reject this application.
Best regards
Andrew Rees
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