The statement is full of dangerous mistakes and omissions putting the health and safety of our community and especially children at risk.
Comments and objections can be uploaded on the City of London Planning website here
THE DEADLINE FOR COMMENTS IS 1st OCTOBER 2017
You can upload comments online or write to the case officer Catherine Linford. This is a delegated decision which means the decision is made by the Senior Planning Officer, Annie Hampson. These are their email addresses.
Catherine.Linford@cityoflondon.gov.uk
Annie.Hampson@cityoflondon.gov.uk
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| The correct positioning of Prior Weston and Richard Cloudesley School, east of Bernard Morgan House |
Alderman David Graves has told me that the Demolition Method Statement (DMS) would have already been discussed with Officers. If that is the case then this is even more concerning, do they know that Prior Weston School is east of the site and not west? And are they not concerned that there is a school for children with disabilities opposite the site?
This error in the geography of the site is not a minor problem, if Prior Weston School and Richard Cloudelesley School were west of Bernard Morgan House it would mean the school would be much further away from the site and partly protected by the Jewin Church. As can be seen in this simple mock up.
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| If Prior Weston School was west of the Bernard Morgan House building site it would be much further away and protected by the Jewin Church |
It is unacceptable that Richard Cloudesley School is not mentioned once, especially as children are dropped off and picked up by mini buses directly opposite the site, a few metres away. Lorries parked here will be a huge problem for children at the school and this needs to be addressed in the report. Transport is coming and going from Richard Cloudesley throughout the day as children from the senior school are transferred for time in the therapy pool. These children have complex conditions and could be badly effected by noise and dust.
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| Mini bus picking up children from Richard Cloudesley School opposite Bernard Morgan House |
Whoever wrote this statement might have looked at Google Maps and seen Prior Weston School but City Planning Officers must know that Richard Cloudesley School is metres away from the demolition site. It is not hidden and protected by the Jewin Church as implied by the incorrect geography.
Special care has to be taken regarding anything that will effect the children in this school, they can not be ignored in this way.
For the safety of all the residents and children who live here and use the local schools it is vital that Taylor Wimpey are asked to withdraw this application and resubmit one with correct information.
There are too many mistakes to make if fit for purpose and it puts the health and mental well-being of this community at risk. Especially the 500 children in the Golden Lane Campus.
These are the obvious mistakes in the DMS, some less serious than others, but all sloppy and unacceptable.
page 3
'The building was constructed in the 1970’s….'
Bernard Morgan House was completed by 1961 and housing police officers from 1961 until 2015.
page 5
'For the demolition to the main block we will provide a full height protection scaffold as per the attached Scaffolding Plan areas 1 to 5 and have full Monarflex to all scaffolding.’
There is some confusion about this material, whether it is Monarflex or something else, or a mixture of materials, the TWCL logo is made from a different type of plastic and the logo covers the whole site. It is important to find out if the material used is a fire risk or toxic when burning.
page 5
'If at anytime we have a lorry in site and another lorry approaching we will ensure the vehicle is parked up in a bay outside site with the engine turned off.'
Where will these lorries be parked off site? Not in Fann Street or Golden Lane or outside the school? As they don't mention Richard Cloudesley School there is a risk that these lorries will park in the bays outside the school entrance which are used all day for the school buses.
It is important that this area is specified in the document and that lorries can never use these parking bays.
page 7
'Proximity of sensitive buildings: To the east of the site is Golden Lane with Commercial & office premises on the opposite side of the road. '
There aren't any commercial buildings on the east of Golden Lane, opposite the site. The only commercial premises is south of the site, the UBS building.
'Prior Western Primary School is located to the west of the site. Santander Bike hire station is located to the west of the site. The issues where the demolition works are immediately adjacent to other properties are dealt with above. Prior Weston is east and so is the Santander Bike hire station. Richard Clousdesley School and no residential properties are mentioned ‘above' in the DMS.'
I have shown clearly in the illustration above how serious this mistake is.
page 7
‘Until such time GLD have agreed that we will have additional restrictions on our deliveries/collections to/from site at certain times to ensure that our deliveries have no impact on the children being dropped off/collected from Hatching Dragon’s Nursery.'
Shouldn’t these restrictions also apply to Richard Cloudesley School?
page 15
'All vehicles arriving to Bernard Morgan House have White Noise Alarms fitted. All Construction traffic will either approach the site coming along Goswell Road, onto Aldergate Street, Left onto Beech Street, left onto Golden Lane, Left into Brackley Street then reverse in to site with a qualified banksman or alternatively Approach the site coming along Old Street, Right in to Golden Lane, right in to Brackley Street, reverse in to Viscount Street qualified banksman'.
In the meeting last month with TW and GLD said that the lorries wouldn’t be using Beech Street. This was surprising as it could be worse if the lorries were coming all the way down Golden Lane and over the zebra crossing. In the DMS they say they will be using both routes.
They don’t say that the vehicles will be leaving via Fann Street. In the diagram below this is what is indicated.
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| Traffic flow diagram from the Demolition Method Statement |
page 15
‘No vehicle movements will take place between the hours 8am-9.20am and 3pm- 3.30pm due to the close proximity of schools and nursery.’
Prior Weston finishes at 3.30 so vehicle movements should not be allowed until at least after 4.30 because of the use of the park after school etc. Extraordinary that the school times were not checked with the school. This is just another example of the dangerously sloppy lack of consideration towards the people who live here.
page 23
'The central section of the building will be demolished to ground level first, with the demolition machine located west of the building. The demolition machine can then stand between the remaining north and south blocks debris to demolish the remaining sections. The north end will be demolished first working from the middle area already demolished. The south end will then be demolished again working from the middle southwards. The protection scaffold will be taken down sequentially as the demolition progresses and no more than 2 lifts at a time shall be exposed.’
The diagrams below seem to contradict this description.
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| Diagram shows how the block will be demolished, starting from the north end |
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| In this diagram the Jewin Church seems to have been omitted |
page 26
'Proximity of sensitive buildings: The works are to be carried out next to a church/day nursery along with residential and commercial areas.
'1. All demolition plant is to be well maintained and fully fitted with silencers.
2. Plant is not to be left running unnecessarily.
3. Use munchers / shears wherever possible for demolition works, and only use _hydraulic breakers as a last resort. Munchers / shears are a “quiet” method of _demolition and generate a greatly reduced noise level for both the plant operators and _other people in the vicinity.
4. Working hours are restricted as follows - Monday to Friday 8.00am to 6.00pm/ _Saturday 9.00am to 14.00pm 5. Quite Hours – 10.00am-12.00pm Mon-Fri – 14.00pm-16.00pm Mon-Fri 6.
'GLD will monitor noise levels around the site to ensure excessive levels are not being _generated. 7. Acoustic Barriers to be placed on the edge of Hatching Dragons Nursery.’
Bowater, Breton, Cobalt House or Richard Cloudesley School mentioned. Acoustic barriers be placed around the whole site. There are many vulnerable people living adjacent to the site as well as a school with over 500 children including children with disabilities.
page 27
'Noise levels generated by machine mounted hydraulic excavators are in the range of 85 – 95dB at 10 metres distance. Therefore plant operators should keep the cab doors closed and wear ear defenders to BS EN 352 with an SNR rating of at least 20dBa. Banksmen supervising machine breaking should stay at least 10 metres from the breaker & wear ear defenders to BS EN 352 with an SNR rating of at least 20dBa if within 15 metres of the breaker.’
Bowater residents, including many children live only 19 metres away. Sounds will echo off the surrounding buildings and can become amplified. The schools are also very close. Noise needs to be measured from surrounding buildings to check that it falls within acceptable levels?
There’s not much difference between 15 metres and 19 metres. This needs to be investigated. It sounds like this could be seriously damaging to our health.
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| Permanent sound monitoring points |
Later in a separate document temporary measuring points are mentioned for these sites, but measurements need to be done in our flats. The sound also needs to be monitored in the school playground and the classrooms which face the site and in the Richard Cloudesley classrooms.
page 59
DEMOLITION NOISE PREDICTION REPORT 2.0 Site Layout
‘The development site is boarded by Golden Lane, Fann Street, Viscount Street and Brackley Street. To the north, south and west are residential properties that overlook the site. Cripplegate Free Library is to the south east. A church that includes a crèche is in the north west corner of the block of the site, and to the east is a Prior Weston Primary School.’
At least the person who wrote the Demolition Noise Prediction Report understands where east and west are and at last the residential properties are mentioned but still no mention of Richard Cloudesley School.
page 60
‘Quiet hours’ are put in place to give nearby commercial occupiers at least 4 hours without noisy working from street and construction sites during the working day. Noise levels within businesses during noisy periods must enable workers to carry out conversations, both face-to-face and on the telephone, and allow normal business to be conducted. It is considered that an internal noise level of 65 dBA or above is likely to cause annoyance and interference (dependent on the noise characteristics).'
Are there no regulations which protect school children, particularly nursery and primary school age children whose ears are much more sensitive? Again they are not mentioned here. Or are there separate regulations for building sites in residential areas which should be used here? The DMS treats this area like a commercial district when it is clearly residential.
5.0 Monitoring
'It is understood monitoring positions for both noise and vibration, as detailed in Table 8065/T2 below and on the attached Site Plan 8065/SP1, have been agreed.’
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| Points where both noise and vibrations will be monitored |
Who has agreed this?
'Permanent Position 1 On-site permanent noise and vibration monitoring located at the centre of the east façade of the neighbouring church and crèche.
Permanent Position 2 On-site permanent noise monitoring located at the centre of the south façade of the neighbouring church and crèche.
Handheld Position 1 Off-site handheld noise monitoring located at the residential building on the corner of Fann Street and Golden Lane.
Handheld Position 2 Off-site handheld noise monitoring located at the main entrance of Prior Weston Primary School on Golden Lane.'
There needs be permanent monitoring in Bowater House, Breton House, Cobalt House and the Schools. There’s no mention of Richard Cloudelsey School again. The entrance of RCS should be monitored but also the playground and classrooms at that end of the building, in both RCS and PW.
page 61
‘Attended spot vibration measurements have not been proposed by CoL but if they were to be included in the Scheme of Works, due to the complexity of such measurements and the equipment required, these would be undertaken by a suitably qualified engineer.’
Because of the lack of consideration shown toward the community during the last 18 month by TW we can not trust that their contractors will be allowed to carry out these tests. We need the City to protect it’s residents from the harm that noise and vibrations will cause.
page 61 cont.
'We would strongly recommend that good communication with the local residents, church and crèche, school and library is upheld, with prior warning of any likely significant noise disturbance. This is of particular importance where breaking works are likely to be in close proximity to guest rooms and/or where structure borne noise is likely to be significant.’
From our experiences over the last 18 months it seems highly unlikely that TW will comply with that recommendation.
'Discussion
'8.1 Predicted Noise Levels Hand Held Positions The predictions at each of the four hand held positions are all above 75 dBA which is a significant effect and which may trigger sound insulation for those effected by 10 or more consecutive days in a 15 day period or a total of 40 days in a 6 month period. Code of Practice for Deconstruction and Construction Sites, Seventh Edition May 2013 [CD/D12], states the following: Noise levels within businesses during ‘noisy’ periods must enable workers to carry out conversations, both face-to-face and on the telephone, and allow normal business to be conducted. It is considered that an internal noise level of 65 dBA or above is likely to cause annoyance and interference (dependent on the noise characteristics). Such noise should be restricted to hours outside the normal working day of 09.00 17.00. Timings of works with noise levels exceeding 65dBA should be discussed and agreed with Environmental Health Officers prior to commencing.'
This all relates to office workers, what about residents and school children? There are many elderly residents and parents with young children at home during the day who live only a few metres from the site.
'With reference to worst case glazing performance (as detailed in Section 6.2) in PPG24 we would expect the difference between noise levels internally from external site sources to be in the region of 28 dBA. It is expected, with windows closed, noise levels would be significantly below 65 dBA internally at the nearest receptors. For example, worst-case predicted noise levels at the handheld positions during noisy hours is 86 dBA and worst case single glazing performance is 28 dBA; therefore 86-28= 58 dBA.’
None of the windows in Bowater House are double glazed. We have to have the levels checked inside our flats when demolition starts.
'Furthermore, we would expect that triggers for sound insulation over consecutive days would not be exceeded as predicted noise levels are based on worst case concurrent activities and time on periods as well as demolition not taking place at the weekends.’
Do we presume from this statement that work will not be allowed to go ahead at the weekends at all? Taylor Wimpey have been telling us that they will be working on Saturdays and that the City have agreed this, even though this is a residential area.
There is no rush to finish this block as it doesn’t include any of the ‘much needed homes’ that Taylor Wimpey said they would be building. Anyone who can afford there flats can easily buy one of the hundreds of luxury properties on the market at the moment.
And lastly, condition number 3 in the Planning Permission relates to the Bernard Morgan House decorative tiles. It says that;
‘Prior to demolition, a method statement for the salvage and details of the reuse of the decorative tiles on the north elevation and the south elevation of the existing building shall be submitted to and approved by the Local Planning Authority.’
There is no mention of a method statement for the salvage and detailed use of these much loved tiles. It seems unlikely that White Ink, the architects who have replaced AHMM will find a way of using these tiles that equals their current setting.
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| The Bernard Morgan House tiles, once photographed by hundreds of passers by |
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