Wednesday, 27 September 2017

Sorry to Hear That

Aaagh not another dodgy report?
The RCS noise report that accompanies the planning application looks pretty technical, so we asked a helpful acoustic expert (HAE) to cast an eye over it:

GLERA: You've read through the report, it seems to say that the school playground won't cause any disturbance for residents.

HAE: Hmmm...

GLERA: Hmmm what? Is there something we should know?

HAE: It estimates that the nearest sound receptors are “about 25m to the South”. In fact Basterfield house windows are 8.8m away from the playground.

GLERA: And that's important because?

HAE: Distance is the main form of attenuation of the noise from the playground - perimeter fencing won't have any effect for the first floor windows and above - its line of sight.

The assessment levels they have used are not correct (table 8.1). By definition,  the levels in policy (LOAEL/SOAEL) are absolute levels and not variable.

GLERA: They make the following assumption from similar playgrounds: "At the edge of an external play area with a similar number of pupils, noise level was found to be around 75 dB LAeq,1h."  Is this realistic?

HAE: Yep. Now ask about Ambient Noise.

GLERA: What about Ambient Noise? That's the background level at our windows now right?

HAE: Yes, The report assumes the Typical Ambient Noise Level (LAeq,9h) to the South is 65dB, which seems unlikely. Their own survey within the Estate boundary gave readings of between 50 and 54 dB (Table 4.3) No acoustic survey was undertaken to the South of the site (Basterfield) which is the most directly affected, but it most closely resembles the location to the West.

GLERA: How do we check?

HAE: Here, borrow one our sound meters. Check the background noise at different times of day

GLERA: Anything else?

HAE: Give it back when you're done.

We checked the typical (Ambient) noise levels at Basterfield House. they hovered around 50-55 decibels in the mornings, went down slightly in the afternoons. Here's what we found out:

RCS Noise Report 2 from Charles Humphries on Vimeo.

Thursday, 21 September 2017

Defective BMH Demolition Statement not fit for purpose

Taylor Wimpey's Demolition Method Statement has been uploaded on the City of London Planning Website and they are inviting people to comment.

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


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.

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.

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.

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.

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.

Diagram shows how the block will be demolished, starting from the north end
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.

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


‘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.’ 

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.


'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.

The Bernard Morgan House tiles, once photographed by hundreds of passers by

Thursday, 14 September 2017

Don't Let the Sun go Down on Me

The developers of the RCS site have submitted a daylighting report prepared by Anstey Horne. To go by the Executive Summary it would appear that nothing is amiss:

"Considering the proposals as a whole we believe that the daylight, sunlight and overshadowing results for the scheme as designed are good given the city centre location"
But this disguises the true situation.  For example the bedroom of Flat 1, Basterfield House will have the Vertical Sky Component (That's your view of the sky) reduced to less than 50% of existing. Worse, the kitchen of Flat 12 will be reduced to 40% of its current VSC. BRE guidelines state that a reduction beneath 80% is likely to be noticeable, so these effects are likely to be highly significant.

The situation is obscured by the way that Anstey Horne have tabulated the results. The loss of daylight to each window is expressed using a random code number. So it is necessary to go to a set of abstract plans inserted at the back of the document to find out that, for example, F00, R7,W7 is the kitchen of my flat at Basterfield House. There is no need for this obfuscation – it would be perfectly possible to annotate the table so that it shows the address. So far I have yet to meet anyone on the estate (other than architects and even then...) who understands how to interpret the tables and diagrams.

So is it just one or two flats that are affected? I counted the number of windows where the VSC will reduce to less than 80% of existing (and breach BRE guidelines). Of the windows measured a total of 122 windows are losing more than the BRE guidelines.  Some rooms are losing 60-70% of their access to natural light.

My own kitchen at Basterfield House is losing 48% of its natural light. (In case you cared)

Sorry seems to be the hardest word

Anstey Horne immediately proceed to try and establish wiggle room. The BRE guidelines should be “flexibly interpreted”. Lets take a look at how Anstey Horne wiggle.

Candle in the Wind - its so BRIGHT in here
1. The existing site is very open and we enjoy an unusual amount of daylight for London. Anstey Horne do not provide any justification for this; for example by measuring the actual light levels. The existing RCS site is two storey and clearly does not block the same amount of light as a 14 storey tower.  However the existing site was designed with due regard to the pattern of urban design established by  Chamberlin, Powell and Bon which sets the residential blocks East-West with open space to the North and South to allow light to penetrate the relatively deep plan. This gives the lie to the next argument that Anstey Horne adduce:

Rocket Man - you look familiar
2. If you were to build an imaginary mirror image of Basterfield House immediately on the other side of the access mews it would be more impactful on daylight levels than the CoLPAI proposals. Whilst perfectly true, this argument is meaningless and is used inappropriately. The access mews is not a public highway and was never designed as such. The proposal has been described by the developers as an “An Extension to the Golden Lane Estate”. There is no imaginary boundary that can be used for this purpose –  and the use of Appendix F of the BRE report is inappropriate in this case. The extension to the Estate needs to be designed with due regard to the existing buildings and following the urban pattern established by the original architects.

Can you Feel the Love Tonight?  No, I said Transgressions and I meant it.
3. These reductions are inevitable given that they currently face a low-rise site, and any meaningful development will result in BRE transgressions . 
This argument ignores the fact that the principal transgressor is the residential tower. There are several alternative schemes that have been brought forward that have development on the scale and density of the existing estate and that do not involve a residential tower. It would be more truthful to say that any over-development will result in BRE transgressions.

If There's a God in Heaven (What's he Waiting For?)
4. The majority of rooms that face the development are kitchens and bedrooms, which are considered to be less important than living rooms for daylight and sunlight.  
This is an “interpretation” of the BRE guidance, which in fact says that “sunlight is viewed as less important in bedrooms and kitchens where people prefer it in the morning rather than the afternoon”  It makes no mention of daylight in this connection and misses the point that the tower, being situated to the East of Basterfield House will rob daylight and sunlight precisely in the mornings, when people prefer it in the kitchen and bedrooms.

A Town Called Jubilee. Did someone mention a balcony?
5. The most sensitive neighbouring windows are effectively self – obstructing due to their own design, namely projecting balconies and bays. In other words, contrary to the assertion in (1) above, the affected windows already receive rather less light than they might expect. Anstey Horne go to the trouble of making all the calculations with a re-design of the Grade II and II* listed Golden Lane Estate Blocks, removing the access balconies.

They needn’t have wasted their time; It turns out that the  new tower still blocks so much light to the kitchens that they still fail to meet BRE guidelines even after Anstey Horne’s  imaginative architectural redesign.

Of course there are no “projecting bays” (They are confused with the South Elevations) and the bedroom windows are in fact flush with the face of the balconies, so there is no effect on those.

Don't Go Breaking my Heart

The fact is that no amount of wiggling can conceal that the proposed CoLPAI tower blocks extraordinary, excessive amounts of light from Basterfield House, Hatfield House, Banner Street and even the Community Centre, where one window apparently loses 79% of its natural light.

This is not a question of fine judgment,  of a balance of good and necessary evil, or of a small change that won’t be noticeable. This is a massive and permanent change to the character and quality of a large number of homes.

Wednesday, 13 September 2017

Public Meetings Blast RCS Scheme

Two Public Meetings held at the Golden Lane Estate following the submission of the Planning Application for the RCS site have heard how the proposed scheme will impact life on Golden Lane and provide poor quality social housing.

GLERA Meeting at Community Centre 31/8/17

Too Much Stuff

Extraordinary as it may seem Islington and the City of London have brought forward a scheme that breaches their own planning policies on Height, Density, Access to Nature and Playspace. Even policies such as Cycling Provision, Disabled Parking and Refuse Collection are breached. When challenged the planning consultants point to the "constrained" nature of the site. Which is another way of saying that they have stuffed far too much onto the site.

Is that it?

It would be bad enough if that was it. But the height and density give rise to all sorts of other problems for residents on Golden Lane and Banner Street such as excessive noise, overshadowing, traffic congestion. The planning application tries hard to make light of these effects, but as the meeting heard - is unconvincing as soon as you drill down into the details. The noise report submitted was littered with errors, saying for example that the school playground was "about 25m away from the nearest residential receptors". In fact Basterfield House is less than 9m away.

Link to give your comments and views on the scheme:

Islington Planning Website

City of London Planning Website

Sunday, 10 September 2017


Despite numerous well argued objections the City has now, on 30 August, granted planning permission to Taylor Wimpey’s to demolish Bernard Morgan House and build its monstrous development called the Denizen. The developer must satisfy various planning conditions before commencing work.

Bernard Morgan House and The Denizen

The Denizen is the name Taylor Wimpey have decided to call the new building. It’s being marketed in Hong Kong as an investment or a hotel for the super rich. Asking prices range from £695,000 for a small studio to £2,375,000.

The Denizen is being marketed in Hong Kong by Savills and Knight Frank

The planning permission had been subject to negotiating further terms with Taylor Wimpey for an 'upward only independent review of the affordable housing contribution which the Chairman and Alderman Sir Michael Bear will be consulted on' One outcome of that Taylor Wimpey’s previously contribution to affordable housing has now decreased from £4.5million pounds to £4,455,000.

We have received advice from Matthew Horton QC, a senior specialist barrister and our lawyers have sent a letter before action to the City requiring it to withdraw the planning permission or face an application for judicial review to the Planning Court to set it. The appendix to this letter lists the factual background and policy context, the consideration of the officer’s report and the alleged errors of law. You can read this letter here

If the permission is not withdrawn then we will need to raise more funds to meet the cost of the application to the Planning Court for a judicial review and for this purpose we will be starting a new campaign to Save Golden Lane and Stop the Denizen.

From TWCL's advertising campaign

As Pippa Henslowe says in her blog

'Taylor Wimpey’s promotional effort is clearly aimed at wealthy but culturally unsophisticated ghost home investors who are likely to buy-off plan without ever visiting the property or the area it is located in'

The City of London has chosen to replace accommodation for 120 police officers and other keyworkers with these ghost homes.

I hope that you will be able to continue to donate financially to support our campaign and protect our community from such monstrous and unnecessary over development. A development which contains no affordable housing and a shockingly inadequate financial contribution to affordable housing off-site. Donations can be made on the Crowd Justice campaign page.

Many thanks