Dear Matthew Gest (Planning Officer for Brighton and Hove City Council)

Last year WHP telecom made a planning application (BH2021/01639) for a 15 metre mobile mast just 27 metres from St Peters Community Primary School in Portslade. Despite over 135 objections including the School, Peter Kyle (MP) and Councillors, the planning application was approved.

We, parents, residents and the wider community were appalled by this decision and raised funds to carry out a judicial review at the High Court of Justice. We won the case. We demonstrated that both WHP and the Council acted unlawfully by not considering the highways risk, the health risk or looking into locating the antennas on existing structures and sites.

WHP telecom have now submitted a new application (BH2022/03457) attempting to address all the points. They have not. Our solicitor has written a formal objection to demonstrate that they are still in breach of the court ruling. Most particularly we wish to highlight that they have failed to provide evidence to show they have looked into existing buildings and structures upon which to locate the antennas.

The coverage map WHP telecom submit in the planning application to highlight their 'extremely small cell search area' contains no source information or legend and is open to misinterpretation that this is a 5G coverage hole. Upon looking at Three's network coverage on their own website, this map is identical to the 3G coverage hole, not 5G!

Below is a map showing the coverage hole for 5G for Three, sourced from their own website, which you can see has much more scope for the siting or upgrade of antenna. They have not provided evidence of looking into upgrading their four existing 4G masts or looking into rooftop options. All of their options presented were 'ground based new options' and some of the arguments for discounting these are weak.

For example, one option presented was by the 'Shark Park' and this was discounted because 'less sensitive sites available away from a childrens playpark'. This is shocking given that a school is a far more sensitive location. They also listed that the development has been sited 'as far away from sensitive residential receptors as possible'. They completely ignored St. Peters Community Primary and Nursery School. They also failed to appropriately consult the school. The classrooms are within just a short distance away from the exclusion zone, where radiation is deemed unsafe for the public to be. The science behind 5G is not yet proven and we think it 'precautionary' to keep masts a good distance from schools. Children are more vulnerable. This location is entirely inappropriate to site a 5G mast.

Another option discounted was outside Goatley's, on account of 'insufficient pavement width'. However, if they include the grass verge, this width is wider than outside Dreams store, by St Peters School. It demonstrates how WHP have not seriously looked into other siting options and do not consider the residents or children and staff at the school.   

Three claim that they are bringing 5G to the people however they only have a 10% share of the market and only 12% of mobile users state they want 5G. Therefore they will only be bringing it to 1-2 users out of every 100 in the area.

The above points demonstrate how the application directly breaches Court Ruling CO/3114/2021:

Adur & Worthing Planning team have rightly refused recent applications close to schools. Please do the right thing for this community and REFUSE the application for this location. 

Sincerely,

Carol Springgay, Carole Ward and the community around St Peters Community Primary School, Portslade, Brighton.