Retaining Ealing's Cast-Iron Lamppost Heritage: SEAL 2007 1. Foreworda) This report has been compiled by Save Ealing Antique Lampposts (SEAL), which was formed in November 2006 and is fighting for the retention of Ealing's antique, cast-iron lampposts. SEAL is made up of Ealing residents, and members of Ealing Civic Society, Kingsdown Residents' Association, Lammas Residents' Association and West Ealing Neighbours. b) The cast-iron lampposts in an area of South Ealing and Northfields are particularly suitable for retention because they were structurally tested, electrically upgraded and re-installed such that their increased, positional density met illumination standards in 1989. c) The definitive description of Ealing's cast-iron lamppost heritage is ‘Cast-Iron Lamp Columns in the Borough of Ealing', written by Mark Kehoe. The document can be viewed on the SEAL page at www.westealingneighbours.org.uk 2. Management Summarya) The behaviour of Ealing Council Members and Officers during the period 2001 to date in performing their duty of care with regards to the retention of Ealing's Victorian and Edwardian cast-iron lampposts has been inadequate. This report reveals a recurring pattern of inappropriate behaviour characterised by flawed public consultation, secrecy, ignorance and disinformation with regards international standards' adherence, and an absence of real world costings for cast-iron lamppost retention. b) Our cast-iron antique lampposts can be retained and their lanterns updated without breaking any laws; whilst complying with all relevant UK and European standards; and without incurring excessive costs. c) Past mistakes can be rectified and a collaborative way forward involving all interested parties can be established to retain this valuable part of Ealing's heritage. d) SEAL sees no immediate legal, standards, health and safety or financial imperatives which necessitate the immediate removal of our antique cast-iron lampposts. 3.Introduction. a) This report documents the case for retaining Ealing's cast-iron antique lampposts, and updating and renovating them in situ. The report examines and refutes the Ealing Council case for the removal and replacement of the lampposts on the grounds of ‘standards' and cost. The report also exposes details of the Ealing Council/EDF Energy Street Lighting and Illuminated Signs Public Finance Initiative (PFI) contract, which was negotiated and signed behind closed doors in 2005. The report documents the flawed Ealing Council Public Consultation process on street lighting, which preceded the PFI negotiations. b) This report has been compiled in order for it to be considered by the Ealing Council Leader in a meeting set for 28/02/07 he has requested with Irving Jones, a Salisbury Road resident and his supporters. The meeting might take place in time for all the relevant issues to be investigated before the final cut of the Council's 2007/8 budget on 06/03/07. The Chairs of Brentham Society, Ealing Civic Society, Kingsdown Residents' Association and West Ealing Neighbours are all committed to attend the meeting; along with Salisbury Road residents, a representative from Lammas Residents' Association and other SEAL members. 4. Ealing's Cast-Iron Lamppost Heritagea) The 1,100 cast-iron lampposts, whose lanterns still light our Ealing streets, are almost all of the same design and date from the late 19th Century to the 1920's. Their particular octagonal design was very popular and many thousands of lampposts were cast at a number of UK iron foundries including those in Stockport and Gt. Castle Street, London W1. The design surpassed most others by way of simplicity, versatility and enduring robust construction. It is particularly resistant to corrosion and fatigue. Cast-iron lampposts identical to or very close in age and design to the ones in Ealing still light the streets in Albert Embankment, Aldershot, Bedford, Bradford, Camden, Green Park, Malvern, Manchester, Portsmouth, Reading, Rye, Southport and Southsea. b) But the majority of Ealing's cast-iron lampposts have been abandoned in recent years by the Council's street lighting department as far as physical, external maintenance has been concerned. So much so that concerned residents in Clovelly, Dorset and Gloucester Roads recently spent their own money to restore the physical appearance of the cast-iron lampposts back to their pristine, antique grandeur.
c) These cast-iron lampposts are specifically a major part of what is left of West Ealing's heritage. Much of West Ealing centre's Victorian heritage was demolished in the last century - cottages, shops, stables, mission halls, churches, and inns: all gone forever.
5. Ealing Cast-iron Lamppost Removal - The Story So Fara) In 2002, Ealing Council carried out a flawed Public Consultation on Street Lighting (see section 9.) b) The PFI contract was signed in June 2005. This contract ceded control over the installation and maintenance of Ealing's 14,700 lampposts to EDF Energy. This contract specifies the replacement of the vast majority of these lampposts, including all of the antique cast-iron lampposts by 2010. (See section 8.) c) In February 2006, the residents of Salisbury Road called a public meeting in order to express and openly discuss their unhappiness at the prospect of losing their 16 Edwardian cast-iron lampposts. Local Councillors, Ealing Council Officers and EDF Energy were all invited to the meeting to speak and to answer questions. No local Councillors bothered to attend this meeting. The residents were in fact faced down at this meeting by a Council Officer and two EDF Energy contractors, who told them that the removal of the cast-iron lampposts was a fait accompli. d) The first cast-iron antique lampposts to be removed in west Ealing were the 9 in Woodstock Avenue, which were removed in the Summer of 2006. The lampposts were replaced by 6 metre, steel lampposts, which were much taller than the cast-iron lampposts they replaced. e) In October 2006, Ealing Council convened a meeting for Ealing Conservation Area Panel Members. Kingsdown Residents' Association (KRA) representatives also attended this meeting. At this meeting Shahid Iqbal of Ealing Council said that contrary to commitments made previously to Conservation Area Panels, it would not now be possible (because of financial considerations) to replace Conservation Area antique cast-iron lampposts with ‘Heritage-style', replica, replacement lampposts. Modern, much taller hockey stick-style lampposts would be installed instead. Panel Members were upset by this statement.
f) EDF's Barry Smith said that:
- Ealing's cast-iron lampposts don't meet safety ‘standards'
- Some new ‘standard' required that lampposts must be of a certain height
- In answering questions about the height conflicting with trees, that Ealing Council had a duty to trim trees on a regular basis where leaf cover is near or below the new lanterns and obstructs the light.
KRA (Arthur Breens) subsequently wrote to EDF's Barry Smith asking him to define the ‘standards' he referred to and to put in writing Ealing Council's tree trimming requirements. (More on this in section 6.)
g) In November 2006, EDF lighting contractor's workers arrived in Salisbury Road to begin ‘relighting' the street. Residents complained to the workers and the installation stopped. As of February 19/02/07 the relighting work has not re-commenced.
h) In February 2007, SEAL observed antique cast-iron lampposts sanded down, derusted and primed for painting in Hereford Road and Julien Road in W5. This is encouraging but doesn't conform to the policy enshrined in the PFI.
SEAL also observed in February 2007, EDF contractors removing antique cast-iron lampposts being from Hicks Avenue, Greenford.
Is there one cast-iron lamppost policy for W13, one for W5 and another one for Greenford? What exactly is going on here? 6. Street Lighting ‘Standards' a) The following standards have been variously quoted in correspondence by EDF's Barry Smith to Arthur Breens (KRA) dated 11/12/06 and in discussions about the proposed removal and replacement of Ealing's cast-iron antique lampposts: BS 5489-1:2003 Code of Practice for the Design of Road Lighting BS EN 13201-2:2003 Road Lighting - Performance Requirements BS 7671 (IEE Wiring Regulations 16th Edition) BS EN 40 Lighting Columns. b) SEAL has reviewed copies of all these standards at Imperial College London Library; has taken professional technical advice on their interpretation ; and has described their applicability and relevance below with regards to the PFI contract and the written and verbal statements variously made by Councillors, Council Officers and EDF Energy. c) Before reviewing the specifics of these standards, it's important to note the distinctive, non-prescriptive nature of them - with great emphasis put on aesthetics, sensitivity to scale and environmental history. d) The standards all use the words 'luminaire' and ‘column' which are equivalent to SEAL's use of the words ‘lantern' and ‘lamppost'. e) There is no reference in any of the standards to a mandated height for columns. f) EDF Energy's Barry Smith in his letter to Arthur Breens of 11/12/06 refers to ‘Height requirements are determined by the Council and the accepted height for residential roads is 6mts'. (We interpret this to mean 6 metres). g) The choice of a height of 6 metres for lampposts and S2 luminance is simply arbitrary. It has no basis in international lighting standards. It is indeed contentious with regards the standards' guidelines (see BS 5489-1 below). Barry Smith explained that 6 metres was chosen to produce S2 level lighting without ‘having to resort to huge numbers of additional lighting units'. In other words, to make financial savings. h) There is no reference in any of these standards to the requirements for electrical supply isolation and the location and height above ground of electrical power ‘cut out' and fuse within the lampposts. i) EDF Energy's Barry Smith in his 11/12/06 letter to Arthur Breens makes copious references to Distribution Network Operators (DNOs) refusing to re-connect cast-iron columns like ours which have no ‘base compartments' (panels to access cut out and fuse near ground level). The DNOs are primarily Scottish Energy, Southern Energy and EDF Energy. As SEAL is making no recommendations for the cast-iron lampposts to be removed for any purpose, these unilateral and non-standard policy adoptions by DNOs in this area of re-connection are irrelevant. j) EDF's policy for working on lamppost equipment above the height of 1.5 metres (above which in fact the ‘top box' containing the fuse and associated electrical control gear in our cast-iron lampposts resides) is somewhat risible. Barry Smith contends that access would require the use of a ladder and the presence of a second person to steady the ladder. He contends that DNOs would not have access to Mechanical Working Platforms in urban locations in order to access ‘high' locations on the lampposts. DNOs have accepted the status quo for many years with regards to the isolation/cut out/fuse location characteristics of our working cast-iron lampposts. Hoists have been used for over 20 years for lens cleaning, bulb changing and fuse maintenance. Given that modern 4 metre and 6 metre lampposts also have equipment contained within the lantern, use of a ladder at such height would be equally risky. k) If EDF Energy want to make a big issue of ground level access, there is a system in use which can provide this called Feeder Pillars. Discretely placed, Feeder Pillars can supply more than one lamppost. Sub-surface Feeder Pillars also exist which could be fitted as and when required next to any lamppost. l) As a further (admittedly another non-standards) reflection, we notice that the base compartments on the newly installed steel lampposts are at car bumper, child interference, and vandal interference level. In fact, one could argue that there are more potential dangers implicit in Road Traffic Accident (RTA) damage to lampposts with ‘low' compartments than with those with ‘high' compartments. Barry Smith's comments about our antique cast-iron lampposts being more susceptible to being rendered in a more dangerous state than the new EDF steel lampposts if involved in an RTA are unsubstantiatable. At least we have the audit trail of 100 years acceptable use with our cast-iron lampposts as opposed to the few months of performance data from the new steel lamppost. m) Standard BS 5489-1 Here is a selection of important quotes/points easily found in this standard: 1) ‘There is no statutory requirement to provide street lighting. Neither is there any statutory requirement to install a particular class of lighting if a decision is made to light a particular road.' This standard....'gives recommendation on the general principles of road lighting, gives recommendations on aesthetics and technical aspects and advises on statutory provisions, operation and maintenance'. 2) Re: Height of lampposts: ‘ In tree-lined roads, lower mounting heights than usual may be used to bring luminaries below the tree canopy'. In Woodstock Avenue the now replaced cast-iron lamppost lanterns were positiononed just below the tree foliage, and there was no light blocked in the summer by the leaves. The lanterns of the new lampposts are situated within the tree foliage or above it. It would be interesting to find out what the achieved illumination level on the pavement and on the street was when the trees were fully leaved in Summer 2006. If such measurements were not made in summer 2006, they certainly do need to be made in summer 2007. Barry Smith of EDF's suggested solution to this leaf problem stated at the 26/10/06 Conservation Area Panel Meeting was that Ealing Council had a duty to trim street trees on a regular basis, where leaf cover is near or below the new lanterns and obstructs the light. So far, despite requests he has not put this statement in writing but the PFI contract section MS5 (see section 8.) states that to maintain optical conditions.....'luminaire is not obstructed by foliage'. The Council currently trims its trees once every three years. This addition tree trimming cost will clearly increase the Council's annual tree trimming costs. Also ‘scalping' the trees every year would detract from their traditional fullness and would be yet another degradation of Ealing's environmental heritage. 3) ‘....the height of the lighting column and luminaire should not exceed that of nearby buildings'. 4) Care to prevent light intrusion into adjacent properties is mentioned. After observing the light intrusion into the front bedrooms of Woodstock Avenue residents, Irving Jones is concerned about the cost of preventing similar light pollution into his front bedrooms in Salisbury Road and in his 28/12/06 email he asked the Leader of the Council about financial compensation should this occur. 5) Luminance Levels (Values in lux ) (Lux is the International system of unit of illuminance). There are five ‘S' classes of luminance, which conform to this standard - S2, S3, S4, S5 and S6. In the PFI the ‘brightest' lighting class - S2 - is selected (with no apparent justification) as the luminance class for all Ealing residential roads.
n) Standard BS EN 40 This document is concerned with new columns and the stress caused by wind effects. This is particularly pertinent to tall columns and not a consideration for short, cast iron columns the strength of which is indicated by their longevity.
Ealing Council's Joe Tavernier said at the 24/01/07 Overview and Scrutiny Committee Meeting that cast-iron lampposts were brittle and that cast-iron lampposts would have to be reinforced. SEAL can find no substantive evidence to back up this statement. o) Standard BS EN 13201-2:2003 Lighting classes are defined as a set of photometric requirements aiming at the visual needs of certain road users in certain types of roads. S2 Class Luminance (the choice selected by the PFI signatories for Ealing's residential roads) is rated at 10 lux, while S4, for example, is rated at 5 lux. S2 was chosen for the PFI contract but it is important to reiterate that there is no legal/standards requirement to select S2 for residential roads. 7. The Cost of Retaining the Cast-Iron Lamppostsa) This whole issue of the cost of cast-iron lamppost retention has been consistently clouded by widely different verbal cost quotations emanating from a variety of sources. b) (With regards the retention of Ealing's antique cast-iron lampposts)...‘Cost is the killer issue' Councillor Anthony Young, Ealing Area Committee Meeting, 06/02/07. c) Brentham Society has been told by Ealing Council that the cost of refurbishing a single antique, cast-iron lamppost would be between £3,000 and £4,000. d) Ealing Council Officer Sebastian Navaranjan has at various times told Salisbury Road resident Robert Darke and Waldemar Avenue resident Arthur Breens that lamppost refurbishment costs range from £2,000 to £5,000 per lamppost. e) In February 2007, SEAL obtained a quotation from a local Master Builder who suggested a figure of £900 per cast-iron lampposts to cover the cost of refurbishment and lantern updating in situ. This would include shot blasting, filling (instead of welding), sealing, priming, two coats of repainting and the upgrading of the lantern. If all 1,100 antique cast-iron lampposts were renovated and upgraded in this way it would cost - allowing for some administration and contingency costs - £1 million. f) In 2006/7, local residents in Clovelly and Gloucester Roads checked the structural integrity of their 22 antique, cast-iron lampposts. Apart from flaky paint - caused by years of neglect by Ealing Council - all the lampposts were found to be in perfect condition. The residents, giving up their time for free, then refurbished the lampposts manually in situ. The total costs of tools and materials to do this was £2:11p for each lamppost. We feel that cast-iron lamppost painting is an activity which would be suitable for people carrying out Community Service/Community Payback orders to perform. SEAL proposes that it is only the lantern upgrade work which would need to be carried out by paid contractors. Assuming that this reduced the cost to £700/lamppost, the total cost over four years - with admin/contingency added would be £200,000/year. This also assumes that the PFI could not be adjusted to include antique, cast-iron lamppost retention. (See section 10.) This costing is significantly lower than the two costing options of £300,000/year and £500,000/year over four years contained in Jason Stacey's 01/02/07 email to Mark Kehoe. However SEAL accepts that its estimates are informal ones. g) In his email reply to SEAL member and Salisbury Road resident Irving Jones on 28/12/06, the Leader of the Council stated that the cost of replacing the Borough's cast-iron lampposts with Heritage-style lampposts would be £3.2 million over a four year period. This reply did not relate to the cast-iron lampposts' retention questions posed by Irving Jones' in his 28/12/06 email to the Council Leader. SEAL's assessment of this question and answer content mismatch is that the Leader of the Council has been convinced that the retention of the cast-iron lampposts is impossible on the grounds of ‘standards' adherence and on cost. SEAL refutes both of these assertions. h) The Street Lighting PFI contract quotes a figure of £1,379:60p for the ‘Jointing Only' and 'Groundworks' for a single new steel lamppost. This would be the same cost that would be required to replace a cast-iron lamppost which had been taken out of the pavement and then put back into the pavement. Most but not all the cast-iron lampposts in Northfields and South Ealing were fully rewired and jointed when they were converted from series time switch to independent photo-cell operation. As for the PFI contract, if our suggested retention approach were adopted, one wonders how EDF Energy would ‘account' for the 1,100 jointing and groundworks not being performed (ie £1.52 million worth) for the new, steel lampposts and lanterns , which wouldn't need to be purchased. i) A definitive, independent, written quotation is required in order to correctly cost the renovation and upgrade of our cast-iron lampposts. 8. PFI for Street Lighting & Illuminated Traffic Signs in the London Borough of Ealing, June 2005a) Anecdotal evidence suggests that Ealing Council's finances have not been very healthy for years. The Borough was some years ago ranked as the worst lit borough in London. When the Government came along with a £25 million grant as an inducement to outsource the whole street lighting business, maybe it was too good an offer for the Council to turn down. b) On paper the deal with EDF Energy will cost the Council some £32 million, at a current per annum payment of around £2 million. Ealing Council's Sebastian Navaranjan told SEAL that after projected inflation the total cost over 25 years would be £120 million. c) The lampposts are owned by Ealing and EDF can't dispose of lampposts without obtaining the Council's permission. d) ‘Optical Integrity : ..that the luminaire is not obstructed by foliage'. e) As stated in earlier in this section, the height of the tall, new lampposts matches the height of the mature trees that grace Ealing's Roads and the light is therefore likely to be obstructed by foliage without regular and costly trimming. f) Consultation: Performance standard 1 ‘Consultation...(to include)...community groups and residents This was a flawed process. (See section 9.) g) Feeder Pillars are an acceptable problem solver if the DNOs insist on not wanting to connect lampposts without isolation built-in the lampposts at ground level. ( See Section 6.) h) PFI Independent Certifier: Tony Price, Capita Symonds Ltd., Wood Street, East Grinstead, West Sussex Tel; 01342 327161
i) ‘MS11 (Method Statement):
...open mind and not unreasonable in our request for change....'
j) ‘Annual Service Report:
...is scheduled for the 28th February each year and will contain......volume and scope of complaints'
k) ‘MS5 (Method Statement)
Maintenance of optical conditions
.....luminaire is not obstructed by foliage
l) The guaranteed life of the steel lampposts is 30 years'
m) ‘.....where a luminaire is obstructed by trees or other vegetation the
Council will be notified....'
n) The vast proportion of existing lampposts are scheduled to be replaced by June 2010
o) There are no references whatsoever to Ealing's antique cast-iron lampposts in the PFI contract. 9. Public Consultation on Ealing Street Lighting - A Flawed ProcessStreet lighting questionnaires, dated 1st February were mailed to some but not all Ealing Conservation Panels in February 2002. We understand that the results of this consultation with Conservation Panels was submitted to Ealing Council Cabinet during 2002.
No-one can find any evidence of Street Lighting questionnaires being mailed to any other Ealing residents, Ealing residents'groups, or Ealing traders'/business groups. The Ealing public whose roads are lit by upgraded (1989) cast-iron, antique lampposts were not consulted. The PFI contract said that there was consultation with all the above stated groups. This clearly did not take place and is a serious omission. In the absence of this consultation the removal of the cast-iron lampposts must stop and a somewhat belated Street Lighting Public Consultation exercise must be performed.
10. Ealing Cast-Iron Lampposts - The Way Forward
a) We have thoroughly researched the British and European Standards quoted to us by EDF Energy and Ealing Council and contrary to what we have been told by both parties, have found that there are no standards or legal basis for the assertions they have made about the necessity to remove the cast-iron lampposts. It is of serious concern that as residents we have been misled to this extent. Similarly we believe that our Councillors have equally been wrongly advised and misled.
We therefore conclude that there is no pressing health and safety, legal, standards or financial imperative for Ealing Council to re-commence (or even continue) removing our cast-iron lampposts.
Our case is:
1) We have found that there are no BS or European Standards imperatives either for the height of lampposts or a requirement for the S2 luminance level. On the contrary, the advice stresses compatibility with the street environment, height and style of houses, trees etc and encourages flexibility
2) The Standards recognise that ‘lower mounting heights may be used to bring luminaries below the tree canopy'. There is no need to keep to the 6 metre lamppost height where it is not suitable.
3) It is questionable whether the S2 light level will be attained unless a regular trimming of trees takes place (at least yearly). This will be very costly. To achieve the S2 level, more severe action such as tree removal may be needed which would be undesirable
4) So far we have found no health and safety legislation to suggest that lampposts with high compartment/panels to access cut out and fuse (as opposed to ground level compartment/panels) are illegal. We are unconvinced by EDF Energy's assertions in this area. If EDF Energy insist, a Feeder Pillar system could be installed - which would add to installation costs. Also the high compartment/panels offer some advantages as outlined in section 6.
5) The claims that very high costs are required in order that the borough can retain its antique cast-iron lampposts are exaggerated. We have presented evidence to refute these claims in section 7.
6) The PFI states that consultation with residents was carried out (see section 8.f) ). This was clearly not the case (see section 9.). No renovation of cast-iron lampposts is specified in the PFI and this is clearly taking place now in Hereford Road and Julien Road. Somebody, somewhere convinced Council Members and Council Officers that our cast-iron antique lampposts could not be retained on the grounds of not meeting UK/EU standards/Health and Safety standards, and even if they could(?) that the cost would be excessive. The contents of this report provides strong evidence that these assertions are untrue. Did these now discredited assertions emanate from EDF Energy? There may be other areas of non-performance in the PFI, but so far we have only been able to peruse the contract for three hours. Obviously EDF Energy will not want to entertain reduced revenue or profit in executing the PFI contract, but surely the above non-performance gives the Council a basis for negotiation? After all section 8.i) quotes the PFI ‘(Method Statement MS11 ....open mind and not unreasonable in a our request for change'.
b) We therefore request that the current moratorium on removing antique cast-iron lampposts in Salisbury Road should be formalised. This moratorium should apply throughout the borough.
c) We also propose that a Council-recognised working group should be set up to propose how to proceed from here. This working group should be made up of interested resident group and special interest group representatives, along with Member and Officer representatives from Ealing Council, and EDF Energy. An independent, definitive, written costing needs to be obtained for the refurbishment and update of our cast-iron antique lampposts.
d) The working group should organise a complete audit and numbering of all the cast-iron lampposts including those still in situ and those which have been removed from our streets by EDF Energy contractors. The group should oversee a trial in which a sequence of cast-iron lamppost lanterns are upgraded and the illumination measured to confirm conformance to S2 standards and to verify the maximum length of the gap between lampposts which will support the S2 standard. For those roads where the wide spacing of lampposts makes even ones with upgraded lanterns inadequate in the level of luminocity, the lampposts in these roads should be carefully removed and kept in stock as replacements.
As part of this lantern upgrade various designs should be considered which are architecturally sympathetic to the Victorian lanterns, which originally graced our streets.
e) SEAL recommends that if, as expected, these performance trials are successful it is then imperative that the group proposes a Street Lighting Public Consultation process - so painfully lacking six years ago. This will constitute a belated attempt to restore some legitimacy for the Council's cast iron lamppost street lighting activities; to discover exactly what domestic and business rate payers want in this area; and to restore public confidence in local governance.
f) If the public recommends the retention of our cast-iron lampposts and the Council Cabinet agrees, then a detailed audit of the antiquely lit streets is required which would result in a work schedule for lamppost renovation and update.
g) From this schedule an Antique Cast-Iron Lamposts Renovation, Update and Maintenance Invitation to Tender (ITT) could be drawn up and a variety of contractors - EDF Energy included - could be asked to respond to it. It is also possible that the lamppost painting could be done by workers on Community Service/Community Payback under supervision.
SEAL Tel: 020 7099 9036 Email: westealingneighbours@gmail.com Web: www.westealingneighbours.org.uk 21st February, 2007 |
