OPEN
Dalston’s comments on TfL’s “Western Curve” Planning application 2013/1039 at 10-34
Kingsland High Street and the north west side of Ashwin Street (eastern site);
and 25-33A Kingsland High Street and the south eastern corner of Boleyn Road
1 Design and departures from the “Planning and Design Guidance for the
Dalston Western Curve” and the Dalston Area Action Plan.
This Guidance was adopted by the Council Cabinet on 26.10.09 to provide
detailed planning and design guidance:
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which was intended to be, and is, a “material
consideration for planning applications” and
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which would result in “development
and public realm that will be of high quality and well integrated within the
fabric of Dalston, will provide services and amenity that enhance the town
centre and will provide housing”.
At the same meeting the Cabinet approved a contribution from the Council
to TfL of £1.325m towards the cost of design and construction of ‘decks’ over
the railway cuttings to facilitate enhanced construction of above ground development
which previously comprised 1-2 storey buildings only.
The application departs from the objectives and detailed recommendation
contained in the Guidance in the following respects and for these reasons the
application should be refused:
1.1
The application does not meet the Guidance’s aspiration that “New and improved areas of green open space
and/or public realm will be encouraged subject to appropriate design” and
“public spaces, small and large, should be considered and designed to integrate
with the existing fabric of the street and area..” The design provides no
green open space and/or public realm and precludes the opportunity to consider
“elements of green open space and or
public realm surrounded by active frontages” on the southern site. OPEN
Dalston engaged in public consultation regarding the Guidance but the applicant
has ignored the local community’s desire for green open space in the site.
1.2
The application does not meet the Guidance’s aim that “The possible development envelope could
incorporate building heights of a maximum
of six storeys”. The building heights exceed the Guideline and is not, and
cannot be, justified by the applicant.
1.3
The application does not meet the Guidance’s requirement that the development “should demonstrate an exemplar standard of design ad sustainable
construction”. The designs are bland and undistinguished. They overpower the
attractive and notable buildings locally and render them as subservient. They are
not designs which are worthy of replication as “exemplars”.
1.4
The application does not meet the Guidance’s aim to “improve
overall permeability and the pedestrian environment on Dalston town centre”.
The designs preclude the opportunities which exist within and around the sites
to meet these objectives
1.5
The application does not meet the Guidance requirement to properly
consider the “impact on its immediate and
wider context –Dalston Town centre and surrounding listed buildings” and “impact of overshadowing of taller elements
on amenity space and neighbouring development”. The designs deprive locally listed and notable
buildings of adequate natural light, namely the locally listed Reeves and Sons
Printhouse in Ashwin Street and 51-57 Kingsland High Street (which includes Grade II Listed Cookes) and renders the
amenity space within the proposed development as 90% overshadowed.
1.6
The application does not meet the Guidance requirement of buildings “ranging between 3-6 storeys high. The maximum
height considered appropriate is 6 storeys for both sites, subject to the
quality of the design proposed”. The design for the southern site creates a
continuous 6-storey roof line which obscures
views form the High Street and encloses Ashwin Street, and the northern site
7-storey block exceeds the guidelines. Both site designs “result in domineering levels of development” which are contrary to
the Guidance.
1.7
The application does not meet the Guidance requirement for “contemporary architecture of the highest
quality which enhances the ‘sense of place’ of Dalston town centre.” The
architectural designs create a ‘sense of
anyplace’, and ‘out of place’
which does not respond to or enhance Dalston Town Centre.
2 Housing Provision
Of a total of 106 flats only 9 (8.5%) are for
affordable social rent and 6 (5.6%) are intermediate.
Of a total of 106 flats only 20 (19%) are 3
bed family homes, of which only 5 (5%) are for social rent.
The provision does not meet the Guidance
objective that 30% of homes should be accessible for wheelchair users.
Having regard to local needs we consider that
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the provision of family housing
is totally inadequate.
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the provision of affordable housing is totally inadequate and contrary
to the LPA’s Planning and Design Guidance for the Western Curve ( 50%
affordable of which 70% should be for social rent and 30% Intermediate) and both
the LPA’s & GLA’s overarching policy targets for affordable housing.
The applicant does not and cannot justify the
inadequate provision
For these reasons the application in its
present form should be refused.
3 Building heights
The northern site development rises to 7
storeys. The height is so overscale to the streetscape that it would dominate the
surrounding buildings of 3-4 storeys, adversely affect the setting of heritage
buildings at 51-57 Kingsland High Street and (the applicant’s sunlight report
reveals) reduces the natural sunlight to them to below BRE standards. This is
clear evidence of overdevelopment.
The Dalston
Area Action Plan, approved by a Planning Inspector, identifies that 4-6 storeys
would be an appropriate height for developments on this site. The Applicant
fails to justify any development exceeding 4 storeys and was unsuccessful in
its representations to the Inspector that it would be appropriate to exceed the
DAAP guidelines on height.
The southern site development proposes a
continuous terrace of 6-storeys. The height is so overscale to the streetscape
such that it dominates surrounding buildings, adversely affects the setting of
heritage buildings in Ashwin Street, namely Reeves & Sons and Shiloh Pentcostal Church and ( the
applicant’s sunlight report reveals) reduces the natural sunlight to Reeves
& Sons to below BRE standards. This clearly demonstrates overdevelopment.
The Applicant
fails to justify a development exceeding 4 storeys. The continuous roofscape is
contrary to paragraph 3.51 LPA’s Planning and Design Guidance for the Western
Curve which seeks variable building heights.
We consider
that the buildings described here as adversely affected by the development are local
and national heritage assets and are representative of Dalston’s character,
identity and cultural history. We consider that the applicant’s development
would substantially and irreversibly damage their settings and amenities
including sunlighting.
The applicant
states that no sunlighting study has been carried out to the lower floors of
the Reeves & Sons building, which is presently occupied by Arcola Theatre,
because sunlight is “not required”.
We disagree and consider that any current occupiers are temporary custodians of
the buildings and that their settings and amenities should be safeguarded for
future generations.
The proposed
development fails to give due consideration to its impact on the town centre
and surrounding listed buildings contrary to paragraphs 3.48 LPA’s Planning and
Design Guidance for the Western Curve and contrary to the LPA & GLA policies
and the NPPF
For these
reasons the application in its present form should be refused.
Public realm
The design of
the development misses the opportunity to set back further the development at
the Abbott Street junction which would both enhance pedestrian entry to Ashwin
Street and assist alignment of the pedestrian way across Kingsland High Street
between Abbott St and Boleyn Rd.
We consider
that the proposals fail to adequately respond to paragraph 3.64 of the LPA’s
Planning and Design guidance “to link the
site into existing local routes; reduce pedestrian congestion.and to improve
overall permeability and the pedestrian environment in Dalston town centre”
The 6-storey
height of the continuous terrace along the southern site obscures light to
Ashwin Street which is detrimental to the sun lighting of its ‘pavement café’
and pedestrianised use.
The proposal
is to remove some street trees from Ashwin Street ( to facilitate HGV
turnaround there) and to plant one tulip
tree and four small trees on Ashwin St west pavement and 5 small trees on Boleyn Rd. east pavement
and a mature plane tree and to provide planting pots on Boleyn Rd. west.
We consider
that the applicant’s description of such planting as creating a “green way” is derisory. The provision is
wholly inadequate given the extent of the applicant’s public land available to
create ‘pocket parks’ on each of the northern and southern sites to enhance the
public realm and to create ‘stepping stones’ of green oasis along the route
We consider
that the proposals fail to respond adequately to the LPA’s Planning and Design
guidance that “new and improved areas of
green open space and/or public realm will be encouraged subject to appropriate
design” and, to paragraph 3.64 for “public
spaces, small and large,…should be designed to integrate with the existing
fabric of the street and area…and new green public open space and or public
realm on the southern site..”.
OPEN Dalston
has had extensive discussion with the applicant and proposed designs which
would be compliant with the Guidance, the LPA’s & the London Plan and NPPF.
OPEN Dalston’s proposals are attached here and form part of these representations
and demonstrate the opportunities which
the applicant has missed in its application. The applicant has rejected these
proposals but has pursued an application which is non-compliant with planning
policies.
For these
reasons the application in its present form should be refused.
Gated Community
The Western Curve
sites are railway land owned by TfL, a public body. The scheme is subsidised by
a very substantial financial contribution by the local authority but the
development proposal makes no provision for public open or green spaces on the
sites nor provides for any public access into or through the sites. The
developments occupy the entire sites and creates a private enclave of almost
exclusively unaffordable homes for sale, with the minimal provision of green
and amenity space which is enclosed within the development and 90%
overshadowed. The design effectively creates a barrier between the development
and the rest of Dalston rather than an accessible mixed-tenure, diverse,
sustainable community.
For these
reasons the application in its present form should be refused.
Bio-diversity
The designs
miss the opportunity to enhance bi-diversity within the Dalston Town Centre by
the provision of managed green space and urban food growing , contrary to the
NPPF, the London Plan, the LPA’s Core strategy and the applicants own policies
and public commitments.
Provision for Children
The designs
make no provision for children’s play areas contrary to the NPPF, the London Plan and the LPA’s Core strategy
13.6.20
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