Dalston Area Action Plan - OPEN’s supplementary representations to Inspector conducting the DAAP Inquiry in Public: regarding “Shadow Analysis Report” of Matrix Partnership Urban Design

Dalston Area Action Plan Examination in Public

OPEN’s representations to Inspector Paul Clark, BA, MA, MRTPI  regarding “Shadow Analysis Report” of Matrix Partnership Urban Design   

1             This submission is confined to the issue of potential overshadowing identified  by Matrix in its report on the DAAP.
2             The Matrix Report analyses the potential overshadowing/sunlighting impact of tall buildings proposed for the Dalston Shopping Centre and Peacocks site at 51-57 Kingsland Road. The analysis is with reference to the BRE test that “no more than 2/5ths and preferably no more than 1 /4 of any garden or amenity area should be prevented from receiving any sun at all on the 21st March.”

3             Matrix comment on the BRE test that “It is important to notice that the area-based guideline is very much a minimum standard. It will not guarantee large amounts of sun in summer, or any sun at all in winter” (our emphasis)

4             Matrix comment that the test is often applied to gardens (including private gardens), allotments, parks, public squares, focal points for views etc. The Report focuses on Ridley Road Market, Bradbury Street and Gillett Square.

5             The report does not comment on the proposed development of the Eastern Curve (identified in the Core Strategy Table 8.2 as a Linear Park) however this area is illustrated in the diagrams and some conclusions can be drawn from these.

6             Matrix’s analysis proceeds from assumptions regarding the total extent of the amenity area to be considered for the purpose of calculating the percentage of that area which would be adversely affected by overshadowing. The analysis makes no distinction regarding the importance of sunlight to any particular parts of the area. For example it takes the entire length of Ridley Road and identifies that at the Vernal Equinox 35< 36.4% of that length will be overshadowed by existing and proposed developments and it concludes that Ridley Road as a whole would therefore meet the BRE threshold for compliance.

7             The Report does not place the overshadowing impacts identified within the context of other relevant policies of the:-
-        Council’s Core Strategy eg Policy 13 to enhance environmental quality of Town Centres and Policy 14 to protect and secure improvements to the Ridley Market environment and
-       DAAP Policies DTC 04 1(b) and  DTC23 1 (h) and DTC – CA 2 which prescribe against the overshadowing of Ridley Road Market (and the Eastern Curve) and  DTC 11 1 c) to avoid excessive overshadowing to the public realm generally.

8             Site Analysis

8.1 Gillett Square and Bradbury Street :
The Report identifies that these two amenity areas are lined with three storey buildings on their south sides and that potential overshadowing would not overreach shadowing already created by existing buildings on the Vernal Equinox.
8.2 Bradbuy Mews:
This terrace of residential homes with gardens are on the south side of Bradbury Street and currently have an open aspect facing south towards the existing Peacocks site.
The Matrix illustrations demonstrate that with the proposed tall building on the Peacocks site the homes would be cast into shade for periods ranging from 10am until between approximately 2pm to 4pm throughout the year save for the period around the Summer Solstice
8.3 Ridley Road:
The Kingsland Road entrance to the market presently suffers some limited overshadowing to its south side from the existing shopping centre.
The Matrix illustrations demonstrate that with the proposed redevelopment of the Shopping Centre the vast majority of the entrance area of the market, extending from Kingsland Road to the junction with Colvestone Crescent, will be cast into permanent shadow save for a period around the Summer Solstice. Further the entire length of Ridley Road market will be in permanent shadow in the period around the Winter Solstice and by 6pm in the periods of the Vernal and Autumnal Equinox.
8.4 Eastern Curve:  
The Matrix illustrations demonstrate that with the addition of the proposed buildings overlooking the Eastern Curve ( from the redeveloped Thames House site and th shopping centre) the southern ( Dalston Lane) end of the Eastern Curve will throughout the year experience extensive overshadowing from the proposed buildings, that throughout the year sunlight exceeding 50% of its area will be limited to a couple of hours in mid-afternoon ( although the position is improved over the Summer Solstice) and that  it is in permanent shade over the Winter Solstice period.          
8.5 Historic Assets:
We have identified these in our earlier submission but the Matrix Report does not include them for specific analysis. We consider that there will be an overshadowing effect arising from the proposed developments on 74-78 Kingsland High Street, Grade II Listed Colvestone Primary School which will be detrimental to their settings

9                   Conclusion

9.1 The DAAP places particular emphasis on preserving and improving the environment of Ridely Road Market and the Eastern Curve.
9.2  The Matrix Report describes the overshadowing effect of the proposed buildings following their placement in optimum location to mitigate overshadowing eg on the southern side of the proposed redeveloped shopping centre. Notwithstanding this the overshadowing effect is detrimental to the local environments studied.
9.3 The western entrance to the market is of particular importance because it is the ‘gateway’ to the market from Dalston’s primary shopping frontage of Kingsland Road. Development of the proposed buildings would result in overshadowing of the market’s entrance to such an extent that it would conflict with policies in the DAAP which are designed to protect its environment.
9.4 The Eastern Curve is presently Dalston’s only public green open space. It’s original designation had been as Dalston Park but following amendments made, after public consultation closed, it has been proposed as a “shopping circuit” with some (undefined)  areas designated for amenity use. Development of the proposed buildings would result in overshadowing of the Eastern Curve to such an extent that it would conflict with policies in the DAAP which are designed to protect its environment.
9.5 In these circumstance we consider that the DAAP’s prescription of a specific range of building heights for the Dalston Shopping Centre, the Peacocks site and the Eastern Curve creates  conflict with the other DAAP policies referred to in paragraph 7 above We consider therefore that reference to particular building heights for these sites  should be removed from the DAAP, in particular Figure 8 at page 38,  so that any particular development application would therefore be considered in its own merits and with regard to its compliance with the DAAP and Core policies generally.  


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