OPEN's representations to the Inspector at the DAAP Examination in Public


Dalston Area Action Plan Examination in Public

OPEN’s Response to Issues raised by Inspector Paul Clark, BA, MA, MRTPI. 

We believe that it is a fundamental principle of the National Planning Policy Framework that local plans shall:
-        - reflect the vision and aspiration of local communities, with whom there should be early and        meaningful engagement (150 and 155)
-       - be aspirational but realistic(154)
-       - contain a clear strategy for enhancing the natural, built and historic environment (157)
-       - be based on adequate, up-to-date and relevant evidence ( 158)
-       - pay careful attention to viability and costs in plan-making and decision taking. Plans should be deliverable (173)
-       - minimizing impacts on biodiversity and providing net gains in biodiversity (109)

For the following reasons we submit that aspects of the DAAP which we have considered are unsound and are not legally compliant.

Eastern Curve

The DAAP proposes that linkage can be “punched through” between Dalston Square and the Shopping Centre by the creation of a new “shopping circuit” along the route of the Eastern Curve.
The proposal is unsound and not legally compliant.

1              The proposal now for adoption is not the proposal which the public was consulted on in 2009. Consequently it is not legally compliant.The proposal for the site in the 2009 draft DAAP, page 52, provided for  Dalston Park – “a  largely green open space with a series of inter-linked spaces of different character and atmosphere… could be a major play space” The shopping circuit proposal now for adoption,  page 55, is a “series of inter-linked spaces  (that could accommodate areas of green space).. a pedestrian & cycle route... shops, cafes ….Close to this could be a play space”.
The proposal for adoption is so significantly different from the 2009 proposal consulted upon as to be barely recognisable. It is constructive to compare the DAAP Eastern Curve illustrations: in 2009 (Page 43, Figure 5.2) and 2012 ( Page 47 Figure) the “shopping circuit” in the latter extending the entire length of Eastern Curve

2              The Eastern Curve is land safeguarded for strategic railway purposes. The DAAP proposal would involve constructing a slab over all or part of the railway cutting. In 2009 it was recognized that engineering advice would be required to asses cost and feasibility. No such evidence has been produced since then confirming that the proposal would be technically feasible or financially viable. ( As an indication, the slab over the Dalston Junction station cutting cost between £39m and £63m, albeit to support higher loadings) 
NOTE: Hackney advised the Inspector that TfL have released the Eastern Curve from its 'safeguarded' designation and has sold part of the site to Hackney and the remainder to the owner of the Dalston Shopping Centre. 

3              Strategic Perspectives ‘Retail Centre Study’ July 2011 advised the LPA, at paragraph 2.50, that “the 2005 Retail and Leisure Study should be updated as a priority, as it will provide an important evidence base needed to inform the emerging AAPs…to identify any changes to shopping and leisure patterns over the last 6 years”. The 7-year old report has not been updated and the economic environment has since changed dramatically. The lack of occupation of commercial units in Dalston Square is indicative of over optimistic expectations and low demand. It may be argued that this is symptomatic of temporary current economic conditions but the scheme also faces competition from the largest shopping centre in Europe, at Westfield Stratford, which  is 15 minutes by train from Dalston Kingslandand the growth of internet shopping. Furthermore we understand that Stratford City shopping centre is to undergo redevelopment. We consider that, even if investment could be attracted, retail development of the Eastern Curve for national multiples will result in vacant commercial units and blight for a considerable period.

4              We consider that development of the Eastern Curve as a “shopping circuit” will draw footfall away from the High Street which would be detrimental to the independent businesses there which the LPA states it is seeking to support. Further it will draw footfall away from, and render less viable, Dalston Square where the commercial units built were intended to attract national multiples of the type now proposed for a re-developed Shopping Centre, but which still remain empty.

5              For the above reasons we consider that the proposal for an Eastern Curve Shopping Circuit, whilst aspirational, is unrealistic and is unsupported by any evidence that it is deliverable. Adoption of the proposal would therefore be contrary to NPPF.

6              The development proposed in the DAAP for the site area (notably Thames House) would result in significant loss of sunlight to wide areas of the site for considerable periods. The LPA has not disclosed evidence to the contrary. Such overshadowing would be detrimental to a new area of public realm.

7              Since public consultation on the DAAP closed in 2009 the Eastern Curve has been brought back into the public use. In November 2009 a planning application 2009/2510 to build a structure for community use and gateway to the rear open space was granted. Since June 2010 the site has been managed as a temporary community garden with facilities for holding local events. It is an essential community resource.

8              The Garden has increased footfall in the Town Centre considerably and contributed to Dalston’s reputation as a destination with a beneficial impact on existing local businesses. 50,000 visitors to the year ending October 2011 and this will increase by between 50-100% in the current yea

9              The Garden is the only open green space in the Town Centre.Its’ exemplary design resulted in its selection as the Winner of the President’s Award in the 2011 Landscape Institute Awards. The Institute commented that “The eco-garden with new barn to host community events ….has provided a much-needed green oasis.”  More recently the Garden took part in the Chelsea Fringe Festival and was visited by HRH Camilla, Duchess of Cornwall.

10           Development of the Eastern Curve as a new ‘shopping circuit’ would be incompatible with the existing usage and, contrary to NPPF, result in the loss of biodiversity and  the only green open space in the Town Centre absent alternative provision (of which none is proposed in the DAAP).

Site C, Peacocks site at 51- 57 Kingsland Road

11           Site C, at 51-57 Kingsland Road, is on a historic high street where the buildings are generally of 3-4 storeys in height. The site neighbours Dalston Kingsland station and overlooks the high street entrance to Ridley Road market. The site provides a large footprint suitable for a larger retailer and offers an opportunity to replace the existing unremarkable building with an imaginative modern design, which could achieve the greater development potential of the site subject to remaining respectful of its surroundings and which also offers the opportunity to improve the appearance and amenity of the public realm.

12           The neighbouring Dalston Kingsland overground railway station is a single storey structure fronting the Kingsland High Street. The station entrance building forms an unnatural break in the street’s roof line and the entrance therefore has potential for development to that roof line.

13           OPEN considers that the DAAP proposal for Site C ( 4-6 storeys fronting the High Street and 10 – 15 storeys to the rear) neither meets the DAAP policy objectives nor complies with the NPPF. The proposal would amount to overdevelopment which would be to the detriment of the surrounding area.

14           The site has recently been the subject of a development application broadly in line with the DAAP proposal although rising to 18 storeys at the rear of the site. The application was widely opposed by the local community and unanimously rejected by the Committee. We attach, as an Appendix 1, OPENs written objections to that application which apply equally to the DAAP proposal. In summary:

15           Density :The application site is not specifically identified for intense housing development in the London Plan or identified as essential to meet the LPAs housing targets.  The 18-storey/130 dwelling proposal had a density of 2,117 hr/ha - almost double the upper London Plan range of  650<1100 hr/ha

16           Height: Due to local engineering constraints, there is limited opportunity to site other tall buildings locally. The development will not form part of a cluster of tall buildings but will appear as an isolated and incongruous addition to a historic high street. It would not confer a “sense of place” but a “sense of out of place”.

17           Consultation: The draft 2009 DAAP for public consultation purposes, identified the site as having a potential for 4-6 storeys on the high street rising to up to 10 storeys to the rear. A development of 15-storeys has not been the subject of public consultation.

18           Historic Assets: A 6-storey high street frontage, without any stepping back of the upper storeys, would exceed the roof lines of the current High Street to the detriment of nearby historic assets.This, and a 15 storey tower behind, would dominate & thereby diminish their significanceand harm their views and settings contrary to NPPF. The historic assets comprise Rio Cinema, 74-78 Kingsland High Street, Grade II Listed Colvestone Primary School,37-49 Kingsland Road (a 1902/3 terraced group which includes the Grade2 listed building at 41 Kingsland High Street and The Kingsland public househas recently been recommended for local listing by English Heritage. We attach English Heritage letter and photographs illustrating the detriment of the proposal.
       
19           Any building over four storeys on the high street frontage would be taller than its surroundings and so of prominent landmark appearance. A taller building is not necessary to achieve that objective.

20           Overshadowing: A tower would create both long and wide shadows over large areas of Dalston Kingsland. It will obscure light from public space, local homes and roof gardens, businesses, locally listed buildings and from Ridley Road market.A specialist consultant opined of Bradbury Mews that “an open aspect would be transformed to life in a shadow zone”.

21           Wind acceleration: The Applicant’s wind consultant’s identified that the development would create accelerated windspeeds locally in public areas so as to render them unsuitable for standing. It states in particular that “localised zones of acceleration have been identified where the criteriafor safety for all pedestrian including sensitive pedestrians and cyclists is exceeded”.

22           The characterful period buildings of Boleyn Road (south of Crossway), have all been carefully restored and developed to a human scale. A tower on Site C would be an incongruous presence which would dominate an area of micro-regeneration and creativity (Gillett Square & Bradbury St). 

23           We consider that a tower to the rear of site C would severely compromise Boleyn Road and its future development potential. We attach a photograph illustrating this detriment.

24           Overdevelopment: We consider that a tower on Site C would amount to overdevelopment of the site by reason of its excessive scale, mass, height and density to the extent of damaging Kingsland High Street’s local character and identity. Several indicators, as described above, support this conclusion.


Western Curve sites D1, D2 and H

25           Dalston is one of the most dense wards in Hackney which is in turn one of the most dense boroughs in London. Its density is not mitigated by any significant areas of permanent open green space. The DAAP focuses on housing and retail development to the detriment of any practical proposals for mitigating the deficit in open green space and for improvements to the public realm of the Western Curve. 

26           The principal landowners of development sites in the Town Centre, TfL and Hackney Council, have made no proposals to utilize any part of any their vacant demolished sites in the Town Centre for such use.  This is detrimental to the DAAP policies for improvement in the public realm.

27           Dalston’s diverse demographic has seen a significant and rapid increase of young entrepreneurs in the creative sector. The local economy has responded with a rapid growth in its entertainment/leisure, night time and ‘boutique’ retail offer. With the improved transport links, Dalston has become a destination attracting that demographic. It is not a generic Town centre requiring generic provision. We consider that a better retail strategy would be to encourage the development of open and covered daytime and evening markets. (Chalk Farm/Camden Lock is a successful example of this strategy). Sites on the Western Curve may well be suitable for these uses.

Sites D1 and D2 : the Western Curve

28           Taylor Wimpey have recently presented proposals for these sites to a core group of local professionals. We attach, as an Appendix 2, a summary of the views expressed.
We confine the comments here to the issue of building heights.

The Northern site (Kingsland Rd/Boleyn Rd)

29           Buildings of six storeys fronting the site, absent stepping back of upper storeys, would give the appearance of overscale. Deeper setbacks of upper floors could mitigate this and achieve adequate quantum of development compatible with surroundings.

30           The Boleyn Rd/High Street junction is acknowledged not to be a landmark site but (absent set back) a 6 storey frontage to the high street proposed in the DAAP would dominate the surroundings, including its listed buildings and in particular the terraced group of four storey heritage buildings at 37-49 Kingsland Road, referred to above, which are immediately to the north.

31           Similarly there would be imbalance with the buildings on the south and west side of Boleyn Road( 2-4 storeys).

32           Six storeys would take afternoon and evening light from the northern part of the site, particularly the area covered above the tunnel which has the least commercial development potential and which therefore presents an opportunity of public amenity green open space. It would further take light from areas to the rear of 37-49 Kingsland Road.

33           It follows from the above that Taylor Wimpey proposal for increasing the height of buildings on the site to 8 storeys is inappropriate

The Southern site (Kingsland Rd/Ashwin St)

34           A six-storey building on the Kingsland Rd/Ashwin Street site would enclose and conceal the attractive elevations of the Reeves Printhouse/Colourworks (a listed building), Shiloh Church and 12 Ashwin Street buildings which, since demolition of the single storey buildings on the site, are presently fully visible from the High Street.

35           The height generally will take afternoon and evening light from Ashwin Street and make it much less attractive than presently.

36           The enclosure of Ashwin Street would amplify sound generated by the night-time businesses of Café Oto, Arcola Theatre and Bootstrap, and daytime uses of Shiloh Church, which could be incompatible, and create social tensions, with residential uses of the upper floors of any new development.

37           A six-storey building extending fully to the north end of the site would mean that the approach along Abbot Street would be narrow and unattractive, presenting a blind corner - quite threatening at night - and give no indication of the activity further round Ashwin Street at Arcola Theatre, Café Oto and Bootstrap.

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