BISHOPSGATE GOODSYARD

REVIEW OF DAYLIGHT AND SUNLIGHT IMPACT ON SURROUNDING RESIDENTIAL PROPERTIES

by Paul J Littlefair MA PhD CEng MCIBSE MSLL MILP

Principal Lighting Consultant

29 May 2015

BRE Bucknalls Lane

Garston Watford

WD25 9XX

Tel : 01923 664874 Fax : 01923 664010

Email : littlefairp@bre.co.uk

© Building Research Establishment Ltd 2015

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BISHOPSGATE GOODSYARD REVIEW OF DAYLIGHT AND SUNLIGHT IMPACT ON SURROUNDING RESIDENTIAL PROPERTIES by Paul J Littlefair MA PhD CEng MCIBSE MSLL Building Research Establishment 29 May 2015 SUMMARY

S1. A large new development is proposed on the Bishopsgate Goodsyard site in

Shoreditch. This report assesses the impact of the proposed development upon

the levels of daylight and sunlight received by neighbouring residential

properties. Because of the large number of buildings affected, it focuses only on

the worst affected ones. It does not address the levels of light in the proposed

residential buildings, artificial light pollution or reflected solar glare.

S2. I have not carried out any independent calculations of the loss of light; my

assessment has been based on the data provided by the developer’s

consultants GIA. I have assumed that these data have been calculated correctly.

My assessment has been carried out against the guidelines in the BRE Report

'Site layout planning for daylight and sunlight: a guide to good practice'.

S3. According to my assessment, loss of daylight would result in a major adverse

impact to 194-196 Shoreditch High Street,15 Bethnal Green Road (2A/2B

Chance Street), 17 Bethnal Green Road, 25 Bethnal Green Road (1 Club Row),

28-30 Bethnal Green Road, 32-42 Bethnal Green Road (Telford Homes), 93-99

Sclater Street, 100-106 Sclater Street, 2-4 Chance Street, 19-29 Redchurch

Street, 31-39 Redchurch Street, 48-50 Redchurch Street, 70 Redchurch Street,

119 Brick Lane, 1-16 Sheba Place, Eagle Works, Wheler House, 10 Quaker

Street, 154 Commercial Street (Hollywood Lofts), 167-169 Commercial Street,

25 Wheler Street and possibly 30-32 and 44, 46, 52, 54A Redchurch Street as

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well. Some of these buildings are blocks of flats with multiple dwellings, so over

200 homes are expected to be seriously affected.

S4. GIA’s data identify 1584 windows which would fail the BRE vertical sky

component guideline for loss of daylight, of which 873 would lose more than

double the guideline amount. This may be an underestimate, because this

review has identified dwellings at 192-193 Shoreditch High Street and 44, 52

and 54A Redchurch Street that could have been analysed too.

S5. The loss of sun is limited to areas to the north of the site, but a large number

of homes are nevertheless affected. There would be a major adverse effect on

sunlight to 194-196 Shoreditch High Street, 17 Bethnal Green Road, 25 Bethnal

Green Road (1 Club Row), 28-30 Bethnal Green Road, 32-42 Bethnal Green

Road (Telford Homes), 19-29 Redchurch Street, 119 Brick Lane and possibly 70

Redchurch Street as well. GIA’s results give 597 windows not meeting the BRE

guidelines for loss of sun, 470 of which would have a reduction of more than

double the recommended 20%.

S6. In addition to the major adverse impacts listed above, there would be a

moderate or minor adverse impact to many other properties in the local area;

these are detailed in the review.

S7. The BRE Report advocates a flexible approach to interpreting its own

guidelines, for example in areas with modern high rise buildings. However, in

this case the loss of light is particularly substantial for a very large number of

existing dwellings, and the resulting levels of daylight and sunlight are in many

cases well below what would be expected in an urban environment.

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1. INTRODUCTION

1.1 A large new development is proposed on the Bishopsgate Goodsyard site

in Shoreditch. The environmental statement for the development included a

chapter 11 ‘Daylight and sunlight, overshadowing, solar glare and light pollution’

written by Gordon Ingram Associates (GIA). This was accompanied by a series

of appendices.

1.2 The local residents’ groups the Goodsyard Action Group and Jago Action

Group have commissioned BRE to provide an independent assessment of the

daylight and sunlight aspects of the new development. In particular they were

concerned about loss of daylight and sunlight to nearby housing.

1.3 This assessment therefore covers loss of daylight to residential properties

only. It does not address the levels of light in the proposed residential buildings,

sunlight in open spaces, artificial light pollution or reflected solar glare.

1.4 The assessment included a site visit on 19 May 2015 to inspect surrounding

buildings that could be affected. During my site visit I was able to view the inside

of flats at 2-4 Chance Street, 19-29 and 31-39 Redchurch Street, and 192-193

Shoreditch High Street.

1.5 I have not carried out any independent calculations of the loss of light and

the assessment has been based on the data provided by GIA in the appendices

to the Environmental Statement. I have assumed that these data have been

calculated correctly.

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2. THE PROPOSED DEVELOPMENT

2.1 The proposed development includes a number of different buildings on a site

between Bethnal Green Road, Sclater Street, Brick Lane, the railway to the north

of Quaker Street, Commercial Street and Shoreditch High Street. Figure 1 shows

the development and the surrounding buildings.

Figure 1. Site plan by PLP Architecture. North is to the top of the plan. 2.2 Details of the proposal are given in a set of plans by PLP Architecture,

including a site plan 1207-A-M-021 dated 10.06.2014, and context elevations

1207-A-C-201 to 204 inclusive, also dated 10.06.2014.

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2.3 Large numbers of properties would be affected by the proposed scheme. For

example GIA’s data identify 1584 windows which would fail the BRE vertical sky

component guideline for loss of daylight. To make this review more manageable,

it has concentrated only on those properties which would suffer the worst loss of

light. It has not dealt in detail with minor adverse impacts to properties at 12-14,

23-28 and 30-32 Calvin Street, 12-14 and 23-27 Folgate Street, 10 Holywell

Lane, 33 Old Nichol Street and Daniel Gilbert House, all of which would have at

least one window or room failing the BRE guidelines.

2.4 The data in the Environmental Statement are difficult to follow because

results for particular streets are not always grouped together. In this review, the

assessment has been carried out on a street by street basis. Properties to the

west of the site have been assessed first (Shoreditch High Street area) then

those to the north (Sclater Street, Bethnal High Road and Redchurch Street

areas), then those to the east (Brick Lane area) and finally those to the south

(Quaker Street and Commercial Street areas).

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3. GUIDANCE ON LOSS OF LIGHT TO EXISTING BUILDINGS

3.1 To assess the loss of daylight to existing buildings nearby, GIA have referred

in the Environmental Statement to the BRE Report 'Site layout planning for

daylight and sunlight: a guide to good practice'. This guidance is widely used by

local authorities to help determine planning applications. It was revised in 2011.

3.2 To assess the impact on the amount of diffuse daylighting entering existing

buildings, the Report uses the vertical sky component (VSC) on the window wall.

The Report sets out two guidelines for vertical sky component:

1. If the vertical sky component at the centre of the existing window exceeds

27% with the new development in place, then enough sky light should still be

reaching the existing window.

2. If the vertical sky component with the new development is both less than 27%

and less than 0.8 times its former value, then the area lit by the window is likely

to appear more gloomy, and electric lighting will be needed for more of the time.

3.3 Appendix F of the BRE Report outlines ways in which alternative target

values for vertical sky component could be derived. Paragraph 11.80 of the

Environmental Statement refers to this. Paragraphs 11.81-11.83 state that

alternative vertical sky component targets have been derived ‘using the IPG

massing as an alternative baseline’. The IPG is understood to be the

Bishopsgate Goods Yard Interim Planning Guidance 2010, adopted by Hackney,

Tower Hamlets and the London Mayor.

3.4 In principle this is a reasonable approach. However the IPG does not give a

definitive massing. Although it states where tall buildings and lower buildings

would be expected, it does not give specific guidance on the height and width of

these buildings. Thus it is not clear how GIA actually derived the alternative

target values and what sort of massing they are based on.

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3.5 GIA’s alternative target values for buildings to the north of the site along

Sclater Street are low. 15% vertical sky component represents a continuous wall

of development opposite subtending a 45 degree angle in section. This appears

to contravene the guidance in the IPG which states that ‘Penetration of daylight

and sunlight should be encouraged by ensuring there is not a ‘wall’ of

development along the northern site edge’.

3.6 The clearest relevant guidance in the IPG is in its recommendations BG14

which states that ‘The location of tall buildings must not create unacceptable

impacts on the amenity of existing or future residents in terms of access to

daylight and sunlight’. This review has therefore aimed to assess that impact on

the residents using the BRE guidelines as a basis.

3.7 The BRE report also gives guidance on the distribution of light in existing

buildings, based on the areas of the working plane which can receive direct

skylight before and after. If this area is reduced to less than 0.8 times its value

before, then the distribution of light in the room is likely to be adversely affected,

and more of the room will appear poorly lit. This is referred to by GIA as the No

Sky Line (NSL) analysis.

3.8 These two guidelines address different aspects of the daylit environment in a

space. The vertical sky component relates to the amount of light entering the

room, while the no sky line relates to the way the light is distributed. A room can

experience an adverse effect if either guideline is not met. So for example, if the

amount of light entering the room is significantly reduced but the distribution

remains adequate, there would still be a significant effect on the daylight amenity

of the room.

3.9 For sunlight, the BRE Report recommends that for existing buildings checks

are carried out for all main living rooms of dwellings, and conservatories, if they

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have a window facing within 90° of due south. Access to sunlight should be

calculated for the main window of each of the above rooms which faces within

90° of due south. If the centre of the window can receive more than one quarter

of annual probable sunlight hours, including at least 5% of annual probable

sunlight hours in the winter months between 21 September and 21 March, then

the room should still receive enough sunlight. The 2011 revision of the guide

introduced another guideline, that if the year round loss of annual probable

sunlight hours does not exceed 4%, then the loss of sunlight is small.

3.10 The BRE Report also gives guidance on the classification of impacts, in its

Appendix I. This has also been quoted in the Environmental Statement. The

BRE Report states that ‘The assessment of impact will depend on a combination

of factors, and there is no simple rule of thumb that can be applied… Where the

loss of skylight or sunlight does not meet the guidelines in this book, the impact

is assessed as minor, moderate or major adverse. Factors tending towards a

minor adverse impact include:

• only a small number of windows or limited area of open space are

affected

• the loss of light is only marginally outside the guidelines

• an affected room has other sources of skylight or sunlight

• the affected building or open space only has a low level requirement for

skylight or sunlight

• there are particular reasons why an alternative, less stringent, guideline

should be applied.

Factors tending towards a major adverse impact include:

• a large number of windows or large area of open space are affected

• the loss of light is substantially outside the guidelines

• all the windows in a particular property are affected

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• the affected indoor or outdoor spaces have a particularly strong

requirement for skylight or sunlight, eg a living room in a dwelling or a children’s

playground.

4. ASSESSMENT OF LOSS OF LIGHT TO EXISTING RESIDENTIAL

PROPERTIES

4.1 Shoreditch High Street

4.1.1 Shoreditch High Street lies to the west of the site and properties on the

west side of it face slightly south of east towards the proposal site. Towards the

southern end of this part of the street, 221-222 appear to be in commercial use,

but number 223 onwards appear to have flats on the upper floors above

commercial uses.

4.1.2 The data for number 223 are labelled ‘ground floor’ in GIA’s tables but only

the first two windows in the table are on the ground floor. All except one of the

upper windows would experience a loss of daylight outside the BRE guidelines.

The impact would be assessed as moderate adverse, as these are expected to

constitute the main windows to each flat.

4.1.3 For number 224 loss of daylight on the first and second floors would be

outside the guidelines, while at number 225 loss of light to the first floor flat

would be outside the guidelines. The impact is assessed as minor adverse

because the resulting vertical sky components would be just below the

recommended 27%.

4.1.4 Loss of daylight to number 226 and properties to the south would be within

the guidelines. Loss of sunlight to this row of dwellings is small because the new

development would lie to the north east.

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4.1.5 Further north, 194-196 Shoreditch High Street (Figure 2) lie immediately to

the north of the railway line and would be directly opposite the proposed

development. There appear to be flats above commercial uses on the ground

floor.

Figure 2. 194-196 Shoreditch High Street.

4.1.6 Loss of daylight to these flats would be assessed as major adverse

because vertical sky components to all the windows on this side would drop by

40-45% in relative terms following development. For number 194 there would

also be a substantial adverse impact on the daylight distribution.

4.1.7 There would also be a major adverse loss of sunlight to these flats with

annual probable sunlight hours dropping by 50-70% in relative terms.

4.1.8 Across Holywell Lane, 192-193 Shoreditch High Street also contains flats

on the first, second, third and fourth floors. On the first and second floors the

spaces are open studio flats, while there is subdivision on the third and fourth

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floors into living rooms and bedrooms. However this building was omitted from

the Environmental Statement, presumably because it is currently covered in

scaffolding during refurbishment. Figure 3 shows this building before the

scaffolding was erected.

Figure 3. 192-193 Shoreditch High Street, before commencement of works.

4.1.9 Loss of daylight to at least some of the windows to these flats would be

expected to be outside the BRE guidelines, because this building would be more

affected than 191 next door. Loss of daylight to number 191 is assessed as

minor adverse, because one residential window is outside the guidelines.

Number 190 and properties to the north would be less affected.

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4.2 Great Eastern Street

4.2.1 1-7 Great Eastern Street adjoin 221-222 Shoreditch High Street (Figure 4).

One column of windows faces east but most of them face north east with an

oblique view of the new development. Loss of sky light to all these windows

would be outside the BRE guidelines, with relative vertical sky component losses

of 20-40%. The impact as assessed as moderate adverse, although there is a

case for assessing loss of daylight to number 1 as major adverse. Loss of

sunlight would be within the guidelines, partly because most of the relevant

windows face within 90 degrees of due north.

Figure 4. 1-7 and 11-17 Great Eastern Street. 221-222 Shoreditch High Street is

the dark coloured building to the left.

4.2.2 Further along, loss of daylight to the main windows of numbers 11-17

would be within the BRE guidelines. There is one column of windows for which

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there are significant losses. These windows are not shown on GIA’s window

map, but probably face into an internal lightwell. The significance of this loss of

light would depend on the usage of these rooms.

4.3 Bethnal Green Road

4.3.1 Bethnal Green Road lies to the north of the site. This area is changing with

a range of new housing developments currently under construction.

4.3.2 1-13 Bethnal Green Road are in commercial use. Number 13 has been

analysed by GIA; it is currently in use as a hotel and would have a substantial

loss of light, with a number of windows having their vertical sky components and

sunlight hours reduced to a tenth of their current values.

4.3.3 Immediately to the east, between Ebor Street and Chance Street, is the

Huntington Estate. This is an industrial estate but is the subject of a planning

application for a large housing scheme. The latest application has been refused

but it is understood that either an appeal or a revised scheme is likely. Given the

loss of light to the adjoining properties, daylight and sunlight to any future flats

on this site would be significantly compromised by the Goodsyard development.

4.3.4 The next building has been analysed by GIA as 15 Bethnal Green Road,

but the doors are labelled 2A and 2B Chance Street (Figure 5).

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Figure 5. 2A and 2B Chance Street. Bethnal Green Road is to the right.

4.3.5 The top floor is understood to be in residential use (a window is just visible

at the top of Figure 5). The main windows face south towards the proposed

development. These windows would lose around half their daylight, resulting in a

major adverse impact. Loss of sunlight is assessed as minor adverse, because

although the living room would lose half its sun, the resulting annual probable

sunlight hours would exceed the recommended 25%.

4.3.6 17 Bethnal Green Road appears to have residential use above a café.

Loss of daylight to the residential windows is assessed as major adverse; these

windows lose around two thirds of their light and for all but one room there would

also be a significant impact on daylight distribution. There would also be a

substantial loss of sunlight to these rooms.

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4.3.7 The next building has been analysed by GIA as 25 Bethnal Green Road,

but the doors are labelled 1 Club Row. There is a restaurant on the ground floor

but the upper floors are understood to be residential (Figure 6).The windows

facing into Bethnal Green Road would have a substantial loss of daylight and

sunlight, with vertical sky components and annual probable sunlight hours

dropping by over 60% in relative terms. For the windows facing Club Row, loss

of daylight would be within the BRE guidelines, but there would still be a major

loss of sunlight.

Figure 6. 1 Club Row/25 Bethnal Green Road, taken from the south.

4.3.8 Paragraph 11.579 of the Environmental Statement points out that ‘this

property is situated behind the newly constructed Telford Homes scheme and

therefore many of the windows do not achieve 27% VSC in the Existing

Baseline. This, therefore, makes them more sensitive to any increase in massing

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on the Goodsyard site.’ Although this is possibly intended as a justification for

the loss of light, in reality it makes the situation worse for the residents of 25

Bethnal Green Road/ 1 Club Row. Having recently lost light due to the Telford

Homes scheme (at 32-42 Bethnal Green Road, see below), they would then

have another, even larger loss of light due to the Goodsyard. The net effect

would be to lose around three quarters or more of their light within a few years.

4.3.9 28-30 Bethnal Green Road (Figure 7) occupies a site at the corner of

Sclater Street. It is understood to have flats on the first, second and third floors.

Loss of daylight and sunlight to the Sclater Street elevation would be very

severe, with reductions to between a fifth and a quarter of their current values.

The impact is assessed as major adverse.

Figure 7. 28-30 Bethnal Green Road, taken from Sclater Street.

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4.3.10 32-42 Bethnal Green Road (described as Telford Homes in the

Environmental Statement) comprises a major new development on land between

Bethnal Green Road, Sclater Street, Cygnet Street, Bacon Street and Brick

Lane. At the time of my site visit the development appeared to have been

completed and occupied.

4.3.11 The elevation facing south into Sclater Street (part of Block A in the

Environmental Statement) would be directly opposite the proposed development

(Figure 8). Rooms facing this way would lose 60-80% of their daylight and

sunlight.

Figure 8. The section of 32-42 Bethnal Green Road (Telford Homes Block A)

facing into Sclater Street.

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4.3.12 Behind this elevation is a tall tower (the Avant Garde tower). Most rooms

on the south east side of this tower would have a significant loss of daylight (20-

80%), which varies according to the location of the room, its level, and whether it

has a balcony above it which blocks light from the sky.

4.3.13 On the Cygnet Street side of this part of the development is a linking

block. There are rooms on this block which face west and south west towards

the development site. Many of these windows would have a significant loss of

daylight and some living rooms would have a significant loss of sunlight too.

4.3.14 The other part of this development (Block B) would be less affected as it

is further away, but there would still be a sizeable number of windows with a

significant loss of daylight. These are mostly on the façade facing south towards

the new development across Bacon Street.

4.3.15 According to the Environmental Statement, 535 windows in Block A and

29 in Block B would fail the BRE guidelines for vertical sky component, with 349

windows in Block A and 3 in Block B having losses more than twice that

recommended. This constitutes a major adverse impact on the development as a

whole.

4.3.16 The Environmental Statement also states that 374 windows in Block A

and 6 in Block B would fail the BRE guidelines for annual probable sunlight

hours. It does not differentiate between living rooms and other rooms, but

nevertheless this constitutes a major adverse impact.

4.3.17 The Environmental Statement also gives detailed analysis for 65-66

Bethnal Green Road, which is described as a commercial building. It is not clear

where this building is, as it is not marked on the maps in the appendices and no

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window map is given. According to the data, there would be a substantial loss of

daylight and sunlight to a large number of windows.

4.4 Sclater Street

4.4.1 Sclater Street borders the northern edge of the eastern part of the site.

Flats at 93-103 Sclater Street (odd numbers) face south and would be directly

opposite the new development. In numbers 93-101, loss of light to all main

windows on this side would be outside the BRE guidelines. For numbers 93-99

the impact is assessed as major adverse because all windows would have

losses well in excess of the guidelines (30-40%). For number 101 the impact is

assessed as moderate adverse, while for number 103 it is assessed as minor

adverse because only one room fails the guidelines, for impact on daylight

distribution. Windows to these properties would continue to receive enough

sunlight with the new development in place.

4.4.2 The rear of 100-106 Sclater Street (even numbers) would also face the

proposed development. Loss of daylight to these windows is assessed as major

adverse; nearly all of them would lose over a third of their light. Loss of sunlight

is assessed as minor adverse; two dining rooms would marginally fail the

guidelines.

4.4.3 A new development is under construction next to 93 Sclater Street, on the

site of a car park between Sclater Street, Cygnet Street and Bacon Street. Loss

of light to this development does not appear to have been taken into account in

the Environmental Statement. There would be flats with an elevation on Sclater

Street (see the planning application PA/13/02529). Loss of daylight to these

flats, once completed, would be expected to be similar to, or worse than, that for

93 Sclater Street.

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4.4.4 Across Sclater Street, next to number 100, is another vacant site, which

adjoins the Goodsyard site but does not appear to be part of it. Planning

permission (PA/05/2010) was given for flats here in 2005, but this has since

lapsed. If the Goodsyard development went ahead, it would be difficult for future

residential development on this site to receive enough daylight.

4.5 Chance Street

4.5.1 The loss of light to 2A and 2B Chance Street has already been addressed

in paragraphs 4.3.4 and 4.3.5.

4.5.2 Further north, 2-4 Chance Street (Figure 9) consists of a second floor flat

above an artist’s studio. The main windows to this flat face south towards the

proposed development and would have a substantial loss of light, with vertical

sky components around a quarter of their existing values (though some light is

blocked by the existing overhang). There would also be a significant loss of

sunlight to the living space.

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Figure 9. 2-4 Chance Street. Windows to the second floor flat are under the

large overhang.

4.5.3 Further north still, across Redchurch Street, 14 Chance Street has

windows facing due south towards the proposed development. Loss of daylight

and sunlight to these windows would be well outside the BRE guidelines

although this is partly due to the design of the windows which are heavily

recessed.

4.5.4 Across the road, 11-17 Chance Street would be less affected. Loss of

daylight would be within the guidelines, though loss of winter sun to one window

would be outside the guidelines.

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4.6 Club Row

4.6.1 The loss of light to 1 Club Row has already been addressed in paragraph

4.3.7.

4.6.2 Across Whitby Street, 3 Club Row (Figure 10) is understood to be in

residential use. Windows at the side of this building face into Whitby Street,

southwards towards the proposed development. There would be a significant

loss of daylight and sunlight for most of these windows, with vertical sky

components and annual probable sunlight hours dropping by 20-40% in relative

terms. The loss of daylight and sunlight is assessed as moderate adverse.

However these windows have recently experienced another substantial loss of

light due to construction of the Telford Homes scheme, so the cumulative impact

of the two schemes would be major adverse.

Figure 10. Residential windows to 3 Club Row, taken from the corner with

Whitby Street.

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4.7 Redchurch Street

4.7.1 Two blocks north of the proposed development, Redchurch Street runs

east-west. Odd numbered properties face due south into Redchurch Street and

towards the proposed development site. For even numbered properties, the rear

windows face south towards the proposal site.

4.7.2 Loss of daylight and sunlight to 5-7 and 11-13 Redchurch Street would be

within the BRE guidelines. (These flats would have a limited view of the

proposed development because they are already obstructed by the Tea Building

opposite). In 15-17 Redchurch Street four rooms would have a significant impact

on their daylight distribution, though loss of sun would be within the guidelines.

4.7.3 At the other end of Redchurch Street, loss of daylight to numbers 49-65

would be within the guidelines. Loss of annual sun would also be within the

guidelines though there would be a significant loss of winter sun to some

windows in numbers 57-63.

4.7.4 The main loss of light would be to dwellings in the central part of

Redchurch Street. 19-29 Redchurch Street (Figure 11) incorporates flats on the

second, third and fourth floors with commercial use on the ground and first

floors. Loss of daylight to all the south facing windows would be outside the BRE

guidelines. The relative loss would be very bad (around 90%) for those windows

on the second and third floors which are recessed or fitted with overhangs; these

rooms would also have a big impact on daylight distribution and lose nearly all

their sunlight. However the other windows would still have a relative daylight

loss of 30-35%, well outside the guidelines. Loss of daylight and sunlight is

assessed as major adverse.

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Figure 11. 19-29 Redchurch Street (middle of picture).

4.7.5 31-39 Redchurch Street (Figure 12) currently has flats on the second and

third floors. Loss of daylight to all the south facing windows would be well

outside the BRE guidelines, with relative losses of around 35%. Daylight loss is

assessed as major adverse because all these windows are affected including

main living rooms. The windows would retain enough sunlight to meet the

guidelines with the new development in place.

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Figure 12. 31-39 Redchurch Street. The first floor has been in commercial use

but is being converted into flats.

4.7.6 31-39 Redchurch Street is currently being refurbished, with planning

permission for flats on the first floor and conversion on the upper floors resulting

in some other residential windows. They have not been analysed in the

Environmental Statement, but loss of daylight and sunlight to these windows is

expected to be similar to those already analysed in this building.

4.7.7 41-43 Redchurch Street is understood to be residential on the upper floors.

Loss of daylight to ten windows, all facing south towards the new development,

would be outside the BRE guidelines. The impact is assessed as moderate

adverse. The windows would retain enough sunlight to meet the guidelines with

the new development in place.

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4.7.8 45-47 Redchurch Street are believed to contain flats above commercial

uses. Loss of daylight would be outside the guidelines for two windows at each

address. The impact is assessed as minor adverse. Most of the windows would

retain enough sunlight to meet the guidelines with the new development in

place, though there would be a significant loss of winter sun to one window.

4.7.9 The rear of 30-38 Redchurch Street would face the proposed development.

All the windows at the rear of 30-32 (except for one which apparently has no

daylight at all) would have a significant loss of vertical sky component as well as

a substantial impact on their daylight distribution. Loss of daylight could be

classed as major adverse if they light main rooms. For 36 and 38, loss of

daylight would be well outside the BRE guidelines for two windows. There would

be a loss of winter sun outside the guidelines for nine windows in 30-38, with a

significant loss of annual sun to one window, in number 32.

4.7.10 The rear of 48-50 Redchurch Street (Figure 13) has been assessed in the

Environmental Statement. All the south facing windows would have a substantial

loss of daylight (39-49% in relative terms). The windows would retain enough

sunlight to meet the guidelines with the new development in place.

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Figure 13. Rear of 48-50 Redchurch Street, taken from Whitby Street.

4.7.11 According to council tax registers, there are also flats at numbers 44, 46,

52 and 54A nearby. Loss of light to their windows should have been analysed as

well; in the Environmental Statement only one window, in number 46, has been

assessed. The impact on daylight is expected to be similar to that for 48-50

Redchurch Street.

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4.7.12 The rear of 70 Redchurch Street (Figure 14) has rear windows with a

view of the proposal site. These windows are already obstructed by buildings in

Bethnal Green Road, and by overhangs above some of them. There would be

substantial losses of daylight, (relative losses of 25-99% in vertical sky

component), and of sunlight, though it is not known whether these windows light

main living rooms.

Figure 14. Rear of 70 Redchurch Street (centre of picture), taken from Club

Row.

4.8 Brick Lane

4.8.1 Brick Lane runs to the west of the proposal site. Only a short section of the

road has dwellings which could be significantly affected by it. In this section, odd

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numbered properties are nearest to the site and their rear windows face towards

it. Even numbered properties face the site across Brick Lane.

4.8.2 131-139 Brick Lane (odd numbers) lie to the north of the proposal site. The

impact on daylight would be minor (one window in number 135 not meeting the

vertical sky component guidelines). The impact on sunlight would be more

marked, with four windows in number 135 failing the annual sunlight guidelines

and one in each of numbers 133, 135 and 139 failing the winter guideline only.

4.8.3 125A and 127A Brick Lane, at the corner of Sclater Street, would meet the

daylight guidelines but four windows (in three rooms) would fail the winter

sunlight guideline.

4.8.4 119 Brick Lane, the closest to the new development, is much more

affected. It would lose around 40% of the current daylight and 50-70% of the

current sunlight to its rear windows.

4.8.5 On the other side of the street, loss of daylight and sunlight to 182-200

Brick Lane would largely be within the guidelines, except for an adverse impact

on daylight distribution to two rooms in 184-186 and one in 188. 180 Brick Lane

would have two bedrooms failing the vertical sky component and daylight

distribution guidelines, and a further bedroom and kitchen failing just the daylight

distribution guideline. All the front windows to number 178 would have a

significant loss of daylight. Loss of sunlight is not an issue for 178-180 as the

relevant windows face slightly north of due west.

4.8.6 For the portion of Brick Lane south of the railway viaduct, loss of sunlight is

not an issue as the relevant windows face north of due west. There would be a

significant loss of daylight, as measured by the vertical sky component, to two

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rooms in number 174 and one in number 176. Loss of light to even numbers

156-172 would be within the guidelines.

4.8.7 97-105 Brick Lane (Figure 15) is part of a newer development which goes

round into Quaker Street (see below). There would be a significant loss of

vertical sky component to 22 windows and an additional two rooms would have a

significant impact on their daylight distribution. The impact is assessed as

moderate adverse because, despite the number of rooms affected, the relative

reductions are not as large as for other properties.

Figure 15. The portion of 97-105 Brick Lane nearest to the proposal site (to the

left). View of rear windows.

4.9 Quaker Street

4.9.1 Quaker Street runs east-west to the south of the proposed development.

Loss of sunlight to dwellings there is not an issue because the new development

lies to the north.

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4.9.2 62-76 and 78 Quaker Street form part of the same development as 97-105

Brick Lane. A large number of windows and rooms would have significant

impacts on either vertical sky component or daylight distribution or both. The

impact is assessed as moderate adverse because, despite the number of rooms

affected, the relative reductions are not as large as for other properties.

4.9.3 1-16 Sheba Place also forms part of this development. It would be closer to

the proposed development and the loss of daylight would be more severe, with

relative reductions in vertical sky component of 20-95% for a large number of

windows. The impact is assessed as major adverse.

4.9.4 Further west is the Eagle Works development (described as Eagle House

in the Environmental Statement). A large number of windows would have a

substantial loss of light, with typical relative reductions in vertical sky component

of 30-45%. The impact is assessed as major adverse.

4.9.4 Across Quaker Street, 41 and 43-47 Quaker Street are already obstructed

by the Eagle Works development and thus the relative impact of the proposed

development would be less. One room in number 41 would have a significant

impact on its daylight distribution, and three windows in 43-47 would have a

significant loss of vertical sky component. The impact is assessed as minor

adverse.

4.9.5 Further west, Wheler House (Figure 16) would be more severely affected,

with relative losses of 20-80% of vertical sky component. Nearly all the windows

facing the proposed development would have a significant loss of light. The size

of the relative loss is made worse by the existing access decks which block

some light from the sky, but most of the windows without an access deck above

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would have significant losses of light too. The impact is assessed as major

adverse.

Figure 16. Wheler House.

4.9.6 10 Quaker Street (Figure 17) is a block of flats close to the proposal site.

Loss of light to windows facing the proposed development would be severe, with

relative reductions in vertical sky component of 55-60% for most of these

windows, together with impacts on daylight distribution. The impact is assessed

as major adverse.

34

Figure 17. 10 Quaker Street.

4.9.7 The Hollywood Lofts development, which looks out onto Quaker Street, is

dealt with under Commercial Street, below.

4.10 Commercial Street

4.10.1 Despite its name, Commercial Street contains a number of residential

properties that would be adversely affected. At number 154, the Hollywood Lofts

development (Figure 18) occupies the corner site with Quaker Street, and its

Quaker Street façade would have the biggest loss of daylight, with reductions in

vertical sky component of 35-60% for a large number of windows. The impact is

assessed as major adverse.

35

Figure 18. 154 Commercial Street (Hollywood Lofts). The Quaker Street façade,

which would be the most badly affected, is on the left of the picture.

4.10.2 Across Commercial Street, Burhan Uddin House is a block of flats

converted from a former police station. There would be a significant loss of light

to windows at the north west end of this building. Though losses of vertical sky

component to these windows are marked (over 40% in some cases), the impact

is assessed as moderate adverse because fewer windows are affected than in

some other buildings.

4.10.3 Properties further to the south east would be less affected. At 159

Commercial Street ten windows would have a significant loss of vertical sky

component, and at 148-150 five windows would. At 132 and 157, loss of light

would meet the guidelines.

4.10.4 167 and 169 Commercial Street consist of flats above commercial use.

There would be a severe loss of light to windows facing into Commercial Street,

36

with typical relative reductions of 55-60% in vertical sky component. The impact

is assessed as major adverse.

4.11 Elder Street and Fleur de Lis Street

4.11.1 Elder Street runs south from Commercial Street. Most of the dwellings in

this street do not face the new development directly and would have a negligible

loss of light. However 1-3 Elder Street would be adversely affected, because this

building has windows facing north across Fleur de Lis Street towards the

development site. A large number of windows would fail the BRE guidelines for

vertical sky component but the impact is assessed as moderate adverse

because, despite the number of rooms affected, the relative reductions are not

as large as for other properties.

4.11.2 8 Fleur de Lis Street faces in the same direction. Five windows would not

meet the guidance for vertical sky component. The impact is assessed as minor

adverse.

4.12 Wheler Street

4.12.1 Wheler Street runs south from Quaker Street to Commercial Street. Most

windows in 6 Wheler Street and 23-24 Wheler Street do not directly face the

development site and they would be less affected, with one window failing the

guidelines in number 6 and two in 23-24.

4.12.2 However there would be a bigger impact on 25 Wheler Street (Figure 19),

on the corner with Quaker Street. This is particularly bad on the ground floor

where windows with an overhang above them could lose nearly all their daylight.

However a lot of other windows would also have significant losses of daylight.

The overall impact is assessed as major adverse.

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Figure 19. 25 Wheler Street.

5. CONCLUSIONS

5.1 Table 1 summarises the impacts of the new development on daylight to

windows in the worst affected surrounding residential properties (those with a

moderate or major adverse impact). Properties with a minor adverse impact, for

example at 12-14, 23-28 and 30-32 Calvin Street, 12-14 and 23-27 Folgate

Street, 10 Holywell Lane, 33 Old Nichol Street, Daniel Gilbert House, 191 and

224 Shoreditch High Street, 11-17 Great Eastern Street,103 Sclater Street, 15-

17 Redchurch Street, 45-47 Redchurch Street, 131-139, 174-180 and 184-188

Brick Lane, 41-47 Quaker Street, 148-150 and 159 Commercial Street, 8 Fleur

de Lis Street and 6 and 23-24 Wheler Street have not been included in the

table. For comparison, GIA’s impact ratings in the Environmental Statement are

also given.

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Table 1. Summary of impacts on daylight.

Address Impact on skylight (BRE assessment)

Impact on skylight (taken from Environmental Statement assessment)

223 Shoreditch High Street

Moderate adverse Minor/Moderate adverse

194-196 Shoreditch High Street

Major adverse Moderate/Major adverse

192-193 Shoreditch High Street

Moderate adverse? Not analysed

1-7 Great Eastern Street

Moderate adverse Minor/Moderate adverse

15 Bethnal Green Road (2A/2B Chance Street)

Major adverse Moderate adverse

17 Bethnal Green Road

Major adverse Moderate/Major adverse

25 Bethnal Green Road (1 Club Row)

Major adverse Moderate adverse

28-30 Bethnal Green Road

Major adverse Moderate adverse

32-42 Bethnal Green Road (Telford Homes)

Major adverse Moderate/Major adverse

93-99 Sclater Street Major adverse Minor/Moderate/ Major adverse

101 Sclater Street Moderate adverse Moderate adverse 100-106 Sclater Street

Major adverse Minor/Moderate/ Major adverse

2-4 Chance Street Major adverse Minor/Moderate adverse

14 Chance Street Moderate adverse Moderate adverse 3 Club Row Moderate adverse Moderate adverse 19-29 Redchurch Street

Major adverse Moderate/Major adverse

31-39 Redchurch Street

Major adverse Moderate adverse

41-43 Redchurch Street

Moderate adverse Minor/Moderate adverse

30-32 Redchurch Street

Major adverse? Moderate/Major adverse

39

36-38 Redchurch Street

Moderate adverse Minor adverse

48-50 Redchurch Street

Major adverse Moderate adverse

44, 46, 52, 54A Redchurch Street

Moderate/Major adverse?

Moderate adverse (only 46 analysed)

70 Redchurch Street Major adverse Major adverse 119 Brick Lane Major adverse Moderate adverse 97-105 Brick Lane Moderate adverse Moderate adverse 62-78 Quaker Street Moderate adverse Minor adverse 1-16 Sheba Place Major adverse Major adverse Eagle Works Major adverse Minor/Moderate

adverse Wheler House Major adverse Moderate/major

adverse 10 Quaker Street Major adverse Moderate/major

adverse 154 Commercial Road (Hollywood Lofts)

Major adverse Moderate adverse

Burhan Uddin House Moderate adverse Moderate adverse 167-169 Commercial Street

Major adverse Moderate/major adverse

1-3 Elder Street Moderate adverse Minor adverse 25 Wheler Street Major adverse Moderate adverse

5.2 An unusual feature of the assessment is the very large number of properties

which would have a major adverse impact. GIA have been less rigorous in their

interpretation of impact, but still assess a major or moderate/major impact for

most of these properties. GIA’s data identify 1584 windows which would fail the

BRE vertical sky component guideline for loss of daylight, of which 873 would

lose more than double the guideline amount. This may be an underestimate

because this review has identified dwellings at 192-193 Shoreditch High Street

and 44, 52 and 54A Redchurch Street that could have been analysed too.

5.3 According to the above review, properties with a major adverse impact

comprise 194-196 Shoreditch High Street,15 Bethnal Green Road (2A/2B

Chance Street), 17 Bethnal Green Road, 25 Bethnal Green Road (1 Club Row),

40

28-30 Bethnal Green Road, 32-42 Bethnal Green Road (Telford Homes), 93-99

Sclater Street, 100-106 Sclater Street, 2-4 Chance Street, 19-29 Redchurch

Street, 31-39 Redchurch Street, 48-50 Redchurch Street, 70 Redchurch Street,

119 Brick Lane, 1-16 Sheba Place, Eagle Works, Wheler House, 10 Quaker

Street, 154 Commercial Road (Hollywood Lofts), 167-169 Commercial Street, 25

Wheler Street and possibly 30-32 and 44, 46, 52, 54A Redchurch Street as well.

Some of these buildings are blocks of flats with multiple dwellings, so over 200

homes are expected to be seriously affected.

5.4 GIA have attempted in some cases to justify the large losses of light by

comparison with an ‘alternative baseline’ based on the Bishopsgate Goods Yard

Interim Planning Guidance. However the IPG does not give a definitive massing,

and the alternative target values for daylight to buildings to the north of the site

are low, appearing to contravene the guidance in the IPG. Even then, loss of

light for many properties is substantially worse than these alternative targets

would allow.

5.5 Table 2 summarises the impacts on sunlight. Again dwellings which would

have a negligible or minor adverse impact, or those to the south of the site which

would not normally be assessed, have been omitted.

Table 2. Summary of impacts on sunlight.

Address Impact on sunlight (BRE assessment)

Impact on sunlight (taken from Environmental Statement assessment)

194-196 Shoreditch High Street

Major adverse Moderate/Major adverse

17 Bethnal Green Road

Major adverse Major adverse

25 Bethnal Green Road (1 Club Row)

Major adverse Major adverse

28-30 Bethnal Green Major adverse Major adverse

41

Road 32-42 Bethnal Green Road (Telford Homes)

Major adverse Moderate/Major adverse

2-4 Chance Street Moderate adverse Moderate adverse 14 Chance Street Moderate adverse Moderate/Major

adverse 3 Club Row Moderate adverse Major adverse 19-29 Redchurch Street

Major adverse Major adverse

30-32 Redchurch Street

Moderate adverse? Minor/Moderate/ Major adverse

70 Redchurch Street Major adverse? Major adverse 119 Brick Lane Major adverse Major adverse 135 Brick Lane Moderate adverse Moderate/Major

adverse

5.6 According to the above review, there would be a major adverse effect on

sunlight to 194-196 Shoreditch High Street, 17 Bethnal Green Road, 25 Bethnal

Green Road (1 Club Row), 28-30 Bethnal Green Road, 32-42 Bethnal Green

Road (Telford Homes), 19-29 Redchurch Street, 119 Brick Lane and possibly 70

Redchurch Street as well. The loss of sun is limited to areas to the north of the

site, but a large number of homes are nevertheless affected. GIA’s results give

597 windows not meeting the BRE guidelines for loss of sun, 470 of which would

have a reduction of more than double the recommended 20%.

5.7 In addition to the effect on existing residents, the new development would

also substantially reduce the daylight and sunlight available to surrounding sites

currently being planned or under construction, including the Huntington Estate,

Cygnet Street car park and land next to 102 Sclater Street. This would make it

more difficult for residents of future developments to have adequate daylight and

sunlight in their homes.

5.8 Given the substantial impact on so many properties, the concluding

statements in the chapter and in the Environmental Statement Non-Technical

42

Summary (NTS) are misleading. The NTS starts by saying ‘The Proposed

Development has evolved throughout the design process to ensure that it has a

minimal effect on the daylight, sunlight and overshadowing amenity’, the second

part of which is clearly untrue. It adds that ‘However, the detailed strategic

approach to the architectural structure of the scheme has ensured that where

possible BRE compliance is either achieved or that the levels of retained light

are commensurate with an inner urban location’. This statement is also untrue.

The NTS arbitrarily selects 18% vertical sky component as characteristic of an

inner urban location, but according to its own figures over a thousand windows

for which loss of light fails the BRE guidelines would end up with a vertical sky

component of less than 18%.

5.9 In assessing the impact on daylight, paragraph 11.763 of the Environmental

Statement (reproduced in the NTS), states that ‘Overall, out of the 162

properties assessed for daylight, 78 (48%) will experience a negligible impact,

46 (28%) a minor adverse impact, 6 (%) a minor to moderate adverse impact, 20

(12%) a moderate adverse impact, 8 (5%) a moderate to major adverse impact

and 5 (3%) a major adverse impact’. This is misleading because it implies that

only 5 households would have a major adverse impact and 8 a moderate to

major adverse impact. In reality these two categories actually cover over 200

homes, because some of the ‘properties’ affected are large blocks of flats.

5.10 There is a similar misleading statement on sunlight in the Environmental

Statement: ‘In terms of sunlight, out of the 112 properties assessed, 67 (60%)

will experience a negligible impact, 13 (12%) a minor adverse impact, 5 (4%) a

minor to moderate adverse impact, 10 (9%) a moderate adverse impact, 6 (5%)

a moderate to major impact and 11 (9%) a major adverse impact’. In reality the

16 ‘properties’ with either a major, or moderate to major, adverse impact

comprise well over 100 homes.

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A1. APPENDIX: QUALIFICATIONS AND EXPERIENCE A1.1 My name is Paul Jeffrey Littlefair and I have been working on daylighting

and related issues at the Building Research Establishment, Garston, Watford

WD25 9XX, since 1979. BRE is the UK’s foremost construction research

organisation. It was formerly part of the Department of the Environment and is

now owned by the BRE Trust, a registered charity. In 1984 I was awarded a PhD

for work carried out at BRE. The title of my thesis was ‘Daylighting design and

energy conservation’. In 1988 I became a member of the Chartered Institution of

Building Services Engineers (the professional institution responsible for interior

lighting) and am a Chartered Engineer. I was a founder member of the Society of

Light and Lighting, and am a member of the Institution of Lighting Professionals.

A1.2 I have published over 100 papers on daylight and related issues and wrote

part of the British Standard Code of Practice on daylight and the CIBSE Lighting

Guide ‘Daylighting and window design’. The effect of building layout on interior

daylight, particularly in existing buildings, is one of my specialised subjects. In

1991 I wrote ‘Site layout planning for daylight and sunlight’, for the Department

of the Environment, which is widely used by developers and planning authorities

to help determine the loss of light to existing buildings. I revised this document in

2011.

A1.3 I am BRE’s specialist on Rights to Light issues, and have carried out over

250 studies of the loss of light to existing buildings.

This report is made on behalf of BRE. By receiving the report and acting on it, the client - or any third party relying on it - accepts that no individual is personally liable in contract, tort or breach of statutory duty (including negligence).