Bishopsgate Goodsyard Reserved Matters Application - Plot 1
Reserved Matters Application - GLA reference 2023/0836
Objections submitted by the Boundary Tenants and Residents Association on the matter of excessive light pollution and harm to views from the Boundary Estate Conservation Area.
Visualisations of the development provided by the applicant suggest that the upper part of the development will be a glass box occupied by office workers. The entire mass will be brightly lit at night. This block is very close to the Boundary Estate comprising 600 council homes. The level of light pollution that will dominate the view from windows of a southern impact will be shocking.
Environmental Compliance Report - Townscape and Visual Impact Addendum
The report shows only one view from the Boundary Estate, labelled as “View 32 Proposed - Arnold Circus Roundabout: Boundary Gardens, southern steps, winter”. This is incorrect. It is actually the view in summer, not winter. Please compare with the 2019 outline planning application shown below. The 2019 winter view clearly shows a significant impact on the view from Arnold Circus.
The provided viewpoint is from street level. The impact will be greater at the raised top tier of Boundary Gardens which is a Historic England Registered Landscape. In 2019 this was described, at street level as a moderate to major change of view. The change of view from the top tier level will be drastic. See the attached empirical study using Avantgarde Tower as a comparator. At ground level, only the top 6 (out of 25) stories are visible: from Boundary Gardens, at about 5m above ground, the upper 15 stories are all clearly in view..
In summary - the view provided is inaccurate and highly misleading as to the impact on residents of the Boundary Estate.
(a) - the impact on flats with south and west facing windows will be most impacted not at street level, but at the upper floor levels of the estate blocks and at the upper tier of Boundary Gardens. This hasn’t been assessed.
(b) - in the view provided the impact is mostly mitigated by a tree full of leaves in daytime during the summer. As clearly shown in the 2019 study, the trees on the Boundary Estate shed their trees in winter when the impact will be far greater.
(c) - the impact of light pollution from office lighting can only be assessed from a night time view, not a day time view. A night view is not provided.
The impact of light pollution will be greatest when seen from dwellings on the higher floors, and from Boundary Gardens, in the winter, when the nights are long and the trees have no leaves. This is not addressed in the application.
To assess the increased impact from higher floors, and from the upper (bandstand) tier of Boundary Gardens, we have conducted a measured experiment, comparing views of the existing Avantgarde Tower
(a)that can be seen from street level above the roofline of Rochelle School
(b) that can be seen from bandstand level above the same roofline.
At ground level, the upper 5 storeys of the 25-storey Avantgarde tower can be seen from this position. Whereas from the top tier, 16 of the 25 storeys are all clearly visible, only the lowest nine stories not viewable. Any impact on the Boundary Estate should be considered at least from this top tier of Boundary Gardens. The uppermost floor views from south facing flats will be impacted even further.
Environmental Compliance Report - Chapter 8 - Daylight Sunlight, Overshadowing
The report indicates that no assessment was undertaken for Plot 1 in the 2019 outline application as the design was not known at that stage. But neither is one provided here. In the DSO report there is a very short section on light pollution 8.4.16-23 - only eight short paragraphs - with many inaccuracies.
8.4.18 “No technical assessments have been undertaken”.
The authors of the report rely on their ability to identify sensitive receptors, to which they apply ‘professional judgement’ . Not even a desk top study has been considered.
8.4.19 “sensitive receptors to light pollution have been identified”
Only three receptors are listed, none of which are in the Boundary Estate Conservation Area.
8.4.21 The proposed Plot 1 does not comprise highly glazed façade or office uses, which are most likely to result in significant light pollution effects.
This statement is just false. The development is for office floorspace on the upper floors with retail on the ground floor.. The night time illustration provided shows a highly glazed office spaces that are brightly illuminated at night.
..The lighting strategy has not yet been confirmed, however, it is understood that the proposed Plot 1 would not comprise high powered external lighting.
As the lighting strategy hasn’t been confirmed, how can an assessment of light pollution be carried out at all?
8.4.22 - mitigating measures. These comprise dimming of lights “post-curfew” and automatic office blinds. Neither of these measures would suffice and would be unenforceable. The very need to propose such mitigation betrays the expected impact.
On the basis of these observations we request that the application be REFUSED.
Boundary Tenants and Residents Association
℅ St Hilda’s East Community Centre
18 Club Row
London
E2 7EY
boundary.tra@gmail.com
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