Stop The Blocks Community Action Group

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Daylight for everyone!

DAYLIGHT FOR EVERYONE’S HOMES, GARDENS, GREEN SPACES & PARKS

The proposed supporting guidance to the new London Plan covering the quality of homes for Londoners is proposing a drastic and controversial reduction in daylight to existing residents properties.

We are asking local residents to add their voice calling for the London Mayor to amend his proposed targets in the draft 'Good Quality Homes for all Londoners' consultation draft with regards to section C5.3 ‘Daylight, sunlight and overshadowing’ , which will allow developers to reduce the daylight benchmark on existing properties from 27% to 13% Vertical Skylight Component (VSC), and we believe will be an unacceptable harm to the health and wellbeing of existing communities.

The guidance for sun and daylight will be applicable not only in our homes, but also for green spaces, gardens and parks.

This current proposed draft guidance will allow developers to go much further than the original dismissed scheme for the Woodlands site proposed in terms of reduced daylight and sunlight which the planning inspector found on the whole to be unacceptable.

Parts of this draft London Plan guidance in relation to daylight, sunlight and overshadowing was developed in collaboration with Point 2 Consulting who were commissioned to act as the developer’s consultants on this subject for that original dismissed Woodland’s nursing home scheme.

Previously...

We asked and thankfully many responded to our request at short notice to write to London Assembly Member (AM) Marina Ahmad (Lambeth) asking her to support a crucial change to the draft guidance via the motion from AM Sian Berry which called upon the London Mayor to:

“Amend his London Plan draft supplementary guidance to include a requirement that London’s green spaces receive six hours of daylight on the two equinoxes each year and to retain the BRE guidance on daylight levels (Vertical Sky Component) at 27 per cent.”

The tabled motion also called for a standard of six hours sunlight on the two equinoxes each year. The current draft guidance only proposes as acceptable a minimum of two hours daylight for just 50 per cent of any outdoor space at the equinoxes. If applied to green spaces, this could result in them being overshadowed or in darkness for 22 hours a day in the spring and autumn, and in perpetual shadow in the depths of winter.

A short video clip which helpfully explained the issue and the debate that occurred can be found HERE

But this is not the end of it!

The motion to improve the current draft guidance was passed, however, it was clear from the debate and press coverage that the majority group abstaining on the motion may not have fully understood or grasped the issue. There is still a real risk that the efforts made to improving the guidelines could be sidelined.

We need you to write to your London Assembly Member please

We need everyone to write a or email or their London Assembly member to make sure that the motion that was passed leads to a real change in the London Plan supplementary draft guidance.

A sample letter which you can copy and tailor to your own circumstances which can be found HERE

An article in the Observer which demonstrated the impact on one family’s life can be found HERE

There is an online petition which can be found HERE calling for a change to planning policy to commit to giving London’s parks, playgrounds and green spaces for wildlife six hours of sunlight on 21st March of each year.

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London Plan March 2021

The London Plan 2021 is the Spatial Development Strategy for Greater London. It sets out a framework for how London will develop over the next 20-25 years and the Mayor’s vision for Good Growth.

The Plan is part of the statutory development plan for London, meaning that the policies in the Plan should inform decisions on planning applications across the capital. Borough’s Local Plans must be in ‘general conformity’ with the London Plan, ensuring that the planning system for London operates in a joined up way and reflects the overall strategy for how London can develop sustainably, which the London Plan sets out.

London Plan Guidance

The London Plan is supported by guidance, which provides further information about how the London Plan should be implemented.

Good Quality Homes for all Londoners - consultation draft (October 2020)

This document provides guidance for the interpretation of the London Plan with respect to designing sites for new housing and in Module C - Housing design standards, it gives guidance on daylight standards. The section is C5.3 ‘Daylight, sunlight and overshadowing’

This later section contains (according to the BRE) errors of interpretation of benchmarks and if adopted will lead to very low standards of daylighting. It will allow developers to reduce the daylight benchmark on existing properties from 27% to 13% VSC, potentially cutting the daylight standard anywhere in London by half, resulting in levels of gloom that will be unacceptable and harmful to the health of existing communities.

On 11 June 2021 at the London Assembly Plenary Meeting Assembly Member (AM) Sian Berry tabled, explained, and secured approval for a motion that called on the London Mayor to amend his “Good Quality Homes for all Londoners” draft guidance.

More daylight for gardens, green spaces, and parks!

Why is this important?

This current proposed draft guidance will allow developers to go much further than the original dismissed scheme for the Woodlands site proposed in terms of reduced daylight and sunlight.

Parts of this draft London Plan guidance in relation to daylight, sunlight and overshadowing was developed in collaboration with Point 2 Consulting who were commissioned to act as the developer’s consultants on this subject for the original former and dismissed Woodland’s nursing home scheme.

It would allow developers to reduce the daylight benchmark on existing properties from the current 27 per cent Vertical Skylight Component to 13 per cent, potentially cutting the daylight standard anywhere in London by half, which could be detrimental and harmful to the health and wellbeing of many communities.

The unacceptable harms often require detailed and exhaustive scrutiny to challenge and often disproportionately impacts the most vulnerable in the community.

Next Steps

Stop the Blocks Community Action Group (STB) alongside other parties is seeking to meet AM Marina Ahmad. We will be highlighting the very real unacceptable harms that this proposed shift will mean to residents facing typical high-density development schemes. The planning inspector at the Woodlands nursing home public inquiry detailed in his report the unacceptable harms of drastically reduced daylight for existing residents but fundamentally also to prospective residents.

A Special Thanks

Our gratitude and thanks to the volunteers at Lambeth Village who helped us with this subject and provided much information.

WRITE NOW!

Uphold Sian Berry's motion on daylight!

We need you to write to your London Assembly Member please

Even if you have written already to your London Assembly Member, we still need you to please. The easiest way is to email or complete the online webform HERE calling upon the London Assembly Member and their colleagues in the London Assembly to:

1. Uphold London Assembly Member Sian Berry’s motion on sun and daylight and embed her revisions into the London Plan draft supplementary planning guidance which was passed by motion at the London Assembly Plenary meeting on 10 June 2021

2. Not to allow the current unrevised draft London Plan supplementary planning guidance to come into effect without alteration to improve and maintain current standards on sun and daylight.

3. Understand your first-hand experience and views of what the currently unrevised London Plan draft supplementary guidance could mean to your own personal living conditions and wellbeing.

You can find a sample letter which you can tailor below

WRITE NOW!

Uphold Sian Berry's motion on daylight!

We need you to write to your London Assembly Member please

2. Not to allow the current unrevised draft London Plan supplementary planning guidance to come into effect without alteration to improve and maintain current standards on sun and daylight.

3. Understand your first-hand experience and views of what the currently unrevised London Plan draft supplementary guidance could mean to your own personal living conditions and wellbeing.

You can find a sample letter which you can tailor below

SAMPLE EMAIL LETTER

Please tailor and amend to suit...

To: marina.ahmad@london.gov.uk

CC: mayor@london.gov.uk

Dear London Assembly Member Marina Ahmad (for Lambeth and Southwark)

Re: London Mayor’s proposed sun and daylight targets in the draft 'Good Quality Homes for all Londoners' (consulted October 2020)

I wish to add my voice calling for the London Mayor to amend his proposed targets in the draft 'Good Quality Homes for all Londoners' consultation draft with regards to section C5.3 ‘Daylight, sunlight and overshadowing’ , which will allow developers to reduce the daylight benchmark on existing properties from 27% to 13% Vertical Skylight Component (VSC), and will be an unacceptable harm to the health and wellbeing of existing communities. The guidance for sun and daylight will be applicable not only in our homes, but also for green spaces, gardens and parks.

My Own Experience

I am resident at…. [Please add your details] and also explain your own experience and concerns on this matter.

London Assembly Member Sian Berry’s Motion

On 10 June 2021 at the London Assembly plenary meeting, Sian Berry the leader of the Green Party had a motion approved challenging the London Mayor on his proposed targets for sun and daylight in our parks and in our homes. You can find more details here and in summary it called for:

The London Mayor to amends his London Plan draft supplementary guidance to include a requirement that London’s green spaces receive six hours of daylight on the two equinoxes each year and to retain the BRE guidance on daylight levels (Vertical Sky Component) at 27 per cent.”

Whilst the motion was passed, the Labour Group abstained from supporting the motion and explained that the reason was that they wish for it to referred to a committee. However, the explanation offered by an assembly member for the Labour Group abstaining on the motion we believe does not accurately reflect how the proposed guidelines will in actual fact cut daylight standards for existing resident’s homes.

Former Woodlands Nursing Home site

I understand that just prior to the London Assembly Member elections you came to visit the site of the Woodlands Nursing home with Councillors Jon Davies and Cllr David Amos. You are aware that in January 2021 the planning inspectorate dismissed the appeal by the developer (Lifestory Group) to construct 258 units on the 0.51ha site.

One of the many reasons that the planning inspector rejected the proposed scheme for the Woodlands site was for the unacceptable harms to the level of sun and daylight that existing and prospective new residents would experience in their homes. It is those very low target levels (i.e. 13% vertical sky component) that the London Mayor is proposing to reduce daylight standards in the draft of his new 'Good Quality Homes for all Londoners' policy guidance for developers. This specific issue and its negative unacceptable harms it was determined by the planning inspectorate would have outweighed any public benefits and this example was flagged to the policy team on 21 February 2021.

This policy element appears to have been produced by the daylight consultants Point 2 that the developer for Woodlands used and who were also employed in the controversial 8 Albert Embankment scheme which also went to a public inquiry. The proposed guidance if approved could lead to residents to suffer the low levels of sun and daylight which were vehemently challenged in both cases and backed up with evidence and scrutinised by the planning inspectorate.

We respectfully request that you not to allow the current unrevised draft London Plan supplementary guidance to come into effect without alteration to improve and maintain current standards on sun and daylight.

Please support Sian Berry's motion to ensure that the London Mayors amends his London Plan draft supplementary guidance to include a requirement that London’s green spaces receive six hours of daylight on the two equinoxes each year and to retain the BRE guidance on daylight levels (Vertical Sky Component) at 27 per cent.”

Thank you in advance for your kind consideration of this matter.

Yours sincerely

[Your Name]

Daylight for everyone!

DAYLIGHT FOR EVERYONE’S HOMES, GARDENS, GREEN SPACES & PARKS

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Motion at the london assembly on Daylight for everyone

WRITE NOW!

Uphold Sian Berry's motion on daylight!

WRITE NOW!

Uphold Sian Berry's motion on daylight!

SAMPLE EMAIL LETTER

Please tailor and amend to suit...

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