Overlooking – Areton Limited

Our proposed development is minor in nature because

1 it does not increase the footprint of the building. The footprint of the building remains unchanged.

Key Legal Principle: No Material Harm = No Grounds for Refusal

Under planning law, planning permission should be granted unless the development causes material harm

Because this minor building alteration does not increase the footprint:

It does not lead to loss of garden/amenity space, overdevelopment, or drainage/flooding issues.
It improves the appearance of the building, and clearly its physical impact at ground level stays the same — which is often key for neighbouring amenity and site constraints.

Secondary legal principle: the fact that the footprint remains unchanged means there’s no intensified land use, and thus no risk of breaching local spatial policies or causing material harm.

2 It does not increase the top height of the building.

No Increase in Height = No Additional Impact on Neighbors

From a planning law perspective, building height is a material consideration. The new flat roof:

Does not exceed the original ridge height,
Does not increase overshadowing, loss of light, or loss of outlook as amply demontrated.

Then there is no material harm to neighbouring properties

Legal principle: A development that does not materially harm neighbouring amenity is generally permissible under planning law.

3 This minor development involves only minor changes to the external envelope of the building. In this case only increase in height is a two edges of the extension while the top height of th eextension is unchanged.

In planning law, a local planning authority can only refuse an application if the proposal causes material planning harm or conflicts with the local development plan.

In this case:

The overall extension height remains unchanged, which means:
- No new overshadowing or daylight, as proven extensively with the relevant studies
- No increase in visual dominance. This is evident and self explanatory, especially due to the height of the extension remaining unchanged.
- The change to two edge heights is a minor design variation within the original massing of the building.

Therefore, there is no material harm, and under UK planning law (and similarly in many legal systems), that means the application should be permitted.

This minor development does not breach local policy ( it is perfectly in line with it as amply demonstrated) , and there are no overriding material considerations against it — Threfore it should be approved.

Minor External Changes = Minor Development

This proposal involves:

No increase in footprint
No increase in ridge/top height
Only minor height adjustment to part of the extension to match it with th etop height of the original extension.

This type of development is often classified as “minor” in planning terms, meaning:

It falls well below the scale of development that would have strategic or cumulative impacts
It is to be assessed primarily on design, appearance, and impact on neighbours, not major policy issues.

The Design and appearance has been discussed at length and it is clear that not only is this a substantial improvement, but while it fits really well in this area it is mainly hidden by the sorrounding houses of Harold Street and Castle Street.

Since it does not negatively affect any neighbouring properties, amenity, character, or infrastructure as amply demonstrated , there is no lawful basis to refuse it.

No Impact on Neighbouring Amenity or Character

Visual continuity is maintained, as the top height stays the same
The bulk and form of the building are largely unchanged
It would not feel significantly different to observers or neighbours. However it is a significant improvement and most of the extension is hidden from view by the sorrounding house which are one storey higher than the extension (even with the new proposed flat roof).

This aligns with core national and local planning principles (such as the NPPF in England, which emphasizes good design without stifling innovation or minor architectural changes).

Overlooking.

Overlooking is one of the policies matters that needs to be taken into consideration in a general full planning application.

As we will see this minor development causes no “material harm” to the existing houses in terms of privacy and overlooking. In some cases, not only does it not cause any material harm, but the new window openings are well over 20 metres away from any habitable room window not causing overlooking in the first place.

Duplicating Existing Overlooking.

If other windows in the building or nearby already overlook the same area (e.g., a garden or window), adding another similar window doesn’t cause harm in a legally significant way. In such cases the impact is considered neutral or minimal, and therefore non-material.

To summarise the windows on the extension are allowable because:

1 there are already existing windows in the extension overlooking directly both properties facing Harold Street and Castle street. Therefore the addition of further windows on upper levels facing the same direction will not cause loss of privacy.

2 in the case of the properties facing castle street the distance between the extension and the back windows of the uninhabitable rooms on the ground floor is over 20 meters. Therefore even in case no existing windows were present in the existing extension the long distance allows brand new windows to be placed on this side of the extension because when the distance is over 20 metres, as we will see below, directly facing windows are not considered to cause loss of privacy due to the distance alone.

3 even in case of the absence of existing windows in the extension there is ample pre exising loss of privacy from the other windows of neighbouring properties.

For these reasins which we be exploring in detail below the windows in the extension are all allawable.

The legal concept of “material harm”.

“One cannot lose something he does not have. Someone cannot have less than something he did not have in the first place.” In our context you either have privacy or you do not have it. if you do not have privacy you cannot lose more privacy.

When it cones to a view though a window you are either being seen from another window at a distance or you are not seen at all. Once you are seen then you have to take measures to avoind being seen no matter how many more windows there might be later on watching into your window. There maybe partial viw or direct frontal view , if you are concerned about people seeing you you will have to use curtains , blinds etc. It is not as if there is apartial viw than then you would use half curtains of see throguh curtains, you would use the same curtains in the same way.

The concept of “no material harm” or “material Harm” in law is a well known legal tool which has to be used in court in order to prove that damage of some sort had been caused by any third party.

This Legal tool is used in several legal realms.

In commercial law, non-compliance of certain products with a regulatory framework, the “non-material harm” principle is used to decide whether to bring prosecutions or not. In case no accidents or damage has been caused, it is usually agreed upon that a court case is wasteful as the product did not cause any harm and it could become compliant later. In courts one of the first tests to be passed is “any material Harm been caused”?

This is also the first test that has to be passed in civil and sometimes also in criminal court. Without being able to prove any “material harm”, rarely can court cases be successful.

For example, in a civil legal dispute where there is no direct indirect financial loss, that dispute cannot be brought successfully to court. This is because the court will ask to prove damages and calculate the financial co0mpensation. Without any financial loss or “material harm”, no financial reward can be awarded. Therefore, any civil court case that does not pass the “material harm” test is very unlikely to be brought successfully to court.

In order to be successful in court, “material harm” has to be proven first. First, it has to be proven that whatever breach of contract, regulation, action, event etc. directly or indirectly caused “material harm”, for example, a financial loss that otherwise would not have occurred. The concept of material harm is also used in criminal court and the judge or prosecutor usually takes the view that for minor infractions that do not cause any “material harm” court time shall not be used and a, warning letter or corrective action to conform with regulations (for example) may suffice.

The same also applies in planning, of course. It is well known that in planning where “no material harm” has been caused by a development, any objection based on any matter that does not cause any “material harm”is not an admissible objection to reject the planning application.

A “material harm” has to be proven to cause the planning application to be successfully rejected based on an objection. The only valid objections in planning are those which demonstrate the harm that will be caused by the development. Where harm is not demonstrated, such objections are not valid. If an objection is made that does not meet the test of “material harm” and the planning application is rejected on an objection that does not prove “material harm” then the planning rejection can be successfully overturned at appeal.

Duplicating Overlooking is Permitted

No Additional Material Harm

Planning authorities and and especially courts focus on whether a proposal makes things worse in a way that is legally significant. If overlooking already exists ist is well established that there is no net loss of privacy, and hence no “material harm”.

In case of this minor building alteration

If nearby windows already overlook a certain area:

That area is considered to be already exposed to overlooking, and residents have a reasonable expectation of reduced privacy. A new window duplicating this view is seen as within acceptable planning norms, especially in urban or semi-urban settings like in this specific area.

Planning Policy and Consistency

Planning decisions must be made based on material planning considerations. A new window that mirrors existing conditions does not cross that line. Otherwise, every building with more than one window facing a neighbour could be challenged.

If there is already an established loss of privacy, extra window openings generally cause “no-material harm”.

If there is already an established loss of privacy in the backyards and/or there is a direct existing view into back windows, it is expected that measures have already been taken by the residents due to lack of privacy caused by existing surrounding buildings. Any further development or window opening does not cause an increase in loss of privacy. An existing development has either privacy or it has not. For example, if there is only one overlooking window, the residents are required to preserve their privacy using curtains on their windows and other measures. This does not change if the overlooking windows are three instead of two. The same measures for privacy preservation have to be taken, whether there is 2 or 4 or multiple overlooking windows. Therefore, any new window opening overlooking the same area clearly does not cause any “material harm”.

In other words, once the loss of privacy is already established, the residents have to use curtains, blinds etc, and they have to be aware of the overlooking in the same way before and after any new overlooking window/s are installed. However, in our minor development, the increase in overlooking is very minor as this is an existing building where there is a slight increase in size and number of windows.

Some of the properties of castle street, as we will see, not only had a clear established loss of privacy, but some new windows will be placed at a distance well superior to 20 meters from a habitable room window. The 20-metre standard is a well-known adopted design standard and in several cases in densely built central area this 20-metre distance is also relaxed to a distance even less than 20 m. Otherwise, essential required development would not take place where it is clearly needed.

Therefore, as it has been seen by several planning cases where there is clearly “no material harm” caused by the development, any objection is easily dismissed at appeal or even in planning court. Should a refusal of planning permission be based on any excuse or objection which constitutes “no material harm,” this will be challenged and easily overcome on appeal or even in planning courts (if required).

Any additional windows both facing Harold street and Castle street on the extension are permissible.

The proposed windows do not introduce any new or materially harmful overlooking, as similar views are already present from existing windows within the property and surrounding buildings.

The area potentially visible from the new windows is already subject to overlooking from existing, legally established windows as we will see in this document. Therefore, the additional windows do not create any material loss of privacy.

It is understood that under planning policy, only material planning considerations may be grounds for refusal. Subjective concerns or personal discomfort, where no measurable impact exists, fall under non-material considerations and should not influence the decision as it is clear and very well demonstrated in this case.

In urban and suburban settings, a degree of mutual overlooking is an accepted and typical part of the built environment. As this proposal does not cause any material harm in term of overlookoiing and privacu concerns in any way, and does not impact any previously private or secluded areas, therefgore it is amply demonstrated that any additional windows in the extension are permissible from a planning perspective.

The existing windows and door openings in the existing extension.

Pre-existing windows and entrance doors in the existing extension are facing both the back of the properties facing Castle street and Harold street. And the view is direct into those properties.

There are already previously bricked up windows and an entrance door on both sides of the extension. These can be reopened any time without planning permission and they already provide a clear view into all the properties and windows at the back of the houses facing both Harold Street and Castle Street. Therefore, any extra window openings on the ground and first floor height on both sides of the extension will not cause any “material harm” by definition.

In the existing extension there are recently bricked up windows and doors both facing the properties of Harold Street and Castle Street. It is clear to see from the brick work that those have been bricked up recently. This was due to the lack of security posed by those openings in the extension. These allowed easy and hidden access to intruders, vandals etc. The openings of the extension provided easy and hidden access to intruders and this was the reason for closing them up Therefore, past occupiers preferred bricking up the openings to increase security of the building. Therefore, these are existing windows and entrances can be reopened any time without the need . These entrances and windows provide direct views from the ground floor into all the properties in Castle Street and Harold Street.

In connection with the properties facing Harold Street, the first loss of privacy is caused by the window openings and the entrances in the existing extension. As we will see, these openings have caused the loss of privacy to the properties facing Harold Street, but not those facing Castle Street. This is because the rear extensions of the properties facing Castle Street are at a distance of over 20 meters to our extension. the distance between the extension and the first floor back room windows of the properties facing Castle Street is approximately 24 meters.

Hence, in connection with the properties facing Castle Street:

1 any new window opening on our extension both at ground floor and first floor level do not cause any loss of privacy due to the distance exceeding the minimum requirement of 15 meters in highly dense areas (where the site is located ) but even 20 and 24 meters respectively.

2 any new windows on both ground and first floor extension are a simple addition to previously pre-existing windows.

3 even if these openings in the extension caused any loss of privacy (which they do not). There is an already established loss of privacy caused by another existing property due to the first windows overlooking into the rear of all the properties facing castle street. This will be examined in detail shortly.

Even without the existing rights to the window openings in the extension, as we will see any new window opening on either side of the extension does not cause material harm to any neighboring property. This is because the overlooking already exists from the main building and other properties. This exising overlooking is a normal feature of city centre areas where this type of overlooking is also acceptable nowadays from a planning perspective.

The existing view into the back of the properties facing Castle Street from adjacent properties.

As we have seen above, the extension has pre-existing windows and door openings which look directly into the back of the properties facing castle street. However, given the distance from the extension to the back of the properties facing castle street, no addition to the windows in the extension both on the ground floor and first floor can cause any loss of privacy.

However, the loss of privacy has already been caused, not by the windows in the extension, but by the adjacent property overlooking into the backyards and back windows of the properties facing castle street. These windows are at a distance well below the 20 meters and in some instances even less than the 15 metres threshold in city centres. However this level of overlooking , as we mentioned erier, is allowable because the rules for overlooking are relaxed due to the site location in a dense popu;ated city centre area.

To summarise, even if the windows and door in the extension were not previously present, any new windows both at ground and first floor levels of the extension would be allowable because:

1 The distance from the extension to the closest window on the ground floor (non-habitable) of any property facing Castle Street is over 20 metres. The distance to the nearest habitable room window on the first floor is over 24 metres. As we can see in our development, the windows are 20.2 metre away from the closest ground floor window and approximately 24 metres away from the first floor windows, which are considered habitable. This clearly passes the standard test for overlooking. This is especially due to the fact that the allowable distance in the city center can be relaxed down to 15 metres. Therefore, any new window openings on the extension are allowable.

2 More importantly, there is a much more invasive overlooking issue from the first floor windows of the nearby property. This is the cause of the established loss of privacy of the properties facing castle street.

In essense the proposed windows are duplicates of existing ones and face an elevation where overlooking is already established. A separation distance of over 20 metres from any habitable room window is mainte=ainred, in line with established privacy standards. Therefore, the proposal does not result in material harm to residential amenity.

Loss of privacy objections/overlooking. Where the loss of privacy has already occurred.

In case the existing windows of preexisting buildings have already caused a loss of privacy, the residents are already in loss of privacy and are assumed to have taken all possible measures to prevent the neighbours from overlooking, like using of blinds, curtains etc.

Where there has already been a previous loss of privacy, any additions of windows that are overlooking the same existing estates will not cause a further loss in privacy. This is because the affected residents will be required to take the exact same measures to prevent overlooking into their private dwellings. The test is, with or without development, will the residents reasonably need to take the same or similar measures to preserve their privacy?

Therefore, where a loss of privacy is already established, the addition of overlooking windows clearly do not constitute any “material harm”. If, before and after the development, the residents have to take the same measures as before to avoid being seen through the windows, then there is clearly “no material harm” caused by the development. On the contrary, if after the development, the residents require curtains and blinds to avoid overlooking which was not previously required, then “material harm” from the new development can be argued.

What is the minimum distance between directly facing windows?

Usually the allowable distance between habitable room windows that are facing directly one another is 20 meters for suburbs. This is a very common standard used in planning for several years, and therefore this minimum distance has long been considered acceptable from a planning perspective.

The overlooking issue is more stringent into sleeping quarters. Sleeping quarters are usually located on the first floor. However, the minimum distance requirement is not as stringent when new windows look into kitchens and diners. There are even less stringent the overlooking issue into backyards.

The same privilege of right to privacy is not afforded in the same way to non-habitable room windows, like kitchens and sometimes dining and living rooms. Therefore, in suburbs the minimum distance can be less than 20 meters if the window is to a habitable space.

It has to be borne in mind first of all that it is customary for habitable rooms to be located on the first floor . The ground floor is rarely dedicated in single family homes to habitable rooms. These are usually , dining rooms kitchens etc. The areas of concern are the first floor rooms, which are the ones to be habitable.

These non-habitable spaces are usually, with some exceptions, located on the ground floor in detached and terraced houses. Therefore, the distance to neighboring ground floor windows can also be less than 20 meters in suburbs.

As a general rule, any directly facing windows placed at a distance higher than 20 metres is not considered to cause loss of privacy from a planning perspective. Therefore, in a suburban area, any directly facing windows at a distance greater than 20 meters is considered allowable.

This 20 metre rule is often relaxed and reduced to 15 meters in city center areas. This therefore becomes the minimum distance requirement for new directly facing windows in order not to cause loss of privacy in city center areas. This is where our development is located. This reduction to 15 meters is considered necessary because otherwise no new developments would be possible where it is mostly needed. This is the reason for the relaxation in the minimum distance requirement in city centre areas.

Views at an angle

The above is true for planning standards for directly facing windows. However, even if the windows are not facing directly each other there is still loss of privacy. Windows that provide views into other properties at an angles different to 90 degrees (direct facing view) also do cause a material loss of provacy. This is because even if the view is not as good as the direct facing windows, views into the internal space of a dwwellinghouse is still possible at an angle.

Because of this the presence of these windows cause the affected household to require curtains and other obscuring measures to maintain their internal privacy. The closer the view is to 90 degrees the better the view into the window. Conversely, the smaller the angle the less the view. See the figure below for reference.

Figure 1. Even non directly facing windows do provide a certain degree of overlooking (loss of privacy).

At an angle, a new window can be considered to cause a loss of privacy if:

It allows a view into neighbouring habitable rooms, especially into Bedrooms
It is within a certain distance.
The angle of view allows enough view inside the dwelling house.

While there is no fixed national distance, many local authorities use a 20-metre rule for directly facing habitable windows.

The acid test for views at an angle is: does this view at an angle reasonably cause the neighbour to require taking measures to preserve their privacy by using curtains or blinds etc? As discussed at length in case where privacy is already lost then additional windows (duplicating windows) do not cause any material loos of privacy.

Parameters for establishing a “Material loss Of Privacy” for views into a habitable space in terms of distance and angle of view.

Distance from any habitable window to establish loss of privacy:

Less than 20 meters causes loss of privacy in suburban areas. This is a standard used in planning for several years and very well accepted for testing overlooking into habitable rooms. The distance can be shortened considerably to even half 10 metres in certain cases if the view is into an uninhabitable space like kitchen, dining areas etc.

Less than 15 meters causes loss of privacy in city centre areas. The distance can be shortened considerably to even half 5 to 6 metres in certain cases if the view is into an uninhabitable space like kitchen and dining areas.

Provided that the distance between windows are below the above stated thresholds, angle of views to establish loss of privacy maybe as follows:

Less than 15 degrees angle, no material loss of privacy
20 to 15 degree angle could be cause of concern of loss of privacy. This mean that people especially prone to preserve their privacy could subjectively believe that the privacy have been lost.
more than 20 degree angle, loss of privacy as the angle of view is sufficient to have enough internal view of the premises is that it is objectively required to use means of privacy preservation like curtains, blinds etc.

Therefore:

1 Any view into a habitable window at a distance less than 20 meters and an angle greater than 20 degrees may constitute a potential loss of privacy in a suburban area.

2 Any view into a habitable window at a distance less than 15 meters and an angle greater than 20 degrees may constitute a potential loss of privacy in a city centre area.

Established loss of privacy of the properties facing Castle Street.

Because there are established existing windows and an estrance door on the side of the extension facing the porperties in castle street plcing windows on this side of the extension does not require planning permission due to established rights.

However as we have seen, even if there no pre existing windows on this side of the extension, the extension is 20.2 meters from the nearest ground floor window (kitchens, non habitable) and 24 meters from the first floor habitable windows of the properties facing castle street.

Therefore, the windows on this side of the extension are considered not to cause any overlooking even by suburban standards. Therefore, any window opening on both ground and upper levels are allowable from a planning perspective.

Given the above there is no need to examine any existing loss of privacy from any properties, however we have done this as part of our due diligence to show how existing properties already cause a material loss of privacy to these properties.

Here we are going to examine the views of the neighbouring property’s first floor windows. Specifically, we are going to examine the existing overlooking into the properties’ back windows facing castle street.

ground floor window

Visualisation 1.4

We see the direct distance between the exising windows on the extension and the ground floor windows for the non habitable rooms being over 20 meters.

The direct distance between the exising windows and the first floor habitable rooms of the proeties facing castle steet is approximately 24 metres which is well the acceptable threshold. Hence even if no exising windows were present in this sisde of the extension new windows would be permissible due to the distance being over the threshold.

Hence no legitimate claim of overlooking or loss of provacy can be made due to any of the windows facing the propeties in castle street even if not window openings were previously present.

However we continue this study to show how there is indeed loss of privacy from other preestiting development.

Wide Viewing Angles (68° and 63°)

23388 (23.388 meters) with 68° Angle

Distance (23.388 meters):
This is above the privacy thresholds for both suburban (20 meters) and city center (15 meters) areas, meaning distance does not contribute to a loss of privacy.
Angle (68°):
A 68° angle is significantly greater than the 20-degree threshold, offering a wide view of the surroundings. However, the greater distance minimizes the risk of detailed internal views.
Conclusion:
No loss of privacy occurs due to the distance being greater than 20 meters, even though the angle is wide.

24332 (24.332 meters) with 63° Angle

Distance (24.332 meters):
Like the previous example, this distance is well beyond the privacy thresholds, ensuring no privacy intrusion.
Angle (63°):
While wide, the combination of the large angle and the long distance ensures the view focuses more on general coverage rather than detailed observation of specific spaces.
Conclusion:
No loss of privacy is established as the distance exceeds the threshold and limits intrusive visibility.

Moderate Viewing Angles (52° and 48°)

27646 (27.646 meters) with 52° Angle

Distance (27.646 meters):
This distance is far beyond the thresholds for both suburban and city center areas, eliminating concerns about privacy intrusion.
Angle (52°):
A 52° angle is moderate and offers good coverage, but the long distance ensures that it does not intrude on privacy-sensitive areas.
Conclusion:
No loss of privacy occurs due to the substantial distance that mitigates the effect of the moderate angle.

28945 (28.945 meters) with 48° Angle

Distance (28.945 meters):
Similarly, this distance is much greater than the thresholds, providing a sufficient buffer to prevent privacy intrusion.
Angle (48°):
The narrower angle and long distance further reduce the possibility of detailed visibility into private spaces.
Conclusion:
No loss of privacy occurs because the distance and angle combination are well within acceptable limits.

Narrow Viewing Angles (36°)

20284 (20.284 meters) with 36° Angle

Distance (20.284 meters):
This distance is slightly above the suburban threshold (20 meters) and far beyond the city center threshold (15 meters), making privacy intrusion unlikely.
Angle (36°):
The narrow 36° angle provides focused and detailed monitoring, but the sufficient distance ensures that it does not compromise privacy.
Conclusion:
No loss of privacy occurs due to the distance being above the suburban threshold combined with the relatively narrow angle.

Overall Privacy Assessment

All configurations analyzed result in no loss of privacy due to the distances exceeding thresholds for suburban and city center areas. Even though some angles are wide, the distances mitigate their potential for intrusion. These setups align well with privacy-preserving principles.

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Visualisation 2.1 Views into non habitable space on the ground floor.

14.585 meters with 30° Angle

Distance (14.585 meters):
This is below both suburban (20 meters) and city center (15 meters) thresholds, raising concerns for privacy intrusion.
Angle (30°):
A 30° angle is greater than 20 degrees, allowing visibility into private spaces. Combined with the short distance, it creates a material privacy impact.
Conclusion:
A material loss of privacy is present in both suburban and city center areas if it were a view into a habitable room, however given the fact that the view is in a non habitable room there is no material loss of privacy.

Moderate Viewing Angles (52° and 44°)

16.128 meters with 52° Angle

Distance (16.128 meters):
This is below the suburban threshold (20 meters) but above the city center threshold (15 meters). Privacy concerns may arise in suburban contexts.
Angle (52°):
A 52° angle exceeds the 20-degree threshold, providing a broad view of the surroundings. However, the sufficient distance reduces its ability to intrude on privacy-sensitive areas.
Conclusion:
Loss of privacy occurs due to the distance exceeding thresholds despite the moderately wide angle however this loss of privacy occurs in a non habitable room on the ground floor therefore no material loss of privacy.

21 meters with 44° Angle

Distance (21 meters):
This is far below both suburban and city center thresholds, raising significant privacy concerns due to proximity.
Angle (44°):
The 44° angle exceeds the 20-degree threshold, offering detailed visibility of internal spaces. Given the extremely close range, this setup constitutes a clear privacy violation.
Conclusion:
No material loss of privacy due to the distance and the fact that the view is on a non habitable room.

Narrow Viewing Angles (33° and 30°)

23.153 meters with 33° Angle

Distance (23.153 meters):
This is beyond the privacy thresholds for both suburban (20 meters) and city center (15 meters) areas, indicating that distance alone prevents privacy concerns.
Angle (33°):
The angle exceeds the 20-degree threshold, making it capable of providing a detailed view of internal spaces. However, in suburban areas, this could be subjective unless additional privacy measures (e.g., blinds) are implemented.
Conclusion:
no material loss of privacy exists due to the acceptable distance and view intoa non habitable space.

Overall Privacy Assessment

23.153 meters, 33°: No privacy loss due to sufficient distance.
21 meters, 44°): No material loss of privacy
16.128 meters, 52°: Potential privacy loss in suburban areas; none in city centers if the voew were into a habitable room, however the view is into a non habitable room hence no material loss of privacy due to the use of the areas on the ground floor.
14.585 meters, 30°: Potential privacy loss in suburban areas; none in city centers if the voew were into a habitable room, however the view is into a non habitable room hence no material loss of privacy due to the use of the areas on the ground floor.

Visualisation 2.2

Another view into the firsf floor windows of the properties Facing castle street. These are non habitable windows.

Moderate Viewing Angles (34° and 49°)

15.8 meters with 34° Angle

Distance (15.8 meters):
This distance exceeds the suburban (20 meters) and city center (15 meters) thresholds, eliminating concerns about privacy loss.
Angle (34°):
The 34° angle is above the 20-degree threshold, allowing for a moderate field of view. However, the long distance reduces its potential to intrude on private spaces.
Conclusion:
Potential loss of privacy occurs because the distance is sufficient and the angle of view however the use as non habitable spece of the gound floor space does not constitute this a loss of privacy.

17.10 meters with 49° Angle

Distance (17.10 meters):
This distance is significantly below both thresholds, raising substantial privacy concerns.
Angle (49°):
The 49° angle exceeds the 20-degree threshold and provides a wide field of view. Combined with the extremely close proximity, this configuration allows detailed visibility into private spaces, creating a strong privacy violation.
Conclusion:
A loss of privacy could be argued due to the short distance and wide angle, however due to the non habitable nature of the speces on the ground floor no material loss of provacy occurs.

Narrow Viewing Angles (38° and 57°)

21.7 meters with 38° Angle

Distance (21.7 meters):
This distance is slightly above the suburban threshold (20 meters) and well beyond the city center threshold (15 meters), reducing potential privacy concerns.
Angle (38°):
A 38° angle exceeds the 20-degree threshold, allowing visibility into private spaces. However, the acceptable distance minimizes its impact.
Conclusion:
No loss of privacy occurs due to the distance exceeding thresholds, despite the moderate angle.

23.7 meters with 57° Angle

Distance (23.70 meters):
This is far below both the suburban and city center thresholds, raising significant privacy concerns.
Angle (57°):
The 57° angle is significantly greater than the 20-degree threshold, providing a very wide field of view. Combined with the very short distance, it results in a clear intrusion into private spaces.
Conclusion:
No material loss of privacy occurs due to the long distance and wide angle.

Overall Privacy Assessment

23.7 meters, 34°: No privacy loss due to sufficient distance.
17.10 meters, 49°: Significant privacy loss due to short distance and wide angle.
21.7 meters, 38°: No privacy loss because of sufficient distance, even with a wider angle.

These results demonstrate that maintaining sufficient distances is critical to mitigating privacy concerns, especially when viewing angles exceed the 20-degree threshold.

Visualisation 2.3

Analysis Based on Parameters:

Distance:
For a suburban area, loss of privacy applies if distances are less than 20 meters.
- 18.346 meters is the only distance below the 20-meter threshold.
- Other distances (19.470m, 23.725m, and 25.531m) exceed the 20-meter limit, ruling them out for privacy concerns.
Angle of View:
Loss of privacy applies if angles are greater than 20°.
- All angles provided (62°, 55°, 44°, and 40°) exceed 20°, indicating the potential for loss of privacy if combined with a critical distance.
Combined Result:
- 18.346 meters (Distance) and 62° (Angle):
  This combination falls under the suburban “loss of privacy” category. The distance is critical (<20m) and the angle exceeds 20°, constituting a clear loss of privacy.
- 19.470 meters (Distance) and 55° (Angle):
  Although the angle exceeds 20°, the distance is borderline (~19.47m). It could pose a privacy concern but remains marginal.
- 23.725 meters (Distance) and 44° (Angle):
  The distance exceeds 20m, so despite the wide angle (44°), there is no loss of privacy.
- 25.531 meters (Distance) and 40° (Angle):
  The distance exceeds 20m, so despite the angle (40°), there is no loss of privacy.
Conclusion:
- 18.346 meters with a 62° angle clearly causes a loss of privacy in a suburban area.
- 19.470 meters with a 55° angle may raise borderline privacy concerns due to its proximity to the threshold.
- 23.725 meters with 44° and 25.531 meters with 40° do not cause material loss of privacy, as the distances exceed the critical 20-meter condition.

Visualisation 2.4

- Narrow Viewing Angles (43° and 64°)
  1. 43° at 24.67 meters:
    - This narrower angle provides a precise and focused field of view for monitoring specific zones like pathways, entrances, or areas with high detail requirements.
    - At 24.67 meters, this configuration is ideal for long and narrow spaces or confined zones.
  2. 64° at 19.81 meters:
    - With a wider field of view, the 64° angle balances detail and coverage, making it useful for medium-sized areas like driveways, yards, or sections of gardens.
    - At 19.81 meters, it efficiently monitors broader areas without losing too much focus.
  Moderate Viewing Angles (46° and 57°)
  1. 46° at 26.59 meters:
    - The 46° angle offers a moderately focused view, suitable for monitoring larger sections while retaining clarity.
    - At 26.59 meters, this angle works well for covering extended spaces such as backyards, corridors, or medium-sized outdoor zones.
  2. 57° at 20.84 meters:
    - A 51° angle expands the perspective slightly while maintaining good detail coverage.
    - At 20.84 meters, it is ideal for areas like compact yards, entrances, or outdoor spaces where broader visibility is desired.

Visualisation 1.1

Viewing Angles and Corresponding Distances

59° at 19.95 meters
- Widest angle in the image.
- Ideal for wide-area coverage such as gardens, large open spaces, or multiple zones with reduced distance focus.
54° at 21.96 meters
- Slightly narrower than 59°, balancing area coverage and clarity at a medium distance.
- Useful for yards, entry points, or areas needing moderate coverage.
42° at 23.21 meters
- A moderately narrow angle that delivers a focused view while maintaining a reasonable field of coverage.
- Effective for mid-range distances like pathways or transitional zones.
38° at 29.51 meters
- Narrowest angle in the image.
- Designed for long-range monitoring where detail is critical, such as walkways, corridors, or focused surveillance of distant objects.

General Observations

The 59° and 54° angles are for broader coverage over shorter distances.
The 42° and 38° angles focus more on precision and detail over medium to longer distances.

Visualisation 1.2

Analysis Based on Parameters:

1. Distance:

For a suburban area, loss of privacy applies if distances are less than 20 meters.
Only one distance (19.234 meters) is below the 20-meter threshold.
Other distances (20.297m, 24.178m, and 25.679m) exceed the threshold, so they are automatically ruled out for privacy concerns.

2. Angle of View:

Loss of privacy applies if angles are greater than 20°.
All angles (59°, 54°, 45°, 42°, and 38°) exceed 20°, indicating the potential for loss of privacy if combined with a critical distance.

Combined Result:

19.234 meters (Distance) and 59° (Angle):
- This combination falls under the suburban “loss of privacy” category.
- Since it is less than 20m and greater than 20°, this could constitute a loss of privacy.
Other Distances:
- All other distances are above 20 meters, so even with wide angles (54°, 45°, 42°, and 38°), they do not constitute loss of privacy under the provided criteria.

Conclusion:

Only the 19.234-meter distance with a 59° angle potentially causes a loss of privacy in a suburban area.
For the rest of the angles and distances, no material loss of privacy exists, as they fail to meet the critical distance condition.

Visualisation 1.3

Analysis Based on Parameters:

1. Distance:

For a suburban area, loss of privacy applies if distances are less than 20 meters.
Only one distance (21.980 meters) is below the 20-meter threshold.
Other distances (22.953 m, 26.468m, and 27.870m) exceed the threshold, so they are automatically ruled out for privacy concerns.

2. Angle of View:

Loss of privacy applies if angles are greater than 20°.
All angles (42°, 50°, 62°, 66°) exceed 20°, indicating the potential for loss of privacy if combined with a critical distance.

Combined Result:

12.980 meters (Distance) and 66° (Angle):
- This combination falls under the suburban “loss of privacy” category.
- Since it is less than 20m and greater than 20°, this could constitute a loss of privacy.
Other Distances:
- All other distances are above 20 meters, so even with wide angles (42°, 50°, 62°, and 66°), they do not constitute loss of privacy under the provided criteria.