Flat Roof Extension Compliance With Planning Policy.

 

1.1 Introduction

 

Our planning proposal involves the roof reconfiguration from a double-pitched to flat roof on the extension of the commercial building.

The picture below provides an aerial view of the entire building, including the double-roofed extension.

 

Figure 1.1 We can see the two double-pitched roofs of the extension. Our proposal is to alter the extension to place a flat roof at the height of the existing roof ridges. Therefore, the top height of the extension will remain the same. Note that the main building’s top ridge height is a comparable height to the existing houses surrounding it. Because of this, the main building (which is higher than the extension) is not visible from the main roads. The height of the top ridges of the extension is one storey lower than the main building. Therefore, the extension is even less likely to be seen from any main road. The building as a whole is concealed by the surrounding houses.

Click Here To View Existing Drawings Of Flat Roof (Before)

Figure: 1.1.2

Click Here To View: Updated Elevation Drawings Proposed Side Extension(After)

 

Figure: 1.1.3

Below is the side extension with a flat roof. The height is in line with the current roof’s ridge height. The building as a whole is hidden from full view of Harold Street and the main roads. The extension is particularly hidden due to its lower height than the surrounding buildings. The design is perfectly in line and blends in with the existing building and the character of the area. Virtually, even if it is not easily visible, the proposed design is much more pleasing than the present design.

 

 

1.2 Windows

 

There are existing windows on both sides of the extension overlooking both the backyards of the properties in Castle Street and Harold Street.

The privacy concerns in connection with any windows facing any of these properties have been extensively studied, and it is clear that no rights are infringed on by any of these properties, even if there were no existing windows and entrance doors in place on both sides of the extension. As we have examined extensively, no right would be infringed even if these windows did not previously exist.

The pre-existence of windows on both sides of the extension eliminates completely any possibility of objecting to any additional windows on the upper levels.

1.2.1: Context and Existing Situation

• The existing building already contains windows on both the side and rear elevations which currently overlook the same areas that would be visible from the proposed new windows.

• These existing windows have long-established sightlines over adjacent properties, particularly towards the rear  of properties on Castle Street and Harold Street.

• The proposed windows are neither introducing new vantage points nor altering the character of visibility already established by the current fenestration.

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 1.2.2: Planning Policy Position

• Materiality: For a concern such as overlooking to be a material planning consideration, it must give rise to new harm. In this case, no new overlooking is introduced.

• Precedent: Case law and guidance from Planning Inspectors repeatedly affirm that overlooking from a new window which duplicates an existing view does not materially worsen privacy and therefore is not a valid ground for refusal (e.g. East Staffordshire BC v Secretary of State [2001]).

• The National Planning Policy Framework (NPPF) promotes development that makes efficient use of land and encourages well-designed spaces. The proposal does not infringe on this principle.

• The additional windows in this planning application do not cause any material harm as amply demonstrated below.

• A review of local planning decisions in the area shows consistent approval for window additions where no novel  overlooking is caused.

The windows facing the playground do not cause any privacy concerns. They are facing land that is already developed and activity conducted on this land is considered public, not private.

Please refer to our detailed studies on this matter further along in this document.

 

1.3 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, over-development, 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 Neighbours

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

• Does not exceed the original ridge height,
• A detailed shadow study has been conducted for the proposed extension at 68 Harold Street, in accordance with BRE Guidelines (BR209). Shadow simulations for March 21, June 21, and December 21 at 9am, 12pm, and 3pm show no material increase in overshadowing to neighbouring homes or amenity spaces. The development complies fully with accepted overshadowing thresholds and does not impact the light access or enjoyment of surrounding properties. A full shadow study report is included as part of this submission.

Download The Complete Shadow Study Report

 

Then there is no material harm to neighbouring properties.

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

 

3: This minor development involves only minor changes to the external envelope of the building. In this case, the only increase in height is at the two edges of the extension, while the top height of the extension 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 by 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 on 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.

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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. Therefore, it should be approved.

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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 the top 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 have 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 surrounding 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.

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1.3.1: 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 surrounding 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 emphasises good design without stifling innovation or minor architectural changes).

1.3.2: Preliminary Vertical Sky Component (VSC) Assessment

 

Download Full Vertical Sky Component (VSC) Compliance Report

To support our claim, we have conducted a preliminary Vertical Sky Component (VSC) analysis in line with BRE Guidelines (BR209). Based on the measured 7.5m distance from the proposed extension to the nearest neighbouring window, and an estimated height differential of approximately 1.5 metres, the angle of obstruction is calculated as approximately 11.3 degrees.

This is well below the BRE threshold of 25 degrees, suggesting that the proposed development will not materially impact the amount of diffuse daylight received by neighbouring properties. Therefore, the proposal complies with BRE standards and is unlikely to result in a significant loss of light or amenity to adjoining buildings.

1.4 Development merits review summary

 

From a planning perspective, this minor development is classed as a building envelope alteration. More specifically, a roof alteration, because we will not increase the height of the roof, we will only convert the roof from double-pitched to flat, keeping the flat rooftop height the same or lower height than the existing pitched roof’s ridges.   Therefore, the top height of the extension will either remain unchanged or will be lowered slightly. This alteration will not increase the top height of the extension. To be clear, after the alterations is complete, the height of the extension will be the same as the top height as of today and lower than the height of all surrounding houses and buildings therefore not visible from the main roads in the same way as it is not easily visible today. Therefore, it is a very minor development.  Because it only seeks to modify the roof configuration from a double-pitched to a flat roof.

This minor development is:

1. Fully compliant with the national planning framework
2. Fully compliant with local panning policy
3. Our alteration does not increase the footprint of the building.
4. It does not increase the internal square footage.
5. It does not have any adverse impact on any neighbouring property.
6. It does not infringe upon any rights of the neighbouring properties. No right of light, no privacy rights are infringed.
7. It does not cause any overshadowing.
8. Due to its location and its height, this building (both the main building and the extension) is not visible from any main roads.
9. It adds a disproportionate value to the area while being a minor development and having no negative impact on any neighbouring properties.
10. This proposed design choice  renders private development a feasible proposition both in the medium and long term.
11. Once the project is completed, it will foster further investment by occupying the premises, and it will  very likely spark further investment in the area as explained in detail later on.
12. This minor proposal is classed as sustainable development as per the definition of the national planning policy. Later on, it is clearly demonstrated how this is a sustainable development as defined by the national planning policy framework. As such, there is a very strong bias for approval as clearly stated by the national planning framework. This is clearly stated in the section “The presumption in favour of sustainable development”.

1.5 Minor Development/Alteration

 

This is considered a minor development of the building envelope or building alteration.

If it were feasible to restore this building utilising the existing construction style of the extension, this could be done without planning permission. However, given the various features of this double-pitched roof design, this building requires some minor modifications and design optimisation for the regeneration of the building to produce a “sustainable” building.

This is a minor development because:

1. It does not increase the footprint of the extension or any part of the building, it only seeks a roof reconfiguration.
2. It does not increase the top height of the extension.
3. It seeks to regenerate and modernise this existing building with an optimal design,
4. It does not increase the scale of the building.

Under these parameters, this proposal is classed as a minor development or minor building alteration.

 

1.5.1: The similarities of this alteration with permitted development rights of householders.

 

Permitted development rights of householders allow the extension of the part of the roof using dormers almost up to the edge of the eaves, provided that any part of the dormer is not higher than the top ridges of the roof. This is applicable to the part of the house that is not visible from any road (like in our case).

Although, in this instance, permitted developments do not apply, in our minor building alterations:

1. The roof is only been converted from a double-pitched to a flat roof, and like permitted development rights for householders, the final roof is not higher than the top ridges of the original roof. In other words, the top height of the flat roof is going to either be the same height or slightly lower than the ridge of the existing roof.
2. The extension is positioned in a location not easily visible from any main road. However, even if it were visible from the main road the impact would be positive since our design is an objective improvement form the original design and the current state of the double-pitched roof. Additionally, the flat roof would be much less expensive in terms of maintenance than current configuration in  a double-pitched roof. As we will see, this fits well with the government’s definition of “Sustainable development”.

Given this stark similarity with permitted development rights of householders, it is one of the several factors in favour of the approval of this Minor Development/ Building Alteration.

 

1.5.2: The main building visibility and the full extent of the expansion are admissible of the extension from a planning perspective.

 

The non-visibility of the building from the main roads is an important factor in increasing the scope of what is admissible from a planning perspective.

The main building is two storeys high with a double-pitched roof. Its top roof ridge height matches the height of the surrounding houses. Because of the height of the surrounding houses being the same as the main building, this building cannot be seen from any main road. The whole building is not visible from Rutland Street, Castle Street and Harold Street.

The only part of the building that is visible from one of the main roads (Harold Street only) is the front access to the main building.

Additionally, the existing double-pitched roof extension is one storey lower than the main building and one storey lower than the surrounding houses. Therefore, it is even less likely to be seen from any main road and therefore completely concealed.

It is known that for a planning proposal to be allowable from an architectural perspective, it does not need to stand out. It has to merge seamlessly with the area and fall in line with the height of the surrounding buildings.

A two-storey alteration with a double-pitched roof configuration with its top roof ridge matching the height of the main building and the surrounding houses, would fit the criteria of what is allowable. This is because the height would be the same as the surrounding buildings. The double-pitched roof height would be the same as the main building and the surrounding houses. Because of this, a double-storey extension with a pitched roof matching the height of the existing building would not be visible from any main road. It would fit with the area’s look and feel. Therefore, this would be allowable in principle.

In other words, given that the main building is not visible from any main road, and it is two storeys high, therefore, if the extension were made two storeys high with a pitched roof and the top ridge matching the height of the main building, then the extension would still not be visible. Therefore, since the extension would match the height of the main building, and not visible from the main roads, this would make this double-storey alteration with a double-pitched roof allowable from an architectural point of view.

This double-storey design with a pitched roof on top of the extension would be allowed as long as the right of light and the other rights of the neighbouring properties are not impeded. Studies have been carried out with this alternative design, and it has been demonstrated that no rights of any neighbouring properties would be infringed.

The admissibility is due to three factors:

1. Like the main building, a double-pitched roof configuration matching the main building’s height will still be hidden by all the surrounding houses.
2. Right of light and other rights of the neighbouring properties would not be affected by the structure.
3. Even if the extension design is made to match the main building in height, the claim of scale and dominance is also dismissed based on all the points discussed in the “scale and dominance” section, but also on the fact that this building is not visible from any main road in all circumstances.

Therefore, the scope of what is admissible from a mere planning perspective is much more than what our minor building alteration requires.

Although making the extension’s two-storey double-pitched roof is architecturally allowable from a planning standpoint, we put forward a more conservative design which fits the definition of sustainable development as defined by the national planning policy.

1.5.3: Our minor development/alteration is a much more conservative design than the full extent of what is allowable from an architectural point of view.

 

The extension is currently double-pitched and one storey lower than the main building. It is also one storey lower than the surrounding houses that block its view from the main streets. As it is easy to observe from the main streets, in particular Harold Street and Rutland Street, the main building, which is one storey higher than the extension, is completely covered by all the surrounding houses. This is because the top height of the main building matches the top height of the surrounding houses.

Therefore, even if the top height of the extension were to match the surrounding houses (it would be a double storey with a pitched roof or three storeys with a flat roof), it would still not be visible from any main road because its visibility would be obstructed by the surrounding houses.

Under this minor development proposal, the top height of the extension will remain the same as today. We will adopt a flat roof configuration and the top height of the flat roof will match the lower height of the present double-pitched roof extension.

Therefore, if the main building which is two storeys high with a pitched roof, the extension with a flat roof that reaches only the current ridge of the roof’s extension will not remain visible in the same way it is today.

1.6: Flat roof in line with the area’s look and feel, and better than the Phoenix academy.

 

The Phoenix Academy building has a flat roof structure all throughout and the closest part of the building is in the region of 20 to 25 metres from the extension. It has to be noted, therefore, that our construction a flat roof is similar tho that of the Phoenix building.

In particular, the Phoenix house has a sloped bubble-pitched roof. The slope is very low and similar to a flat roof due to is very low  slope.

The Phoenix Academy is not concealed by any house or building, and it is visible from Harold Street.

The Phoenix Building Academy building complex has a simplistic type of construction in order to reduce building costs. This style of construction does not blend well with the area.

Our proposed building alteration, in contrast, is going to be constructed using the same or similar outer brick work as the surrounding houses, therefore blending in well with the surrounding area even if it is mainly hidden from view.

Additionally, the type of construction of our proposed building alteration is a much better fit than the Phoenix building, which is also very easily visible from Harolde Street.

Our minor building alteration, while it is lower than the surrounding houses (therefore it is hidden from direct view from Harold Street), is a better fit to the look and feel of the area. Additionally, the top height of our minor building alterations will match the existing roof ridges height and will still be lower or similar to the height of the Phoenix house. Our minor building alterations are of the same or similar height to the Phoenix building. However, since it is lower than the main building and the surrounding houses, it is hidden.

 

 

To summarise the main advantages to our minor development versus the Phoenix building complex academy and, in particular, the Phoenix house:

1. Our building is a much better fit with the area than the Phoenix building. As we know, the planning policy,  both local and central governments prefer designs of buildings that fit with the area. In our case, the flat roof matches with the flat roofs already existing on the Phoenix Academy Building.
2. Although our building is a much better fit with the area, it is mostly concealed from view from any major road. The Phoenix building is very well visible from Harold Street. The Phoenix building is not concealed whereas our building is concealed. Despite that, our construction using the original bricks is a much better fit than the Phoenix building, because the design of the Phoenix building was made with material that does not match the area as well and also a blue colour. Very likely this was done to save on construction costs.
   In conclusion, it is clear from the above picture that a flat roof design blends really well with the look and feel of the area (as required by central and local planning policy) as long as the colour of the build is in line with the area’s colour and feel.

Our proposal fits very well with the look and feel of the area and the height of the extension will be lower than the surrounding houses. Therefore, although our design is a substantial improvement from the current configuration, and it is a better fit with the area, the alteration is not visible from any main road, and it does not directly influence the look and feel of the area.

As we have seen, and we will continue to demonstrate throughout this document, our building alteration is hidden from sight and the overall design is a very good fit with the area.

1.6.1: Scale, dominance, layout and density

The footprint of the extension will remain the same. Therefore, any objection in terms of the scale of footprint is dismissed on the simple basis that the footprint remains unchanged. Additionally, any claims of scale are also dismissed due to the fact that the height of the extension is not increased, since this minor development will seek to match the new flat roof with the current height, therefore not increasing the height of the extension.

In terms of height, the extension will keep the same top height (height of the exiting roof ridges). Therefore, the objection in terms of dominance due to the height is dismissed due to the fact that the  height of the extension remains the same. As we have seen, the scope of what is admissible from a planning perspective is much larger than our proposal.

Additionally, this is dismissed because the extension cannot be dominant from a mere height point of view because it is lower than the main building and any surrounding neighbouring houses. By definition, a building to be dominant has to meet three criteria.

1. It has to be taller than any other surrounding buildings.
2. Even if it is taller, it has to be clearly visible from the main road.
3. It has to be clearly visible and clearly stand out from all the neighbouring buildings or houses.

These three criteria have to be met in order for a legitimate and admissible claim of dominance to be made. A building that is lower than the surrounding houses and surrounding buildings, not easily visible from any main road, cannot by definition be dominant.

Furthermore, more simply, the building is not visible from any main road. Therefore, the claim of dominance is baseless also due to this mere reason.

From all the above, it is clear that any claim of dominance is clearly legally and factually baseless.

Not withstanding the above, in case an argument is made that the building is dominant because of the increased height of the boundary walls on the part facing Harold St and Castle Street, this is dismissed based on the following:

1. Dominance cannot occur because our minor development will not increase the height of the extension. It can only legitimately occur if all the three criteria above are met.

2. The current height of the ridges is lower than the height of the sounding houses. The height of the flat roof will either match the current roof’s ridge height or be slightly lower.  Therefore, dominance claims cannot be made since the extension is currently lower and will remain lower than ANY existing houses surrounding it. So much so that the height of the surrounding houses does cover the view of the extension as well as the main building, which will remain 5 to 6 metres higher than the extension.

In other words, because our minor development will keep the top height of the extension unaltered, the extension will still not be visible because its view will still remain covered by the surrounding houses of Harold Street and Castle Street, which are approximately 5 to 6 metres higher than the top height of our extension alteration. To be clear, the height of the flat roof will  be the same as the current roof’s ridges, and it is and will remain  5 to 6 metres lower than the surrounding houses. The claim could have some justification only if the height of the flat roof was higher than the existing ridges of the surrounding houses, and it would be somewhat visible from any of the main streets.

3. Claims of dominance due to overshadowing or loss of light are dismissed due to our study that extensively proves there is no loss of light or overshadowing. Our studies prove how even if the extension were made as a two-storey building with a pitched roof matching the main building construction, overshadowing would still not take place in any neighbouring house.

4. The claim due to overlooking is dismissed because there is no material harm and no loss of privacy as proven extensively. Our studies prove how even if the extension would be made as a two-storey building with a pitched roof matching the main building construction, material loss of privacy would still not take place to any neighbouring house.

Any claim in density or layout of development is dismissed since our minor development only involves the change in roof configuration from double-pitched to a flat roof. No increase in footprint is made nor are any internal alteration made.  The development only seeks to change the roof configuration within the limits of its current ridge height. The current ridges height are lower than the ridges of all surrounding houses. Therefore, there is no increase in the density of the building in any way. No extra floor is added under this planning application.   A claim on density could only be argued only if there is an application where the building would be extended beyond its original footprint (like a new extension, for example).

The external layout remains unchanged because this minor development involves the modification of the roof layout only. Therefore, any objection based on external layout is dismissed because there is no change in the footprint of the external layout of the building.

The external layout remains unchanged. Therefore, any dismissal in terms of internal layout is unsubstantiated or baseless.

1.7: Central Area, local deprivation, dilatated, boarded-up and unoccupied houses in the area.

 

The local policy map describes this as a central area. This is located right between Grimsby city centre and Cleethorpes city centre. It is easily accessible on foot from both Grimsby city centre and Cleethorpes city centre. Cyclist commuters from both Cleethorpes city centre and Grimsby city centre can reach this location within 5 to 10 minutes. But generally far less than 10 minutes on a slow bicycle ride.

Therefore, this area is very convenient for working-class families, and single people who have employment either locally or in the city centres.

However, the general look and feel of the area is of deprivation. The root cause of deprivation in this area is the systemic long-term lack of investment. This deterioration started 20 years prior and the area is currently still in a downward trend due to the continued lack of investment.

The area has progressively deteriorated in recent years and it presents several challenges. At present this is NOT considered a “place where people want to live” as defined by the local planning policy.

 

The root cause of this is the systemic lack of private capital investment in the area. This is not due to the lack of business opportunities but the lack of public and private investment in the regeneration of the area.

It is possible to see more depicted and abandoned houses just by walking around the area. Also, the major challenges of the area are:

 

 

Petty crimes, robberies, burglaries, fly-tipping, drug growth, drug use, the unsanitary appearance of the area, unclean pavements, litter all around and activities that discourage middle-class families to move into the area.

The area is very much in need of investment to revive it. There are a number of boarded up and/ or burned down empty properties.
The overall outlook of both Rutland Street and Harold street is poorly and this is not only palpable in the area but there is also hard evidence of this and can be easily verified independently.

 

Any family that moves into the area does so because of low rent which still meets the payments for social welfare.
To working professionals, this area is only attractive due to the low rental payments. Most working households which reside in this area state that they will move into a better area at the first given opportunity. Therefore, this is a transitional area for working families.
This area is currently long-term residents for those who are on long-term benefits.

This area is currently long-term residents for those who are on long-term benefits.

 

Although our minor development is allowable from a strict legislative and policy viewpoint, it is good practice to be as lenient as possible with planning applicants in order to secure as much private investment in this area as possible. This will encourage the much-needed regeneration of the area.

 

1.8: The need for public and private investment.

 

In order to resolve all these issues, investment is required from the private sector. There is already a beginning of private investment, which will bring significant benefit to the area. This is the residential development at the rear of 110 Harold Street. However, this is not sufficient to break the systemic lack of investment in this area.  Further investment is required to reach the tipping point when private investment will flow in unencumbered and systematically. At that point, the area will regenerate itself by default simply due to private investment.

 

Additionally, this building is a pivotal part of the area and its regeneration will strongly contribute to the regeneration of the area. The planning approval of our minor development will provide us with the permission needed to invest private capital in a financially viable project.

Our minor development will allow key private investment into this key commercial building, which is very likely to reach the tipping point required to attract a further cascade of private investment. This is due to the increased business investment in the area in employment and skill development by the future occupying business/es. Our minor development will generate highly skilled employment in the area, therefore increasing the local demand for high-quality housing close to the area of employment. In turn, this will encourage private capital to invest in further local business development and derelict housing regeneration due to the increased demand in this area (as we will see this is completely in line with the local planning policy, where the planners need to prioritise approval of those developments that will lead to the reoccupation of derelict uninhabitable houses).

 

As this minor development will allow us to revive the building, the whole area will experience an economic uplift as well as a new uplift to the look and feel of the area. In fact, the approval of our planning applications will allow us to initiate a viable project of regeneration of the building and the areas. This is because this building is pivotal to the area.

The immediate short as well as long-term consequence of our minor development is a significant contribution to the start of the regeneration of the area.

 

 

1.8.1: How the approval of this minor development is likely to spark a chain reaction of further private investment and area self-regeneration.

 

It is acknowledged that the impact the public sector can make in a meaningful investment in regeneration is limited. Help is required by the private sector.

The benefits brought by this minor development which will regenerate this commercial building are disproportionate. It is very likely that this minor development could be the ignition of the spark required to in turn attract further investment in the area, not only from the future businesses occupying the building. Also, other businesses in the area will find the increased business opportunities created by our private investment an attractive factor to make further safe investment in this area.

As a consequence, with the approval of this minor development, local high-skilled employment will increase in the area. Therefore, the housing demand and desirability of the area as a place to live close to the employing business/es will increase. The desirability of the area as a place to work and live will increase, therefore allowing an increased housing demand which will in turn encourage private investment to restore uninhabitable, derelict, boarded-up empty homes in the area (this is a stated local planning policy).

 

1.9: Derelict state of the premises and its restoration.

 

The state of part of the premises, although it is structurally secure, is partly derelict. The definition of derelict when referring to a building is “in a very poor condition as a result of long-term lack of maintenance and neglect”. This building currently meets this definition. It can still be used, but in a limited fashion and by taking certain precautions. The building requires restoration. However, this restoration needs to be done using a “sustainable” design and sustainable construction. As we will see, the deterioration of the extension is mainly due to the design choice made at the time of construction. This present design and mode of construction renders the extension not sustainable in the long term, and it is recommended to adopt a sustainable design to allow a sustainable use of the building for several decades to come.

The same does not apply to the main building, where the whole construction and design is highly durable and sustainable.

 

1.10: Design choice

 

An in-depth study has been carried out to find a sustainable design solution for the long term outlook of the building and the area. The word “Sustainable” in this case fits the definition made by the government in the national planning policy. More on this in the section where we examine the compliance of our minor development/alteration with the stated national planning policy framework.

A number of design solutions have been considered. This was done with sustainability in mind and also with what is allowable from a planning perspective. Therefore, our final design solution is both desirable, sustainable and favoured from a planning perspective but also a viable project that will attract private investment in the area.

Therefore, our proposal for the regeneration of this commercial building is considered to be the best possible “sustainable” solution for this building.

 

1.10.1: Summary of why selecting the flat roof matches the height of the current roof ridges.

 

The flat roof height does not exceed the height of the current ridges. Therefore, the top height of the extension is not increased . This makes the planning proposal non-intrusive and a very minor development.

This height offers much greater security for the building. This is because for intruders to attempt entry through the roof equipment like ladders is required and this type of effort is too high a risk, especially at night. Therefore, the likelihood of intrusion through the flat roof is dramatically reduced. This makes this development much more sustainable than any other possible configuration.

The higher height of the flat roof allows a higher degree of security for any solar panel installation. This is because the roof can only be accessed using ladders.

The higher height also allows the capture of less turbulent and higher-speed winds by any possible roof-mounted wind turbine producing more energy. The higher fleet roof height makes the wind turbine less subject to possible vandalism and theft.

For these and other reasons, the higher flat roof design is the most sustainable solution while not increasing the top height of the extension.  Therefore, keeping our proposal clearly classed as a minor development because it seeks to modify slightly the envelope of the existing extension without increasing the top height of the roof.

From a planning perspective, because we are not increasing the top height of the extension  and the extension is in an area not easily visible from any main road, this is generally considered a very low invasive planning proposition which is comparable to the household permitted development rights. The household permitted development rights allow the development of a dormer window of any shape, including a flat roof, under the condition that the height of the roof or the flat roof has not increased and other minor conditions. This is because the height of the top height of the building is not increased.

1.11: The current design is unsustainable.

The current design is not sustainable in the area due to the high security risks caused by the low double-pitched roof of the extension. The low height of the side walls has historically allowed easy, undetected and safe access into the building through the lower part of the roof’s extension.

It is clear how the current double-pitched roof configuration is not a sustainable design and structure. This is additionally due to the middle valley maintenance requirement.

On both sides of the extension (facing Harold Street and Castle Street), windows and entrance doors have been bricked up to prevent access to intruders. After the side windows and entrance doors were bricked up, the easiest point of entry to the intruders was through the extension’s roof.

The method of entry was and is simply through taking off a few roof tiles and making your way into the building, both safely and undetected. This has caused this building not to be financially sustainable throughout recent years, leading to the present degree of disrepair.

The possibility of restoring the current double roof configuration is unsustainable because this design presents intrinsic security risks. The inherent security risks of the extension’s current design render the building not only unsustainable, but it is also not possible to invest in its regeneration due to these intrusive design flaws. In order to overcome those inherent high security risks, a sustainable design has to be implemented.

Therefore, repairing this building using this current design is not a financially viable proposition, because any investment may not have a return on capital deployed , due to the inherent security risks and high maintenance requirements.

For these reasons, the current extension design is unsuitable for a regeneration project, keeping the extension’s design unchanged.

The unsustainability of the extension’s current design is also demonstrated by the constant, costly maintenance requirement to maintain the middle valley of the double-pitched roof.

Lack of this essential maintenance will cause roof deterioration, which then causes roof damage which becomes prohibitively expensive to repair.

Also, the current roof configuration does not allow the installation of renewable energy sources in a way that can guarantee any return on capital invested. The reasons for it are amply discussed in the appropriate section.

For these reasons, the current roof configuration is not sustainable and a sustainable design is required for the restoration of the building. Our proposed flat roof configuration, although there are minor alterations, at the same time, is a “sustainable” solution for the restoration of this building.

 

1.11.1: Sustainable extension design and construction; the consequences for the area.

 

Given the unfeasibility of the current extension design, our objective is to select the most “sustainable” building design for the extension. The word “sustainable” has to be interpreted as defined in the national planning policy.

The “sustainability” of the extension in terms of design and construction, as a consequence, will decrease the carbon footprint of the whole building itself because it will require less ongoing maintenance and lower running costs.

The potential of carbon footprint reduction will be exacerbated by the possibility to install effective renewable energy sources on the rooftop.

The building will be capable of sustaining long-term occupiers. The longer businesses are going to occupy the building unsustainably, the more the chances for businesses to grow and create new jobs and invest in the area itself.

The area will benefit by the increased prosperity generated by the businesses that will be able to occupy this building sustainably. It is a very well-known fact that in order for an area to be prosperous, the prosperity of local businesses is what brings prosperity through investments in the local area, job creation and general uplift of the local community.

 

1.12: The design optimisation process.

 

The design choice was made with sustainability in mind. Because the current double-pitched tiled roof is clearly an unsustainable design, we have examined a number of possible solutions.  Several alternative options have been considered, and we have selected  the best possible design, considering both what is considered a minor development (which is generally permissible) and the most “sustainable” option.

The implementation of the most sustainable design option is the government’s priority to promote “sustainable development” as defined in the national planning framework.

The proposed higher side walls, which will match the current roof ridges height, will grammatically reduce the risk of intruders making their way in easily through the roof because

• It is a flat roof at a higher height which will require the use of ladders or other equipment to reach it,
• The flat roof will not have tiles, Therefore, it is much more difficult to break into. Noisy battery-powered specialised tools would be required to break in through the new flat roof. This would attract attention.

1.12.1: The cost of vandalism. The un-sustainability of the current extension design/configuration.

 

One of the main issues that makes this extension unsustainable is the cost of burglaries and vandalism.

The present extension design presents several challenges. One of the major challenges is the general un-sustainability of its current double-pitched roof design. This renders the building non-sustainable to the businesses that occupy it.

Historically, this building had been burgled and vandalised several times.

The vandalism and burglaries have accounted for the following damages over recent years:

1. Electrical wiring stripped out, replaced and stripped out again. The main motivation for this type of act is reselling the copper in the wires stripped out from the building. While the copper stripped from the wires can be resold for a few hundreds pounds, the repairs cost amounts to thousands of pounds every time. The cost of repair is very high mainly due to the costs of the employment of electrical contractors who also required to certify the new installation every time such large repair is carried out. Therefore the cost of repair is several times higher than the cost of copper, mainly because of the high costs of the specialised highly skilled labour required to perform the fault-finding to identify the wires to reinstall, how and where. Then carrying out the new wiring installation, testing and certifying the new installation every time. This type of costs are devastating to small businesses.
2. Copper pipes are stripped out a number of times causing floods, damage to goods and downtime to the businesses occupying the premises. Once again, the motivation for stealing live copper pipes inside the building is the small gain for copper conversion into cash. Therefore, not only the cost of repair had to be borne by the occupiers, but also the cost of repairing the damage caused by the floods. Additionally, the costs of replacing the goods damaged by the internal floods are significant. Again, every time the copper pipes are stripped form the building the copper can be converted into 3 or 4 hundred pounds every time while the copper pipes replacement cost alone amounts to thousands of pounds every time. This is because not only of the costs of acquisition of the new pipes but the high costs of skilled labour to install it again. The cost of the damage caused to goods can also be estimated to be in the region of thousands of pounds depending on the goods present in the building at the time of the floods.
3. Cost of replacing stolen merchandise. This cost varies depending on the value of the goods stolen each time.
4. Cost of roof repair since the intruders preferred entry point is through the extension’s roof, this is because the extension an a hidden access and it is easily accessible due to its low height.
5. Downtime to the businesses caused by these burglaries and acts of vandalism.

Historically, an act of theft in the building while it provided gains of less than 200 pounds to the thieves, it cost several thousands of pounds in rewiring, roof repair, lost goods, downtime etc not including the increased costs of adding extra security to the building. These are crippling costs to small-medium-sized businesses, and this security issue which is inherent to the building requires a definitive long-term solution.

Once the businesses occupying the building face these issues, they are required to look for a more sustainable building that offers more inherent sustainable security. This inherent security issue has made this building not viable throughout recent years to several small-medium-sized businesses that occupied it. In fact the recent occupation history of the building shows that businesses only managed to occupy the building for a relative short period of time for then preferring other more sustainable buildings to conduct their business in . In turn they moved their businesses elsewhere where they could grow their businesses sustainably. Therefore, this area has missed out in crucial growth opportunities due to the unsustainability of the current extension design.

1.13: The intrinsic security issue of the current extension design.

 

The cost of preserving security with the present extension’s double-pitched roof configuration is very high and therefore unsustainable to the occupying businesses. As we will see here this is mainly due to its design and construction.

The preferred entry point for intruders or buglers into the building is the extension. The extension is not easily visible to the public therefore this offers protected, safe and easy access to intruders especially at night.

The extension is the easiest point of entry into the building because the path surrounding is not illuminated at night. The alleyways that lead to the extension are not illuminated and hidden from public view therefore, intruders feel safe taking this route to access the building. Furthermore the mode of entry through the roof does not require noise to be generated during the breaking ins.

Additionally the low height of the extension side walls allows intruders to make their way into the building through the roof. The side walls of the extension are low enough for intruders to access the roof without using ladders. There is no requirement for ladders to access the roof of the extension from the two lower walls facing Harold Street and Castle Street. Historically once reached the side of the roof without the help of ladders, intruders lifted a few roof tiles to make their way into the building (this does not generate any significant noise level that could wake up neighbours at night who might in turn alert the authorities). Hence the lifting of roof tiles, which does not cause any high noise level, and the non requirement of ladders, make this entry very easy and low risk to intruders. In this way intruders enter the building, at night, relatively safely and without being detected.

Therefore, the high costs of maintaining the extension secure is mainly due to the low height of the side walls facing Harold Street and Castle Street and the method of construction of the roof.

A different design is required for the extension to make it inherently secure in the long term and therefore sustainable to the occupying businesses.

If the walls facing Harold Street and Castle Street were the same height as the roof ridges, a ladder would be required to access the roof and the extension would not be the preferred access point rendering the building inherently secure. This is because it is a risky and difficult endeavour for intruders to carry a ladder and other equipment to climb a high wall safely, especially at night. This high risk would deter most intruders from attempting to access the building through the extension. This alone will make the whole building inherently (by design and construction) secure and hence “sustainable” to the occupying businesses.

The term sustainability, here, is also referred to in the sense of the government’s stated definition in the national planning policy framework as “sustainability” goals .

Also the flat roof will require the use of power tools to make a hole in it to gain access. These power tools would need to be specialised and battery-powered, which would require considerable prior extensive preparation and investment by the intruders. Additionally the noise generated by the power tools will inevitably attract attention. This would make the building even further inherently secure and therefore “sustainable”.

This is because by choosing the correct design for the extension, any means of entry will require the use of equipment and noise will be generated to gain entry into the building. Hence, the increased risks connected to the unlawful entry into the building will deter most intruders.

1.13.1: The high ongoing maintenance costs imposed by the double roof configuration with a valley in between.

 

The middle valley requires ongoing maintenance due to  its construction. Failing to carry out contact yearly maintenance can result in severe building structural deterioration, which can be extremely costly to repair. This is the case when the construction, like in the case of this building, is made partially of wood and structural steel. 

If the whole structure is in steel, then the failure to carry out maintenance of the middle valley will have minor adverse effects. However, when the building is mixed steel and structural wood, the damage from failing to carry out maintenance could be devastating to the building.

Therefore, either a different construction method is required to keep this design, which will render the lack of maintenance not such a devastating event in the long run or the design is changed to an overall better solution . As we have seen and co0ntinue to see, there are instructing design disadvantages in keeping the present design and simply changing the construction to a steel frame. This will still pose inherent security challenges as we have seen int he section where we explain the ease of access by intruders with the current design.

As we have seen, the cost of replacing the structure from hybrid structural wood and structural steed to pure structural steel is not worthwhile due to  the relatively high replacement cost and the inherent risks of introduction plus the inability of a proper feasible installation of renewable energy sources on the building.

Whereas a slight building alteration will make at almost the same replacement/building costs a much more “sustainable” building.  As we have seen, the sustainable term fits into the definition of the government objective for sustainable building in the national planning policy.

1.13.2: Summary of the main causes from a building design perspective that allows ease of access to intruders and the basic design solutions.

 

Therefore, the building design has to be changed in order to make this building intrinsically secure, hence a competitive and unsustainable choice for the occupying businesses.

The ease of access is provided by

The low height of the side walls. This allows the intruders to access the roof safely without the use of ladders. Therefore, our design requires a height which will require the use of ladders and other heavy equipment to access the roof safely. In this way, access to the roof is more difficult and, therefore, it will be deterred.

The ease of access into the building through the roof by simply lifting some roof tiles and creating a hole in the roof through which the intruders access the building. The design solution therefore needs to have a roof which is higher and more impervious to intruders. A roof that requires power tools to allow access through it. If power tools are required, then the burglars and intruders are deterred because of the high noise levels generated during break-ins, attracting the attention of the neighbours.

Therefore, a higher roof and more impervious roof construction are required to achieve a sustainable security level.

1.14: The alternatives are explored to resolve this inherent security issue.

 

Changing the roof from tile to other materials, like resin or metal sheet.

This could improve the building’s security slightly because intruders would very likely require power tools to open up the roof therefore causing noise which would attract attention.

However, access is still very easy due to the accessibility of the roof from the two low walls facing Harold Street and Castle Street. Access to the roof will still not require ladders and other safety equipment. Therefore, the extension will remain the most vulnerable access point to intruders and burglars.

1.15: Single-storey flat roof

 

The intruders will still easily reach the roof and break into the flat roof to make their way in, especially at night. This configuration will still allow easy access to the flat roof without the use of ladders, therefore rendering the building intrinsically not secure.

A single-storey flat roof would present the same inherent high risk of break-ins and vandalisation as currently with the double-pitched configuration.

A single-storey flat roof makes the installation of wind turbines on the roof less energy efficient (due to lower energy capture due to higher wind turbulence at lower heights). Consequently, this will further increase the payback of any future wind turbine installation on the roof. This does not take into account the high risk of theft and vandalisation due to this low height. These risks and disadvantages make the investment in roof-mounted wind turbines not a viable investment for this building configuration.

The same high risk would apply to any solar panel installation. A single-storey installation of a flat roof would make the investment not viable, mainly due to the risk that the installation would be easily vandalised or stolen.

Therefore, any possible future solar panels and/or wind turbine installations on the single-storey flat roof will be highly vulnerable to theft and vandalism due to the low height. This will discourage private investment in renewable energy sources on this building. Renewable energy installations do increase the EPC rating of the building. Increasing the EPC rating of buildings throughout England and wales is a priority of the central government.

For these reasons a single storey flat roof is a comparatively unsustainable development, similar to the current single-storey double-pitched roof configuration.

 

Changing the roof from tile to other materials, like resin or metal sheet.   This could improve the building’s security slightly because intruders would very likely require power tools to open up the roof therefore causing noise which would attract attention. However, this solution has the following issues Access is still very easy due to the accessibility of the roof from the two low walls (parallel to harold Street and Castle Street). Access to the roof will still not require ladders and other safety equipment. Therefore, the extension will remain the most vulnerable access point to intruders and burglars. The high costs of this exercise for the only smalt advantage of having the intruders to require power tools is not worthwhile, due to also the higher maintenance costs of this current double-pitched roof configuration. Also as we will see this configuration has several other drawbacks where the installation of renewable sources would be at risk of vandalism and theft, while additionally, also not financially viable compared to other solutions. The ongoing maintenance costs imposed by the double-pitched roof configuration with a valley in between is still higher compared to a flat roof or a simple pitched roof.

1.16: Match the new flat roof level with the height of the previous top ridges of the double-pitched roofs.

 

The building security risks are dramatically reduced if the height of the flat roof is the same or even slightly lower than the ridges of the current roof height.

Matching the flat roof height to the same height of the current ridges would present several advantages, while at the same time not increasing the top height of the extension.

The main advantage is the increased security of the building. Therefore, a more sustainable development due to the decreased running costs of keeping the building secure. These are substantial savings that can be allocated to business development instead of incurring constant high security costs.

 

 

1.17: Double Storey and Double-pitched roof configuration.

 

A two-storey-high extension with pitched roof matching the height of the main building.

This design is intrinsically secure, but requires costly construction. The installation and payback of future renewable energy solutions on this type of roof configuration do not produce optimal payback compared to the two-storey-high flat roof configuration.

As we have seen from a planning perspective, it is allowable to match the height of the extension with the height of the main building and the surrounding houses. This is because the top height of the roof extension would match the height of the surrounding houses. Although it is admissible from a planning policy perspective (because it is consistent with the look and feel of the area), this arrangement has the following disadvantages:

1. High maintenance of the middle valley’s double-pitched roof.
2. Unfeasibility of the installation of solar panels in a way that renders investment in renewable energy a financially unviable proposition using private funds. This is due to the relatively low efficiency of the panels if installed on the pitched roof and also the high maintenance of the solar panels  due to the height of the roof.

A two-storey building’s pitched roof is relatively more challenging for solar panels and wind turbine maintenance (versus a flat roof) because it requires special training and expensive health and safety preparations to work on a high slope. Any roof repair enquires the uninstallation of the solar panels and their reinstallation to carry out simple  repairs which would otherwise be simple and inexpensive therefore the installation of solar panels in such a configuration increases the normal roof maintenance cots.

The installation of wind turbines would be much more challenging on a two storey double pitched roof. Also the same applies to the maintenance of the wind turbines. Additionally, the double pitched roof brings about a much higher degree of turbulence than a flat roof therefore decreasing the efficiency and therefore making the payback far longer and uncertain.

Also this roof arrangement requires a mush higher installation costs of the wind turbine/s.

All the above renders the investment into solar and wind too uncertain for the appetite of private investors.

1.18: Single-storey flat roof configuration

 

Low height means that the installation of solar panels becomes a high risk investment since it is too easily reachable by intruders and thieves/vandals theretofore making the investment in solar renewable power not viable on a single flat storey roof.

The same applies to the installation of wind power.

The construction costs of this type of configuration are slightly lower than placing a flat roof matching the current roof ridges of the extension. While an elevated flat roof is a much more sustainable design.

 

1.19: Why is this development classed as a minor building alteration?

 

This is a minor building alteration because

1. the footprint of the building is unchanged

2. the top height of the extension remains the same

3 it is an alteration which only seeks to change the roof from double pitched to flat.

It will only increase the height of the side walls facing Harold Street and Castle Street to match the height of the current roof ridges.

The flat roof will be at the same height or lower than the current roof ridges and still one storey lower than the main building and one storey lower than the surrounding houses.

It does not seek to change the full extent of what is architecturally allowable from a planning point of view. What is architecturally allowable from a planning perspective is matching the extension height with the height of the main building keeping the roof as a double pitched.

 

1.19.1: How this small development/building alteration will have a disproportionate positive impact on the area. 

 

This minor building alteration has no negative impact on any neighbouring properties as amply demonstrated in our studies presented in this document.

As we have demonstrated, this minor development (alteration) will not cause any loss of privacy, no loss of light to the neighbouring properties and it passes all the tests to be approved throughout the planning process.

1. This minor development will have a disproportionate positive impact on the area because, despite being a minor alteration to an existing building (which will not have any negative impact on any neighbouring properties), it will:
2. Allow the restoration of this much-needed commercial building. Without this minor building alteration, a sustainable restoration of this building is unfeasible.
3. All the alleyways used to access the rear of the building will be restored, kept clean and secure once again. These alleyways are currently unused, in disrepair and subject to fly tipping.
4. This minor building alteration will deploy private investment in the area
5. The building will become sustainable for normal business occupation.
6. The occupying businesses will be capable to expand and hire locally
7. The type of businesses occupying this building after the completion of this minor development will be very likely to invest in employees skill development, apprenticeships, attract talent from other areas of the country and employ people living locally.
8. The area look and feel in the immediate vicinity will improve dramatically.
9. The local demand for housing will be boosted by the presence of highly skilled employees working at the premises. Therefore encouraging other private capital investment into the renovation of boarded up uninhabitable houses (as stated in the local planning policy)
10. The presence of highly skilled employees will in turn boost the housing demand encouraging more private investment into the regeneration of the area.
11. Further investment will be encouraged into commercial buildings given the outlook betterment of the area.
12. The area will be reinvigorated by the  fact that people will once again, after several years of area degeneration, may decide again to make this area a long term place to live of their choice.

1.20: The extension and most of the main buildings are not visible from any main road.

 

We have demonstrated how our design represents a drastic improvement compared to the minimalist existing design. However, any possible argument that the design is not a clear improvement is easily defeated.  It is important to emphasise the positioning of these minor developments. It does not face any main road and is hardly visible from any main road. Also since the top height of th ebuilding is not increased, it is not any mor visible than it may have been previously.   Therefore, although an objective improvement of the design has been made, any objection in connection with the way the building will look with this new improved extension is easily defeated because

1. The design is a drastic improvement to the existing configuration.
2. The material  used is the same as the existing
3. Its location is as such that it is hardly visible from any main road, therefore minimally intrusive.
4. The top height of the extension remains unchanged.

Although the overall look of the building will improve dramatically as a result of our development. It is important atto realise the the building is not visible form any main road. This is characteristic of the type of development that is subject to permitted development rights in dwelling houses, for example. The permitted development right in the dwelling house allows  the household to add extensions (wining limits) and dormers which extend the scope of the part of the roof which is not facing the main road . The reason for allowing these types of permitted development rights to share holders,  it became there is little if no impact at all on the effect that the development visually does to the back of the properties, which is not  easily visible form the main roads. Hence the relaxation in planning law of any part of  developments that are not easily visible form the main roads.

1. This is the case with our development.
2. Our development is minor.
3. Placed in a part of land where it is not easily visible from any main roads.

1.21: Drawback of rejecting planning approval for this minor building alteration.

Resistance to this minor building alteration is not expected by the council because, as amply demonstrated, this minor development meets all the criteria for approval. This development is a minor building alteration that complies with all planning policies, both national and local as amply demonstrated in this document.

However, if the council attempted to reject this minor development proposal, this will be a major contributing factor in keeping the are in the present deprived state. This area is in need of investment, especially through private capital.

This minor building alteration will disproportionately improves the outlook of the area. Therefore, rejecting the approval will be seen by the public as a failure of the public sector to simply facilitate a minor development that has disproportionate positive consequences to the area and no negative impact. This would grow a sentiment of distrust in the competency of the council to resolve the entrenched deprivation of the area. This is especially true when part of the solution to the issues of this deprived area could be resolved by private investment.

The council is expected to facilitate private capital investment in an area which desperately needs it. Especially when this is deployed in a minor building alteration that will have disproportionate positive impact in the area while meeting all the criteria for approval. In case private capital deployment is not going to be facilitated by the council, this will be negatively viewed by the residents and the public.

In case the planning department will take a stand against this minor building alteration, the building’s unsustainability will continue for longer than required. The building’s full rehabilitation is dependent on the approval of this minor development. This is because the building restoration utilising the the current extension design is not “sustainable” and is not feasible with private capital.

In the current configuration the building will remain incapable of offering full sustainable accommodation to any local business in the long term. As it has occurred until recent years and it is unlikely that most businesses will be able to occupy the building in the long term unless the extension design is improved.

Keeping the current design, the building will be unsuitable, as it is today, to accommodate the viable installation of renewable energy sources. Therefore the building will be incapable of contributing to the government’s “sustainable” goals.

We examined and proved extensively how this minor development meets all the criteria for approval therefore in the unlikely case this minor development application would be refused, we believe there would be very high chances of approval at appeal. In case of approval at appeal the public would be confronted again with the bureaucratic stranglehold on the area, which will only delay the inevitable investment required to improve the area’s conditions.

1.22: Advantages of granting planning permission.

Not with standing that this minor development meets all the criteria for full approval as amply demonstrated in this document, the following are true:

1. Our minor development will deliver a better-looking and pleasant design than what the present design offers. As amply demonstrated, the proposed design blends really well with the area and the building is concealed by the surrounding houses. This will improve the area outlook in general and boost economic development locally.
2. Our minor development helps regenerate the area using private capital. At present, this area is widely considered deprived/underdeveloped. As we have seen this area has uninhabitable boarded-up houses and has several major challenges.
3. Our minor development will increase local highly skilled employment both in the short term and long term.
4. Our minor development will deliver a more durable and improved “sustainable” building construction and design.
5. The inherent sustainability of our design will require much lower maintenance therefore the occupying businesses can allocate their resources into business development and the development of the local job market.
6. This minor development will allow the provision for sustainable energy production on the building, both solar and wind. The flat new roof, which matches the height of the current roofs ridges, will be capable to accommodate the installation of renewable energy sources.This provision is hardly viable keeping the present design.
7. While our development is minor, it does have a disproportionate positive impact on the entire area as amply demonstrated in this document.
8. As part of the works we will incorporate full thermal insulation of the extension.

1.23: The back unused and not maintained alleyway is shared with the properties in Harold Street.

 

Figure 1.9: Derelict State Of One Back Alleway

This alleyway has not been maintained for several years, since one of the back entrances to the entrances to the building has been blocked up for security reasons. This minor development will make the maintenance of the alleyway necessary for the occupier/s of the building, since these entrances will be safe and required again. Also this will improve the safety and monitoring of the alleyway with CCTV cameras and make the surrounding houses and building much safer. For example the arson of 68 Harold Street would have been much less likely to happen if this alleyway were monitred and maintained. This another example of the many benefits brought by this minor development.

 

1.24: Sustainability of this proposed minor development (minor building alteration).

 

According ro the “International Institute for Sustainable Development”, the definition of sustainable development is :

“A development that meets the needs of the present without compromising the ability of future generations to meet their own needs.”

See  https://www.iisd.org/mission-and-goals/sustainable-development

This is the definition adopted for “word by word” in the National Planning Framework.

Therefore, our proposed minor building alteration (minor development) meets this definition because:

It makes the installation of renewable energy sources possible . Hence increase the ability of “future generations to meet their own needs” by promoting a cleaner environment.

Additionally the need for lower maintenance reduces the inherent carbon footprint making this development a further substantial improvement compared to the present alternative (without the approval of our minor building alteration). Therefore the improvement of the building performance constitutes the accomplishment of the “sustainable” objective per se.

Because the new design will resolve the present issues of high maintenance, low security, vandalism and theft the lower running costs of the improved building will lead to the businesses occupying these building to have freed up resources, Those resources can be invested in apprenticeships, high skilled employment and business development in the area. This, therefore by definition, increase the ability “of future generations to meet their own needs”.

This minor building alteration will improve the overall outlook of the area hence “meets the needs of the present without compromising the ability of future generations to meet their own needs”.

This minor building alteration will bring to life a design witch is an improvement compared to the existing alternative and it will blend in a better fashion with the area. Therefore it “meets the needs of the present without compromising the ability of future generations to meet their own needs”

As a result of this minor development we will be thermally insulating the whole extension. This is a feasible investment because it will not add significant extra costs at the building stage and this will be integral part of the government requirement for sustainable development. At present the extension and the main building does not have any thermal insulation. We are under no legal obligation to incorporate any thermal insulation within any part of the building. However if planning permission is granted we will voluntarily integrate full thermal insulation to the extension.

To summarise, our minor developments ensure high levels of sustainability due to

1. Low maintenance
2. Making this extension suitable for the installation of renewable energy devices.
3. High energy efficiency. Lower heating requirements due to the new thermal insulation. Lower carbon emissions.
4. Increased inherent security
5. Better overall design and construction

Therefore, this minor building alteration meets the definition of sustainable development as the definition adopted in the national planning policy. While at the same time, not only preserving the rights of the neighbouring properties but also meeting all other planning policies both local and national.

 

1.25: Unlocking the potential of green energy generation.

Our minor development unlocks the possibility, which is not currently achievable, of the green generation of electricity and heat. This is because the current roof configuration renders the installation of green energy sources a unviable investment.

 

1.26: The proposed use is suitable for the area

This application is not in connection with the use of the building. However given the local planning policy (as discussed at length) this use is perfectly in line with the stated local planning policy.

 

1.27: The appearance and size of this alteration is in keeping with its neighbours and the surrounding area.

The part of the building that our minor development is targeting is the rear of the building. The only part of the building easily visible from any main road is the front of the main building. This part of the building (the front) is not going to be affected by our minor development. The rest of the building is not visible from any main road. It is only visible from the back of the properties that surrounds it. A small potion is visible from the car park.

It said that, notwithstanding the fact that the building is concealed by the surrounding houses the design is considerable an improvement and perfectly in character with the surrounding area and the existing building. This is because the same or similar bricks will be used for the development.

The appearance of our minor development blends in with the surrounding properties.

 

1.28 These external alterations to the existing building is in character

The part of the building that will be altered is mostly concealed from public view. Therefore, whether in character or not should be a major concern from a planning perspective. However, even if it is a major concern, which is should not be, this alteration will be carried out using the same or similar external bricks as the original construction. Therefore, it is completely in character.

 

1.29 Potential increase in noise and disturbance, for example from the comings and goings of extra traffic

The minor development is a minor alteration to the building envelope only. No change of use is made under this application.

For these reasons, there is not going to be any increase in noise , disturbance or any increase in traffic.

1.30: Public footpaths remain unaffected

This minor development consists in a minor alteration only in the building envelope and does not affect any public footpaths or roads.

1.31: Visual effect on the landscape, i.e. loss of trees and

This minor development consists in a minor alteration only in the building envelope, and it is concealed from view from any public road. It clearly does not have any impact on any landscape, trees or hedgerows.

 

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Overlooking

 

 

 

2.1: Overlooking.

 

Overlooking is one of the policy 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.

 

2.2: 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 directly overlooking both properties facing Harold Street and Castle Street. Therefore, the addition of further windows on the 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 if 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 the case of the absence of existing windows in the extension, there is ample pre-existing loss of privacy from the other windows of neighbouring properties.

1. Any new window openings 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.
4. 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 neighbouring property.  This is because the overlooking already exists from the main building and other properties. This exciting overlooking is a normal feature of city centre areas where this type of overlooking is also acceptable nowadays from a planning perspective.

 

2.7: 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 centre 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 essence, 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 maintained, in line with established privacy standards. Therefore, the proposal does not result in material harm to residential amenity.

2.8: 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.

2.8.1: 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 neighbouring 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 centre areas. This therefore becomes the minimum distance requirement for new directly facing windows in order not to cause loss of privacy in city centre 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 of the minimum distance requirement in city centre areas.

 

2.9: 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 a 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 privacy. This is because even if the view is not as good as the direct facing windows, views into the internal space of a dwelling house 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 2.1. 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:

1. It allows a view into neighbouring habitable rooms, especially into Bedrooms
2. It is within a certain distance.
3. 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:

1. Less than 15 degrees angle, no material  loss of privacy
2. 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.
3. 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.

 

 

2.10: Established loss of privacy of the properties facing Castle Street.

 

Because there are established existing windows and an entrance door on the side of the extension facing the properties in Castle Street, placing windows on this side of the extension does  not require planning permission due to established rights.

However, as we have seen, even if there are 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 areas overlooking the properties’ back windows facing Castle Street.

Ground floor window

 

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Visualisation 1.1

 

This analysis assesses privacy implications based on distances and viewing angles, using the standard thresholds:

• Suburban threshold: 20 meters

• City center threshold: 15 meters

• Viewing angle concern threshold: 20° and above

• General rule: If the space being viewed is non-habitable on the ground floor, there is no material loss of privacy, even if the distance is under 20m.

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🔹 1. 17816 – 59° – Distance: 17.81 meters

• Distance: Below both suburban and city thresholds.

• Angle: 59° (wide view).

• Assessment: The wide angle and close distance typically suggest a strong visibility concern.

• Conclusión:
  ⚠️ Potential privacy intrusion, but 🛑 Likely material loss of privacy since the space is habitable.

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🔹 2. 19015 – 54° – Distance: 19.01 meters

• Distance: Slightly below suburban threshold.

• Angle: 54° (moderate to wide).

• Assessment: Could potentially view into private areas, but depends on space usage.

• Conclusión:
  ⚠️ Privacy concern exists, but 🛑 Likely material loss space is habitable.

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🔹 3. 23211 – 42° – Distance: 23.21 meters

• Distance: Well above all thresholds.

• Angle: 42° (very wide).

• Assessment: The wide view is mitigated by the long distance.

• Conclusión:
  ✅ No loss of privacy.

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🔹 4. 24824 – 38° – Distance: 24.82 meters

• Distance: Substantially above all thresholds.

• Angle: 38° (extremely wide).

• Assessment: Though the angle is high, the distance is safe.

• Conclusión:
  ✅ No loss of privacy.

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Summary Table Visualisation 1.1

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Visualisation 1.2

 

Analysis Based on Parameters:

This analysis evaluates potential privacy loss based on two main parameters:

• Distance threshold (Suburban context):
  Less than 20 meters → Possible privacy loss
  Greater than or equal to 20 meters → No privacy concern

• Angle threshold:
  Greater than 20° → Potential for visibility into private areas

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🔹 1. 19234 – 63° – Distance: 19.234 meters

• Distance: Just below suburban threshold.

• Angle: 63°, which is very wide.

• Assessment: This is the only combination that qualifies as a potential privacy concern, since both the distance is below 20m y el angle is wide.

• Conclusión:
  ⚠️ Loss of privacy can be argued, depending on the use of the space. If the view is into non-habitable ground floor, 🛑 no material privacy loss occurs.

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🔹 2. 20287 – 57° – Distance: 20.297 meters

• Distance: Slightly above suburban threshold.

• Angle: 57°, wide view.

• Conclusión:
  ✅ No loss of privacy — Distance exceeds threshold, mitigating the wide viewing angle.

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🔹 3. 24178 – 45° – Distance: 24.178 meters

• Distance: Significantly above threshold.

• Angle: 45°, wide angle.

• Conclusión:
  ✅ No loss of privacy — Safe distance outweighs the wide field of view.

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🔹 4. 25679 – 42° – Distance: 25.679 meters

• Distance: Far above threshold.

• Angle: 42°, moderately wide.

• Conclusión:
  ✅ No privacy concern — Excellent distance.

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Summary Table Visualisation 1.2

 

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Visualisation 1.3

 

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Visualisation 1.4

 

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

The direct distance between the existing windows and the first floor habitable rooms of the properties facing castle street is approximately 24 metres which is well the acceptable threshold. Hence, even if no existing windows were present in this side 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 privacy can be made due to any of the windows facing the properties on Castle Street, even if not window openings were previously present.

However, we continue this study to highlight how existing developments already cause a degree of overlooking and potential loss of privacy..

 

This analysis evaluates privacy implications based on direct distances and viewing angles from the windows of a proposed extension to surrounding properties. It uses the following thresholds:

• Suburban threshold: 20 meters

• City centre threshold: 15 meters

• Viewing angle concerning threshold: 20° or greater

• Privacy rule: No material loss of privacy is considered if a non-habitable ground floor space is being viewed—even when within 20 meters.

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🔹 Viewpoint 1: 23388 – 23.38 meters – 68°

 

Distance: Above threshold.

Angle: Wide view, though not intrusive due to sufficient distance.

Conclusión: ✅ No privacy loss.

🔹 Viewpoint 2: 24332 – 24.33 meters – 63°

Distancia: Well above both suburban and city center thresholds.

Angle: Extremely wide view, but mitigated by long distance.

Conclusión: ✅ No privacy loss.

🔹 Viewpoint 3: 27646 – 27.64 meters – 52°

 

Distancia: Far above the minimum threshold.

Conclusión: ✅ No privacy loss.

🔹 Viewpoint 4: 28945 – 28.94 meters – 48°

Distancia: Substantial distance from neighbouring properties.

Angle: Extremely wide viewing angle.

Conclusión: ✅ No privacy loss.

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Summary Table Visualisation 1.4

 

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Visualisation 2.1

Views into non habitable space on the ground floor.

 

1. 14585 – 52° – Distance: 14.58 meters

Distance (14.58m): Well below thresholds.
Check: Again,  ground floor is non-habitable.
Conclusión: ⚠️ High privacy risk, but 🛑 Likely no material loss of privacy if non-habitable.

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2. 16128 – 44° – Distance: 16.12 meters

Distance (16.12m): Below both suburban and city thresholds.
Angle (52°): Moderate, but wide enough to see into private areas.
Check: the view is into non-habitable space on the ground floor,
🛑 No material loss of privacy.
Conclusión: ⚠️ Potential privacy concern, but ❌ Likely no material loss due to space usage.

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3. 21089 – 33° – Distance: 21.0 meters

Distance (21.0m): Slightly over suburban threshold.
Angle (44°): Very wide viewing angle.
Conclusión:
✅ No loss of privacy — Angle is wide, but distance keeps it safe.

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4. 23153 – 30° – Distance: 23.1 meters

Distance (23.1m): Above suburban (20m) and city center (15m) thresholds → safe zone.
Angle (33°): Wide, above 20° threshold.
Conclusión:
✅ No loss of privacy — Distance mitigates any potential visual intrusion despite the wide angle.

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Summary Table Visualisation 2.1

 

 

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Visualisation 2.2

 

Another view into the first floor windows of the properties facing Castle Street. These are non habitable windows.

1. 15837 – 57° – Distance: 15.83 meters

Distance (15.83m): Below both thresholds → high concern for habitable spaces.
Angle (57°): Very wide field of view → strong potential for intrusion.
Check: If this is a ground floor view into non-habitable space,
❌ Still no material privacy loss. Conclusión: ⚠️ Privacy concern, but Likely No material loss of privacy because the space is non-habitable.

2. 17100 – 49° – Distance: 17.10 meters

 

Distance (17.1m): Below both suburban and city thresholds → normally a concern.
Angle (49°): Wide viewing angle; potential intrusion.
BUT: If the view is into ground floor, non-habitable space,
❌ Like No material privacy loss applies.
Conclusión:⚠️ Significant privacy concerns can be argued, Likely No material loss of privacy because the space is non-habitable ground floor.

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3. 21758 – 38° – Distance: 21.7 meters

Distance (21.7m): Slightly above suburban threshold, well above city center’s.
Angle (38°): Moderate to wide angle.
Conclusión: ✅ No privacy loss — Sufficient distance offsets angle.

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4. 23754 – 34° – Distance: 23.7 meters

Distance (23.7m): Well beyond both suburban (20m) and city center (15m) thresholds.
Angle (34°): Above 20°, allowing a moderate view.
Conclusión: ✅ No privacy loss — Distance sufficiently mitigates any visibility concerns, despite the angle.

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Summary Table Visualisation 2.2

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Visualisation  2.3

 

1. 18346 – 62° – Distance: 18.34 meters

Distance (18.34m): Below both thresholds.
Angle (62°): Wide and may allow private views.
Check: If this is ground floor, non-habitable — still okay.
Conclusión: ⚠️ Potential privacy intrusion, Likely No material loss of privacy because the space is non-habitable.

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2. 19470 – 55° – Distance: 19.47 meters

Distance (19.47m): Just under suburban threshold, below both technically.
Angle (55°): Very wide and potentially intrusive.
Check: If the view is into ground floor non-habitable space,
🛑 Likely No material loss of privacy.
Conclusión:⚠️ Privacy concern, Likely No material loss of privacy because the space is non-habitable.

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3. 23725 – 44° – Distance: 23.72 meters

Distance (23.72m): Exceeds both suburban (20m) and city center (15m) thresholds.
Angle (44°): Wide field of view.
Conclusión: ✅ No loss of privacy — Distance ensures that even with a wider angle, there is no intrusion.

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4. 25531 – 40° – Distance: 25.53 meters

Distance (25.53m): Well above all thresholds.
Angle (40°): Very wide field of view.
Conclusión: ✅ No loss of privacy — Distance completely eliminates any risk of intrusion, even with a very wide angle.

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Summary Table Visualisation 2.3

 

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Visualisation 2.4

 

1. 19812 – 64° – Distance: 19.81 meters

Distance (19.81m): Slightly below suburban threshold.
Angle (64°): Very wide, potentially intrusive.
Check: If viewing ground floor non-habitable space,
🛑 Likely No material loss of privacy.
Conclusión: ⚠️ Privacy concern due to short distance and wide angle, but Likely No material loss of privacy because the space is non-habitable.

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2. 20848 – 57° – Distance: 20.84 meters

Distance (20.84m): Slightly above suburban threshold.
Angle (57°): Very wide and intrusive.
Check: View is into ground floor non-habitable space,
🛑 Likely No material loss of privacy.
Conclusión:⚠️ Wide angle, but Likely No material loss of privacy because the space is non-habitable.

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3. 24670 – 46° – Distance: 24.67 meters

Distance (24.67m): Above both suburban (20m) and city center (15m) thresholds.
Angle (46°): Wide field of view, over the 20° threshold.
Conclusión: ✅ No loss of privacy — Distance exceeds thresholds, so the wider angle does not result in intrusion.

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4. 26594 – 43° – Distance: 26.59 meters

Distance (26.59m): Well above both thresholds.
Angle (43°): Very wide viewing angle.
Conclusión: ✅ No loss of privacy — Distance completely negates impact of wide angle.

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Summary Table Visualisation 2.4