Cllr Alan Hall Response to Lewisham Council’s Local Plan

The Local Plan helps to ensure that planning decisions are made in the best interests of our neighbourhoods and communities. It provides a strategy for the Council and its partners to direct investment across Lewisham, recognising it is an integral part of London. It includes policies and guidelines that are used to determine planning applications.

Lewisham Council says:

“The Local Plan sets out a shared vision for the future of Lewisham along with the planning and delivery framework to achieve this vision.

The Local Plan helps to ensure that planning decisions are made in the best interests of our neighbourhoods and communities. It provides:

A strategy for the Council and its partners to direct investment across Lewisham, recognising it is an integral part of London. Policies and guidelines used to determine planning applications.”

The formal consultation process ran from 15th January 2021 to 11th April 2021 and Cllr Alan Hall has asked what are the next steps in the process to take the public’s views into full consideration.

Cllr Alan Hall made a formal response mentioning the need for more green space and the expansion of the River Pool Linear Park. He said: “I would like to see the biodiversity and green space commitments explicitly included in this Local Plan and at the sites mentioned above. In Bell Green, a community masterplanning approach should be undertaken and the proposals as they stand are unacceptable. The heritage assets of the Livesey Hall, War Memorial and Grounds needs to be fully recognised in any plan for Bell Green.”

On social housing, Cllr Alan Hall has called for a clear and strong statement in the Local Plan, saying: “A target of 50% of all new homes built to be ‘genuinely affordable’, which is defined as housing at social rent levels (which is set on the basis of local income levels); this means that intermediate and market housing products would not be considered as genuinely affordable.”

London Affordable Rent is classified as an intermediate rent product by most housing experts as it is more expensive than social rent.

Bellingham Estate to be Area of Special Local Character

Full response to the London Borough of Lewisham Local Plan:

The Integrated Impact Assessment on the Local Plan published November 2020 states:

“There will also be a need to consider in-combination issues and opportunities associated with redevelopment at both Bell Green Retail Park, as the southern extent of the Pool River Linear Park, and two sites at the northern extent, namely Wickes and Halfords, Catford Road and Pool Court (proposed as a gypsy and traveller site; currently comprises a Site of Importunate for Nature Conservation, SINC).

There could feasibly be an opportunity to extend the Linear Park into one or both of the larger development sites, and it is recommended that this option is explored, with a view to an overall biodiversity net gain, as measured/calculated at an appropriate functional scale. Extending the Linear Park would also be in line with open space objectives, noting the key finding of the Lewisham Open Spaces Assessment (2019), which is that a significant amount of additional provision will be required to maintain standards (of access to open space) over the long-term. However, it is recognised that there is a need to balance wide ranging objectives when considering how best to redevelop these sites.

I support the expansion of the Linear Park.

Site specific policy currently states:

• Bell Green Retail Park – “Development proposals must protect and seek to enhance green infrastructure, including SINC, green corridor, Metropolitan Open Land and the Pool River.”

• Wickes and Halfords, Catford Road – “Development should maximise opportunities to enhance the ecological quality and amenity provided by the River Ravensbourne, including by revealing the river through decluverting, repairing gaps in Waterlink Way and improving public access to it.” This site specific policy is broadly in accordance with the Site Specific Design and Development Guidelines set for Wickes and Halfords, Catford Road within the adopted River Corridor Improvement Plan SPD (2015). Figure 9.1 shows one of the figures from the SPD, showing the location of the Pool River Linear Park between BGLS and Catford, also highlighting proximity of Beckenham Palace Park.

• Pool Court – the site specific policy does not reference biodiversity constraints or opportunities; however, it explains: “Applicants should consult with Network Rail and Transport for London on design and development options.”

I would like to see the biodiversity and green space commitments explicitly included in this Local Plan and at the sites mentioned above. In Bell Green, a community masterplanning approach should be undertaken and the proposals as they stand are unacceptable. The heritage assets of the Livesey Hall, War Memorial and Grounds needs to be fully recognised in any plan for Bell Green.

On the proposed Gypsy and Travellers Site the document makes the specific comments:

“9.7.5 Finally, there is a need to consider the proposed strategy in respect of meeting gypsy and traveller accommodation needs.

The background is as follows: The Lewisham Gypsy and Traveller Accommodation Assessment (2015 and amended 2016) identifies a minimum need for six pitches within the plan period, arising from people currently living in bricks and mortar homes, teenage children and household formation. Having regard to this assessment, the Council commenced preparation of a Gypsy and Traveller Site Local Plan. This set out the approach to meeting identified local need for this group, including through site allocation policies.

A Preferred Site Consultation was then over six weeks in 2018. Consultation responses have been considered and negotiations with landowners are progressing. This is particularly to ensure that any future proposed site is deliverable for the intended use, and that feedback from the wider public is appropriately addressed.

9.7.6 In light of the above, the Draft Local Plan proposes an allocation at Pool Court, which is a 0.3 ha site located to just to the southwest of the Catford Masterplan area; specifically, to the south of the large proposed allocation at Wickes and Halfords, Catford Road. The site comprises a ‘left over’ triangle of land at the point where the two railways south of Catford cross-over one another. The River Ravensbourne borders the site, and the confluence of the rivers Ravensbourne and Pool is near adjacent to the west of the site (separated by the railway); however, the site is shown intersect flood zone 2 (as opposed to flood zone 3, which constrains Wickes and Halfords, Catford Road), presumably because the river is effectively channelled or culverted at this point.

A related constraint is the on-site local nature conservation (SINC) designation, and it is important to consider the biodiversity value of this site not only isolation, but as one element of the ecological network associated with the Ravensbourne and Pool river valleys (see discussion of the Wickes and Halfords site above, under ‘Biodiversity’). Whilst it is recognised that this site has been identified following a site selection process undertaken over a number of years, given the onsite constraints, it is recommended that further detailed assessments of biodiversity and flood risk are undertaken, with additional requirements/guidance included within the site allocation, as appropriate; the council should also continue to explore other opportunities to meet the housing needs of this group.”

I support the need for further detailed consideration of the negative impact to biodiversity and the SINC.

Not only this, I believe that this site is insufficient to meet the needs of the Traveller community and that as a stand alone policy is insufficient to comply with the London Plan.

Genuinely Affordable Housing

If delivery of genuinely affordable housing is a clear corporate priority for Lewisham Council then The Local Plan needs to set a strategic target for 50 per cent of all new homes delivered in the Borough to be locally defined as housing at social rent levels, below the GLA’s London Affordable Rent level. This would recognise the distinctive characteristics of the local housing market and the relative affordability of different types of provision to the resident population.

All other housing products below market levels, whether for sale or rent, are defined as intermediate housing, and should not be conflated with genuinely affordable housing.

To be clear, a target of 50% of all new homes built to be ‘genuinely affordable’, which is defined as housing at social rent levels (which is set on the basis of local income levels); this means that intermediate and market housing products would not be considered as genuinely affordable.

I support the designation of the Bellingham Estate as an Area of Special Local Character and we support further consideration to making this a Conservation Area.

The Industrial Estate in Bellingham is a successful employment zone. The designation needs to be reinforced.

Local Green Space and Metropolitan Open Land needs to be designated at Coutrai Road in Crofton Park and along the railway cuttings from Forest Hill, Honor Oak Park through to New Cross Gate.

Finally, the fact that this consultation has taken place during a pandemic and at a time of limited communication including an election period needs to be acknowledged. Further formal consultation is required to achieve a common understanding of the plans and therefore, this consultation is inadequate.

Yours sincerely,

Alan Hall

Cllr Alan Hall – Bellingham

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