The Lewisham Local Plan helps to ensure that planning decisions are made in the best interests of our neighbourhoods and communities. It provides a strategy for Lewisham Council and its partners to direct investment across the London borough. Local Plans are town planning documents. They must be compliant with the Mayor of London’s regional plans in the London Plan.
On the 20th September 2021, as a local ward Councillor, Alan Hall said that he had made a formal response to the Regulation 18 consultation – a statutory consultation on the making of a Local Plan – mentioning the need for more green space and the expansion of the River Pool Linear Park. At that time 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.”
Lewisham Council has said that it has considered the responses it has received. The next stage in the process to formally approve a Local Plan is a further consultation called, the Regulation 19 consultation on the Lewisham Local Plan – Proposed Submission document.
The purpose of the Regulation 19 consultation is to provide an opportunity for representations to be made on the amendments to the Local Plan before it is examined by a planning inspector. In accordance with the Planning and Compulsory Purchase Act 2004 (PCPA). The planning inspector will consider all comments on the plan that are made within the consultation period: This consultation period concluded on the 25th April 2023.
Alan Hall made a formal submission and the full text is below:
Dear Strategic Planning,
I have raised the matters below in the Regulation 18 consultation and I cannot see that they have been addressed in full. Hence, I am submitting these detailed comments as part of the Regulation 19 consultation:
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 deculverting, 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.”Annex-3b-Lewisham-Local-Plan-IIA-Interim-IIA-Report
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.
On the section relating to London Squares, I have sent information that a London Square on Taymount Rise is absent from the Council’s list and this should be included now.
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 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.
I understand that the longstanding commitment for a railway station at Surrey Canal Road is in doubt. Lewisham Council paid for the enabling works along the old East London Line many years ago yet, no station has opened. If the tall buildings and high density are to be achieved there needs to be better public transport. The bus services currently are inadequate. Again, tall buildings and increases in density for residential uses require open space. The commitment to a [linear] park along the route of the old surrey canal need to be maintained and strengthened. Mature trees in the area should be mapped and retained where possible.
The loss of employment spaces in general and in Deptford & Bellingham including Bell Green lacks proper justification. The London Borough of Lewisham needs employment areas. There is insufficient consideration of new employment as a solution.
Finally, the fact that the Regulation 18 consultation was conducted during a pandemic and at a time of limited communication including during an election period needs to be acknowledged. These procedural flaws are compounded by this consultation taking place simultaneously with changes to the Statement of Community Involvement and the fact that constitutional changes to Lewisham Council’s planning arrangements have been agreed by the Council whilst this consultation was underway. That is to say, the whole planning process has been in flux whilst this consultation has been undertaken. Taking all of this in account, more formal consultation is required to achieve a common understanding of all the plans and changes proposed. Therefore, this leads me to conclude that this consultation at Regulation 19 is inadequate. The plans are unsound. There is no evidence that these proposals are compliant with the London Plan nor that neighbouring local authorities have positively engaged. I trust that this letter will be forwarded to the Planning Inspectorate.
Former Cllr Alan Hall – Bellingham