31 March 2023

Planning Application: Bell Green Gas Works Development

Development of three buildings ranging in height between 5 and 15 storeys with 261 residential units at Land at the Former Bell Green Gas Works, London, SE26

Application DC/23/129814



We are writing to object to the above application on the basis of the following points:

1. The level of affordable housing proposed is wholly inadequate, as currently only 4% is proposed. A development of this size should not be approved without getting closer to or higher than the council target of 35%.

2. The development does not comply with Lewisham’s target housing mixes, with too few family dwellings and a disproportionate number of one bedroom dwellings.

3. The location of the proposed residential buildings are so close to the Livesey Memorial Hall that they threaten the viability of the Hall and sports grounds. The existing use of the rear space as a smokers bar area will conflict with the residential bedrooms which overlook the rear of the Hall, creating friction between new residents and the established community use of the hall resulting in complaints. The Livesey is protected under the Agent of Change principle in the revised National Planning Policy Framework of 2018. The Lewisham Plan quotes it, saying “New noise-sensitive development is situated away from existing noise generating uses and activities, or, where this is not possible, providing adequate separation and acoustic design measures.”

While the Applicant intends to address the Livesey’s potential for noise nuisance issues by making windows facing the Livesey non-opening, the ventilation system does not provide adequate cooling and in combination with a poorly modelled fa├žade providing little shading, overheating in the new apartments is a real risk. We would recommend that consideration is given to planning conditions that would prevent complaints of noise nuisance directed at Livesey Memorial Building caused by poorly situated new housing.

4. The public spaces in the proposals are problematic, with large areas including play areas, overshadowed, poor relationships to buildings and inappropriate planting and cycle parking.

5. There is no improvements proposed to the surrounding pavements, highways or wider public realm which is currently poor and will be vital if it is expected that new residents will make their way to the closest station at Lower Sydenham. Improvements that join up pedestrian access around the site are vital to make this development work well and should be considered as part of any approval process.

6. The application does not contain proposals for contributing to the local infrastructure that their development’s new residents will rely on. In particular we are concerned about the stress that this development (and future neighbouring developments) will place on health services in the area.

7. The Livesey consists of 3 nationally Listed Structures. The Livesey Memorial Hall, its Front Wall, and the Livesey Hall War Memorial are each separately listed Grade II by Historic England. The draft Lewisham Local Plan I c. states that: “Important views, both of and from the listed building are protected”, in developments involving listed buildings, and Application site adjoins the Hall’s curtilage at their western boundary. The views shown indicate that the proposals will adversely affect the Listed Building and Structures.

8. The heights of the buildings have not been adequately justified either by reference to existing buildings in the locality or the Bell Green Vision. Although the Bell Green Vision is not an approved planning document, it gave an indication of potential and acceptable heights for the Bell Green development area, based on criteria. Key to the criteria was the location of a new station on an extended Bakerloo Line, providing the justification for greater densities and more height. Even though this criteria is not met, and will not be for at least the foreseeable future, the Applicant considers that this is justification for the proposals to rise to 15 storeys. This has not been justified in relation to the rest of the Vision’s masterplan area nor in relation to the current townscape. The height of the tower should therefore be reconsidered.

We therefore ask that unless these issues are fully addressed, that the application be refused.

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