Response to Planning Application DC/25/141944, 2A Radlet Avenue

To Lewisham Planning Department,

I am writing on behalf of the Forest Hill Society regarding the proposed development at 2A RADLET AVENUE, LONDON, SE26 4BZ, application DC/25/141944: The alteration and conversion of the basement and lower basement into a self-contained flat, together with the provision of bike and bin stores and all associated works at 2A Radlet Avenue SE26.

The Forest Hill Society is the local amenity society for the area covered by SE23 (and close proximity) and has around 400 members. The society is keen to ensure that the area develops in a positive way for the people that live and work in it. 

We are writing to object to the above application by virtue of insufficient information and non-compliance with relevant policy.

Insufficient Information

Firstly, the drawings and Design and Access Statement (DAS) do not label the floor-to-ceiling height within the spaces, so it is unclear if the spaces meet space standards. There is not an adequate daylight/sunlight assessment submitted for the proposed basement unit - the only information that has been submitted relates to the house above. The DAS makes reference to new planting being proposed for the proposed Apartment 2 'amenity' area at the front, which is simply the front entrance, but the proposed ground floor drawing only indicates one new planter. 

Policy Non-compliance

 Lewisham's Residential standards Supplementary planning document states:

"5.5 Rooms in attics and basements in conversions: Rooms in basements and semi-basements, unless they can be provided with adequate natural lighting and outlook, should not in themselves form a separate unit of accommodation but should form part of a unit (e.g. the lower half of a maisonette)."

 Whilst the above is only a guidance document, it is a material consideration, and it is clear that the proposed new unit does not have sufficient natural lighting or outlook. 

London Plan Policy D6 'Housing quality and standards' states: "9) Where there are no higher local standards in the borough Development Plan Documents, a minimum of 5 sq.m. of private outdoor space should be provided for 1-2 person dwellings and an extra 1 sq.m. should be provided for each additional occupant, and it must achieve a minimum depth and width of 1.5m. This does not count towards the minimum Gross Internal Area space standards required in Table 3.1." 

The proposal only provides 4.5sqm of private outdoor space in the lightwell. The lightwell is not shown on the proposed ground floor plan when it is shown on the existing plan, and the lightwell is covered by what appears to be a grate. The lightwell is also open to immediately below the access to the rear garden by the house above. Therefore, this lightwell is arguably not private at all and could be covered by the occupants above by furniture or anything should they so wish, and this could not be controlled or restricted by any planning mechanism. The area to the front would also not be sufficient given it is not strictly amenity area and is simply the entrance to the unit.

The established character of Radlet Avenue is that of single-family homes that have not been subdivided into flats. Lewisham Local Plan Policy HO2 'Optimising the use of small housing sites' states: "E. In order to maintain a supply of housing suitable for families, development proposals for the conversion of a single family dwelling, or self-contained unit with 3+ bedrooms, into smaller self-contained residential units (including flats) will only be supported where: d. The development will not result in an adverse impact on local character." The provision of cycle storage, bin storage and the separate entrance to the proposed new unit would negatively affect the character of the streetscape and create visual clutter and inconsistency.

Finally, the submission makes reference to the Lewisham Development Management Local Plan, which was superseded in July by the new Local Plan, 3 months before the submission. It therefore has not been assessed by the agent or applicant against the relevant local policy framework. 

Summary

Therefore, the above comments have highlighted the proposed development does not meet policy requirements and would not provide adequate accommodation. We therefore request the application is refused.