Response to Planning Application DC/25/142180, 33 Dartmouth Road

To Lewisham Planning Department,

I am writing on behalf of the Forest Hill Society regarding the proposed development at 33 DARTMOUTH ROAD, LONDON, SE23 3HN, application DC/25/142180: Change of use of part of the existing lower ground, ground and first floor and the construction of a mansard extension to provide 3 self-contained flats, together with the installation of windows and a terrace door to the elevations, and all associated works at 33 Dartmouth Road, SE23.

The Forest Hill Society is the local amenity society for the area covered by SE23 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 the harm to the Forest Hill Conservation Area and non-compliance with relevant policy.

Heritage

The Forest Hill Conservation Area is characterised by its commercial and retail centre around the railway station and surrounding suburban residential streets and green spaces.

The application site has historically operated as retail at ground floor with accommodation above. The form, materiality and appearance of the building is representative of that Victorian/Edwardian town centre architecture that characterises the Conservation Area. Whilst it has been altered to accommodate new first floor windows with more modern proportions and a new shopfront at ground floor level, original elements like the brick cornice at parapet level and the butterfly roof have remained intact. These features are considered to contribute positively to the significance of the Conservation Area.

The proposals comprise an upwards extension in the form of a standing seam mansard roof, alterations to the windows and reconfiguration of the interior to allow for additional accommodation. This also includes alterations to the shopfront to create access to the new accommodation and reduction of the retail frontage.

This side of Dartmouth Road is very clearly more traditional than the other side, and whilst there are instances of contemporary forms or mansards beyond Dartmouth Road, such as in the more recent developments towards the railway, the built form along Dartmouth Road has retained traditional roofs. There are no mansards on any buildings on this side of the road fronting Dartmouth Road. The acceptance of a mansard roof in place of an original roof form would establish a dangerous precedent within this part of the Forest Hill Conservation Area as well as result in the loss of an original butterfly roof. Moreover, the standing seam materiality of the mansard roof would exacerbate its contemporary origins. Lastly, the proposed upward extension would obscure views of the decorative chimney associated with the Bird in Hand pub, which is considered to contribute positively to the significance of the Conservation Area. Therefore, this element of the proposals is considered to result in harm to the significance of the Conservation Area.

The proposals also include the enlargement of existing windows on both elevations of the building. The existing windows are not currently in their original form or proportions. The proposals to the rear would accommodate Juliet balconies. Given the utilitarian appearance fo the rear elevation, the limited positions in which the windows would be visible, and the mix of window types and proportions to the Conservation Area generally, it is not considered that this would result in any negative impacts to its established character and appearance. However, the windows to the front are more readily visible from the public realm, and the proposed windows would exacerbate what are already negative changes to this elevation. Although the new windows would allow for more light into the proposed residential unit, the form and appearance of the windows would not be in keeping with the existing building and does not preserve or enhance the significance of the Conservation Area. If the applicant were to submit a more traditional window proportion and materiality, this could be considered an enhancement. Nonetheless, the proposals as they currently stand would result in harm to the significance of the Conservation Area.

At ground floor level, it is proposed to reduce the width of the shopfront to accommodate a new residential access. This would create odd proportions on the terraced building whilst also reducing the retail floorspace. Part of the character and appearance of the Forest Hill Conservation Area is attributed to its predominant commercial uses along Dartmouth Road. The loss of retail frontage in exchange for residential would be contrary to the established character and appearance and result in harm.

The Planning Statement states:

"4.29. With regard to the Conservation Area, this planning application is accompanied by a separate Heritage Statement, which considers the development’s impact on the Forest Hill Conservation Area. This concludes that “while the development does have a minor impact on the setting of the Conservation Area, by virtue of the proposed extensions; it is not considered to be unacceptable in the wider context of the character of the Conservation Area. Accordingly, the development would preserve the character and appearance of the Conservation Area, in accordance with the requirements of the NPPF, the London Plan, and Section 72(1) of the Planning (Listed Buildings and Conservation Areas) Act 1990.” "

There appears to be no Heritage Statement on the portal. Furthermore, the above summary fundamentally misunderstands the definition of 'setting'. The application site falls within the boundaries of the Conservation Area, NOT its setting. Setting is defined as the surrounds of an asset in which its significance can be appreciated. These proposals would not relate to setting. The summary has also failed to recognise that even a minor impact equates to harm and thus cannot be considered to preserve the character and appearance of the Conservation Area.

Therefore, we believe the application proposals would result in harm to the significance of the Conservation Area through the loss of features and elements of the site which contribute positively. This harm would be considered 'less than substantial' and should be weighed against public benefits of the proposals. The proposals are also contrary to Policies HE1: Lewisham’s historic environment and HE2: Designated heritage assets in the Lewisham Local Plan.

Policy Non-compliance

Although the floor areas of the proposed flats meet space standards, the layouts are impractical. For example, Flat 1 has a generous floor area over two storeys, with the single bedroom of 10.8sqm and ensuite at ground floor, limiting the occupancy to 1-person. The position of residential accommodation at ground floor level and below is also contrary to Policy EC14 of the Lewisham Local Plan, which states:

"G Development proposals for residential uses on the ground floor level or below, both within the PSA and the wider town centre area, are inappropriate and will be strongly resisted. This includes proposals for the conversion of units currently in a main town centre or complementary commercial, cultural or community use."

Summary

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