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 façade 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.
