David Syme Strategic Planning Manager Department: Planning Lewisham Council Our reference: LDF23/SPDs/SPD02/HA01 3rd Floor Laurence House Date: 24 December 2019 Catford London SE6 4RU

By email: [email protected] [email protected] [email protected]

Dear David

Statement of general conformity with the London Plan (Planning and Compulsory Purchase Act 2004, Section 24(4)(a) (as amended); Authority Acts 1999 and 2007; Town and Country Planning (Local Development) () Regulations 2012

RE: Surrey Canal Triangle Supplementary Planning Document (SPD)

Thank you for consulting the Mayor of London on the Surrey Canal Triangle SPD. As you are aware, all Development Plan Documents in London must be in general conformity with the London Plan under section 24 (1)(b) of the Planning and Compulsory Purchase Act 2004. While it is noted that the draft document is not a Development Plan Document, it has elements of strategic importance and considered worthy of the Mayor’s input. The Mayor has afforded me delegated authority to make detailed comments which are set out below. Transport for London (TfL) have provided comments, which I endorse, and which are attached at Annex 1. This letter provides advice, setting out where amendments should be made so that the document is more in line with the emerging draft new London Plan.

The draft new London Plan As you know, the Mayor published his draft new London Plan for consultation on 1st December 2017. The Panel’s report, including recommendations, was issued to the Mayor on 8 October 2019 and the Intend to Publish version of the London Plan was published on the 17 December 2019. Publication of the final version of the new London Plan is anticipated in March 2020, at which point it will form part of Lewisham’s Development Plan and contain the most up-to-date policies.

General The Mayor welcomes Lewisham’s ambition to deliver much needed growth in the Surrey Canal Triangle area and recognises the positive contribution it can make to delivering development across London for industry, jobs and genuinely affordable housing. The draft SPD early on provides a comprehensive contextual analysis which is welcome. The area’s relationship with London’s Central Activities Zone and opportunity areas could be set out and explored more clearly and more fully. It is important that proposed development in the Surrey Canal Triangle responds to and provides links to these areas too, through walking, cycling and green infrastructure among others. A map setting out the relationship of the Surrey Canal Triangle with the CAZ and opportunity areas should be included as a future amendment as this is not currently clear in Fig. 21. It is understood that the area has been identified as an area for potential growth over the long term. The site was originally designated in Lewisham’s Core Strategy for mixed employment use and since that time an outline planning permission was granted approval in 2012 with a ten year extended time limit for subsequent reserved matters planning applications. It must be recognised that since that time the Mayor’s strategic approach to the management of London’s industrial land has changed. Over the period 2001 to 2015 more than 1,300ha of industrial land was released to other uses across London. This was well in excess of previously established London Plan monitoring benchmarks. The London Industrial Land Demand Study 2017 further compounds the issue by establishing that there will be a positive net demand for industrial land over the period 2016 to 2041. Based on that evidence, the draft new London Plan identifies Lewisham as a ‘retain capacity’ borough in Table 6.2. This means that Lewisham should be seeking to intensify industrial floorspace capacity following the general principle of no net loss across designated Strategic Industrial Land (SIL) and Locally Significant Industrial Sites (LSIS). Lewisham is also identified as being in the Central Services Area in Table 6.2 and boroughs in this area are expected to recognise the importance of providing essential services to the Central Activities Zone (CAZ) and in particular sustainable ‘last mile’ distribution/logistics, ‘just-in-time’ servicing (such as food service activities, printing, administrative and support services, office supplies, repair and maintenance), waste management and recycling, and land to support transport functions. This makes it especially important that existing B8 and B2 uses are specifically identified early on and their wider CAZ significance taken into account. The Mayor strongly encourages Lewisham to recognise the importance of these uses by identifying and protecting or relocating them as part of the emerging Local Plan so that they can continue to serve the important functions of the CAZ. The Mayor has set out the approach for mixed use development proposals on non-designated industrial sites in draft new London Plan Policy E7C. The Mayor recognises that the area has been allocated/designated for mixed use development and has extant planning permission but strongly encourages Lewisham to follow and implement the principles set out in in the draft new London Plan on the basis of the borough’s ‘retain capacity’ status and due to its location within the Central Services Area. The Mayor has published guidance in his practice note on industrial intensification and co- location through plan-led and masterplan approaches to help boroughs to protect much needed industrial land, and Lewisham is urged to follow this guidance. In addition, Lewisham must note that in accordance with draft new London Plan Policy H4A5, where residential development is proposed that would result in the loss of industrial floorspace capacity there will be a strategic requirement for 50% affordable housing and this will also form the threshold for the Fast Track Route under draft new London Plan Policy H5B3. The Neighbourhood Plan area should be illustrated to set out clearly its proximity and relationship to the Surrey Canal Triangle area and that it has been taken into consideration. The Mayor welcomes that the draft SPD responds positively to a strategic view set out in the London View Management Framework (LVMF). The view is 23A as identified in the LVMF; the townscape view Bridge over the Serpentine, Hyde Park to Westminster. While the SPD identifies this view as significant it does not clearly illustrate how the viewing corridor relates to the site in both plan and section. Sectional analysis or 3D modelling would give an indication as to the maximum height restrictions that would be necessary to effectively manage and protect the strategic view. Guidance set out in draft new London Plan Policy HC4 should be followed. More specific comments on the draft document are provided in the following table.

PAGE REF COMMENT Pg. 7 – 1.1 - • The role of the SPD within the hierarchy of planning policy should be set para 1 out clearly • A vision for the area would be useful and should be included here. Pg. 12 Analysis of land ownership/long lease holds would be useful and provide evidence regarding delivery Pg. 16 Clarity on the status (open/agreed/aspirational) of pedestrian/cycling routes and access through/under railway would be useful here as this is key to future development quantum on the site Pg. 18 Fig. 20 needs a key Pg. 19 • Should include area specific planning documents/masterplans • Cross borough development in LB Southwark should also be considered – opportunities for linking spaces and establishing a more coordinated approach • Local Neighbourhood Forums/Areas should be identified and discussed Pg. 21 Clarity on building height limits would be useful and should be explored. Specific locations for tall buildings and associated heights should be identified in accordance with draft new London Plan Policy D8. Pg. 24 Strategic planning objectives should set out indicative quantum of expected development i.e. Numbers of affordable homes, industry and jobs etc. Pg. 32 • Key objectives are laudable but vague – more clarity should be provided to guide development early on • neighbouring developments/public realm schemes beyond SPD boundary should be included in the SPD to allow for more coordinated and comprehensive planning that capitalises on opportunities Pg. 35 SELCHP – Fig.26 should clearly illustrate the zone where development is required to link to the heat network. Pg. 43 Clarification of appropriate heights across the site may be useful here – heat map doesn’t currently reflect what’s consented in outline for Surrey Canal Road. Pg. 46 The SPD should clearly identify specific requirements for stadium access here. Pg. 48 Clarify the stadium specific requirements for spaces and give them priority over others e.g. outside broadcast/segregation of home and away supporters Pg. 52 The SPD should follow the guidance set out in draft new London Plan Policy D8 and should identify where tall buildings are appropriate within the area and clearly illustrate this. Pg. 57 • The Character Areas should include a plan/aerial/pictures of the sites as onwards they currently are • Including opportunities/constraints plans before vision drawings would be useful • Greater clarity on building heights would be useful • Development phasing should be considered Pg. 67 Mitigation measures should be illustrated on this high-level plan e.g. SELCHP

The Gate Area Framework and Station Opportunity Study It is understood that this SPD builds on the evidence and findings of the New Cross Gate Area Framework and Station Opportunity Study. With regards to the overall Framework and how it feeds into Lewisham’s new Local Plan, my officers would welcome further discussions on the land use aspects of this document. Of particular concern is the document’s approach to Strategic Industrial Locations (SIL) and industrial land and waste which does not fully align with the new London Plan.

Next steps I hope these comments inform the preparation of the Surrey Canal Triangle SPD. If you have any specific questions regarding the comments in this letter, please do not hesitate to contact Hassan Ahmed on 020 7084 2751 or at [email protected].

Yours sincerely

Juliemma McLoughlin Chief Planner

Cc Len Duvall, London Assembly Constituency Member Andrew Boff, Chair of London Assembly Planning Committee National Planning Casework Unit, MHCLG Lucinda Turner, TfL

Annex 1 – Transport for London Comments

Transport for London City Planning 5 Endeavour Square Westfield Avenue Stratford London E20 1JN

Phone 020 7222 5600 www.tfl.gov.uk

RE: Surrey Canal Triangle Supplementary Planning Document

Thank you for providing TfL with the opportunity to comment on the Surrey Canal Triangle Supplementary Planning Document (SPD).

The comments below summarise Transport for London (TfL’s) views on the draft Supplementary Planning Document (SPD). Please note that these comments represent the views of TfL officers and are made on a “without prejudice” basis. They should not be taken to represent an indication of any subsequent Mayoral decision and they do not necessarily represent the views of the Greater London Authority (GLA). Any views or opinions are given in good faith and relate solely to transport issues.

General

Supplementary Planning Document

TfL supports the principle of drafting an SPD for this area. To ensure that the proposed developments within the area deliver Good Growth, the Council may wish to add greater detail/guidance to the document in order to have a stronger influence on the developments that are coming forward and to enable developers to be better aware of the Council’s expectations and of the area’s constraints and opportunities

Lewisham Core Strategy

Throughout the document, there are a number of references to the Lewisham Core Strategy. It is noted that this document in 2011, therefore it is possible that the policies that it contained do not reflect current circumstances/aspirations. Whilst it is recognised that this document still forms part of the development plan for the borough, we would suggest if the Council has not already done so to confirm that these policies are still up to date and relevant and have not instead been superseded by those in the adopted London Plan (2016) and also the draft version on the basis it is likely to be adopted prior to the SPD being finalised. A similar point applies to the Development Policies and Site Allocations documents which are over 5 years old.

VAT number 756 2770 08

Healthy Streets

The Mayor and TfL has adopted the Healthy Streets Approach to improve air quality, reduce congestion and help make London’s diverse communities greener, healthier and more attractive places to live, work, play and do business. In light of this, the references to healthy and active living within the document are welcomed. It is recommended that the document includes explicit refers to the Healthy Streets approach and its criteria to align with strategic policy in the Mayor’s Transport Strategy (MTS) and the draft London Plan, and provide detail on how it will respond to this agenda. TfL would encourage the use of the Healthy Streets diagram to further support the guidance contained within the proposed document.

Vision Zero

The Mayor and TfL have committed to delivering a ‘Vision Zero’ approach in London to make streets safer and eliminate death on London’s transport network. We strongly encourage reflecting the Mayor of London’s Vision Zero approach to eliminating all death and serious injuries on the road within the guidance contained in the document.

Public Transport

Significant development is anticipated to come forward within the area. However, it currently has poor public transport connections with the majority of the area having a Public Transport Access Level (PTAL) of 1a or 1b (on a scale of 0 to 6b, where 6b is the highest). Improvements to public transport accessibility within the area will be required to support the quantum of development anticipated and support a shift to sustainable and active modes of travel in line with the Mayor’s strategic mode shift target.

Buses are key to delivering Healthy Streets and achieving strategic mode shift targets. Therefore, future developments within this area will be expected to contribute to the introduction of bus services, either extending existing routes and/or providing new routes. Furthermore, as part of the extant planning permission for this site, a new bus interchange in close proximity to the new London Overground Station and financial contributions to improving existing bus stops/stands was secured. This infrastructure will need to be secured as part of any future development of the area, with references included in section 6.2.

HIF funding has been awarded to provide a new station at Surrey Canal Road and to increase train frequency on the East London Overground line as a whole from 16 tph to 20tph of which an additional 2 tph would be on the Clapham Junction branch serving this area. However, this funding will not be confirmed until a funding agreement has been signed next year and in any case will be subject to the terms and conditions therein. Given the currently low PTAL, the high density anticipated and to deliver the Mayor’s strategic policies the development promoted in the SPD must be dependent upon these improvements being delivered.

It is also useful to highlight that the HIF funding, does not include an allowance for works around the station nor for example additional passenger facilities and materials/design over and above that for existing London Overground stations. Should the Council require further improvements and/or infrastructure above that which has been secured, references should be included within this document and these should be discussed/agreed with TfL to confirm that they are feasible subject to Council and/or third party funding. It is noted that the requirement for improvements to the immediate environment of the new Station is included within section 6.2.

It is important for all developments to be configured to maximise the accessibility to both the new and existing stations and bus stops/stands within the area for pedestrians and cyclists including those with less mobility. This is a particular issue given the levels differences and other existing barriers to movement both within the SPD area and beyond, including within the London Borough of Southwark

Detailed Comments

3.1 Strategic Planning Objectives

Paragraph 1.7 of the chapter refers to the draft London Plan consolidated changes version 2019. This should be amended to reflect the publication of the ‘Intend to Publish’ London Plan, which was published on 17 December 2019.

There are a number of references to policies contained within the draft London Plan. The Council should ensure that the draft London Plan policy wording incorporated into this section reflects the most up-to-date wording.

It is recommended that this section is updated to also include draft London Plan policies on transport and implementation and delivery. These are critical to the design of the area of the prioritisation of necessary infrastructure. Streets, which form part of London’s transport network, make up 80 per cent of London and are an integral part of its public realm.

Vision

TfL is generally supportive of the Vision presented within the SPD.

The Vision refers to creating a healthy, liveable and sustainable place. This is welcomed and in line with the Mayor’s Healthy Streets approach. Since TfL’s previous comments, the Vision has been amended with references to ‘building on the opportunities created by the existing station at South and a new station at Surrey Canal Road’ being omitted. As highlighted previously, improving public transport within this area is key to supporting the anticipated quantum development coming forward within this area. Furthermore, creating strong connections to and from these public transport facilities and key trip attractors will be required to achieve the strategic modal shift and support the car-free nature required for developments within Opportunity Areas. In light of this, it is recommended that the Vision is updated to include references to the importance of public transport within this area to support forthcoming development and the need to create strong and attractive walking and cycling routes.

4.2 Design Constraints and Opportunities

A number of site constraints and opportunities have been identified in Figure 26. The Council should consider amending this figure to identify a north-south route between Millwall Stadium and Lovelinch Close via the Renewal Site and Rollins Street as an opportunity.

4.3 Overarching Principles

In general, the document needs to allow for flexibility to maximise local connections for walking and cycling that can be delivered. It should seek to maximise the permeability of the area, prioritise pedestrians, cyclists and public transport users and ensure that the MTS and London Plan objectives on mode shift can be met. With this is mind, the Council may wish to consider updating Figure 26 and the diagram on page 39 to include the following:

• Discussing with TfL options for its land holding not required for the station, such as the closed pedestrian link on the west side of the London Overground line between Surrey Canal Road and Rollins Street • Pedestrian and cycle links through the housing estate east of Bridgehouse Meadows • Links to Hunsdon Road and Avonley Road via John Williams Close and adjacent parking areas and footpaths • Links to adjacent parts of Southwark within which significant development is coming forward to be supported by improvements to public transport, active travel and the public realm. These areas include Ilderton Road, Hatcham and Verney Road area, as set out in the Old Kent Road Area Actin Plan (AAP). • The role of secondary streets in the hierarchy. These streets can be considered predominantly as public spaces that allow pedestrian and cycle through-movement often with much passive if not active surveillance, but provides access-only for motor vehicles. The secondary streets could therefore play an even more important part of the walking and cycling network that the various off-carriageway routes proposed 4.4 Access and Movement

It is welcomed that that SPD acknowledges that development within the area will need to enable better routes and connections within the site, through the site and with the wider area.

It is noted that the applicant refers to the Mayor’s strategic mode shift target, which is for 80 per cent of all journeys to be made by public transport, walking or cycling by 2041. As highlighted in Figure 10.1 of the draft London Plan, the mode shift target for inner London boroughs such as Lewisham is 90 per cent of all journeys to be made by sustainable and active travel. This chapter should be amended to reflect this strategic target.

This section should seek to be more specific about what constitutes as a ‘route’. This could, and should be dealing with streets (in the conventional sense), off-carriageway footpaths and cycling paths, and public areas within residential estate that can function for through- movement. Each of the aforementioned would benefit from having separate discussions within this section, but it is acknowledged that there can be some overarching principles which have been articulated in the current draft.

This section should clearly identify that the cycle network can also include streets with no or low traffic as well as dedicated cycle paths.

4.5 Public Realm and Spaces

It would be useful if this section commented on public ownership and access, and about any commercial opportunities that arise through public spaces ie what kind of activities want to be encouraged or indeed discouraged within these spaces. The SPD could offer some guidance on the different roles that different space might provide in the overall public space network and what is necessary in terms of infrastructure, design and/or management to make them successful as public spaces including any commercial activity.

Character Areas

It is noted that through the Character Area chapters, there are a number of references to providing car parking and cycle parking away from the public realm.

Whilst the principle of provision of car parking away from the public realm is supported as it will reduce car-dominance on streets, this area is within an Inner London Opportunity Area where development coming forward should be car-free, with the exception of disabled parking. This should be reflected in the policy for all character areas, with further detail on the overall approach to parking provision and its design and management provided.

It is also useful to highlight that excessive levels of undercroft car parking can also lead to blank facades/inactive frontages and misuse.

In addition, it is useful to clarify that cycle parking and entrances should not be hidden from the public realm or other means of ensuring surveillance to provide safe and convenient provision for residents, the work force and visitors.

Character Area – The Stadium, the Lions Centre and Surrounds

The references to designing the new public realm to the front of the Stadium to accommodate the increases crowd on Event Days and for communities to enjoy on non-Event days are welcomed. The design of the public realm should be in line with the Mayor’s Healthy Streets approach and ensure that pedestrians from all walks of life and cyclists can easily navigate around the space. The design should seek to closely link the different parts of the SPD area together and in particular integrate the use and development of the different landholdings. The design should also seek to create a strong connection with local facilities and services including nearby public transport whilst putting in place the arrangements and layout necessary to manage demand especially from the existing and proposed events venues. Short-stay cycle parking provided in this space should be considered from the early outset to ensure that it is secure and easily accessible to support the mode shift target for Lewisham whilst also enabling the space to function well with large crowds.

It is recommended that Principle 5 is amended to ensure that public access to the public realm in front of the stadium is available at all times, albeit it is recognised that the stadium site itself will necessarily not be open 24/7.

It is noted that Principle 5 refers to the provision of car parking and coach parking underneath a raised piazza. Further detail on how this raised piazza will fit in with the wider walking and cycling routes should be provided within the document. As previously mentioned this area should be car free. Additionally, consideration should be given to off site coach (and mini bus) parking for football matches and other large events at the Millwall Stadium and the proposed church and indoor sports arena.

Character Areas – Orion

A new public square is to be provided as part of this character area. Sufficient space should be provided for potential crowding within this area especially given the large church which is proposed.

Principle 3, which seeks the creation of a new public realm/link as part of development of the area linking beneath the East London Overground Line through to Stockholm Road, and another with the proposed new station at Surrey Canal, is welcomed in principle. Further engagement with the appropriate stakeholders, including TfL in regards to the implementation of this should be undertaken.

Character Areas – Excelsior

Due to the site’s proximity to the new London Overground station, greater detail should be provided on how the transport interchange between trains and buses will function. This is crucial infrastructure which will help facilitate active and sustainable travel to and from this area, but also support the quantum of development coming forward. The design of the station and bus infrastructure should seek to seamlessly connect these two modes. Further engagement with TfL on this matter is strongly encouraged, and consideration should be given to establishing a Working Group for this interchange.

Principle 6 relates to the creation of two new links between Rollins Street and Surrey Canal Road, which will allow vehicle and pedestrian access to the development area from the north. Principle 8 refers to the creation of two new north-south routes to the east and west of the plot respectively. Due to the car-free nature of the development that should be coming forward in this area, consideration should be given to making these new routes as ‘Access and Bus only’. As noted above consideration should also be given to connecting in with Lovelinch Close the existing housing area to the south of Rollins Street for pedestrians and cyclists and the potential for westward routes to/from Ilderton Road and beyond.

Character Areas - Timber Wharf The provision of pedestrian access from all sides of the plot, as identified within Principle 4, is welcomed. Vehicular access to the plot will be obtained from Rollins Street and/or Lovelinch Close. Our comments above re westward routes applies

Character Areas – Stockholm and Senegal

Stockholm Road will be a pedestrian priority route, only providing vehicle access to the Stockholm Plots themselves. Prioritising pedestrian movement down this route is welcomed. However, Priority 4 (Page 82) appears to indicate that the new public realm that is to be created between the buildings will also facilitate cyclists’ movement. This should also be referenced within Ambition for the character area and appropriate design and management required for shared or dual use.

Character Areas – Bolina Gardens

Facilitating access between the public realm adjoining the west stand of the stadium and South Bermondsey station, including the utilisation beneath the disused rail archway in the north west corner is welcomed.

Character Areas – Surrey Canal Road

This chapter recognises Surrey Canal Road as a principal circulation route through the development area.

Clear delineation of uses on the footways will facilitate a safe place for pedestrians to dwell or stroll alongside active ground level uses whilst allowing cyclists to pass by safely away from the vehicle carriageway. Currently this route is a shared surface and so consideration should be given to whether segregation is required/desirable

The existing embankments raise the pedestrian and cycleways above the vehicle route but the introduction of activity along Surrey Canal Road together with new crossing places will slow traffic through the Development Area. The difference in levels needs to be addressed in promoting crossings of Surrey Canal Road by pedestrians and cyclists

New legible north-south routes for pedestrians and vehicles will increase the porosity of the area as a whole.

Section 6 .1 - Delivery

It is noted that ‘Transport’ has identified as part of the list of general S106 obligations. Whilst the inclusion on this list is welcomed, there is no indication of priority within the broad category. It is recommended that the list is made more specific and clearly prioritise provision for sustainable transport modes, which is required to support the quantum of development coming forward.

The SPD could provide clarity on what is expected to be funded through Section 106 and what is to be funded through CIL or other public sector sources, and associated timeframes for delivery. There is the possibility that should this not be identified, developers may be under the impression that certain infrastructure requirements are to be funded through CIL which then turn out to be S106 obligations and/or that their delivery will be rather earlier than is possible. In this area Grampian type restrictions on development will be crucial to ensure that it comes forward with the necessary transport improvements.

Section 6.2 – Infrastructure

The following transport infrastructure requirements are identified within this section:

• Surrey Canal Road Station • Improvements to the immediate environment of the new Station • Improved cycle and pedestrian access to South Bermondsey Station through improving the railway archway to the north west . Consideration should also be given to step free access to South Bermondsey. • Bus Services and Infrastructure, including improved bus services, bus shelters and driver facilities • Highway improvements, including junction improvements and additional new pedestrian crossing along Surrey Canal Road Whilst TfL are supportive of all the above improvements, the SPD should make it clear that the above list is not exhaustive and that further necessary infrastructure requirements may be identified as sites go through the planning application process.

It is noted that the SPD identified that the Station will be delivered by “TfL using developer contributions and/or other funding streams in line with the occupation of early phases of development”. We would urge the Council to agree with us suitable wording for the SPD regarding funding of the station ahead of publication of the SPD so as to reflect the HIF position.

Glossary of Terms

Transport for London (TfL) should be added to the Glossary of Terms.