David Syme Department: Planning Strategic Planning Manager Our reference: LDF23/SPDs/SPD01/CG01 Lewisham Council Date: 24 December 2019 3rd Floor Laurence House Catford London SE6 4RU

By email: [email protected]

Dear David

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

RE: New Cross Gate Supplementary Planning Document (SPD)

Thank you for consulting the Mayor of London on the New Cross Gate 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) has provided comments separately.

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 1 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 optimise development on the sites covered by the New Cross Gate SPD. The Mayor is particularly supportive of the sections of the SPD that provide for the safeguarding for the Bakerloo Line Extension (BLE) worksite and station. More detailed comment in this regard are provided by TfL in its response.

The draft SPD provides a contextual analysis which is welcome. The Mayor welcomes the reference to the Lewisham, Catford and New Cross opportunity area and the Deptford Neighbourhood Forum Area on page 13 of the draft SPD.

Creative Enterprise Zone

The Mayor welcomes the reference to the New Cross and Deptford Creative Enterprise Zone (CEZ). He would welcome further detail on how the borough will, in particular: • Retain creative talent from the borough’s education institutions, Goldsmiths and Trinity Laban, and in the local community through access and tailored support for employment and enterprise; • Increase affordable spaces for the fast-growing creative and digital cluster via Goldsmiths’ Enterprise & Innovation Hub, and opening 80 new artists’ studios by Second Floor Studios/Anthology; • Embed development policies within the local plan and business rates, and identifying council’s assets that can help the sector to thrive.

In this regard, the Mayor welcomes the potential provision of workspace on Goodwood site. The SPD should set out how space for creative industries will be delivered.

Transport

The draft SPD expresses the Council’s support of key transport policies included in the adopted and draft London Plan and generally applies them appropriately to this site’s context, including relating to Healthy Streets and the BLE. However, while including mention of draft London Plan policies on car parking, given the location of the SPD area all development, including any re-provided retail, should be car-free except for disabled persons.

There is relatively little mention of existing congestion and road safety problems on the A2 New Cross Road, and much greater emphasis on this is required, together with a requirement that the proposed development contributes significantly to the resolution of these problems. Consequently, any proposals would be expected to deliver improvements on this road, including for pedestrians and cyclists. Further, any new or revised junction arrangement proposed onto the A2 should perform at least as well as the existing site accesses in order to avoid potentially significant impacts on traffic, with particular concern over bus movements.

Similarly, there is relatively little mention of capacity problems at New Cross Gate station, and none of crowding on the rail lines serving it, and again a much greater emphasis on these points is required. Station improvements should be an integral part of the development of the area, to address the immediate problems. However, significant capacity improvements are unlikely to be feasible on Overground and Southern services. Consequently, while the SPD assumes that BLE will be delivered, is should also be specific that the scale of development proposed cannot be deliverable without the capacity and connectivity benefits that would be provided by the BLE.

There are further and more detailed comments in TfL’s response sent separately.

Public space

The Mayor welcomes the focus on the provision of suitable and robust public space and public realm and the incorporation of children’s play space into the SPD area. The SPD could cross reference any specific standards set out in Lewisham’s Local Plan and show indicative spaces on the illustrative masterplan.

Housing

The Mayor welcomes the aim of the SPD to optimise development, including the delivery of housing. It should be noted that the draft new London Plan sets a minimum threshold of 35% affordable housing for developments to follow the Fast Track Route under draft new London Plan Policy H5B3.

Given the proposed mixed use development and Lewisham’s aim to protect and enhance night time cultural uses, the SPD should refer to the agent of change principle as set out in new London Plan policy D13.

Tall buildings

The Mayor welcomes the inclusion of a definition of a tall building and Figure 44 which shows potential suitable location for taller buildings. In this regard, Figure 30 shows that the south-west corner of the site falls within the background of LVMF Protected Vista. The SPD responds positively to this designation and local views by seeking a detailed assessment of views at local and cross London levels.

The New Cross 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 New Cross Gate SPD. If you have any specific questions regarding the comments in this letter or would like to discuss the development of Lewisham’s Local Plan and its evidence base, please do not hesitate to contact Celeste Giusti on 020 7983 4811 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