A2 - BACKGROUND PAPERS
Planning Policy Guidance PPS1: Delivering Sustainable Development PPG3: Housing PPG4: Industrial and Commercial Development and Small Firms PPS6: Planning for Town Centres PPG9: Nature Conservation PPG10: Planning and Waste Management PPG13: Transport PPG15: Planning and the Historic Environment PPG16: Planning and Archaeology PPS23: Planning and Pollution Control PPG24: Planning and Noise PPG25: Development and Flood Risk
RPG3A: Supplementary Guidance for London for the Protection of Strategic Views 1999
Strategic Policy The London Plan (February 2004) Safeguarded Wharves on the River Thames, Implementation Report (January 2005)
Local Policy Lewisham Adopted UDP (July 2004)
Background & Supporting Research Reports Guidance on Tall Buildings (CABE / English Heritage, March 2003) Convoys Wharf: Urban Design Framework (London School of Economics Cities Programme, July 2001) Report on Convoys Wharf Consultation (Planning Aid for London, March 2002) Convoys Wharf (Roger Tym & Partners for London Borough of Lewisham, January 2003) Convoys Wharf Cruise Terminal Feasibility Assessment (Locum for PLA, October 2003) Convoys Wharf Cruise Terminal: Initial Planning Report (Royal Haskoning for PLA, February 2004) Convoys Wharf Cruise Terminal Financial Feasibility Assessment (Locum for PLA, May 2004) Convoys Wharf Cruise Liner Terminal Assessment (Scott Wilson for LDA, January 2005) London Development Agency Convoys Wharf Eco-Business Research Project USA Study Tour 13-16 April 2003 London Development Agency’s European Study Tour 10-13 June 2003 Environmental Statement Review (Arup for London Borough of Lewisham, June 2003 and May 2005) Transport Assessment Review (Arup for London Borough of Lewisham, August 2003, April 2004, June 2004, January 2005) London Borough of Lewisham Report to Mayor & Cabinet 16 July 2003: London Borough of Lewisham Response to GLA Consultation Report ‘Safeguarded Wharves on the River Thames’
Mayor of London ‘Safeguarded Wharves on the River Thames’ London Plan Implementation Report January 2005 Redevelopment of Convoys Wharf Deptford: Appraisal of Proposed Retail Development (Nathanial Lichfield & Partners for London Borough of Lewisham, April 2005)
A3 - APPLICATION DOCUMENTS For Approval Application Form and Certificates Drawings (for approval) ME: 1 – Red Line Plan (October 2002) 3600/PA/001 – Development Parcels (October 2002) 3600/PA/002 – Development Heights 1 (October 2002) 3600/PA/003 – Routes & Access Points (October 2002) 3600/PA/004 – Development Heights 2 (October 2002) 3600/PA/005 – Basement Parking & Servicing Level (October 2002) 3600/PA/006 – Wharf-Related Development Parcels (October 2002) 3600/PA/007 – Site Elevations and Sections 1 (October 2002) 3600/PA/008 – Site Elevations and Sections 2 (October 2002) Development Framework Principles (June 2004)
Additional Information Drawings (for information) 3600/PA/009 – Tower Elevations (February 2003) 3600/010 – Illustrative Site Context Plan (October 2002) 3600/011 – Illustrative Site Location Plan (October 2002) 3600/012 – Illustrative Ground Level Plan (October 2002) 3600/013 – Illustrative Typical Level Plan (October 2002) 3600/014 – Illustrative Typical Upper Level Plan (October 2002) 3600/015 – Illustrative Typical Tower Plan/Roof Plan (October 2002) 3600/016 – Illustrative Central Space (August 2002) 3600/017 – Illustrative Site Elevations and Sections 1 (October 2002) 3600/018 – Illustrative Site Elevations and Sections 2 (October 2002) 3600/019 – Illustrative Site Elevations and Sections 3 (October 2002) 3600/020 – Illustrative Site Elevations and Sections 4 (October 2002) 3600/021 – Illustrative Site Elevations and Sections 5 (October 2002) 3600/022 – Olympia Warehouse – Existing Plan (October 2002) 3600/023 – Olympia Warehouse – Existing Sections (October 2002) 3600/024 – Olympia Warehouse – Existing Elevations North/South (October 2002) 3600/025 – Olympia Warehouse – Existing Elevations West/East (October 2002) 6914 C100 – Site Plan and Flood Defence Sections (July 2002)
Environmental Statement Main Report Non-Technical Summary 1 & 2 and Technical Appendices (October 2002, Supplemental Information June 2004, April 2005) Planning Statement (September 2002) Design Statement (October 2002) Statement on Tall Buildings (October 2002) Marine Terminal Assessment (October 2002) Delivering Sustainability (October 2002) Statement on Public Consultation (October 2002) Assessment of Waste Recycling & Reprocessing Facilities (October 2002) Environmental Statement Supplemental Information (June 2004) Design Framework Document (June 2004) Transport Technical Note 1: Highway Assessment (June 2004) Transport Technical Note 2: Public Transport Accessibility (June 2004) Transport Technical Note 3: Highway Trip Generation, Mode Split and Distribution (November 2003) Transport Technical Note 5: Car Parking (June 2004)
Transport Technical Note 6 Improving PTAL (June 2004) Transport Technical Note 7 Trip Generation / Census Comparison (June 2004) Transport Technical Note 8 Non-Residential Parking Profiles (June 2004) Transport Technical Note 9 Updated Traffic Modelling (June 2004) Flood Risk Assessment (April 2005) Energy Strategy and Assessment (September 2004)
A4 - MAP SHOWING EXTENT OF PUBLIC CONSULTATION
A5 - RECONSULTATION RESPONSES (APRIL 2005)
Reconsultation took place in June 2004 and April 2005, following the submission of substantive supplementary information. Residents and businesses in the locality were notified and a more comprehensive letter was sent to those who had replied earlier and to statutory consultees and other interested third parties.
13 pre-prepared letters of objection have been received sharing concerns raised by Convoys Opportunity from 15, 19, 20, 25, 50, and 63 Eddystone Tower Oxestalls Road, 33 and 36 Harman House Bowditch, 112 Daubeney Tower Bowditch, 37 Marlowe House Bowditch, 11 Deptford Wharf, 102 Gilbert House McMillan Street, 23 Rochdale Way
12 replies were received from occupiers of 9 and 32 Albury Street, 40 Etta Street, 252 and 315 Evelyn Street, 32 Stretton Mansions Glaisher Street, 4 Sanford Walk, 41 Lanyard House Windlass Place, 13 Woodcote House Prince Street, 71 Parkside Vanbrugh Park.
These raise a number of points that are incorporated in the summary of objections below:
• current proposal is a missed opportunity and a conventional high rise scheme that could be found anywhere in London; • construction of 3,500 flats would be ‘socially unsustainable’ and at odds with the community environment of Deptford. Flats would be bought as investment; • a mix of housing tenure is required; • a mix of dwelling types are needed, including family housing to help ensure stability in the community; • affordable housing is needed; • employment opportunities should be created other than those in service/retail outlets; • some maritime use should be found for available deepwater; • the towers would be out of keeping with the area; • loss of wall around the site; • waste recycling plant (and would remove the responsibility of waste disposal from its producers); • need for range of community facilities; • need for bus services; • the deep water facility should be maintained; • support for alternative proposals that include a cruise liner terminal, which is also backed by the PLA and in various reports; • proposal is contrary to Blue Ribbon Network within The London Plan; • details of environmental impact are still unclear; • loss of light to neighbouring properties; • increase in traffic during demolition, construction and upon the commencement of the use would lead to air and noise pollution and damage to buildings and drains and would require remedial works in the area; • there is no firm undertaking that waste would be transported by barge;
• a significant number of facilities would be required to support the development. These include health, education, leisure and community uses; • query about any Section 106 package the Council might be negotiating; • a heritage centre should be created on site because of its archaeological significance.
In addition, one letter of support has been received (no address given).
Cllr. David Grant (Greenwich West Ward) has written in support of the proposal for a cruise liner terminal. He feels that the three tower blocks are likely to disfigure the area since they would be entirely out of character with other local buildings. He supports high density housing but believes that this could be delivered without the higher buildings.
Letters have also been received from two other people expressing an interest in the development. • The AHOY (The Adventure Help and Opportunities for Youth Centre) Centre, a sailing and boating centre on Deptford Reach has written to explain the nature of their facility and their need for funding. • The Rev Canon Graham Corneck has also requested assistance through Section 106 monies to help the development of a mixed community facility at St Luke's Church, Evelyn Street.
Lastly, a letter has been received from a company wishing to use the existing jetty for the servicing of vessels that would provide a range of services, including commuting.
Thames Water No further response
Environment Agency The EA considers that the ecological response in the resubmission is inadequate: parts of the documentation were missing and the new material did not address earlier concerns. In particular, the submission needs to address impacts upon the river wall and its ecology resulting from works to the riverbed, hard landscaping and the replacement of flood defences. The EA lists the following areas of study that should be addressed in order for full comment: • full assessment of impact upon the foreshore and river wall and any mitigation; • clarification of river bed re-suspension, including concern about possible dredging; • inadequate information regarding enhancements to the river wall to allow fisheries/habitat creation; • no detail of impact on foreshore of any new structures over the inter-tidal foreshore; • insufficient detail about the proposed 16m buffer zone, including the absence of any habitat creation; • no detail of any enhancement to the other waterfront areas, such as the canal; • no proposals for enhancement and mitigation for some protected species (eg. linnets); • the inclusion of green roofs is welcomed, however details have not been supplied and there is no information regarding there their extent or location. Further habitat creation through the site should be provided; • green corridors should be shown across the site;
• native species should be used in planting and only native species should be planted next to watercourses. Tall trees should be avoided at the river edge to exclude roosting points for crows.
Notwithstanding these requirements, the EA restates the need for conditions should permission be granted. These relate to: • approval of reserved matter; • maintenance of flood defences; • completion of scheme for flood defences; • details of treatment to river walls; • examination of risk of groundwater flooding; • details of jetties and similar structures; • inclusion of 16m buffer zone; • provision of suitable brown roofs; • provision of landscape management plan; • details of landscaping; • details of surface water drainage system; • exclusion of soakaways of greater than 2m in depth; • prevention of pollution of groundwater; • details of site foundations to be provided; • site investigation of contamination and remediation, including validation report.
An objection on the grounds of the lack of a Flood Risk Assessment has been withdrawn and the Agency confirms that the (amended) report and measures set out in it is acceptable.
Corporation of London The Corporation expresses continuing concerns about the application. It makes the following points: • Material in the Environmental Statement and Design Framework is still inadequate to demonstrate the impact of the proposals on the Strategic View from Greenwich Park to St Paul’s Cathedral; • The three towers would have a significant impact on the Wider Setting of the Greenwich Park Strategic View and the revised material does not address this concerning sufficient detail; • Further montages should be provided to demonstrate the impact on views of the River Thames and the setting of Tower Bridge; • Further information regarding verification of the submitted montages is not included in the Supplemental Information document.
London Borough of Greenwich Object to the application for the following reason: “The proposed development by reason of its proposed scale, height and bulk would adversely affect the strategic views of St Paul’s and local views from Eltham Park, Greenwich Park and the World Heritage Site. The proposal is therefore contrary to policies D15, D16 and D17 of the Greenwich Unitary Development Plan adopted 1994 and policies D24, D25, D26 and TC7 of the Greenwich Unitary Development Plan, Second Deposit Draft, April 2004.”
London Borough of Tower Hamlets No objection to principle of development but trust authority will ensure relevant national and local policies will be adhered to. In particular ask that there is sufficient public transport capacity for the development to take place or the developer makes reasonable Section106 contributions to upgrade capacity.
London Borough of Southwark No further response
Government Office for London No further response
English Heritage This large, riverside site sits on a broad north-south sweep of the river, in views of Greenwich Maritime to East, and within the wider Setting Consultation Area of strategic view of St Paul’s from Greenwich Park. Formerly Deptford Royal Dockyard, it contains one listed building, the Olympia Warehouse and a Scheduled Ancient Monument, the underground remains of the great storehouse. There is a rich archaeological legacy throughout the site, including structures, dry docks and mast ponds. The Masterplan for redevelopment of the site as a “high density, mixed-use urban quarter”, drawn up by Richard Rogers Partnership, was originally considered by our London Advisory Committee in September 2003. Comments were made then and formally again, when the outline applications were submitted for approval. In both instances English Heritage expressed concern at a number of issues, including the very broad concept of “Development Parcels” and the degree of information to be reserved by condition (everything except access); the fact that archaeology had not been sufficiently acknowledged nor historic assets employed to inform design and create a sense of place; the proposed tall buildings and their impact; the impact on views along the river
As you are aware, there has been continuing dialogue on the proposals culminating in a further report to our London Advisory Committee Meeting of 17th September 2004, to discuss the Design Framework for the site; an Archaeological Resource Management Scheme (ARMS) which closely follows English Heritage advice; and outline designs for tall buildings.
While on that occasion LAC re-iterated their concerns at the approach taken by the scheme, as set out in our previous letters, we are aware that Lewisham Council is now broadly content with the scheme, and is of the opinion that the most significant historical/archaeological features of the site can be safeguarded. We also acknowledge, in respect of tall buildings, that Lewisham’s Revised Deposit Draft UDP does now identify Convoys Wharf as an acceptable location for tall buildings.
The Design Framework provides a key mechanism for ensuring that the development parcels are refined in subsequent detailed applications to enable the historic/archaeological features of the site to be acknowledged more creatively. The effective implementation of the principles of the framework will need to be securely embedded in any grant of consent, and it is accepted that incorporation of the Design Framework into the S106 agreement will achieve this.
The Design Framework will also enable attainment of high quality design of the tall buildings on site. This will be expected to comply with EH/CABE guidance on the design of tall buildings.
The developers’ acceptance of the Archaeological Resource Management Strategy for the site is also an important step in ensuring that the archaeological resource is fully acknowledged and that appropriate mitigation strategies are adopted. Compliance with this should be secured by conditions.
We expect that listed building consent for the re-use of Olympia Warehouse will be sought in due course, but in the meantime would strongly urge the preparation of a conservation management plan for this important structure, which allow its appropriate re-use to be put at the heart of proposals for the site. All parties should seek to avoid the threat of compromise to special interest, which can arise in situations where listed buildings are not given detailed, early and serious consideration in major schemes. It cannot be an afterthought. Its timely consideration may be achievable by condition.
In the light of Lewisham Council’s broad acceptance of the proposals, and willingness to put mechanisms into place to control the development of detailed designs, it is perhaps now time to move on to working closely with the Council and applicants to secure the highest possible standards of design and best acknowledgement of the site’s rich history as detailed proposals are developed.
London Fire and Emergency Planning Authority No further response
Commission for Architecture and the Built Environment The Masterplan has changed very little since the original submission, so comments made in 2002 still apply. At that time, CABE expressed support for the principle of a high density mixed use scheme and commended the way in which the scheme looked beyond the boundary of the site and linked local landmarks and spaces. However CABE was slightly disappointed that higher aspirations had not emerged for a site with a rich historical legacy. CABE also made a number of detailed points and suggested ways in which the scheme could be developed with further information.
CABE has also commented on the Design Framework and agree that those submitting reserved details should produce a design statement. CABE also puts forward the suggestion that the Masterplanners (Richard Rogers Partnership) should be retained to advise the local authority on the quality of submissions. CABE questions the status of the document and whether it would become supplementary guidance or be part of a Section 106.
Looking at detail, CABE feels that design principles for the public realm should be given a higher profile and distances between frontages and the nature of open spaces should become fixed. The Framework places emphasis on corners, suggesting that each should be of greater height compared with its neighbours. The advice could be clearer and specify where this is important. Reference should be made to CABE/EH guidance on Tall Buildings. The Framework would also benefit from more narrative around the illustration to explain the point of the images.
The Royal Parks The Royal Parks strongly object to the proposal as it clearly impacts on the protected strategic view from Greenwich Park. This contravenes previously agreed planning standards and goes against conventional planning standards adopted by riparian planning authorities. The three imposing towers of the development would undoubtedly distract the view and dwarf St Paul’s Cathedral into insignificance in the background of the corridor.
Friends of Greenwich Park The three tall towers would dominate the view to St Paul’s and the (tallest) right- hand tower would come very close to the direct view of St Paul’s itself. The Friends of Greenwich Park consider the effect to be seriously detrimental, dwarfing the Cathedral to the point of invisibility and fencing off the view to the north-west. The suggestion that the view to the Cathedral would be “framed” seems unconvincing given their height, closeness and asymmetrical placing. The existing tower blocks in North Deptford, though certainly not enhancing the view, are much smaller and do not obtrude above the skyline to anything like the same extent.
The Rt. Hon. Nick Raynsford MP was sent a copy of the letter and asks that the Friends are given the opportunity to air their concerns to the Committee.
Port of London Authority No further response on the application. However, the PLA has been actively promoting the use of part of the site as a cruise liner terminal and submitted correspondence relating to this matter.
London Rivers Association The LRA supports the development of the Thames’s potential for the transportation of waste, the proposed recycling plant does not compensate for the loss of over 50% of the site to non-marine related development. The proposal acutely contradicts the requirement of The London Plan for river related uses to take precedence over non-river related uses.
The LRA strongly supports the proposal for the development of a cruise liner terminal on the site of Convoys Wharf. The recent report commissioned by Creekside Forum and the PLA provides substantive evidence as to the technical and economic feasibility of such a facility. The Association believes that the highly imaginative use would act as a catalyst for the development of other marine related uses as well as bringing other wide reaching benefits to the whole of London associated with an expanded tourist market.
The LRA asks that the London Borough of Lewisham rejects the current application and works pro-actively with local stakeholders to provide a clear and inspiring planning framework. The Association would be willing to offer its expertise to assist in such a process.
Greater London Industrial Archaeological Society No further response
London and Middlesex Archaeological Society Make comments on behalf of the Council for British Archaeology. The Society expresses concern that the present proposals pay too little heed to the rich heritage of the site. Call for a redevelopment not merely investigated below ground, but celebrated in the pattern of development above. The overall layout, with its continuation of the High Street to the river is imaginative and welcomed, but the mix of uses and detailed layout are more problematical.
The Society has sympathy with the local campaign for a cruise liner terminal to revitalise the waterfront and to provide employment. A mixed use development makes sense and residential is appropriate though the quantity and height of blocks is questionable.
Naval Dockyards Society The Society welcomes the thoroughness of the desk-based investigations and sample digs and the design response to leave archaeological features in situ and to retain and reuse historic fabric wherever possible.
The Society feels that the Great Dock should be exposed and used, otherwise an unrivalled opportunity would be lost. The option of a paved piazza to the Olympia Building should be rejected in favour of a water element of sufficient size and strength to be a reminder of Deptford’s maritime past.
The Society also has a number of concerns as follows: • the design has not emerged from Deptford’s maritime location, but more of a ‘Heritage backdrop’; • other than the Olympia building, the other historic parts of the site are peripheral; • the proposal to use the old mast ponds (and an option for the Basin) as a shallow water feature trivialises the site’s history and its potential; • the proposal that the Great Dock should be overshadowed by a recycling plant is disturbing; • a fundamental problem of the development is the view that the cultural and historic aspects in the proposal are seen to be ‘dead’. Without a serious proposal for economic re-use, it is difficult how the tokenism within the scheme could be altered.
Lewisham Friends of the Earth No further response
Lewisham Chamber of Commerce No further response
Evelyn Traders Association The retail impact study included as part of the application makes no mention of the Evelyn traders even though the shopping area is nearest to Convoys. A viability study was carried out in 2003 and it concluded that another retail development in close proximity would have an adverse impact on the current traders.
The Evelyn Traders Association supports the alternative marine development of Convoys Wharf with the inclusion of the liner terminal which would benefit the area and the borough in general. The Council should invest in the Triangle to complement and serve any development on Convoys Wharf. This could be funded out of receipts from the sale of Aragon Tower.
Eyeview Neighbourhood Watch and Residents Association No further response
Mayday Housing Co-operative Object to the proposal because ‘it will involve melting down plastics’. This will cause emissions that are likely to be toxic and will disrupt the quality of lives and probably affect people’s health. A further waste recycling plant would exacerbate existing problems.
Tenants Action Group (Pepys) This proposal does not recognise the need for successful employment regeneration in the area to meet the needs of a largely disadvantaged local community. It does not recognise the real historical significance if the site - only in a ‘tokenised’ way, not a ‘living’ way. It does not recognise the need to bring back genuine and sustainable marine based activities to a site that has a unique geography to do exactly that. The redevelopment proposal as a whole gives nothing back to the community as a benefit. No Section 106 agreement benefit indication from what may amount to a £1bn development scheme, in the socially deprived Evelyn Ward, at a time of housing shortage.
The proposals put forward do not reflect any of the consultations with local people. Disagree with the proposed ‘recycling plant’ as Deptford already has the SELCHP, scrap metal recycling on Pepys estate, recycling in Deptford High Street, plus other recycling plants. What is required is places to work. Support the Convoys Opportunity Group’s ideas around re-introducing an active marine environment including a cruise liner terminal. This will complement the range of skill levels required to generate a wide range of employment opportunities for existing local people - unskilled, semi-skilled, and skilled.
What is missing in general are features like a primary school, a secondary school, places for the community to meet, primary health care, sports facilities of the larger scale, e.g, football, rugby, cricket, athletics, etc ( both outdoor and indoor). The existing local facilities will not be able to cope with the vast increase in population, and therefore demand, if this proposal were to go forward. There should be an increase in the proportion of ‘affordable housing’, above 35%, because of the high degree of people on the waiting list for accommodation. There needs to be genuine activities to attract people to visit the site many times over, not just features of limited use and focused on particular sections of the population - the economically better off.
The proposal has the wrong vision for the site. We believe that employment should be encouraged, again, on the site. Olympia, as proposed, is disconnected from the real activities it was designed for, here made into a sterile exhibition container alongside two disconnected ‘ornamental ponds’. Bulk of ‘massing’ of the main ‘low’ buildings alongside wharf stifle human activity- need to be opened up by a more versatile design features. Multi-level wharf for recycling from barges/containers wrong focus of activity on this principal frontage. The whole development of the site is over-controlIed urban design. No creative use is proposed for the water features, canals and marine life park. The diversity of cultures in the Evelyn Ward of Lewisham indicates that the extant tenant profile has over 45% of the population on the made up of BME groups. There is a need to integrate these residents into the everyday life on the site or there is a real danger that half the population will remain isolated from it and unable to contribute.
Creekside Ecology Group The Group express disappointment at the lack of direct contact from the applicants. They question the amount of brown roof that would be provided across the site to replace existing habitats. They are also concerned about the lack of detail of surveys generally in the report and especially in respect of inter-tidal habitat. Lack of access to the site has restricted the Group’s ability to contribute to, and comment on, the process.
Creekside Forum Creekside Forum restates their original objection that the development would result in the loss of an excessive amount of the protected wharf. The Forum considers the amount of residential development to be excessive and one that would overwhelm local services. Alternatively, it would become a self contained community that would not be part of Deptford. Instead the Forum commends the alternative proposal for a cruise liner terminal promoted by Convoys Opportunity.
The Forum makes the following comments in respect of the additional material:
Design Framework: The intention of the document to provide the high quality development of individual parcels is supported as are the principles. These need to be bound into any agreement to ensure adherence when any details are submitted for approval. However, the principles do not make the scheme site specific and there is insufficient priority given to the site’s position on the River Thames. The scheme is gross overdevelopment and one that could be located anywhere.
Sustainable Business Park (SBP) • Comparisons have been made with similar development in other countries, but these are not located in residential areas. • Materials would be drawn from a wide area other than just the immediate locality. • Concern is expressed about the extent of the SBP, which would provide 33,000m² of the 73,000m² of employment floorspace. • Of great significance is the reluctance of the application to commit itself to using the river for the transportation of material. The transportation of material by road would add to the number of HGV movements in the area as well as negating the rationale for a riverside location. • The list of materials to be recycled is still very general, which makes it difficult to predict what processes would take place, as is the volume of material entering and leaving the plant. • Reassurances about air quality are inadequate at present. • There is a contradiction between a proposal for a windowless shed and information in the design framework that suggests that this solution would be unacceptable.
In a subsequent letter, the Forum writes to confirm that following research, they conclude that material would not be transported by river unless a developer was compelled to so do. They add: "Whereas it would be perfectly reasonable for LBL to require the use of water transport either by condition or Section 106 Agreement, there may be knock-on effects. Both conditions and Section 106 Agreements have to be reasonable and proportionate not only in regard to individual clauses but also in their totality. If LBL required the applicants to use water transport then the Council runs the risk of having to scale down other appropriate requirements even though the extra cost is entirely the fault of the applicants. LBL should not accept that the vehicle movements described are the ‘worst case scenario’.”
Additional Transport Assessment Material The Forum is highly critical of the work produced by the transport consultants, most notably in their application of PTAL methodology (the means of comparing accessibility of sites) and despite guidance from the Council’s consultants. There is also a failure to address concerns about capacities on trains stopping at Deptford on their approach to London Bridge. The Forum’s response to the additional material makes a number of detailed points. It concludes: “The failure to set out PTAL calculations in a logical and ordered sequence renders the Transport Assessment defective as a whole as the assertions made by Buro Happold (the consultants) cannot be verified”. They add: “We strongly suspect that the entire planning application is actually based on Buro Happold’s wholly erroneous perceptions of the site’s accessibility. The absence of spare capacity on existing or proposed, services through Deptford station and the limitations of the bus services along Evelyn Street render the applicant’s proposals wholly inappropriate for the Convoys Wharf site.”
The Forum has also submitted ‘Convoys Wharf Cruise Liner Terminal: Economic Impact Assessment’, a report commissioned by Creekside Forum and the Port of London Authority, which concludes that the potential economic benefits to London and to Deptford would be substantial.
SUSTRANS No further response
Greenwich Society No further response
Greenwich Conservation Group No further response
Deptford High Street Association No further response
Pepys Community Forum The Forum has submitted a Social Impact Study prepared by the Civic Trust that represents its concerns which are shared by Creekside Forum. The following points were considered to be of particular significance: • Despite considerable increases in pre-school places, there is likely to be a continuing shortfall with demand exceeding supply, given the history of rapidly changing patterns of childcare and the increasing population of the area; • Reception classes are anticipated to be in excess of 77 places by 2009 and yet Evelyn is a youthful ward with 26% under 16 and projected to grow by 22% in the next 4 years, much of it within the primary age group. Lewisham also has the fourth highest rate of teenage pregnancies in London and the fifth highest number of lone parents, which could exacerbate this situation; • The potential child numbers arising from the Convoys development over ten years could be around 2,500 or more; • There is a major debate over the current shortfall of secondary school places in the north of the borough (likely to increase from 118 to 250 places by 2008) and does not take account of any additional demand from new development. Lewisham already has 23% of the 16 – 60 adult population (33,000 people) with low numeracy and literacy; • BEM communities will comprise nearly half the population by 2011 and there is an increasing asylum population to cater for; • The area is currently ‘under-doctored’ with around 200/month patient turnover, and recruiting staff can be problematical.
The Forum calls for a greater amount of ‘joined-up’ thinking to look at the cumulative impact of development in the area to help make proper provision for education and health.
The Forum has indicated that an economic assessment of development is to follow.
Detailed comments have also been submitted in response to the Design Framework as follows:
• no mention is made of the Silwood SRB or of the Pepys Community Forum; • no mention is made of the lack of transport links between Surrey Quays, New Cross and Deptford; • no overview statement is made about nurturing, sustainability and the integration of existing and proposed green spaces; • concern about the increase in traffic generation and the need for traffic calming. Some of the images suggest less traffic; • there is no statement about the relationship between the public realm and young people. A third of the population is under-19 and this will not change. There could be more imaginative street furniture as the scheme looks as if it is designed for adults only; • no reference to Upper and Lower Pepys Park (all the others are shown) and not enough reference to nature conservation; • insufficient comment on green space sustainability. • There are also detailed concerns about some of the images and the indicative layouts.
Lewisham Design and Conservation Panel Concern that great thought must be given to the impact of the scale of the development envisaged on the surrounding areas, communities and infrastructure. Deptford High Street should not form a future vehicular access to the Convoys site. The opportunity given by the double dry dock should not be missed. Sustainability principles should permeate through the entire development.
Transport for London Covered in GLA Stage 1 report
London Transport Planning Covered in GLA Stage 1 report
Greater London Authority Stage 1 Report 8 August 2003 concludes The Masterplan has responded positively and imaginatively to the key draft London Plan elements envisaged for the Deptford Creek area. The Masterplan will deliver a dramatic new urban quarter predicated on mixed-use high-density development and a high quality environment. There is no doubt that the Masterplan has sought to maximise land use opportunities on Convoys Wharf, however there is doubt whether the identified mitigation arrangements will be sufficient enough with regard to transport, air quality and ambient noise impacts. This report identifies a number of key issues, which need to be addressed before the Mayor can give a formal indication of whether he can support the application. In summary these are as follows: - • Details of, or a commitment to support the creative and environmental industries in the early phases of the development until the industries are fully developed, including flexible terms of lease in terms of rent and minimum rental periods. The LDA can work with the applicant and Lewisham Council to scope the appropriate form of these support mechanisms, although any subsidy is likely to need to come from the development and other sources. • Clarification as to whether there is any flexibility in the financial viability of the scheme to deliver 50% affordable housing provision in recognition of the site’s sub-regional and regional role. The proposed tenure mix of the affordable housing provision. • Urban design/tall buildings/strategic views information and clarification as identified above. Particularly CAD photomontages of the buildings in the context
of strategic views and from local parks to aid in the assessment of their individual and group impact on the skyline and panorama. • Transport issues as identified in the full report. • Final results of the London ReMade study on using the wharf for eco processing or remanufacturing. • Final results of the PLA feasibility study into using part of the site as a cruise liner terminal. Other River Thames/flooding issues as identified in the full report. • Confirmation on the eligibility of properties under Noise Insulation Regulations. Noise impact during actual tram pass-bys, should a tram prove feasible. • Further measures to reduce the air quality impact, particularly from traffic along Evelyn Street. Difference maps showing the air quality impact of the development to demonstrate whether there is relevant exposure in areas with significant increases in nitrogen dioxide. • Evidence that accessible and inclusive design principles have been incorporated into the proposal in line with draft Supplementary Planning Guidance to the London Plan entitled ‘Accessible London’. • Revisions to the ‘Delivering Sustainability’ document as identified in the full report.
Stage 1 report 25 January 2005 concludes: As noted in the previous report from August 2003, the Masterplan has responded positively and imaginatively to the key draft London Plan elements envisaged for the Deptford Creek area. The Masterplan will deliver a dramatic new urban quarter predicated on mixed-use high-density development and a high quality environment. There is no doubt that the Masterplan has sought to maximise land use opportunities on Convoys Wharf, however there are still outstanding issues to be resolved as detailed below.
Affordable housing to be considered on balance with other regenerative benefits offered by the scheme. 35% is offered. The mix of tenure is of some concern and further negotiation will be undertaken with the developers and Lewisham Council including the submission of a full range of alternatives within the toolkit analysis.
Provided the correct procedures are enacted, the conditional realignment of the safeguarded wharf to the designated SBP is supported. This will be secured by legal agreement to ensure the continued usage of the residual safeguarded wharf element. The roll back of the safeguarded wharf element will coincide with the phasing of the development and will also be secured by legal agreement. The legal agreement on the residual safeguarded wharf element occupied by the SBP will ensure the ongoing usage of the Thames for river transport to/from the site.
Transport connections to the site are to be improved with new bus routes proposed, connections to Deptford mainline station improved and both the Greenwich riverside transit scheme and the riverbus scheme explored for future development. Further negotiations will need to occur to secure adequate widths and turning space within the development.
The cruise liner terminal is unfortunately not appropriate. Redevelopment of the site to accommodate the SBP, a cruise liner terminal and other regenerative benefits such as affordable housing would result in the scheme being unfeasible. However, consideration of other options and locations for a cruise liner terminal in London is encouraged.
Creative and or environmental industries should be secured on site by way of condition applied by Lewisham Council and to be referred back to the Mayor. The site is well placed to become a beacon development with respect to energy efficiency in terms of usage and design. All parties, including the GLA are pleased with the direction the scheme is taking.
London Development Agency The LDA is concerned that any development at Convoys Wharf should maximise the regenerative benefits to surrounding residents and Greater London. The Agency and seeks certainty that the Sustainable Business Park (SBP) would emerge in the form described and that its future would be secured in the longer term. The Agency considers that Lewisham Council should seek a clear agreement about the management arrangements for the SBP from inception onwards. Separate to the management arrangements, the Agency also seeks greater certainty about the longer term future of the facility.
Environmental Health Comments covered in main report
Highways and Transportation Comments covered in main report
A6 – EXTENT OF SAFEGUARDED WHARF
A7 –SITE HISTORY: OVERVIEW
Deptford Strand, on the eastern boundary of the site, was probably settled from the Medieval period, and may have been the site of a castle mentioned in Domesday. The manor house of Sayes Court was in existence on the western part of the site by the early 15th century. There are early references to fishing and shipbuilding.
A Royal Dockyard was established on the central part of the site in 1512 as part of Henry VIII’s initiative to develop English seapower. It comprised a storehouse for naval supplies, two docks, three slipways and supplementary facilities such as ropewalks and workshops. Together with Woolwich, Deptford became one of the main centres of naval shipbuilding, and the yard expanded during the 16th, 17th and 18th centuries. In the mid-16th century, Sir Francis Drake’s ship, the Golden Hind, was put into dry-dock here after his circumnavigation of the globe, and its timbers may well remain insitu.
A map of 1753 shows the Great Storehouse, flanked to the south by a 370-foot long dry-dock and to the north by slipways, a wet basin providing access to slipways and another dry-dock, and a victualling yard comprising a mast pond, sawpits and boathouses. The southern part of the site included a range of workshops, together with barracks and accommodation for senior personnel. During the late 18th century, the yard equipped the ships for James Cook’s second and third voyages to the Pacific.
The Olympia Building, spanning the slipways on the main basin, was constructed in 1846. By this time, however, activity at the yard was declining, since its facilities were less suitable for accommodating the larger, steam-powered warships of the time than more modern yards such as Portsmouth. Silting of the channel was also impeding access. The dockyard closed in 1869, although the victualling yard was to remain in use for another century.
The 1753 map shows the landscaped grounds of Sayes Court adjoining the dockyard to the south-west. The house had been re-built in 1568 and is best known as the home, in the late 17th century, of John Evelyn, who published a number of influential works on gardening and horticulture. Peter the Great stayed here in 1698 whilst studying naval architecture at the dockyard. The estate was sub-divided in the early 18th century, with part being incorporated within the dockyard, whilst the mansion became the parish workhouse in 1729. This was subsequently altered and survived until about 1930. Part of the grounds lie within a public park (Sayes Court Gardens).
Following its closure, the dockyard was redeveloped as the Foreign Cattle Market. Most of the main buildings appear to have been retained, although the basin, slips and one of the mast ponds were filled, new sheds erected and a deepwater wharf constructed. The cattle market closed at the outbreak of World War I, when the site became a military depot. Part of it reverted to commercial use during the 1920s, handling a range of cargoes. The site, together with much of the surrounding area, was damaged during the blitz. During the course of post-war reconstruction, many of the original dockyard buildings (including the great storehouse) were levelled and the northern mast pond filled. The naval victualling yard also closed, and the site redeveloped for warehousing. The existing character of the site mainly reflects its development as a roll-on/roll-off terminal for the import of newsprint during the 1980s.
A8 – PHASING OF DEVELOPMENT (INDICATIVE)
A9 - RELEVANT POLICIES IN LEWISHAM ADOPTED UDP (JULY 2004)
The following policies are considered relevant to the outline planning application for Convoys Wharf.
URBAN DESIGN AND CONSERVATION
URB 1 Development Sites and Key Development Sites The Council wishes a high standard of design and townscape quality to be achieved on all development sites. Also sites that contribute to the image of the Borough, by reason of their location or size, are identified as Key Development Sites.
URB 3 Urban Design The Council will expect a high standard of design in new development or buildings and in extensions or alterations to existing buildings. Schemes must also be compatible with or complement the scale and character of existing development and its setting.
URB 4 Designing out Crime The Council will require all development to be designed to provide and improve safety and a secure environment.
URB 5 Design and Location of High Buildings The Council will consider applications for high buildings, and applications should be of outstanding architectural quality and should comply with the various stated criteria.
URB 7 Access to Buildings for People with Disabilities Development of buildings, open to the public and used for employment and education purposes should provide suitable access for people with disabilities.
URB 2 Landscape and Development Applications for development should, where appropriate, include landscape proposals for all areas not occupied by buildings, and be based on a landscape appraisal which takes note of the relevant site features, such as trees or protected or rare species.
URB 13 Trees The Council will seek to maintain, protect and increase the numbers and quality of trees in the Borough.
URB 18 Preserving Listed Buildings The Council wishes to preserve and enhance Listed Buildings and their features of architectural or historic interest.
URB 19 Listed Buildings – Changes of Use The Council will consider the contribution of existing and proposed uses to the character or appearance of the historic building, and will resist proposals which would fail to preserve or enhance the character or appearance of the historic area or building.
URB 21 Archaeology The Council will promote the conservation, protection and enhancement of the archaeological heritage of the Borough.
URB 22 Important Local Views and Landmarks Development which impedes or detracts from Local Views or obscures existing views of Local Landmarks will be assessed against the criteria in the Conservation Area and Listed Buildings policies, but will generally be resisted.
URB 23 Strategic Views The Council will seek to protect and enhance the Strategic Views of St Paul’s Cathedral illustrated on the Proposals Map.
URB 24 Thames Policy Area The Council will seek a high quality of design respecting the special character of the River within the designated Thames Policy Area shown on the Proposals Map.
URB 25 Thames Path The Council supports the concept of a continuous Thames Path as part of the Thames National Trail.
URB 26 Thames Foreshore Opportunities to maintain, and where appropriate, enhance access to the foreshore will be encouraged in conjunction with the Port of London Authority, subject to environmental and safety considerations.
URB 27 Areas of Special Character The Council will continue to maintain and enhance the strategic qualities of the designated Areas of Special Character.
URB 29 Art in Public Places The Council strongly encourage the provision of public art in association with all major development schemes in the Borough.
OPEN SPACE
OS 6 River Corridors The Council will seek, where appropriate, to protect, enhance and restore the natural elements of the river environment.
OS 8 Areas of Public Open Space Deficiency The Council will concentrate its efforts to create new and enhance public access to existing open space, and to negotiate with developers for new provision.
OS 12 Nature Conservation on Designated Sites Development on or within Sites of Nature Conservation Importance, will not be permitted if it is likely to destroy, damage or adversely affect the protected environment.
OS 13 Nature Conservation The Council will seek to protect and enhance the nature conservation value of all sites, through the imposition of planning conditions or through ensuring alternative equivalent new habitat provision nearby.
OS 17 Protected Species Planning permission will not be granted for development or land use changes which would have an adverse impact upon protected species which are rare or under threat in London. Certain plant and animal species including all wild birds are protected under the Wildlife and Countryside Act 1991.
ENVIRONMENTAL PROTECTION
ENV PRO 1 Waste All planning decisions about waste management facilities will be taken in accordance with the principles of Best Practicable Environmental Option (BPEO), the Waste Hierarchy, the Proximity Principle and Regional Self Sufficiency.
ENV PRO 5 Waste Management Facilities The Council will assess applications against specific criteria. Sites of Nature Conservation Importance, Metropolitan Open Land, Public Open Space and Urban Green Space will generally not be regarded as appropriate locations for waste management facilities.
ENV PRO 7 Environmental Impact Assessment Where a development is considered to have significant likely effects upon the environment by virtue of factors such as its nature, site and/or location, a statutory environmental statement will be required to be submitted with the application.
ENV PRO 8 Air Quality Management Areas Any significant development proposed within an Air Quality Management Area (AQMA), as identified by the Council, will be required to include an assessment of its likely impact on air quality.
ENV PRO 9 Potentially Polluting Uses Applications for a polluting or potentially polluting use will be assessed against specific criteria.
ENV PRO 10 Contaminated Land Proposal on contaminated land, or land suspected of being contaminated, the Council will require developers to investigate and identify any remedial measures that may be required to deal with the hazards.
ENV PRO 11 Noise Generating Development The Council will resist development that could lead to unacceptable levels of noise. A noise impact survey maybe required, outlining possible attenuation measures.
ENV PRO 12 Light Generating Development Proposals for light-generating development, floodlights or otherwise obtrusive lighting may be required to be accompanied by a detailed light-impact survey outlining possible attenuation measures.
ENV PRO15 Sustainable Surface Water Drainage in New Development Where appropriate surface water should be disposed of as close to source as possible, or be attenuated before discharge to a watercourse or surface water sewer.
ENV PRO16 Protection of Tidal and Fluvial Defences
Development will not be permitted which would adversely affect the integrity of London’s tidal or fluvial defences.
ENV PRO 17 Management of the Water Supply Major new development should seek to incorporate measures to prevent the depletion or reduction in quality of groundwater or surfacewater that can jeopardise future supplies.
ENV PRO 19 Energy Efficiency Developments should have regard to the principles of energy and natural resource efficiency through their design, orientation, density and location.
ENV.PRO 20 Renewable Energy Developments The Council will consider environmentally acceptable forms of renewable energy where there is no conflict with other policies sin the Plan.
HOUSING
HSG 2 Housing on Previously Developed Land In the interests of achieving sustainable development the re-use of previously developed land will be promoted. The Council will normally consider housing as its preferred alternative land use.
HSG 3 Provision of Housing Sites The Council will aim to exceed the Governments target of 8,400 dwellings between 1992 and 2006 and will work towards providing a minimum of 11,000 units between 1997 and 2016.
HSG 4 Residential Amenity The Council will seek to improve and safeguard the character and amenities of residential areas throughout the Borough.
HSG 5 Layout and Design of New Residential Development The Council expects all new residential development to be attractive, to be neighbourly and to meet the functional requirements of its future inhabitants.
HSG 6 Dwelling Mix The Council will seek a mixture of dwelling sizes in the case of residential developments of 15 units or more. The mix will be determined by reference to the housing needs of the area, the nature of the development and its proposed relationship to the surrounding area.
HSG 7 Gardens The Council will seek in all new dwellings the provision of a readily accessible, secure, private and useable external space. Family dwellings should be provided with their own private garden area.
HSG 13 Affordable Housing The Council will continue to work with housing associations and private housing developers to provide a minimum of 2,800 affordable units between 1997and 2016.
HSG 14 Provision of Affordable Housing
The Council will negotiate for an element of affordable housing to be provided on any site of 0.5hectares or more or capable of accommodating 15 dwellings or more that comes forward for housing development and including mixed use sites.
HSG 15 Creating Viable and Balanced Communities The Council will seek, in agreement with developers, for the affordable housing contribution to be provided in a way which assists in securing a more balanced social mix.
HSG 16 Density New residential development should normally be built within a density range of 180- 210 habitable rooms per hectare. Higher densities maybe acceptable within specific criteria.
HSG 22 Consultation on Housing Developments The Council will consult the public, the Design Conservation Panel, the Amenity Societies Panel, landowners, developers and where appropriate adjoining boroughs in the preparation of Planning Briefs, other planning studies including Conservation Area designation, and on development applications for housing development.
SUSTAINABLE TRANSPORT AND PARKING
TRN 1 Location of Development Proposals that generate a large volume of traffic or person movement must be located close to good public transport facilities or where this can be provided as part of the proposal.
TRN 2 Travel Impact Statements The Council will require Travel Impact Statements, which assess the likely travel movements by all modes and their impact on congestion, safety, and the environment of the surrounding area.
TRN 3 Developer Contributions Contributions to highway improvements or traffic management measures and to public transport services or facilities or other measures to improve accessibility by pedestrians or cyclists will be sought from developers.
TRN 4 Access for Public Transport Developers of major schemes should provide road and footpath access that takes account of the requirements of public transport providers.
TRN 5 Green Travel plans The Council encourages business or organisations that either employ or attract a large number of visitors to draw up Green Travel plans. An S106 may be sought on this matter.
TRN 8 Use of River Thames The Council will support the increased use of the River Thames for both freight and passenger transport, provided access and environmental quality of the River and surrounding land uses is protected.
TRN 10 Protection and Improvement of Public Transport The Council will support the provision of public transport by assessment of specific criteria.
TRN 14 Cycle Parking The Council will negotiate provisions for cycle parking.
TRN 15 Provision for Cyclists and Walkers Developments should make good provision for users and visitors to cycle or walk to and from the development including cycle parking and storage facilities.
TRN 16 Developing Pedestrian and Cycle Networks The Council will implement the Strategic Cycle Network and the Strategic Walking Routes as shown on Map 6.3.
TRN 17 Protecting Cyclists and Pedestrians The Council will take full account of the needs and safety of cyclists and pedestrians and people with disabilities when developing and implementing traffic management and parking schemes.
TRN 26 Car Parking Standards The Council will require the provision for off street parking in accordance with specific standards.
EMPLOYMENT
EMP 1 Land and Premises for Employment Purposes The Council will aim to ensure a satisfactory supply of land and premises for employment uses.
EMP 2 Promotion and Retention of Creative Industries The Council will seek to retain existing premises in use by the Creative Industries, and to promote the development of new premises.
EMP 7 Live-Work Developments Live-work developments will be welcome in Defined Town Centres, and locations closely associated with Local Shopping Parades.
EMP 9 Convoys Wharf Special Policy Area Part of Convoys Wharf, as shown on the Proposals Map, is a protected wharf by two Directions made by the Secretary of State for the Environment. New developments within this area must use the site as a wharf, as described in the Secretary of State’s directions, and will be referred to the Mayor for London before permission is granted. New development proposals for those parts of Convoys Wharf, not included in the Protected Wharf Area shall be considered in the light of the requirements of Policy EMP 2 9A and 9B where appropriate. New development proposals which do not involve wharf uses will need to prove that the wharf is no longer needed for this purpose. In order to do this the following information will be required: (a) the length of time the site has been vacant, and demonstration by any applicant that the site has been actively and appropriately marketed for use as a wharf, having regard to port operator development timescales, together with current and future market demand for such a use; (b) environmental impact of any current and future wharf use that may come forward (e.g. aggregates), and the physical suitability of the site for this;
(c) geographical proximity, and connections, to existing and potential market areas; (d) the contribution a development not involving use of the site as a wharf would make to the physical, economic and social regeneration of the Borough, including the number of jobs likely to be created by the proposal.
EMP 9A Convoys Wharf – Comprehensive Redevelopment If the criteria for release of the Protected Wharf from use as a wharf as described in Policy EMP 9 are satisfied, the Council will require a predominantly employment related mixed-use development, subject to a detailed Masterplan to be prepared for the site, involving all the following uses: - (a) tourism, heritage and leisure uses, especially those that enhance the river- related heritage of the site; (b) commercial development especially river-related commercial development, including B1, B2, and live-work units; (c) high density housing.
EMP 9B Convoys Wharf – Partial Redevelopment In the case of wharf uses remaining on the land reserved as a wharf, or on part of the site, or where the site, or part of it, is still reserved for use as a wharf, any new development proposed on the rest of Convoys Wharf should not interfere with the operation of the wharf, or prejudice its future operation. New development on Convoys Wharf, outside of the land reserved as a wharf should be, in these circumstances, for all the uses identified in Policy EMP 9A, so far as this is consistent with the maintenance of the wharf use. It should also be subject to a detailed Masterplan which will include the requirement that the employment contribution from the rest of the Convoys Wharf is maximised.
SHOPPING AND TOWN CENTRES
STC 2 Location of New Stores (Sequential Test) The Council will grant planning permission for additional retail use, and in particular substantial additional retail in the Major and District Town Centres. Proposes for substantial retail provision (normally greater than 1,000m2) will only be considered if specific criteria are satisfied.
STC 12 Mixed Use Development The Council welcome development proposals which involve appropriate mixed use schemes or a compatible mix of uses within close proximity to each other and are well served by public transport.
LEISURE, COMMUNITY FACILITIES AND EDUCATION
LCE 1 Location of New and Improved Leisure, Community and Education Facilities The Council will welcome proposals to provide new buildings, or to adapt existing buildings for specific uses.
LCE 4 Places for Children to Play The Council will seek to provide attractive, safe and accessible places for children to play.
LCE 5 Day Nursery and Child Care Facilities The Council will seek an adequate number of day nurseries and facilities for the care, recreation and education of children.
IMPLEMENTATION, RESOURCES AND MONITORING
IRM 3 Community Benefit and Planning Loss Where appropriate, the Council will expect planning applications for built development to include proposals which: (a) deal with the fair and reasonably direct and indirect infrastructural requirements of the development; (b) will ensure that there is not a consequential and significant planning loss to the existing community subject to; : (c) it being understood that the proposals for community benefit can vary according to the impact of the proposed development; (d) the effects of development being assessed, where relevant, in combination with those from other related proposals; (e) the proposals being secured by a planning condition or obligation, or other legal agreement or undertaking.
IRM 4 Consultation The Council will consult the public, the Design and Conservation Panel, the Amenity Societies’ Panel, landowners, developers and where appropriate adjoining boroughs in the preparation of Planning Briefs, other planning studies including Conservation Area designation, and on development applications.