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); Greater London Authority Acts 1999 and 2007; Town and Country Planning (Local Development) (England) 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 Deptford 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 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.