The Bell Green Neighbourhood Forum has a panel of local architects, civil engineers, a traffic engineer and environmental experts who have studied the plans. We are all keen to see this site redevelop, but think that this application is unsatisfactory. This is their response.
Emma Talbot, Director of Planning, Lewisham Council Planning Ref. DC/23/129814 Barratt Homes
Bell Green Works
Objections from the expert panel of the Bell Green Neighbourhood Group
Approved by the membership, 25th March; submitted 27th March 2023
1. The development has far too few affordable homes. Barratt is offering only 4% affordable housing. Lewisham’s strategic target is 50% of all new homes. Lewisham’s minimum requirement for fast-track route is 35% affordable housing. The 4% isn’t guaranteed and may be revised down for ‘financial viability’ reasons.
2. The development has a disproportionate number of one-bedroom units, and the balance of property sizes will be a problem if Barratt should not be able to get a subsidy from the Mayor of London. The draft Lewisham Local Plan Policy H01 section E states that “a reasonable proportion of family units [3 bed or more] to be delivered on major developments. This scheme offers only 10% family dwellings.
3. The footprint of the Barratt scheme threatens the viability of the Livesey Memorial Hall and sports grounds. By placing the blocks so close to the Livesey, the existing use of the rear space as a smokers bar area will conflict with the many bedrooms that will overlook ‘Livesey Square’, as the developers name this area, and create conflict between the Halls existing use and the new residents. The Livesey is protected under the Agent of Change principle in the revised National Planning Policy Framework of 2018.
4. the Lewisham Plan quotes it, saying “New noise-sensitive development is situated away from existing noise generating uses and activities, or, where this is not possible, providing adequate separation and acoustic design measures.” See
https://www.shoosmiths.co.uk/insights/a ... iple-14454
5. The developers intend to address the Livesey’s potential for noise nuisance issues by making windows onto that aspect non-opening. The cooling system, however, doesn’t provide the capacity to manage this, and the shallow window reveals will amplify the overheating problem. The green credentials of the scheme are inadequate, including the compromise in using air heat pumps instead of ground heat pumps, while their calculations are not futureproofed against climate change. Briary’s energy strategy report proposes inadequate 93 litres per second air flow to combat overheating. There is no mention of adiabatic cooling, or ground air pumps.
6. The public spaces on the development are problematic, being largely in the wrong place, and poorly thought through. Areas are included which are likely to encourage antisocial behaviour, play provision is made where there is very little sunlight, and the commercial units are scattered around, providing very little sense of place. Plantings seem inappropriate for the suggested area use, and bike racks are placed where they will obstruct pedestrians. The SGN gas substation is poorly integrated into the scheme, as is the 15-storey point block D.
7. Barratt Homes is not contributing to the local infrastructure that their development’s new residents will rely on. Neither the NHS’s need for the new Neighbourhood 4 hub at Sydenham Green Health Centre, nor the critical losses of local sports provision are advanced.
8. Barratt are applying for a car-free development, despite a Public Transport Access Level of 2 – out of a possible 6b. The 2021 London Plan says that PTAL 5-6 developments must be carfree. Inner London developments with PTAL 2 may have a maximum 0.5 spaces per dwelling. PTAL 2 shows the poor public transport makes a car-free development unrealistic, and grossly overdelivers the London Plan requirements for PTAL2 areas.
9. The development fails to deliver on the London Plan requirements for sustainability. The Design & Access Statement doesn’t address the issues at all, and the Sustainability Statement shows the development doesn’t minimise carbon emissions in construction and operation, as claimed. The Whole-Life Carbon Statement lacks citations for its benchmarks, and the Circular Economy targets are not ambitious. Futureproofing has not been achieved, despite the immediate threat of global warming.
10. The development is not exemplary architectural quality and should not be used to set the tone for developments coming forward locally, as suggested by Barratt in their Planning Statement (1.3).
11. The Livesey consists of 3 nationally listed structures. The Livesey Memorial Hall, its Front Wall, and the Livesey Hall War Memorial are each separately listed Grade II by Historic England. The draft Lewisham Local Plan I c. states that: “Important views, both of and from the listed building are protected”, in developments involving listed buildings, and Barratts site adjoins the Hall’s curtilage at their western boundary.
12. Barratts have failed to produce images of the visual impact of the development behind the Livesey from Perry Hill, despite being asked repeatedly. We need to see a series of artist’s realisations of the set views, or preferably a 3-D model so the local community can understand what they are being consulted on.
13. Lewisham’s own commissioned Lower Sydenham and Bell Green Vision Study shows that buildings of up to 5 storeys are suitable in the site zone. Given that the developers were instructed by Lewisham to follow the Vision Study, it is surprising that they are applying for tall buildings including a 15-storey point block. There is no townscape justification for a tower on this site, and with the massing of the other blocks, will have a negative impact on the listed Livesey Memorial Hall.
14. The heritage report is inaccurate and makes several false assumptions with no evidence cited. The claim that the Livesey’s rear was separated from the gasholders by a brick wall, and there was no visual continuity across the boundary is totally untrue. Photographic evidence from 1911, 1920, and later show that the rear boundary was a high-quality oak fence, scalloped to echo the ellipse-and-post pattern of the listed Front Wall. The posts were about 5 foot high, but the scallops reduced the height by at least a foot. A low gate allowed movement between the areas, which is in approximately the same place as the locked gate in the security fencing of the Barratt site. These decorative features invited views of the gasworks from the Livesey, and vice versa. This has implications for establishing the Hall’s curtilage.
15. Air quality – the development contributes to an increase in PM10 and NO2 at noted sensitive receptors. Although these are below the objective limits, are very minor and not significant, there is a lost opportunity in not seeking to minimise exposure of the new residents (and those residents who already use the area surrounding the site) to poor air quality. Measures such as those set out in the GLA’s Air Quality Positive Guidance should be considered further.
16. Transport & Access
a. No provide kerbed location for the accessibility requirements for black cabs.
b. Lack of short-stay cycle parking to satisfy a decent level of coverage - within 15m of each commercial unit entrance.
c. No demonstration of sufficient sustainable urban drainage systems to mitigation measures against the likelihood off pooling/standing water.
d. The provision of car parking adjacent to F-02 and F-03 residential units should be revised to increase separation between residential units and the parked vehicles.
e. No allocated provision of pick up / drop-off area/bay for residents.
f. Lack of protection to cycle stands adjacent to Workspace 04.
g. No provision of vehicle restraint measures to prevent vehicles reversing too far into Alan Pegg Place Garden.
h. The provision of short-stay cycle parking is not within the visibility of retail units leading to a reduction of natural surveillance which could increase the likelihood of cycle theft.
i. No provision of secure cycle parking for delivery cargo bikes and charging facilities for ecargo bikes.
j. No provision of charging facilities for residential e-bike charging.
k. Provision of loading bay is on the side of the road where there are no workspaces – concern with noise to adjacent residential units at ground floor and operational concern of loading/unloading requires crossing the road to access commercial units.
l. Accessibility concerns with shared surface areas where pedestrians with visual impairments could find difficulties in navigating this space safely.
m. Concerns with no provision of inset loading bay on Alan Pegg Way servicing the Retail units, Workspace 01 and residential Lobby A – this would help to reduce the need for commercial vehicles needing to access via heavily used access road to the east of the site.
n. No on-site car club provided – closest car club is located 650m walk from site.
o. Concerns with the lack of onsite parking provision will adversely affect the surrounding areas. There should at least be the provision of car parking on site for residents of up to 0.25 spaces per dwelling to match that of the London Plan 2021 Inner London PTAL 3, which is immediately adjacent to the site. This is a reasonable balance considering the ambitions of a new rail station at Bell Green. This would increase the parking provision by up to 57 spaces on site.
Probably more suitable for Bell Green, too? I thought the ground had been designated too polluted to build homes on?