Chris Best

Bell Green Barratt's development

Planning permission granted

DC/23/133854 - LAND AT THE FORMER BELL GREEN GAS WORKS, BELL GREEN, LONDON, SE26

Development comprising the phased construction of three building plots (comprising 6no blocks) ranging in height between 6 and 14 storeys, accommodating 780.8sqm (GIA) of flexible retail and workspace floorspace (Use Class E) at ground floor level, together with 262 residential units (Use Class C3), with associated public realm, landscaping, amenity space, cycle parking, car parking, plant and associated works at Land at the Former Bell Green Gas Works, London, SE26. This application is accompanied by an Environmental Statement and further information (submitted 21/12/2023) is available to view in relation to the Environmental Statement which had already been provided.

Dear Mr Gibson

We are writing to comment on the above planning application and to support the objections from the Sydenham Society and the Bell Green Neighbourhood Forum as well as other local residents.

We note this replaces the previous application - DC/23/129814 –

Development comprising the phased construction of three buildings ranging in height between 5 and 15 storeys accommodating 867sqm (GIA) of flexible retail and workspace floorspace (Use Class E) at ground floor level together with 261 residential units (Use Class C3), with associated public realm, landscaping, amenity space, cycle parking, car parking, plant and associated works at Land at the Former Bell Green Gas Works, London, SE26. This application is accompanied by an Environmental Statement.

We submitted an objection and the comments on that application are similar in substance. This is because there have been few changes of any substance, and even critical points made by the GLA and TfL have not been addressed. Despite this being a new application, there has been no public consultation, no local meeting, and the only notification we have received is a leaflet that was sent by Barratts London to local Councillors on the 25th October 2023 -

Please find attached a leaflet that will be distributed to over 4000 residents and businesses tomorrow advising them of Barratt London’s revised proposals for Bell Green Works, Sydenham. The distribution area for the leaflet is also attached. This follows the withdrawal of our earlier application in the Summer. I hope the leaflet is self –explanatory but should you wish to discuss further, please do not hesitate to contact me.

We, and those residents who have contacted us, believe there has been no genuine consultation on the revised application, and we urge the developers to withdraw this application and work with the community to address the issues that have been raised. We are keen to see this much-needed housing delivered with a scheme that has the support of the local community.

Context and Design

The proposal is for the site of the former gas holders at Bell Green and we think should be considered in the context of the existing residential neighbourhood, the listed Livesey Memorial Hall, the existing retail park and give consideration to any future redevelopment in the vicinity including Sydenham Green Health Centre.

The Sydenham Society have made the point that this is in accordance with the guideline in the Mayor of London’s ‘The London Plan’ (March 2021) that development should ‘…enhance local context by delivering buildings and spaces that positively respond to local distinctiveness through their layout, orientation, scale, appearance and shape, with due regard to existing and emerging street hierarchy, building types, forms and proportions…’ (Policy D3.1).

In 2019 the Sydenham Society prepared a masterplan for the site with Discourse Architecture. Lewisham Planning Department subsequently commissioned a masterplan from We Made That for consultation, which, although invoked as the ‘emerging plan’ in the application ‘Design and Access Statement’ (pp2 & 48-50) has not been formally adopted for planning guidance.

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 14-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. The developer invited members of the public to comment on the indicative layout showing tower blocks to a height of 12 storeys.

As local councillors we believe that there should be an emphasis on creating a high-quality sustainable neighbourhood with the best possible homes, local schools and health facilities. We have spent some years campaigning to ensure Our Lady and St Philip Neri School is built in accordance with the planning permission granted. We will be expecting the redevelopment of the Sydenham Green Group Practice in Holmshaw Close to provide a quality health facility with the height of the homes above to reflect the locality of two storey housing.

Character and street scape

We have been contacted by local residents who have said that 262 homes are just too many for the site of the old gas holders and believe this scheme is being overdeveloped. They say that it is not in keeping with the area and we agree that it is incongruous. On a positive note, residents welcome the green space and pathway to river and support SINC.

Height of the tower blocks

We have real concerns with the massing and overall form including the definition of space between the buildings and in relation to the Livesey Memorial Hall. We are opposed to the

14-storey tower because it fails to contribute to the bigger picture on the site. As noted in ‘The London Plan’: ‘…high density does not need to imply high rise…’ (Policy D9, 3.9.1)

There is no precedent for a 14-storey tower in the immediate locality or indeed in the Lewisham West and Penge Constituency, as pointed out by Ellie Reeves, our local MP.

Opposite the site, at 86-92 Bell Green, an 8-storey building reducing to 6 storeys and is currently under construction. The neighbouring buildings at Orchard Court have a maximum height of 8 storeys, designed to complement the gas holders with a spiral wrap around reducing to 3 storeys. The tallest blocks locally are the 7 blocks of flats set within the spacious grounds of Home Park and reach a maximum height of 8 storeys. We are concerned with the overlooking of the oval designed Pear Tree Court – the flats above Sports Direct are single storey on the corner of Alan Pegg Place and Ron Stockbridge Close. They have a communal garden on the flat roof with raised planter beds to encourage the residents to work together and develop the use of the open space.

We are concerned that, to reduce the height of the tallest block from 15 storeys to 14, two other blocks have been increased – the block next to the Livesey is now 6 storeys with the block on the corner of the site is now 9 storeys. As stated above the block that is currently being built diagonally opposite (86 – 92) is 8 storeys reducing to 6. We are concerned that the Livesey will be overshadowed, and our view remains that the scheme is being over-developed with the increase of one additional home to 262 homes. The revised heights of the blocks do not address the scale nor create a more cohesive arrangement.

Livesey Memorial Hall

As local councillors we have campaigned to ensure the Livesey Memorial Hall is listed as an asset of community value. The Council has issued a statement showing our support to “ensure it is protected and maintained, including taking enforcement action if necessary” - https://lewisham.gov.uk/articles/blogs/statement-on-the-livesey-memorial-hall

We are now very concerned that this asset of community value will be overshadowed by a 6-storey block.

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 the developer’s site that adjoins the Hall’s curtilage at their western boundary.

The heritage report is inaccurate in that there has been visual continuity across the site. Photographic evidence from 1911 onwards shows 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 gate in the security fencing of the gasholders site. These decorative features invited views of the gasworks from the Livesey, and vice versa. This has legal implications in establishing the Hall’s protected curtilage.

The footprint of the developer’s 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. This will create conflict between the Hall's 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. 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.” https://www.shoosmiths.co.uk/insights/articles/nppf-the-agent-of-change-principle-14454

Mix and layout of the flats

The development has a disproportionate number of one-bedroom units. 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.

We are concerned with the single aspect homes as more than one quarter of the units (26%) are single aspect with windows on one elevation. This is contrary to policy and only allowable in ‘exceptional circumstances’. The developer’s statement that these dwellings are not north-facing is unacceptable. The developer should be required to re-work the blocks’ designs in order to remove such minimally lit dwellings from the scheme.

All flats have a combined kitchen/dining/living space, generally single aspect and up to 6.5m (more than 21 feet) deep in plan. It is inadequate to ask 3 or 4 people to share a single common space for cooking, eating and living. The single aspect nature of these spaces will lead to dark living conditions and unnecessary use of electricity to light the space. In recent years LB Lewisham has refused planning consent for single aspect flats; for this reason (among the others listed below) we are of the view that the scheme should be refused planning permission.

Lewisham has previously recognised that open plan spaces for food preparation and cooking need to be designed to provide safety and security for the vulnerable including children and older people who may have dementia or risk of falling. There is also consideration of cooking smells that linger in living areas and potential condensation issues that can cause mildew and mould growth.

Post Covid society involves increased working from home. These flat layouts fail to acknowledge this new reality and will consign residents to working in cramped conditions in which it is impossible to separate work from domestic life, causing hardship and mental stress to residents.

We note the addition of balconies attached to the face of the buildings and this appears to be an “add on”. We would prefer balconies that are designed within the ‘footprint’ of the flats, thus providing privacy and a sense of integrated external space.

There is also concern with the proximity to the Livesey as the developers intend to address the Livesey’s potential for noise nuisance issues by making windows facing the Livesey 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 report from Lewisham Disabled People’s Commission includes the housing recommendation to commit to ensuring that 30% of housing built meets the M4(3)(2)a) criteria (‘wheelchair adaptable’), rather than the government minimum of M4(2) and that the maximum for each site meets the M4(3)(2)a) criteria. We support this recommendation to provide a maximum of wheelchair adaptable homes recognising there is an undersupply of accessible and adapted housing for disabled people.

Provision of Parking Spaces

The developer is applying for a car-free development, despite a Public Transport Access Level of 2 – out of a possible 6. The 2021 London Plan says that PTAL 5-6 developments must be car-free, and outer London developments with PTAL 4 may have a maximum 0.5 to 0.75 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.

Local residents have highlighted that in the Car Management Plan document 'Appendix A Public realm and landscape masterplan (Additional Parking)' page 8 has the following points:

4.1.6 The TfL standards also specify that a residual capacity of blue badge spaces equivalent to 7% of the number of units should also be deliverable on site, subject to demand following occupation of the site, equivalent to a further 18 spaces. Appendix A shows the potential locations of additional blue badge parking. It should be noted that this would have an impact on the public realm, should they be provided, and discussions would take place about the optimal level and location of provision, should the additional spaces be deemed necessary. They are concerned that the reserved blue badge parking would obliterate the public realm, with parking instead of 'Alan Pegg Place' garden, and obstructing the green cycle/ pedestrian route. There appears to be no explanation as to how the vehicle movements would be achieved. This adds to our concerns of overdevelopment.

The lack of provision of parking spaces, other than eight Blue Badge spaces, seems unrealistic and is perhaps based on the short-sighted assumption that residents will park in the existing retail park parking areas. Car-use, albeit hired electric vehicles, looks set to continue, and some provision should be made for convenient on-site parking as well as supporting parking spaces for car clubs and a loading bay for the commercial premises.

In providing car free schemes we strongly believe there is need to consider the most appropriate location of drop off and pick up points for taxis and dial-a-ride provision. These spaces need to be well lit and secure.

Colour of brickwork

We note the brickwork is red to chime in with the Livesey but we would prefer a softer brick colour with more honey as in London stocks. This would complement the façade of the Livesey and there are many examples of lighter brickwork in the locality. We ask that the brickwork is a condition of the planning permission.

Management Strategy for the green space

Residents have asked for a Management Strategy of the green space as the area can attract significant amounts of litter from the retail park.

Financial viability and affordable housing

Lewisham’s strategic target is 50% of all new homes and Lewisham’s minimum requirement for fast-track route is 35% affordable housing. We understand that the developer has an aspiration that 35% of the housing will be affordable.

We note that the developer has increased the 4% from the previous application to 26% affordable homes. This will be provided as 70% (37no) London Affordable Rent and 30% (22no) Shared Ownership. We remain concerned that this does not reach the 35% affordable target and is still reliant on grant monies becoming available. Our concern remains on the availability of grant and the contingencies if the grant is reduced.

We also question the location the affordable housing and request that this is pepper potted throughout the scheme. We would also like to see housing provision for people with learning disabilities and comment on the success of the Mayow Road scheme that was able to attract investment from the NHS.

As local councillors we know how vital it is to provide affordable housing in Lewisham and believe that the development should not be granted planning permission unless and until the 35% target is guaranteed.

Commercial use

We are aware of issues in letting commercial spaces for example the retail spaces left vacant opposite Forest Hill Station for years and the commercial spaces on the corner of Knighton Park Road were converted into housing as the developer said there were no takers for the two commercial spaces. Is there a plan in place to guarantee the letting of the commercial spaces at the time of development rather than leaving the marketing to the end of the building works.

Apex site

We note that L4 is shown as Indicative Apex Housing facing the access road to the retail park. We are asking if there has been any joint working on the main Apex site as the Apex web site doesn’t show this space as in their ownership – https://www.apexcapitalpartners.co.uk/4th-project

We are very concerned with height and if the developer is granted planning permission for nine storeys on the corner of their site will this create a precedent for Apex on the adjacent site on the corner and similarly on site L4.

Conclusion

We therefore ask that the planning application is refused on the following basis:

• that the massing is too focussed on individual buildings and misses the opportunity to initiate a new street-based urban quarter as proposed in the Sydenham Society’s masterplan.

• that the 14-storey tower is not integrated into a coherent urban vision.

• the architectural detailing is pared back to achieve economy for the developer rather than a rich material quality for residents, building users & local people.

• that there is insufficient emphasis on the creation of well-proportioned spaces between buildings and ensuring sufficient protection for the Livesey Memorial Hall.

• the landscape strategy is fragmented and does not relate sufficiently strongly to the layout of the proposed buildings.

• the proposal fails to provide good places for people to live and work.

• that the design of the flats includes a large number of single aspect homes.

• that none of the flats have separate kitchens or kitchen/dining spaces, they all have combined kitchen/dining/living spaces. There is no provision for working from home.

• that the provision of only 8 Blue Badge spaces is insufficient for the proposed 262 homes and will cause displacement on to neighbouring streets; there should be the offer of a Car Club.

Bell Green gas holder site planning application