Facts about Lewisham Gateway



 

Lewisham Gateway’s Planning Application: unpicking the PLANNING STATEMENT

Download a Word document of this statement here.


ABOUT THE APPLICATION AND THE PARTIES INVOLVED

The Lewisham Gateway planning application has two elements:

• for outline planning approval for building development;

• for detailed planning permission for a new road layout and changes to the rivers.

The planning application has been submitted by RPS Planning on behalf of Lewisham Gateway Developments Ltd and the London Development Agency.

Lewisham Gateway Developments Ltd is a partnership of two building firms — Amec and Taylor Woodrow.

The London Development Agency is a "business-led board appointed by the Mayor of London and "responsible for driving London's sustainable economic growth". It has £300m of funds for investment each year. http://www.lda.gov.uk

 

ABOUT THE LOW H ROAD LAYOUT

Crucial to understanding the whole development is the Low H road layout.

Here is a simplified diagram:

The long sides of the H are formed by Molesworth Street to the west and Lewisham High Street/Lewisham Road to the East. The bar of the H is formed by an expanded (4-5 Lane) Rennell Street.

Below is the developers' description:

The Lewisham Gateway scheme proposes to replace this roundabout with a highway layout known as the 'Low H'. This involves the realignment of Molesworth Street and Lewisham High Street to the western and eastern edges of the Lewisham Gateway site. They will be linked together by a new two-way road which is proposed along the approximate line of the existing Rennell Street. To facilitate introduction of the Low H layout the existing bus layover and related facilities will be re-provided in Thurston Road. The introduction of the Low H highway layout provides a new development site in a strategically important location in the town centre. It presents an opportunity to accommodate a significant quantum of floorspace together with improvements to public transport interchange and the public realm.

The Low H highway layout was selected as the preferred option through a public consultation exercise and was agreed by the SRB Board as the development option that would meet SRB objectives. The layout has subsequently been advanced through the Lewisham Gateway SPG. (Planning Statement, 5.1)

It is crucial to understand the Low H because without it, there would be no parcel of land created for development.

 

ABOUT THE PLANNING STATEMENT and the RATIONALE FOR DEVELOPMENT

Among the documents submitted is the Planning Statement. This is a very important document summarizing the information elsewhere. In this part of the website we take their section 2.2 which provides a "Rationale for Development", and we provide some comments on the fairness of their representation of their scheme.

Each of their key 'rationales' are printed in bold and are followed by our comments. The numbers given here are ours to make reference easier, but the order of the statements is the same as that provided in the Planning Statement at section 2.2.

B: SECTION 2.2 OF THE PLANNING STATEMENT

1. "Lewisham Town Centre is the focus of several economic, social and environmental initiatives. These initiatives have arisen partly in response to the Mayor's London Plan and also from the formation of the Urban Renaissance in Lewisham Partnership (URL) — an organisation comprising key local stakeholders and statutory bodies who are engaged in shaping the form of new development in Lewisham. The Partnership successfully bid for Single Regeneration Budget (SRB) funding to help advance long-term regeneration initiatives for Lewisham Town Centre and the local community. The URL SRB process included preparation of the Lewisham Gateway Planning Brief, which sets out a development framework for an area that includes the application sites. The Planning Brief was approved as Supplementary Planning Guidance (SPG) by the London Borough of Lewisham on 10 December 2002."

The primary rationale for this development is the Lewisham Gateway Planning Brief. That part of the brief concerned with this application was based upon the Low H road layout. According to the Planning Statement the crucial element in the adoption of the Low H road layout was the result of a public consultation exercise in 2002:

'The Low H highway layout was selected as the preferred option through a public consultation exercise and was agreed by the SRB Board as the development option that would meet SRB objectives. The layout has subsequently been advanced through the Lewisham Gateway SPG" (5.1)

There are two objections to making the Low H road layout the basis of the Planning Brief:

a) there was and is no proof that this road layout will work

The decision to adopt the Low H was made in 2002, but there are now serious concerns about the Low H scheme, so far expressed mainly by Transport for London (TfL). At a meeting in October 2005 of stakeholder consultees the Amec representative stated: "TfL has stated that they will not sign the (development) agreement until all transport issues are resolved." The meeting indicated that TfL had doubts as to whether the new road scheme could accommodate existing traffic. (Transport Assessment Appendix A Section 1, minutes 12th October 2005). TfL later stated in their letter to Lewisham Planning Services of June 2006 that:

"From the information currently available, TfL has a general concern that the proposed low-H scheme layout and surrounding junctions will not operate within capacity and would result in increased delays for genera l traffic including buses on certain parts of the network."

b) there was no clear-cut public endorsement of the Low H

The extent of public involvement was low: approximately 450 people attended the various 'invitation only' focus groups and approximately 1400 the public meetings and exhibitions.

The outcome of the public consultation exercise of 2002 was ambiguous with many reservations expressed about upheaval and the Low H scheme. (Statement of Community Involvement Appendix D, see in particular Summary table p, 65) We would argue that the view that the public supported the Low H comprehensive change option for Lewisham centre is just that — one view of the totality of opinions expressed. In fact the single most important concern was environmental "Open up rivers, with walk / cycle paths beside them, make the most of greenery; more open space". We show later that these specific concerns are definitively NOT addressed in this application.

But even had there been definitive public agreement with the Low H system, it would have been based on an assumption that the Low H system would work as a traffic system. If there is insufficient information available in June 2006, when the developers are seeking detailed planning permission, for TfL to support the new scheme, it cannot have been available in 2002 when the initial public consultation was undertaken. In which case the public were not being offered a real, workable alternative to the current system.

2. "The Brief was prepared in recognition of Lewisham Gateway as a significant regeneration opportunity for Lewisham. The site offers the potential to fully integrate Lewisham Town Centre with its public transport interchange and to promote good quality modern urban development in place of the existing traffic dominated roundabout."

The site is only appropriate for urban development if, as a result if the Low H layout, a parcel of land is created on which to build the development. The second sentence is meaningless: the site IS the link between the station and the town centre. It was Lewisham Planning which originally created a gulf between the town centre and the station through the current "traffic dominated roundabout".

We are concerned that there is no real business case for the scale and nature of the development and the regenerative effects are not demonstrated (see 5 below). What assurances have we that the offices and retail units will be let for instance? The rationale for the development appears to be only that this is a suitable site.

3. "LB Lewisham has recognised the pressures and opportunities placed on the public transport interchange and its environs by the increasing number of train, DLR and bus users passing through the area. Any proposed redevelopment must address these pressures and opportunities by creating improved pedestrian, bicycle and vehicular circulation through the area and improving the connectivity for pedestrians between the interchange and the town centre."

The proposal recognizes that development will outstrip provision of rail, DLR and bus provision. This is contrary to the London Plan, which states (Policy 3C.2 Matching development to transport capacity):

"The Mayor will and boroughs should consider proposals for development in terms of existing transport capacity, both at a corridor and local level. Where existing transport capacity is not sufficient to allow for travel generated by proposed developments, and no firm plans exist for a sufficient increase in capacity to cater for this, boroughs should ensure that development proposals are appropriately phased until it is known these requirements can be met."

Vehicular circulation even for existing traffic levels is not proven. Should Lewisham press ahead with other initiatives for Loampit Vale and Thurston Road which include a new swimming pool, a B&Q and still more flats in high rise blocks, then it is very difficult to see how the new road layout will work.

There are clear and specific problems created by the Low H scheme and the scale of the proposed development:

• the bus station is moved to Thurston Road, and 10 buses are re-routed so that they make two right hand turn across streams of traffic to get to Thurston Road and cross traffic again to get into the bus station. A projected 73 buses an hour must make these turns. (Transport Assessment section 4)

• On the Lewisham Road side of the development, buses turning into Station Road, delivery vehicles (a projected 165 deliveries a day) and cars going to and from the underground car park must compete for road space and turning space;

• The taxi stand is to be relocated to Lewis Grove, but buses must still turn right into Lewis Grove to get to Catford.

• Northbound traffic from Molesworth Street wishing to use the service area and car park in the Riverdale Centre must make 180 degree turns if they wish to avoid going round the whole system.

Cyclists do not seem to gain anything and may be worse off, even though Lewisham's Unitary Development Plan states: "the needs of pedestrians and cyclists must be built into the earliest stages of new development" (Chapter 6, STR TRN 3)

For instance, cyclists must dismount to go through the complex and if they are not prepared to do that they must go all the way round a daunting traffic system. They are not provided dedicated cycle paths to do this. The plans indicate a cycle route, but that is not a cycle path. They are likely to be particularly vulnerable as buses pull out of the Molesworth Street stand. The design of the Rennell Street crossing also raises the possibility of conflict between cyclists and pedestrians, which could be accentuated by cyclists wheeling their bikes through crowded urban space in the middle of the development.

All these elements are at odds with guidance provided by the Mayor of London's London Plan. Policy 3C.21 suggests:

"Improving conditions for cycling UDP policies should: identify and implement high quality, direct cycling routes, where possible segregated from motorised traffic"

For pedestrians in certain places the density is very high. The Transport Assessment, the major document submitted in support of the application is worth quoting in detail here:

2.3.5 In areas where the level of service indicates greatest likelihood of crowding occurring, three pinch points were identified for further analysis. The GEHL Architects' "Towards a fine City for People" commissioned by TfL proposes a measure of how acceptable a footway is in terms of crowding. It uses a benchmark of 13 people per minute, per metre of footway width, as the upper limit for reasonably acceptable walking space. Beyond this level crowding occurs.

2.3.6 At the northern footway under the railway bridge on Loampit Vale, the GEHL model suggests an upper limit of 39 people per minute before crowding occurs. The forecast pedestrian model estimates a peak 15 minute pedestrian flow of 38 people per minute. This suggests that this area will, at the busiest period of the day, be at the upper limit of acceptable walking space, but not over crowded.

2.3.7 At the northern end of the Molesworth Street bus interchange, the GEHL model suggests an upper limit of 47 people per minute before crowding occurs. However, the forecast model estimates a peak 15 minute pedestrian flow of 96 people per minute. The GEHL model suggests this area will be at twice the comfortable capacity during the busiest period of the day. The detail design of the building at this corner will alleviate this pinch point.

2.3.8 At the north-western corner of Lewisham High Street, the GEHL model suggests an upper limit of 43 people per minute before crowding occurs. The forecast pedestrian model estimates a peak 15 minute pedestrian flow of 51 people per minute. The GEHL model suggests conditions at this pinch point could be 20% more crowded than the comfortable capacity during the busiest period of the day.

Within the development itself it must be a matter of opinion as to how pleasant the environment will be: pedestrians are routed through relatively narrow paths, given the height and scale of the buildings. There is potential conflict within the development between cyclists and pedestrians, especially as cyclists must dismount to gain a more direct route around the complex. (See also section 4 below on the nature of the "open space" provided within the scheme.)

In summary the transport effects of the scheme are still to be proved. Yet throughout the documents the improved traffic system is used as mitigation for other negative impacts.

3. The Creative Lewisham initiative, established through the Council's Culture and Urban Development Commission seeks to transform Lewisham into a stimulating and recognisable environment ö a centre for creativity, cultural development, the arts and design.

There are no guaranteed additional cultural facilities provided. A cinema is mentioned, but this is dependent on market favourability (Planning Statement 4.3). The buildings look standard town centre stuff, very high and dense. It is not obvious how this will contribute to creativity — except perhaps by disaffected graffitti artists.

4. Both the River Ravensbourne and River Quaggy pass through the site but are presently culverted and canalised. Comprehensive redevelopment of the site presents an opportunity to restore the historic role of these rivers as a focal point for the local community, improving both the natural environment and amenity for residents and commuters

The rivers will remain culverted with a small area exposed in the middle of the urban development. The opportunity to regenerate the Quaggy near St Stephen's Church is being specifically opposed by the developers. The river Ravensbourne is being tampered with as described by the developers:

"Most of the construction work will be within the river Ravensbourne: removing existing structures, realigning the river channel, inserting a new culvert and regrading the river bed. During the construction phase the channel width will be reduced, this will have to be managed to ensure that there is no increase to flood risk" (Environment Statement Non-Technical Summary section 10)

It is not clear why such a huge project is necessary, except, perhaps, to facilitate the high rise development.

Existing archaeological evidence of the role of the rivers will be destroyed as a result of the deep digging required to accommodate high rise blocks. In particular "A major environmental effect may occur in the area of Lewisham Bridge due to the potential for survival of remains relating to a medieval stone bridge". (Environment Statement Non-Technical Summary section 10). The history of Lewisham as a 19th basin site will be lost.

We would suggest that a major opportunity to revitalize the rivers in Lewisham is being lost and will be removed forever. Two pleasant pedestrian walkways to the town centre could be created by opening out both rivers and even exposing the archaeological sites in a new town centre open space.

It is not just the loss of original elements of Lewisham's historical background at the confluence of two rivers that will be lost — other elements of Lewisham's history will be destroyed forever: especially the remains of a palaeological burial ground; and the memorial to the bombing of Lewisham during the 2nd world war provided in Charlottenburg Gardens.

There is a net loss of green open space acknowledged in the Planning Statement (10). Their figures show that green space currently totalling nearly 4,000 square metres will be reduced to 1,160 square metres.

Two areas to be lost are Charlottenburg Gardens which is Metropolitan Open Land and Quaggy Gardens which is Public Open Space. Both disappear under roads which need to be moved to the outer edges of the site in order to accommodate the scale of the buildings proposed. Currently the area around the bus station and roundabout has trees, grass and flower beds, which are enjoyed by many people going into the town centre or en route to other places. In addition the pub near the bus station has a large garden to the rear.

The UDP states:

"The value of open space in a built-up residential Borough cannot be overstated." " to enjoy the natural environment or simply to be reassured by its presence, open space is critical to modern Urban living".

Metropolitan Open Land is given specific protection in the Mayor's London Plan states:

"3.249 MOL will be protected as a permanent feature, and afforded the same level of protection as the Green Belt. Appropriate development should minimise any adverse impact on the open character of MOL through sensitive design and siting and be limited to small scale structures to support outdoor open space uses. The boundary of MOL should only be altered in exceptional circumstances and should be undertaken through the UDP process in consultation with the Mayor."

The same guidance specifically states that: "Development that involves the loss of MOL in return for the creation of new open space elsewhere will not be considered appropriate."

And yet the scheme tries to do exactly that:

The loss of the open space areas will be mitigated through the introduction of a better integrated and accessible open space area at the proposed 'Confluence Place'. The design will allow for a much more natural integration of part of the River Ravensbourne and River Quaggy with a removal of part of the canalised edge. These areas are likely to be safer, quieter and better used than the two existing areas. (Environment Assessment Table 13.8)

The two new open spaces are mainly paved, overshadowed by high rise buildings of glass and concrete. One of them is predicted to be "excessively windy" due to the surrounding tall buildings. Much of the other "public realm" is paved pedestrian areas, in between tall buildings.

"The proposed development is taller than its surroundings and is exposed to the prevailing winds. Without any mitigation, conditions are expected to exceed the criteria of 'distress' for 'general public access' at a variety of locations. Mitigation measures such as planting, canopies and porous screens have been developed to improve conditions' (ES NonTechnical Summary section 4)

According to the Planning Statement there is no way of keeping Charlottenburg Gardens because: "If Charlottenburg Gardens were required to remain, the new road layout could not be achieved and the development as a whole could not proceed".

Because of the density of development, there will be significant overshadowing within the complex and for surrounding areas, bringing loss of sunlight: "The development will have a significant impact on the vertical sky component. The effect is more pronounced on the terrace of houses (in residential and commercial use) adjoining the River Quaggy" (ES Non-Technical Summary section 4). These houses also form an important element of the streetscape view on arriving in Lewisham at the station.

The density of the development will have a negative impact on local conservation areas, especially St Stepehen's. It will also have an adverse impact on views from areas in Lewisham and Greenwich. This is not considered significant by the developers, but Lewisham's position in a valley affords extensive and green views which are well-loved by residents.

The Environment Statement makes clear that air quality will deteriorate:

"Existing air quality around the site is poor and both the annual mean national air quality objective (NAQC) and the EU Limit value for nitrogen dioxide are predicted to be exceeded without the development. The proposed development is predicted to increase concentrations of receptors around the site by up to 3%. The receptors include sensitive residential locations (1-6 Hornbuckle House) and (1-58 Century House (part of) that are within 100m of both the Lewisham Gateway and Thurston Road development."

Table 5 states: "The residential operational impacts are considered to be a major adverse impact" and no mitigation is described.

The noise impact is also high, falling into Noise Exposure Category D of the PPG24. The advice for developments where the level of noise falls into this category is that permission should normally be refused.

Hence, open space is removed and put inside a development where the air quality is predicted to be worse than it is at present. And all this in return for limited and unguaranteed additional amenities ...see below.

5. The Lewisham Gateway development presents a significant opportunity to redefine Lewisham town centre as a hub for the local community and a desirable location to live, work, shop and relax. Given the site's prominent location, the development of the Lewisham Gateway site is likely to have a catalytic effect in regenerating the surrounding area.

Two key regenerative effects are described in the Planning Statement.

a. employment creation.

The Environment Statement divides the employment impact into two areas: a wider impact zone "derived from the boroughs that surround the site" (that is Lewisham, Greenwich, Southwark and Bromley); and an inner impact zone "mainly derived from wards within approximately one mile of the proposed site" in Lewisham and Greenwich. The Planning Statement (at 4.3) states that the completed development will provide 878 jobs for the inner zone and 215 for the wider area: but this is the reverse of the promised employment gains given in the Environment Statement which gives the figures of 215 for the inner zone and 878 for the outer. The figures cited above from the Environment Statement are based on the maximum scheme: for the minimum scheme the figures in the Environment Statement are 109 and 444 respectively (section 6.11.20). At the outside, therefore, local people, who will be taking the strain of the upheaval, lose open space, suffer worse air quality etc, will make a gain of only 215 jobs.

However, even these figures are open to dispute. Included in the figures for jobs provided are some created by the provision of facilities which are elsewhere described as dependent on favourable market conditions, such as the cinema and a hotel. There is the possibility that Lewisham College will move to the Gateway site and this is asserted to provide an extra 57 full-time equivalent jobs (Environment Statement 6.11.5). However, these will surely not represent any net gain to the area: they already exist and would simply be moved from Loampit Vale to the new development.

But even were an extra 215 jobs in the local area to be gained these will surely be insufficient to have a "catalytic effect in regenerating the surrounding area". They are mainly in the retail sector — that is low paid, low skilled and often temporary. Moreover, the retail development could have an adverse effect on the existing and vibrant market and other independent traders

The 'regenerative benefits' are actually unproven. Yet reference to them is used frequently in the planning documents as mitigation for the loss of other amenities or deterioration in the quality of the environment. This is a pattern which was recently repeated in the Mayor London's response of 17th October 2006.

b) Housing provision

Planning Statement (4.0.3) states:"up to approximately 800 residential units, an element of which might be affordable housing". The figure of 20% affordable housing is mentioned, well below Lewisham's guidance of 35% or the Mayor of London's aspiration for 50%.

But this is not at all guaranteed for in justification of this poor level of provision that Planning Statement (section 7.2.d) states:

"With specific regard to the Lewisham Gateway site, there are significant inherent costs relating to the realignment of the existing highways and other infrastructure work on the site:

The total upfront cost of the infrastructure and enabling works is likely to be in the region of £25 million

This has a significant impact on the overall viability of the scheme and, in particular, the level of affordable housing that can be provided. £4.3 million of Social Housing Grant is required to enable the scheme to break even.

A further indicator marginal viability is the injection of £9 million SRB funding from the LDA

Should higher affordable provision be required, the scheme would not be financially viable, jeopardizing the entire development. A likely outcome would be that no development occurs on the site. Without these finely calculated provisions the scheme would not be viable."

The marginal viability of the plan referred to here must surely give pause for thought: how good will quality be — whether of building design and materials, of landscaping, of noise and air quality mitigation — when the developers' finances are so tight?

 

CONCLUSION

This is a response to the rationale for the Lewisham Gateway development. Many more points are to be made about specific elements of the proposal. We would like to see a business case for the development, rather than a statement that the site is suitable for development. And we would ask the Council to consider in more detail the key request of the residents of Lewisham in 2002: "Open up rivers, with walk / cycle paths beside them, make the most of greenery; more open space".

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The Statement of Community Involvement EXPOSED

As part of the information gathering process, Lewisham Gateway Developments (LGD) and Urban Renaissance Lewisham (URL) have been obliged to consult with the local community. They have done this via a number of vehicles – exhibitions, workshops, focus groups, surveys etc etc. In the ‘Statement of Community Involvement’ they say:

This activity has sought to be inclusive for all people, irrespective of age, sex, ability, ethnicity or background, business, the voluntary sector and others. To achieve this, local community meetings have been held with specific groups, including a young persons’ forum, a pensioners’ forum, a business forum, a disabled group, Voluntary Action in Lewisham, and local residents’ associations, as well as open public meetings and presentations. This activity has sought to be as inclusive as possible and has not sought to exclude any person or group from comment on the proposals.

They presented at consultations, with annotated graphic display panels and models, three options for consideration. Option 1: No Change, Option 2: Moderate Change and Option 3: Complete Change.

The consultations with residents are detailed and attempt to be exhaustive, but a dominant feature is that if you are a member of a recognisable group you would have far more chance of either being invited to a meeting and giving an opinion and filling in a questionnaire at the same time. If you were outside of these defined recognisable groups then the opportunity to engage would be possible but you would have to be more pro-active.

In the ‘Statement of Community Involvement’, LGD come to conclusions very quickly:

The Options for Lewisham Gateway stage considered whether development was appropriate for the site and if it was what kind of development should take place. This resulted in the local community overwhelmingly choosing “complete change” for the site and the selection of the “Low-H” layout to replace the existing roundabout.

They go on:

Over three years, several thousand people have had the opportunity to discuss their aspirations for the site and to influence its development. The advantage of this continuous approach to consultation has been to ensure that local support for the scheme has been maintained throughout the process.

The population of Lewisham is approximately 250,000 (census 2001), so several thousand is a relatively small percentage of the population.

Pressing the ‘several thousand people’ a little further leads to another claim:

At the LGD pre-application public exhibition, where a model, information boards and members of the project team were available over 2 weeks in March 2005 to explain the final proposals, 82% of people who responded through written feedback said that they either Strongly Agree and Agree with the statement: “I am generally in favour of the proposals”. This significant majority in favour of the final scheme reflects the input the local community has had in developing the final masterplan.

This exhibition was one of 3 open to the public.

Public activites were widely publicised, for example, for the Open Day in September 2004, 12,000 newsletters were distributed to local residents and information released to the press as well as  a dedicated website and ‘full utilisation of council channels’. 750 people attended this exhibition and 89 feedback responses were received.

As well as the exhibition held in September 2004, another was spread over two weeks in March 2005 and a further in September 2005. The quote above is based on questionnaires filled in at the exhibition held in March 2005. 650 people attended the two week long exhibition and of these 154 filled in the questionnaire. This means that the percentage of Lewisham people who said “I am generally in favour of the proposals” is in fact 0.0616 of the population of Lewisham. They made more mileage from the 154 respondents in a conclusion which also managed to bring in people who opposed the scheme:

Given the size and complexity of the scheme, and the number of people the changes to Lewisham Town Centre will affect, it could have been anticipated that there would be a significant group opposed to the proposals.

However, a level of support of around 80% was registered,with less than 8%of local people disagreeing with LGD’s plans for Lewisham Gateway. This is an extremely positive reaction that suggests that the vast majority of Lewisham residents are keen to see the development go ahead.

A further exhibition held in September 2005 drew forth 25 questionnaires. Given the embarrasment of such an abject failure to accumulate more facts in support of the ‘low-h scheme’ (option 3) the developers sidestepped elegantly:

Given the number of responses, it is difficult to extrapolate any firm conclusion beyond the high level of support for the proposals and the low level of disagreement.

But this didn’t stop them from turning the failure into triumph:

Broadly, however, the results are in line with other consultation activities, reflecting the local support for the scheme.

And again:

The Options for Lewisham Gateway stage considered whether development was appropriate for the site and if it was what kind of development should take place. This resulted in the local community overwhelmingly choosing “complete change” for the site and the selection of the “Low-H” layout to replace the existing roundabout.

Overwhelmingly, in the context of the public consultation, means, at best, approximately 520 who expressed a written opinion in response to a questionnaire had wished for a “complete change”. This is 0.218 of the population of Lewisham.

We can account for some more of the 520 people by looking at the attendances at ‘focus groups and public meetings’. These ranged from the Youth steering group (Attendance: Appx. 8); ABC Residents (Attendance: 28); Transport interests /operators workshop (attendance: 11); Cyclists Focus Group (attendance 5); etc etc. A total of 229 were reached in this way and their views noted, but not in a formal way. Within these noted views there were 55 that were in favour of option 3 whilst 97 favoured option 1. Votes or views were not always taken at all meetings and some have been noted as being ‘inconclusive’.

Other meetings were planned and took part to spread the message and consultation further. These included meetings, often ‘by invitation only’, with the Lewisham Area Forum; the Sundermead Tenants and Residents ’Association; the Lunch, Munch and Listen Pensioners Forum; the Lewisham Business Forum; etc etc. It’s difficult to pin down exact numbers for attendance at these meetings, but in total it appears it was in the 200-250 range. These meeting often followed a similar format of a presentation and question and answer session. There was however no response mechanism in place to record the views expressed the LGD commented:

As meetings have been consultation and informational no response to the proposals was sought, so no formal conclusion can be drawn. However responses received by the development team have been broadly positive and this has been reflected in results during other consultation activity.

The ‘broadly positive’ response took this form at the Focus Group attended by the Lewisham Business Forum:

In particular three elements of concern were highlighted:

• The effect on the High Street of the development and efforts that would be made to ensure that there wasn’t a disparity between the High Street and the new development

• The lack of investment from the Council in the market

• The effect on local businesses caused by disruption during the construction phase

and the ‘Lunch, Munch and Listen Pensioners’ Forum’ also had comments to make:

The group welcomed the changes to the existing roundabout and comments were broadly supportive of the scheme. There was a significant amount of interest in the scheme and the majority of questions reflected previous consultation events. Additional points raised included:

• Public toilet provision
LGD explained that there are existing public toilets very near the development at the shopping centre, but there was an intention to have café’s, bars and restaurants that might include accessible toilets.

• Would the plans be made available for the visually impaired
LGD commented that when the masterplan was finalised a version for the visually impaired would be produced.

• The location and access to bus stops
LGD explained the changes to the interchange.

• The relocation of the travellers site
LGD commented that the London Borough of Lewisham is currently in consultation with the travellers on Thurston Road.

• A space for elderly people
LGD noted the point.

• Would there be public art
LGD commented that as this was an outline planning application, so this information was unavailable, but that the point would be noted.

The developers also invoke a ‘Qualitative response analysis’ which again emphasised the ‘broadly positive’ comments and then listed some concerns:

• Construction disruption

• The quality of the shops and restaurants

• The size of the public spaces

• The design of the buildings

• The relocation of the travellers site

• Access to the station, both pedestrian and car

• Traffic flows and the balance between pedestrian and car access

• The name of Confluence Park

• The river improvements

• Infrastructure

which makes it difficult to identify what exactly the ‘broadly positive’ comments were.

This is a biased and partial meander through one of the LGD’s documents, and reading through the entire document will give a balanced picture. The developers cannot hide the fact that the questionnaires were geared to get the answers that they wanted. If they’d included questions such as ‘do you want a group of seven high buildings, some as big as Citibank in the centre of Lewisham?’ or ‘do you want a new road layout that will not have increased capacity?’ they might have received a different response.

But let’s leave the final word to the publicity material and LGD.

In the March 2005 edition of ‘urban renaisance in Lewisham’, Gavin Moore, Chair of Urban Renaissance in Lewisham Partnership Board, waxed lyrical about an evening out in Lewisham:

Imagine a long summer evening and a short walk to the new park where the rivers Ravensbourne and Quaggy meet. There, at one of the outdoor tables, you can take your time over a nice meal and a glass of wine. You’ll be able to relax after your meal with your friends or family with the sound of the river in the background.

The Gateway Development,with its pavement cafes, new squares and open spaces will play a key role in stimulating what is known as ‘the evening economy’ in Lewisham, attracting visitors and creating jobs.

A note of caution from the ‘Environmental Statement Non-Technical Summary’:

The proposed development is taller than its surroundings and is exposed to the prevailing winds. Without any mitigation, conditions are expected to exceed the criteria of ‘distress’ for ’general public access’ at a variety of locations. Mitigation measures such as planting, canopies and porous screens have been developed to improve conditions.


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The Mayor of Londons response to the planning application

The Mayor of London has responded to the planning application in a letter dated 17 October 2006.
Download the document here.

We welcome the statement that because of the absence of sufficient information of transport issues ćthe proposals cannot be supported in strategic planning termsä. We found many of the points interesting and supportive of our concerns regarding air quality, noise, play area and recreation space, renewable energy technologies, drainage strategy and employment benefits

However, in two regards we are concerned about the logic of GLAās reasoning:

1. Overall GLA recommends ćThat Lewisham Council be advised that the broad principle of redevelopment is fully supported but a number of significant strategic planning issues remain outstandingä.

The transport issue is crucial to the whole scheme. Without the low H no parcel of land can be created and no development is possible. But the ability of the low H scheme to cope with even existing traffic flows is seriously in doubt. For this reason, in the eyes of Transport for London, the proposed road layout cannot be supported at the present time on existing information available. In which case we would argue that the principle of redevelopment cannot be supported while the outstanding transport issues are of such magnitude.

GLA cannot logically support the development in principle while questioning the viability of the system used to create the development in the first place.

2. We are also concerned that the Mayor of Londonās report appears to accept at face value the planning documentsā claims for the regenerative benefits of the scheme. We show, in the Planning Statement unpicked that these are actually very modest, even accepting the figures given by developers. We therefore wonder if the GLA has done its own economic assessment and would suggest that any such assessment take into account the impact of the development on existing traders and independent shops, and on the loyalty of existing residents to the area.

We are concerned that in the absence of an independent economic assessment, claimed regenerative benefits are being used to mitigate some very glaring downsides of the scheme, such as the loss of Metropolitan Open Land.


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The London Plan, The Unitary Development Plan, and Lewisham Gateway

“High buildings are not generally in keeping with the established scale and character of Lewisham.”
Lewisham Council Unitary Development Plan

Exchange at public meeting about the Lewisham Gateway scheme:

Resident to developer: "The size of these buildings is really up to the developers to determine how much they think they can sell."

Developers response: "Yes, that’s correct."



The Lewisham Gateway is a complex scheme, but it’s based on, and has to abide by, two documents. The London Plan and Lewishams Unitary Development Plan. These are both complicated and ambiguous documents, but they both very clearly detail plans for many aspects of both living in the London environment and life in Lewisham.
Here we have picked out some parts of both document. Taken out of context may change the meaning and reference slightly – but this is what the developers attempt in an effort work their way around the problems, as they see it, of ‘filling in spare land’.


The London Plan

5.5 London has historically been developed at a wide range of different densities, with many of London’s most successful residential neighbourhoods being built at relatively high density more than a century ago. Much of this higher density housing stock (often five or six storeys high with communal gardens and shared open spaces) is popular and of high value.


8.5 Large developments, especially mixed use developments, offer the opportunity to incorporate neighbourhood combined cooling, heat and power (tri-generation) or combined heat and power (co-generation) systems operating as island distribution networks and using a significant proportion of renewable energy sources.


Lewisham, incidentally, is not mentioned in the London Plan as either an Area of Intensification or and Opportunity Area but simply an area ‘to explore’.


The Sub-Regional Development Framework should also explore the potential of centres like Bexleyheath, Barking, Dalston, Woolwich, Lewisham and Romford to provide accessible and more sustainable alternative attractions to regional shopping centres outside London and to increase housing and viable employment capacity.


Streets for People This refers to areas where a comprehensive package of measures are aimed at improving the street environment to enhance the sense of community, increase priority for public transport, walking and cycling, and improve social inclusion and safety.


Policy 4B.7 Respect local context and communities
The Mayor will, and boroughs should, work with local communities to recognise and manage local distinctiveness ensuring proposed developments preserve or enhance local social, physical, cultural, historical, environmental and economic characteristics. In doing so, the requirements of Policy 3A.14 should be taken into account.


4.55 The compact city and intensive development does not necessarily imply high-rise buildings. London has achieved some of its highest residential densities in relatively low-rise areas, while isolated, poorly designed tower blocks have not necessarily delivered high density or usable public space.


Don't forget the waterways, remember that the Ravensbourne and the Quaggy are unique, unused local attractions and part of the “Blue Ribbon Network”:


4.76 The Blue Ribbon Network Principles have been developed and refined from the five functions of the Thames and the objectives that were identified in RPG3b/9b. One fundamental change is that the water is not seen as merely a setting for development. Rather, this plan promotes the use of the water-related spaces. Types of sustainable use are many and varied but include water transport, water recreation, waterside open space, natural habitats and flood storage or protection.


4.80 The Blue Ribbon Network serves as a valuable series of habitats for wildlife. Many parts of it are semi-natural systems and in such a heavily urbanised area, they often offer a sense of nature that has been lost across much of London.


Policy 4C.4 Natural landscape
The Mayor will, and boroughs should, recognise the Blue Ribbon Network as contributing to the open space network of London. Where appropriate natural landscapes should be protected and enhanced. As part of Open Space Strategies, boroughs should identify potential opportunities alongside waterways for the creation and enhancement of open spaces.


Policy 4C.5 Impounding of rivers
The Mayor will, and boroughs should, resist proposals for the impounding or partial impounding of any rivers unless they are clearly in the wider interest of London. Proposals that include the removal of such impounding structures should generally be welcomed.


4.120 Water space needs to be set at the heart of consideration of development along the waterside – the water must be the starting point. The emphasis on context does not mean that a uniform blandness for the areas around water spaces is sought or that new forms of development are not appropriate, but rather that the waterside should be regarded as a scarce resource and development should achieve a balance between the roles identified in the Blue Ribbon Network Principles.


Policy 4C.31 Rivers, brooks and streams
The Mayor will, and boroughs should, in discharging their development control and other duties, ensure that rivers, brooks and streams of all sizes are protected, improved and respected as part of the Blue Ribbon Network and as valuable entities in themselves. In particular, measures should be taken to improve the habitat and amenity value of such waterways.



Transport:

5.13 Accommodating the expected growth in population and jobs in London will hinge on the ability of the transport system to cope – in terms of location and phasing of increase in capacity. Future public transport improvements include those that support development of East London, growth in Central London and Opportunity Areas and better access to town centres and Areas for Regeneration.



Housing:

Policy 6A.4 Priorities in planning obligations
The Mayor will, and boroughs should, reflect the policies of this plan and include appropriate strategic as well as local needs in their policies for planning obligations.The Mayor wishes to develop with boroughs a voluntary system of pooling for the provision of facilities related to proposed developments. Affordable housing and public transport improvements should generally be given the highest importance with priority also given to learning and skills and health facilities and services and childcare provisions.


6.23 Many developments have impacts beyond borough boundaries, such as those involving public transport improvements and new school and health facilities. The acute shortage of homes and the constraints on the public transport system mean that all developments make an incremental impact upon the overall needs of the city. A strategic approach is needed in respect of the wider impacts of an application, in addition to the assessment of more local needs, in accordance with in accordance with national guidance. The Mayor wants to reconcile strategic with more local impacts. There is also need for pooling of contributions in cases where partial contributions towards a larger objective may be appropriate:for example towards secondary schools, open space provision or strategic public transport investment.



What is the part of the residents in this?

6.28 London’s communities need the capacity to have a greater say in the future of their areas and to benefit from full participation in community life (see Chapter 3,Part A). The Mayor will support the development of Community Strategies to this end and would welcome a neighbourhood response to the strategic goals of this plan. The Mayor’s Annual Monitoring Report (see Policy 6B.2) will seek to reflect local community responses to the implementation of this London Plan.


6.84 The Mayor also wants to hear Londoners’ views on the issues and will create a network that can be used to gather stakeholder opinion and feedback.


3A.25 Social and Major developments in, or with the potential economic impact to impact on, Areas for Regeneration should assessments be subject to social and economic impact assessments.


4A.8 Energy assessment Major developments should require an assessment of energy demand including demonstrating the steps taken to apply the Mayor’s energy hierarchy.


4A.9 Providing for Major developments should show how the development renewable energy would generate a proportion of the site’s electricity or heat needs from renewables, wherever feasible.


4B.1 Design statements Development proposals should include urban design statements showing how design principles have been incorporated which illustrate their design impacts. The detailed requirements will be defined in UDPs and for proposals referred to the Mayor, further advice will be given in the urban design SPG.



 

And Lewishams own Unitary Development Plan

In the Main Submission for the Lewisham Gateway Development the UDP is quoted a couple of dozen times at most, and the developers have concentrated on aspects which don't bring their scheme into sharp focus. We've put together a few quotes from Lewishams UDP as well, that perhaps do adjust the focus towards the needs of the residents of Lewisham.

The Council will seek a high standard of design on the Odeon site, and the Lewisham Interchange/Obelisk site which form the gateway to Lewisham Town Centre. The improvement to the transport interchange is a priority, and the Council wishes to see the development of a prestigious landmark building to provide a convenient interchange between bus, rail, DLR, pedestrian and cycle facilities. These sites are identified in Schedule 1 as Key Development Sites, which contribute to the image of the Borough by reasons of location or size.


In those situations where the height of the proposed development may, in the Council’s view generate potential developmental, overshadowing or micro-climatic problems at street level, overshadowing of riverside pathways, channels and the foreshore with detrimental effect to the river environment or in relation to adjoining buildings, the Council will require information to be submitted that will demonstrate that such problems will not result from the proposed high buildings. Applications for high buildings should therefore be accompanied by design statements. An Environmental Impact Assessment may also be requireds.


High buildings and structures are for the purpose of this policy defined as those which significantly exceed the general building heights of their surroundings.


High buildings are not generally in keeping with the established scale and character of Lewisham.


There are the remains of a palaeolithic archaeological site ö the foundations of a medieval stone bridge ö on which there would be a 'potentially major residual effect' (ie, it would be destroyed) due to the development

URB 21 Archaeology
encouraging suitable development design, land use and management to safeguard archaeological sites and seeking to ensure that the most important archaeological remains and their settings are permanently preserved in situ with public access and display where possible and that where appropriate they are given statutory protection.

URB 22 Important Local Views and Landmarks
Significant local vistas and buildings currently considered to be of townscape importance which are the basis for local views are designated as Local Views and Local Landmarks respectively and are listed in Schedule 1A and shown on the Proposals Map. Development which impedes or detracts from Local Views or obscures existing views of Local Landmarks will be resisted.



Familiar views of the landmarks and panoramas of London, both within the Borough and across its boundaries, are an essential element of the quality of London’s environment. This is recognised by Strategic Guidance which recommends that local authorities take reasonable measures to designate and protect locally significant views. Important local views and landmarks are identified on the Proposals Map and in Schedule 1A. Under this Policy, development within the view corridors should be limited in height and bulk so that it does not detract from the view or obscure the landmark. The significant compass quadrant(s) of the Local Views are indicated with a curved line in the relevant quadrants(s) on the Proposals Map, with details in the Schedule 1A.

7. The value of open space in a built-up residential Borough cannot be overstated. Whether for formal participation in team sport, informal use such as walking or dog-walking, as a place to find space for peaceful relaxation, to enjoy the natural environment or simply to be reassured by its presence, open space is critical to modern urban living.


Open space contributes to the quality of life of Lewisham residents, so in this sense also it can help to create a more sustainable environment, one in which people will continue to want to live, work and learn.


The aims of the SELGC Joint Committee (comprised of 2 members from each of the boroughs of Lewisham, Bexley, Greenwich and Bromley) have been agreed as follows:
• to improve and encourage the provision of suitable recreational facilities with an emphasis on those serving a wide area of south east London and/or requiring open land;
• to safeguard the open land from built development and maintain its structural contribution in providing a visual break in the built-up area of London;
• to conserve and enhance the visual amenity and ecological aspects of the landscape;
• to improve the public access to and through the area;
to promote an overall identity for the area in order to increase public awareness of available recreational facilities; and
• to encourage the collaboration and co-operation of the various public and private agencies, owners, organisations, clubs etc., in the area to achieve the above objectives.


Lewisham’s rivers (a short section of the Thames, and longer stretches of the Ravensbourne and its tributaries the Pool, Quaggy and Spring Brook) provide important linear features which can form the basis for wildlife corridors, as well as the Waterlink Way (see Policy OS 4) and the Thames Path (see Policy URB 25), and are important to sustain biodiversity. The Council considers that buffer zones around watercourses can help to maintain the character of rivers and provide undisturbed refuges for wildlife. Where possible the Council will seek the implementation of these zones (see also Policy URB 26 on the Thames Foreshore). The culverting or building over of watercourses will require the consent of the Environmental Agency. The Council considers that such works can increase flood risk, and should generally be resisted as it results in a break in the continuity of river corridors, and adversely affects nature conservation interests.


5. The other context in which the Plan must operate is the national requirement to find space for more housing. The most recent household projections show that between 1996 and 2021 the number of households in England are projected to increase by 3.8 million. The London element of this is a requirement for approximately 600,000 additional households over the 1996-2021 period. The largest component of the projected growth in households is for single person households (83%). This sets the context for the need to increase the provision of housing in Lewisham.


The Lewisham Housing Needs Survey (LHNS) found that low-cost market housing is of little value in meeting housing need in Lewisham because it is too expensive for those in housing need.


15. The Council’s strategy for housing is to protect and enhance the residential environment. This forms a crucial component in the Council’s corporate vision to make Lewisham the best place in London to live, work and learn. Lewisham’s residential environment is one of the Borough’s main assets; the range, variety and quality of the housing stock, some of it relatively affordable, is a valuable asset and the planning system can go a long way towards its protection. The Council’s strategy recognises the importance of protecting this asset.


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Snippets from the "Lewisham Gateway Non-Technical Survey"

We can also draw some interesting features out of the Lewisham Gateway Developments Limited '4.3 Environmental Statement – Non-Technical Summary – 2006-04-28'. This is essentially a precis of a larger document and contains many of the core features of the Development. Here's a flavour of it. You can download this and all other documents from the Lewisham Website (link here).

Transport & Access

Traffic modelling has shown that the system proposed for the Gateway scheme provides a similar level of capacity as the existing highway network.

Air Quality

There are some uncertainties with the modelling. Monitoring NO2 concentrations once the development is completed is therefore recommended to confirm the impact. The mitigation measures recommended will reduce the impact, but there is considered to be a major residual adverse impact.

Wind Environment

The proposed development is taller than its surroundings and is exposed to the prevailing winds. Without any mitigation, conditions are expected to exceed the criteria of 'distress' for 'general public access' at a variety of locations. Mitigation measures such as planting, canopies and porous screens have been developed to improve conditions.

Conditions within Confluence Place were observed to be excessively windy for the intended use of the area. Through extensive planting and the incorporation of a porous screen extending from block A, conditions were improved, and, while they remain windy, they would be acceptable for general access.

The open spaces between blocks B and C and between blocks C2 and E would have acceptable conditions for the intended leisure activities. Suitable conditions for outside seating can be expected on calm weather days in summer.

Along Rennell Street conditions would be windy, however they would remain acceptable for general access. Whereas conditions at the entrance to the Bank One Tower would be unacceptable for an entrance. Mitigation measures will need to be developed for this area at a later stage.

Maximum Height Scheme

Conditions with the maximum height scheme would be, for the majority of areas, worse than for the optimum height scheme. Generally conditions remain acceptable, however, to the north of block A, in Confluence Place, along the main retail area between blocks C and D and along Rennell Street, conditions would no longer be acceptable for their intended use. Massing adjustments, such as changes in height or orientation of the buildings, would be required to create acceptable conditions.

Daylight and Sunlight Availability

The development will reduce the sunlight availability but the results still exceed the minimum criteria in nearly every case.

Land Quality

The effects of the proposed scheme related to land contamination are primarily those associated with:

• the demolition of the existing buildings and structures on the site, and

• the removal of existing areas of pavement and hard surfaces.

These works will increase the potential for contact, uptake or leaching of any existing contaminants in the soils. This could potentially resulting in a negative effect on site workers and the chalk aquifer present below the site during the proposed construction works. The chalk aquifer present below the site is considered to represent a sensitive receptor. Considering the number of and distance to the abstraction points in the vicinity of the site the potential for significant harm is considered to be high to very high. This will be mitigated in part by phased construction of the proposed scheme and by specific measures to be adopted to isolate or treat any significant areas of contamination encountered during the construction works.

Landscape Character & Visual Impacts

In terms of visual impacts, all those currently having views of the Lewisham roundabout area and the culverted River Quaggy will have views of the new traffic layout and the urban centre. Overall the cumulative effects on landscape character might be termed moderately adverse.From the perspective of visual effects considered over the range of sensitive receptors, it is considered that the overall cumulative effects are likely to be moderately beneficial.

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What the Developers think of our views

If we turn our attention to our views we see another facet of the developers rich imagination and playful use of words. I'm concentrating on Hilly Fields because it's a popular destination for all kinds of activities, not the least of these being the enjoyment of the views.

The developers are sensitive to our panoramic views, so sensitive in fact that the residents are often referred to as 'receptors'. For instance, if you live in Brookbank or Ellerdale Road, this is how the developers see you:

Middle and longer distance views are apparent to areas above the site from Loampit Vale and to the east of the site along the roads running towards the site, namely Brookbank and Ellerdale roads for pedestrian and vehicle travellers (see Photomontage Views 10 and 13, Figures 13.23 and 13.26 respectively). The sensitivity of these receptors is considered low and the sensitivity of these receptors to change to the type and scale of development proposed is considered low, because views are transitory.

See the illustration at the top of the page for the view that is considered 'transitory'.

And specifically Hilly Fields:

Panoramic views from high ground towards the east. The Citibank building breaks the skyline and is a dominant feature. The sensitivity of receptors is considered low and the magnitude of change experienced by the receptors is considered small. The significance of the effect is considered minor beneficial as the clustering of buildings around the predominant Citibank building will help to improve a small part of the view.

So, as a receptor I'm glad to hear that I may derive benefit from the development, albeit minor.

They go on:

High quality architecture will help to improve the skyline and reduce the predominance of the Citibank building.

and

With the delivery of high quality architecture, the residual effect is considered to be positive

Here are some photos of how the new development will look from Hilly Fields.

Incidentally, the first picture is based on a picture that appears in their glossy brochure, and shows that, short of actually lying down on the grass, the building can just about be seen from their chosen viewpoint.

 

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