The following letter was submitted to Lewisham Council, and copied to the developer's agent last week (emphasis is ours):
In May 2005 your Council resolved to grant outline planning permission for a scheme of redevelopment that is broadly comparable to that which is now being proposed. As the applicants' planning statement points out, "the current proposals represent essential "fine tuning"" of this earlier scheme which has, "resulted in a "shuffling" of uses and little change to the overall scale of the development".
The development site extends to 16.6 hectares on the south bank of the River Thames approximately 1 kilometre west Greenwich, the heart of which is designated as the Maritime Greenwich World Heritage Site. It is a site of significant historic importance as it incorporates what remains of Deptford Royal Dockyard. Following his accession to the throne in 1509, King Henry VIII set about expanding what had become recognisable as a standing Royal Navy and, as part of this expansion, he ordered the building of a storehouse at Deptford Dockyard in 1513. By the mid sixteenth century Deptford and Woolwich Dockyards had become the most important dockyards nationally for the construction and repair of warships. This importance waned during the seventeenth century when Chatham and Portsmouth gained pre-eminence and in 1869 the dockyard was closed.
Significant archaeological remains of the dockyard survive including the remains of the Tudor storehouse, a site that was accorded Scheduled Ancient Monument status in 2003. Above ground, the designated heritage assets that survive from the dockyard are relatively few. Three are within the development site: At the centre of the development site stands a building known as the Olympia Warehouse, an iron framed building of c.1846/7 that provided cover for two slips that opened into the central basin of the dockyard; in the south west corner of the site stand a pair of brick piers and stubs of boundary wall that are the remains of a gateway into the dockyard; and along the site's eastern boundary, is a length of high brick wall dating from the eighteenth century.
All are included in the List of buildings of special architectural or historic interest at grade 2. Outside the development site are two buildings that were part of the dockyard, both of are listed at grade 2*. They are adjacent to the north east corner of the development site and are the former Master Shipwright’s House and the former Office Building of the dockyard which date from 1708 and 1720 respectively. Immediately to the north of the development site on the riverside – and also outside its boundaries – are a pair of former warehouse buildings that date from the late eighteenth century which were part of the Royal Victoria Victualing Yard. Converted to residential use in the mid-twentieth century they are listed grade 2.
The development site also includes the site of Sayes Court – the house occupied by the diarist and gardener, John Evelyn – and its celebrated gardens. However, the archaeological investigations carried out so far have not found any significant remains that can be dated to his occupation of the site.
When my former colleague, Paul Calvocoressi, wrote to your Council on 20 October 2003 commenting upon the previous application, he wrote at some length about
the failure of that masterplan to relate to the outstanding historic importance of the site and that an analysis of the dockyard's development and its place in the wider history of the area had not been expressed in the creation of a really distinctive sense of place. He pointed out that
an understanding of the site's history should have been used as a stimulus to the creative process and that the archaeological evidence, of which a great deal more is now known, ought to have been used to inform what happens above ground.
The key historic features – the double dock, the Olympia building, the basin (and its connection to the river), the Tudor storehouse, the mast ponds and the slips – could all have been used as catalysts to inform a design that retains a legible link with the river and the former activity of the site and create a more unique place than the rectilinear, grid-like planning of the 'fine-tuned' masterplan now before your Council.
English Heritage is particularly disappointed that the opportunity re-engage with the site's outstanding historic significance has not been grasped. Indeed, we can see no compelling reason why the one real attempt that was originally proposed to interpret the site's history in the new development, i.e. the creation of a significant area of public open space that evoked the dockyard basin in front of the Olympia building, has been 'fine-tuned' out of this latest application. In our view, the creation of a tangential link with the river as now proposed is a distant second best relative to the original proposal.
Turning to the wider impacts of the proposal, English Heritage accepts that this is a major development site which is recognised as an opportunity area in the London Plan and that there is a clear policy basis within Lewisham's Core Strategy that recognises Convoys Wharf as being a site that may be appropriate for tall buildings. However,
we are not persuaded that there is a compelling justification for three tall building on the site especially when taking account of the visual impact that they will have upon the panorama from Greenwich Park, a panoramic view that is designated as worthy of management in the current draft of The London View Management Framework (LVMF).
We recognise that the LVMF suggests that development on the river edge at Deptford in the foreground and the middle ground of the designated panoramic view from Greenwich Park, "should help reinforce the composition of the existing view" but we consider that the proposal to erect three towers rising to 46, 38 and 32 storeys concentrated in the central area of the site and close to the river edge fails to fit within the prevailing pattern of buildings and spaces and is therefore at variance with the core LVMF Policy 7.12.D.a. Taken with the two existing tall buildings on the nearby Pepys Estate, the net impact is, we believe, the creation of a cluster of tall buildings within this area of the designated panoramic view that competes dis-advantageously with the existing clusters of tall buildings in the City of London and Canary Wharf.
It remains our view that any development at Convoys Wharf should relate to the local scale of Deptford and Greenwich and not to the metropolitan scale of the City or Canary Wharf.
We also note that the proposed tall buildings will have an impact, described by the applicants as "moderate, adverse and permanent", upon views from within the Maritime Greenwich World Heritage site and especially from views within – and especially along the northern boundary of – the group of grade 1 listed buildings that comprise the former Greenwich Royal Hospital. We note that in analysing this view the applicants
make no reference to the existence of the World Heritage Site and no comment upon whether the proposals have any impact upon its Outstanding Universal Value.
We regard this as a significant omission.
Since your Council decided that it was minded to grant outline planning permission for the previous scheme in 2005, there has been an opportunity to re-visit the comprehensive redevelopment of this site and to bring forward a scheme which paid a greater regard to its historic context.
English Heritage is disappointed that the applicants have failed to grasp this opportunity and see this current application simply as a fine tuning exercise. Indeed, the one element of the earlier proposals where historic context was positively recognised, i.e. the setting of the Olympia Warehouse, has been omitted from the latest proposals.
It is English Heritage's view that the regeneration of Convoys Wharf as now proposed fails to grasp the unique opportunity to create a distinctive sense of place that takes full advantage of the rich historical legacy of the site and its local area.
I should make it clear that the comments and views expressed in this letter relate to the impact that the proposals have upon the wider historic environment in general and the site itself. My colleague Dr Jane Sidell will deal with matters relating to the Scheduled Ancient Monument and any applications for Scheduled Monument Consent that may arise and my colleague Mark Stephenson will deal with matters associated with the wider archaeological issues associated with the proposed development. They will be writing to you separately with their comments upon the application for outline planning permission in due course.
Malcolm Woods
Historic Buildings & Areas Adviser