The main points of our 2012 objection are outlined below. We maintain that very little has changed in terms of the application details since this information was compiled.
However, the decision will no longer be made at local level since the Mayor of London agreed to the developer's demands that he take over the decision-making process from the local authority.
As a result, any new objections should be sent directly to the Mayor of London. We also recommend that anyone who sent objections to Lewisham planning department as part of the standard procedure, should send them again to Boris Johnson, to ensure they are noted.
In addition to our own objections, there have been some important comments by statutory bodies and other consultees, which we have highlighted in our blog, not to mention the decision by the World Monuments Fund to place Deptford Dockyard and Sayes Court Garden on its 'at risk' register.
English Heritage has raised strong objections, and Transport for London has highlighted some critical aspects of the transport strategy which are out of date. We believe the transport assessment seriously underestimates the impact the development will have on local travel.
How to write an objection
You should include your name and address, and send your letter (including the planning application reference number shown below) to the Mayor of London at the address shown below.
We recommend that you also copy it to your local councillors, Lewisham's mayor, deputy mayor, the chair of the strategic planning committee, and your local MP (all details shown below).
We have identified the following major aspects of the Convoys Wharf planning application (reference DC/13/83358) which we believe either contradict or fail to take account of current planning policy.
You may wish to include some or all of these in your letter. If you have other suggestions for specific objections, please feel free to add them in the comments or email us at deptfordis@yahoo.co.uk.
Overall
As a whole, we believe that the illustrative nature of the planning application means that it fails to go into sufficient detail to safeguard essential aspects such as architectural design quality, building density and massing, height of perimeter buildings, the future of the working wharf, the cultural centre, the energy supply and the school.
Some indication of the size of the proposed structures can be gained by looking at the renderings, some of which we have posted here. However you should also be aware that certain devices have been employed to try and minimise the visual impact of the structures - for example by making taller blocks the same colour as the clouds etc.
Heritage
National planning policy statement 5 states in HE6 that:
Where an application site includes, or is considered to have the potential to include, heritage assets with archaeological interest, local planning authorities should require developers to submit an appropriate desk-based assessment and, where desk-based research is insufficient to properly assess the interest, a field evaluation.
This information together with an assessment of the impact of the proposal should be set out in the application (within the design and access statement when this is required) as part of the explanation of the design concept. It should detail the sources that have been considered and the expertise that has been consulted.
Local planning authorities should not validate applications where the extent of the impact of the proposal on the significance of any heritage assets affected cannot adequately be understood from the application and supporting documents.
We do not believe that the application meets this criteria, neither for the structures of the Royal Dockyard, nor for the site of Sayes Court Garden.
The proposals fail to respect the heritage value of these assets, which have national significance and which could form the focus of a heritage-led regeneration of Convoys Wharf and Deptford.
The developers have publicly claimed to have incorporated Sayes Court Garden and the Lenox Project into their latest masterplan. However the site offered for the Lenox Project is impractical for the build and launch of a ship (it is neither a slipway nor a dry dock) and is a temporary site which the developers have no use for. Additionally, no permanent berth for the ship has been offered. Likewise the site that has been suggested for Sayes Court Garden does not support its long-term viability.
We are disappointed that the planning application shows a lack of imagination as regards the exploitation of these unique resources, which could be used to benefit Deptford by creating a nationally-significant tourist attraction on the site.
The masterplan as it stands is reluctant to reflect the dockyard's historical fabric - the dock structures still present on the site could be restored and used to reconnect Deptford to the river, providing a place of sense which fully acknowledges the site's heritage.
Parking and highway traffic
The suggested ratio of 0.49 parking spaces per residential unit and the additional provision of 323 spaces for non-residential uses is excessive. The additional car traffic generated by this proposed development will create an unacceptable impact on the surrounding highway network and in particular on the access roads in and out of the site.
The proposed accommodation of these parking spaces in 'podium' car parking will have an unacceptable impact on the streetscape, making it oppressive and potentially undermining the safety and security of the streets.
Transport
If redevelopment proceeds to the maximum extent set out in the planning application, the impact on the existing local transport system will be totally unacceptable.
The transport plan predictions of the number of journeys to and from the site by riverbus are overly optimistic, suggesting the true impact on other modes of transport has been severely underestimated. Read more details on our post here.
As the GLA has already pointed out, some transport aspects fall seriously short of what may be acceptable in terms of the London Plan transport policies.
Density, height and mass of buildings
The proposed density of development on a site with such a low public transport accessibility level is inappropriate and undesirable. The illustrative design which shows large C-shaped residential blocks on the waterfront is inappropriate both in its scale and its impermeability, which makes access to the riverfront difficult.
The three high towers which are proposed are out of scale in relation to the existing tall buildings in the vicinity. The lack of detail and scale parameters in relation to them gives concern regarding their final quality and makes it impossible to fully assess their impact, including that on the nearby view corridor, the setting of listed buildings/structures and the adjacent conservation area.
We support the comments made by the GLA report: "There are grounds for a concern that the overall quantum of development cannot be acceptably accommodated on the site. This concern is reinforced by the overall densities that would be required to reach the upper level of development quantum."
If perimeter buildings are developed to the maximum heights proposed, they will cause severe overshadowing and have an unacceptable impact on the daylight available to residential properties on the perimeter of the site.
Open space
Plan views of the development are misleading and deceptive, suggesting a good proportion of open space will be created. However the majority of this open space consists of private gardens above the podium car parks, and will be neither visible nor accessible from the street.
The lack of open space will create an oppressive and unattractive streetscape which is likely to prove uninviting for visitors to the site.
Affordable housing
A firm commitment should be given to the proposed percentage of affordable housing that the developer intends to deliver, and the mix of housing units that will be provided.
The current scheme incorporates NO social rented housing at all, it is all proposed to be shared ownership or 'affordable' housing (offered for rent at 80% of the local market rate). Considering this is one of the biggest redevelopment sites in south east London, we believe this is totally unacceptable.
Comments by others
Joan Ruddock's introduction to the Naval Dockyards Society conference.
A column by Paula Hirst, head of regeneration at Mazars, in Estates Gazette.
Leader column by Building Design executive editor Ellis Woodman.
Architecture critic Kieran Long writing in the Evening Standard.
Private Eye writing about the Mayor's decision to call in the application.
SEND YOUR OBJECTION TO:
Boris Johnson
Mayor of London
Greater London Authority
City Hall
The Queen's Walk
London SE1 2AA
Email: mayor@london.gov.uk
Although it is possible to send an objection up to the The sooner you send your objection, the better. The Mayor of London is currently stating that he plans to hold the public hearing (and subsequently make the decision) in February next year, so we recommend that objections be sent by mid-January at the very latest.
COPY YOUR OBJECTION TO:
1. YOUR WARD COUNCILLORS
(Councillor’s name)
Town Hall
Catford
SE6 4RU
Evelyn Ward
Crada Onuegbu
cllr_crada.onuegbu@lewisham.gov.uk
Sam Owolabi-Oluyole
07552 203462
samoluyole@yahoo.co.uk
Olufunke Abidoye
020 8691 2377
New Cross Ward
020 8318 1338
madeliene.long@lewisham.gov.uk
Paul Maslin
020 8297 2544
cllr_paul.maslin@lewisham.gov.uk
Stephen Padmore
020 7639 4246
cllr_stephen.padmore@lewisham.gov.uk
Telegraph Hill Ward
020 8314 7047
cllr_paul.bell@lewisham.gov.uk
Joan Millbank
020 8314 6929
cllr_joan.millbank@lewisham.gov.uk
Dan Whittle
020 8314 6975
cllr_dan.whittle@lewisham.gov.uk
Brockley Ward
020 8314 7053
cllr_obajimi.adefiranye@lewisham.gov.uk
Vicky Foxcroft
020 8314 6899
cllr_vicky.foxcroft@lewisham.gov.uk
Darren Johnson
020 8694 6541
Cllr_darren.johnson@lewisham.gov.uk
Don’t know who your local councillors are?
Enter your postcode here to find out:
councilmeetings.lewisham.gov.uk/mgFindCouncillor.aspx
Greenwich West
Deputy mayor
74 Royal Hill
London SE10 8RT
david.grant@greenwich.gov.uk
020 8691 9459/07904 280 472
Maureen O’Mara
25 Ashburnham Place
London SE10 8TZ
maureen.omara@greenwich.gov.uk
020 8692 5379/07931 963 852
Matthew Pennycook
Town Hall
Wellington St
London SE18 6PW
matthew.pennycook@greenwich.gov.uk
020 8921 5050
2. OTHER IMPORTANT COUNCIL MEMBERS
Mayor Steve Bullock
Civic Suite
Town Hall
Catford
SE6 4RU
020 8314 6193
steve.bullock@lewisham.gov.uk
Deputy mayor Alan Smith
020 8697 5505
cllr.alan.smith@virginmedia.com
Chair of the strategic planning committee: John Paschoud
020 8291 5729
cllr_john.paschoud@lewisham.gov.uk
3. YOUR MP
Lewisham Deptford constituency
Joan Ruddock MP
House of Commons
London
SW1A 0AA
joan.ruddock.mp@parliament.uk
Lewisham East constituency
Heidi Alexander MP,
House of Commons,
London, SW1A 0AA
020 8852 3995
Greenwich & Woolwich constituency
Nick Raynsford MP
House of Commons
London
SW1A 0AA
nick.raynsford.mp@parliament.uk.
0207 219 5895
