representation hearing report D&P/0051c/03
31 March 2014
Convoys Wharf, Deptford
in the London Borough of Lewisham
planning application no. DC/13/83358
Outline planning application
Town & Country Planning Act 1990 (as amended); Greater London Authority Acts 1999 and 2007;
Town & Country Planning (Mayor of London) Order 2008 (“the Order”); and, Town and Country
Planning (Environmental Impact Assessment) Regulations 2011.
The proposal
Demolition of all non-listed structures at the site, and comprehensive redevelopment (to include
retention and refurbishment of the Grade II Listed Olympia Building) to provide up to 419,100
sq.m. of mixed use development comprising up to: 321,000 sq.m. residential (Class C3) (up to
3,500 units); 15,500 sq.m. business space (Class B1/live/work units) and to include up to 2,200
sq.m. for three energy centres; 32,200 sq.m. working wharf and vessel moorings (Class B2 and sui
generis); 27,070 sq.m. hotel (Class C1); 5,810 sq.m. retail, financial and professional services
(Classes A1 and A2); 4,520 sq.m. restaurant/cafes and drinking establishments (Classes A3 and
A4); and, 13,000 sq.m. community/non-residential institutions (Class D1), 1,840 car parking
spaces, together with vehicular access and a river bus facility.
The applicant
The applicant is Convoys Properties Limited, and the architect is Farrells.
Recommendation summary
The Mayor, acting as Local Planning Authority for the purpose of determining this application:
i. grants conditional planning permission in respect of application DC/13/83358 for the
reasons set out in the reasons for approval section below, and subject to the prior
completion of a section 106 legal agreement;
ii. delegates authority to the Assistant Director - Planning and the Executive Director of
Development, Enterprise and Environment to issue the planning permission and agree,
add, delete or vary, the final detailed wording of the conditions and informatives as
required, and authority to negotiate, agree the final wording, and sign and execute, the
section 106 legal agreement;
iii. delegates authority to the Assistant Director - Planning and Executive Director of
Development, Enterprise and Environment to refuse planning permission, if by 30 June
2014, the section 106 legal agreement has not been completed;
iv. notes that approval of details pursuant to conditions imposed on the planning permission
will be submitted to, and determined by, Lewisham Council; and,
v. notes that Lewisham Council will be responsible for the enforcement of the conditions
attached to the respective permission.
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Drawing numbers and documents
Existing plans
CON1-PA-03-001; CON1-PA-03-002; CON1-PA-03-003; CON1-PA-03-004; and, CON1-PA-03-005.
Proposed parameter plans
CON1-PA-03-006A; CON1-PA-03-007A; CON1-PA-03-008A; CON1-PA-03-009A; CON1-PA-03-010A;
CON1-PA-03-011B; CON1-PA-03-012B; CON1-PA-03-013A; CON1-PA-03-014A; CON1-PA-03-015A
(indicative); CON1-PA-03-016A (indicative); CON1-PA-03-017A; and, CON1-PA-03-018A.
Submitted documents
Application Form (ref: CW01); Environmental Statement (ref: CW02); Environmental Statement Addendum
Report (ref: 027979); Design and Access Statement (ref: CW03); Design and Access Statement Addendum
(ref: CW03A); Design Guidelines (ref: CW04); Development Specification (ref: CW05A); Planning
Statement (ref: CW06); Transport Assessment (ref: CW07); Energy Strategy (ref: CW08); Sustainability
Statement (ref: CW09); Retail Impact Assessment (ref: CW010); Statement of Community Involvement (ref:
CW011); Delivery Strategy (ref: CW012); Commercial Strategy (ref: CW013); Heritage Statement (ref:
CW014); and, Cultural Strategy (ref: CW015).
Reasons for approval
1
The Mayor, acting as the local planning authority, has considered the particular
circumstance of this application against national, regional and local planning policy, relevant
supplementary planning guidance and any material planning considerations. He has also had regard
to all consultation responses and representations made on the case, including those submitted by
Lewisham Council following its Strategic Planning Committee meeting of 16 January 2014. The
reasons set out below are why this application is acceptable in planning policy terms:
i.
The future operation of a working wharf at this site has been suitably secured, and the
proposed comprehensive mixed use redevelopment at this site will provide valuable homes
and jobs to catalyse the regeneration of Deptford. Accordingly, the principle of mixed use
redevelopment at this site is strongly supported in line with the NPPF; London Plan Policy
2.13; and, Core Strategy policies SP2, SSA1 and SSA2.
ii.
Having regard to the characteristics of the site and its context, and the critical factors
influencing wharf viability (as outlined within London Plan paragraph 7.77), GLA officers are
satisfied that the proposed contraction and reconfiguration of the safeguarded wharf at the
site is acceptable, and that the proposed wharf location, plot boundary, and associated
maximum floorspace quantum would provide a viable, flexible and commercially attractive
environment for a range of potential river freight operators. Necessary assurances are in
place to secure appropriate use of the Blue Ribbon Network for construction logistics, and
measures to reasonably incentivise uptake of the wharf by one or more suitable operators
are to be included within a section 106 legal agreement. Furthermore, subject to the
inclusion of planning conditions to protect neighbourhood amenity, GLA officers are
satisfied that the potential impacts of the working wharf on sensitive uses could be suitably
mitigated. Accordingly, the application is supported in line with the NPPF; and, London
Plan Policy 7.26.
iii.
The outline application provides a wide range of uses in accordance with local and strategic
policy aspirations for this Opportunity Area site. Whilst the proposed nature and provision
of employment generating floorspace within the scheme does not strictly accord with that
prescribed by part 1(b) of Core Strategy Policy SSA2, the scheme would, nevertheless,
deliver significant new local employment opportunities and successfully achieve key
employment related Core Strategy objectives for this site in terms of transforming the
economic fabric of this part of Deptford and supporting the development of commercial
activity with respect to wharf-related activities and the creative sector. The retail
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component of the scheme has been designed to complement existing provision at Deptford
town centre (including Deptford High Street and Deptford Market) and, subject to
reasonable controls, will positively contribute towards a vibrant and diverse local economy.
Furthermore, the inclusion of hotel provision within the scheme as part of the wider
regenerative mixed use strategy for this site will allow the scheme to capitalise on its
riverside Opportunity Area setting, and significantly boost the visitor economy within
Deptford. Accordingly, the application is supported in line with the NPPF; London Plan
policies 4.5 and 4.7; and, Lewisham Core Strategy Policy SSA2.
iv.
The proposal would optimise the residential potential of this Opportunity Area site and
make a significant contribution to housing and affordable housing delivery in Lewisham.
The financial viability position has been independently verified and, subject to the inclusion
of a review mechanism within the section 106 legal agreement, the scheme will continue to
deliver the maximum reasonable amount of affordable housing over the lifetime of the
delivery programme. The housing schedule responds to the need to support mixed and
balanced communities, provides a good variety of dwelling sizes, and appropriately
prioritises affordable family housing within the wider residential mix. The scheme is also
capable of achieving good practice residential design and amenity standards, and exceeding
children’s play and minimum space standards. Accordingly, the proposed housing provision
is strongly supported in accordance with the NPPF; London Plan policies 3.3, 3.4, 3.5, 3.6,
3.8, 3.9, 3.11, 3.12 and 7.15; and, Lewisham Core Strategy policies 1, 4 and SSA2.
v.
Through various commitments to deliver necessary social infrastructure; promote social
inclusion; improve local employment opportunities; and, deliver a cultural legacy at the site,
the outline application would positively contribute to the promotion of sustainable
communities. Accordingly, the outline application is supported in accordance with the
NPPF; London Plan policies 3.1, 3.16, 4.6, 4.12, 7.8 and 7.9; and, Lewisham Core Strategy
Objective 10 and Policy SSA2.
vi.
The proposed site layout and masterplan strategy has been well considered and achieves the
key aims of providing a generous central open space and a direct and legible route between
the riverside and Deptford High Street; the masterplan plots would put Olympia (Grade II)
at the heart of the site and generate blocks that would ensure that the public realm
(including streets and open spaces) would be clearly defined by active built frontages; the
scheme would provide a range of soft and hard-landscaped public spaces contributing to a
significant uplift in local open space; and, the height and massing of the development
would enliven the silhouette of the scheme when viewed from the riverside, landmark the
Thames from townscape views inland, and would not cause harm to the surrounding context
(including strategic and local views). Accordingly, the application complies with the NPPF;
London Plan policies 7.1, 7.3, 7.4, 7.5, 7.6, 7.7, 7.12, 7.18 and 7.27; Lewisham Core
Strategy Objective 10 and policies 15, 18 and SSA2; saved Lewisham UDP policies STR URB
1, STR URB 4, URB 1 and URB 3, and emerging policies DM 30 and 35 within the
submission stage Development Management Local Plan.
vii.
The outline application would appropriately ensure the preservation of existing archaeology
at the site, and would strike an optimum balance between showcasing and expressing the
site’s rich historic past, and allowing this Opportunity Area site to fulfil its regenerational
potential as a twenty first century contribution to the Thames riverside at Deptford. With
respect to historic buildings and spaces, and having had special regard to the desirability of
preserving Listed Buildings, their settings and any features of special architectural or historic
interest which they possess, GLA officers are satisfied that the proposed development would
conserve the significance of the Olympia building (Grade II) and Master Shipwrights House
and Dockyard Office (Grade II*) and enhance the settings of these Listed Buildings. The
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proposal would not cause harm to the setting or significance of the other Listed Buildings at
the site, or in the surrounding townscape. Furthermore, the proposed development would
preserve the character of Deptford High Street, West Greenwich and Greenwich Park
Conservation Areas, and preserve the outstanding universal value of the Maritime
Greenwich World Heritage Site. Accordingly, GLA officers are satisfied that the application
complies with the NPPF; London Plan policies 7.8, 7.9 and 7.10; and, Lewisham Core
Strategy Policy SSA2.
viii.
The outline application has significant potential to support social inclusion, and promote
the creation of sustainable communities, by opening up this site and sharing the Thames
riverside with the local community in an accessible way. Whilst careful attention to detail
will be required at reserved matters stage to ensure the detailed design of the masterplan
would deliver the highest standards of access and inclusion, further to the principles
enshrined within the outline design strategy, and the assurance that relevant accessibility
standards will be suitably secured as part of the section 106 agreement, the application
accords with the NPPF; London Plan policies 3.8, 4.5 and 7.2; and, Lewisham Core Strategy
policies 1 and SSA1.
ix.
The outline application appropriately prioritises sustainable energy measures, including
prioritisation of connection with the South East London Combined Heat and Power district
energy network, and will deliver a minimum 25% saving of carbon dioxide emissions
compared to a 2010 Building Regulations Part L compliant development. Accordingly, the
application complies with the NPPF; London Plan Policy 5.2, 5.6 and 5.7; and Lewisham
Core Strategy Spatial Policy 1, and polices 7, 8 and SSA1.
x.
The proposed development would acceptably mitigate its own environmental impact.
Furthermore, when relevant cumulative impacts are taken into account, the proposal would
result in a positive impact on the local environment as a result of the significant
regenerational benefits of the scheme. Accordingly, the application complies with the NPPF;
London Plan policies 5.10, 5.11, 5.12, 5.13, 5.14, 7.6, 7.15, 7.19 and 7.24; Lewisham Core
Strategy polices 7, 10, 11, 12; and 18, emerging policies DM26 and DM27 within the draft
Lewisham Development Management Local Plan.
xi.
The outline application would not cause significant adverse local impacts with respect to
issues of daylight, sunlight and overshadowing; or, privacy/overlooking. Accordingly the
application complies with the NPPF; London Plan Policies 7.6; and, Lewisham saved UDP
Policy HSG4.
xii.
With respect to issues of transport, the application submission includes sufficient
assessment at this stage to establish an appropriate context for decision making and to
provide the basis for subsequent more detailed work as the scheme is progressed. The
proposals would strike an appropriate balance between promoting new development and
encouraging cycling, walking and public transport. The scheme would contribute towards a
range of public transport and walking and cycling improvements in the area and be
accessible by a range of means of transport. The quantum of proposed car parking is
acceptable, subject to a suitable framework of controls and through the promotion of noncar modes of transport. Appropriate controls and mitigation measures are proposed to
ensure that transport impacts (during construction and subsequently) would be acceptable.
Accordingly, the application complies with the NPPF; policies contained within Chapter 6 of
London Plan; Lewisham Core Strategy Policy 14; and, emerging Policy DM 29 within the
submission stage Development Management Local Plan.
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xiii.
Appropriate, reasonable and necessary planning conditions and planning obligations are
proposed to ensure that the development is acceptable in planning terms. Accordingly
there are no, or insufficient, grounds to withhold planning consent on the basis of the
policies considered and other material planning considerations.
Recommendation
2
That the Mayor, acting as Local Planning Authority, grants planning permission in respect
of application DC/13/83358, subject to prior completion of a section 106 legal agreement, and the
inclusion of planning conditions and informatives, as summarised below. The detailed draft
wording of conditions and informatives are set out in the draft decision notice appended to this
report.
Section 106 legal agreement
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Local employment and training initiatives - £1,500,000;
Local education - £440,000 (with a top up to £881,000 subject to viability review);
Local open space - £560,000;
Local heritage and public art - £300,000;
Community Trust - £250,000;
Community projects - £250,000 (Subject to community project business plan approval. If a
business plan is not approved, this sum will be added to the Community Trust);
Communications infrastructure (including monitoring and mitigation) - £20,000;
Provision of Controlled Parking Zone - £250,000;
Highways works to Evelyn Street (including at Deptford High Street/New King
Street/Watergate Street, Prince Street/Abinger Grove, Grove Street and Oxestalls Road
junctions to accommodate development traffic and support walking and cycling and access
to public transport) - works to a specification to be agreed;
Highway works to New King Street (to accommodate development traffic, enable two way
bus operations and promote walking and cycling) - works to a specification to be agreed;
Highway works to Prince Street and Grove Street to accommodate development traffic and
the diverted bus route and support walking and cycling - works to a specification to be
agreed;
Highway works to northern section of Deptford High Street (to support walking, cycling and
access to public transport) - £500,000;
Any further highway works to accommodate development traffic and support walking,
cycling and public transport agreed as necessary following detailed modelling and
assessment;
Pedestrian and cyclists improvements to Deptford Church Street/A2 junction - £20,000;
Riverbus service - £3,000,000;
A new and a diverted bus service (plus capacity enhancements to existing services on Evelyn
Street) - £5,750,000;
New and enhanced off-site bus stops - £147,500;
Travel Plan for each use (including Travel Plan measures, coordinator and monitoring);
School Management Plan;
Delivery of on-site spine road (including site accesses at Grove Street and New King Street,
and a pair of bus stops);
Delivery of Thames Path extension and a network of public pedestrian and cycle links within
the site and accesses thereto;
Management and maintenance of site spine road, river pier and access (including Thames
Path extension and pedestrian and cycle links to adoptable/agreed standards);
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Delivery of river pier for timetabled passenger services and associated land facilities and
access;
Rights of access to spine road, river pier, Thames Path and pedestrian and cycle links
(equivalent to adoption);
Implementation of approved site Parking Management Plan (including drop off/pick up
arrangements, delivery and servicing and service management plans, and construction
logistics and travel plans);
Maximising use of the river for transport during demolition, site clearance and construction;
Car parking ratio review;
Occupiers of the development to be ineligible to apply for local parking permits;
Section 278 agreement with the relevant Highway Authority to facilitate delivery of highway
works;
Property agreement with relevant land owner(s) to facilitate delivery of off-site highway
improvement works and pedestrian and cycle links (including New King Street widening);
Modelling and assessment of local and strategic highways impacts (including upon buses,
pedestrians and cyclists);
Safeguarding of sites for two cycle hire docking stations;
Wharf infrastructure and activation;
Method Statement for wharf infrastructure construction;
Affordable housing review mechanism;
Marketing strategy for residential units;
Social infrastructure (including specification of school);
Cultural Steering Group;
Connection to Pepys Park;
Design Panel;
Archaeological works;
Energy strategy (including prioritisation of SLCHP connection, and details of air quality
abatement technologies where on-site CHP option would be pursued);
Flood Risk Alleviation Strategy;
Biodiversity measures (including fenders);
Air quality monitoring;
Code of Construction Practice (to include adherence to pollution prevention guidance);
Site Waste Management Plan; and,
Section 106 monitoring.
3
That the Mayor agrees that the Assistant Director - Planning and the Executive Director of
Development, Enterprise and Environment, are delegated authority to negotiate, sign and execute
the abovementioned legal agreement, the principles of which have been jointly agreed with the
applicant and Lewisham Council, and which include the heads of terms as detailed above.
Planning conditions
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Time limits;
Development in accordance with approved plans;
Phasing and sub-phasing;
Reserved matters details;
Building Design Guidelines (including guidelines for tall buildings);
Submission of details: infrastructure, drainage (including on site and off site connections/
improvements), wharf infrastructure, servicing and parking, footpaths and cycle paths
(including the Thames Path), landscaping and planting, and site boundary treatments;
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London Plan residential space standards;
100% of dwellings to meet ‘Lifetime Homes’ standard;
10% of dwellings to be wheelchair accessible or adaptable;
10% of hotel bedrooms to be wheelchair accessible or adaptable;
Securing a mix of uses;
Reconciliation Document;
Approval of wharf operation and environmental impact detail;
Wharf servicing strategy;
Control of wharf deliveries by road;
Control of wharf through put;
Retail controls;
Control of non-residential institution use;
Control of hours of use for leisure, community, retail, restaurants, and employment spaces;
Design of basement and semi-basement car parking areas;
Control of plant noise;
Submission of details: noise and vibration attenuation measures for residential plots
adjacent to the wharf;
Control of wharf development prior to attenuation measures for adjacent residential plots;
Assurance of amenity space delivery;
Secured by Design;
Lighting strategy (to include artificial light spill assessment);
Wind test modelling;
Daylight and sunlight assessment;
Details of measures to manage potential overlooking from tall buildings and Jetty Park;
Maximum carp parking ratios related to use/phase/plot;
Maximum disabled parking, electric vehicle charging points and cycle parking ratios related
to use/phase/plot;
Details of cycle, car, motorcycle, coach, disabled parking and electric vehicle charging
points (including drop off/pick up arrangements);
Details of pedestrian routes and facilities;
Details of cycle routes and facilities;
Details of pier and associated land facilities;
Details of bus stops and associated passenger facilities;
Details of Thames Path extension and riverside walk;
Details of Cycle Hire docking stations and any temporary use/landscaping;
Site access and on-site highway infrastructure;
Implementation of Archaeological Resource Management Scheme;
Implementation of a programme of archaeological work;
Programme of archaeological recording;
Protection of archaeologically sensitive areas;
Details of below ground development;
Details of foundation design;
Control of impact piling;
Conservation Management Plan for Olympia;
Details of measures to protect Olympia during construction;
Ecological Management Strategy (to include protection measures for bats);
Tidal inlet ecology details;
Living roofs;
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Landscaping;
Tree protection;
Code of Construction Practice;
London City Airport consultation on construction programme and methodology;
Contamination precautions;
Implementation of Flood Risk Assessment;
River wall surveys;
Scheme for raising of the tidal flood defence;
Surface water source control measures;
Surface Water Drainage Strategy (including sustainable urban drainage measures);
Energy and sustainability standards;
Energy statement for detailed phases; and,
Heritage statement for detailed phases.
Informatives
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No change to safeguarded wharf designation;
Listed Building consent will be required;
Development in proximity of Southern Gas Network infrastructure;
English Heritage advice and further consultation;
City Airport advice and further consultation regarding airport safeguarding criteria;
Port of London Authority further consultation;
TfL further consultation (including London Bus Services and London River Services);
Thames Water advice and further consultation; and
Works affecting public highway.
4
That the Mayor agrees that the Assistant Director - Planning and the Executive Director of
Development, Enterprise and Environment be delegated the authority to issue the planning
permission and agree, add, delete or vary, the final wording of planning conditions and
informatives as required.
5
That the Mayor notes that approval of details pursuant to conditions imposed on the
planning permission will be submitted to, and determined by, Lewisham Council.
6
That the Mayor notes that Lewisham Council will be responsible for the enforcement of the
conditions attached to the respective permission.
Publication protocol
7
This report has been published seven days prior to the Representation Hearing, in
accordance with the GLA procedure for Representation Hearings. Where necessary, an addendum
to this report will be published on the day of the Representation Hearing. This report, any
addendum, and the Mayor of London’s decision on this case will be made available on the GLA
website www.london.gov.uk.
Site description
8
Convoys Wharf is located in north Deptford, on the south bank of the River Thames,
approximately 400 metres north of the main shopping core of Deptford High Street. The site,
identified in figure 1 below, comprises 16.6 hectares and accounts for approximately half of the
London Borough of Lewisham’s frontage on to the River Thames. Further to a direction issued by
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the Secretary of State in June 2000, approximately nine hectares of the site is designated as a
safeguarded wharf. The wharf facilities currently at the site comprise a roll-on/roll-off berth, and a
fixed concrete landing stage/jetty. The wharf is not currently being operated.
9
The site is located within the Deptford Creek/Greenwich Riverside Opportunity Area as
identified by the London Plan, and Convoys Wharf is specifically recognised by Lewisham Council’s
Core Strategy as having potential to be a wider regeneration catalyst for Deptford.
10
The majority of the eastern side of the application site boundary corresponds with the
administrative boundary with the Royal Borough of Greenwich. Notwithstanding this, the eastern
edge is also partly defined by the property boundary with the Grade II* Listed Master Shipwright’s
House (which originally formed part of the former Royal Naval dockyard at the Convoys Wharf site,
and is located within the London Borough of Lewisham). The eastern context to the site is
predominantly residential in nature, characterised by terraced housing, low-rise flats and various
open spaces (including Twinkle Park). The character of the other key landward edges of the site is
also predominantly residential - with the Pepys Estate and Pepys Park defining the site boundary to
the northwest, and Sayes Court Estate and Sayes Court Park characterising much of the boundary
to the south and west. The scale of development at the fringes of the site is predominantly low-rise,
with properties on Grove Street, Barnes Terrace and Leeway (to the west) and Prince Street and
Dacca Street (to the south) ranging from two to five storeys. Notwithstanding this, there are a
number of taller buildings in the vicinity, including two 25-storey buildings and a 30-storey building
(Aragon Tower) at Pepys Estate, and three 11-storey blocks at the Sayes Court Estate.
11
The majority of the proposed development plot has been cleared of buildings, however, the
site is still occupied by eight warehouses, including the Grade II Listed Olympia building (which was
originally constructed for shipbuilding between 1844 and 1846).
Figure 1: Extract from existing site plan, Farrells, drawing number CON1-PA-03-001 (April 2013).
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Site access
12
Existing access to the site is via an entrance at the junction of Prince Street and New King
Street. In addition, there is a closed access to the site on Grove Street. Evelyn Street (A200) and the
northern end of Deptford High Street are approximately 100 metres to the south, and the proposed
route for Cycle Super Highway 4 (Woolwich to London Bridge, expected to be delivered in 2015)
runs diagonally past the site along Evelyn Street.
13
In terms of public transport services in the area, various bus services (47, 188, 199, N1,
N47) run along Evelyn Street, and one service (199) is routed along Grove Street (although not
adjacent to the site). The nearest mainline rail stations are at Deptford and Greenwich (services
to/from Cannon Street and Charing Cross via London Bridge). Docklands Light Railway services are
available at Greenwich Cutty Sark and Deptford Bridge, and the closest London Underground
services are available at Canada Water and Surrey Quays. Surrey Quays station also offers London
Overground services. Notwithstanding the availability of various transport services in the wider area,
the site currently records a low level of public transport accessibility, registering a score of one to
two, on an accessibility scale where one is lowest and six is highest.
Brief summary of site history
14
The site has a distinguished history, having been established as a Royal Dockyard during the
16th century, and also being the location of Sayes Court Manor and Garden - once occupied by
diarist and horticulturalist John Evelyn. Historical evidence demonstrates that Sayes Court Manor
was demolished and rebuilt as a workhouse (incorporating some of the previous building’s fabric)
around 1759. This workhouse has also been subsequently demolished. The Royal Dockyard evolved
and remained in use until 1869, by which time it had expanded so as to absorb Sayes Court. Shortly
after this date the site was broken up, and following partial operation as a foreign cattle market,
and military use during the First and Second World Wars (where the site sustained notable bomb
damage), the site was sold in two parts in 1979 and 1984 - to be used as an import wharf by News
International PLC.
Heritage asset context
15
As a result of the long and varied history summarised above (and notwithstanding numerous
cycles of demolition and redevelopment which have occurred over this period), there are various
associated heritage assets that remain at the site – albeit as underground archaeological features in
many cases. Accordingly, English Heritage has identified the site as an Area of Archaeological
Priority. This status is reflected through a corresponding designation within Lewisham Council’s
Local Plan.
16
Whilst the Olympia building (Grade II) is the most visible remnant of the former dockyard at
the site, there are various other features which remain above ground including Grade II Listed
fragments of seventeenth and eighteenth century wall along Watergate Street, Grade II Listed
bollard at Watergate Street; Grade II Listed gate piers at Grove Street, and a Grade II Listed section
of river wall. Beneath the ground, dockyard related archaeological features include a Tudor
Storehouse (Scheduled Ancient Monument), Double Dry Dock, five slipways, Dockyard Basin and
mast ponds.
17
With respect to John Evelyn’s legacy at Sayes Court, recent archaeological work has
identified structural remains at the site of the former Sayes Court Manor. However, current
evidence indicates that these remains relate more closely to an eighteenth century workhouse
which was built later at the same site. Notwithstanding this, it appears that materials from the
former Sayes Court Manor were incorporated within this later building - and various bricks dating
from late sixteenth to seventeenth century have subsequently been preserved. An area of tiled floor
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surface (likely to pre-date the eighteenth century workhouse) was also found. In the wider vicinity,
various fragments of wall were located which, based on historical evidence, are likely to be
remnants of those used to enclose Sayes Court Garden. However, no remains of Sayes Court
Garden, as such, have been discovered.
18
There are also various heritage assets in the vicinity of the site, which, in addition to the
Grade II* Master Shipwright’s House (and adjoining former Dockyard Office), include: Grade II
Listed Paynes Wharf, 227 Deptford High Street, Deptford Fire Station and Club Boathouse premises
and foreshore; Grade II* Listed terrace at Albury Street; and, Grade I Listed Church of St. Paul.
19
Whilst the site is not located in or adjacent to any Conservation Areas, there are a number in
the vicinity, including: St. Paul’s Conservation Area; Deptford High Street Conservation; West
Greenwich Conservation Area; and, Greenwich Park Conservation Area. The site does, however, lie
within the wider setting of the Maritime Greenwich World Heritage Site, and falls within panoramic
strategic views towards central London from Greenwich Park and Blackheath Point. Part of the
northwest corner of the site is also over sailed by a protected vista towards St. Paul’s Cathedral
(Grade I).
Other conservation considerations
20
There are a number of trees subject to Tree Preservation Orders at the site, including a
group of mature specimens at the eastern site boundary (adjacent to the Master Shipwright’s
House) and a number of trees located along the south-western boundary (adjacent to Sayes Court
Estate and Sayes Court Park).
Other significant development in the vicinity of the site
21
Just to the east of Convoys Wharf, within the Royal Borough of Greenwich, construction of
257 new homes at Baynes and Borthwick wharves is well advanced. Further to the east, at Deptford
Creek, Creekside Village has 371 homes recently built out (with a further 226 homes permitted in
Lewisham and 204 permitted in Greenwich) and 980 new homes are under construction at
Greenwich Reach. To the west of the site (within the London Borough of Lewisham) development
at Oxestalls Road (also known as The Wharves, Deptford) has planning permission for 905 new
homes. Further west a major site at Plough Way (comprising Marine Wharf West, Marine Wharf
East, Cannon Wharf and sites in Yeoman Street) already benefits from planning permission for
1,244 new homes, some of which has already been implemented. The plot at Marine Wharf East is
subject to a live planning application for an additional 183 homes. At Surry Canal Triangle
permission was granted in 2012 for mixed use development including 2,500 new homes, a sports
village and retention of Millwall Football Club. It is understood the implementation of this
permission will commence next year. There are also significant residential and other developments
underway or consented in the Canada Water area, within the adjoining London Borough of
Southwark.
Details of the proposal
22
The following description of the development incorporates alterations to the application
made following the submission of minor revisions to the Mayor of London on 18 February 2014
and 24 February 2014 (refer to paragraph 50).
23
The application proposes up to 419,100 sq.m. of mixed use redevelopment at the site
comprising:
page 11
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retention and refurbishment of the Olympia building (Grade II) and demolition of all
remaining non-listed structures on site;
up to 321,000 sq.m. residential floorspace (up to 3,500 units) (Use Class C3)
up to 15,500 sq.m. employment floorspace (Class B1/Live/Work units) including up to
2,200 sq.m. for three potential energy centres;
working wharf with associated vessel moorings and up to 32,200 sq.m. of employment
floorspace (Sui Generis and Class B2);
up to 5,810 sq.m. of retail and financial and professional services floorspace
(Classes A1 and A2);
up to 4,520 sq.m. of restaurant/cafe/drinking establishment floorspace (Classes A3 and
A4);
up to 13,000 sq.m. of community/non-residential institution floorspace (Class D1) and
assembly and leisure (Class D2);
up to 27,070 sq.m. of hotel floorspace (Class C1);
river bus jetty and associated structures; and,
1,840 car parking spaces together with vehicular access from New King Street and Grove
Street.
24
As part of related planning obligations it is also proposed to extend the Thames Path
National Trail through the site (securing new riverside pedestrian and cycle links); undertake
improvement works to New King Street/Evelyn Street/Deptford High Street/Watergate Street
junction; route a bus service through the site; deliver a new pier with river bus services; and, provide
a two form entry Primary School.
Figure 2: Extract from key development plot plan, Farrells, drawing number CON1-PA-03-006A (February 2014).
25
The proposal is in the form of an outline masterplan, which prescribes details of the mix of
uses and quantum of floorspace (including the maximum number of residential units); the location
of development plots (including minimum and maximum dimensions and limits of horizontal and
page 12
vertical deviation); the siting (subject to limits of deviation) and massing of the three towers;
vehicular and pedestrian access and egress points to and from the site; the amount and location of
publicly accessible open space; public rights of way and private open space; the maximum number
of car parking spaces, location of on-street parking for public and taxis, bus stop zones and coach
drop-off zones; and, the size and location of the wharf and a river bus facility. Figure 2 above
identifies the key development plots at the site, as defined by the outline masterplan.
Building height strategy
26
The scheme comprises a series of low/medium-rise blocks of between 2 to 10-storeys, a
number of ‘feature buildings’ at approximately 14-storeys, and three high-rise tower elements of
between 38 to 50-storeys (124.55 to 158.95 metres above ordnance datum). The height of
buildings across the masterplan is proposed to be lowest at the interface with existing development
at the landward edges of the site, and generally rises towards the centre. The three tower elements
are proposed to be located at masterplan plots two, six and fourteen, with the tallest of the towers
proposed to be located at the riverfront.
Housing
27
Given that this is an outline application, the proposed housing figures are indicative at this
stage. However, the application would provide for up to 3,500 new homes, 15% of which (525
units) are proposed to be affordable. All dwellings would be built to the ‘Lifetime Homes’ standard,
with 10% to be wheelchair accessible, or easily adaptable for wheelchair users.
Other land uses
28
In addition to the proposed housing within the masterplan, a wide range of non-residential
uses are proposed for the site - totalling 98,100 sq.m. Of this, 47,700 sq.m. would be directly
employment related (15,500 sq.m. for Use Class B1/B2/B8 space (including live/work), and 32,200
sq.m. for wharf uses). The remainder would be hotel space (Use Class C1), retail (Use Classes A1,
A2, A3 and A4) and community and leisure (Use Classes D1 and D2). The application seeks
approval for the location of the uses within development plots, and the maximum quantum, but
does not set a minimum amount of floorspace for any of the uses.
Transport
29
A series of transport improvements are proposed to support the development. In addition to
the provision of key pedestrian, cycle and vehicular access routes through the site (including an
extension of the Thames Path), it is proposed to provide a new river bus pier and contribution
towards river bus services stopping at the site. Contributions are also to be made to divert a bus
service through the site, enhance the capacity of bus services on Evelyn Street and provide a new
bus service. The bus interventions alone are expected to improve the public transport accessibility
level of the site from a score of one to two at present, to three in future (it should be noted that
river bus services are not included in public transport accessibility level calculations). As part of a
package of planning obligations the application also proposes mitigation/enhancements beyond
the site boundary along Evelyn Street (including at the New King Street/Evelyn Street/Deptford
High Street junction); and, to New King Street, which, subject to securing third party land, would
be widened to allow for two way bus movements (as well as enhanced pedestrian and cycle
connections).
30
1,840 car parking spaces are proposed - 1,540 residential spaces (equating to a ratio of 0.44
car parking spaces to units) and 300 non-residential spaces. Disabled parking, electric vehicle
charging points and a car club are also proposed.
page 13
Environmental Impact Assessment
31
The proposal is treated as Environmental Impact Assessment development for the purposes
of the Town and Country Planning (Environmental Impact Assessment) Regulations 2011.
Accordingly, the applicant has submitted an Environmental Statement, which, in conjunction with
other supporting documents (such as the Design Guidelines), identifies the measures necessary to
mitigate the environmental impact of the proposed development.
32
Consideration of the proposed mitigation of environmental issues is set out within the
relevant sections for this report, as necessary. For the avoidance of doubt, all the environmental
information submitted for the purposes of the Town and Country Planning (Environmental Impact
Assessment) Regulations 2011 has been taken into account in the consideration of this application.
Figure 3: Extract from illustrative masterplan ground floor uses plan, Farrells, Design and Access Statement Addendum
(February 2014).
Future detailed design and illustrative masterplan
33
The eventual detailed design of the masterplan would be subject to a number of further
reserved matters planning applications. It is proposed that these future applications would be
page 14
informed by a series of design guidelines which would act in conjunction with parameter plans, and
set out principles for how buildings and spaces should be brought forward at detailed design stage.
34
Notwithstanding the above, the architect has prepared an illustrative materplan to provide
an example of a scheme that could be delivered in accordance with the parameter plans and design
guidelines. This is important in order to establish a representative benchmark for undertaking
various key planning and environmental assessments, but is also particularly helpful in terms of
offering a visualisation of what the scheme could look like, and establishing a general precedent for
overall design quality. Past practice and planning case law has demonstrated that indicative plans
submitted at outline stage are a material consideration when assessing subsequent reserved matters
applications. Figure 3 above presents a visualisation of the illustrative materplan and proposed
ground floor uses.
35
A submitted phasing plan shows that the scheme is proposed to be delivered in three
principal phases. The applicant also states that delivery programme is it estimated to take place over
a fifteen year period.
Relevant planning history
Previous history
36
On 23 October 2002 Lewisham Council received outline planning application DC/02/52533
for comprehensive redevelopment of the Convoys Wharf site to provide up to 447,045 sq.m. of
mixed use development comprising up to: 337,980 sq.m. residential floorspace (up to 3,514 units);
19,100 sq.m. employment space; 32,200 sq.m. working wharf and vessel moorings; 30,000 sq.m.
hotel; 6,400 sq.m. retail; 4,520 sq.m. restaurant/cafes; and, 15,000 sq.m. community/nonresidential institutions, 2,318 car parking spaces, together with vehicular access and a river bus
facility. The application was submitted by News International PLC.
37
The application was formally validated by Lewisham Council on 17 February 2003, and,
following subsequent referral to the Mayor of London, the former Mayor issued initial
representations on the application on 6 August 2003. Having considered GLA report
PDU/0051a/01, the former Mayor indicated his broad support for the application, whilst
identifying a number of issues to be resolved prior to the application being referred back at the
Mayor’s decision making stage.
38
Following a period of negotiation and engagement with both planning authorities, and
other key stakeholders, the applicant submitted additional environmental information in June 2004
and April 2005.
39
On 25 January 2005 the former Mayor considered update GLA report PDU/0051a/02, and
issued further representations stating that the proposed development was acceptable in strategic
planning terms subject to the resolution of a number of outstanding issues, including: further
testing of the affordable housing offer; management of safeguarded wharf area contraction/
release; and, detailed discussions on transport improvements. The former Mayor also expressed the
view that a cruise liner terminal at the site was not considered to be appropriate at that time.
40
On 26 May 2005 Lewisham Council considered the application at a planning committee
meeting and subsequently resolved to grant permission subject to planning conditions, conclusion
of a section 106 legal agreement and referral back to the Mayor of London for his final decision on
the case.
page 15
41
Following Lewisham Council’s resolution, a series of lengthy negotiations took place with a
view to resolving the outstanding issues raised within the former Mayor’s representations on the
scheme. In particular, the GLA sought further information with respect to the case for the proposed
reduction of the safeguarded wharf area at the site.
42
In early 2008 Convoys Investments S.ar.l secured an interest in the site, and in July 2010 an
amendment to application DC/02/52533 was submitted. Following the submission of a number of
further revisions in October 2010, the application was formally referred to the Mayor of London by
Lewisham Council on 23 December 2010.
43
On 2 February 2011 the Mayor considered GLA report PDU/0051a/03 and issued
representations stating that the application did not comply with the London Plan for a number of
reasons with respect to safeguarded wharf; urban design/density/quantum of development; tall
buildings and strategic views; World Heritage Site; inclusive design; climate change and energy;
housing; transport; retail impact; noise and air quality; and, section 106 legal agreement heads of
terms. Notwithstanding this, the Mayor indicated that these strategic planning issues were
potentially capable of being resolved – subject to further work and revisions. Furthermore, the
Mayor’s representations stated that the release of some safeguarded wharf land at the site was
acceptable in principle - given that wharf use across the full safeguarded area at the site would
result in unacceptable impacts on neighbouring residential areas.
44
In July 2011 a further revision to the above application was submitted with the intention of
responding to the strategic issues raised by the Mayor, and a Regulation 19 request for additional
environmental information made by Lewisham Council. This application remains undetermined.
Current scheme
45
On 29 April 2013 Lewisham Council received planning application DC/13/83358 for the
current proposal - which represents a slightly reduced quantum of development and a new
masterplan arrangement, compared to prior application DC/02/52533 discussed above. On 30 May
2013 Lewisham Council formally referred application DC/13/83358 to the Mayor of London under
the following categories of the Schedule to the Mayor of London Order 2008:
 1A 1. “Development which comprises or includes the provision of more than 150 houses,
flats, or houses and flats”;
 1B 1.(c) “Development (other than development which only comprises the provision of
houses, flats, or houses and flats) which comprises or includes the erection of a building or
buildings outside Central London and with a total floorspace of more than 15,000 square
metres”;
 1C 1.(a)(c) “Development which comprises or includes the erection of a building… more
than 25 metres high and is adjacent to the River Thames…” and “more than 30 metres
high and is outside the City of London ”;
 2C 1.(i) “Development to provide… a passenger pier on the River Thames”;
 3B 1.(a)(b) “Development which occupies more than 4 hectares of land which is used for a
use within Class B1 (business), B2 (general industrial) or B8 (storage or distribution) of the
Use Classes Order; and which is likely to prejudice the use of that land for any such use”;
 3E 1.(a)(b)(i, ii, iii, iv, vi, vii, ix and xi) “Development which does not accord with one or
more provisions of the development plan in force in the area in which the application site is
situated; and comprises or includes the provision of more than 2,500 square metres of
floorspace for a use falling within… the following classes in the Use Classes Order – class
A1 (retail); class A2 (financial and professional); class A3 (food and drink); class A4
(drinking establishments); class B1 (business); class B2 (general industry); class C1 (hotels);
and, class D1 (non-residential institutions)”;
page 16
 3F 1. “Development for a use, other than residential use, which includes the provision of
more than 200 car parking spaces in connection with that use”; and,
 4 1. “Development in respect of which the local planning authority is required to consult the
Mayor by virtue of a direction given by the Secretary of State under article 10(3) of the
GDPO”. In this case the local planning authority is required to consult the Mayor because
Convoys Wharf is a safeguarded wharf as identified through a direction by the Secretary of
State.
46
On 10 July 2013 the Mayor considered GLA report PDU/0051c/01 and issued
representations stating that the proposed provision of jobs and homes at this major development
site, which has been vacant for many years, is strongly supported. Notwithstanding this, the Mayor
noted that the application did not fully comply with the London Plan for a number of reasons with
respect to safeguarded wharf; transport; urban design; inclusive access; tall buildings and strategic
views; heritage/cultural uses; World Heritage Site; flood risk; housing; open space/children’s play
space; retail; social infrastructure; and, section 106 legal agreement heads of terms. Nevertheless,
the Mayor indicated that these strategic planning issues were capable of being resolved – subject
to further work, assurances and commitments. Furthermore, the Mayor expressed the view that the
release of safeguarded wharf land at the site was acceptable, subject to necessary assurances, in
line with the emerging principles of the Mayor’s draft Safeguarded Wharves Review (2013).
47
On 17 October 2013, Hutchison Whampoa Properties (Europe) Ltd., on behalf of the
applicant, wrote to the Mayor requesting, pursuant to paragraph 7(6) of the Town and Country
Planning (Mayor of London) Order 2008, that he become the local planning authority for the
purposes of determining this application. On 30 October 2013, the Mayor considered GLA report
D&P/0051c/02, and subsequently concluded that the development would have a significant
impact on the implementation of the London Plan (with respect to polices on Opportunity Areas,
regeneration, housing delivery, employment, safeguarded wharf, heritage, London’s visitor
infrastructure and river passenger facilities), and that there were sound planning reasons for his
intervention. The Mayor also had regard to the extent to which Lewisham Council is achieving, and
has achieved relevant development plan targets. Accordingly, the statutory tests to be applied in
this case have been met, and on 30 October 2013 the Mayor issued a direction under Article 7 of
the aforementioned Order that he will act as the local planning authority for the purposes of
determining this planning application.
48
Since the Mayor issued this direction, GLA officers have undertaken a programme of
regular joint meetings with Lewisham Council planning officers and the applicant team (as well as
various dedicated sessions with local interest groups, statutory consultees and other key
stakeholders) - with a view to resolving the outstanding issues on the case; appropriately securing
local community benefits; and, providing the Mayor with a timely recommendation to consider at a
public Representation Hearing.
49
On 16 January 2014 Lewisham Council’s Strategic Planning Committee considered a report
on the application from its planning officers. The report concluded that Council officers support
the development in principle, but that amendments are sought in a number of areas including
design and heritage; accommodation of community projects; masterplan/design guideline
flexibility; transport; and, community benefits. A number of other detailed clarifications and
commitments were also sought. Having considered the report, along with the various consultation
responses/representations received at that time, the Committee resolved to issue representations
to the Mayor of London setting out the Council’s position on outstanding issues and authorising
Lewisham’s Head of Planning to continue to negotiate with the GLA and applicant with a view to
securing amendments. These representations are summarised in detail in paragraphs 159 to 160.
page 17
50
Following negotiations with GLA officers, the applicant submitted minor revisions on 18
February 2014 and 24 February 2014. The Mayor undertook 21 days of public consultation on
these minor revisions from 26 February 2014 to 20 March 2014. In summary, the revisions result in
the following changes:
 relocation of primary school from plot 17 to be incorporated within plot 16 (with floorspace
subsequently displaced from plot 16 reallocated to other masterplan plots);
 release of plot 17 to open space (creating an uplift in public open space);
 reduction in the building height parameters for the eastern flank of plot 1 (to provide a
maximum five-storey height at the plot’s interface with adjacent public space and the
Master Shipwright’s House (Grade II* Listed));
 minor changes to the mix of affordable housing (to provide an increased provision of
affordable rented units relative to intermediate units, and an increased provision of familysized affordable rented units); and,
 increased flexibility with respect to parameter plans for the three tallest buildings at the site
(to allow for more varied high quality design permutations for these buildings in future, as
part of the wider masterplan).
Relevant legislation, policies and guidance
51
The Mayor must determine the application in accordance with the development plan. He
must have consideration to planning policy and guidance at the national, regional and local levels.
The relevant material planning considerations relate to: principle of development (Opportunity
Area, Strategic Site Allocation, safeguarded wharf contraction/reconfiguration and regenerative
mixed-use development; Safeguarded wharf (including maximising freight use of the Blue Ribbon
Network); mix of uses (including employment, retail and visitor infrastructure); housing (including
affordable housing, residential standards and density); sustainable communities (including social
infrastructure and social inclusion); design (including urban design and heritage); inclusive design;
energy; environmental issues (including noise and vibration, air quality, river and water resources,
biodiversity, artificial light spill, microclimate, communications infrastructure and cumulative
environmental impacts); neighbourhood amenity (including daylight, sunlight, overshadowing, and
privacy/overlooking); transport; and, mitigating the impact of development through planning
obligations. There are also a number of other issues raised through the consultation process
(including the accommodation of community projects at the site). As the proposal will affect Listed
Buildings and their settings, the Mayor must have special regard to the desirability of preserving
the buildings, their settings and any features of special architectural or historic interest which they
possess. Having regard to the above material considerations, the relevant planning policies and
guidance at the national, regional and local levels are as follows:
National planning policy and guidance
52
The National Planning Policy Framework (NPPF) provides the Government’s overarching
planning policy, key to which, is a presumption in favour of sustainable development. The NPPF
defines three dimensions to sustainable development: an economic role contributing to building a
strong, responsive and competitive economy; a social role supporting strong, vibrant and healthy
communities; and, an environmental role contributing to protecting and enhancing our natural,
built and historic environment. The relevant components of the NPPF are:
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Chapter 1.
Chapter 2.
Chapter 4.
Chapter 6.
- Building a strong, competitive economy;
- Ensuring the vitality of town centres;
- Promoting sustainable transport;
- Delivering a wide choice of high quality homes;
page 18
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Chapter 7.
Chapter 8.
Chapter 10.
Chapter 11.
Chapter 12.
- Requiring good design;
- Promoting healthy communities;
- Meeting the challenge of climate change;
- Conserving and enhancing the natural environment; and,
- Conserving and enhancing the historic environment.
53
On 6 March 2014 the Government published new Planning Practice Guidance as part of an
internet-based national guidance resource. The Planning Practice Guidance has superseded and
cancelled various previous circulars, good practice guides and Chief Planning Officer’s letters
(including the 2009 Circular and guidance note on The Protection and Management of World
Heritage Sites). For the avoidance of doubt, the new Planning Practice Guidance has been taken
into account in the assessment of this application.
54
Other relevant national guidance includes:
 Guidance Note: Financial Viability in Planning (RICS, 2012); and,
 Guidance on Tall Buildings (English Heritage and CABE, 2007).
Regional planning policy and guidance
55
The London Plan consolidated with revised minor alterations (October, 2013) is the Spatial
Development Strategy for Greater London. Henceforth this report shall simply refer to this regional
policy document as the ‘London Plan’. The relevant policies within the London Plan are:
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Policy 1.1
Policy 2.9
Policy 2.13
Policy 2.14
Policy 2.15
Policy 3.1
Policy 3.3
Policy 3.4
Policy 3.5
Policy 3.6
Policy 3.7
Policy 3.8
Policy 3.9
Policy 3.10
Policy 3.11
Policy 3.12
Policy 3.13
Policy 3.15
Policy 3.16
Policy 3.17
Policy 3.18
Policy 4.7
Policy 4.12
Policy 5.1
Policy 5.2
Policy 5.3
- Delivering the strategic vision and objectives for London;
- Inner London;
- Opportunity Areas and Intensification Areas;
- Areas for regeneration
- Town centres;
- Ensuring equal life chances for all;
- Increasing housing supply;
- Optimising housing potential;
- Quality and design of housing developments;
- Children and young people’s play and informal recreation facilities;
- Large residential developments;
- Housing choice;
- Mixed and balanced communities;
- Definition of affordable housing;
- Affordable housing targets;
- Negotiating affordable housing;
- Affordable housing thresholds;
- Coordination of housing development and investment;
- Protection and enhancement of social infrastructure;
- Health and social care facilities
- Education facilities;
- Retail and town centre development;
- Improving opportunities for all;
- Climate change mitigation;
- Minimising carbon dioxide emissions;
- Sustainable design and construction;
page 19
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Policy 5.5
Policy 5.6
Policy 5.7
Policy 5.10
Policy 5.11
Policy 5.12
Policy 5.13
Policy 5.15
Policy 5.18
Policy 5.21
Policy 6.1
Policy 6.2
Policy 6.3
Policy 6.5
Policy 6.9
Policy 6.10
Policy 6.11
Policy 6.12
Policy 6.13
Policy 6.14
Policy 7.1
Policy 7.2
Policy 7.3
Policy 7.4
Policy 7.5
Policy 7.6
Policy 7.7
Policy 7.8
Policy 7.9
Policy 7.10
Policy 7.11
Policy 7.12
Policy 7.13
Policy 7.14
Policy 7.15
Policy 7.18
Policy 7.19
Policy 7.21
Policy 7.24
Policy 7.25
Policy 7.26
Policy 7.27
Policy 7.29
Policy 8.2
Policy 8.3
- Decentralised energy networks;
- Decentralised energy in development proposals;
- Renewable energy;
- Urban greening
- Green roofs and development site environs;
- Flood risk management;
- Sustainable drainage;
- Water use and supplies;
- Construction, excavation and demolition waste
- Contaminated land;
- Strategic approach;
- Providing public transport capacity and safeguarding land for transport;
- Assessing effects of development on transport capacity;
- Funding Crossrail and other strategic transport infrastructure;
- Cycling;
- Walking;
- Smoothing traffic flow and congestion;
- Road network capacity;
- Parking;
- Freight;
- Building London’s neighbourhoods and communities;
- An inclusive environment;
- Designing out crime;
- Local character;
- Public realm;
- Architecture;
- Location and design of tall and large buildings;
- Heritage assets and archaeology;
- Heritage-led regeneration;
- World Heritage Sites;
- London View Management Framework;
- Implementing the London View Management Framework;
- Safety, security and resilience to emergency;
- Improving air quality;
- Reducing noise and enhancing soundscapes;
- Protecting local open space and addressing deficiency;
- Biodiversity and access to nature;
- Trees and woodland;
- Blue Ribbon Network;
- Increasing use of the Blue Ribbon Network for passengers and tourism;
- Increasing use of the Blue Ribbon Network for freight transport;
- Blue Ribbon Network: supporting infrastructure and recreational use;
- The River Thames;
- Planning obligations; and,
- Community infrastructure levy.
56
On 15 January 2014 the Mayor published draft Further Alterations to the London
Plan. These further alterations are out for public consultation until 10 April 2014.
page 20
57
The following supplementary planning guidance (SPG) documents and implementation
reports published by the Mayor are also relevant:
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Use of planning obligations in the funding of Crossrail, and the Mayoral Community
Infrastructure Levy SPG (2013);
Housing SPG (2012);
Land for Industry and Transport SPG (2012);
Shaping neighbourhoods: play and informal recreation SPG (2012);
London View Management Framework SPG (2012);
London World Heritage Sites - Guidance on Settings (2012);
Planning for equality and diversity in London SPG (2007);
Sustainable design and construction SPG (2006);
Safeguarded Wharves on the River Thames: London Plan Implementation Report (2005);
and,
Accessible London: achieving an inclusive environment (2004).
58
The following emerging draft SPG documents and draft implementation reports are also
relevant:
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Safeguarded Wharf Review (Final Recommendation to the Secretary of State);
Shaping Neighbourhoods: character and context SPG (public consultation draft); and,
Draft Sustainable design and construction SPG (public consultation draft).
Mayoral Community Infrastructure Levy
59
The Mayor has introduced a London-wide community infrastructure levy (CIL) to help
implement the London Plan, particularly policies 6.5 and 8.3. The Mayoral CIL formally came into
effect on 1 April 2012, and it will be paid on commencement of most new development in Greater
London granted planning permission on or after that date. The Mayor's CIL will contribute towards the
funding of Crossrail.
60
The Mayor has arranged boroughs into three charging bands. The rate for Lewisham is £35
per sq.m. The required CIL charge will be confirmed once the components of the development, or
phase thereof, have themselves been finalised.
61
London borough councils are also able to introduce CIL charges which are payable in
addition to the Mayor’s CIL. The status of Lewisham’s emerging CIL is discussed below.
Local planning policy
62
The adopted Lewisham Core Strategy (2011) forms a key part of Lewisham’s Local Plan and
provides the overarching local policy approach for the Borough. The relevant policies within the
Lewisham Core Strategy are:
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Spatial Policy 1
Spatial Policy 2
Core Strategy Policy 10
Core Strategy Policy 12
Core Strategy Policy 14
Core Strategy Policy 15
Core Strategy Policy 18
- Lewisham Spatial Strategy;
- Regeneration and Growth Areas;
- Managing and reducing the risk of flooding;
- Open space and environmental assets;
- Sustainable movement and transport;
- High quality design for Lewisham;
- The location and design of tall buildings;
page 21
 Core Strategy Policy 19
- Provision and maintenance of community and recreational
facilities;
 Strategic Site Allocation 1 - Requirements for strategic site allocations; and,
 Strategic Site Allocation 2 - Convoys Wharf.
63
The 2004 Lewisham Unitary Development Plan (UDP) is gradually being replaced by the
Lewisham Local Plan, however, a number of saved policies are still in effect. The relevant saved
UDP policies are:
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STR URB 1
STR URB 4
URB 1
URB 3
HSG 4
HSG 5
LCE 1
- The Built Environment;
- Regeneration Areas;
- Development Sites and Key Development Sites;
- Urban Design;
- Residential Amenity;
- Layout and Design of New Residential Development; and,
- Location of New and Improved Leisure, Community and
Education Facilities.
64
Also relevant is the 2004 Lewisham UDP Proposals Map (consolidated with subsequent
changes), which identifies that the site falls within the following spatial designations: Area of
Archaeological Priority; Thames Policy Area; Protected Vista: Landmark Viewing Corridor and Wider
Setting Consultation Area; Site of Importance for nature Conservation; and, Area of Special
Character.
65
The following local supplementary planning documents (SPD) published by Lewisham
Council are also relevant:
 Residential development standards SPD (2012); and,
 Planning Obligations SPD (2011).
66
The emerging Lewisham Development Management Local Plan is also a material
consideration. Lewisham Council consulted on the proposed submission version of this document
between 16 August 2013 and 4 October 2013. The Mayor’s view on the draft Development
Management Local Plan, expressed on 9 October 2013, is that whilst the document contains many
positive aspects, the proposed plan is not in general conformity with the London Plan with respect
to affordable housing – DM Policy 7. Since the Mayor expressed this view GLA officers have
engaged in further discussions with the Council, however, as set out in the GLA’s letter of 3
February 2014 this issue is still outstanding. This matter was subsequently considered in detail at a
public examination between 26 and 27 February 2014, and in due course the Planning Inspectorate
will make its report to Lewisham Council, setting out whether the plan is sound. The Inspectorate
may also make recommendations for changes. Once adopted, the plan will provide the detailed
policies for development management within the borough. Having regard to the above, the
relevant emerging policies in this case are:

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DM Policy 1
DM Policy 9
DM Policy 29
DM Policy 27
DM Policy 30
- Presumption in favour of sustainable development;
- Mixed use employment locations;
- Car parking;
- Lighting;
- Urban design and local character (General Principles, Detailed Design
Issues);
 DM Policy 32 - Housing design, layout and space standards (Siting and layout of
development, Internal standards);
page 22
 DM Policy 35 - Public realm; and,
 DM Policy 43 - Art, culture and entertainment facilities.
Lewisham Community Infrastructure Levy
67
London borough councils are able to introduce Community Infrastructure Levy (CIL)
charges which are payable in addition to the Mayor’s CIL. Lewisham Council has yet to adopt a
scheme, but submitted its draft charging schedule to the Planning Inspectorate in August 2013.
Following receipt of the Inspector’s report, the Council expects to adopt the scheme from 1
October 2014.
Response to consultation
68
As part of the planning process Lewisham Council carried out a round of extensive public
consultation on the application from 25 May 2013 to 1 July 2013. As discussed in paragraph 50
above, the Mayor of London undertook a further round of public consultation on a number of
minor revisions to the application from 26 February 2014 to 20 March 2014.
69
For both rounds of consultation the application was publicised by sending notifications to
all relevant statutory bodies, as well as 9,606 addresses in the vicinity of the site (9,225 residential
addresses and 381 business addresses). Site notices were also displayed, and the application has
been advertised and consulted upon in accordance with the requirements of the Town and Country
Planning (Environmental Impact Assessment) Regulations 2011.
70
All responses to the local consultation process, and any other representations received by
Lewisham Council, the GLA and/or the Mayor of London, have been made available to the Mayor.
All consultation responses and representations received in respect of this application at the time of
writing this report are set out below. Whilst the comments received have been made available to
the Mayor in their original form, in the interests of conciseness, and for ease of reference within
this report, the issues raised are summarised.
Responses from statutory consultees
Mayor of London (including Greater London Authority and Transport for London)
71
The Mayor’s initial representations stated that the application is supported as delivering a
major boost to jobs, growth and housing delivery in London through development of this strategic
and long vacant site. Notwithstanding this, the Mayor identified a number of issues that needed to
be resolved in order to ensure compliance with the London Plan. The conclusion of the Mayor’s
initial representations were as follows:
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


Land use principle: The principle of development is strongly supported and the proposed
mix of uses broadly accords with London Plan policies.
Regeneration/employment: This large brownfield site that has been hugely under-used for
over 10 years will deliver much needed regeneration and significant employment
opportunities to Deptford and the wider area.
Transport: Further modelling work is sought by TfL, and various detailed transport issues
still need to be resolved.
Safeguarded wharf: The proposal to reduce the wharf to an area of 2.3ha of land (plus a 0.3
hectare jetty) is acceptable in principle provided that the section 106 agreement is amended
to include provision for best endeavours to accommodate temporary uses not associated
with the development construction from phase one. Options to include the Lenox project
should be further explored.
page 23
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
Urban design: Considerable further work has been undertaken since the previous planning
application. This has indicated both a willingness and ability of the applicant to address a
number of the design challenges of the site, particularly in relation to how the site
integrates with surrounding development. The Sayes Court Park link should be reconsidered to be a minimum width of 35 metres. The current scheme demonstrates that the
density of development can be accommodated on this site but it will require strict control at
detailed planning application stages.
Inclusive design: Further information is sought to ensure that future detailed applications
will meet London Plan requirements, particularly in relation to the accessibility of the 2storey podium levels.
Tall buildings/strategic views: The views assessment demonstrates that the tall buildings are
outside view management corridor 5A.2. Strict controls will be required at the detailed
planning application stage to ensure that the tall buildings are designed to the required
high specification.
Heritage/cultural uses: The re-use of the Olympia building for cultural use is welcomed,
although more detail on the proposed use should come forward as a matter of urgency. The
inclusion of the Lenox project within the site, at least during the construction phases would
be welcomed.
World Heritage Site: Although it is acknowledged that the site is in the setting of the
Maritime Greenwich World Heritage Site, there is no explicit assessment of the impact on
the outstanding universal value of the World Heritage Site.
Climate change/energy: The scenario one strategy of a connection to SELCHP is supported
and in line with London Plan policy.
Blue Ribbon Network: The proposals are broadly in line with the London Plan.
Flood risk: The flood risk assessment demonstrates general compliance with London Plan
Policy 5.12, but the diversion of more of the surface water directly to the River Thames
would be beneficial and could reduce development costs by avoiding the need for large
attenuation tanks.
Housing: The proposals will make a sizeable and valuable addition to housing provision in
south east London. The level of affordable housing (15%) is low and the mix of units is not
in line with London Plan policy, but may be accepted for this site subject to viability testing
and a suitable review mechanism.
Open space/children’s play space: There is an absence of detail although the illustrative
masterplan diagram would suggest that the proposal can make a valuable contribution to
public space in this part of London.
Retail impact: Whilst there are some concerns about the impact of the scheme, particularly
on Deptford High Street, the provisions within the section 106 heads of terms are
considered to provide reasonable protection.
Noise/air quality: The detailed planning application stage will deal with these issues and
particular attention will need to be paid to residential uses near to and overlooking the
wharf.
Crossrail/Mayoral CIL: The applicant needs to confirm the appropriate payment.
Social infrastructure: The application is broadly supported for its contribution to social
infrastructure on the site, although clarification relating to secondary and post 16 education
commitments is sought.
Section 106 agreement: Given the outline nature of the planning application and the large
and complex nature of the development, further tightening of the heads of terms are
required to ensure that detailed planning applications can be appropriately managed.
72
The Mayor stated that the resolution of the above issues could lead to the application
becoming compliant with the London Plan.
page 24
Mayor of London (decision following request to become the local planning authority)
73
Having received a request from the applicant to become the local planning authority
pursuant to article 7 of the Town and Country Planning (Mayor of London) Order 2008, the Mayor
stated that having regard to the details of the application, representations from Lewisham Council,
and GLA officers report - the proposed development has a significant impact on the
implementation of the London Plan (with respect to policy on Opportunity Areas, regeneration,
housing, employment, safeguarded wharf, heritage, visitor infrastructure and river passenger
facilities), and there are sound planning reasons for the Mayor to intervene in this particular case
and become the local planning authority for the purposes of determining the application.
English Heritage
74
English Heritage has made a number of comments on the application (and associated
archaeological reports), and has been actively engaged with both Lewisham Council and the GLA as
part of officer-level discussions and dedicated design and heritage meetings. Below is a summary
of the key responses and recommendations that English Heritage has made with respect to
archaeology and historic buildings.
English Heritage archaeology advice
75
The archaeological fieldwork completed at the site to date is the largest archaeological
investigation of an historic dockyard in the world. Whilst the undertaking of this work befits the
importance of this site, the applicant should be commended for having committed to such a large
scale of works at pre-planning stage.
76
Having regard to Chapter 5 of the Environmental Statement, the ramification of proposed
areas of build for possible inclusion of semi-basements cannot be considered in detail until full
reports have been reviewed. However, it is recommended that the proposed inclusion of semibasements in some areas of the site is supported in principle. Preservation by record is proposed for
deemed local and regionally important archaeology. It would be appropriate that such deemed
evidence is considered on its merits for preservation in situ.
77
The Heritage Statement review includes consideration of the River Wall as a key element but
not the Smithery, Officers Quarters or the Navy Treasurer’s House. The recent archaeological
fieldwork has identified Tudor remains extending to the north-western edge of the complex and
this is not reflected on the plan. Section 6.2 of the Heritage Statement identifies the historic and
archaeological considerations to be woven into the masterplan in respect of reuse, display,
inspiration and remembrance while at the same time permitting the site’s heritage to inform the
character of the new development. It is recommended that this approach is followed through and
fully reflected in the Design Guidelines.
78
With respect to the Design Guidelines, it is recommended that section 2.0.7 includes
consideration of using distinctive materials and design to reflect the Sayes Court area, and a
different palette for the dockyard area. The list of key heritage assets is presented, but when
consideration is given to specific areas of the site the historic starting point is often not considered.
With the exception of the Basin and Double Dry Dock, consideration is largely focussed upon the
Listed components and their setting that have to be accommodated. The Storehouse Scheduled
Ancient Monument appears not to be an element used as a ‘design springboard’. The eight
overarching design principles listed in section 2.0.9 do not include a consideration of the history of
the site as an objective. This would appear to be at odds with the expectation of heritage being a
core element of the design approach alluded to in the Heritage Statement. In Section 3.5 the
‘Evelyn Quarter’ includes in the objectives the creation of a centre to display and interpret the
page 25
Sayes Court building remains but this inclusion is not used as a design starting point to provide a
distinctive character for this quarter.
79
With respect to the Design and Access Statement, it would be helpful to identify the
significant dockyard features proposed for removal so that their location and dimensions can be
used to inform the next stage of the design process i.e. by them being reflected within the shape
and location of the new buildings and spaces. Section 2.4.3.15 lists the belowground archaeological
constraints. This list does not appear to include the Georgian River Wall, Officers Quarters,
Smithery, the Navy Treasurer’s House or the Georgian Storehouse. It is recommended that serious
consideration should be given to the retention of the sixteenth and seventeenth remains of the
Navy Treasurer’s House. The proposed use of the connecting canal between river and Basin is
welcomed. It is unfortunate that at present the corners of building blocks P02 and P06 impinge
upon the Basin space, with the block form of the development overriding the major historic element
that makes sense of the Olympia building. It is recommended that the relationship between building
blocks P02 and P06 and the Basin are considered further. The minimum proposed dimension and
positioning of building block P01 just includes the designated area of the Tudor Storehouse.
However, the recent archaeological fieldwork has identified additional Tudor remains to the
immediate west of the designated area and in the area of proposed build. It is recommended that
the relationship between building block P01 and the Scheduled Ancient Monument are considered
further.
80
The explanation of the masterplan process does not appear to include bringing forward the
range of heritage assets, whether for retention or for excavation, that are worthy of reflection in the
emerging design. It is recommended the memory of historic place needs reflecting more strongly in
the emerging design.
81
The position and orientation of the Sayes Court sequence of building and associated space
is lost within the proposed arrangement of roads and building blocks. Also the inclusion of a
‘garden city’ green strip along the centre of one of the routes in this area as the main landscape
reflection of the John Evelyn legacy is, on its own, a disappointment. It is recommended that the
configuration of building blocks P15 and P16 should be reconsidered given that the footprint of
the Sayes Court building evidence is currently proposed to be partly within P16 and partly under
the roadway. Reconfiguration of these two blocks would also enable the building to be associated
with open space. This immediate area of the site should take the historic orientation as its lead.
82
With respect to the Scheme of Archaeological Resource Management (SARM) document, it
is recommended that the framework it represents is secured by condition. In addition to the SARM,
it is additionally recommended that public realm considerations are addressed as part of the section
106 agreement. This would include identification of the range of elements to best reflect the
former historic environment within the site. It is recommended that if planning permission is to be
granted that the historic environment interest be secured by appending a series of conditions.
83
Following the resolution of a number of matters, the third (and latest) draft of the postexcavation archaeological assessment is recommended for approval.
English Heritage historic buildings and places advice
84
English Heritage recognises the significant economic benefits of bringing the Convoys
Wharf site back into comprehensive use, and the wider cultural benefits that access and
enhancement of the riverfront and heritage assets can bring. Positive design work on the
masterplan to better reflect and enhance historic riverfront features (including the Double Dry
Dock, Great Basin, Slips, and Riverwall) is also welcomed. The landscaped pier is also an attractive
page 26
feature of the scheme. English Heritage expects future detailed proposals to further develop this
approach to the underlying history, and to enhance the surviving historic elements.
85
English Heritage nevertheless expresses concern that the overall scale of development is
such that the opportunity to create a distinctive sense of place which responds to the outstanding
historic legacy of the site has not been realised. With respect to the reuse and the setting of the
Olympia building, the proposals to better link the building to the Great Basin are identified as
positive, as is the revised orientation of the masterplan – which now provides greater flexibility of
public space for potential uses. However, concern remains that the proximity and massing of the
feature buildings and 14-storey riverside block create a dominating scale around the Listed
building. This is accentuated by the close proximity of blocks P06 and P08. As the vision for
Olympia Square is to be the heart of the community, with the Olympia building at its centre, it is
essential that this is a generous active and inviting space, making the most of its links to the river.
The narrow glimpsed view fails to make the best opportunity of this prominent and centrally located
heritage asset. English Heritage acknowledge that the extent of visual connection to the river has
varied since the construction of the Olympia building, however, historically the current proposal
would appear to represent the most restricted view.
86
In the event of the local planning authority being minded to grant permission, English
Heritage recommend that planning conditions securing a full condition survey and options appraisal
(identifying the significance of the component elements of the asset and its setting, and informing
its proposed use) are imposed. It is also recommended that such work is tied to being completed at
an early stage of the first phase, and prior to the occupation of the residential units.
87
English Heritage also expresses the opinion that the cumulative impact of the three tall
buildings within the proposal is at odds with part D.(a) of London Plan Policy 7.12 which states that
panoramas should be managed so that development fits within the prevailing pattern of building
and spaces and should avoid a canyon effect on strategically important landmarks. English Heritage
states that the impact of the three towers within the Blackheath Point and Greenwich panoramic
views is dramatic and contributes towards a potential canyon effect. It was also noted that the
accompanying Townscape Assessment assumes that the towers will have an elegant wellproportioned silhouette which will contribute beneficially to the skyline. However, given that this is
an outline application, English Heritage seek further design assurances to ensure that the taller
elements are elegant structures which minimise the impact within the affected panoramas and on
the setting of the heritage assets.
88
English Heritage notes that public realm works across the site will be critical in ensuring that
the underlying history is legible. Whilst the associated proposals within the masterplan are identified
as positive, further design development work is sought for way-finding, interpretation and
enhancement of specific features (including the River Wall, Double Dry Dock) and works to
boundary walls etc. It is also suggested that further consideration be given to the design and
associated landscaping of the school - to reflect the location of the former Sayes Court Garden and
the proposed Sayes Court interpretation centre – so that the historic relationship between these
spaces is better reflected.
89
Whilst acknowledging the design work that has been undertaken since the previous
application, English Heritage still has concerns that the overall scale of the scheme (including the
tall buildings) will cause harm to the significance of designated and non-designated heritage assets.
Accordingly, further assurances are sought to ensure that a scheme that reflects local character
would be successfully delivered.
90
In the event that the local planning authority is minded to grant outline permission, English
Heritage recommends that consideration is given to ensuring that potential benefits of the scheme
page 27
are delivered, and that the design, materials, and appearance of the scheme reflect the local historic
context.
English Heritage historic buildings and places advice in response to submission of revised plans
91
English Heritage welcomed the revisions to the masterplan, and expressed the view that
changes to the minimum parameters for the tall buildings, the reduction of height at plot one, were
beneficial. However, English Heritage also sought additional flexibility within the Design Guidelines
document – particularly with respect to prescription for tall building design.
92
The provision of greater public space at plot seventeen was also supported, and English
Heritage noted that this would provide an improved relationship with the Sayes Court remains and
its former garden. However, with reference to the Sayes Court Garden community project, English
Heritage sought a relaxation of the minimum parameter at plot sixteen in order to allow further
design exploration at reserved matters stage, and to give greater opportunity to develop a
horticultural programme which is both viable and better reflects the historic significance of the site.
93
With respect to the Olympia building, English Heritage reiterated that it sought an options
appraisal for the future use of the Listed Building, and stated that an understanding of significance
should inform emerging proposals. English Heritage also expressed the viewed that the Lenox
Project presents an attractive and compelling vision, which would enhance and offer a potential use
for the Olympia Building. It was recommend that the option for building the Lenox at Olympia is
fully explored as part of proposals to bring the Listed Building into long term sustainable use. A
feasibility study for the Lenox Project within the Olympia building was identified as key to this.
94
The Mayor is advised that the issues raised by English Heritage are considered in the design
and community projects sections of this report. Corresponding conditions are also proposed to be
secured accordingly (including a Conservation Management Plan to secure the protection and
timely restoration of Olympia).
Environment Agency
95
The Environment Agency raised no objection to the application, but sought a number of
detailed clarifications and commitments. Various technical advice and guidance was also provided.
A summary is provided below.
96
The proposal to raise ground levels to mitigate flood risk is supported. The Flood Risk
Assessment states that a further 500 m.m. of level raising will be accommodated in addition to the
proposed ground level of 5.7 metres above ordnance datum. The Environment Agency expects
details of how this would be achieved to be set out at reserved matters stage. It was noted that
adjacent and nearby sites might not offer the same resistance to breach, and the floor levels of
more vulnerable accommodation should be set accordingly. Any detailed application should set
floor levels based on the most relevant and up to date breach information available at the time.
97
It was noted that commercial uses have been proposed on masterplan plot 22 (the jetty),
which is located within the river channel, and classed as Flood Zone 3b. In accordance with tables 1,
2 and 3 of the Technical Guidance to the NPPF, such uses are not acceptable, and should not be
permitted in this location.
98
The submitted flood risk assessment does not refer to the proposed new jetty. The
Environment Agency seeks hydrodynamic modelling to understand what impacts the new jetty may
have on river hydrology (and how this may alter existing scour and deposition characteristics).
page 28
Where additional erosive action at the foreshore would undermine and/or expose the footings of
tidal flood defences, or adversely impact on ecology, appropriate mitigation will be necessary.
99
Whilst the Environment Agency noted that the Blue Ribbon Network policies of the London
Plan seek to ensure that structures in the River Thames are utilised for river dependent uses, it was
acknowledged that the local planning authority will come to its own view on whether the proposed
provision of public open space on the jetty complies with the London Plan. Additional biodiversity
enhancements to the jetty structure were nevertheless sought, to maximise ecological benefit.
100 The Environment Agency is of the view that a detailed engineering assessment of works to
flood defences should be provided to ensure the right level of safety for the users of the
development. The statutory flood defence level of 5.23 metres (above ordnance datum) should be
maintained throughout development. For a development of this size, it is also recommended that
flood defence is designed (and raised) to year 2100 levels at the time of construction. Confirmation
of the distances between buildings and flood defences is also sought, to ensure clear access for
inspection and repair of flood defences.
101 The Flood Risk Assessment contains various approaches for managing the drainage of
surface water (these include use of a pump system to overcome tidelocking, and/or attenuation of
surface water on site until such time as it is able to discharge by gravity). The Environment Agency
stated that it recommends passive drainage measures. The commitment to incorporate sustainable
urban drainage systems at the site in order to enhance attenuation characteristics was supported,
and the Environment Agency stated that the surface water drainage scheme should aim to achieve
greenfield run-off rates.
102 The Environment Agency stated that it was unclear how a proposed tidal inlet feature would
contribute to the nature conservation value of the site. Accordingly, a commitment was sought that
this feature will be designed in a way which would offer biodiversity enhancements.
103 With respect to matters of waste handling, the Environment Agency stated that it must be
notified immediately of any incident likely to cause pollution. Waste from the development must be
re-used, re-cycled or otherwise disposed of in accordance with Environmental Protection Act 1990,
and the Duty of Care. Details of the proposed waste handling strategy should be provided. All areas
where waste is to be stored, handled or transferred shall be underlain by impervious hard-standing,
with dedicated drainage to foul sewer or sealed tank to prevent pollution of the water environment.
104 There is potential for demolition waste to be contaminated and hazardous. Therefore, the
site should be registered as a hazardous waste producer for the duration of associated works.
Identifying a quarantine area is good practice for the stockpiling of hazardous or suspected
hazardous demolition waste. The applicant should also prepare an incident management plan and a
site waste management plan. These plans should be reviewed and updated through the course of
the project.
Environment Agency update following response by the applicant
105 Having considered the applicant’s response to the matters raised above, and further to the
Mayor’s decision to act as the local planning authority, the Environment Agency provided an
updated position. The response generally welcomed clarifications and various additional
commitments provided by the applicant. However, the Environment Agency reiterated that the
inclusion of non-river related uses on the jetty (masterplan plot 22) was contrary to various NPPF
and London Plan policies which promote the use of such structures for river activities (GLA officers
consider this issue in the design section of this report). With respect to the other matters raised, the
Environment Agency stated that the associated issues could be appropriately dealt with through the
page 29
inclusion of various planning conditions with respect to: flood risk management; fisheries and
biodiversity; flood defences; groundwater and land contamination; and, general guidance/good
practice. The Mayor is advised that corresponding conditions are proposed to be secured
accordingly.
Natural England
106
Natural England raised no objection to the application, but sought the inclusion of a
planning condition to ensure the adequate protection of bats, and the incorporation of enhanced
green infrastructure. The local planning authority was also advised to consider securing other
measures to enhance biodiversity. The Mayor is advised that an Ecological Management Strategy
(to include measures for bat protection) is proposed to be secured by way of condition accordingly.
Furthermore, consideration of measures to enhance biodiversity at the site is set out within the
environmental issues section of this report.
Responses from other consultees
Port of London Authority (PLA)
107 The PLA provided a number of detailed comments and identified the need for various
clarifications and commitments to be suitably secured. Whilst broad support was indicated for the
scheme in principle, the PLA concluded that, given current uncertainties and concerns (with respect
to the wharf element in particular), it must object to the application at this point in time. The PLA
nevertheless stated that it would welcome the opportunity to engage further, and to provide
further comments following the receipt of any additional information, commitments and
amendments. A summary is provided below.
108 The PLA confirmed that the proposed reduction in the physical extent of the wharf area,
and its relocation to the northern end of the site, has been agreed in principle. The PLA also
welcomed confirmation within the Marine Terminal Assessment, that at least five metres of water
would be available at the proposed jetty at all states of the tide. However, the PLA expressed the
view that the proposed shape and dimensions of the wharf do not appear to be ideal.
109 The PLA seeks to ensure that all of the identified wharf area is useable for cargo-handling
operations. Given the shape of the wharf area, the PLA indicated that this is likely to be challenging
if there are to be multiple occupiers. The principle of enabling cargo-handling operations for
multiple occupiers is also relevant to considerations about jetty design and location.
110 In terms of the outline development specification for the wharf, the PLA expressed concern
that the quantum of floorspace proposed at plot 21 (up to 32,200 sq.m., Class B2) may prejudice
the viability of the site as a working wharf. The PLA also sought the removal of a proposed public
access across the centre of the site (which could have implications for cargo handling operations).
Furthermore, the PLA stated that the layout of the wharf (including the various outline
development parcels) and supporting infrastructure should not be designed in the absence of any
operator(s), and should be planned in consultation with the PLA. The PLA also stated that at this
stage there appears to be little evidence to demonstrate that the interface between the wharf
activities and adjacent development parcels could be appropriately and successfully
managed/mitigated.
111 The PLA stated that the proposed location of the new river bus pier is acceptable subject to
the completion of a navigational safety risk assessment, and the removal of the existing roll on/roll
off jetty infrastructure. It was nevertheless recommended that the provision of this facility during
page 30
phase one is secured as part of the section 106 legal agreement. The PLA also seeks further
discussion with respect to the nature and location of vessel moorings proposed at the site.
112 The PLA nevertheless remains to be convinced by the conclusions of the Marine Terminal
Assessment in relation to the proposed volumes of cargo per annum, and the strategy for activation
during the construction phase for ‘scenario one’. In essence, the PLA considers that the wharf could
handle significantly more than the proposed 89,200 tonnes of cargo per annum during the scheme
construction stage.
113 Accordingly, the PLA seeks clarification of the phasing and time period for the use of the
wharf in connection with the construction activities, and a greater commitment to utilising the river
for the transport of construction materials to and waste materials from the site during this period.
The PLA stated that such a commitment should include greater volumes and types of materials than
those currently specified, and that this arrangement should be captured as part of any section 106
legal agreement.
114 Notwithstanding the above, the PLA notes that the proposed approach within the Marine
Terminal Assessment report appears to favour ‘scenario two’, where the wharf would initially be
used for both construction activities and other cargo-handling uses simultaneously. The PLA does
not object to this in principle, however, further information is sought to demonstrate how these
arrangements would work in practice. Where such an approach would be feasible and can be
agreed, it should be secured within the section 106 legal agreement.
115 In addition to securing the abovementioned interim wharf uses, the PLA seeks suitably
worded clauses within the section 106 legal agreement to ensure that a permanent wharf is
provided and operational prior to the commencement of development phase three.
116 With respect to the option for accommodating temporary shipbuilding at the wharf in order
to facilitate a heritage-led community project (Build the Lenox), the PLA stated that it was
supportive of the project in principle, but does not view the project as an appropriate use of the
wharf. Accordingly, the applicant was advised to demonstrate that this project could not be located
elsewhere on the site, before any further detailed consideration was given to the use of the wharf.
The PLA further stated that such a use of the site should not prejudice waterborne cargo handling
operations.
117 In response to the submission of revised plans, the PLA confirmed that the above comments
remain relevant. Notwithstanding this, the PLA stated that the Thames Path connection across the
wharf would need to be carefully designed at reserved matters stage to ensure that public access
would not interfere with waterborne cargo handling operations. Accordingly, a condition was
sought to secure the submission and approval of detailed plans. The PLA also expressed
disappointment that a public right of way is still proposed across the centre of the wharf, and
queried whether the River Thames would be used for construction logistics during delivery phase
three. The PLA confirmed that at this time it is unable to withdraw its objection to the application.
118 The Mayor is advised that approval of detailed plans for the Thames Path are proposed to
be secured by way of planning condition, and that the timely delivery of the riverbus pier (linked to
an appropriate trigger point of customer demand) is proposed to be secured within the section 106
agreement. The other issues raised by the PLA are considered within the safeguarded wharf, design
and transport sections of this report.
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Thames Water
119 Thames Water did not raise an objection to the application, but provided a number of
detailed comments and identified the need for various commitments to be suitably secured. A
summary is provided below.
120 Thames Water stated that it is the responsibility of a developer to make proper provision for
drainage to ground, water courses or a suitable sewer. However, based on the information currently
provided, it has not yet been possible for Thames Water to determine the waste water infrastructure
needs of the scheme. Accordingly, a drainage strategy is sought by way of planning condition.
Thames Water stated that this strategy should set out the proposed points of connection to the
public sewerage system, as well as the anticipated flow.
121 Thames Water stated that existing water supply infrastructure in the area has insufficient
capacity to meet the additional demand of the proposed development. Accordingly, a supply
infrastructure impact study is sought to be secured by planning condition - to determine the
additional capacity and/or connectivity required.
122 Thames Water also sought the inclusion of a planning condition to control impact piling.
The Mayor is advised that corresponding conditions are proposed to be secured accordingly.
Southern Gas Networks
123 Southern Gas Networks did not raise an objection to the application, but identified the
presence of its gas main in the proximity of the site. Accordingly Southern Gas Networks
recommended that safe digging practices be used in accordance with Health and Safety Executive
guidance. The Mayor is advised that the relevant advice has been passed on to the applicant, and
that a corresponding informative is proposed to be included on the decision notice.
London City Airport
124 London City Airport did not raise an objection to the application, but provided a number of
detailed comments and identified the need for future consultation/engagement with respect to
airport safeguarding criteria. A summary is provided below.
125 The applicant should provide a construction programme and methodology for safeguarding
approval by London City Airport prior to the commencement of works on-site.
126 Given the proximity of the site to the airfield, any changes to the height or location of the
development should be submitted to London City Airport for re-assessment. The applicant is
advised of the need to give careful consideration to construction methodology for the tallest block
at masterplan plot two (158.95 metres above ordnance datum), because additional height
associated with carnage or scaffolding would significantly infringe safety limits, and, therefore,
would not be acceptable to the airport. The Mayor is advised that a corresponding condition and
informative are proposed to be included on the decision notice accordingly.
Metropolitan Police
127 The Metropolitan Police did not raise an objection to the application, but, sought a planning
condition to ensure that the development would achieve Secured by Design accreditation. It was
also recommended that a CCTV and lighting strategy is developed in conjunction with Lewisham
Council. The Mayor is advised that a corresponding condition is proposed to be secured
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accordingly, and that details of CCTV and lighting will be developed in due course, as part of future
reserved matters applications.
London and Middlesex Archaeological Society (on behalf of Council for British Archaeology)
128 The London and Middlesex Archaeological Society (LAMAS) noted that the scheme tries to
address some of the heritage concerns previously raised. However, LAMAS expressed the view that
the masterplan was only partially successful in this regard - primarily because the proposed
quantum of floorspace remains very much the same as in earlier applications. LAMAS stated that
further changes were needed in order to achieve a balance between the site’s heritage value and
development potential, and that currently the proposed development of the site was at the expense
of proper historic appreciation. Accordingly, LAMAS expressed the view that the proposed
masterplan was unacceptable.
129 As part of a detailed set representations, LAMAS queried whether an outline application was
appropriate for such a complex site, and expressed the view that a greater reflection of the scale
and relationship between the component parts of the historic dockyard was required as part of
connectivity strategy for the site. LAMAS stated that a failure to express more of the historic basin
would be harmful to the setting of Olympia (Grade II), and also questioned the role of tall buildings
within the scheme – stating that these were likely to be seriously detrimental to an understanding
of various on-site heritage assets and their settings.
130 LAMAS also identified three particular issues which it felt required further detailed
consideration:
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The working wharf – the potential for conflicts between wharf operations and pedestrian
access along the river is an issue which remains un-resolved. This access will need to be
designed carefully - having regard to best practice examples.
Archaeology – a better understanding of the archaeology at the site is required. This should
inform the development layout and the landscaping proposals.
Landscaping – the landscaping of spaces, docks and the pier needs to be revised to give a
better appreciation of heritage assets, and to define routes between them.
131 LAMAS expressed the view that the proposed scale of the development makes achieving an
acceptable scheme highly challenging. Nevertheless, LAMAS stated that if the desired connectivity
between heritage assets could be achieved, together with a complementary landscaping scheme, an
appreciation of the scale and features of the historic Tudor dockyard might possibly emerge.
132 However, LAMAS concluded that the proposed masterplan is nether sympathetic or
appropriate, and in its current form it would have a detrimental impact on designated and nondesignated heritage assets at this historic site. According, LAMAS urged that the local planning
authority: delays consideration until procedural matters can be discussed and resolved; or; defers
the application to allow for further consideration along the lines set out above; or, refuses planning
permission due to the impact upon the fabric and setting of this nationally important site and its
individual heritage assets.
133 The Mayor is advised that issues related to archaeology at the site are considered within the
heritage section of this report.
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Responses from other organisations and local groups
Pepys Community Forum
134 The Pepys Community Forum stated that the proposed redevelopment of Convoys Wharf
has the potential to deliver a number of significant local benefits (including a boost to the local
economy and improved connections with the riverside). However, the community group object to
the current masterplan for the following reasons: the proposed mixed use development does not
reflect the site’s history, fails to promote social inclusion, and would not offer employment
opportunities that would be accessible to the local community; low level of affordable housing
(particularly social housing); the design of the proposed tall buildings is not clearly defined, and
these elements would dominate local community buildings; green amenity space is internalised
rather than shared; the development does not adequately reflect the maritime history at the site;
the proposed development is profit driven; the scheme is overwhelmingly residential and mainly
targeted at an affluent minority; and, further consideration is required with respect to school places,
childcare, needs of the older population, integrated service delivery and the impact of
environmental change on the local community.
135 The Pepys Community Forum provided findings of four social impact assessments which it
had commissioned in 2004 to 2005 (in relation to education, health, economic development and
traffic movement), and made a number of detailed recommendations to address community
concerns with respect to: biodiversity; community involvement, education and training;
employment; economic viability; health; recognition of site history; housing and community
facilities; local identity; public amenity; and, transport. A proposal for a new community
development trust, to be independently led by local people, was also submitted by The Pepys
Community Forum. The group proposed that this be set up at the Convoys Wharf site (supported by
a financial contribution from the scheme), and used for the benefit of the local community.
The Tenants Action Group (Pepys Estate)
136 The Tenants Action Group stated that it objects to the application for the following reasons:
ineffective consultation/engagement by the developer; lack of response to community aspirations
and ideas; lack of recognition of site history; lack of on-site communal areas and children’s play
space; internalisation of amenity space within perimeter blocks; low provision of affordable housing;
query over affordability of affordable housing; cumulative traffic impacts; excessive density; lack of
social inclusion; impact of tall buildings on views; lack of design flair; negligible contribution to local
educational need; reduction in wharf area; insufficient industrial employment opportunities; site
access constraints; amenity and safety impacts associated with the proposed routing of heavy
traffic; and, disturbance to Pepys Park through a proposed new access route with the site.
Greenwich Conservation Group
137 The Greenwich Conservation Group welcomed a number of design changes made to the
scheme since the previous application at the site – specifically identifying a greater recognition of
archaeology and historic fabric. The extent of public consultation undertaken by the applicant prior
the submission of the current application was also commended, and the group expressed support
for both the Lenox and Sayes Court Garden community projects. However, the group also identified
various objections to the current proposal with respect to: height of development (and associated
impact on strategic views and World Heritage Site); housing (low provision of affordable housing
and family housing); heritage (missed opportunity to recreate canal and dry dock); open space (lack
of distinction between public and private amenity space); Thames Path (landward detour at eastern
site boundary is a disappointing compromise); Impact on existing infrastructure; and, overdevelopment of site.
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The Greenwich Society
138 Whilst The Greenwich Society supports the comprehensive development of this area, it
expressed concern with respect to the impact that this very large development will have on local
infrastructure. The Society stated that the generation of over 2,000 cars (excluding service vehicles)
will add to vehicular congestion on the A206, which is already very heavily trafficked. Whilst the
proposed Thames Path extension and jetty for river bus services were supported, the Society
expressed serious concerns over the impact that the three tall buildings would have on the riverscene. The Society expressed the view that the height of buildings at the northern part of the site is
excessive, and that their scale would have a detrimental effect on views out of the Maritime
Greenwich World Heritage Site (at river level, from Cutty Sark Gardens, Greenwich Pier and the
grounds of the Old Royal Naval College), as well as an adverse impact on strategic views of St.
Paul’s Cathedral from Greenwich Park and Blackheath Point.
139 In response to the consultation on revised plans, The Greenwich Society welcomed the
proposed amendments to the application, but expressed regret that the changes did not go far
enough in terms of addressing the Society’s previous objections.
The Friends of Greenwich Park
140 The Friends of Greenwich Park expressed dismay at the proposed height of the three tallest
buildings at the site, stating that the scale of the buildings would dominate the view of the
Deptford bend in the river from many locations in Greenwich Park. The Friends of Greenwich Park
sought much lower towers, in order that the scheme would be more in keeping with the historic
waterfront, and with the general panorama of London as seen from Greenwich.
Lewisham and Greenwich People Before Profit
141 Lewisham and Greenwich People Before Profit raised a number of key issues with the
scheme as follows:
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Jobs – whilst it is stated that this would be a thirteen year building project , the developer
has not initiated any advanced local training programmes – suggesting that it is intended to
bring in workers from elsewhere.
Housing - on close inspection the proposal would only deliver 8% affordable housing – this
does not comply with local planning policy. Lewisham needs affordable housing which is
genuinely affordable for those on the average wage within the borough. The local planning
authority should impose a restriction on the number of units sold abroad and the number
sold as buy-to-let investments.
Energy – the energy strategy should prioritise roof mounted renewable energy technologies
over connection to SELCHP.
Access – Evelyn Street would become heavily congested as a result of the impact form this
and other schemes. The proposed side road access to the site from Grove Street and Evelyn
Street is totally unsuitable for the expected volume of traffic. Oxstalls Road is totally
unsuitable as a main access for lorries (particularly given the presence of Deptford Green
School). Dragoon Road is safer and should be used instead. Deliveries by river should be
prioritised rather than by road. Increased traffic from the proposed development would
result in a negative impact on air quality and could cause a health and safety issue – this has
not been taken into account.
Business space – the scale of units within the scheme could undermine the entire local
business community. All commercial units should be used to launch a green business hub as
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a sustainable business community for new start up companies, or to boost the link with the
artistic community.
Heritage and river – more should be done to reflect the area’s maritime and dock history
and greater access to the river should be given for tourism – the Lenox project could
support this. A better connection to Greenwich would be supported, as would a modern
boat building centre.
Olympia – plans of a community use for the Listed Building are tokenistic and not
sustainable and the cultural strategy is flawed. Instead of what is proposed the Listed
Building could support a green energy hub, or centre for building the Lenox.
Contamination – the developer does not have a clear proposal for decontaminating the site.
If this is not done properly the health of neighbouring residents would be at risk.
Social infrastructure – there is a shortage of health care provision and school places.
Community engagement – whilst residents have been constantly approached their views and
concerns have been ignored.
Regeneration X
142 Regeneration X expressed the view that the proposal would create an enclave with poor
permeability and legibility, cut off from the real world of Deptford and its current population, and
based on an urban design and grain which could be anywhere. The nature of public space within
the scheme was also criticised as inward facing, poorly connected to the Deptford community,
failing to reflect John Evelyn’s legacy, and undermined by internal facing blocks. Regeneration X
also expressed concern at the likely commercialisation of public spaces within the scheme, and
stated that the masterplan did not appropriately accommodate the Build the Lenox Project. In its
assessment, Regeneration X stated that the application fails to meet Lewisham's Core Strategy
Objective 10 and Spatial Policy 2; that the towers are too tall; and, that the proposed affordable
housing provision is inadequate.
143 Regeneration X subsequently highlighted that the Convoys Wharf site has been placed on a
list of heritage at risk by The World Monuments Fund (refer to paragraph 202).
The Lenox Project CIC
144 The Lenox Project CIC stated that, notwithstanding commentary within the submitted
documentation, the community group had not received any written communication demonstrating
a commitment by the applicant to accommodate the project, or a formal offer with respect to use of
space at the site for the project.
Bench Outreach
145 Bench Outreach, based in New King Street, introduced its role as a local charitable
organisation assisting the homeless, and those affected by drugs and alcohol dependency. The
organisation expressed support for the principle of redevelopment at Convoys Wharf, but identified
a number of concerns with respect to: a low proportion of affordable housing; scale of
development; and, objectivity of a parking survey undertaken at New King Street. The organisation
stated that due to the aforementioned concerns it did not support the application. Bench Outreach
also stated that it would strongly object to the removal of existing car parking spaces along New
King Street (as part of any highway improvement options).
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The Jessica Mathers Trust
146 The Jessica Mathers Trust, based in New King Street, introduced its role as a local charitable
organisation assisting the homeless and those affected by premature bereavement. The
organisation stated that it was in favour of redevelopment at Convoys Wharf, and the intention to
open up this section of river frontage to the local community. However, the Trust identified the
following concerns associated with the current proposal: low proportion of affordable housing
(particularly social housing); scale of development; and, objectivity of a parking survey undertaken
at New King Street. The organisation stated that due to the aforementioned concerns it did not
support the application. The Jessica Mathers Trust also stated that it would strongly object to the
removal of existing car parking spaces along New King Street (as part of any highway improvement
options).
147 In response to the consultation on revised plans, the Jessica Mathers Trust reiterated it’s
previous comments and concerns, and sated that it supported the representations made by
Lewisham Council following the strategic planning committee meeting on 16 January 2014.
Responses from other local authorities
148 The neighbouring authorities of the Royal Borough of Greenwich, London Borough of
Southwark and London Borough of Tower Hamlets were consulted. Whilst acknowledgements to
the initial public consultation undertaken by Lewisham Council were received, no specific
comments were submitted by these local authorities at that time. Following the Mayor’s
consultation on revised plans the following responses were received from neighbouring local
authorities.
Southwark Council
149 Southwark Council welcomed the delivery of new homes and employment into the area,
stating that, in conjunction with Southwark’s own proposals in Canada Water, the redevelopment
will contribute to transforming this part of London and help to enhance the vitality and viability of
these areas. Notwithstanding this, Southwark Council expressed the view that the proposed
development was likely to impact on the London Borough of Southwark with respect to:
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Vehicular traffic – the proposals for Convoys Wharf are of a significant scale and will impact
not only on local roads adjacent to the site, but also on the wider strategic road network,
including Lower Road.
Secondary school places – a secondary school is not proposed as part of the proposals so
children of this age group will need to be accommodated in existing schools within and
outside of Lewisham. It is likely that the surplus of secondary places assumed by the
Environmental Statement will be reduced considerably and become a shortfall in the near
future (as shown in Southwark’s secondary school place forecasting). The increase in the
secondary pupil population as a result of the development of Convoy's Wharf is therefore
likely to contribute to the pressure for places at Southwark secondary schools.
Air quality – the Southwark/Lewisham borough boundary falls within part of areas that have
been declared by both authorities as Air Quality Management Areas. The Council considers
that it would be appropriate for a contribution to be made to mitigate the impacts of the
development on Southwark in relation to air quality impacts.
150 Accordingly, Southwark Council seeks financial contributions by way of planning obligation
to mitigate the above impacts. The issues raised by Southwark Council are considered within the
other issues raised during consultation section of this report.
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Representations made to the Mayor of London
151 At the time of writing this report the Mayor has received a number of representations in
relation to this application (refer to table 4). Two representations were also received prior to the
Mayor’s decision to become the local planning authority. A summary of representations made to
the Mayor is provided below.
Representations received prior to the Mayor becoming the local planning authority
Hutchison Whampoa Property (on behalf of the applicant)
152 Edmond Ho, Director and General Manager of Hutchison Whampoa Properties (Europe)
Ltd., made a formal request for the Mayor to act as the local planning authority for the purposes of
determining this planning application pursuant to pursuant to paragraph 7(6) of the Town and
Country Planning (Mayor of London) Order 2008.
153 Hutchison Whampoa Property stated that such a decision would be justified because: the
development will have a significant impact on the implementation of the London Plan given the
proposal for 3,500 new homes, 2,150 new jobs, new river bus service and highway improvements;
the site is close to three other neighbouring boroughs and the scale of the development means it
will have an effect on these; it is proposed to connect to the SELCHP waste to energy plant; the
typical 16-week determination period has expired; the GLA supports the scheme in principle and
the applicant team has responded positively to issues previously identified by the GLA; concerns
that Lewisham Council may make unrealistic demands and seek further changes to the masterplan;
and, risk that determination of the planning application by Lewisham Council may be delayed by
local elections in May 2014.
Lewisham Council
154 In response to the above request from Hutchison Whampoa Property, Barry Quirk, Chief
Executive of Lewisham Council, made representations to the Mayor asking that he allow Lewisham
Council to continue with determining the application.
155 Lewisham Council noted that the Mayor has committed to using his ‘take over’ powers
sparingly, and has achieved considerable success in delivering London Plan priorities through joint
working with borough’s and developers - without the need to become the local planning authority.
Lewisham Council stated that it has worked constructively with the GLA on a number of major
schemes, and there are no sound planning reasons for the Mayor to intervene in this case.
156 With respect to Lewisham’s performance against relevant development plan targets, the
Council stated that it has: demonstrated its ability to determine significant, complex and
controversial applications; acted reasonably in responding to the issues arising in this case; and, has
identified a realistic and deliverable timescale for determining the application. The Council also
offered to provide statistics which clearly demonstrate the ability of Lewisham to achieve its
housing targets and deliver affordable housing. The Council stated that it does not consider that
the circumstances present a significant risk to the delivery of London Plan priorities, and the
application should remain with the Borough for determination.
157 With respect to the current application process, the Council stated that good progress had
been made, but that there remained a number of key issues to be resolved – many of which had
also been identified by the GLA. The key issues identified were with respect to: design and
heritage; accommodation of community proposals for Lenox and Sayes Court Garden (both
projects are supported by the Council in principle); transport and access; and, environmental issues.
The Council cited the applicant’s discontinuation of regular project meetings and general lack of
page 38
meaningful engagement as the cause of delay to the determination of the application, but stated
that the Council remains committed to resolving the outstanding issues and seeking a positive
resolution.
158 In conclusion the Council reiterated its view that there is no significant threat to the
delivery of the key strategic objectives of the London Plan, and that the outstanding planning
issues on the case are fully capable of being resolved by Lewisham Council in the normal way. The
Council stated that it was unfortunate that the applicant had decided to seek the Mayor’s
intervention, rather than engaging with the Borough to resolve outstanding issues. The Council
asked for the Mayor’s support in encouraging the applicant to engage, whilst leaving the
application with the Borough for determination. It was also stated that the application could be
reported to the Council’s Strategic Planning Committee in February 2014 with a positive
recommendation.
Representations received after the Mayor became the local planning authority
Lewisham Council
159 On 16 January 2014 Lewisham Council’s Strategic Planning Committee considered a
planning report of the same date setting out Lewisham officers’ position on the application at that
point in time. Having considered the report, along with the various consultation responses/
representations received at that time, the Committee resolved to issue representations to the
Mayor of London setting out the Council’s position on outstanding issues, and authorising
Lewisham’s Head of Planning to continue to negotiate with the GLA and applicant with a view to
securing amendments. In summary, the representations issued by Lewisham Council’s Strategic
Planning Committee are as follows.
160 The Council supports the principle of mixed use development of the site in accordance with
Policy SSA2 of the Core Strategy, but considers that in its current form the application should not
be approved, and that amendments should be secured in relation to the following matters:
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Scale, massing and relationship with historic buildings and spaces: reduction of the scale
and massing of selected development parcels as outlined in the report to achieve an
acceptable urban scale and an appropriate relationship of new buildings with historic
buildings and spaces, in particular in relation to the Olympia Building, former Master
Shipwrights House and site of John Evelyn’s House.
Sayes Court Garden and The Lenox: the approach to Sayes Court fails to provide a
meaningful green link between the site of the Gardens with the remains of Sayes Court
House. The opportunity to link these two historically significant spaces should be fully
explored. The Lenox preferred building location is either within the Double Dry Dock or
Olympia warehouse. These options need to be explored further, as does the future use of
the Olympia warehouse and an agreement reached on the deliverability of the Double Dry
Dock or Olympia warehouse as options for constructing the Lenox.
Building in scope for design flexibility, evolution and innovation: the Design Guidelines
should either be significantly streamlined to identify what is essential (mandatory) in terms
of providing guidance for reserved matters applications and what is too specific/
constraining, or should become ‘for information’ only.
Transport issues: the site has a relatively low level of public transport accessibility and it is
essential that car parking is minimised and the opportunity to provide access to public
transport, pedestrian and cycle links are maximised. This includes the widening of New King
Street to allow for two-way bus movement and improved pedestrian and cycle access and
the re-design of the New King Street/Evelyn Street/Deptford High Street junction to
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provide a direct single all-red phased pedestrian crossing. TfL needs to satisfy itself of the
robustness of the data and that the modelling outputs can be resolved.
Community benefits: securing appropriate social infrastructure and the maximum possible
amount of affordable housing to meet the needs of Lewisham residents. There is an
identified need for investment in affordable housing and a range of community
infrastructure projects directly attributable to the impact of the new development including
the need for a new primary school, GP facilities, funding for additional secondary school
capacity, jobs and training and open space. A number of questions remain about the
applicants' assumptions on costs and future values in their viability statement, changes to
which could support additional section 106 payments and affordable housing.
Clarifications, commitments and procedural compliance: clarifications and/or commitments
are sought with respect to operation of the wharf; process and timing of reducing the area
of the safeguarded wharf; retail floorspace impacts; housing mix; transport assessment
modelling; car parking management; school capacity; delivery of projects set out in the
cultural strategy; mechanism to ensure a mix of uses is secured across the site; Lifetime
Homes standard; wheelchair and housing design standards; decentralised energy network
connection; Code for Sustainable Homes Level 4 and BREEAM ‘Excellent'; Environmental
Impact Assessment; Flood Risk Assessment; and financial review mechanism.
Construction: Ensure there is a Code of Construction Practice to manage and mitigate
construction impacts and maximise the use of the river for construction materials and waste
from the commencement of the project.
161 Following the committee meeting, Sir Steve Bullock, Mayor of Lewisham, wrote to the
Mayor of London to specifically endorse and reiterate the recommendations of Lewisham’s
Strategic Planning Committee (discussed above), and to request a meeting to discuss the issues
raised. On 18 February 2014 a related meeting was held at City Hall, which Sir Steve Bullock and Sir
Edward Lister, Deputy Mayor for Planning and Chief of Staff, both attended. Lewisham Council
planning officers and GLA planning officers were also in attendance. The issues discussed at that
meeting were as set out in paragraph 160 above.
Member of Parliament for Lewisham Deptford (Labour Party)
162
Shortly after the Mayor had made his decision to become the local planning authority in
this case, Rt Hon Dame Joan Ruddock MP, Member of Parliament for Lewisham Deptford, wrote to
the Mayor in order to emphasise the heritage value of the site, and to highlight the years of effort
that the local community has put into the scheme. The MP for Lewisham Deptford sought a
meeting with the Mayor’s Office in order to express a number of key local aspirations and concerns
associated with the application.
163 On 16 December 2013 a related meeting was held at City Hall, which Rt Hon Dame Joan
Ruddock MP and Sir Edward Lister, Deputy Mayor for Planning and Chief of Staff attended. GLA
planning officers and representatives of various local groups (Sayes Court Garden CIC, The Lenox
Project CIC and Deptford Is) were also in attendance. The issues discussed at that meeting focused
on: the heritage value of the site (and how the proposed redevelopment should celebrate this); two
heritage-led local community projects (Sayes Court Garden programme and Build the Lenox
project); and, how the masterplan might be adapted to accommodate the aforementioned
community projects.
164 Rt Hon Dame Joan Ruddock MP subsequently wrote to the Deputy Mayor for Planning to
express thanks for the initial meeting discussed above, and proposed a further meeting, to which
the applicant team would be invited to.
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165 In advance of the next meeting, the MP for Lewisham Deptford sent a letter to the
applicant (copied to the Deputy Mayor for Planning), identifying proposed topics for discussion.
The letter also expressed views on how the masterplan could be revised to accommodate the Sayes
Court Garden and Lenox community projects. A summary is provided below:
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Sayes Court Garden: An adjustment to the block at masterplan plot 16 could facilitate a
project worthy of the site. The centre for urban horticulture should be set in an open space
both as a reflection of the archaeology and heritage, and to ensure its viability (English
Heritage supports the former and the National Trust supports the latter).
Build the Lenox: We believe that the proposed use of the wharf for this project is unviable.
Use of the Olympia building instead would provide a superb focus to the site and offer a
unique attraction. Opening the former basin from of Olympia would provide a vital link to
the river and a further enhancement of the site. English Heritage support the proposal to
build the Lenox in Olympia in principle, subject to further feasibility testing.
166 The proposed follow up meeting was held at City Hall on 7 February 2014, and Rt Hon
Dame Joan Ruddock MP, Sir Edward Lister, Deputy Mayor for Planning and Chief of Staff, and
Edmond Ho, Director and General Manager of Hutchison Whampoa Properties (Europe) Ltd.
attended. GLA planning officers, Lewisham planning officers, representatives and consultants from
the applicant team, English Heritage officers and representatives from the National Trust and
various local groups (Sayes Court Garden CIC, The Lenox Project CIC and Deptford Is) were also in
attendance. The issues discussed at that meeting focused on: archaeological findings within the
draft post excavation report; emerging proposals for revised plans affecting masterplan plots 16 and
17; emerging proposals for infrastructure to enable temporary shipbuilding at the wharf; responses
from community stakeholders; and, open discussion of progress made with respect to
accommodating the Sayes Court Garden and Lenox community projects.
167 Rt Hon Dame Joan Ruddock MP subsequently wrote to the Deputy Mayor for Planning to
express thanks for facilitating the follow up meeting discussed above. The MP for Lewisham
Deptford also provided a number of observations from the meeting summarised below.
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Sayes Court Garden: The progress made to date with the Sayes Court project is very much
welcomed. However, viability concerns remain for this project given the fact that the
proposed revisions (and masterplan parameters) would not allow for provision of the
horticultural centre as a standalone building. Accordingly, further consideration of the
project’s needs, and the setting of masterplan parameters, is encouraged so as not to ‘shut
down’ options for the Sayes Court project.
Build the Lenox: As noted at the meeting there needs to be a fundamental discussion
between The Lenox Project CIC and Hutchison Whampoa about the siting and future of the
Lenox project. The Lenox team are, nevertheless, committed to giving serious consideration
to the proposal to provide temporary shipbuilding infrastructure at the wharf in order to
facilitate the project. It was noted that the applicant seeks to recoup costs associated with
the refurbishment of Olympia as soon as possible. For the avoidance of doubt, the Lenox
project only seeks to occupy half of Olympia.
168 In addition to the representations discussed above, the office for the MP for Lewisham
Deptford also provided the transcript of an adjournment debate, held at the House of Commons, on
the relevance of national heritage issues in the development of Convoys Wharf. The debate took
place on 22 January 2014, and was led by Rt Hon Dame Joan Ruddock MP. The debate covered a
range of issues including: the site’s history; the value of heritage assets at the site; heritage-led
community proposals (Sayes Court Garden programme and Build the Lenox project); changes
proposed to the outline masterplan to accommodate/facilitate the aforementioned community
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proposals and/or celebrate the heritage at the site; and, considerations of the Secretary of State for
Culture, Media and Sport with respect to a review of statutory heritage designations at the site (due
to be informed by a recommendation from English Heritage).
169 In response to the consultation on revised plans, the MP for Lewisham Deptford welcomed
the release of plot seventeen to open space, and the reduction in height parameters at plot one.
Whilst the revision to the housing mix (providing an increased number of family sized affordable
rent units) was also generally welcomed, Rt Hon Dame Joan Ruddock MP expressed the view that it
did not go far enough in terms of responding to local housing need. Furthermore, with respect to
the ability of the masterplan to successfully accommodate the Sayes Court Garden and Lenox
community projects, the following representations were made:
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In order for the Sayes Court Garden horticultural programme to succeed, this project needs,
at this stage, a minor revision to minimum parameters of masterplan plot sixteen to give the
opportunity to improve the setting of the archaeology, and provide the critical mass of open
space which would enable the project to deliver a vigorous future. This would make such a
future possible, without detriment to either the developer’s aims or the timescale for
determination of outline planning consent.
An independent feasibility study is needed to establish the most viable location for the Build
the Lenox project, giving appropriate weight to its significant contribution to the heritage of
the site and acknowledging the importance of creating the best conditions for its success.
With appropriate planning conditions and a commitment to the project from the applicant,
this could be achieved without significantly impacting the existing masterplan.
Deptford Is
170 Deptford Is set up an online petition of objection to the application entitled: Reject
redevelopment plans for Deptford’s Royal Dockyard. The petition states that the signatories are
very concerned about the proposed scale and impact of the development proposal, which would
destroy the site of Britain’s historic Royal Dockyard and Sayes Court Garden. The petition also
expresses strong support for the Sayes Court Garden and Build the Lenox community projects,
stating that these would reinterpret and celebrate the heritage of the area; create new tourist
attractions; safeguard Deptford’s maritime and horticultural links; and create skilled jobs for local
people. The petition also expresses the view that there has not been meaningful community
engagement by the applicant, and that the scheme would not address London’s housing need given
a low provision of affordable housing. Ultimately the petition calls for the Mayor to seek revisions
to the outline application to ensure the proposals would have greater sensitivity for the
surroundings.
171 At the time of drafting this report this petition of objection has attracted 1,979 signatures
from a wide range of individuals based in Deptford and Greater London, as well as a significant
number across the United Kingdom and abroad.
Sayes Court Garden CIC
172 Sayes Court Garden CIC has engaged in various community stakeholder meetings with GLA
and Lewisham Council planning officers, and has made numerous detailed written submissions as a
valuable contribution to the planning process (and often at the request of planning officers). All of
the submissions received to date have been made available to the Mayor in their original form,
however, in the interests of conciseness within this report GLA officers provide a key summary
below of the Sayes Court Garden project vision, and the position of the community group with
respect to its view on how the proposed masterplan responds to the project vision requirements.
Sayes Court Garden – project vision
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Creation of a centre of excellence in urban horticulture for public benefit, and as a means of
expressing the John Evelyn legacy, and celebrating Sayes Court Manor and its historic
garden. The National Trust has a fundamental association with the John Evelyn legacy at
the site, and it is envisaged that the Trust would ultimately operate the centre proposed.
Reflection of the historic relationship between Sayes Court Manor and garden through the
provision of the horticultural centre within a standalone building in green open space,
located above the archaeological remains of Sayes Court Manor. Such an arrangement
would be supported by English Heritage and the National Trust.
Provision of 1,500 sq.m. of floorspace for educational spaces, with break out into one
hectare of open space for a proposed horticultural programme based on extensive research
and consultation, and supported by the National Trust, World Monuments Fund, Garden
History Society, Eden Project, Council for British Archaeology, London Parks and Gardens
Trust, and local schools, colleges and universities.
Provision of learning opportunities across the educational spectrum (from primary school to
higher education/research and adult learning) and links to industry practitioners and
apprenticeships (such as landscape architects, environmental professionals and local
authorities).
The educational programme would deliver numerous public benefits including promotion of
healthy eating and sustainable food production, and addressing a skills shortage within the
horticultural industries.
Other proposed public benefits associated with the project would be directly related to the
meaningful celebration of the historical significance of Sayes Court and an increased
provision of open space (through revised configuration of masterplan plots to provide open
space around the horticultural centre). The community group also identifies further public
benefits relating to health; environment; climate change; air quality; food management;
biodiversity; social infrastructure, and place making.
Community group position on how the masterplan responds to project vision requirements
173 Sayes Court Garden CIC has expressed concern that whilst the masterplan includes a space
for community use above the archaeological remains of Sayes Court Manor, this would not benefit
from the necessary interface with open space (central to the realisation of the horticultural
programme). The community group nevertheless stated that it is keen to find a way to allow for its
proposed programme to be incorporated within the general framework of the outline masterplan.
Accordingly, the community group has focused attention on masterplan plots sixteen (location of
former Sayes Court Manor) and seventeen (a primary school block, situated between the former
Sayes Court Manor and an area of green open space extending into Sayes Court Park). With respect
to the positioning of these blocks prior to the submission of revised plans, Sayes Court Garden CIC
stated that, in their current configuration they would have a serious adverse impact on both the
historic significance and future use of this part of the site. The community group also noted that it
would not be possible to revise the parameters of these blocks at reserved matters stage.
174 Sayes Court Garden CIC also expressed particular concern that the remains of Sayes Court
Manor would be landlocked within a larger block, and that the site of Sayes Court Garden would be
buried partly beneath that block and the primary school. Accordingly, the community group
presented its argument, supported by the National Trust, that masterplan blocks sixteen and
seventeen should be revised to allow for the centre for urban horticulture to be provided as a
standalone building. The group stated that this approach would have many benefits for the project
including: the potential to deliver an inspirational piece of architecture set within a garden; direct
relationship with green open space; stronger presence/identity of the horticultural centre; increased
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control of delivery timing (and potentially earlier establishment of the planting programme); and,
greater independence and improved project viability.
Community group response to revised plans
175 Sayes Court Garden CIC stated that is was encouraged to see the GLA’s recognition of the
potential benefits of the Sayes Court Garden project, and welcomed the removal of the block at
masterplan plot seventeen – which creates additional open space in the vicinity of the former Sayes
Court Manor. However, the community group stated that it would still not be possible to realise the
project within the proposed masterplan configuration (which maintains the provision of floorspace
for the horticultural centre within a larger mixed use block). As a means of resolving this issue,
Sayes Court Garden CIC proposed a change to the minimum parameters at masterplan plot sixteen to allow for greater flexibility as to how this plot could be designed at reserved matters stage. The
community group has also presented a number of design studies illustrating examples of how this
plot could potentially be arranged. These drawings demonstrate that the community group would
consider a developmental configuration that (whilst not necessarily providing a standalone building)
would offer a large frontage on to an increased area of green open space.
176 Sayes Court Garden CIC also sought to emphasise that the horticultural centre proposal is
based on the four pillars of the sustainable development of historic sites (cultural resources,
community, economy and the environment). The community group stated that it has, from an early
stage, sought to build in the revenue streams necessary to make the project financially selfsustaining over the long term - including opportunities for education, training, life-long learning,
professional development and tourism. Sayes Court Garden CIC also stated that whilst it was open
to discussion as to the final designation and layout of open space to support the programme, it
would seek to avoid potential use conflicts associated with any potential expansion of the
programme into Sayes Court Park.
National Trust
177 The National Trust wrote to express its interest in the application, and highlighted a
fundamental link between a historic desire to preserve Sayes Court, and the eventual formation of
the National Trust of Historic Interest or Natural Beauty in 1895.
178 The National Trust stated that it seeks amendments to the proposed outline masterplan in
order to allow for the archaeology of Sayes Court Manor to be revealed within a dedicated building,
set within a new garden. The Trust expressed the view that a failure to do this would severely
compromise the opportunity to reveal the significance of this archaeological asset, and represent a
considerable missed opportunity to contribute to place-making within the scheme.
179 The National Trust also provided a detailed report on Sayes Court and John Evelyn, which
the Trust intended to help inform the assessment of significance of Sayes Court.
180 In response to consultation on revised plans, the National Trust noted the effort to provide
an improved relationship with the Sayes Court Manor archaeology and the location of the former
Sayes Court garden. The Trust also stated that it wished to make clear it was not seeking a
recreation of Evelyn’s seventeenth century garden at the site. The Trust confirmed that it
continued to support the Sayes Court Garden horticultural project, and that it was committed to
working with the community group, and other partners, on the detailed feasibility and business
planning stages. In this context the National Trust set out that it sought the redrawing of minimum
parameters for plot sixteen to enable further design considerations at reserved matters stage, and
to give greater opportunity to develop a project which is both viable and fully reflects the historic
significance and importance of the site.
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London Parks and Gardens Trust, and Garden History Society
181 The Chairman of the Planning and Conservation Working Group of the London Parks and
Gardens Trust stated that the sites of Sayes Court Manor and Sayes Court Garden are important
heritage assets and every effort should be made to protect them and ensure that their historic
connecting links are re-established physically as well as notionally. With respect to the outline
masterplan, the following shared concerns were expressed by the London Parks and Gardens Trust
and Garden History Society: whilst the current proposal acknowledges Evelyn and provides a green
link from the existing park into the new square around the Olympia building, the proposal of
building over the manor house site at a new and alien scale is very disappointing; the response
would also make no provision for a suitable garden setting linked to the existing park, or to the park
extension; the height and bulk of the new buildings and the highly-regimented organisation of
spaces is difficult to reconcile with the prevailing scale of Deptford, or what is known of the historic
character of Sayes Court and the Royal Naval Dockyard; and, relaxing the masterplan’s tight grip in
respect of at least the manor house and its immediate garden site could help ensure a scheme that
celebrated Evelyn in a suitably green way and at a human scale.
182 Jonathan Lovie, Principal Conservation Officer and Policy Advisor of the Garden History
Society and Dr Marion Harney, Director of Studies at the University of Bath, also offered their
endorsement to the above representations.
183 Following consultation on revised plans, the London Parks and Gardens Trust stated that it
wished to express explicit support for the Sayes Court Garden horticultural programme. The trust
also sought a relaxation of parameters at plot sixteen in order to allow sufficient flexibility to
successfully accommodate the horticultural programme.
Gardens Illustrated
184 Gardens Illustrated stated that it was concerned that the current design of the scheme
would have a serious adverse impact on the remarkable history and aspiring future of Sayes Court
Garden – which is an enduring icon of horticultural innovation. Gardens Illustrated indicated strong
support for the community-led proposals put forward by Sayes Court Garden CIC, stating that the
horticultural project offers a dynamic response to the site's history, and a valuable resource for
education, training, jobs, tourism, enterprise and research, as well as access to a rich and complex
new open space with multiple benefits for physical and mental health, biodiversity and the
environment. Gardens Illustrated urged that the Mayor presses for changes to the planning
application which would enable the history of the site to be preserved, and a vibrant new future
created.
185 Gowan Landscape Design also endorsed the Sayes Court Garden project by submitting
broadly similar representations to those of Gardens Illustrated, summarised above.
The Lenox Project CIC
186 The Lenox Project CIC has engaged in various community stakeholder meetings with GLA
and Lewisham Council planning officers, and has made numerous detailed written submissions as a
valuable contribution to the planning process (and often at the request of planning officers). All of
the submissions received to date have been made available to the Mayor in their original form,
however, in the interests of conciseness within this report GLA officers provide a key summary
below of the Lenox project vision, and the position of the community group with respect to it’s view
on how the proposed masterplan responds to project vision requirements.
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Build the Lenox - project vision
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Construction of a full-sized seventeenth century warship (Lenox) on the site of the former
Deptford Royal Dockyard (where it was originally built).
Mooring of the completed ship in the restored Great Basin (in front of the Olympia
building). This would become the Lenox’s home port, where other ships can visit, and from
where she may voyage to other world destinations.
To generate training, employment and trading opportunities associated with taking vessels
to sea.
Establish a construction training programme, and ongoing legacy scheme (repairing other
historic vessels in future), to provide transferrable skills in both modern and heritage
construction techniques.
Revitalise Deptford’s unique marine and maritime heritage, and support the establishment
of a marine enterprise zone on the wharf.
To support the restoration of Sayes Court Gardens.
Support the creation of a Deptford Dockyard museum on the site, which, along with the
Lenox itself, would celebrate and remember the former dockyard’s vast heritage.
Improve the waterfront environment and provide a new national and international tourist
attraction in Deptford (both during construction and following completion) to complement
existing nearby heritage attractions at Maritime Greenwich.
To work in association with other organisations to address issues of social and economic
deprivation in Deptford and encourage social cohesion.
Community group position on how the masterplan responds to project vision requirements
187 In an effort to provide additional context to the community group’s position, The Lenox
Project CIC has expressed a number of views on the outline application. In general the community
group has stated that whilst the heritage status of the site has been acknowledged and recorded by
the applicant, a genuine appreciation of this value has not appropriately fed through into the
design of the outline masterplan. In particular, and making reference to issues identified within
Lewisham Council’s Committee report of 16 January 2014, the community group stated that the
Great Basin, Double Dry Dock and setting of the Olympia building deserve greater recognition than
they are currently proposed to be afforded. Against this context, The Lenox Project CIC stated that
any option being considered for accommodating the project should be assessed on the basis of
whether it can revitalise the legacy of the historic dockyard in a manner that the masterplan
currently fails to do.
188 The Lenox Project CIC has commented on three location options for accommodating the
Lenox project within the masterplan: the safeguarded wharf; the Double Dry Dock; and, the
Olympia building and (a reinstated) Great Basin. A summary of the community group’s position in
respect to each is provided below.
The safeguarded wharf option
189 The Lenox Project CIC noted that this site represents the applicant’s preferred option, but
stated that undertaking the project in this location would have no advantages for the community
group, and no relevance to the historic dockyard. In particular the following disadvantages were
identified: given that the site would only be made available temporarily, a significant proportion of
the local benefits of the Lenox project would fail to materialise; lack of a long term presence would
undermine the ability of the project to attract investment or funding (particularly for education and
training programmes); the legal conditions that the applicant is likely to apply would not be flexible
enough to allow the project to succeed; the project would not comply with planning policy
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definitions for suitable safeguarded wharf uses (as previously identified by the GLA and Port of
London Authority); the Lenox project could not successfully coexist with other wharf related uses;
public visitor access (key to project viability) would be difficult/unattractive where the wharf would
be in simultaneous use for construction logistics purposes/other wharf uses; the cultural offer
within the masterplan would be disjointed/spatially separate; and, enabling shipbuilding
infrastructure may adversely impact on archaeology (mast pond).
The Double Dry Dock option
190 This was originally proposed as the preferred location for the project by The Lenox Project
CIC, before various archaeological concerns associated with use/renovation of the historic dock
prompted the community group to explore other options. The Lenox Project CIC identifies the
following key advantages of using the (renovated) Double Dry Dock: this represents the original
launch site of the Lenox and benefits from direct access to the river; the historic relationship
between shipbuilding and the Master Shipwrights House would be recreated; this location is
identified as one of two preferred options by Lewisham’s planning committee; the location would
offer improved access to Greenwich and the Thames Path (potentially improving visitor numbers);
the location would minimise the interaction between shipbuilding and construction of the scheme;
and, re-use of the Double Dry Dock for its original purpose is supported in heritage terms and
would allow for a more legible interpretation of the site’s history. The Lenox Project CIC
nevertheless identifies the following potential disadvantages of using the (renovated) Double Dry
Dock: a temporary building would be required to facilitate shipbuilding, and this would need to
become a more permanent fixture in order to deliver the intended legacy benefits; there is limited
space around the Double Dry Dock for workshops and a permanent museum; there would be a
reduction in public space within the masterplan; and, there would not be a strong link to Sayes
Court Garden.
The Olympia building and Great Basin option
191 This is now the preferred option of The Lenox Project CIC, and would allow for the creation
of a museum of shipbuilding within the Olympia building and reinstatement of the Great Basin
(either in original form or as a smaller version). The Lenox Project CIC identifies the following key
advantages of using the Olympia and (reinstated) basin: the proposal would contribute to a vibrant
hub of creative activity at the heart of the development; the return of shipbuilding to Olympia
would be a very favourable use for the Listed Building, and would positively respond to London
Plan and English Heritage approaches to the re-use of heritage assets; the proposal (including
potential use of slipways beneath Olympia) is supported by English Heritage in principle (subject to
further feasibility work); the project would bring a tangible use to the Olympia building; the
Olympia building provides a covered space for shipbuilding; the project could contribute to a multiuse strategy for Olympia and encourage vibrancy and return trips; the Olympia building provides
space for both workshops and exhibitions; restoration of the Olympia building could be phased to
allow for early implementation of the Lenox project; there would be a tangible connection with the
Sayes Court Garden community project; the masterplan would be significantly improved by a
reinstated Great Basin (either in original form or a smaller version); the basin would allow for a
viable and sustainable shipbuilding use at Olympia; the creation of additional waterside within the
scheme could enhance sales values (meaning construction of the basin could be self-financing);
and, the basin would provide a permanent home for the Lenox after it has been launched.
192 The Lenox Project CIC did not specifically identify any disadvantages associated with its
preferred option of undertaking the project at Olympia and a reinstated basin. The community
group, nevertheless, acknowledged that there is a clear need to conduct a detailed feasibility study
in order to verify the extent of any potential impact on the historic building or Dockyard
archaeology, and that access to the Thames via a reinstated basin would require modification to an
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existing jetty. The community group also stated that it was unlikely that the aforementioned
feasibility work (or a detailed business plan) could be developed within the timetable for
determining this outline application.
Community group response to revised plans
193 The Lenox Project CIC stated that the revisions were disappointing, however, the community
group confirmed that it remained keen to work with the applicant in order to achieve the maximum
benefit for all from this historic site. To this end The Lenox Project CIC has proposed a number of
terms for the applicant to consider for incorporation into a section 106 legal agreement: 1)
commitment by the applicant to accommodate the Build the Lenox Project and the core elements
of the project vision at the Convoys Wharf site; 2) an independent feasibility study to determine the
preferred site for the Lenox Project (exploring Olympia, the Double Dry Dock and the wharf); and,
3) mutual agreement of detailed operational requirements (to be informed by the feasibility study).
Naval Dockyards Society
194 The Naval Dockyards Society stated that it had been reviewing various iterations of plans for
the Convoys Wharf site since 2004. With respect to the current application, the Society expressed
the view that the outline masterplan represented an improved design - particularly with respect to
the creation of a broader vista linking the Olympia building with the historic entrance channel from
the Thames. The proposed provision of a public realm water feature (to recall the existence of this
waterway connection), was also generally welcomed. However, the Society expressed the view that
these design moves had been somewhat undermined by crowding and enclosure by surrounding tall
buildings.
195 Notwithstanding an acknowledgement of these design changes, the Naval Dockyards
Society expressed the view that, on the whole, the current proposals for the site do not
appropriately reflect the international historic significance of the Deptford Dockyard. Accordingly,
the Society raises an objection to the current application. In particular, the Society identified the
following concerns: the scheme does not authentically reflect/express the site’s history and
archaeology; the development would not produce the best outcome for the Deptford community;
and, the outline application is vague on detail and the Design Guidelines are not architecturally
inspiring.
196 In addition, the Society articulated a number of views which emerged at the Naval
Dockyards Society’s 2013 conference (including: any evidence which conveys the size and multiperiod evolution of the Deptford Dockyard should be preserved; new housing blocks could be laid
out in a way which replicates the floor plans of the L-shaped Officers’ terrace; preservation of the
shape in the ground of the double dock is essential; and, in general, more of the archaeological
footprint should be preserved and integrated). This, in addition to some descriptive commentary
(on the heritage value of the Great Storehouse; the applicant’s proposed scheme for archaeological
resource management; and, recent archaeological findings at the site) was used to provide context
to a number of key recommendations. In summary, these are as follows:
 Olympia: Should be restored for permanent and temporary Dockyard related exhibitions,
funded through a section 106 contribution. The Olympia building should be plainly visible
from the River Thames.
 Dockyard basin: Should be expressed within a public piazza – with the varying historic
position of walls and gates clearly denoted as part of the landscaping scheme.
 Great Storehouse: Foundation walls should be suitably protected and significantly exposed
and interpreted. This could be achieved by raising proposed buildings by one-storey above
ground level.
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 Double Dry Dock: Where substantial remains of the dock are found these should be restored
and revealed for public display.
 Sayes Court: Foundations should be displayed under cover, and a garden should feature the
plants in John Evelyn’s garden plan.
 River Wall/Thames foreshore: The existing jetty should be used for visiting historic ships.
Reconstruction of a ship from Deptford’s shipbuilding past – such as the Lenox – would add
both economic and cultural value.
 Surviving walls and gates: The chronological sequence of historic dockyard boundaries
should be expressed through stone paving.
The Shipwreck Museum, Hastings
197 The Business Director of the Shipwreck Museum expressed support for the Lenox project at
Convoys Wharf, stating that it would positively contribute to the recognition of London’s maritime
history and attract many new visitors to the area. The Shipwreck Museum also identified various
related community benefits associated with employment and training opportunities, and enhancing
community awareness of local maritime history.
Faversham Creek Trust
198 The Faversham Creek Trust, located in North Kent, expressed its sense of affiliation with the
former Deptford Royal Naval Dockyard, and stressed that the site is of international significance
and interest as a key part of Britain’s maritime heritage. The Trust stated that the site has
significant potential as a tourism and educational centre, but that the proposed redevelopment
must be handled carefully in order to manage environmental and ecological impacts, and ensure
that the history of the site would not be eroded by high-rise residential and commercial
development. The Faversham Creek Trust also expressed its support for the build the Lenox project.
Medway Queen Preservation Society
199
The Hon Vice-Chairman of the Medway Queen Preservation Society expressed support for
the Lenox project and Sayes Court Garden project, and sought the favourable inclusion of these
community proposals within the masterplan. The Society also expressed the view that both of these
community projects would bring social and economic benefits to the area.
Council for British Archaeology
200 The Council for British Archaeology stated that it was not opposed to the principle of
development at this site, however, it wished to express concern over the heritage implications of
the outline application. In summary, the Council for British Archaeology stated that: any
development on the site should be led by an understanding of the significance of the heritage
assets (both designated and non-designated); the application fails to take account of the
desirability of sustaining and enhancing the significance of heritage assets as required by NPPF
paragraph 131; the masterplan does not appear to have been genuinely informed by the site’s
history; the slipways, double dry dock, Tudor storehouse and mast pond are inadequately
recognised/expressed; the Olympia building is enclosed by tall buildings; and, the current maximum
building heights and massing would cause unacceptable harm to heritage assets. In conclusion, the
Council for British Archaeology emphasised that the magnitude and prestige of the archaeology and
heritage at this site should be a central consideration in the determination of this outline
application.
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201 In response to the revised plans, the Council for British Archaeology stated that it continues
to object to the application. The Council reiterated that any development on the site should be led
by an understanding of the significance of heritage assets, and expressed the view that whilst
connections between neighbouring areas had been prioritised by the masterplan, connections
between archaeological features had not been given due regard. Concerns associated with the scale
and height of development were also reiterated, however, the Council for British Archaeology
expressed support for the Sayes Court Garden community project, and sought a relaxation of
parameters at masterplan plot sixteen.
World Monuments Fund
202 The World Monuments Fund stated that it had placed Deptford Dockyard and Sayes Court
Garden on its 2014 World Monuments Watch list (along with various other international heritage
sites including the city of Venice, various sites in Syria and ancient irrigated terraces of Battir in
Palestine). The Fund stated that the decision to include these Deptford sites on the list is testament
to their irreplaceable heritage value. The Fund also stated that it supported the efforts of the
Council for British Archaeology and local community group Deptford Is in seeking greater
recognition of the site’s historic significance, and a more careful integration of the archaeology
within the proposed redevelopment.
Greenwich Park Conservation Society
203 The chair of the Greenwich Park Conservation Society indicated concern with respect to the
proposed tall buildings within the scheme, and sought assurance that the application would be
rigorously assessed against relevant planning policy and guidance with respect of strategic views
and the settings of World Heritage Sites.
Twinkle Park Trust
204 The Chair of the Twinkle Park Trust provided information and background on the role that
Twinkle Park (adjacent to the eastern boundary of the site, within the Royal Borough of Greenwich)
plays for the local community as a valuable public open space. The Trust expressed the view that
the proposed development at Convoys Wharf would intensify the use of this public space, and that
maintenance of the park is challenging as it is already very well used.
205 In response to consultation on revised plans the Twinkle Park Trust stated that it objected
to the scheme due to the unsustainable burden that it would place on open space at Twinkle Park
and Charlotte Turner Gardens.
Second Wave Centre for Youth Arts
206 The Community Development Officer for the Second Wave Centre for Youth Arts introduced
the work that the group has done locally with the Crime Reduction Service and Metropolitan Police
in order to support the aims of safer neighbourhoods. Second Wave has also engaged in community
led meetings with the applicant to discuss the social impact of this scheme, and to express the risks
of neglecting the needs of young people in the Deptford area.
207 Second Wave cited an urgent need for long-term training and employment opportunities for
young people in the local area, and also identified demand for new meeting places where young
people can feel comfortable and relaxed. With particular emphasis to the impact on young people,
the group also identified various concerns with the proposed development including: the scale of
development, extent of social inclusion, provision of affordable housing (and actual affordability);
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housing density; sense of ownership of proposed public spaces; masterplan response to heritage
assets (particularly Olympia); increased traffic; and, construction impacts.
208 To assist in the mitigation of the aforementioned impacts Second Wave recommends the
creation of a ‘Neighbourhood Trust’ and ‘Youth Legacy Fund’ to safeguard working partnerships
between developers and the community, and to sustain a positive youth vision of Deptford.
Pepys Community Forum
209 The Pepys Community Forum introduced its role as a not for profit local regeneration
company, and outlined the projects that it runs locally including: Residents Education, Employment,
Training and Advice; and, the John Evelyn Community Garden. The community group provided a
number of comments on the proposal (broadly similar to those previously submitted to Lewisham
Council), and stated that it was concerned with securing maximum inclusive access to community
benefits associated with the proposed Convoys Wharf development. The Pepys Community Forum
provided a copy of its original objection to the scheme, and its proposal for a new community trust
fund (discussed in paragraphs 134 and 135 above). The community group also suggested the
inclusion of space for self-build homes within the masterplan - as a means of delivering a greater
provision of affordable housing.
Crossfields Tenants and Residents Association
210 The Crossfields Tenants and Residents Association stated that it strongly objects to the
application on the following grounds:
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Cultural Strategy - the proposed cultural strategy is commercially driven and based on an
out-dated model that has been shown to create no benefits to the communities. Provision
of affordable workspace is the real issue for Deptford.
Heritage – The site is of international heritage significant and nothing should be built here
until the entire site has been thoroughly excavated. The proposed scheme dose not respond
to the historic significant of the site, and ignores advice from English Heritage, The World
Monuments Fund and The Council for British Archaeology, as well as NPPF guidance and
London Plan heritage policy. The Lenox Project and Sayes Court Garden programme are a
great example of locally specific heritage-led projects – and these should be incorporated in
accordance with the community groups’ wishes.
Scale and massing - these proposed buildings (especially the towers) are too tall and too
large. The proposed density and number of units is also too high. The proposed buildings
are completely out of scale with the surrounding area.
Transport - the cumulative impact of all the redevelopment in the area does not seem to
have been taken into account. As a result, local residents will be subjected to noise,
congestion and pollution. The public transport accessibility level of the site (even after
proposed improvements) is not sufficient for the size of the scheme. Deptford station, local
bus services and the London Underground/Docklands Light Railway are already
overcrowded and the proposal would significantly exacerbate this. Parking pressure from
the proposal will mean that Local residents become forced to pay for permits in Controlled
Parking Zones. There would be a massive increase in construction vehicles on local roads for
at least ten years.
Affordable housing - this scheme now makes very little real contribution, if any, to London’s
housing provision.
211 A blog dedicated to life on the Crossfields Estate also raises similar objections to those set
out above, and indicates support for the Deptford Is petition of objection (refer to paragraph 170).
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Lewisham People Before Profit
212 Lewisham People Before Profit submitted representations raising similar issues to those
discussed in paragraph 141 above. However, particular emphasis was placed on the need for
affordable housing within the scheme to be genuinely affordable to those on the average wage in
the London Borough of Lewisham. The community group also sought the inclusion of lease clauses
to ensure that affordable homes would remain affordable in perpetuity. In addition, the community
group sought a connection to/share in the proposed energy network for Convoys Wharf (linked to
SELCHP and with additional roof mounted renewable technologies) in order to reduce utility bills
for local residents. Furthermore, Lewisham People Before Profit sought a greater commitment to
biodiverse green landscaping, and reiterated its view that the site has significant potential for green
industries. The community group also stated that the gentrification of Deptford is pricing out many
small businesses and creatives.
Regeneration X
213 Regeneration X stated that it objects to the application due to concerns associated with: site
permeability and legibility; inadequate connections to wider Deptford area; failure to recognise and
celebrate the historic nature of the site; internalised/commercialised open spaces; height and lack
of design detail for tall buildings; failure to reflect the John Evelyn legacy through proposed green
spaces; and, risk that new homes would be purchased by foreign investors and left empty.
214 Regeneration X also expressed the view that the application does not comply with Lewisham
Core Strategy Objective 10 (Protect and enhance Lewisham’s character) or Spatial Policy 2
(Regeneration and Growth Areas), and highlighted that the Convoys Wharf site has been placed on
a list of heritage at risk by The World Monuments Fund. Regeneration X also expressed specific
support for the build the Lenox project, on the basis that the proposal would connect the site to
the River Thames in a meaningful way.
London Assembly Member, London wide (Green Party)
215 Darren Johnson, London wide, London Assembly Member, raised an objection to the
application on the basis that the proposed level of affordable housing (15%, 525 affordable homes)
is unacceptably low, and does not adequately respond to local need. This concern was echoed by
Lewisham Green Party.
Neighbourhood representations made to Lewisham Council and/or Mayor of London
216 In response to the local neighbourhood consultation process 98 representations have
currently been received. Of these, 64 were objections (there was also an online petition of
objection with 1,979 signatures at the time of writing this report); 17 were representations of
support; and 7 made comments on the scheme or procedure without indicating specific objection
or support. Table 4 below provides a more detailed breakdown, and all of the corresponding issues
raised are summarised within the overview below.
Overview of all neighbourhood representations
217 Whilst all the representations received have been made available to the Mayor in their
original form, in the interests of conciseness, and for ease of reference within this report, the issues
raised have been grouped by theme and summarised below.
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Objection
Representation
format
Written
representation
Initial
After Mayor
consultation became LPA
22
Petition
Support
Comment
Representation
format
Written
representation
Representation
format
Written
representation
17
Revised plans
consultation
Total objection
25
64
1 petition (1,979 signatures)
1
Initial
After Mayor
consultation became LPA
3
6
Initial
After Mayor
consultation became LPA
4
2
Revised plans
consultation
Total support
8
17
Revised plans
consultation
Total comments
1
7
Table 4: Overview of neighbourhood representations (figures accurate at time of report publication).
Representations of objection
Principle of development (wharf contraction and regenerative mixed use redevelopment)
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loss/reduction of wharf area and loss of employment generating uses;
loss of London’s only heavy-duty roll-on roll-off pier;
lack of proposed traditional industrial employment;
Housing (including affordable housing, residential standards and density)
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more affordable housing (particularly ‘social housing’) should be provided;
the proposed housing would be unaffordable;
the proposed housing would be purchased by foreign investors and left empty;
excessive housing density;
Sustainable communities (including social infrastructure and social inclusion)
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no feasible or sustainable use for Olympia has been proposed;
adverse impact on local infrastructure;
loss of cultural heritage;
greater commitment is needed to community facilities and infrastructure;
a school should be provided on-site;
a school should be provided at a vacant site in the Royal Borough of Greenwich;
facilities for older people are needed (including lunch clubs);
the development would not promote social inclusion;
Design (including urban design and heritage)
 the design is not sufficiently led by the site’s history;
 the height, scale and massing of the outline masterplan is inappropriate, does not reflect
the historic nature of the site and will cause harm to various designated and nondesignated heritage assets (including archaeology and historic buildings);
 the development does not respond to a “group value” Listing which includes the Master
Shipwrights House and Dockyard Office (Grade II*), and the Scheduled Tudor Storehouse;
 the three towers are too tall and there is a lack of detail about their final quality;
 the towers will have an adverse impact on the setting of the Maritime Greenwich World
Heritage Site, strategic views and local views;
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the towers are a fire hazard and have potential for social problems, crime and isolation;
the proposed development is not locally specific to Deptford, or London;
the masterplan does not sufficiently connect and integrate with surrounding areas;
the scale of development is at odds with the surrounding context;
the development lacks human scale;
the design of the scheme is commercially driven;
the scheme may become a gated community;
the proposed open spaces are fragmented and uninspiring;
the external treatments will be generic and industrially prefabricated;
podium car parks would have an unacceptable impact on the streetscene, and would
remove the opportunity for residents to properly engage with the ground;
Thames Path access west from Millennium Quay is unresolved;
lack of green space (the jetty would not improve access to public open space);
the development does not reflect the heritage assets at the site;
more masterplan flexibility should be introduced to accommodate community projects;
the relationship between the River Thames and Olympia is unacceptably restrained;
buildings surrounding Olympia are too large in scale and will harm it’s setting;
the masterplan does not celebrate the mast pond location/archaeology;
the treatment of the Double Dry Dock is unimaginative/and does not adequately reflect its
historic use and importance;
the density should be reduced and more of the archaeology should be revealed;
Environmental issues / neighbourhood amenity
 no use that would harm the environment should be permitted;
 development of this site would reduce Thames floodplain and make other areas more
vulnerable to flooding;
 wharf activity would have adverse impacts on local residents and open space;
 loss of daylight and sunlight and overshadowing to neighbouring properties (particularly at
Decca Street);
 tall buildings would create wind tunnels;
 overshadowing and overlooking at Master Shipwrights House;
 increased neighbourhood noise impact due to intensified use of local parks;
 adverse noise and disturbance impacts (associated with demolition/construction);
 no use that would harm amenity should be permitted;
Transport
 the transport assessment (and associated traffic and parking survey data) is not sufficiently
accurate/fair/representative/robust;
 existing roads are already congested and cannot accommodate extra traffic;
 level of proposed car parking is too high;
 level of proposed car parking is too low;
 there are only 1,840 parking spaces but each resident is likely to own a car even if they use
public transport;
 bus re-routing will result in longer bus journey times and bus overcrowding;
 potential overcrowding on buses and Docklands Light Railway;
 increase to rush hour overcrowding at Deptford station;
 lack of proposed public transport improvements;
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 adverse traffic congestion impacts on residents along Grove Street and New King Street
from increased noise and vibration;
 use of the river bus service has been overestimated and insufficient details and
commitments have been provided;
 rail capacity has been overestimated and the increased use of Deptford Station in recent
years has not been accounted for;
 the reliance on Crossrail to alleviate rail capacity issues is inappropriate;
 cumulative impacts have not been assessed;
 the removal of parking spaces on New King Street unacceptable;
 a controlled parking zone will be unavoidable;
 local roads are in poor condition;
 insufficient parking for construction workers;
 adverse impacts on surrounding residents and child safety as a result of heavy goods
vehicle traffic on local roads;
 insufficient mitigation of highway impacts;
Mitigating the impact of development through planning obligations
 additional employment opportunities are required for local people;
 existing parks and play spaces do not have capacity to accommodate additional residents;
Other issues
 the masterplan does not adequately accommodate community projects;
 existing buildings should be retained, refurbished and reused;
 a playground within the masterplan may preclude re-instatement of a north/south access
route on the west elevation of Master Shipwrights House;
 the masterplan does not consider access or public realm issues associated with emerging
pre-application proposals at Master Shipwrights House site;
 construction impacts on Master Shipwrights House;
 inadequate public engagement/local consultation by the applicant;
 insufficient access to submitted documentation;
 an outline application is not appropriate for this scheme (particularly given tall buildings);
 the detailed first phase should have been submitted in simultaneously;
 the environmental statement relies on information used for a previous iteration of the
scheme;
 insufficient design detail to allow for appropriate special regard when considering the
desirability of preserving the setting of the various Listed Buildings on and adjacent to the
site; and,
 insufficient scope, rigour and detail of the submitted documentation.
Representations of support
Principle of development (wharf contraction and regenerative mixed use redevelopment)
 redevelopment of the site is overdue;
 the development would link to Deptford High Street and bring new visitors/trade to the
High Street;
 the proposal represents a significant regeneration opportunity;
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Mix of uses (including retail and London’s visitor infrastructure)
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improved access to shops, restaurants and new business facilities;
new employment opportunities;
the proposal would generate new tourist opportunities;
Housing
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The development would provide much needed housing;
Sustainable communities (including social infrastructure and social inclusion)
 the development would boost local job creation;
 the development would bring regeneration and community benefits;
Design (including urban design and heritage)
 the proposal represents an opportunity to improve the appearance of the area;
 new public spaces would be provided; and,
 a significant section of the river front (and Thames Path) would be opened up.
Representations of comment
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support for community project: Sayes Court Garden horticultural programme;
support for community project: Build the Lenox project;
the site could be redeveloped to provide a maritime enterprise zone;
query with respect to how a public right of way to the River Thames would be secured;
significant improvement to Thames Path (between Greenwich and Surrey Quays) required;
a more spacious extension of Sayes Court Park should be included to counterbalance the
density of the development;
a cycle/foot bridge to Canary Wharf should be considered;
an additional Dockland Light Railway stop from Cutty Sark should be considered;
it should not be necessary to pay more for riverboat travel (over price of Oyster travel card);
the Cycle Hire Scheme should be extended through to Greenwich;
query on how local employment and training initiatives could be accessed; and,
procedural queries on the Mayor’s representation hearing process, public consultation and
determination timetable.
Response to consultation summary
218 The issues raised by the consultation responses and various other representations received
are appropriately addressed within the material planning considerations section of this report, and,
where appropriate, through the proposed planning conditions, planning obligations and/or
informatives outlined in the recommendation section of this report.
Material planning considerations
219 Having regard to the facts of the case; relevant planning policy at the local, regional and
national levels; and, the consultation responses and representations received, the principal
planning issues raised by the application that the Mayor must consider are:
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220
Principle of development (Opportunity Area, Strategic Site Allocation, safeguarded wharf
contraction/reconfiguration and regenerative mixed-use development);
Safeguarded wharf (including maximising freight use of the Blue Ribbon Network);
Mix of uses (including employment, retail and visitor infrastructure);
Housing (including affordable housing, residential standards and density);
Sustainable communities (including social infrastructure and social inclusion);
Design;
Heritage;
Inclusive design;
Energy;
Environmental issues (including noise and vibration, air quality, river and water resources,
biodiversity, artificial light spill, microclimate, communications infrastructure and cumulative
environmental impacts);
Neighbourhood amenity (including daylight, sunlight, overshadowing, and
privacy/overlooking);
Transport;
Other issues raised during consultation; and,
Mitigating the impact of development through planning obligations.
These issues are considered within the sections which follow.
Principle of development
221 The site falls within the Deptford Creek/Greenwich Riverside Opportunity Area as identified
by London Plan Policy 2.13. London Plan Table A1.2 in support of the aforementioned policy
identifies the area as having an indicative employment generating capacity of 4,000 jobs and the
opportunity to provide a minimum of 5,000 new homes. Table A1.2 also sets out that development
in this location should benefit the concentrations of deprived neighbourhoods across the
Lewisham/Greenwich borough boundary, and capitalise on the historic waterside character of the
area. The Convoys Wharf site is specifically identified as suitable for mixed use redevelopment
within Table A1.2 - subject to the appropriate resolution of wharf related issues.
222 Spatial Policy 2 within the 2011 Lewisham Core Strategy sets out the Council’s vision for
the borough up to 2026, and identifies the area of Deptford New Cross as one of a number of key
Regeneration and Growth areas. The Deptford New Cross area is expected to accommodate up to
2,300 additional new homes by 2016, and a further 8,325 additional new homes by 2026. This
planned housing growth is also expected to be paired with a significant increase in new business
and employment generating floorspace.
223 Spatial Policy 2 also specifically identifies the Convoys Wharf site as one of a number of
strategic sites with the potential to be a wider regeneration catalyst for Deptford. Strategic Site
Allocation 2 (SSA2) within the Core Strategy provides a number of site specific polices for Convoys
Wharf. Collectively, these seek to ensure that redevelopment of the site would not prejudice wharf
operation, and would deliver key regeneration aims for Deptford, and the wider borough, by
making a major contribution to housing provision, employment opportunities and community
facilities. SSA2 also sets out a number of key design objectives for the site, and promotes the
creation of a new destination on the Thames riverfront.
224 Also relevant in this case is Core Strategy Policy SSA1, which seeks the submission of a
detailed first phase in tandem with any outline masterplan application for a designated strategic
site. However, it is noted that in this case only an outline masterplan has been submitted.
Notwithstanding this, having considered the nature of the proposed outline parameters (which
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reasonably specify details of layout, scale and access); the indicative detail of the illustrative
masterplan (a material consideration when assessing subsequent reserved matters applications);
and, the good practice design principles embedded within the submitted Design Guidelines
document (discussed in the housing and design sections of this report), GLA officers are of the
view that the submitted material suitably addresses the core objectives of Policy SSA1.
Furthermore, officers are satisfied that there is appropriate detail to adequately assess the
proposed outline masterplan against all relevant planning policies, and that the application (subject
to various necessary planning conditions and obligations) would provide the necessary assurance
that future detailed phases would come forward in a way which would result in a high quality
design outcome, and a sustainable form of development.
225 Accordingly, having had regard to relevant considerations with respect to the safeguarded
wharf, mix of uses and design (discussed within the associated sections of this report), GLA officers
are of the view that the proposal to provide a reconfigured working wharf as part of a wider outline
masterplan to deliver up to 3,500 new homes a wide range of uses (including up to 15,500 sq.m. of
new employment space in addition to that proposed for the wharf) responds positively to the local
and strategic policy context set out above.
Principle of development - conclusion
226 The future operation of a working wharf at this site has been suitably secured (refer to the
safeguarded wharf section below), and the proposed comprehensive mixed use redevelopment at
this site will provide valuable homes and jobs to catalyse the regeneration of Deptford. Accordingly,
the principle of mixed use redevelopment at this site is strongly supported in accordance with the
NPPF; London Plan Policy 2.13; and, Core Strategy policies SP2, SSA1 and SSA2.
Safeguarded wharf
227 A 9.1 hectare portion of the site (approximately 55% of the total site area) is currently
designated as a safeguarded wharf. London Plan Policy 7.26 affords safeguarded wharfs strategic
protection for waterborne freight uses, and states that their redevelopment for other land uses
should only be accepted if the wharf is no longer viable (or capable of being made viable) for
waterborne freight handling. London Plan paragraph 7.77, in support of Policy 7.26, sets out
various critical factors which influence safeguarded wharf viability.
228 As discussed in paragraph 8, the wharf at the site is not currently in use. Nevertheless, the
2005 Safeguarded Wharves Implementation Report identifies Convoys Wharf as having a number of
favourable wharf characteristics, and being viable for a range of cargo-handling uses (particularly
green industry operations). The 2005 Report recommends continued safeguarding of the wharf,
and promotes a future role for the site orientated around river freight operations. Further to this,
the Mayor’s draft Safeguarded Wharves Review also notes that positive characteristics associated
with the position of Convoys Wharf on the Thames (refer to paragraph 230) mean that it remains
viable for a range of cargo-handling uses. Notwithstanding this, the draft review also acknowledges
that a reduction in the safeguarded area is proposed as part of planned development proposals for
the site. It is also noted that both the London Plan (Table A1.1) and Lewisham Core Strategy
(Policy SSA2) broadly support reconfiguration and reactivation of the safeguarded wharf as part of
a comprehensive mixed use approach to redeveloping this site.
229 It is also worthy of note that the Mayor has previously expressed the view that the release of
some safeguarded wharf land at this site is acceptable in principle - given that wharf use across the
full safeguarded area at the site would result in unacceptable impacts on neighbouring residential
areas.
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Existing wharf characteristics
230 The existing site represents the closest safeguarded wharf to the eastern side of central
London, and has a number of other favourable characteristics including a deep river berth and
various existing jetty structures. The wharf’s current configuration provides a large expanse of river
frontage, and a regular rectangular shape for flexible operation. These characteristics mean that the
wharf is potentially attractive to a wide range of cargo types and river freight operators.
231 Notwithstanding this, the wharf is in close proximity to existing residential development on
all of its landward sides, and road infrastructure between the site and the Strategic Road Network is
constrained - being generally of a residential scale and character. This existing context is
particularly sensitive to environmental impacts (such as noise, dust, air pollution and heavy goods
vehicle traffic), and this places a reasonable limitation on the potential scale of wharf operations at
the site. Accordingly, GLA officers are of the view that a reduction in operational wharf area at this
site is justified.
Proposed wharf contraction and reconfiguration
232 To support its proposal for safeguarded wharf contraction and reconfiguration, the applicant
has submitted a Marine Terminal Assessment. The assessment has been developed in response to
wharf-related issues previously raised by the GLA and Port of London Authority, and both parties
were invited to comment on the brief for the assessment, and to observe interviews with potential
wharf operators.
233 The outline application proposes a 71% contraction in the area of safeguarded wharf at the
site - from 9.1 hectares to 2.3 hectares (plus a new jetty structure of 0.3 hectares). The wharf is
proposed to be positioned at the northwest edge of the site (at masterplan plot 21), with the
reconfigured boundary offering good frontage onto the riverfront, but a slightly irregular dogleg
shape (induced by the site’s boundary with the Pepys Estate) towards the rear (western end) of the
wharf area. The development plot floorspace schedule also specifies that the wharf plot could
accommodate up to 32,200 sq.m. of built floorspace for industrial/wharf-related Class B2 uses.
234 As set out in the response to consultation section of this report, the Port of London
Authority (PLA) does not object to the proposed reduction in the physical extent of the wharf, or
its relocation to the northern end of the site. However, the PLA expresses the view that the
proposed shape and dimensions of the wharf may not be optimal in terms of providing maximum
flexibility for potential occupiers, and that the quantum of floorspace proposed at masterplan plot
21 may threaten the viability of the working wharf.
235 When considering these concerns GLA officers have been mindful of the general desirability
of this location for wharf operations (particularly given its proximity to central London relative to
other safeguarded wharves to the east), and the fact that at least two potential operators (Brett
Group and Redresco) have confirmed that the wharf shape would be suitable for their respective
operational requirements. With respect to the proposed provision of Class B2 floorspace, GLA
officers acknowledge that this represents a maximum, and depending on the actual quantum that
would be delivered at the plot, it may be stacked to some extent above the ground floor. Past
practice suggests that floorspace above ground level is likely to be ancillary office type floorspace
rather than operational cargo handling, however, GLA officers are of the view that this would be
complementary to the primary operation of the wharf, and could enhance, rather than undermine,
wharf viability. Furthermore, subject also to the operational specifications of future wharf occupiers,
there is potential for such multi-level employment generating floorspace to be laid out so as to
offer a buffer to neighbouring sensitive uses – thereby protecting local amenity and safeguarding
wharf operations at the same time.
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236 Having regard to the considerations above, GLA officers are satisfied that the proposed
wharf location, plot boundary, and associated maximum floorspace quantum would provide a viable,
flexible and commercially attractive environment for a range of potential river freight operators.
Wharf activation and increasing the use of the Blue Ribbon Network for freight
237 The PLA seeks assurance that a permanent wharf would be provided and be operational at
the site before development phase three commences. In addition to this, both the GLA and PLA
have sought to ensure that temporary/interim operations ensure that wharf activation takes place
as soon as reasonably possible within the overall development programme, and that the wharf is
used to its full potential in terms of handling capacity and throughput. Notwithstanding this
position, when negotiating on wharf activation matters GLA officers have also been mindful of the
potential of the wharf to offer temporary accommodation for a local heritage-led community
project - Build the Lenox (refer to paragraph 241 below). Relevant considerations associated with
wharf activation for temporary construction logistics; and, through future use by wharf operator, is
set out below.
Wharf activation for temporary construction logistics
238 Notwithstanding the applicant’s commitment to utilise river freight opportunities for
construction logistics from the first delivery phase (utilising existing jetty infrastructure at the site),
the phasing plan indicates that the proposed wharf area will be activated during delivery phase two.
Commentary within the submission documents confirms that use of the wharf is proposed to
commence from the middle/end of phase two, through into phase three. Whilst earlier activation of
the wharf would be supported by London Plan Policy 7.26, GLA officers acknowledge that the
deferral of activation to phase two provides a useful opportunity to accommodate any temporary
community use of this space, and also offers additional flexibility with respect to scheme cash flow
and delivery of the operational infrastructure necessary to support operations at the wharf.
239 In accordance with the principles of London Plan Policy 7.26, GLA officers propose to
secure the provision and implementation of a construction logistics plan through the section 106
legal agreement, in order to ensure timely activation of the wharf as part of a wider strategy for
maximising the sustainable transportation of construction and demolition materials via the Blue
Ribbon Network.
Securing future use by a wharf operator
240 In addition to the temporary use of the wharf for construction logistics (and subject to
feasibility with respect to operator requirements) the applicant is keen to facilitate other
simultaneous interim river cargo uses at the site - until the wharf can be made available for
permanent use by one or more wharf operators. Section 7 of the Marine Terminal Assessment sets
out the applicant’s proposed strategy for securing wharf operators, and identifies a programme that
would allow an operator to commence construction of necessary buildings by the end of phase two.
The approach proposed includes a detailed marketing strategy, competitive rental and lease
arrangements, consideration of operator specific requirements (including necessary mitigation
measures), and consultation with relevant authorities. The applicant has also proposed a legal
mechanism (related to a restriction on the occupation of private residential units) in order to ensure
that the developer is reasonably compelled to secure a wharf operator. Having regard to this
proposed approach, GLA officers propose to use the section 106 agreement to secure an
appropriate programme for wharf activation, along with a financial contribution of £7,239,000 for
enabling infrastructure at the wharf.
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Potential temporary wharf use for Lenox community project
241 As part of its engagement with local community stakeholders, and in conjunction with GLA
officer advice, the applicant has made an offer to The Lenox Project CIC, proposing an agreement
to allow the community group temporary use of the wharf for its heritage-led shipbuilding project.
GLA officers acknowledge that such a use would not comply with London Plan Policy 7.26 (which
seeks to ensure that safeguarded wharves are only used for waterborne freight handling uses),
however, having had regard to the temporary nature of the shipbuilding, and the public benefits
associated with the project (including recognition of Deptford’s unique maritime heritage and
generation of valuable new local employment and training opportunities), GLA officers broadly
support the applicant’s proposed offer. (Other issues associated with the Build the Lenox Project
are considered in detail within the community projects section of this report).
Mitigating impacts associated with wharf operation
242 Whilst various river freight operators have indicated a potential interest in occupying
masterplan plot 21, the eventual end user of the wharf is not yet known. The Marine Terminal
Assessment identifies that the most likely wharf operation for the site is the importation of dry bulk
goods, however, the assessment confirms that other cargoes may be considered as long as their
environmental impacts can be acceptably managed. In this regard the Environmental Statement
identifies that, for the purposes of assessing environmental impacts (and in particular noise), the
worst-case scenario is a combination of an aggregates handling facility and a glass recycling plant.
243 As discussed in the housing section of this report, GLA officers have sought to secure
inherent mitigation for the sensitive uses proposed at the site - in order to jointly safeguard wharf
operations and the amenity of new occupiers adjacent to plot 21. However, having regard to the
existing context of the site (which includes residential dwellings and public open space in close
proximity), and whilst not wishing to unduly constrain wharf operations, GLA officers consider it
necessary to seek reasonable controls to safeguard neighbourhood amenity with respect to
environmental impacts associated with future wharf operations. Accordingly a planning condition is
proposed requiring details of the operational nature and associated noise, air quality and odour
control measures to be approved prior to the commencement of development at plot 21.
Managing safeguarding designation
244 If planning permission is granted and the development is to be implemented, the Mayor
would, in due course, be advised to seek a formal revision of the safeguarded wharf designation at
the site. Proposals for such a review could be managed as part of the Mayor’s normal wharf review
process, or, potentially, as a standalone case for consideration by the Secretary of State. It is worth
noting that the direction made by the Secretary of State only requires the referral of planning
applications on the wharf to the Mayor, and, therefore, does not preclude implementation of an
approved planning application (even where some or all of the development contains land uses that
do not comply with wharf-related planning policy).
Safeguarded wharf – conclusion
245 Having regard to the characteristics of the site and its context, and the critical factors
influencing wharf viability (as outlined within London Plan paragraph 7.77), GLA officers are
satisfied that the proposed contraction and reconfiguration of the safeguarded wharf at the site is
acceptable, and that the proposed wharf location, plot boundary, and associated maximum
floorspace quantum would provide a viable, flexible and commercially attractive environment for a
range of potential river freight operators. Necessary assurances are in place to secure the
appropriate use of the Blue Ribbon Network for construction logistics, and measures to reasonably
page 61
incentivise uptake of the wharf by one or more suitable operators are to be included within a
section 106 legal agreement. Furthermore, subject to the inclusion of planning conditions to
protect neighbourhood amenity, GLA officers are satisfied that the potential impacts of the working
wharf on sensitive uses could be suitably mitigated. Accordingly, the application is supported in line
with the NPPF; and, London Plan Policy 7.26.
Mix of uses
246 In accordance with both local and strategic policy aspirations for this site, the outline
application proposes a wide range of uses in addition to the reconfigured wharf. With the
exception of residential and community uses (considered respectively in the housing and
sustainable communities sections of this report) the proposed mix of uses includes up to: 15,500
sq.m. of business space; 5,810 sq.m. of retail, financial and professional services; 4,520 sq.m. of
restaurant/cafe and drinking establishments; and, 27,070 sq.m. of hotel floorspace. Relevant
considerations with respect to the proposed provision of these uses is set out below.
Employment
247 Lewisham Core Strategy Policy SSA2 seeks to secure at least a 20% provision of Use Class
B1(c), B2 and B8 business space at Convoys Wharf (excluding the safeguarded wharf area) as
appropriate to the site and its wider context.
248 Depending on which energy strategy option is ultimately adopted (refer to the energy
section of this report) the masterplan would provide up to 15,500 sq.m. of business space for Use
Class B1 employment and/or live work space (equivalent to approximately 4% of the proposed
development floorspace). Based on detail within the planning statement it is clear that the
employment space offer is likely to be targeted mainly at small and medium sized businesses within
the creative sector. This form of employment role is likely to represent a departure from the
general industrial type of employment uses promoted for the site by Policy SSA2. However, GLA
officers are of the view that, in conjunction with the applicant’s commitment to deliver subsidised
work space for start-up businesses (refer to paragraph 518), the nature of the employment space
proposed has significant potential to nurture fledgling enterprises in the local area. Accordingly,
GLA officers support the proposed nature of the employment offer on the grounds that it would
positively contribute towards the wider regenerational characteristics of the scheme, and catalyse
the form of urban renewal envisaged for Deptford by Lewisham’s Core Strategy.
249 Whilst it is noted that, at 4%, the proposed provision of employment floorspace is
considerably lower than that sought by Policy SSA2, GLA officers are of the view that the type of
business space proposed has the potential to deliver higher employment densities than the more
traditional B Class uses that the policy promotes. Furthermore, when the floorspace of other
proposed uses with employment generating potential is taken into account, officers note that the
level would reach about 20%. Based on estimates provided by the applicant, the scheme is
expected to generate 2,150 operational jobs and up to 1,200 construction jobs.
250 Accordingly, GLA officers are of the view that whilst the proposed nature and provision of
the employment generating floorspace within the application would not accord with that
prescribed by part 1(b) of Core Strategy Policy SSA2, the scheme would successfully deliver the key
objectives of: transforming the physical, social and economic fabric of this part of Deptford; and,
supporting the development of commercial activity in the area (including the opportunity for
continued wharf-related activities and the creative sector) - as set out by paragraphs 8.13 and 8.14
in support of Policy SSA2. GLA officers therefore support the employment offer proposed within
the scheme.
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Retail
251 As discussed above, the applicant proposes to provide up to 5,810 sq.m. of retail, financial
and professional service floorspace, and up to 4,520 sq.m. of floorspace for restaurant/cafe and
drinking establishments. Detail within the submission documents indicates that this provision has
been principally designed to serve the needs of new on-site residents and employees, whilst also
taking into account visitors drawn to the scheme’s culture, leisure, entertainment and tourism
offer. With respect to the retail component, the provision is proposed to include a locally-scaled
convenience offer of approximately 1,200 sq.m. (to include a local supermarket of not more than
800 sq.m.), provision of a number of high value small comparison goods shops (approximately
3,510 sq.m.), and various other retail/financial services (approximately 1,100 sq.m.). As part of the
comparison goods offer it is proposed to provide a number of specialist shops and stalls within the
Olympia building.
252 London Plan Policy 4.7 supports the delivery of additional retail and commercial floorspace
in order to support London’s established hierarchy of town centres. This policy applies a ‘town
centre first’ approach to commercial development, and states that when assessing related proposals
regard should be had to a number of criteria including the scale of the proposed commercial offer
relative to the size, role and function of the relevant town centre. Policy 4.7 also states that retail
proposals at the edge (or outside) of town centres will be subject to an assessment of impact.
253 Convoys Wharf lies outside the boundary of Deptford district town centre, and
approximately 400 metres from the main shopping core of the high street. However, the site
benefits from a direct relationship with the town centre via a key route and pedestrian desire line to
Deptford High Street and Deptford rail station (via New King Street). This relationship is recognised
by Lewisham Core Strategy Policy SSA2, which identifies the Convoys Wharf site as suitable for
retail uses to serve local needs; and, a mix of restaurant and food and drink uses to serve residents
and visitors at the site. The intention of this allocation is to deliver new retail/commercial provision
at the Convoys Wharf site in order to complement the offer of Deptford town centre (including
Deptford Market) and other neighbourhood parades (such as at Evelyn Street Triangle). Policy
SSA2 nevertheless makes clear that it will be necessary to demonstrate that such provision would
not adversely impact on the vitality and viability of established centres.
254 In accordance with the requirements of London Plan Policy 4.7 and Core Strategy Policy
SSA2, the applicant has submitted a Retail Impact Assessment. The assessment concludes that,
subject to the inclusion of a number of proposed planning conditions, there would be no significant
impact on local centres. In order to verify these findings Lewisham Council has commissioned an
independent review of the applicant’s assessment. The findings of this review have been made
available to the GLA, and officers note that there is broad agreement on all key conclusions.
Notwithstanding this, the independent review makes a number of recommendations to modify the
detail of a number of conditions in order to provide greater assurance with respect to the delivery
and control of retail floorspace. In particular, it is recommended that a restriction period for
occupation of any future market at Convoys Wharf by existing tenants at Deptford Market is
extended from two years to three. This control is intended to protect the vitality of Deptford
Market, by ensuring that any new market at the site establishes itself in a complementary way,
rather than potentially drawing stallholders away from the existing provision within the town centre.
The applicant has agreed to the relevant recommendations made by the independent retail review,
and GLA officers propose to secure the necessary retail controls by way of planning condition.
Accordingly, the proposed provision of retail/commercial uses is supported in accordance with the
aims of London Plan Policy 4.7 and Lewisham Core Strategy Policy SSA2.
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Visitor infrastructure
255 London Plan Policy 4.5 seeks to support London’s visitor economy through a significant
increase in hotel provision in appropriate locations such as town centres and Opportunity Areas. In
this case the applicant proposes up to 27,070 sq.m. of hotel floorspace to be provided between
masterplan plots six and sixteen. This is likely to provide up to 300 hotel bedrooms, in conjunction
with ancillary uses (including restaurant, conference facilities, meeting rooms and gymnasium)
which will culminate in a package of visitor infrastructure that has significant potential to capitalise
on the site’s proximity to the Thames riverside, as well as neighbouring regional centres for
business, heritage and culture. GLA officers are of the view that such provision would complement
the wider commercial offer within the scheme, and would significantly boost the visitor economy
within Deptford town centre. Accordingly, the provision of hotel use as part of the wider
regenerative mixed use strategy for this Opportunity Area site is supported in line with London
Plan Policy 4.5.
Securing a mix of uses
256 Within its representations on the case, Lewisham Council has highlighted that floorspace
totals within the development schedule exceed maximum caps set across the outline masterplan on
a plot by plot basis. The applicant states that it has adopted this approach in order to provide a
degree of flexibility with respect to the eventual distribution of compatible uses within each
masterplan plot. Accordingly, whist acknowledging that it is the applicant’s intention to deliver a
genuinely mixed use scheme, the Council has sought assurance that these uses (and particularly
the employment space) would be delivered at reserved matters stage.
257 In order to address this issue, a planning condition is proposed to secure reasonable
minimum floorspace provisions for various specified uses across the masterplan development
schedule. A further condition is proposed to secure submission of a Reconciliation Document at
each reserved matters stage - to clearly set out: what has been built to date; what has reserved
matters approval (but is unbuilt); what is proposed as part of the associated reserved matters
application; and, what has outline approval but is yet to be approved in detail. Accordingly, GLA
officers are satisfied that the provision of a mix of uses will be secured and tracked throughout the
scheme delivery programme.
Mix of uses conclusion
258 The outline application provides a wide range of uses in accordance with local and strategic
policy aspirations for this Opportunity Area site. Whilst the proposed nature and provision of
employment generating floorspace within the scheme does not strictly accord with that prescribed
by part 1(b) of Core Strategy Policy SSA2, the scheme would, nevertheless, deliver significant new
local employment opportunities and successfully achieve key employment related Core Strategy
objectives for this site in terms of transforming the economic fabric of this part of Deptford and
supporting the development of commercial activity with respect to wharf-related activities and the
creative sector. The retail component of the scheme has been designed to complement existing
provision at Deptford town centre (including Deptford High Street and Deptford Market) and,
subject to reasonable controls, will positively contribute towards a vibrant and diverse local
economy. Furthermore, the inclusion of hotel provision within the scheme as part of the wider
regenerative mixed use strategy for this site will allow the scheme to capitalise on its riverside
Opportunity Area setting, and significantly boost the visitor economy within Deptford. Accordingly,
the application is supported in line with the NPPF; London Plan policies 4.5 and 4.7; and,
Lewisham Core Strategy Policy SSA2.
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Housing
259 The outline application proposes up to 321,000 sq.m. of residential floorspace, which may
be delivered as up to 3,500 new homes. This provision is equivalent to two and a half times the
emerging minimum annual housing target for the London Borough of Lewisham (as set out within
the draft Further Alterations to the London Plan), and is strongly supported in line with London
Plan Policy 3.3 - which seeks to increase housing supply in the capital.
260 Table 5 below sets out the revised indicative residential mix for the masterplan. Whilst the
outline proposal is effectively for a range of provision across each dwelling type (as indicated in
brackets), a numeric provision (as set out within the Environmental Statement Addendum) is
provided as an illustrative benchmark.
Dwelling type
One-bedroom
Two-bedroom
Three-bedroom
Four-bedroom
Total
Private market
units
1,279
(40-45%)
1,250
(40-45%)
357
(10-14%)
89
(2-4%)
2,975
Affordable rent
units
32
(18-23%)
63
(38-43%)
52
(27-33%)
11
(2-7%)
158
Intermediate
affordable units
103
(25-30%)
257
(65-74%)
7
(1-6%)
0
(0%)
367
Total
1,414
(35-45%)
1,570
(42-48%)
416
(10-14%)
100
(2-4%)
3,500
Table 5: Revised indicative residential provision by dwelling type.
Affordable housing
261 The NPPF seeks to significantly boost the supply of housing in a way which would meet
objectively assessed needs for market and affordable housing. London Plan Policy 3.12 seeks to
secure the maximum reasonable amount of affordable housing on schemes which include private
market residential development, and this approach is reflected within Lewisham Core Strategy
Policy 1 - which sets a strategic target of 50% affordable housing delivery across the borough
(subject to an assessment of financial viability).
262 The proposed residential mix would achieve a 15% provision of affordable housing,
equivalent to 525 new affordable homes. Whilst this undoubtedly represents a valuable
contribution to local housing provision, the level of provision is well below the Council’s strategic
target of 50%. However, in accordance with the principles of London Plan Policy 3.12 and Core
Strategy Policy 1, the applicant has submitted a financial viability assessment of the scheme, with
the intention of demonstrating that the proposed provision represents the maximum reasonable
amount that the scheme can afford.
263 The applicant’s assessment concludes that with the proposed 15% provision of affordable
housing, and after relevant scheme costs (including Mayoral CIL and planning obligations) and
income streams (including property sales values at current market levels) have been taken into
account, the scheme (whilst registering a low-level return) would be well below what would
normally be considered to be a reasonable development profit. Notwithstanding this, the applicant
has stated that it is willing to progress the proposed scheme, in the hope that sales values will
improve over the course of the project.
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Scrutiny of the applicant’s viability position
264 Lewisham Council and the GLA have both commissioned respective independent reviews of
the applicant’s viability assessment. The Council’s review commenced whilst it was the Local
Planning Authority, and initial findings/queries arising from this were subsequently incorporated
within the assessment brief for the review commissioned by the GLA.
265 Viability negotiations have taken place as part of joint discussions between the applicant,
and planning officers from Lewisham Council and the GLA. Whilst there is broad agreement from
all parties with respect to the overall viability position, Lewisham Council sought particular scrutiny
of a number of points in line with its consultant’s advice, including: land value assumptions (given
the introduction of the Mayoral CIL); market sales values; and, the effect of applying reasonable
growth assumptions in line with financial viability guidance provided by the Royal Institution of
Chartered Surveyors.
266 The independent review commissioned by the GLA concluded that the given land value was
appropriate, but that assumptions for both build costs and sales values should be revised upwards
somewhat. Through modelling of the impact of these adjustments on the finances of scheme, it
has been demonstrated to GLA officers that the development profit would still be well below a
reasonable rate of return under current market conditions. Accordingly, officers conclude that the
proposed 15% provision of affordable housing does indeed represent the maximum reasonable
amount at this point in time.
267 Notwithstanding this, given the scale of the development and duration of the delivery
programme, all parties recognise the potential for future growth to enhance sales values, and to
improve the ultimate viability and profitability of the scheme. Accordingly, it has been agreed to
incorporate a review mechanism as part of the section 106 legal agreement to trigger a further
financial review at appropriate milestones along the delivery programme (refer to paragraph 519).
In this way, once an agreed profit benchmark is met, it will be possible to capture a reasonable
proportion of any uplift in sales values – in order to fund the delivery of additional affordable
housing.
Affordable housing - conclusion
268 On the basis of the above, GLA officers are satisfied that the proposed 15% provision of
affordable housing is the maximum that the scheme can afford under current market conditions,
and that a financial review mechanism will ensure that the scheme continues to deliver the
maximum reasonable amount of affordable housing over the lifetime of its delivery. Accordingly,
the application accords with the NPPF; London Plan Policy 3.12; and Lewisham Core Strategy
Policy 1.
Affordable tenure split
269 London Plan Policy 3.9 seeks to promote communities that are mixed and balanced in
terms of tenure, and ensure that large scale developments foster social diversity, redress social
exclusion and strengthen communities. To assist with the delivery of these objectives London Plan
Policy 3.11 seeks a strategic tenure split of 60% social/affordable rent and 40% Intermediate.
Lewisham Core Strategy Policy 1 reinforces these principles, whilst applying a respective boroughwide tenure split of 70%/30%. This local policy also notes that where a site falls within an area
which has existing high concentrations of social rented housing, any affordable housing
contribution will be sought in a way which assists in securing a more balanced social mix.
270 As set out within table 5, the indicative mix within the proposed outline application
provides a tenure split of 30% affordable rent and 70% intermediate. This does not accord with the
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strategic tenure splits sought by local or regional policy, however, having considered the local
context (2011 census data indicates that, within the Evelyn ward, 57% of households are social
rented and 3.5% are intermediate), GLA officers are satisfied that the proposed tenure split will
support the creation of a more balanced community in accordance with the associated aims of
London Plan Policy 3.9 and Core Strategy Policy 1.
Mix of units
271 London Plan Policy 3.8 promotes delivery of a genuine choice of new homes of different
sizes and types and London Plan Policy 3.11 accords specific priority to the provision of affordable
family housing. Lewisham Core Strategy Policy 1 states that developments of more than ten units
will be expected to provide family housing, and in the case of affordable housing, 42% should be
provided as family dwellings subject to relevant contextual considerations.
272 When considering the residential schedule within table 5 it is clear that on the whole the
scheme would provide a good range of residential unit typologies - including three and four
bedroom units within both the private market and affordable components of the housing mix.
However, it is recognised that the balance of the mix is weighted heavily towards one and two
bedroom units (particularly within the private market component). With respect to the affordable
component, the scheme proposes a 13% provision of family housing. This considerably short of the
Core Strategy target discussed above, however, it is recognised that following the submission of
revisions (discussed in paragraph 50), the applicant has agreed to provide an increased provision of
affordable rented units relative to intermediate units, and an increased provision of family-sized
affordable rented units (at the expense of family sized intermediate units). This rebalancing of the
residential schedule allows for up to 40% of the proposed affordable rent units (up to 63
dwellings) to be delivered as three or four bedroomed family sized dwellings – ensuring that the
scheme would deliver a higher proportion of affordable rented family housing for Deptford.
273 Having considered the above, and the viability position set out within the affordable
housing section, GLA officers are content that the proposed housing mix accords with the key
objectives of London Plan policies 3.8 and 3.11 and Lewisham Core Strategy Policy 1.
Residential standards
274 Policy 3.5 within the London Plan seeks to ensure that housing developments are of the
highest quality internally, externally, and in relation to their context and to the wider environment.
Table 3.3, which supports this policy, sets out minimum space standards for dwellings. The Mayor’s
Housing SPG builds on this approach, and provides further detailed guidance on key residential
design standards including unit to core ratios, and the need for developments to minimise single
aspect dwellings (particularly those that are three-bedroom, north facing or exposed to an
increased level of noise). Lewisham Council also has its own supplementary planning document
which specifies various local residential design standards.
275 The applicant has had regard to local and regional design standards when developing the
proposal, and clearly states its commitment to delivering a high quality residential environment within
the Planning Statement. In particular, the expressed intention to exceed minimum space standards
were possible is supported. Whilst it is not possible to undertake a full assessment of the proposed
residential quality at outline stage, GLA officers have, nevertheless, sought assurance that the building
parameters would allow for the proposed dwellings to be delivered in a way which would meet or
exceed the minimum space standards within London Plan Policy 3.5, and broadly conform with the
best practice residential design principles of Mayor’s Housing SPG.
276 To this end the applicant has used the Design and Access Statement and Design Guidelines
submission documents to provide illustrative representations of the residential typologies and layouts
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that could be achieved within the proposed parameters, and to enshrine a set of good practice design
principles to be applied when working up the future detailed phases. It is noted that studies of all of
the key residential typology variants within the scheme have been undertaken (courtyard block, semiopen courtyard block, linear block, and tower block), and having reviewed these GLA officers note
that it would be possible to achieve the key aims of minimising single aspect units and ensuring that
residential cores would not be overloaded. Good practice principles within the Design Guidelines will
also ensure that residential ground floors across the scheme will be activated through frequent use of
entrances, and that appropriate levels of private and communal amenity spaces could be provided.
Furthermore, officers note that the adjusted orientation of the masterplan grid for the site (compared
to previous iterations of the scheme) will significantly reduce the number of units within the
development that would face due north.
277 Compliance with London Plan minimum space standards is proposed to be secured by way of
planning condition, and, subject to the inclusion of appropriate conditions to mitigate environmental
impacts associated with wharf operations (discussed in the safeguarded wharf, residential amenity and
environmental issues sections of this report) GLA officers are satisfied that the residential design of
the detailed phases will come forward in broad accordance with relevant local and regional residential
design guidance. The application therefore accords with London Plan Policy 3.5.
Residential amenity
278 As set out within the Mayor’s initial representations on this application, and views separately
expressed by the PLA, it is apparent that the proposed residential blocks adjacent to the working
wharf will require particularly careful design in order to provide a high quality residential environment,
and avoid any potential conflicts of use. These blocks are to be delivered during the final phase, by
which time a permanent wharf operator is expected to be in place. Whilst this interface is likely to
present a number of challenges, it is by no means without precedent. Accordingly, based on past
practice, GLA officers are of the view that it should be possible to provide a good quality residential
environment and acceptably mitigate the environmental impact of wharf activities using appropriate
design and construction techniques. To this end, GLA officers propose a planning condition to secure
appropriate insulation of noise and vibration (to be discharged prior to the occupation of the relevant
blocks) in accordance with the aims of London Plan Policy 7.15, and Lewisham Core Strategy Policy 4.
Appropriate controls on wharf operations are also proposed to be secured (as discussed in paragraph
242 above), and further detailed inherent mitigation measures for the proposed residential blocks may
be designed and secured (as required) at reserved matters stage.
Children’s play space
279 London Plan Policy 3.6 seeks to ensure that children and young people have safe access to
good quality, well-designed, secure and stimulating play and informal recreation provision. Using
the residential mix presented in table 5 above, the Environmental Statement addendum assumes an
expected child population of 566 for the development. Based this figure, the methodology within
the Mayor’s Shaping Neighbourhoods: Play and Informal Recreation SPG (2012) indicates that the
development would need to make provision for 5,660 sq.m. of children’s play and informal
recreation space on-site.
280 Whilst it is not possible to undertake a full assessment of the proposed play strategy at outline
stage, GLA officers have, nevertheless, sought assurance that the masterplan could deliver the 10
sq.m. per child provision of children’s play space sought by the Mayor’s SPG. Details within the Design
and Access Statement and Design Guidelines demonstrate that the scheme could exceed the necessary
provision of children’s play though proposals for various on-site paces totalling 17,534 sq.m.
(including doorstep play, semi-private communal courtyards and other playable space within the
public realm). In addition to this a range of off-site provision (totalling 13,633 sq.m.) is also identified
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as having potential to respond to the needs of older children within the development. This would
comfortably exceed the space requirements of the Mayor’s Play and Informal Recreation SPG, and
with reference also to a secured planning obligation to mitigate intensified use of local open space
(refer to paragraph 521) GLA officers are satisfied that the scheme would make an appropriate
provision of children’s play space in accordance with London Plan Policy 3.6.
Density
281 Given the characteristics of the location (discussed in the site description section above),
GLA officers have classified the context as urban in character. Accordingly, having also had regard
to the jointly proposed transport interventions (expected to achieve a public transport accessibility
level of up to three for this site), the London Plan density matrix (Table 3.2 in support of London
Plan Policy 3.4) suggests a residential density of between 200 to 450 habitable rooms per hectare,
or, 70 to 170 units per hectare for this development. Lewisham Core Strategy Policy SSA2 does not
specify a particular residential density range for this site, but identifies Convoys Wharf as having an
indicative residential capacity of up to 3,500 units.
282 The outline masterplan would deliver up to 3,500 units, and detail within the submitted
planning statement confirms that the proposed residential density is 211 units per hectare, or, 585
habitable rooms per hectare (when assessed on a side-wide basis). This is above the range
identified by the London Plan, and GLA officers note that when account is taken of the mixed use
nature of the scheme (including the 2.3 hectare land allocation for the wharf) plot densities within
the masterplan will considerably exceed this site-wide figure. However, having had regard to the
consideration in this report with respect to: residential standards; residential amenity; children’s
play space; design (including urban design and heritage); and, neighbourhood amenity, GLA
officers are of the view that the proposed density would optimise the residential potential for this
Opportunity Area site, and accord with the objectives of London Plan Policy 3.4 and Core Strategy
Policy SSA2.
Housing conclusion
283 The proposal would optimise the residential potential of this Opportunity Area site and
make a significant contribution to housing and affordable housing delivery in Lewisham. The
financial viability position has been independently verified and, subject to the inclusion of a review
mechanism within the section 106 legal agreement, the scheme will continue to deliver the
maximum reasonable amount of affordable housing over the lifetime of the delivery programme.
The housing schedule responds to the need to support mixed and balanced communities, provides
a good variety of dwelling sizes, and appropriately prioritises affordable family housing within the
wider residential mix. The scheme is also capable of achieving good practice residential design and
amenity standards, and exceeding children’s play and minimum space standards. Accordingly, the
proposed housing provision is strongly supported in accordance with the NPPF; London Plan
policies 3.3, 3.4, 3.5, 3.6, 3.8, 3.9, 3.11, 3.12 and 7.15; and, Lewisham Core Strategy policies 1, 4
and SSA2.
Sustainable communities
284 The London Plan defines sustainable communities as “Places where people want to live and
work, now and in the future; that meet the diverse needs of existing and future residents, are
sensitive to their environment and contribute to a high quality of life. They are safe and inclusive,
well planned, built and run, and offer equality of opportunity and good services for all.” Chapter 8
of the NPPF acknowledges the role that planning can play in facilitating social interaction and
creating healthy, inclusive communities. Chapter 12 of the NPPF also states that the conservation
of heritage assets can make a positive contribution to sustainable communities. This sentiment is
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shared by London Plan Policy 7.9 (heritage-led regeneration). London Plan policies 3.1, 3.16, 4.6
and 4.12 are also relevant. The principle of creating sustainable communities is also a key theme
running through Lewisham’s Core Strategy, and Objective 11 states that the Council, with its
partners, will provide and support measures and initiatives that promote social inclusion and
strengthen the quality of life and well-being for new and existing residents. With particular
reference to the contribution towards sustainable communities, consideration associated with:
social infrastructure; promoting social inclusion; local employment opportunities; and, cultural
strategy are set out below.
Social infrastructure
285 London Plan Policy 3.16 sets out that the capital requires additional and enhanced social
infrastructure provision to meet the needs of its growing and diverse population. With respect to
the Convoys Wharf site, Lewisham Core Strategy Policy SSA2 states that mixed use redevelopment
would need to provide for non-residential institutions, including a primary school and associated
social infrastructure, sufficient to meet the demand of the new resident population. Supporting
text to Policy SSA2 also identifies a requirement to provide a new centralised public open space of
approximately 0.45 hectares, or 4,500 sq.m.
286 GLA officers note that the outline masterplan would provide up to 13,000 sq.m. of
community use floorspace. The scheme proposes to make a positive contribution towards social
infrastructure in Deptford through the provision of a two-form entry primary school, and there is
also provision within the masteplan for a local health facility, in order to appropriately respond to
potential demand for this. In addition, a generously proportioned 11,573 sq.m. public square is
proposed at the heart of the site as part of an overall open space contribution within the scheme of
35,175 sq.m.
287 The proposed new open space is strongly supported, and the provision of a primary school
and health facility are particularly welcome in response to local need. GLA officers are of the view
that, collectively, these elements will positively contribute towards the creation of a genuinely
sustainable community.
288 Notwithstanding this provision, GLA officers have considered it necessary to secure a
number of reasonable planning obligations in order to mitigate the impact of the development
(having regard to the Lewisham Planning Obligations SPD, the Council’s representations and other
responses to local consultation, and the facts of the case). A number of the proposed obligations
relate to social infrastructure (including financial contributions towards secondary and sixth form
education, and local open space), and these are discussed in detail within the mitigating the impact
of the development through planning obligations section of this report. Accordingly, GLA officers
are satisfied that the application accords with London Plan Policy 3.16 and Lewisham Core Strategy
Policy SSA2.
Promoting social inclusion
289 The applicant’s Environmental Statement predicts a population uplift of 7,500 people
(including 574 children) as a result of the housing within the proposed development (of which 15%
would be affordable). As discussed in the housing section of this report, the outline application
would provide a good range of residential accommodation - including three and four bedroom units
within both the private market and affordable components of the housing mix. Furthermore, the
balance of the proposed tenure split has been carefully considered in response to local context, and
will support the creation of mixed and balanced communities. The Environmental Statement sets
out that the new population at the site will have a positive effect on the local area, and GLA officers
concur with this conclusion.
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290 GLA officers are also of the view that the design of the masterplan would positively support
social inclusion in Deptford. Consideration within the design and inclusive access sections of this
report demonstrates that the outline application has significant potential to promote social
inclusion and sustainable communities by opening up the site; providing new connections to
adjoining neighbourhoods; and, sharing the Thames riverside with the local community in an
accessible way.
291 Further to the above, and as set out within the mitigating the impact of the development
through planning obligations section of this report, the applicant has also committed to making
financial contributions to support local community projects (Sayes Court Garden programme and
Build the Lenox project), as well as a local community trust. Collectively these contributions will
help to bring vibrant locally specific activities to the area, supporting community cohesion and
social inclusion
Local employment opportunities
292 The Environmental Statement estimates that 2,150 jobs would be created at the site
following the proposed redevelopment, resulting in a major beneficial effect for the area. Further
to this, there would be an expected 1,200 construction jobs (averaging 700 person years of
employment) whilst the scheme is being delivered. This, in conjunction with a financial
contribution towards local employment and training, is expected to generate an additional
moderate beneficial effect. GLA officers are of the view that these benefits will help to address
skills gaps in the local workforce, and improve employment opportunities for all in accordance with
London Plan policies 3.1 and 4.12.
293 Further to the above, it is also noted that the community-led project proposals for this site
(Sayes Court Garden programme and Lenox project) would also have significant potential to bring
additional novel employment and training opportunities (associated with horticultural industries,
and both modern and historic construction techniques). The applicant’s offer to accommodate
these projects is set out within the community projects section of this report.
Cultural strategy
294 London Plan Policy 4.6 seeks to ensure the continued success of London’s diverse range of
arts, cultural, professional sporting and entertainment enterprises and the cultural, social and
economic benefits that they offer to its residents, workers and visitors. Lewisham Core Strategy
Policy SSA2 states that mixed use redevelopment of Convoys Wharf should provide for tourism,
heritage and leisure uses, including those that enhance the site’s river related location and use.
295 The applicant has provided a Cultural Strategy as part of the submission documents, this
seeks to stimulate the creation of a number of vibrant and sustainable cultural uses at the site in
order to deliver both economic and recreational benefits. The Cultural Strategy covers a wide range
of proposed initiatives across the site, however, having particular regard to the issues raised during
consultation on the outline application, considerations associated with the use of the Olympia
building (Grade II) and proposed the John Evelyn Centre, are set out below.
Use of Olympia building
296 The applicant’s Cultural Strategy proposes to use the Olympia building as a vibrant
community space, activated through a number of cafes, restaurants, specialist shops and stalls intended to promote a sense of place, whilst complementing the wider commercial provision within
the scheme and Deptford town centre. The Cultural Strategy references Old Spitalfields Market
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(London Borough of Tower Hamlets) as key precedent example of what is proposed to be delivered.
In particular, it is understood that the applicant views a multi-use proposal for the Olympia building
as favourable, on the basis that a diverse range of activities would help to promote vibrancy and
encourage return trips.
297 As discussed within the response to consultation section of this report, there is also a
community-led proposal for partial use of the Olympia building for the Lenox project. GLA officers
are of the view that this project has the potential to bring a wide range of local benefits, and would
considerably enrich the historic character of the site. The applicant has also expressed its support
for the project in principle. However, due to a number of physical constraints (and the
abovementioned desire to provide a multi-use proposal for Olympia to ensure a financially
sustainable use for the Listed Building) the applicant proposes that the project takes place at an
alternative part of the site. Further to this, English Heritage has confirmed that whilst it also
supports the project, additional feasibility work would be required before the potential for harm to
heritage assets (including the Olympia building itself, and the archaeology beneath it) may be fully
understood. Issues associated with the build the Lenox Project are considered in detail within the
community projects section of this report.
Use of Olympia building – conclusion
298 As discussed in the heritage section of this report, the applicant’s commitment to protect
and restore the Grade II Listed Olympia building is strongly supported. The undertaking of
necessary refurbishments works to the Listed Building is also proposed to be secured as part of the
section 106 legal agreement. Whilst it is somewhat disappointing that it has not been possible to
more closely define the future use of the Olympia building at this outline stage, having regard to
the matters discussed above, GLA officers are of the view that there are a variety of viable potential
uses for this Listed Building (including cafes, restaurants, specialist shops/stalls, and
cultural/community initiatives). Furthermore, officers are of the opinion that the applicant’s
commitment to invest in the long-term future of Olympia, and to place it at the very heart of the
masterplan, is certain to incentivise the timely fruition of a sustainable use for the Listed Building at
the detailed design stage. Therefore, GLA officers are satisfied that the outline proposals for the
use of Olympia (Grade II) accord with London Plan policies 4.6, 7.8 and 7.9; and Lewisham Core
Strategy Policy SSA2.
Use of John Evelyn Centre
299 The applicant’s Cultural Strategy proposes to use community space proposed within a block
at masterplan plot sixteen to provide a John Evelyn Centre. This centre would be situated above
archaeological remains at the location of the former Sayes Court Manor, allowing for these to be
revealed and interpreted as part of a wider cultural study centre related to the work of John Evelyn.
This centre is proposed to have a direct and tangible link to a new expanse of green open space
(recalling something of the Manor’s historic relationship with John Evelyn’s Sayes Court Garden)
proposed as part of a landscaped extension to Sayes Court Park. Furthermore, following the
submission of revised plans, the John Evelyn Centre is also now proposed to benefit from a close
spatial relationship with the proposed primary school. It is envisaged that, collectively, these uses
would form a critical mass of educational, cultural and community activities - positively contributing
towards the creation of a vibrant and sustainable community hub.
300 As discussed within the response to consultation section of this report, there is also a
community-led proposal for the use of the John Evelyn Centre for the Sayes Court Garden
horticultural programme. GLA officers are of the view that this project has the potential to bring a
wide range of local benefits, and to considerably enrich the cultural and educational offer at the
site. The applicant has agreed in principle for Sayes Court Garden CIC to use this space, however, as
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set out within the response to consultation section of this report, the community group has a
number of specific requirements in order to ensure a viable programme. Issues associated with the
Sayes Court Garden horticultural programme are considered in detail within the community projects
section of this report.
Use of John Evelyn Centre - Conclusion
301 The John Evelyn cultural study centre will be tangibly linked to archaeology related to Sayes
Court Manor and will benefit from a direct connection with green open space recalling something of
the historic presence of Sayes Court Garden. The close spatial relationship with the proposed
primary school will also promote the creation of a vibrant educational, cultural and community hub.
Accordingly, the proposed use of the John Evelyn Centre is strongly supported in accords with
London Plan policies 4.6, 7.8 and 7.9; and Lewisham Core Strategy Policy SSA2.
Securing a cultural legacy
302 The applicant identifies that a cultural steering group as key to delivering the projects
identified in the Cultural Strategy. Accordingly, GLA officers propose to secure a commitment to
the establishment and operation of such a group as part of the section 106 legal agreement.
Further to this, and as set out within the community projects and mitigating the impact of the
development through planning obligations sections of this report, the applicant also proposes a
number of measures intended to successfully incorporate the Build the Lenox Project and Sayes
Court Garden horticultural programme within the masperplan.
Sustainable communities - conclusion
303 Through various commitments to deliver necessary social infrastructure; promote social
inclusion; improve local employment opportunities; and, deliver a cultural legacy at the site, the
outline application would positively contribute to the promotion of sustainable communities.
Accordingly, the outline application is supported in accordance with the NPPF; London Plan
policies 3.1, 3.16, 4.6, 4.12, 7.8 and 7.9; and, Lewisham Core Strategy Objective 10 and Policy
SSA2.
Design
Urban design
304 Chapter 7 of the NPPF states that “Government attaches great importance to the design of
the built environment. Good design is a key aspect of sustainable development, is indivisible from
good planning, and should contribute positively to making places better for people”. Good design is
central to all objectives of the London Plan, and is specifically promoted by the policies contained
within chapter seven, which address both general design principles and specific design issues.
London Plan Policy 7.1 sets out a series of overarching design principles for development in
London. Other relevant design polices in this chapter include specific design requirements relating
to: optimising the development potential of sites (Policy 7.6); tall and large scale buildings (Policy
7.7); heritage assets and heritage-led regeneration (policies 7.8 and 7.9); local character (Policy
7.4); public realm (Policy 7.5); architecture (Policy 7.6); and, designing out crime (Policy 7.3).
305 With respect to the local policy context, Lewisham Core Strategy Objective 10 seeks to
protect and enhance the borough’s character. Core Strategy policies 15 (high quality design for
Lewisham) and 18 (location and design of tall buildings) are intended to assist in the delivery of
Objective 10, and Strategic Site Allocation 2 within the Core Strategy establishes a set of site
specific design criteria for Convoys Wharf. Also relevant are Lewisham’s saved UDP policies STR
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URB 1, STR URB 4, URB 1 and URB 3, and emerging policies DM 30 and 35 within the submission
stage Development Management Local Plan.
Site layout and masterplan strategy
306 Core Strategy Policy SSA2 sets out various design principles for Convoys Wharf, and
inherent within these is the aspiration to open up the site, and knit it into the urban fabric of the
wider area. To this end, the architect has arranged development plots within the outline masterplan
in order to celebrate the Olympia building (Grade II) and create a legible grid pattern of streets and
spaces, inspired by the historic relationship of the site with the River Thames. Primary access into
the site is proposed to be via New King Street and Grove Street. A spine road running through the
south-western third of the site is intended to be used to link both entrances, and this will feed
secondary and tertiary routes which run deeper into the masterplan. Valuable new connections will
also be provided to the riverside, which, in conjunction with an extension to pedestrian and cycle
routes along the Thames Path, will create a direct and legible route from Deptford High Street to,
and along, the riverfront. The masterplan would also allow for additional north/south connections
to be delivered across the heart of the site, through a new access at Watergate Street, and a
potential new pedestrian connection with Pepys Park, across masterplan plot 21 (the safeguarded
wharf).
307 The proposed masterplan achieves a good level of integration with surrounding sites and the
area’s existing open space network. The plan provides a contiguous link east to west across the site
between Pepys Park and Twinkle Park, whilst the introduction of Evelyn Gardens provides a direct
green link between the proposed Sayes Court Park extension and the Olympia building - which sits
in central space, anchoring the masterplan and the network of existing and new spaces. There have
been a number of previous master plans for the site, but this is the first to have resolved the
difficulties of the site’s geometries, and to genuinely link the existing community, and its public
spaces, into the new community. The plan layout, massing strategy and land use at the edges of the
scheme (particularly the school and community uses) ensure that it the masterplan would be well
integrated into the existing urban context.
308 It is noted that the Port of London Authority has raised concern with the abovementioned
route across plot 21 on the basis that it may prejudice wharf operations. A further objection to the
link, due to potential disruption to an area of biodiverse parkland, was also identified within a broad
range of concerns raised by the Tenants Action Group at Pepys Estate. It is acknowledged that
there will be various challenges to overcome as part of the future detailed design of this proposed
pedestrian connection, however, having considered these issues GLA officers are of the view that
the potential benefits of this route (in terms of enhanced local connectivity; supporting a linked
network of local open spaces; and, promoting social inclusion) clearly warrant its inclusion within
the masterplan. Accordingly, GLA officers are of the view that the masterplan would successfully
achieve the key connectivity principles sought by Policy SSA2, thereby improving local legibility and
permeability, and, crucially, reconnecting Deptford to the Thames riverside. The masterplan layout
is also supported in accordance with London Plan Policy 7.1.
Masterplan blocks
309 The Olympia building (Grade II) is intended to act as the heart of the development, and the
Listed Building is proposed to be celebrated within a generously proportioned public square of
11,573 sq.m. The masterplan is offset by approximately 45 degrees from the alignment of Olympia,
and this will act jointly to emphasise the importance of this historic structure, and to support the
creation of a number of distinct and well-defined urban spaces around it. The Olympia building is
also proposed to be used to terminate views from the north (including from positions on the River
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Thames, jetty park and Thames Path) as a means of recalling the structure’s historic relationship
with the river.
310 The illustrative masterplan demonstrates that the new blocks proposed within the scheme
would fall into a number of broad typologies (courtyard block, semi-open courtyard block, linear
block, and tower block). As discussed in the housing section of this report, GLA officers are
satisfied that these typologies would be capable of providing a high quality residential environment.
Furthermore, in terms of their broader role within the masterplan, GLA officers note that these
block typologies would ensure that the public realm (including streets and open spaces) would be
clearly defined by active built frontages. This will provide the opportunity for passive surveillance to
enhance safety and security in line with London Plan Policy 7.3, and will also create a clear
threshold between public and private spaces.
311 Whilst a number of local consultation responses have raised concern that residential amenity
space would be provided within private courtyards (rather than as an extension of the public realm),
it is important to emphasise that GLA officers support this as an urban design strategy. This
approach focuses public activity on streets and open spaces (ensuring that these areas are
perceived as welcoming and safe) and provides a clear sense of ownership for private amenity areas
(ensuring that these are valued and well-used by residents).
312 The Mayor is also advised that, following GLA officer negotiations, the applicant has
submitted revised plans which remove a primary school block that was originally proposed at
masterplan plot seventeen (refer to figure 6 below). The school is now proposed to be provided
within a larger mixed use courtyard block a plot sixteen, and the floorspace displaced as a result has
been reaccommodated elsewhere within the masterplan. The revisions also include a slight
reduction in the maximum parameter at masterplan plot sixteen, in order to chamfer the southern
corner of this block. This design move allows for a greater width of open space to be provided as
part of a new green link – reaching directly from Sayes Court Park to the archaeological remains at
the site of Sayes Court Manor. This arrangement provides a more direct affiliation between Sayes
Court Park and the location of the former Manor, and, as discussed in the sustainable communities
section of this report, would also enable the school to benefit from a closer relationship with the
proposed John Evelyn centre. This relationship would support the creation of a vibrant critical mass
of community, educational and cultural uses, of which, the Sayes Court Garden horticultural
programme would be a valuable component. The removal of this block has also resulted in the
creation of an additional 1,378 sq.m. of open space in the vicinity of the former Sayes Court Manor
(discussed in more detail within the open space section below), and would offer improved
opportunities for integrating a row of mature trees at the southern site boundary into the wider
landscaping strategy.
Figure 6: Original and revised arrangement at masterplan plots 16 and 17 (left to right). Modified extract from Farrells,
Design and Access Statement Addendum (February 2014).
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Open space
313 London Plan Policy 7.18 seeks the creation of new open space in London to ensure
satisfactory levels of local provision to address areas of deficiency. As part of the outline masterplan
the applicant proposes a range of hard and soft-landscaped open spaces, including: a linear jetty
park; public square and mirror pool at Olympia; public spaces reflecting the historic location of the
Double Dry Dock and Slipway One; and, a soft landscaped extension to Sayes Court Park.
Collectively, the open space provision within the scheme would total a maximum of 35,175 sq.m.
The new spaces proposed are strongly supported in line with London Plan Policy 7.18, however,
further specific consideration associated with the Sayes Court Park extension and jetty park is set
out below.
Sayes Court Park extension
314 Following the submission of revised plans affecting plot seventeen (discussed in paragraph
312 above) a provision of 1,378 sq.m. of open space has been made available within the vicinity of
the former Sayes Court Manor. This will contribute towards a larger soft-landscaped extension to
Sayes Court Park, which, together with a green link to Olympia proposed along ‘Evelyn Gardens’,
will create a large expanse of open space which would act as green gateway to the heart of the site.
As discussed within the community projects section of this report, a significant proportion of this
space is proposed to be made available to Sayes Court Garden CIC in order to deliver a proposed
community-led urban horticulture project. To support the realisation of the project GLA officers
have also sought to allow maximum flexibility with respect to the delivery of playground provision
for the school at plot sixteen. The parameter plans do not specify a set location for playground in
support of plot sixteen, and illustrative detail within the Design and Access Statement Addendum
provides two potential options: a southwest triangular space within the Sayes Court Park extension;
or, a northwest rectangular space at Evelyn Gardens. GLA officers are of the view that, through the
joint provision of internal and external playground space for plot sixteen, it would be possible to
provide an optimised design solution at reserved matters stage that would ensure open space
associated with the Sayes Court Park extension would be delivered as a coherent whole, and
opportunities for green breakout space that interfaces with the John Evelyn centre at plot sixteen
would be maximised. As discussed within the community projects section of this report, GLA
officers understand that the latter, in particular, is critical to the delivery of the horticultural
programme proposed by Sayes Court Garden CIC.
Jetty park
315 As discussed above, the applicant proposes to provide a landscaped public park on an
existing jetty at the site. This open space provision is proposed to be supplemented by up to 800
sq.m. of restaurants and/or cafes, and up to 800 sq.m. of Class B2/sui generis floorspace to provide
support facilities for a new river bus pier. The park would benefit from an attractive outlook
upstream to Canary Wharf, and downstream to the Maritime Greenwich World Heritage Site, and
would offer a new high quality amenity space for the whole community. Whilst the delivery of this
park is supported in open space terms, it is noted that consultation responses from the Environment
Agency have raised concern with this proposal for reasons associated with the proposed provision
of inappropriate uses on a functional floodplain.
316 In response to this issue, the applicant has stated that the buildings proposed on the jetty
are intended to be light-weight, and could easily be removed or repaired in the event of flood
situations. Furthermore, this part of the masterplan would be included within a detailed Flood Risk
Alleviation Strategy (discussed in the environmental issues section of this report), which will be
implemented to manage flood risk and ensure public safety.
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317 When considering this issue GLA officers have been particularly mindful of London Plan
Policy 5.2 (which sets out that developments required to pass an Exceptions Test will need to
address flood resilient design and emergency planning matters) and London Plan Policy 7.28 (which
seeks to prevent development and structures into the water space unless it serves a water related
purpose). Having regard to the issues involved, including the value and unique nature of the public
space envisaged, GLA officers are of the view that the small-scale uses proposed for the jetty are
integral to the quality and success of this public space. Collectively these uses will ensure the
riverside park is highly accessible and well activated - supporting the aims of London Plan Policy
7.27, which seeks to promote appreciation and recreational use of the Blue Ribbon Network.
Open space – conclusion
318 The range of public spaces proposed will support a varied character of local open spaces,
and will positively contribute towards an enhanced network of local provision. Accordingly, with
reference also to a secured planning obligation to mitigate intensified use of other local open space
(refer to paragraph 521) the proposed open space provision is strongly supported in accordance
with London Plan policies 7.18 and 7.27; and, Lewisham Core Strategy Policy SSA2.
Height and massing strategy
319 London Plan Policy 7.7 states that tall and large-scale buildings should be part of a plan-led
approach to changing or developing an area, and should generally be limited to sites within the
Central Activities Zone or Opportunity Areas. This policy also sets out a range of criteria for
assessing the design quality of tall and large-scale buildings, and states that such buildings should
not have an unacceptably harmful impact on their surroundings. This site is in an Opportunity Area,
and Lewisham Core Strategy Policy 18 identifies Convoys Wharf as a suitable location for tall
buildings, subject to the need for such buildings to be of the highest design quality.
320 The proposed height and massing strategy would deliver a range of low to medium-rise
blocks of between 2 to 10-storeys, a number of ‘feature buildings’ at approximately 14-storeys, and
three high-rise tower elements of between 38 to 50-storeys. The height of buildings across the
masterplan is proposed to be lowest at the interface with existing development at the landward
edges of the site, and generally rises towards the centre. The three tower elements are proposed to
be located at masterplan plots two, six and fourteen, with the tallest of the towers proposed to be
located at the riverfront.
321 The proposed approach of grading building heights across the site (to avoid significant
juxtapositions of scale at the interface with the surrounding urban fabric) is supported both in
terms of providing a sympathetic response to context, and managing neighbourhood amenity
issues. With respect to the massing strategy for the interface of the scheme with the riverside, the
architect has sought to establish a broadly consistent mid-rise frontage on to the riverfront comprised of various buildings at a datum of between five and eleven storeys (a setback 14-storey
feature building at masterplan plot three will also support this overall approach). The architect then
proposes to interpose this mid-rise scale benchmark with a tower element of up to 50-storeys. This
tower will be seen in conjunction with two others of a similar scale at plots six and fourteen, and
collectively this group of tall buildings will act to enliven the silhouette of the scheme when viewed
from the riverside, and landmark the Thames from townscape views inland. The scale of these
buildings would contribute to the legibility of the city by land-marking this riverside Opportunity
Area destination, and would enhance local way-finding by clearly identifying the site, and the
riverside, within the townscape. The proposed arrangement of the tall buildings at the site ensures
that they would work well collectively to provide a varying and dynamic composition when seen in
kinetic views from the river and townscape. Furthermore, the buildings would help to deliver a
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significant contribution to urban renaissance in Deptford, and would be a visible marker for the
regeneration of the wharf.
322 Further consideration related to the impact of tall buildings in terms of the scheme’s
response to context (including townscape and heritage assets) is considered within the strategic
views, local views and heritage section below, and other considerations associated with impacts on
local amenity (including daylight, sunlight, overshadowing and wind) and communications
infrastructure are considered within the neighbourhood amenity and environmental issues sections
of this report.
323 The scale of the buildings towards the centre of the site is generally between 10 to 14storeys (with the exception of the above mentioned towers at plots six and fourteen). The architect
has allowed for various breaks in massing in order to suitably manage daylight and sunlight levels
within the scheme, and whilst buildings of this scale are not unusual within the wider context, the
proposed concentration of building height at the centre of the site has drawn concern from various
parties (including Lewisham Council and English Heritage). In the main, objections focus around the
impact that these buildings may have on the setting of the Olympia building (Grade II). These
issues are considered in detail within the heritage section below.
Ensuring high quality design of tall buildings
324 Whilst it is not possible to undertake a full assessment of the design of the proposed
buildings at outline stage, GLA officers have, nevertheless, sought assurance that the masterplan
parameters and associated Design Guidelines would deliver a high quality architectural outcome at
reserved matters stage. Having had regard to issues raised by numerous parties (including the
Mayor and Lewisham Council) during the initial round of consultation, that applicant has submitted
revisions which effectively relax the minimum parameters for tall buildings at plots two, six and
fourteen. This will allow for greater flexibility with respect to the detailed design of the proposed
tower elements, meaning that these could potentially come forward in a slightly more slender
and/or curvaceous form (compared to the visualisations currently presented within the illustrative
masterplan).
325 Furthermore, whilst GLA officers support the key design framework principles set out within
the associated Design Guideline document, it is proposed to secure a planning condition that would
allow for reasonable deviation from the proposed guidelines - where this would result in a better
design outcome. Accordingly, whilst the Design Guideline document would remain an important
material consideration, there would be scope for more varied design permutations to come forward
at reserved matters stage (in relation to external appearance for example), where justified. A design
review panel is also proposed (to be secured within the section 106 agreement) in order to allow for
peer review of future detailed proposals - providing additional assurance of design quality control.
326 On the basis of the above, GLA officers are satisfied that the optimum balance between
design detail and flexibility within the outline application has been struck, and that appropriate
controls are in place to ensure that future reserved matters applications would come forward in a
way which would accord with the detailed design requirements of London Plan Policy 7.7 and
Lewisham Core Strategy Policy 18.
Height and massing strategy – conclusion
327 Further to the consideration within the design, heritage, neighbourhood amenity and
environmental impact sections of this report, GLA officers are satisfied that the proposed massing
strategy would enliven the silhouette of the scheme when viewed from the riverside, landmark the
Thames from townscape views inland, make a positive contribution to the London skyline, and not
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cause unacceptable harm to the surroundings. Accordingly, the outline application accords with
London Plan Policy 7.7; and, Lewisham Core Strategy Policy 18.
Strategic views
328 London Plan Policy 7.12 sets out the key principles of the Mayor’s London View
Management Framework (LVMF). This policy states that new development should not harm the
composition of strategic views, and that the ability to recognise and appreciate strategically
important landmarks should be preserved. The Mayor has published his London View Management
Framework SPG (2012) to assist with the detailed implementation of this policy.
329 The proposed development will be visible within the wider panorama for strategic view 5A.2
from Greenwich Park, and 6A.1 from Blackheath Point as defined by the Mayor’s LVMF. Both of
these views centre on St. Paul’s Cathedral as the strategic landmark, and include various other
modern and historic landmarks within a wider panorama of central London.
330 To enable an assessment of impact to be undertaken the applicant has provided accurate
visualisations of these views – including the illustrative masterplan as a wire outline overlay. In both
of the views concerned the proposal would feature in the middle ground, between the viewing
point and the strategic landmark. However, the proposal would not breach the landmark viewing
corridor in either view, and in both cases the development would feature some distance from the
dome of St. Paul’s. An assessment of impact for each view is provided below
Strategic view 5A.2 from Greenwich Park (within Greenwich Park CA)
331 Guidance within the Mayor’s LVMF SPG identifies that the relationship between Tower
Bridge, the Monument to the Great Fire and St Paul’s Cathedral are important elements of the view,
and collectively this relationship is integral to the viewer’s ability to recognise and appreciate the
Cathedral and its western towers. The Mayor’s guidance also states that development on the river
edge at Deptford should help to reinforce the composition of the existing view.
332 When considering the impact of the proposal in this view it is noted that the three tower
elements of the scheme would make a new and prominent contribution in the middle ground of the
panorama, albeit some way to the left of St. Paul’s, Tower Bridge and the Monument when seen
from this position. GLA officers are of the opinion that whilst the proposal would substantially
change the current characteristics of the river edge at Deptford, this change would not undermine
the critical composition of the three historic landmarks discussed above, or harm the viewer’s ability
to recognise or appreciate St. Paul’s Cathedral as the strategic landmark. Furthermore, having
regard to the cumulative impact of other consented development in this view, GLA officers are
satisfied that the impact of the scheme would not amount to ‘canyoning’ around the strategic
landmark.
Strategic view 6A.1 from Blackheath Point (within West Greenwich CA)
333 St. Paul’s Cathedral is at the centre of this view, and guidance within the Mayor’s LVMF
SPG states that the western towers of St Paul’s are integral to the viewer’s ability to recognise and
appreciate the landmark. The guidance also identifies that this panorama is sensitive to large-scale
development in the foreground and middle ground. Notwithstanding this, the view management
advice indicates that there is considerable opportunity to introduce new development if it is
sympathetic to the composition and character of the view.
334 When considering the impact of the proposal in this view it is noted that occlusion between
the proposed tower elements results in a silhouette comprising just two main components. The
overlap of the occluded tower element is not entirely complete, however, when considered in the
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context of the cumulative view it is noted that the scheme maintains a comparatively slender
profile, particularly given that it is situated within the middle ground of this view. It is also noted
that whilst the proposal would make a prominent contribution to the panorama, it would feature
some way to the right of St. Paul’s Cathedral when seen from this position. GLA officers are of the
opinion that whilst the proposal would introduce a significant change to this view, the change
proposed would not harm the viewer’s ability to recognise or appreciate St. Paul’s Cathedral as the
strategic landmark. Furthermore, having regard to the cumulative impact of other consented
development in this view, GLA officers are satisfied that the in the impact of the scheme would not
amount to ‘canyoning’ around the strategic landmark.
Other strategic views
335 The submitted townscape visual impact assessment also considers the impact of the
proposal on LVMF views 1A.1 (from Alexandra Palace) and 2A.1 (from Parliament Hill), GLA
officers are satisfied that the proposal would have a negligible impact of these views.
Strategic views - conclusion
336 Having carefully considered the proposed impact of the outline application on LVMF views,
GLA officers are satisfied that the scheme would not harm the critical composition of these strategic
views, and that the ability to recognise and appreciate St. Paul’s Cathedral as a strategically
important landmark would be preserved. Accordingly, the application accords with London Plan
Policy 7.12.
Local views
337 The applicant has undertaken an assessment of various local views within the townscape
visual impact assessment which supports the Environmental Statement. The assessment provides
various accurate visualisations of these views – including the illustrative masterplan as a wire outline
overlay. In some cases indicative external treatments have also been shown. The proposed impact
on local views is considered below.
Royal Naval College (within the Maritime Greenwich WHS and West Greenwich CA)
338 This view is dominated by building and spaces associated with the World Heritage Site in the
foreground, however, the proposal would be visible on the Thames riverfront in the background of
this view. Occlusion between the tallest elements within the scheme causes only two towers to be
visible in the submitted visualisation, however, the applicant’s assessment acknowledges that all
three towers will come into view when the observer moves along the Thames Path. Having
considered the impact, GLA officers are of the opinion that whilst the proposal would result in a
visible change to this view, the form of the scheme would appear distant, and secondary to the
World Heritage Site in the foreground. Accordingly, GLA officers conclude that the proposal would
not harm this view.
Greenwich Pier (within the Maritime Greenwich WHS and West Greenwich CA)
339 This view is dominated by the southern bank of the River Thames and flanked in the
foreground by a variety of low to mid-rise riverside residential blocks. Various central London
Towers are visible in the distance. The proposal would feature in the middle ground of this view,
between central London and the Thames Path in the foreground. All three of the proposed towers
would be visible, and whilst these would appear as the tallest features on the horizon, once
completed the development would positively contribute to the activation and interest of this stretch
of the Thames riverside. The cumulative view also demonstrates that the proposal would be set
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amongst various other large-scale buildings in the middle ground. Accordingly, GLA officers
conclude that the proposal would not harm this view.
Pointers Close
340 This view is dominated by a broad stretch of the Thames, and looks across the river towards
the southern bank at Deptford. The river frontage is currently occupied by modern warehouse
buildings at Convoys Wharf, and a number of older structures (to the left) associated with Paynes
Wharf (Grade II). The proposed cumulative visualisation demonstrates that the scheme would result
in a dramatic change to the character of the riverside, and, in conjunction with other consented
development in the area, would contribute to new a distinct urban riverside location. The tower
elements give a distinct sense of presence to the 16.6 hectare site in this view, and, once
completed, the scheme would positively contribute to the life and vibrancy of this stretch of the
riverside. Accordingly, GLA officers are of the opinion that the proposal would significantly enhance
this view, and would not harm the setting of Paynes Wharf (Grade II).
Foreshore Deptford
341 The foreground of this view is dominated by a Grade II listed pair of warehouses. These are
set back somewhat from the riverside, and the view is terminated by trees and a modern warehouse
structure at Convoys Wharf. Given the close proximity of the site, the proposal would be visible in
the middle ground of this view. Whilst the submitted visualisations demonstrate that the proposed
tower elements would feature prominently, the massing strategy of the masterplan ensures that, as
a whole, the development would present a sympathetic silhouette – stepping down to below the
parapet height of the Listed warehouses in this view. In this way the proposal would ensure that the
Listed Building retains its visual dominance in the foreground, whilst jointly contributing to an
improved termination of this view. Accordingly, GLA officers are of the opinion that the proposal
would enhance this view, and would not harm the setting of the Grade II Listed warehouses.
New King Street (within Deptford High Street CA)
342 This view looks north along New King Street towards the site, from a position on Deptford
High Street. The foreground of this view is dominated by the road junction with Evelyn Street. Just
beyond this to the left is a Victorian high street terrace (with some modern infill), and to the right is
an eleven-storey tower block set in open green space at Sayes Court Estate. The submitted
visualisation demonstrates that massing strategy of the masterplan would respond well to the scale
of the existing development in the middle ground. The three tower elements will be partially visible
either side of the axis of New King Street, land-marking the site, and framing the gateway to the
Thames riverside. GLA officers are of the opinion that the proposal would enhance this view and
positively contribute towards improving the legibility of the area, whilst preserving the fundamental
setting of the Deptford High Street Conservation Area.
Deptford High Street (within Deptford High Street CA)
343 This view looks north towards the site along Deptford High Street from a position at the
junction of the High Street with Griffin Street. This is an urban setting, and the view is characterised
by a colourful shopping environment comprising Victorian high street terraces and some modern
infill buildings. The view is terminated by a railway bridge at Deptford station. The submitted
visualisation demonstrates that two of the three tower elements would be clearly visible above the
railway bridge at the centre of the view, land marking the riverside from this part of Deptford High
Street. The associated towers would be seen shoulder to shoulder from this position, however, a
variation in treatments (proposed within the Design Guidelines) would ensure that they remain
distinct from one another. GLA officers are of the opinion that the proposal would enhance this
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view and positively contribute to the legibility of the area, whilst preserving the fundamental
setting of the Deptford High Street Conservation Area.
Other local views
344 The submitted townscape visual impact assessment also considers the impact of the
proposal on various other local views including: Pump Hill; Westferry Cicrus; Millennium Quay;
Twinkle Park; Deptford Church Street; Deptford train station platform; Abinger Grove; Rolt Street;
Sayes Court Park; Pepys Park; The Colonnade; St. Georges Square; Plough Way; Surrey
Quays/Lower Road; Southwark Park; Hilly Fields Park; Shooters Hill/Dover Road; and, Eltham
Palace Parade. Having considered the impact of the proposal, GLA officers are satisfied that the
scheme would not harm these local views.
Local views conclusion
345 Having carefully considered the proposed impact of the outline application, GLA officers are
satisfied that the scheme would: not harm local views; preserve the character of Deptford High
Street, West Greenwich and Greenwich Park Conservation Areas; and, not cause harm to the
settings of Listed Buildings in the vicinity of the site. Accordingly, the application accords with the
NPPF; London Plan Policy 7.4; and, Lewisham Core Strategy Objective 10.
Urban design conclusion
346 Having had regard to relevant national, regional and local design policy, the design
concerns raised as part of the consultation process and Lewisham Council’s representations on the
application, GLA officers are of the opinion that: the proposed site layout and masterplan strategy
has been well considered and achieves the key aims of providing a generous central open space
and a direct and legible route between the riverside and Deptford High Street; the masterplan plots
would put Olympia (Grade II) at the heart of the site and generate blocks that would ensure that
the public realm (including streets and open spaces) would be clearly defined by active built
frontages; the scheme would provide a range of soft and hard-landscaped public spaces
contributing to a significant uplift in local open space; and, the height and massing of the
development would enliven the silhouette of the scheme when viewed from the riverside, landmark
the site and the Thames from townscape views inland, and would not cause harm to the
surrounding context (including the settings of Listed Buildings, strategic and local views, and the
outstanding universal value of the Maritime Greenwich World Heritage Site). Accordingly, with
respect to issues of urban design, GLA officers are satisfied that the application complies with the
NPPF; London Plan policies 7.1, 7.3, 7.4, 7.5, 7.6, 7.7, 7.12, 7.18 and 7.27; Lewisham Core
Strategy Objective 10 and policies 15, 18 and SSA2; saved Lewisham UDP policies STR URB 1, STR
URB 4, URB 1 and URB 3, and emerging policies DM 30 and 35 within the submission stage
Development Management Local Plan.
Heritage
347 Pursuant to section 66 of the Planning (Listed Buildings and Conservation Areas) Act 1990,
the Mayor must have special regard to the desirability of preserving Listed Buildings, their settings,
or any features of special architectural or historic interest that they may possess. Chapter 12 of the
NPPF sets out key principles for conserving and enhancing the historic environment and states that
“Local planning authorities should identify and assess the particular significance of any heritage
asset that may be affected by a proposal… taking account of the available evidence and any
necessary expertise”. National Planning Practice Guidance also provides relevant guidance on
conserving and enhancing the historic environment, including further guidance for World Heritage
Sites. London Plan Policy 7.8 seeks to ensure that new development would “identify, value,
conserve, restore, re-use and incorporate heritage assets, where appropriate.” This policy also
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states that “Development affecting heritage assets and their settings should conserve their
significance, by being sympathetic to their form, scale, materials and architectural detail”. London
Plan Policy 7.9 states that “Regeneration schemes should identify and make use of heritage assets
and reinforce the qualities that make them significant so they can help stimulate environmental,
economic and community regeneration”. At the local level, Lewisham Core Strategy Policy SSA2
provides specific heritage design advice for the Convoys Wharf site, stating that development
proposals should protect and restore the Listed Olympia building and protect the principal
archaeological features of the site including the Double Dry Dock, John Evelyn House and Tudor
Store House (Scheduled Ancient Monument), incorporating them into the layout and delivery of
the masterplan in a positive way.
348 In accordance with the principles of London Plan Policy 7.8, the applicant has submitted a
heritage statement (augmented by further detail within the Environmental Statement) which
considers the key attributes and significance of heritage assets at the site, and assesses the impact
of the proposed development. Having regard to this, and the findings of a recent draft PostExcavation Assessment Report (published following a detailed archaeological excavation of the
site), consideration associated with archaeology and historic buildings is set out below.
Archaeology
349 London Plan Policy 7.8 seeks to ensure that new development incorporates measures that
identify, record, interpret, protect and, where appropriate, present a site’s archaeology. In line with
this approach, the applicant has undertaken an extensive programme of archaeological works at the
site which have culminated in the publication of a draft post excavation archaeology report for the
site. English Heritage has commended the applicant for undertaking such an extensive programme
of works at pre-planning stage, and, as discussed in paragraph 83, English Heritage has
recommended the draft post excavation report for approval. This draft document now contributes
to a valuable body of literature on the historical significance of the site.
350 Further to the various archaeological works undertaken at the site, the submitted Heritage
Statement identifies the following archaeological heritage assets associated with the historic Royal
Dockyard: Double Dry Dock/Great Dock; Tudor Storehouse (Scheduled Ancient Monument); Great
Storehouse; slipways one to five; Great Basin; mast ponds; rigging house; and, smithery. Also found
were various fragmentary remains associated with: officers’ houses; the plank store and sail loft;
Naval Store House; saw pits; and, plank sheds. The submitted Heritage Statement provides a
detailed assessment of the significance of these features. With respect to the Royal Dockyard as a
whole, the assessor states that it is of great significance given that it was the most important Royal
Dockyard for the Tudors, and was the Navy’s pre-eminent research and development centre for
centuries. However, due to the extent of twentieth century destruction to the built fabric (discussed
in paragraph 14), this significance lies predominantly in the site’s history. Accordingly, it is
concluded that, whilst the dockyard holds little architectural interest, the archaeological
significance of the site is moderate, and the historical significance is high.
351 With respect to Sayes Court, the Heritage Statement identifies the following archaeological
heritage assets: Sayes Court Manor; and, Sayes Court Garden. The significance of Sayes Court lies in
that it was the home of the seventeenth century diarist and horticulturalist, John Evelyn, and the
site of his celebrated gardens (west of the Manor) where he undertook much of his scientific
research. As with the Royal Dockyard, little of architectural interest remains, however, the assessor
concludes that the archaeological significance is moderate, and the historical significance is
moderate to high.
352 Having regard to the location and significance of the archaeology present at the site, the
applicant has sought to incorporate various key features as part of the outline masterplan in
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accordance with the principles of London Plan policies 7.8 and 7.9, and Lewisham Core Strategy
Policy SSA2. Accordingly, the place making strategy employs four approaches to incorporating
heritage: reuse, display, inspire and remember. In all cases the applicant has appropriately
prioritised the approach of preserving archaeological remains in situ. The key proposals for
incorporating archaeological features within the masterplan are as set out below.
Double Dry Dock/Great Dock
353 The fragile archaeological remains of the double dry dock are proposed to be preserved in
situ underground. Subject to further engineering design, the entrance stonework to the dock will be
displayed, and the outline of the Double Dry Dock will be marked out and interpreted as part of the
landscaping strategy for open space at the site.
Tudor Storehouse (Scheduled Ancient Monument)
354 As with the Double Dry Dock, archaeological field work has suggested that these features
are more fragile than their planned specification would suggest. The foundations of the Tudor
Storehouse (which are not currently visible or accessible) are badly damaged and difficult to display.
Accordingly the Scheduled Ancient Monument is proposed to be stabilised, recorded, protected in
situ, covered, and built over as part of masterplan plot one. As discussed in more detail below, a
Scheme of Archaeological Resource Management (SARM) will be put in pace to ensure that the
archaeological remains would be appropriately protected during the construction process.
Slipways one to five
355 Slipway one is proposed to be preserved in situ underground. The slip will be marked out
within the public realm and landscaped as public open space. Slipways two and three will be
preserved in situ underground beneath the Olympia building. The archaeological remains of
slipways four and five have been recorded and are proposed to be preserved in situ underground.
Options for expressing the detail of stone piers at the river wall, and handling the raised flood level,
will be carefully considered at reserved matters stage.
Great Basin
356 The archaeological remains of the Great Basin have been recorded and are proposed to be
preserved in situ. The presence of the Great Basin would be marked by a water feature set within a
wider triangle of public space adjoining Olympia Square. This is intended to provide a memory of
the former Basin, and to enhance the setting of the Olympia building (Grade II). Subject to further
detailed design, it may also be possible to make archaeological remains of the Great Basin wall
accessible from the basement of masterplan plot two.
Mast Ponds
357 The mast ponds exist in the area that is proposed for the safeguarded wharf, and will be
preserved in situ underground. Limited archaeological preservation of these features means that it
is difficult display them in a meaningful way, however, there is potential for these to be marked out
as part of a wider landscaping strategy in future.
Sayes Court
358 The archaeological remains of the part of the basement of Sayes Court Manor (and elements
of a later workhouse built at the same site) are proposed to be displayed within a John Evelyn
cultural/study centre, incorporated within masterplan plot sixteen. The revealing of the remains,
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and the associated interpretation within the study centre, will enhance the understanding of
Evelyn’s work. There is also significant potential for the John Evelyn centre to be occupied by Sayes
Court Garden CIC, and used to run a horticultural programme linked to the adjoining extension to
Sayes Court Park.
Scheme of Archaeological Resource Management (SARM)
359 In order to manage and mitigate construction (and operational) effects on archaeology at
the site, the applicant has proposed a Scheme of Archaeological Resource Management (SARM).
This will inform the design process and ensure the preservation and enhancement of archaeological
features. The main aim of the SARM is to achieve preservation in situ of archaeological remains.
However, in rare instances where this could not be achieved, it would require preservation by
published record. The Environmental Impact assessment concludes that with the SARM in place the
overall impact on archaeology at the site would be ‘minor’ beneficial.
Response to consultation and planning policy requirements
360 As set out within the response to consultation section of this report, a considerable number
of parties (including English Heritage, Middlesex Archaeological Society, Council for British
Archaeology, Naval Dockyards Society and Wold Monuments Fund) have raised concerns and/or
objections on the basis that the scheme has not gone far enough in terms of integrating the
archaeology that exists at this site. In general the aforementioned parties expressed the view that
the scheme should be more heritage-led, and that a greater number of features (particularly those
associated with the Royal Dockyard) should be revealed and/or more overtly expressed within the
masterplan.
361 Whilst GLA officers note that it has not been proposed to incorporate/express the
Scheduled Tudor Storehouse as part of the built form of the masterplan, it is accepted that the
condition of the remains do not lend themselves to display and meaningful interpretation.
Accordingly, GLA officers are satisfied that the proposal to protect this feature and preserve it in
situ (beneath a new building) is an appropriate response.
362 Having regard to the above, and when considering the proposed response collectively, GLA
officers are of the view that the masterplan does respond positively to the key heritage related
objectives of Core Strategy Policy SSA2 (which seeks protection of the principal archaeological
features at the Convoys Wharf site including the Double Dry Dock; John Evelyn House; and, Tudor
Storehouse, and incorporation of these within the layout and delivery of the masterplan). Whilst it
is acknowledged that not all the archaeology at the site would be revealed (or directly expressed
through built development above ground), GLA officers are satisfied that the applicant’s proposed
hierarchy of priority with respect to approaches to incorporating heritage, and the application of
this hierarchy based on the significance of the heritage assets concerned, is sound. Above all, GLA
officers strongly support the principle of putting preservation in situ at the heart of proposed
approach to conserving archaeological features.
Archaeology - conclusion
363 Having had regard to the consideration above, GLA officers are satisfied that the outline
application would appropriately ensure the preservation of existing archaeology at the site, and
would strike an optimum balance between showcasing and expressing the site’s rich historic past,
and allowing this Opportunity Area site to fulfil its regenerational potential as a twenty first century
contribution to the Thames riverside at Deptford. Accordingly, with respect to matters of
archaeology, GLA officers are satisfied that the application accords with the NPPF; London Plan
policies 7.8 and 7.9; and, Lewisham Core Strategy Policy SSA2.
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Historic buildings
364 Pursuant to section 66 of the Planning (Listed Buildings and Conservation Areas) Act 1990,
the Mayor must have special regard to the desirability of preserving Listed Buildings, their settings,
or any features of special architectural or historic interest that they may possess. London Plan
Policy 7.8 states that development affecting heritage assets and their settings should conserve their
significance by being sympathetic to their form, scale, materials and architectural detail. London
Plan Policy 7.9 supports this approach and states that, wherever possible, heritage assets (including
buildings at risk) should be repaired, restored and put to a suitable and viable use that is consistent
with their conservation and the establishment and maintenance of sustainable communities and
economic vitality. At the local level, site specific policy SSA2 states that development proposals at
Convoys Wharf should protect and restore the Listed Olympia building.
365 As discussed in the site description section of this report, there are various Listed Buildings
at this site including: Olympia (Grade II); Gate Piers to former Naval Dockyard (Grade II); River Wall
(Grade II); and, Dockyard Boundary Wall (part) (Grade II). The proposed response to these heritage
assets is considered below.
Olympia building (Grade II)
366 The outline application proposes to protect and restore the Olympia building for community
and commercial use as part of a cultural strategy discussed in the sustainable communities section
of this report. GLA officers strongly support this approach in line with London Plan policies 7.8 and
7.9, and Lewisham Core Strategy Policy SSA2.
367 Notwithstanding this, as set out in the response to consultation section of this report,
concerns have been raised by various parties (including Lewisham Council and English Heritage)
with respect to the proposed impact of the masterplan massing strategy on the setting of the Listed
Building. GLA officers have distilled these concerns into two key issues: impact of proposed
building heights surrounding Olympia square; and, visual prominence of the Listed Building in views
from the Thames riverside. These issues are addressed in turn below.
368 When considering the response to the setting of the Listed Olympia building it is important
to be mindful of the scale of the public space which it is proposed to occupy (11,573 sq.m.). Whilst
it is noted that the buildings which are proposed to front this square will be taller than Olympia,
GLA officers are of the view that they are, nevertheless, of an appropriate scale to provide the
necessary definition to this space, and, therefore, positively contribute to the setting of the Listed
Building. Furthermore, as discussed in the urban design section above, GLA officers are of the view
that the proposal to offset the buildings fronting Olympia square by approximately 45 degrees acts
jointly to emphasise the importance of the Listed Building, and to support the creation of a number
of distinct and well-defined urban spaces around it. In addition, the proposed mirror pool to the
north of plot seven will also enhance the setting of the Listed Building by expressing a memory of
the historic relationship between the Olympia building and the Great Basin.
369 With respect to the visual prominence of Olympia in views from the Thames riverside, it is
noted that Lewisham Council and English Heritage (among others) have expressed the opinion that
a wider gap should be provided between masterplan plots two and three - in order to maximise
views of the Listed Building for the riverside. It has also been suggested that a reduction in height
at these plots could ensure that Olympia would feature more prominently from river views. It is
noted that the illustrative masterplan currently proposes a 30 metre gap between plots two and
three, and that the indicative building heights at this interface are 8 to 10-storeys and 2 to 14storeys and respectively. It is also noted that the parameter plans for both plots allow for three
metres of inward deviation in this location. Having carefully considered the related components of
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this issue, in particular lines of sight along the north bank of the River Thames (the orientation of
plots two and three relative to the wide sweep of the river at this point mean that the Olympia
building would be visible for a significant section of the river and north bank), GLA officers are
satisfied that the proposed separation between plots two and three (and scale of buildings at these
plots) is appropriate to allow for favourable framing of the Listed Building from key riverside
vantage points.
Olympia building (Grade II) - conclusion
370 Having considered the key components of the proposed built form and landscaping strategy
surrounding and framing Olympia, and the intention to refurbish the building and place it at the
heart of vibrant new urban quarter, GLA officers are of the view that the outline application would
conserve the significance of the Listed Building and significantly enhance its setting.
Other Listed Buildings at the site
371 With respect to the other Listed Buildings at the site (including: Gate Piers to former Naval
Dockyard (Grade II); River Wall (Grade II) and, Dockyard Boundary Wall (part) (Grade II)), GLA
officers are satisfied that the outline application would ensure their significance and setting are
appropriately conserved.
Master Shipwrights House and Dockyard Office (Grade II*)
372 GLA officers are of the view that the outline masterplan has carefully considered the
proposed massing response to the Master Shipwrights House and Dockyard Office (Grade II*). Plot
one will help to define a new public space (in the location of the Great Dock), and provides a sense
of scale to the setting of the Listed Building. Following the submission of revised plans, building
heights at the southeast edge of plot one have been fixed at a maximum of 5-storeys. Furthermore,
the intention within the illustrative masterplan to set back any levels above 3-storeys (at the
interface with the Listed Building) is also proposed to be secured by way of planning condition. The
abovementioned public space will significantly enhance the setting of the Listed Building, and the
Master Shipwrights House and Dockyard Office will address this space in conjunction with an
adjacent 3-storey block on the same building line. Subject to the detailed resolution of boundary
treatments at reserved matters stage, and positive engagement between the applicant and the
landowner of this adjacent plot, GLA officers are of the view that there is considerable scope for the
interface between the Listed Building and the wider masterplan to be enhanced even further. A
solution which could reintegrate the Grade II* Listed Master Shipwrights House and Dockyard
Office with the wider site would serve to considerably enrich the historic character of the area.
373 As part of neighbourhood consultation a concern was raised that the proposed development
does not respond to a “group value” Listing which includes the Master Shipwrights House and
Dockyard Office (Grade II*), and the Tudor Storehouse (Scheduled). GLA officers have considered
issues associated with incorporation of the Tudor Storehouse within the archaeology section above.
As discussed, it has not been possible to incorporate/express the Scheduled Tudor Storehouse as
part of the built form of the masterplan. However, given that the Master Shipwrights House and
Dockyard Office (Grade II*) do not currently benefit form a relationship with the buried remains of
the Scheduled Tudor Storehouse, GLA officers are satisfied that a failure to express this historic
connection as part of the development proposals would not be detrimental to the setting or
significance of the Listed Building.
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Master Shipwrights House and Dockyard Office (Grade II*) - conclusion
374 Having considered the proposed response of the masterplan to Master Shipwrights House
and Dockyard Office (Grade II*), GLA officers are of the view that the outline application would
conserve the significance of the Listed Building and enhance its setting.
Other Listed Buildings in the vicinity of the site
375 The impact of the proposal on other Listed Buildings in the vicinity of the site (as well as
neighbouring Conservation Areas) is considered within the local views section of this report. For the
avoidance of doubt GLA officers are satisfied that the scheme would preserve the character of
Deptford High Street, West Greenwich and Greenwich Park Conservation Areas; and, not cause
harm to the significance or settings of Listed Buildings in the vicinity of the site.
Historic buildings – conclusion
376 Having had special regard to the desirability of preserving Listed Buildings, their settings
and any features of special architectural or historic interest which they possess, GLA officers are
satisfied that the outline application would conserve the significance of the Olympia building
(Grade II) and Master Shipwrights House and Dockyard Office (Grade II*); enhance the settings of
Olympia (Grade II) and Master Shipwrights House and Dockyard Office (Grade II*); and, not cause
harm to the setting or significance of the other Listed Buildings at the site or in the surrounding
townscape. Accordingly, GLA officers are satisfied that the application accords with the NPPF;
London Plan policies 7.8 and 7.9; and, Lewisham Core Strategy Policy SSA2.
Maritime Greenwich World Heritage Site
377 The Convoys Wharf site falls outside the buffer zone defined by the Maritime Greenwich
World Heritage Site Management Plan. However, the proposal would be visible within the wider
cityscape setting of the Maritime Greenwich World Heritage Site when viewed from Greenwich Hill,
and could also be seen from within the World Heritage Site and associated buffer zone from points
at the Royal Naval College and Greenwich Pier.
378 The applicant has provided an assessment of the visual impact of the scheme form
Greenwich Hill, the Royal Naval College and Greenwich Pier within the Environmental Statement
(these views are discussed in the urban design section of this report). Further to this, and in
response to the Mayor’s initial representations on the application, the applicant has also provided a
supplementary statement setting out an assessment of the potential impacts of the scheme on the
outstanding universal value of the Maritime Greenwich World Heritage Site. The assessment
considers issues associated with character; landscape and topography; relationship with the River
Thames; and views, and verifies that, due to the distance between Convoys Wharf and the World
Heritage Site, the potential impacts are primarily visual.
379 London Plan Policy 7.10 states that development should not cause adverse impacts on
World Heritage Sites or their settings, and, in particular, should not compromise the ability to
appreciate outstanding universal value, integrity, authenticity or significance. The Mayor has
published his London World Heritage Sites - Guidance on Settings SPG (2012) to assist with the
detailed implementation of this policy.
380 The Mayor’s SPG provides a draft summary statement of the outstanding universal value of
Maritime Greenwich World Heritage Site setting out various key components of its significance. The
SPG identifies that whist there is some need for refurbishment and repair to the urban pattern
within the setting to the World Heritage Site, the ensemble of buildings and landscapes at Maritime
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Greenwich preserve a remarkably high degree of authenticity. With respect to integrity, the SPG
sets out that the main threats to the World Heritage Site are from development pressures and
traffic within Greenwich town, and tall buildings in the setting which have the potential to impact
adversely on visual integrity.
381 The ensemble of the Maritime Greenwich World Heritage Site (including the formal, axial
arrangement between Greenwich Palace, the Queen’s House and associated landscapes - identified
as critical to the integrity and authenticity of the site) is best appreciated in views from Greenwich
Hill, particularly the strategic view from LVMF viewpoint 5A.1. Whilst the proposed development
would not be visible in LVMF view 5A.1, the scheme would feature in a wider panorama which
includes the World Heritage Site when seen form LVMF view point 5A.2. The impact of the proposal
on this view, and other local views from within the World Heritage Site itself is discussed below.
View of the Maritime Greenwich World Heritage Site from Greenwich Hill
382 Further to the consideration of impact on LVMF view 5A.2 set out in the urban design
section of this report, GLA officers are of the opinion that the proposal would feature some
considerable distance from the Maritime Greenwich World Heritage Site in this view, and would not
undermine the formal, axial arrangement between Greenwich Palace, the Queen’s House and
associated landscapes. Accordingly, GLA officers conclude that the proposal would not adversely
impact the integrity, authenticity or significance of the World Heritage Site in this view, and the
outstanding universal value of the World Heritage Site would be preserved.
Views of the proposal from within the Maritime Greenwich World Heritage Site
383 Further to the consideration of impact on local views from the Royal Naval College and
Greenwich Pier set out in the urban design section of this report, GLA officers are of the opinion
that the proposal would be perceived as secondary to the World Heritage Site buildings and spaces
when viewed from within the World Heritage Site and its buffer zone. The proposal would appear
distant, and would not be confused with the profile and forms of the World Heritage Site in the
foreground. Accordingly, GLA officers conclude that the proposal would not adversely impact the
integrity, authenticity or significance of the Maritime Greenwich World Heritage Site in these views,
and the outstanding universal value of the World Heritage Site would be preserved.
Maritime Greenwich World Heritage Site - conclusion
384 Having carefully considered the proposed impact of the outline application on the Maritime
Greenwich World Heritage Site, GLA officers are satisfied that the scheme would not adversely
impact the integrity, authenticity or significance of the World Heritage Site, and that its
outstanding universal value would be preserved. Accordingly, the application accords with London
Plan Policy 7.10.
Heritage conclusion
385 Following the above heritage consideration, GLA officers are of the view that the outline
application would appropriately ensure the preservation of existing archaeology at the site, and
would strike an optimum balance between showcasing and expressing the site’s rich historic past,
and allowing this Opportunity Area site to fulfil its regenerational potential as a twenty first century
contribution to the Thames riverside at Deptford. With respect to historic buildings and spaces, and
having had special regard to the desirability of preserving Listed Buildings, their settings and any
features of special architectural or historic interest which they possess, GLA officers are satisfied
that the proposed development would conserve the significance of the Olympia building (Grade II)
and Master Shipwrights House and Dockyard Office (Grade II*) and enhance the settings of these
Listed Buildings. The proposal would not cause harm to the setting or significance of the other
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Listed Buildings at the site, or in the surrounding townscape. Furthermore, the proposed
development would preserve the character of Deptford High Street, West Greenwich and Greenwich
Park Conservation Areas, and preserve the outstanding universal value of the Maritime Greenwich
World Heritage Site. Accordingly, GLA officers are satisfied that the application complies with the
NPPF; London Plan policies 7.8, 7.9 and 7.10; and, Lewisham Core Strategy Policy SSA2.
Inclusive design
386 Chapter 6 of the NPPF states that “It is important to plan positively for the achievement of
high quality and inclusive design for all development, including individual buildings, public and
private spaces and wider area development schemes.” London Plan Policy 3.1 promotes equal life
chances for all, and London Plan Policy 7.2 requires that all future development meets the highest
standards of accessibility and inclusion, and that the design process has considered how everyone,
including disabled and Deaf people, older people, children and young people, will be able to use
the places and spaces that are proposed. Also relevant are London Plan policies 3.8 and 4.5; and,
Lewisham Core Strategy policies 1 and SSA1.
387 Whilst it is not possible to undertake a full assessment of access and inclusion at outline
stage, GLA officers have, nevertheless, sought assurance that the outline application would
appropriately accommodate essential access standards, and enshrine inclusive design principles so
that these may feed through into the detailed design at reserved matters stage.
Masterplan response to inclusive design principles
388 The applicant has set out its commitment to inclusive design within the Design and Access
statement. The stated intention to design beyond the minimum requirements of Building
Regulations Part M is particularly supported in line with London Plan Policy 7.2, and it is noted
that the extensive re-profiling works to be undertaken at the site provide an excellent opportunity
to rationalise levels and gradients within the public realm. Notwithstanding this, the various
podium levels proposed at many of the masterplan plots will need to be handled carefully to ensure
that access to internal spaces within these blocks would be inclusive and legible for residents and
visitors alike.
389 The layout of the scheme, and design of the public realm, promotes well defined, legible,
routes across the development. In particular, the proposed delivery of inclusive access to the
Thames Path and other proposed public spaces (including the jetty park) will be a real asset to the
scheme, and the wider area. This will ensure that these spaces are enjoyable and accessible, not
only for older people and the disabled, but for the whole community. The scheme also promotes
inclusive access to the proposed river bus service and bus stops. In these ways the masterplan has
significant potential to support social inclusion, and promote the creation of sustainable
communities. The Design Guidelines document provides additional detail on how movement across
the site is intended to take place in an inclusive way. The key principles and proposed movement
hierarchy is broadly supported, however, careful attention will be required at reserved matters
stage to ensure that the detailed resolution of proposed shared surfaces/home zones, would
successfully avoid unnecessary challenges to the visually impaired, or other disabled people. Use of
boundary treatments around gravel and water features within the landscaping strategy also will
need careful consideration.
Inclusive design standards
390 GLA officers note the intention that all of the proposed units would meet the ‘Lifetime
Homes’ standard, and than a minimum of 10% would be wheelchair accessible (or easily adaptable
for wheelchair users). These standards are proposed to be secured by way of planning condition to
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ensure accordance with London Plan Policy 3.8. In line with London Plan Policy 4.5, the applicant
has also confirmed that 10% of the proposed hotel rooms within the scheme will be wheelchair
accessible or adaptable. This is supported in response to the Mayor’s initial representations on the
application, and this standard is also proposed to be secured by condition.
Inclusive design conclusion
391 The outline application has significant potential to support social inclusion, and promote
the creation of sustainable communities, by opening up this site and sharing the Thames riverside
with the local community in an accessible way. Whilst careful attention to detail will be required at
reserved matters stage to ensure the detailed design of the masterplan would deliver the highest
standards of access and inclusion, based on the principles enshrined within the outline design
strategy, and the assurance that relevant accessibility standards will be suitably secured as part of
the section 106 agreement, GLA officers are satisfied that the application accords with the NPPF;
London Plan policies 3.8, 4.5 and 7.2; and, Lewisham Core Strategy policies 1 and SSA1.
Energy
392 Chapter 10 of the NPPF states that “Planning plays a key role in helping shape places to
secure radical reductions in greenhouse gas emissions, minimising vulnerability and providing
resilience to the impacts of climate change…”. London Plan climate change policies (set out in
chapter five) collectively require developments to make the fullest contribution to the mitigation
of, and adaptation to, climate change, and London Plan Policy 5.2 sets strategic targets for carbon
dioxide reductions within development proposals. Relevant polices at the local level include
Lewisham Core Strategy Spatial Policy 1 and polices 7, 8 and SSA1.
Energy strategy
393 In line with London Plan Policy 5.2, the applicant has submitted an energy strategy for the
development, setting out how the scheme will reduce carbon dioxide emissions in accordance with the
London Plan energy hierarchy. The components of the energy strategy comprise various passive
design and efficiency savings (ensuring that the development would achieve compliance with Building
Regulations Part L through these measures alone); prioritised connection to SELCHP, or, three CHPs
for a site-wide network (as a fall-back position); and, photovoltaic panels (associated with the fall
back position to reach the relevant strategic 25% carbon dioxide reduction target). Whilst more
detailed modelling and testing will be undertaken a reserved matters stage, based on the
representative benchmark figures provided the proposal is expected to deliver a minimum overall
carbon dioxide saving of 25% compared to a 2010 Building Regulations compliant development. This
would accord with the relevant minimum (2010-2013) target within London Plan Policy 5.2 and the
policy approach within Lewisham’s Core Strategy. For the avoidance of doubt, whilst London Plan
Policy 5.2 seeks to introduce a minimum 40% carbon dioxide target for 2013-2016, the Mayor has
indicated that he only intends to apply the 2013-2016 target to planning applications submitted on or
after 1 October 2013.
394 GLA officers note that the delivery of the proposed energy strategy would be secured in
accordance with the approved planning documents, and that the commitment to prioritise connection
to SELCHP will be incorporated within the section 106 legal agreement. Furthermore, standards
associated with BREEAM (‘very good’) and Code for Sustainable Homes (‘Level 4’) will be suitably
secured by way of planning condition. Accordingly, with respect to the energy strategy, the
application complies with the NPPF; London Plan Policy 5.2, 5.6 and 5.7; and Lewisham Core Strategy
Spatial Policy 1 and polices 7, 8 and SSA1.
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Environmental issues
395 As discussed in paragraph 31, the outline application constitutes EIA development.
Accordingly, the applicant has submitted a detailed Environmental Statement which assesses the
environmental impact of the proposed development. This statement, in conjunction with other
supporting documents (such as the Design Guidelines), identifies the measures necessary to
mitigate the environmental impact of the proposed development. Whilst this section of the report
is intended to deal with environmental issues, it should be noted that in a number of cases
consideration with respect to certain Environmental Statement topics are addressed in other
dedicated sections of this report. For the avoidance of doubt, all the environmental information
submitted for the purposes of the Town and Country Planning (Environmental Impact Assessment)
Regulations 2011 has been taken into account in the consideration of this application.
396 Furthermore, following joint discussions with Lewisham Council and the GLA, the applicant
has submitted an addendum to the Environmental Statement to provide a number of factual
updates/clarifications (refer to paragraph 50).
Noise and vibration
397 The Environmental Statement assesses the predicted impact on noise levels during
construction and operation of the scheme. The Statement considers receptors in surrounding
residential areas and open spaces, and acknowledges that there is potential for noise and
disturbance during construction to affect the surrounding area. It is proposed to mitigate this
effect through use of a Code of Construction Practice. With the mitigation in place, the
Environmental Statement predicts that effects would range from none, to moderate minor adverse.
398 Operational effects have also been assessed having particular regard to increased traffic
generated by the scheme (including heavy goods vehicles serving the wharf). The traffic expected
to be generated by the wharf use has been assessed within the Marine Terminal Assessment, and
transport issues are considered in detail within the associated section of this report. The
Environmental Statement states that operational effects of the wharf cannot be fully determined in
the absence of a known operator. However, the likely residual effects are predicted to be minor
adverse. Development traffic from the site is predicted to give rise to significant moderate adverse
noise conditions at properties located near New King Street/Prince Street. Mitigation is proposed
in the form of a Travel Plan to discourage car use through the promotion of more sustainable
modes of transport (Travel Plan measures include restricting car parking, and enhancing pedestrian
and cycle routes). The maintenance of roads is also identified as important (in order to avoid nose
impacts from surface irregularities). It is stated that elsewhere, there would not be significant
increases to traffic.
399 The Environmental Statement acknowledges the operational impacts of noise and vibration
will be largely dependent on the future operation of the wharf. However, as discussed in the
safeguarded wharf section of this report, an operator for masterplan plot 21 is still to be defined.
Given the current unknowns associated with future wharf operations, the Environmental Statement
proposes that impact assessment, and consideration of necessary mitigation for noise and vibration
impacts, continues as part of the detailed design progresses. GLA officers support this approach
and propose a planning condition for the wharf requiring details of operational nature and
associated noise control measures to be approved prior to the commencement of development at
the wharf plot. Accordingly, on the basis that the above mentioned noise and vibration mitigation
will be secured by way of planning condition/ planning obligation (as appropriate), and further to
the condition requiring approval of details associated with operational wharf impacts, GLA officers
are satisfied that, with respect to matters of noise and vibration, the outline application accords
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with the NPPF; London Plan policies 7.6 and 7.15; and emerging Policy DM26 within the draft
Lewisham Development Management Local Plan.
Air quality
400 The Air Quality Assessment considers the associated effects of the development having
regard to: the siting of development next to a wharf; the activity within the wharf; traffic
(construction and operational); and, both on- and off-site combined heat and power energy
scenarios. Implementation of the Code of Construction Practice is proposed to provide mitigation
via measures such as wheel washing, covering of supplies and materials, and use prefabricated
materials. With the implementation of these measures, the Environmental Statement states that no
significant construction effects are expected. The Environmental Statement also concludes that no
significant operational effects would arise under either energy scenario (or other possible industrial
activities on the site) given the inclusion of proposed abatement technologies for energy centres,
and the use of suitable stack heights. Increased traffic would, nevertheless, result in increased
pollutant concentrations at nearby receptors. Accordingly, mitigation is proposed in the form of
highway modifications/enhancements, and promotion of sustainable transport modes (including
use of river transport) as part of measures within the Travel Plan. The Environmental Statement
concludes that, with mitigation, there would be no significant impacts to on-site residents.
However, the Environmental Statement predicts an impact of moderate adverse off-site. It is,
nevertheless, noted that the Environmental Statement has considered the worst case scenario, and
that actual effects may be lower. Furthermore, the Air Quality Assessment states that operational
stage mitigation is still being developed, and that it may be possible to reduce the residual
operational impact at detailed design stage.
401 When considering the impact of the proposed development on air quality GLA officers have
had regard to the worst case scenario presented, and the wider regenerational benefits of the
scheme (the Environmental Statement concludes that cumulatively there would be a beneficial
environmental impact on the local area). Whilst it is noted that the development would not be air
quality neutral (and would not, therefore, comply with London Plan Policy 7.14), GLA officers are
satisfied that the proposed impact has been mitigated as far as is reasonably possible, and that the
worst case scenario is acceptable for an urban location such as this. Accordingly, on the basis that
the above mentioned air quality mitigation will be secured way of planning condition/planning
obligation (as appropriate), GLA officers conclude that the proposed impact of the outline
application on air quality is acceptable, on balance.
River and water resources
402 The site falls within Environment Agency Flood Zone 3 and benefits from the protection of
River Thames flood defenses. A Flood Risk Alleviation Strategy is intended to address flood alleviation
and emergency planning issues for the site (including level raising at the site), and this is proposed to
be secured as part of the section 106 agreement.
403 As part of the Flood Risk Alleviation Strategy, mitigation to address flood risk during the
construction period includes flood warning systems to ensure public safety for construction workers
(and any visitors) at the site, and maintenance of flood defences (including a method statement for
protection of the river wall). As a result of these measures, no significant increased risk of flooding
during construction is predicted. Furthermore, flow rates for discharge into the combined sewer are
proposed to be agreed with Thames Water prior to the commencement of works.
404 In order to mitigate the operational effects of the development, a Surface Water Drainage
Strategy is proposed to be secure by way of condition. This strategy seeks to ensure that
approximately 60% of the surface water from the development will be kept separate from
foul/combined drains, and directed into the Thames via new outfalls. This approach is supported in
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accordance with the sustainable drainage hierarchy in London Plan Policy 5.13. Furthermore, in
response to the Mayor’s initial representations, the applicant’s agreement to investigate opportunities
to increase surface water discharge to the Thames (therefore reducing the requirement for attenuation
tanks) is welcomed. GLA officers note that, in conjunction with proposed sustainable urban drainage
systems (including surface water swales and ditches), the Mayor’s minimum standard for attenuation
of drainage water prior to discharge into the combined sewer would be achieved. Whilst it is noted
that the volume of discharge into the combined sewer is expected to result in a minor adverse effect
on the capacity of the combined sewer network, the applicant is committed to early engagement with
Thames Water in order to ensure the necessary additional capacity could be created. Furthermore, in
response to the consultation response from Thames Water, GLA officers propose to design the
proposed Surface Water Drainage Strategy condition to require details of foul and surface water
drainage (including necessary on-site and off-site connections/improvements).
River hydrology
405 With respect to impacts on river hydrology, a Code of Construction Practice is proposed to
address construction effects on water quality, and a Method Statement is proposed for the
construction of the jetty in order to appropriately manage any potential localised disturbance and
adverse impacts. In combination with the implementation of pollution prevention guidance, the
Environmental Statement concludes that the effects would be minor adverse, and not significant
(being largely temporary and reversible).
River and water resources – conclusion
406 The Environmental Statement concludes that with the proposed mitigation in place, the
proposed development would not have any significant adverse effects on the water environment.
GLA officers concur with this conclusion, and propose to secure the proposed mitigation measures
by way of planning condition/planning obligation, as appropriate. Accordingly, the application
complies with the NPPF; London Plan policies 5.12, 5.13, 5.14 and 7.24; and Lewisham Core
Strategy policies 10 and 11.
Biodiversity
407 The Environmental Statement has assessed the ecological features of the area and potential
effects on notable species of flora and fauna (including bats and the black redstart, which have
previously been identified on the site). It assesses the River Thames as having ‘moderate’ ecological
value, and identifies various designated sites within a two kilometre radius of the site. Four nonstatutory designated sites are also identified.
408 The main construction effects would be the loss of approximately 16.6 hectares of terrestrial
habitat at the derelict site. However, as part of the phased approach to delivering the scheme it is
proposed to retain habitats for as long as possible, and to create new habitats at the earliest
opportunity. In this way the applicant intends to ensure that sections of the site remain available as
suitable habitats for ‘wasteland’ loving species such as the black redstart. An existing warehouse
building at the site (Building 16) is known to contain a bat roost. It is proposed that this building
will be demolished as part of the redevelopment. However, in order to avoid harm to bats, it is
proposed that this demolition will take place under the supervision of a suitably qualified specialist.
It is also proposed that disturbance to inter-tidal mud will be mitigated by retaining the river wall
and jetty, and incorporating additional fenders. Subject to the incorporation of identified
mitigation, the Environmental Statement predicts a minor adverse effect during the construction
phase.
409 In terms of operational effects, the mitigation proposals include a minimum of 18,300 sq.m.
of biodiverse extensive living roof (or other suitable ground or podium level habitat such as brown
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roof or landscaped planting) to address the loss of the existing 16.6 hectares of habitat which
currently exists at the site. This provision is also stated to be suitable for bat flight paths and
foraging, as well as foraging and breeding habitat for the black redstart. Surface water management
(within the Surface Water Drainage Strategy) is proposed to mitigate negative impacts to the
aquatic environment, and there is also scope for the proposed sustainable urban drainage measures
to further enhance the range of ecosystems and biodiversity at the site.
Biodiversity – conclusion
382
The Environmental Statement concludes that with the proposed mitigation in place, the
proposed development would not have any significant adverse effects on biodiversity. GLA officers
concur with this conclusion, and propose to secure the proposed mitigation measures by way of
planning condition/planning obligation, as appropriate. Accordingly, the application complies with
the NPPF; London Plan policies 5.10, 5.11 and 7.19; and Lewisham Core Strategy policies 7 and 12.
Artificial light spill
410 The Environmental Statement addendum confirms that during the construction phase
artificial lighting will be installed and maintained at minimum lighting levels necessary for safe
working around the site. Careful consideration will be given to the position and direction of lighting
to minimise light spill to adjacent properties, nearby spaces, or the River Thames. These good
practice measures will be incorporated as part of the Code of Construction Practice which is
proposed to be secured within the section 106 agreement.
411 Whilst the Environmental Statement acknowledges that the proposed redevelopment of this
vacant land would result in greater night-time illumination at this site, the Environmental Statement
sets out that detailed artificial lighting design and assessment is not possible at outline stage (given
that characteristics of artificial light spill will ultimately be defined by the eventual design of the
building architecture and public realm lighting strategy). Accordingly, the applicant proposes to
undertake a detailed artificial lighting assessment and lighting design strategy at reserved matters
stage. GLA officers are content with this approach to mitigation, and propose to secure these
measures by way of planning condition.
412 Accordingly, with respect to the issue of artificial light spill, GLA officers are satisfied that
the application complies with the NPPF; London Plan Policy 7.6; and, and emerging Policy DM27
within the draft Lewisham Development Management Local Plan.
Microclimate
413 This section deals principally with wind issues. Issues associated with daylight and sunlight,
and overshadowing are addressed within the neighbourhood amenity section of this report.
414 The Environmental Statement has assessed the illustrative masterplan in order to analyse
the effect that the scheme would have on local wind patterns, and how this would affect pedestrian
comfort. The assessment will be updated as necessary during the detailed design process. In terms
of construction effects, there is the potential for the local wind environment to be affected due to
demolition as the built environment changes on site. The Environmental Statement nevertheless
concludes that any neighbouring off-site effects would be temporary.
415 It is noted that, following redevelopment, the site will become more sensitive to wind (given
that numerous new pedestrian areas would be created). In terms of effects, it is noted that there
would be various localised areas of increased wind speed within the site as a result of the
development. In particular, potential areas of high wind speed are identified surrounding the three
towers elements, to the north of the Olympia building, and at the riverfront. In order to suitably
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mitigate this impact it is proposed to use detailed design and landscaping measures to provide wind
breaks and to reduce wind velocity at ground level. The Design Guidelines set out the relevant
measures necessary to deliver the required mitigation, and, the Environmental Statement concludes
that, with mitigation in place, the effects both inside and outside the site are unlikely to be
significant. GLA officers concur with this conclusion, and the Design Guidelines are proposed to be
secured as an approved document (subject to the reasonable design flexibility discussed in
paragraph 325).
416 Accordingly, with respect to the issue of wind, GLA officers are satisfied that the application
complies with the NPPF; London Plan Policy 7.6; and, Lewisham Core Strategy Policy 18.
Communications infrastructure
417 The Environmental Statement predicts that construction processes (including temporary
structures, such as cranes) may have a potential effect in terms of interference to television and
radio signals. Where such effects are attributed to the scheme, the applicant proposes mitigation in
the form of upgraded aerials, or (where impacts are significant) connection of affected properties to
the ‘Freesat’ service. Where the line of sight to satellite dishes would be interrupted, mitigation is
proposed in the form of relocated satellite dishes, or connection to cable services. It is predicted
that FM and DAB radio, and mobile phones and pagers, will not be affected.
418 In terms of operational effects there is the potential to create a signal ‘shadow’ which would
affect TV reception. Again, the applicant proposes mitigation in the form of upgraded aerials, or
(where impacts are significant) connection of affected properties to the ‘Freesat’ service. This
mitigation is proposed to be secured within the section 106 legal agreement, and, with the
proposed mitigation in place, the Environmental Statement concludes that the completed
development will not have a significant impact on communications infrastructure.
419 Accordingly, with respect to the issue of wind, GLA officers are satisfied that the application
complies with Lewisham Core Strategy Policy 18.
Cumulative environmental impacts
420 Given the scale of the scheme, and phased nature of the proposed delivery programme, the
Environmental Statement has assessed the effects on occupants and users of early phases of the
development (whilst construction would be underway on later phases).
421 Accordingly, the Environmental Statement considers an intermediate year assessment in the
final quarter of 2018. The assessment confirms that receptors closest to construction activities and
traffic routes would potentially experience effects from noise, air quality and traffic. Furthermore,
given the potential for interactive effects associated with windblown contaminated dust, and
contaminated surface water, the Environmental Statement proposed use of a Code of Construction
Practice, together with various other issue specific mitigation measures, to address impacts on
ground conditions and water resources.
422 The Environmental Statement concludes that, by ten years from completion, the
effectiveness of mitigation for wind, biodiversity and visual impacts would have matured and,
therefore, improved. Furthermore, it is noted that associated maintenance regimes are proposed to
protect against deterioration of mitigation within the development, and GLA officers propose to
secure this accordingly by way of planning condition/planning obligation, as appropriate.
423 In terms of construction effects, the Environmental Statement indicates that there is
potential for cumulative nuisance and transport impacts, particularly given the proximity of the site
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to the Oxestalls Road development. The Code of Construction Practice and a Construction Traffic
Management Plan (for both developments) is proposed to reduce impacts to an acceptable level.
424 Overall, The Environmental Statement concludes that there will be a beneficial impact on
the local area as a result of the significant regeneration that the scheme would deliver. GLA officers
concur with this conclusion, and propose to suitably secure the necessary mitigation measures by
way of planning condition/planning obligation, as appropriate.
Environmental issues – conclusion
425 With reference also to the consideration in the neighbourhood amenity section of this
report, and further to the inclusion of various necessary planning conditions and planning
obligations, GLA officers are satisfied that the proposed development would acceptably mitigate its
own environmental impact. Furthermore, when relevant cumulative impacts are taken into account,
the proposal would result in a positive impact on the local environment as a result of the significant
regenerational benefits of the scheme. Accordingly, the application complies with the NPPF;
London Plan policies 5.10, 5.11, 5.12, 5.13, 5.14, 7.6, 7.15, 7.19 and 7.24; Lewisham Core Strategy
polices 7, 10, 11, 12; and 18, emerging policies DM26 and DM27 within the draft Lewisham
Development Management Local Plan.
Neighbourhood amenity
426 A core principle of the NPPF is to always seek to secure high quality design and a good
standard of amenity for all existing and future occupants of land and buildings. London Plan Policy
7.6 states that the design of new buildings should not cause unacceptable harm to the amenity of
surrounding land and buildings, particularly residential buildings. At the local level, the Lewisham
Core Strategy places residents at the heart of its strategic vision for 2026. The emerging Lewisham
Development Management Local Plan (submission stage) is intended to provide further detail to
support implementation of the Core Strategy, and seeks to facilitate development which protects
and enhances the amenity of the local area. Also relevant is Lewisham’s saved UDP Policy HSG4,
which seeks to improve and safeguard the character and amenities of residential areas throughout
the borough.
427 Having already discussed various environmental impacts within the associated section
above, and whilst also having regard to the issues raised during public consultation on the
application, the relevant impacts on neighbourhood amenity that need to be considered in this
case are: daylight, sunlight and overshadowing; and, privacy/overlooking. These issues are
addressed under the associated sections below.
Daylight, sunlight and overshadowing
428 In order to assess the impact of the proposal on daylight, sunlight and overshadowing, the
Environmental Statement includes a baseline assessment of existing conditions, and impact
modelling of a three-dimensional representation of the illustrative masterplan. GLA officers note
that baseline information from a previous assessment (associated with an earlier iteration of the
scheme) is still relied upon, and that since this benchmark was established, numerous buildings at
the site have been demolished. Furthermore, whilst it is acknowledged that the impact of building
out all parameters to their maximum extent has not been tested, GLA officers are satisfied that
testing of the illustrative masterplan provides a suitably representative benchmark for assessment
at this outline state.
429 In addition, following a technical matter queried by Lewisham Council, and subsequent joint
discussion on environmental issues with the applicant, the relevant Environmental Statement
assessor has provided confirmation with respect to the methodology used to test taller buildings
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behind/to the side of assessed interfaces. In summary, this verifies that the assessment has been
undertaken in accordance with Building Research Establishment (BRE) guidelines (“Loss of light to
existing windows need not be analysed if the distance of each new part of the new development
from the existing window is three or more times its height above the centre of the existing window”
(BRE209)). In instances where the proposed development is taller or closer than this, the assessor
employed a skylight test, using a 25 degree guide line perpendicular to the affected window (if the
angle is less than 25 degrees for the development then there is unlikely to be a substantial effect
on the diffuse skylight). The output from this test was fed back into the architectural design of the
massing strategy, and accordingly, it has been possible for the scheme to ensure that the 25
degree guide line would not be exceeded. GLA officers are satisfied that the methodology used to
assess the daylight/sunlight and overshadowing impacts of the outline scheme is suitably robust,
and accordingly consideration of the proposed construction and operational impact is set out
below.
430 The assessment within the Environmental Statement notes that construction effects on
daylight and sunlight would fluctuate due to demolition improving the existing situation, followed
by construction reducing levels. The Environmental Statement predicts no significant residual
construction effects because of their temporary nature.
431 The Environmental Statement predicts that, once the proposed development is completed,
surrounding properties would generally receive good levels of daylight and sunlight and that any
property that would experience a reduction is still expected to meet BRE standards. The properties
most likely to be affected are stated to be 90-94 Grove Street (which would experience a reduction
in Average Daylight Factor (ADF) of over 20%, creating a minor adverse impact. It is proposed to
mitigate this (potentially through the provision of breaks in proposed building massing) at the
detailed design stage, and to further consider the impact on the ADF and Vertical Sky Component
at that stage. GLA officers are content with this approach, and propose to secure submission of
detailed daylight and sunlight assessments (to include details of any necessary mitigation), by way
of planning condition. The Environmental Statement establishes that the scheme itself would
receive good levels of daylight and sunlight, and that amenity spaces both on and off-site would
comply with BRE overshadowing criteria in terms of meeting the recommended sunlight levels
throughout the year.
432 As set out within the response to consultation section of this report, particular concerns
were raised with respect to loss of daylight and sunlight and overshadowing at Decca Street (south
of the application site). Concern was also raised with respect to overshadowing at Master
Shipwrights House. Having regard to the modelling and conclusions of the Environmental
Statement (discussed above), GLA officers are satisfied that there would not be a materially
significant adverse impact on daylight, sunlight or overshadowing in these locations.
433 Accordingly, with respect to matters of daylight, sunlight and overshadowing, GLA officers
are satisfied that the outline application accords with the NPPF; London Plan Policy 7.6; and,
Lewisham’s saved UDP Policy HSG4.
Privacy/overlooking
434 As set out within the response to consultation section of this report, concerns have been
raised with respect to loss of privacy and overlooking from tall buildings and the proposed Jetty
Park. This issue was raised with particular reference to impacts on the Master Shipwrights House.
435 As recognised within the scheme’s Design Guidelines, the applicant and architect
acknowledge the need to appropriately manage privacy and overlooking issues as part of the
detailed design of the scheme. GLA officers note that there are, for example, various
balcony/external treatments (for tall buildings) and landscaping measures (for the Jetty Park)
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which would offer suitable options for appropriately mitigating issues of overlooking from the
scheme, and within the scheme itself. The applicant proposes to develop these approaches as part
of the detailed design at reserved matters stage. GLA officers are content with this approach, and
propose to secure the detail of the mitigation measures by way of planning condition. Accordingly,
with respect to issues of privacy/overlooking, GLA officers are satisfied that the application
complies with London Plan Policy 7.6.
Neighbourhood amenity conclusion
436 Having considered the proposed scheme in the context of its setting, and having also had
regard to local representations and the relevant technical assessments within the Environmental
Statement, GLA officers have concluded that the outline application would not cause significant
adverse local impacts with respect to issues of: daylight, sunlight and overshadowing; or,
privacy/overlooking. Accordingly the application complies with the NPPF; London Plan Policies
7.6; and, Lewisham saved UDP Policy HSG4.
Transport
437 Have had regard to the facts of the case, and the issues raised during consultation, the
relevant transport issues are: the adequacy of the transport assessment; capacity on the public
transport network; impacts on the local and strategic highway network; the amount of car parking;
traffic and parking impacts on local residents; proposals for cycling and walking; and, the adequacy
of mitigation measures.
438
The NPPF states that “Transport policies have an important role to play in facilitating
sustainable development but also in contributing to wider sustainability and health objectives…
The transport system needs to be balanced in favour of sustainable transport modes, giving people
a real choice about how they travel.” London Plan Policy 6.1 applies these principles within the
strategic approach for transport in London. Other relevant strategic transport policies in this case
include: providing public transport capacity and safeguarding land for transport (Policy 6.2);
assessing effects of development on transport capacity (Policy 6.3); cycling (Policy 6.9); walking
(Policy 6.10); smoothing traffic flow and congestion (policy 6.11); road network capacity (Policy
6.12); parking (Policy 6.13); freight (Policy 6.14); the Mayor’s priorities for planning obligations
(Policy 8.2); and, Mayoral Community infrastructure levy (Policy 8.3). Relevant local policies
include: Core Strategy Policy 14 - Sustainable movement and transport; and in the emerging
Lewisham Development Management Local Plan, Car Parking (DM Policy 29).
Transport modelling and assessment of scheme impacts and mitigation measures
439
TfL has previously identified the need for area-wide VISSIM modelling in particular of the
Evelyn Street corridor and of Deptford Church Street including the junction with the A2. This work
was considered necessary to enable further understanding of the interaction of the scheme with the
Strategic Road Network (Evelyn Street) and the TfL Road Network (A2), to test options to reduce
the impact of the development and to clarify the interrelationship between the proposals for Cycle
Superhighway.
440
Lewisham Council subsequently commented that the Mayor will need to be satisfied that
the data and subsequent modelling outputs are robust. Specifically, TfL must ensure that the
impacts are fully assessed and understood before the case is determined. The Transport Assessment
(TA) indicates that 16% of residents would use cars to travel during peak periods and 25% of
business users. This equates to 514 two-way trips during the AM peak and 426 two-way peaks
during PM peak. The applicant has provided further information to clarify likely car trip generation
and TfL has reviewed the traffic modelling and provided advice on model audit. Southwark Council
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has recently expressed concern that the TA has not considered the impact upon its area especially
the Lower Road gyratory at the western end of Evelyn Street.
441
TfL has proposed a two-stage approach to resolving highway impact issues; firstly,
establishing whether the proposed highway interventions are acceptable in principle and relate to
development impact based on models submitted, and then secondly undertaking further traffic
modelling (including micro-simulation using VISSIM) at detail design stage. Lewisham Council have
serious concerns with this approach and leaving matters for resolution after the outline application
has been approved as the detail may throw up impacts which have not been identified and cannot
be accepted on the network. They also note that the extent of that risk is yet to be determined by
TfL.
442
The development is phased and the developers have agreed to do further modelling at an
early stage of the development build out. TfL consider that this should happen prior to 10% of the
residential units (350 units) being occupied, which has been accepted by the developers, and allows
for verification of trip rates through actual experience of what is an unusual development as
opposed to estimates based upon standard TRAVL/TRICS databases and Census information, about
which there were previously expressed concerns. The further traffic modelling would need to be
prepared in accord with TfL Model Audit Process including micro-simulation models using VISSIM
and covering for assessment purposes the Lower Road gyratory west of Evelyn Street, Creek Road
to the east and Deptford Church Street/A2 in the south.
443
TfL, Lewisham Council and the applicant will need to work together on the design and
modelling of junctions in the area in conjunction with assessment of other schemes which would
impact upon local highways, notably Cycle SuperHighway 4 (CS4) and Lewisham’s scheme for
Deptford High Street. Southwark’s proposals for the removal of the Lower Road gyratory and the
cumulative impact of other committed development in the area will also need to be considered.
TfL’s advice is that it is unreasonable for approval of the development to be withheld at this point
on the basis of the need for further detail modelling, which is already required as part of TfL’s duty
under the Traffic Management Act 2004 and especially given the uncertainties which currently exist
as to the proposals and impact of CS4 (currently in design but programmed to be implemented prior
to first occupation of Convoys Wharf) and other emerging highway schemes.
444
The highway improvement proposals and financial contributions put forward by the
applicant as mitigation of the traffic impacts of the development and to enhance provision for
pedestrians, cyclists and buses and included in the proposed section 106 agreement will need
further assessment in the future. This assessment should include feasibility and optioneering work
in light of the eventual CS4 scheme for Evelyn Street and impacts of potential changes consequent
upon the other highway improvement schemes in the area. At this stage a detailed assessment
sufficient to determine if the applicant’s proposals for the junctions are fully feasible is not possible,
hence the inclusion in the proposed section 106 agreement of to be agreed specifications for the
various highway improvements on Evelyn Street for which an indicative allowance of £1,510,00 has
been made by the applicant. TfL does, however, consider it has sufficient understanding of the local
road network and scale of development in outline to provide a level of confidence that appropriate
highway measures to mitigate impact and to support non car travel are being developed and can be
delivered subject to safeguards in the proposed section 106 agreement, including a requirement
that if additional or different mitigation measures to those currently identified for the junctions on
Evelyn Street and/or other junctions are agreed these will be funded by the developer in relation to
the identified degree of impact which requires mitigation.
445
In addition to the proposals for Evelyn Street the developer has also offered to include
within the section 106 agreement provision for improvement of the local highways adjoining the
site – Grove Street, Prince Street and New King Street. These works would be delivered through
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section 278 agreements and would be aimed at enhancing conditions for pedestrians and cyclists
and to support bus operations as well as providing for development traffic. An indicative allowance
of £2,615,000 has been made for these works subject to delivery against a specification to be
agreed as part of the section 106 agreement. The applicant has also undertaken to make a financial
contribution through the section 106 agreement towards the Deptford High Street scheme of
£500,000 and £20,000 towards the Deptford Church Street/A2 junction. These contributions would
also focus on improving pedestrian and cyclist conditions and in the case of the Deptford High
Street funding enhancing the public realm and support for the function of the town centre both of
which would benefit the development as well as Deptford more generally.
Public Transport
Bus
446
The TA states that there will ultimately be an additional 554 bus trips towards Canada
Water and 149 trips towards Greenwich in the AM peak hour as a result of the development. The
capacity of the current bus network would be unable to support these trips. TfL has therefore
worked with the applicant to devise a package of bus service enhancements which could meet this
additional demand.
447
The following enhancements, to be funded for five years by the applicant, have been
agreed: three additional return journeys on existing bus services on Evelyn Street (the first to occur
at first occupancy with the subsequent two to occur respectively one and two years after this date);
diversion of a bus route through the development between Grove Street and New King Street upon
completion of the new spine road (due at 20% residential occupancy) and New King Street being
widened for two way bus operations; and, introduction of a new bus route on 33% residential
occupancy.
448
Using TfL’s standard costings the total section 106 contribution would be £5,750,000
comprising £270,000 a year for five years for the additional return journeys on Evelyn Street and
£880,000 a year for five years for the new route. The diversion of the bus route into the site
would be at nil cost provided that the improvements to services on Evelyn Street were
implemented.
449
Subject to future assessment and consultation, the diverted service would be the 199 which
currently runs on the northern section of Grove Street and has termini at Bellingham and Canada
Water. The current intention is that the new route would link the site to Surrey Canal Road and
Greenwich. Overall the enhanced bus service would link the site to a variety of local destinations
and to central London, the City and Canary Wharf including via National Rail (NR) and Docklands
Light Railway (DLR) stations and the proposed river bus service.
450
These bus service enhancements would be supported by new bus stops on the spine road
included within the development and new and upgraded bus stops off site, in particular on Grove
Street and Evelyn Street. The applicant has agreed to provide these bus stops via in kind work or a
financial contribution determined by TfL as being £47,500. All stops would be to full TfL
accessibility standards and meet other current requirements.
451
The applicant will also cover the costs of enabling two way operation of buses on New King
Street along with walking, cycling and public realm improvements to this route. These works would
be implemented in time for the bus route to be diverted through the site, subject to the necessary
land being made available by Lewisham Homes. The proposed section 106 agreement would also
include the improvement of other highways along which buses currently or could in the future run.
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452
The bus proposals are supported by TfL. They would ensure that new residents and others
visiting or working at the site would be able to access the bus network (i.e. be within 400m of the
nearest accessible bus stop) and interchange with the proposed river bus services would be
promoted. In addition bus journey times and reliability should be protected.
453
Having accordingly considered the phasing, scale and nature of the proposal, TfL is
satisfied that the expected bus travel demand arising from the development could be
accommodated on the bus network with the above mitigation and without detriment to existing
passengers.
Riverbus
454
The site is currently passed by a commuter service which runs between Embankment Pier
and Woolwich Arsenal. The applicant has proposed to provide a new river bus stop within the
development, which would be accessible from a pier at the eastern end of the site which is also
proposed. The applicant has also offered £3,000,000 to pump prime a service stopping at the site
and would build the new pier and associated land facilities as part of the development, by 20%
residential occupancy.
455
The TA has assumed 10% of residential trips and 5% of other trips will be by river. Based
upon experience elsewhere, TfL considers these estimates to be realistic. The proposed riverbus
service is essential part of the public transport package for the development and will help reduce
car dependency and additional pressure on other public transport. It will contribute to the
promotion of sustainable transport for this development and the wider area.
456
As well as meeting operational requirements, the detailed design of the pier will need to
consider how passengers, particularly disabled passengers, access vessels at all stages of the tide.
Consideration will also be required to ensure that the operation of the river bus services does not
impinge on the ability to operate the wharf and vice versa.
Rail
457
In the TA 36% of trips in the morning peak hour in or out of the development are expected
to be by London Overground, London Underground and DLR and a further 12% by NR trains.
Whilst this equates to just over 1000 passengers TfL consider that these can be accommodated on
the network especially given that Crossrail will be operational before much of the development is
expected to be occupied.
458
Deptford NR station is within walking distance of the site, however, it is likely that the
other local stations (Cutty Sark, Greenwich, Deptford Bridge, Surrey Quays and Canada Water)
would require passengers to travel by bus or cycle. The proposed bus enhancements and for
walking and cycling trips to be delivered by the development would support rail travel.
Cycling
459
A total of more than 4,300 cycle parking spaces are proposed within the development for
all uses. The level of provision complies with the London Plan standards in Table 6.3 and in the
Revised Early Minor Alterations (October 2013). The final numbers and their nature and location
are to be agreed in later reserved matters applications and would be subject to a condition
requiring, as a minimum, levels of provision compliant with the London Plan.
460
TfL supports the applicant’s intention to safeguard space for the installation of two Cycle
Hire docking stations in anticipation that the scheme will be extended to Deptford, thus providing
an additional choice of mode of travel. TfL considers that a financial contribution towards the cycle
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hire scheme is inappropriate at this stage as the site lies some distance outside of the existing cycle
hire area.
461
A network of cycle links are proposed within the site, including the extension of the
Thames Path along the entire riverside, thus avoiding a long diversion inland. In addition the off
site highway improvements to be secured via section 278 agreements or financial contributions in
the section 106 agreement includes enhanced provision for cyclists. These proposals are welcomed
and are in accord with national, regional and local policy.
462
Cycle Superhighway 4 (CS4) is intended to run along Evelyn Street. It is programmed to be
installed before the proposed upgrades to this highway take place which would be delivered
through the development’s section 106 agreement. TfL is therefore in discussion with Lewisham
Council (the highway authority for Evelyn Street) and the applicant regarding the emerging design
for CS4 to take into consideration the expected impacts of the Convoys Wharf development and in
particular the mitigation intended on Evelyn Street. In turn the applicant’s proposals as they are
detailed up will be required to take account of CS4 so as to avoid potentially abortive work and
maximise the effect of the section 106 contribution.
Walking
463
The applicant proposes a number of improvements that will enhance conditions, safety and
capacity for local pedestrians and create a more attractive walking environment in line with London
Plan policy 6.10. These include the extension of the Thames Path along the entire length of river
bank within the site and enhancements to the key pedestrian desire line between Convoy’s Wharf
and Deptford town centre. In addition a number of new pedestrian and cycle accesses are proposed
to better integrate the site with the surrounding area and reduce its historical isolation arising from
its function as a wharf. These are welcomed.
464
A Fruin analysis of New King Street has shown that there is sufficient capacity even within
the current footway layout to support the predicted number of pedestrians going to/from the town
centre including the station (over 1000 two way trips in the AM peak). A Pedestrian Environment
Review System (PERS) audit has been conducted by the applicant and the results show the
majority of local routes have good footways and adequate lighting. Nonetheless, in addition to
funding improvement of parts of Evelyn Street and New King Street identified in the PERS audit as
requiring enhancements, a significant outcome of the highways works which the applicant has
agreed to include as section 106 obligations would be the upgrade the other local routes and
crossings and in particular the key town centre desire line.
465
As noted above the specification for the highway improvements would be agreed as part of
the section 106 agreement and would be informed by the CS 4 proposals and the outcome of the
required future detailed modelling and assessment work to be undertaken. Lewisham Council’s
preference for an all red phase for pedestrians crossing Evelyn Street between New King Street and
Deptford High Street is understood. This preference would be considered as part of the future
detailed work to be undertaken jointly. However, TfL has concerns that because of the complexity
and constraints at the junction, this option would delay buses and cyclists as well as general traffic
on Evelyn Street resulting in congestion without necessarily providing the best environment and
most convenient and quickest route for pedestrians. This matter will be discussed and resolved
through negotiation when further information is available as to the relative merits of different
options.
466
The indicative cost of the section 278 works to Grove Street, Prince Street, Evelyn Street
and New King Street is £4,125,000, of which about half would be focussed on the town centre
desire line. In addition the applicant has committed to a £500,000 section 106 contribution
towards Lewisham’s scheme for Deptford High Street and a small sum (£20,000) for TfL’s
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proposed pedestrian and cycle improvements at the Deptford Church Street/A2 junction to the
south of the town centre.
467
The timing of the proposed off-site improvements for pedestrians would be related to the
phasing of development and the objective is to ensure that the enhancements are at least in step
with demand so as to encourage walking including to/from public transport. However, it should be
noted that delivery of the land required for the widening and other improvements of New King
Street is dependent upon Lewisham Council as the non-highway land is owned by Lewisham
Homes. Council officers are seeking to secure this land for the scheme. The proposed section 106
agreement includes a requirement for both the applicant and the Council to work together to
deliver the land. However, it is not considered necessary to impose a Grampian condition or other
restriction upon the development pending this being achieved as in the opinion of TfL, it has been
successfully demonstrated by the applicants that the additional land is not essential to support
walking (and cycling and use of public transport). Nonetheless the applicant is committed to the
improvements which could take place to New King Street within a wider corridor and sees their
value in terms of making their development more attractive.
468
In response to TfL’s request at pre-application stage, the applicant has agreed to
incorporate the Legible London way-finding system within the site, in particular to guide
pedestrians and cyclists towards the extended Thames Path and to the proposed Riverbus pier.
Off-site signing would be part of the aforementioned highway works.
469
In summary, officers support the on and off site proposals for walking and consider that
their delivery can be secured through the recommended conditions and planning obligations, thus
promoting and facilitating walking in the area in line with London Plan Policy 6.10.
Car parking
470
A ratio of 0.44 car parking spaces per dwelling is proposed, equivalent to the low current
ownership level within the area especially when compared to elsewhere in the borough or at similar
developments. This level of parking falls well below the maximum London Plan standards in Table
6.2 and represents a reduction in provision from that proposed in previous applications., which is
welcomed. In addition to the maximum of 1,540 spaces for the housing, a further 300 spaces are
intended to serve the other uses which is also compliant with London Plan Policy 6.13.
471
The anticipated impact of vehicle trips to be generated by the development on the highway
network which in part is a consequence of car parking numbers is discussed above. TfL considers
that in establishing parking levels an appropriate balance has been struck between minimising car
movements especially in the peaks and securing a successful development. TfL therefore
welcomes the applicant’s offer to monitor the uptake of parking spaces and associated traffic
generation as the development is built out and accordingly a review mechanism is included within
the proposed section 106 agreement. It is recommended that reviews take place at 10% (350
dwellings) occupation and at 33% (new bus services) with further review points agreed by the
Council and TfL through the site parking management plan.
472
Given the necessary restriction on car parking provided on site, TfL welcomes the
applicant’s proposed contribution of £250,000 for the provision and funding of a Controlled
Parking Zone (CPZ) and their agreement that residents and other occupiers of the Convoy’s Wharf
scheme would not be eligible for parking permits. In addition the site parking management plan
which is also to be required by the proposed section 106 agreement would control on-site parking
by residents, other occupiers and visitors to the site. TfL considers these provisions as being
essential for the future sustainability of the development, to control traffic generation to
acceptable levels and to protect bus operations and promote walking and cycling, in accord with
London Plan policy.
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473
In addition, the applicants are proposing to introduce an ‘on-street’ car club, with up to 35
spaces reserved to be introduced in a phased manner in response to increase in demand. The car
club proposals are strongly supported by TfL as a way to reduce car ownership in the area. To
encourage the take up of the car club and reduce the need for private residential parking, the
applicants have agreed to fund car club membership for the residents for a period of three years to
be secured within the section 106 agreement.
474
There is local concern about the potential removal of parking on New King Street and the
implementation of a CPZ. It is agreed by all parties that replacement on street parking bays should
be provided for local residents and businesses as part of the New King Street highway
improvement scheme. A CPZ would not only protect local people from overspill parking from the
Convoy’s Wharf development but also by commuters and those displaced by the CPZ in the
adjoining area ( in the Royal Borough of Greenwich) and controls within existing estates. As such
TfL considers both concerns to be suitably addressed.
475
TfL notes that Blue Badge and motorcycle spaces and Electric Vehicle Charging Points
(EVCPs) are to be provided in accordance with London Plan standards for each use, which is
supported. The locations and other details for these would be part of the submission of the
reserved matters and details for each phase/plot.
476
The Council raised concerns about the amount of on-site parking proposed being too much
for the highway network to accommodate and to enable key pedestrian, cycling and public
transport improvements to take place. Local objectors have suggested that there is either too little
parking or too much. TfL is satisfied that subject to a suitable framework of controls and mitigation
measures including the site parking management plan, permit- free agreement, electric vehicle
charging points, travel plan and car club spaces that the proposed level of parking strikes an
appropriate balance between promoting new development and encouraging cycling, walking and
public transport use in accord with national, regional and local policy.
Travel plan
477
The submitted transport assessment includes a framework Travel Plan, which has passed the
ATTrBuTE assessment used by TfL to assess the content. The plan seeks to actively promote the
use of non-car modes of transport, including walking, cycling and the use of public transport. It also
supports the car club and aims to reduce single occupancy trips by those who do use a car. Full
Travel Plans for each of the uses and monitoring of these by the Council, together with a School
Management Plan are required in the proposed section 106 agreement.
Access, deliveries and servicing
478
Two vehicular access points are proposed – the existing one at the end of New King Street
at the junction with Prince Street towards the eastern end of the site and reopening of one which
has been closed for some years on Grove Street at the western boundary. The proposed new river
wharf would be accessed from the latter, which was used previously when the whole site was an
operational wharf and can accommodate large articulated vehicles and other HGV’s. The applicants
have also put forward a design for the New King Street access so that it too can accommodate large
vehicles. The two accesses would be connected within the site by a proposed ‘spine’ road off which
there would be links to the various parts of the development.
479
It is proposed that on-street loading bays would be provided adjacent to the carriageway to
meet servicing needs of non-wharf uses, whilst servicing of the latter would be accommodated
within the plot. These bays would be designed so as not to interfere with the free running of traffic
and in particular bus operations on the spine road which would run between the two accesses. The
details of these arrangements would be subject to approval subsequently.
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480
TfL welcomes the intention to develop a Delivery and Servicing Plan (DSP) following grant
of consent. This framework plan is to be secured in the proposed section 106 agreement and
detailed plans would be developed as appropriate as the scheme progresses. The DSPs should
include a commitment to use best practice operators, demonstrated by membership of TfL’s Freight
Operator Recognition Scheme (FORS) or similar. These proposals are in line with London Plan
policy 6.14.
481
Given the size and nature of the development, and the constraints on access, a requirement
for a servicing management plan is also included in the proposed section 106 agreement. This plan
should include the periodic monitoring of HGV movements especially once the wharf is operational.
It should also consider road safety issues which are a stated concern of local residents. It should be
noted, however, that the impacts from servicing and related activity at the development would be
less than was the case when the whole site was an operational wharf.
482
As stated elsewhere in this report the provision of a new wharf is welcomed and in line with
national, regional and local policy.
483
The applicant has proposed to provide coach access to the hotel by means of drop-off/pick
up bay(s). The London Plan standard states that 1 coach parking space should also be provided per
50 rooms. As it is unknown at this stage how large the hotel(s) would be, TfL supports a proposed
condition to ensure appropriate provision for coaches to be included within later reserved matters
applications. Appropriate provision for coach and minibus access should be made elsewhere within
the development in particular for the proposed school, the Olympia building and the proposed
visitor centre.
484
TfL welcomes the proposed taxi rank which is considered to be in an acceptable location
within the centre of the development close to the proposed hotel, the Olympia building and the
new river pier. The detailed design of the taxi rank should be discussed with the TfL prior to
submission of the details. Taxis (black cabs) and private hire vehicles provide an essential door-todoor service, and are particularly important for disabled passengers, passengers who may not be
able to access other transport modes, and is a safe form of transport for late night travellers.
485
Suitable provision should also for drop off and pick up by car at the different parts of the
development. The details of these arrangements should be subject to approval via condition.
Demolition, site clearance and construction
486
The development is of a significant scale and will take place over a number of years. The
importance of a Construction Logistics Plan (CLP), in line with London Plan policy, and a
construction Travel Plan are all the more significant. It has therefore been agreed by the applicant
that section 106 obligations should include a requirement to prepare and secure approval for these
plans and subsequently implement them. Together these plans should ensure that demolition, site
preparation and construction related logistics and travel takes place in an efficient and planned
way, minimises disruption to road users, mitigates impacts on neighbouring residents and the new
occupiers and promotes highway safety especially for vulnerable users. The plans will include the
construction programme, access arrangements, size and nature of construction vehicles, frequency
and programming of construction vehicle movements, construction routes to/from the site, site
workers travel and parking arrangements. The CLP should also include a commitment to use best
practice operators, demonstrated by membership of TfL’s Freight Operator Recognition Scheme
(FORS) or similar.
487
The TA states the applicants intend to make use of the river for transport of materials into
and out of the site. This should be investigated further and use of the river maximised during site
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preparation and demolition and construction phases, particularly as the site includes a wharf. This
information should be included within the CLP in order to comply with London Plan policy.
Transport conclusion
488 With respect to issues of transport: the application submission includes sufficient
assessment at this stage to establish an appropriate context for decision making and to provide the
basis for subsequent more detailed work as the scheme is progressed. The proposals would strike
an appropriate balance between promoting new development and encouraging cycling, walking
and public transport. The scheme would contribute towards a range of public transport and walking
and cycling improvements in the area and be accessible by a range of means of transport. The
quantum of proposed car parking is acceptable, subject to a suitable framework of controls and
through the promotion of non-car modes of transport. Appropriate controls and mitigation
measures are proposed to ensure that transport impacts (during construction and subsequently)
would be acceptable. Accordingly, the application complies with the NPPF; policies contained
within Chapter 6 of London Plan; Lewisham Core Strategy Policy 14; and, emerging Policy DM 29
within the submission stage Development Management Local Plan.
Other issues raised during consultation
Community projects
Sayes Court Garden programme
489 As discussed within the response to consultation section of this report, Sayes Court Garden
CIC seek to secure a centre of excellence in urban horticulture at the site as a means of expressing
the John Evelyn legacy and celebrating the historic relationship between Sayes Court Manor and
Sayes Court Garden. The National Trust has a fundamental association with the John Evelyn legacy
at the site, and strongly supports this proposal. It is envisaged that the National Trust would
ultimately operate the centre proposed.
490 The community group has stated that to deliver a viable programme it requires 1,500 sq.m.
of floorspace for educational space, and a direct interface with one hectare of cultivatable open
space. As discussed in the response to consultation section of this report, the community group has
also consistently expressed the view that the optimum way to deliver the programme would be to
provide the horticultural centre as a standalone building set within open space. Accordingly, Sayes
Court Garden CIC seek a revision to the minimum parameter at masterplan plot sixteen in order to
allow for the scheme to come forward in a way which would deliver a larger proportion of open
space at the plot and/or, not preclude the delivery of a standalone building at reserved matters
stage. As part of this response (and notwithstanding the position that a standalone building would
be the preferred option), the community group has provided a number of other design studies
which would potentially see the horticultural centre delivered as part of a larger mixed use block –
albeit an open ended one (such as a ‘U’ and ‘L’ shaped layout). GLA officers note that the effect of
the ‘U’ or ‘L’ shaped layout would be to provide access to additional open space at the heart of the
plot. Further informal discussion with the community group has indicated that, subject to business
plan testing, it may be possible to deliver the proposed horticultural programme through a centre
provided within a ‘U’ or ‘L’ shaped mixed use block.
491 Having considered the community group’s response, GLA officers are of the view that,
whilst a standalone building brings some advantages (as set out by the community group in
paragraph 172), a horticultural centre incorporated within a mix use block also brings some
benefits. Furthermore, having regard to the more recent submission made by issues raised by Sayes
Court Garden CIC (including options for a ‘U’ or ‘L’ shaped mixed use block layout), GLA officers
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have broadly concluded that it is the interface with, and provision of, cultivatable open space which
is likely to be the key determinate of programme viability.
492 GLA officers strongly support the key aims and associated potential public benefits of the
Sayes Court Garden programme, and have carefully considered the issues that the community group
has raised. Whilst it is acknowledged that it would be possible to revise the outline parameters in
the manner proposed by Sayes Court Garden CIC, GLA officers are of the view that breaking up the
courtyard perimeter at this plot would undermine some important urban design principles of the
masterplan. When considering the characteristics of plot sixteen as proposed, it is important to note
that its perimeter block layout provides good definition to surrounding masterplan routes and
spaces, and offers clearly defined thresholds between the public realm and private amenity space.
This approach focuses public activity on the surrounding streets and public spaces (ensuring that
these areas are perceived as welcoming and safe) and provides a clear sense of ownership for
private amenity areas (ensuring that these are valued and well-used by residents). The plot sixteen
block works collectively with adjacent blocks to reinforce these positive principles through the
masterplan - providing good definition to Olympia square to the northeast, and the open parkland
to the southwest. With these principles established it is clear that opening the courtyard perimeter
at plot sixteen would be detrimental to the definition of the southwest parkland, and would create
a poorly resolved space at the heart of the plot. The perceived role of the latter is likely to be
unclear for residents and visitors alike, as it would not be obvious whether the space is intended to
operate as an extension of public realm, or, as a semi-private amenity space. Ultimately this would
have negative implications for the quality and attractiveness of this space, undermining its
contribution to the wider network of open spaces in the locality.
493 As part of this consideration it is also important to bear in mind that a key part of the
rationale for seeking the incorporation of the proposed primary school and John Evelyn
horticultural centre within plot sixteen is to promote vibrancy, and to create a critical mass of
educational, cultural and community uses. GLA officers are of the view that a community hub of
this nature would positively contribute towards the creation of sustainable communities within the
scheme, and offer a number of important symbiotic advantages for both the school and the
horticultural centre, including: educational overlap; future opportunities for shared spaces;
increased community/visitor footfall; and, enhanced opportunities for community
engagement/outreach. Officers are of the opinion that a dispersal or disaggregation of these
community uses, through a breakup of the courtyard block, would fail to take full advantage of the
cumulative opportunities and benefits mentioned above.
494 For the above reasons GLA officers have not sought a revision to the minimum parameters
at masterplan plot sixteen. However, a number of proposals have been made by the applicant with a
view to successfully incorporating the horticultural programme within the masterplan. Accordingly,
the proposed offer for accommodating the Sayes Court Garden horticultural programme is as set
out below.
Proposed approach to accommodating the project


For a peppercorn rent Sayes Court Garden CIC may fit out and operate 1,500 sq.m. of the
proposed John Evelyn Centre in order to run the horticultural programme. The centre will be
built out to a shell at the cost of the applicant (estimated at £2,420,000). This centre would
be tangibly linked to the (displayed) archaeology related to Sayes Court Manor, and will
benefit from a direct connection with green open space - recalling something of the historic
presence of Sayes Court Garden.
The applicant has offered Sayes Court Garden CIC an allocation of open space adjacent to
the proposed John Evelyn Centre, and (subject to provision of a sound business plan) a
financial contribution of £250,000 towards the landscaping of this space for the
horticultural programme.
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
There is also potential to expand the programme into the adjacent Sayes Court Park to
ensure that the critical requirement for the provision of open space could be met. The
applicant proposes an open space contribution of £560,000, part of which is proposed be
directed to deliver enhancements to Sayes Court Park. Subject to further discussion with
Lewisham Council, an opportunity to enable delivery of a landscaped extension to the
horticultural programme as part of wider parkland improvements could be secured.
495 The abovementioned offer has only been made by the applicant relatively recently
(following GLA-led negotiations), and at the time of writing this report Sayes Court Garden CIC has
not accepted the accommodation and project enabling offer set out above. Instead, the community
group maintains that a revision to parameter plans is required in order to ensure project viability –
by delivering the necessary open space provision. Notwithstanding this, it is hoped that further joint
negotiations between the applicant and the community group will progress positively towards
agreeing favourable terms, so that GLA officers can ultimately secure these as part of detailed work
on the proposed section 106 legal agreement.
Build the Lenox project
496 As discussed within the response to consultation section of this report, The Lenox Project
CIC seek to construct a full-sized replica seventeenth century warship (Lenox) on the site of the
former Deptford Royal Dockyard where it was originally built. Key to the project vision is a long
term legacy of related cultural and vocational programmes.
497 The community group has stated that its preferred construction location to deliver a viable
project is the Olympia building (Grade II). The group also seeks reinstatement of a basin feature in
order to allow the ship to be launched into the Thames, and to become the Lenox’s home port –
supporting a long term legacy. Accordingly, The Lenox Project CIC effectively seeks: use of half of
Olympia for ship construction and a visitor/training programme; and, a revision to the masterplan
to provide a basin feature. Issues associated with these requirements are considered under the
respective sections below.
Use of Olympia
498 The proposed use of Olympia for shipbuilding would bring an exciting and locally specific
heritage project to the heart of the scheme, simultaneously returning the Listed Building to its
former use. In principle this would be strongly supported by London Plan Policy 7.9. However, it is
important to note that this policy also seeks to ensure that Listed Buildings are put to a viable use
- in order to secure the long-term future of the heritage asset. Accordingly, there is a requirement
for the combination of uses at Olympia to be financially self-sustaining. In this context it should be
noted that the applicant has budgeted more than £12,000,000 for restoration and refurbishment
works to the Listed Building. As discussed in the sustainable communities section of this report, the
Cultural Strategy sets out a range of potential uses for the Listed Building which are intended to
promote public use and vibrancy at the heart of the site, as part of a sustainable business model
that would secure Olympia’s future. The proposal to construct the Lenox in half of the Olympia
space obviously impacts on the space available to deliver the form of multi-use proposal envisaged
for the Listed Building. That is by no means to say that a viable solution for accommodating both
Lenox shipbuilding and a multi-use commercial offer at Olympia could not be found. However, it is
likely to add additional complexity (and potentially additional financial burden) to the Lenox
project business plan.
499 English Heritage has expressed its strong in principle support for the Lenox project at
Olympia, whilst also confirming that a robust business plan will be a key component of its own
assessment of a detailed proposal to use the Listed Building for the project. In conjunction with
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this, English Heritage also seeks a feasibility study for the project so that any potential harm to the
Listed Building itself, or the archaeology beneath it (slipways two and three), may be fully
considered as part of the proposal. As set out within the response to consultation section of this
report, the MP for Lewisham, Deptford, has also expressed support for such a study, suggesting
that in may be designed to look at the Convoys Wharf site more broadly, in order to establish the
most feasible and viable location for the project to take place.
Provision of a basin feature
500 The Lenox is too large to be fully constructed within the Olympia building, therefore, a
body of water in the location of the former Great Basin would be necessary to allow for this to take
place in what is currently proposed to be the northern part of Olympia Square. The basin would
also provide a home port for the ship (anchoring the proposed legacy to the site), and crucially, it
would deliver the necessary 120 metre waterway required to launch the ship from Olympia into the
River Thames. It is, nevertheless, noted that the aforementioned waterway would sever one of the
masterplan’s key routes, and require deconstruction of part of the Jetty Park (and probable
relocation of the proposed River Bus terminal). It is also not clear what impact the proposed ship
building, and mooring of the ship in the heart of the development, would have on the residential
amenity of neighbouring blocks. The community group proposes that these issues may be
overcome by various mitigation, bridges and engineering solutions, however, it is not currently
clear whether The Lenox Project CIC has included contingency for these works within its own
business plan. Having regard to the financial viability of the development (discussed within the
housing section of this report) GLA officers concur with the applicant’s assertion that the scheme
could not afford to bear the financial burden of these enabling works whilst delivering the
proposed level of affordable housing and the planning obligations necessary to mitigate the impact
of the development. Whilst it is acknowledged that the community group is of the view that the
provision of a basin may be self-financing given the potential for increased waterway views and
moorings, this has yet to be demonstrated.
501 GLA officers strongly support the key aims and associated potential public benefits of the
Build the Lenox Project, and have carefully considered the issues that the community group has
raised. However, having regard to the matters discussed above, and with the intention of securing
a genuinely viable solution to enable the project to take place at the site, the following offer has
been made by the applicant.
Proposed approach to accommodating the project
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

For a peppercorn rent The Lenox Project CIC may occupy approximately 4,000 sq.m. of the
wharf site to build the Lenox from ground level or from an excavated slipway.
The (current) lease offer is for seven years, with an option for an additional three years.
Subject to provision of a sound business plan, the applicant has also offered to discuss
options for the timing and delivery of enabling infrastructure at the wharf to support the
Lenox construction programme.
502 The abovementioned offer has only been made by the applicant relatively recently,
following GLA-led negotiations. However, the initial reaction from the community group has been
that the temporary nature of the offered accommodation at the site is at variance with the long
term aims and aspirations of The Lenox Project CIC. Notwithstanding this, it is hoped that further
joint negotiations between the applicant and the community group will progress positively towards
agreeing more favourable terms, so that GLA officers can ultimately secure these as part of
detailed work on the proposed section 106 legal agreement.
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Master Shipwrights House and Dockyard Office (Grade II*)
503 As part of the response to local consultation a number of concerns were raised in relation to
impacts on, or the proposed interface with, the Grade II* Listed Master Shipwrights House and
Dockyard Office. A number of these issues are addressed in other sections of this report, however,
those that remain relate to: concern that the proposed landscaping strategy (and children’s play
area) may preclude aspirations for north/south access along the west elevation of the Master
Shipwrights House site; concern that the masterplan does not consider access or public realm
issues associated with emerging pre-application proposals at the Master Shipwrights House site;
and, concern associated with potential “significant adverse” construction stage impacts on the
Grade II* Listed Building.
504 In so far as the design issues are concerned, GLA officers note that the masterplan proposes
a large area of public open space west of the Master Shipwrights House, and that this provides for
considerable flexibility with respect to resolving the detail of boundary treatments and access
routes between these two sites (to be considered in conjunction with any emerging plans for the
Master Shipwrights House site) at reserved matters stage. With respect to the impacts on the
Listed Building during the construction phase, it is noted that the potential construction impacts
have been duly considered within the Environmental Statement, and GLA officers are satisfied that
the mitigation measures outlined are appropriate to mitigate the risk of any significant adverse
effects during the construction phase.
Issues raised by neighbouring local authorities
505 As discussed in paragraphs 149 and 150 Southwark Council has expressed the view that the
proposed development is likely to adversely impact on the London Borough of Southwark with
respect to: vehicular traffic; secondary school places; and, air quality.
506 Issues associated with transport, social infrastructure and air quality have been considered in
the corresponding sections of this report. Having considered the representations that Southwark
Council has made, GLA officers acknowledge that the proposed development may result in impacts
on the London Borough of Southwark. Nevertheless, having had regard to the circumstances in this
case (including the financial viability of the scheme), GLA officers are of the view that the planning
obligations proposed in paragraph 2 of this report have been appropriately prioritised, and, are
necessary to make the development acceptable in planning terms; directly related to the
development; and fairly and reasonably related in scale and kind to the development. Accordingly,
GLA offices take the view that whilst the proposed development may cause impacts on the London
Borough of Southwark which have not been mitigated, these impacts would be outweighed by the
wider regenerational benefits of the scheme.
Reuse of existing buildings
507 As part of the response to local consultation concern was raised that the proposal did not
take a more pro-active or sustainable approach to the reuse and refurbishment of existing
buildings at the site. With respect to this point GLA officers note the applicant’s commitment to
refurbish and restore the Olympia building (Grade II) to a viable long term use, and also the
proposal to use a number of existing structures at the site for temporary construction related uses
during the phased delivery programme. For the avoidance of doubt, GLA officers are satisfied that
the proposal constitutes sustainable development as defined by the NPPF.
Public engagement and public consultation
508 A number of local objections raised concern that the applicant had not sufficiently engaged
or consulted with the community on the proposed development, particularly in the period prior to
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submission of the outline application. A concern was also raised that there was insufficient access
to the submitted application material during the statutory consultation process.
509 Whilst pre-application public consultation is not a statutory requirement, Lewisham Council
and the GLA always advocate comprehensive community engagement. As set out within the
Statement of Community Involvement the applicant has undertaken a series of public consultation
events in March 2012 (attended by over 350 people) and July 2012 (attended by over 200
people). A final consultation exercise was also undertaken in February/March 2013, just prior to
submission of the application. These events included community open days and feedback sessions
and were well attended by local stakeholders and key members of the applicant team. It is,
nevertheless, accepted that the public engagement strategy did not reach the whole of the local
community. Notwithstanding this, GLA officers are satisfied that the applicant has made
reasonable endeavours to engage with the public on the scheme, and to accommodate key
community aspirations within the outline masterplan where practical/feasible.
510 With respect to the concern associated with access to submitted documentation, GLA
officers note that as part of the statutory consultation on the application Lewisham Council has
made hard copies of all application material available at Lewisham Council’s Business Centre
(Laurence House, Catford), and the Deptford Lounge library. The Council has also published all of
the submitted plans and documentation on its website. The same publication methodology was
used during the Mayor’s public consultation on revised plans, and, in addition, copies of the
revised plans were also made available to view at City Hall, and on the GLA website. As discussed in
the response to consultation section of this report, for both rounds of public consultation notice
was given in the local press, and letters (clearly setting out how and where the planning application
could be viewed) were sent to approximately 10,000 local addresses. Accordingly, the statutory
obligation with respect to public consultation has been fulfilled, and GLA officers are satisfied that
the local community had sufficient access the submitted documentation.
Scope and rigour of the outline application
511 A number of objections were raised by the local community with respect to the scope and
rigour of the submitted application documents. A particular concern was that a detailed first phase
had not been submitted in tandem with the outline masterplan (Lewisham Core Strategy Policy
SSA1 identifies this as a requirement for designated strategic sites such as Convoys Wharf). GLA
officers have considered the nature of the submission in respect to the requirements of Core
Strategy Policy SSA1 in the principle of development section of this report. Further to this, and
following the submission of revised plans and a number of document addendums (and
notwithstanding the proposed inclusion of various planning conditions and obligations), GLA
officers are satisfied that the detail and coverage of the submission documents is sufficient to allow
for a full assessment of the outline scheme.
512 A separate concern was also raised that there was insufficient design detail within the
outline application to allow for appropriate special regard when considering the proposed impact
on Listed Buildings. GLA officers have set out an assessment of the impact of the proposal on
Listed Buildings within the heritage section of this report. For the avoidance of doubt, having had
special regard to the desirability of preserving Listed Buildings, their settings and any features of
special architectural or historic interest which they possess, GLA officers are satisfied that the
proposed development would conserve the significance of the Olympia building (Grade II) and
Master Shipwrights House and Dockyard Office (Grade II*) and enhance the settings of these
Listed Buildings. The proposal would not cause harm to the setting or significance of the other
Listed Buildings at the site, or in the surrounding townscape.
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513 A consultation response also queried whether a full environmental assessment had taken
place for the current outline application, give that baseline information used to support an earlier
planning application at the site in 2010 was still referred to within the current Environmental
Statement submission. For the avoidance of doubt, GLA officers are able to clarify that, whilst
baseline information from a 2010 assessment (associated with an earlier iteration of this scheme) is
still relied upon by this application, the submitted Environmental Statement assesses the impact of
the current outline application.
Other issues raised during consultation – conclusion
514 The other issues raised as a result of the consultation process do not present any material
planning issues which have not already been considered within this report.
Mitigating the impact of development through planning obligations
515 The NPPF states that “Local planning authorities should consider whether otherwise
unacceptable development could be made acceptable through the use of conditions or planning
obligations. Planning obligations should only be used where it is not possible to address
unacceptable impacts through a planning condition.” At the regional level, London Plan Policy 8.2
sets out the Mayor’s priorities for planning obligations, and states: “Affordable housing; supporting
the funding of Crossrail where this is appropriate (see Policy 6.5); and other public transport
improvements should be given the highest importance”. At the local level Lewisham’s Planning
Obligations SPD provides the basis for determining planning obligations when considering planning
applications for development in the borough.
516 Pursuant to the consideration within the previous sections of this report, and in line with
the policy context set out above, GLA officers propose to secure a number of planning obligations
required to appropriately mitigate the impact of this proposed development. A full list of the
obligations proposed in this case is provided within paragraph 2 at the beginning of this report.
However, where appropriate, GLA officers provide additional commentary below to support the
consideration within this report, and to inform the proposed detailed drafting of a section 106 legal
agreement.
Safeguarded wharf
517 As discussed in the safeguarded wharf section of this report, GLA officers propose to secure
a programme for wharf activation, along with a financial contribution of £7,239,000 for enabling
infrastructure at the wharf site.
Local employment and training
518 GLA officers propose to secure a sum of £1,000,000 for the provision of affordable
business space within the scheme. It is envisaged that this would support the provision of
approximately 960 sq.m. of business incubator space as part of the first phase, and a further 370
sq.m. in phase three. This space would be fitted out ready for occupation by the applicant, and
start-up occupiers would be offered rent free space for an agreed period of time. It is also
proposed to secure an additional £500,000 for local training and employment initiatives.
Affordable housing
519 As discussed in the housing section of this report, GLA officers propose a mechanism to
secure further financial reviews at appropriate milestones along the delivery programme. The
mechanism will be such that once an agreed profit benchmark has been met, any financial uplift
within the scheme will be split between the applicant and the Council, with the Council’s allocation
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ring-fenced to fund the delivering of additional affordable housing units within the borough.
Notwithstanding this, the review mechanism will also be designed to allow for a proportion of any
financial uplift to ‘top up’ the educational contribution (discussed below). If/when the educational
contribution has been paid in full, all further financial uplift directed for the Council’s
apportionment would be allocated to affordable housing.
Education
520 Whilst the scheme itself includes a primary school facility, the development will,
nevertheless, generate a requirement for additional educational infrastructure (secondary and sixth
form). Accordingly, a contribution of £881,000 has been agreed having regard to Lewisham’s
Planning Obligations SPD, and what the scheme proposes to deliver on site. Given the constraints
of financial viability (and in conjunction with other necessary planning obligations) the scheme
cannot currently afford to make this contribution in full. Therefore, having had regard to the facts
of the case, it is proposed that the abovementioned contribution is paid in part (£440,000), with a
top up to a maximum of £881,000 proposed, subject to the review mechanism discussed in
paragraph 519. GLA officers recognise and accept that if the viability of the scheme does not
improve, and the top up cannot be paid, the impact of the development on educational
infrastructure would not be fully mitigated. However, having regard to the cumulative benefits of
the proposed development (refer to paragraph 424) GLA officers are satisfied that any such gap in
mitigation would be substantially outweighed by the wider regenerational benefits of the scheme.
Local open space
521 In order to mitigate intensified use of local open space GLA officers propose to secure a sum
of £560,000 for improvements to Sayes Court Gardens and/or other open spaces and play areas
within the vicinity of the site.
Community projects
522 Subject to prior approval of a programme business plan by Lewisham Council and the
applicant, a financial contribution of £250,000 is proposed towards landscaping of the Sayes Court
Park extension in order to facilitate the Sayes Court Garden horticultural programme. If a business
plan is not approved, this sum will be added to the Community Trust (refer below).
Community Trust
523 A financial contribution of £250,000 is proposed to me made to be made to a Community
Trust intended to support community initiatives and promote social inclusion in Deptford.
Public transport
524
A contribution of £5,750,000 is to be made towards improving bus services for the
development. These improvements comprise a new bus service, diversion of an existing bus service
and additional capacity on bus services which run along Evelyn Street. These enhancements are
necessary in order to provide sufficient additional capacity to serve residents, workers (including
construction workers) and visitors to the development, and to encourage use of buses as a mode of
travel. The bus service enhancements are proposed to be complemented by a payment of £147,500
for new and improved bus stops off-site, and works in kind on-site (to provide a pair of new bus
stops and detailed designing of the proposed spine road and site accesses for use by buses).
525 To add to the choice of non car modes of travel, and to provide additional public transport
capacity, the development proposal includes a new riverbus pier and associated land facilities. A
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contribution of £3,000,000 is proposed to be made towards ‘pump priming’ a new passenger
service that will stop at the proposed pier.
526 The timing of payments and works in kind for buses and the riverbuses is proposed to be
triggered by the build up of demand from the site. These triggers will be set out in the section 106
agreement.
Highway works
527
Various highway improvements are proposed to mitigate the traffic impact of the
development, and to encourage use of non car modes of travel. These will be governed by section
278 highways agreements, and through financial contributions required in the section 106
agreement. The outline scope and specification of the section 278 works, the triggers for their
implementation, and the financial contributions, will be agreed between the parties in the section
106 agreement. Full details will subsequently be developed and agreed as part of the section 278
process which will need to take account of the outcome of more detailed modelling and
assessment work (also proposed to be secured within the section106 agreement) and the Cycle
Superhighway 4 scheme, which is currently in design, and is programmed to be implemented
before the highway works would be triggered. The indicative value of these highway works is
£4,125,000.
528
In addition, financial contributions are to be secured towards implementation of other
highway improvement schemes, notably £500,000 for Deptford High Street. These relate to the
development whilst also having a more widespread benefit. The timing of payments would, as with
the section 278 works, be determined by development phasing and the amounts related to agreed
impact, including that indicated through the required future detailed modelling and assessment
work.
Cycling and walking
529 The proposed section 106 agreement includes a number of measures intended to
encourage walking and cycling in line with national, regional and local planning policy.
530 As discussed above, the highway works proposed to be secured within the section 106
agreement would incorporate improved provision for pedestrians and cyclists, and an enhanced
public realm (notably on New King Street and Deptford High Street) which would be the main
route between the site and Deptford Station. In addition, as well as a network of pedestrian and
cycle routes to be provided as part of the development, the Thames Path would be extended along
the length of the riverside for use by cyclists and walkers. There are also proposed connections to
the neighbouring open spaces at Pepys Park and Twinkle Park.
531
The applicant has also agreed to safeguard two areas within the site for a Cycle Hire
docking station - in the event that the scheme is extended to the area.
Travel Plan
532 The proposed section 106 agreement will include obligations to develop, implement and
monitor a Travel Plan for each of the uses within the development (including the appointment of a
Travel Plan coordinator), in accordance with local and strategic policy. There will also be a School
Management Plan which will operate in tandem with the School Travel Plan. A further plan is
proposed to be secured which will manage travel by construction workers and encourage use of
non car modes. Together these measures are intended reduce the need to travel (especially at peak
times and by car), in accordance with national, regional and local planning policy.
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Parking restrictions
533 The proposed section 106 agreement is proposed to control parking by residents (and
others associated with the development) both on and off-site. These provisions are important in
order to strike a balance between reducing car dependence (particularly during peak time) and
meeting the reasonable needs of the development in line with relevant policy. The applicant has
agreed to make a contribution of £250,000 to enable implementation of a controlled parking zone
in the vicinity of the site, for which occupiers of the proposed development would be ineligible for
permits. A site Parking Management Plan and a parking review mechanism are also proposed to be
included within the section 106 agreement, and would similarly restrict parking on-site to
appropriate levels.
Construction logistics, deliveries and servicing
534 Both a construction logistics and a delivery and servicing plan are proposed to be secured
by way of planning obligation. In addition, the section 106 agreement is proposed to include a
requirement to maximise use of the river during site clearance and construction, and to activate the
wharf. These measures would assist in reducing the number of goods vehicle movements on the
highway (especially at peak times), and help to safeguard vulnerable road users.
Transport infrastructure
535 The proposed section 106 agreement will include provisions securing public rights of access
at the site. It is also proposed to use the section 106 agreement to secure appropriate management
and maintenance of on-site highways, pedestrian routes, cycle routes, bus infrastructure and
riverbus infrastructure - equivalent to adoptable standards (or those of the relevant transport
provider).
Mitigating the impact of development through planning obligations – conclusion
536 The planning obligations proposed in paragraph 2 of this report are necessary to make the
development acceptable in planning terms; directly related to the development; and fairly and
reasonably related in scale and kind to the development.
Legal considerations
537 Under the arrangements set out in Article 7 of the Order and the powers conferred by
Section 2A of the Town and Country Planning Act 1990 the Mayor is the Local Planning Authority
(LPA) for the purposes of determining this planning application.
538 Section 35 of the Greater London Authority Act 2007 inserts section 2F into the Town and
Country Planning Act 1990 a requirement that for applications the Mayor takes over, the Mayor
must give the applicant and the LPA the opportunity to make oral representations at a hearing. He
is also required to publish a document setting out:
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
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who else may make oral representations;
the procedures to be followed at the hearing; and,
arrangements for identifying information, which must be agreed by persons making
representations.
539 The details of the above our set out in the Mayor’s Procedure for Representation Hearings
which reflects, as far as is practicable, current best practice for speaking at planning committee
amongst borough councils.
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540 In carrying out his duties in relation to the determination of this application, the Mayor
must have regard to a number of statutory provisions. Listed below are some of the most important
provisions for this application.
541 Section 70(2) of the Town and Country Planning Act 1990 (as amended) provides that in
dealing with such an application the authority shall have regard to:
a) The provisions of the development plan, so far as material to the application;
b) Any local finance considerations, so far as material to the application; and
c) Any other material consideration.
542
Section 70(4) defines “local finance consideration” as:
a) A grant or other financial assistance that has been, or will or could be, provided to a
relevant authority by a Minister of the Crown; or
b) Sums that a relevant authority has received, or will or could receive, in payment of
Community Infrastructure Levy.
543 In this context “grants” might include the Government’s “New Homes Bonus” - a grant
paid by Central Government to local councils for increasing the number of homes and their use.
544 These issues are material planning considerations when determining planning applications
or planning appeals.
545 Furthermore in determining any planning application and connected application, the Mayor
is required by section 38(6) of the Planning and Compulsory Purchase Act 2004 to have regard to
the provisions of the Development Plan (which in London consists of the London Plan, the
Borough Local Plan and any Neighbourhood Plans as appropriate) so far as is material to the
application and to any other material considerations. The Mayor must determine the application in
accordance with the Development Plan unless material considerations indicate otherwise.
546 Other guidance, which has been formally adopted by Lewisham Council and the GLA (e.g.
Supplementary Planning Documents and Supplementary Planning Guidance), will also be material
considerations of some weight (where relevant). Those that are relevant to this application are
detailed in this Representation Hearing report.
547 Officers are satisfied that the current report to the Mayor has had regard to the provision of
the development plan. The proposed S.106 package has been detailed in full which complies with
the relevant statutory tests, adequately mitigates the impact of the development and provides
necessary infrastructure improvements.
548 As regards Community Infrastructure Levy (CIL) considerations the Mayoral CIL payment
associated with this development is estimated to £11.8m.
549 In accordance with his statutory duty in section 66 of the Planning (Listed Buildings and
Conservation Areas) Act 1990 the Mayor shall have special regard to the desirability of preserving
Listed Buildings, their settings and any features of special architectural or historic interest which
they possess.
550 Where the Mayor takes over an application, he becomes responsible for the section 106
legal agreement, although he is required to consult the relevant Borough. Both the Mayor and the
Borough are given powers to enforce planning obligations.
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551 When determining this planning application, the Mayor is under a duty to take account of
the provisions of the Human Rights Act 1998 as they relate to the development proposal and the
conflicting interests of the applicant and any third party affected by, or opposing, the application,
in reaching his decision. Planning decisions on the use of land can only be taken in line with the
Town and Country Planning Acts and decided in accordance with the development plan unless
material considerations indicate otherwise.
552
The key Articles to be aware of include the following:
(a)
Article 6 - Right to a fair trial: In the determination of his civil rights and
obligations... everyone is entitled to a fair and public hearing within a reasonable
time by an independent and impartial tribunal established by law.
(b)
Article 8 - Right to respect for private and family life: Everyone has the right to
respect for his private and family life, his home and his correspondence.
(c)
Article 1 of the First Protocol - Protection of property: Every person is entitled to
the peaceful enjoyment of his possessions.
553
It should be noted, however, that most Convention rights are not absolute and set out
circumstances when an interference with a person's rights is permitted i.e. necessary to do so to
give effect to the Town and Country Planning Acts and in the interests of such matters as public
safety, national economic well-being and protection of health, amenity of the community etc. In
this case this Representation Hearing report sets out how this application accords with the
Development Plan.
554 Regulation 122 of the Community Infrastructure Levy Regulations 2010 states that a
section 106 planning obligation may only constitute a reason for granting planning permission for
the development if the obligation is necessary to make the development acceptable in planning
terms; directly related to the development; and fairly and reasonably related in scale and kind to
the development. These are now statutory tests.
555 The Equality Act 2010 provides that in exercising its functions (which includes the functions
exercised by the Mayor as Local Planning Authority), that the Mayor as a public authority shall
amongst other duties have due regard to the need to a) eliminate discrimination, harassment,
victimisation and any other conduct that is prohibited under the Act; b) advance equality of
opportunity between persons who share a relevant protected characteristic and persons who do not
share it; c) foster good relations between persons who share a relevant protected characteristic and
persons who do not share it.
556 The protected characteristics set out in the Equality Act are: age, disability, gender
reassignment, pregnancy and maternity, race, religion or belief, sex and sexual orientation. The
Equality Act acknowledges that compliance with the duties set out may involve treating some
persons more favourably than others, but that this does not permit conduct that would otherwise
be prohibited under the Act.
557 With regard to age, disability, gender reassignment, pregnancy and maternity, race, religion
or belief, sex and sexual orientation there are no identified equality considerations which arise in
respect of the proposed development.
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Conclusion
558 As detailed above Section 38(6) of the Planning and Compulsory Purchase Act 2004
requires the decision to be determined in accordance with the Development Plan unless material
considerations indicate otherwise.
559 When assessing the planning application the Mayor is required to give full consideration to
the provisions of the Development Plan and all other material considerations. He is also required to
consider the likely significant environmental effects of the development and be satisfied that the
importance of the predicted effects and the scope for reducing them, are perfectly understood.
The Mayor has also had special regard to the desirability of preserving Listed Buildings, their
settings and any features of special architectural or historic interest that they may possess.
560 In preparing this report, officers have taken into account the likely environmental impacts
and effects of the development and identified appropriate mitigation action to be taken to reduce
any adverse effects. In particular, careful consideration has been given to the proposed conditions
and planning obligations which will have the effect of mitigating the impact of the development.
561 This report has considered the material planning issues associated with the proposed
development in conjunction with all relevant national, regional and local planning policy, and has
found that the proposed development is acceptable in terms of the principle of development
(safeguarded wharf contraction/reconfiguration and regenerative mixed-use development;
safeguarded wharf (including maximising freight use of the Blue Ribbon Network); mix of uses
(including employment, retail and visitor infrastructure); housing (including affordable housing,
residential standards and density); sustainable communities (including social infrastructure and
social inclusion); design (including urban design and heritage); inclusive design; energy;
environmental issues (including noise and vibration, air quality, river and water resources,
biodiversity, artificial light spill, microclimate, communications infrastructure and cumulative
environmental impacts); neighbourhood amenity (including daylight, sunlight, overshadowing, and
privacy/overlooking); transport; other issues raised during the consultation process; and,
mitigating the impact of development through planning obligations.
562 Accordingly, GLA officers recommend that the Mayor grants planning permission, subject
to conditions and conclusion of a section 106 legal agreement, as set out at the beginning of this
report.
for further information, contact GLA Planning Unit (Development & Projects Team):
Colin Wilson, Senior Manager - Planning Decisions
020 7983 4783 email colin.wilson@london.gov.uk
Justin Carr, Strategic Planning Manager (Development Decisions)
020 7983 4895 email justin.carr@london.gov.uk
Graham Clements, Senior Strategic Planner (case officer)
020 7983 4265 email graham.clements@london.gov.uk
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