COMMENTS ON THE SOUTHWARK UDP
from the Bellenden Residents’ Group (BRG)
_______________________________________________________________________________
Policy Number
Part One, Paragraph 9.3 & 9.3.2
Subject:
Peckham preamble & vision statement
_______________________________________________________________________________
KEY:
Text in bold = the UDP text and paragraph numbers.
04 = the reason for objecting or supporting the policy section.
05 = the changes sought to meet the objection.
_______________________________________________________________________________
This submission should be read with the separate BRG Objections to the Peckham development
proposals paragraphs 9.3.3, i to xii.
9.3 Peckham (the introductory statement in 3 paragraphs on pages 29 & 30)
04. Object because this introductory statement does not give a clear enough view of an integrated
strategy for Peckham town centre.
05. Reduce the length of this preamble and include the essential elements in an expanded vision
statement under 9.2 (similar to the presentation for Canada Water). The revised introduction
would briefly set the context for a revised vision statement, which would include:
* a clear vision for the whole town centre and an integrated relationship between the High Street
uses and the redeveloped uses in central Rye Lane around the station and Bournemouth Road;
* integrated strategies, and the committed involvement of the other key agencies in their
achievement, for public transport in trains, tram and buses;
* a comprehensive car parking strategy for the centre;
* a design strategy integrating historic and modern buildings in an innovative way;
* a robust policy for town centre and street management to cover cleanliness and traffic, and
other quality town centre issues;
* a clear focus on improving sports and leisure facilities, coupled with provisions to exclude uses
incompatible with a clean and safe town centre closely integrated with residential areas;
* an integrated strategy covering Peckham social issues, including provision of adequate
education, training and health services for the local population, and an action plan for developing
and supporting community involvement in partnership with public agencies.
______________________________________________________________________________
9.3.2 VISION STATEMENT FOR PECKHAM
An easily accessible, vibrant Major Town Centre, providing a broad range of homes, shops,
employment, community facilities and public spaces for the diverse local community and the
wider catchment area.
04. Object because
* the Roger Tym (2003) retail study concludes that Peckham is and should remain a localised
town centre and not a major one;
* ‘vibrant’ along with ‘major’ would attract entertainment facilities which are inappropriate to a
small town centre closely integrated with residential areas.
05. redraft (see also comments on 9.3 introductory statement) to emphasise the vision for a clean,
safe and attractive centre with improved shopping facilities, and increased sports and leisure
facilities (especially for young people), meeting the needs as stated in current 9.3.2, and avoiding
the evening and night time uses which increase the potential for disorder and anti-social
behaviour.
END of comments and objections to paragraphs 9.3, & 9.3.2
*******************************************************************************
*******************************************************************************
Policy Number
Part One, Paragraph 9.3.3, i - xii
Subject:
Peckham development proposals
_______________________________________________________________________________
This submission should be read with the separate BRG Objections to the Peckham Preamble and
Vision statement (paragraphs 9.3 & 9.3.2).
______________________________________________________________________________
9.3.3 Development of Peckham should seek:
______________________________________________________________________________
i. Retention and creation of high quality housing, with mix of tenure. Of the Affordable
housing that is secured, the tenure mix should be 70% Intermediate housing and 30% social
rented housing;
04. Object because no estimate has been given of the Peckham share of increased housing for the
borough, and it is not therefore possible to assess the likely impact on the area and services, or
the proposed mix of tenure.
05. Redraft after provision of information about Peckham’s share of increased housing.
04 Support in principle a higher proportion for Intermediate housing because Peckham already
has a large proportion of social rented housing.
______________________________________________________________________________
ii. Retention and creation of high quality offices and retail to increase employment,
opportunities, particularly for Small Business Units.
04. Object because
* good quality retail is at the heart of achieving an improved centre, yet it is buried away here
instead of being prominent.in the long list of guidance in section 9.3.3;.
* there is no mention of the basic public amenities (eg toilets, baby facilities etc) urgently
needed;
* there is silence on problems arising from vehicle access for servicing, including the need to
prevent large retailers from pressing for ease of planning restrictions (cf the problems from
Netto).
05. Support the aim to increase employment through small business units, offices and retail, but
redraft to ensure that high quality retail and improved basic amenities receive due prominence.
Separate into different aims the wider employment issues from the one about high quality retail –
see also comments on Bournemouth Road site.
______________________________________________________________________________
iii. Active frontages to encourage footfall, improve safety and further increase a sense of
place.
04. Object because there is no provision to restrain an over proliferation of ‘active frontages’
where internal uses “spill on to the street”
05. Introduce provisions which will control the number of active frontages with internal uses
spilling onto the street.
______________________________________________________________________________
iv. Public Transport Accessibility Zone intensification on key sites around the Peckham Rye
railway station and the bus interchange with developments that provide exemplary design and
transport improvements.
04 Object because (i) the “development at Peckham” cannot seek ‘Public Transport Accessibility
Zone’; and (ii) the proposed intensification allows higher buildings with greater density than is
desirable on the sites identified in the schedule in Appx 4.
05. Reimpose the Urban Zone densities for the development sites around the station and bus
interchange.
_____________________________________________________________________________
v. The Cross River tram proposals within the safeguarded route.
04. Object as there is no safeguarded route because no route has been published. This makes it
considerably difficult to comment on the proposals for the town centre without knowing the land
and buildings which would need to give way, and the impact of that on town centre activities.
This could lead to considerable disruption to commerce and residents.
05. Need thorough assessment of the impact of the tram on the town centre and the residential
areas, including car parking implications.
______________________________________________________________________________
vi. redevelopment of the bus station, Bournemouth Road and other sites shown on the
proposals map.
04. object because it lumps together too many disparate parts of the development proposals, and
also object to some of the individual site proposals as set out below..
05. the different sites should be separated or grouped appropriately, each of which should have a
stated development objective.
* site 59P Peckham Wharf, Peckham Hill Street
04 object because this is not a suitable site for a relocated cinema. The cinema needs to be in
central Rye Lane, and Peckham Wharf needs to be allocated for performance space.
05. Delete the reference to relocation of the cinema in Appx 4.
* site 61P multi-storey car park & cinema
04. object to this proposed change of use because of the loss of the cinema.
05. make any change of use subject to the prior alternative provision of a good quality cinema in
this Rye Lane part of the town centre, preferably as part of the Bournemouth Road development.
* site 62P Choumert Car park & site 64P Copeland Rd car park
04. Object to change of use to housing because of the lack of a clear car parking strategy for the
town centre, and because of the proposed intensification of housing (height and density) on these
sites under 9.3.3 iv.
05. link any change of use to prior clear and adequate car parking strategy for the whole of the
town centre (see comments on vii below), and clear guidance on housing height, density and
design to avoid inappropriate design and development.
* site 63P Bournemouth Road, Copeland Rd, Rye Lane
04. object to the way this site is listed and described in the UDP, but support as a development
site.
05. give a positive statement about what can be created in the central part of the Rye Lane
shopping area eg “to create an attractive long shopping street, integrated with the High Street,
and at its centre a new shopping and leisure area on the Bournemouth Road site, linked to an
opened up station forecourt, and an attractive and efficient transport interchange, with sufficient
car parking for shoppers, public transport users, and residents.”
Make this statement a prominent part of the overall Plan.
______________________________________________________________________________
vii. To make more efficient use of land by reducing wasteful surface car parking and
encourage shared parking for town centre services.
04. Object to the statement that surface car parking is wasteful, because (i) the UDP is
inconsistent on surface car parks – accepting the two in the north of the town centre but not in
the south of the town centre, and (ii) current surface car parks provide effective support to
existing commerce, and (iii) surface car parks can reduce an otherwise overbearing dense
townscape.
04. Support the encouragement of shared car parking for town centre services.
05. A clear and integrated car parking strategy should be indicated in the UDP, covering
adequately the needs of the various town centre users in different parts of the town centre, ie
shoppers, traders, employees, train and tram travellers, other town centre users eg leisure and
faith groups, and residents, and indicating the criteria for acceptable forms of car parking.
______________________________________________________________________________
viii. Improved accessibility to the train station, and within the Action area by cycle and by foot.
04. Object because this formulation lumps together two different issues: cycling and walking
generally, with accessibility to the station which does not go far enough.
04. Support improved accessibility throughout the Area by cycle and foot.
05. Separate the two issues into distinct statements. On train station accessibility make it clear it
includes, as well as cyclists and pedestrians, also people with disabilities, and people with
luggage and small children. Link this statement to the benefits to be derived from opening up the
station forecourt for uses ancillary to the station, and to the development potential of the
Bournemouth Road site..
_____________________________________________________________________________
ix. Protection and enhancement of open spaces, public realm and other features of
development linking them together with buildings, within a design strategy for the area.
04. Object because of the absence of any statement about the preservation and integration of the
historic parts of the town centre.
04. Support a design strategy for the area, but say more about it.
05. Include in the statement a provision to ensure the historic heritage is conserved and
integrated in and with new developments, and with a plan to improve existing shop fronts.
04. Support the designation of McDermott Grove Nature Garden in Bellenden as Borough Open
Land (OS108 in Appx 11 Open Space Schedule).
04. Support the designation of OS116 as Metropolitan Open Land but object to (i) its separation
from site OS123 Peckham Rye Common, and (ii) the application of the name Bog Garden to the
whole site.
05. Include OS116 site as part of OS123, and consult on an appropriate name.
______________________________________________________________________________
x. A range of educational uses including a new two form entry secondary school.
04. Object as this is an inadequate statement to cater for the wide range of educational uses
which need to be improved.
05. Redraft to reflect an integrated strategy for educational uses for all ages.
______________________________________________________________________________
xi. Leisure and community uses , especially around Peckham Square and Wharf to increase
vitality.
04. Object as there is no overall integrated strategy for leisure and community uses in Peckham
in the UDP, including linking the proposed developments at Bournemouth Road with sports and
leisure facilities. This statement does not make good enough provision for new facilities for the
community, and voluntary and community groups throughout either the town centre or Peckham
as a whole.
05. Link leisure and community uses, especially for young people, to demand rather than to
‘vitality’ for the town centre. Include in this statement references to the relevant development
sites, eg 56P, 57P, 59P, 63P
______________________________________________________________________________
xii. To establish stronger links between Rye Lane and the Bellenden Road shopping area.
04. Object as it is very unclear what the purpose of this provision is or could lead to, and which
part of Bellenden Road it refers to. If it is not about development and land use, there is no need
for it to be in the UDP. If it stays in, it could be a hostage to fortune for unwelcome
developments in the future.
05. Delete the reference in the development proposals.
______________________________________________________________________________
END of objections and comments on paragraphs 9.3.3, i to xii.