This week Lewisham Council's strategic planning committee recommended that the Mayor of London reject the outline planning application for Convoys Wharf in its current form.
The council is a statutory consultee in the planning process now that the Mayor of London has called in the application; with many years' experience of considering applications for the site, it's reasonable to conclude that Lewisham planners are also a major source of advice to the GLA about the application.
During this week's meeting, the committee considered - and agreed - a report by the council's planners recommending that the application in its current form should not be approved. The committee also made some amendments to the recommendations to further strengthen the case against certain aspects of the application, and added another clause about the handling of construction waste and material deliveries, and other potential nuisance from construction.
The report explains the site's planning history and in its recommendations, raises issues relating to the proposed scheme that in the council's opinion need further resolution before planning permission should be granted.
The committee was first addressed by local MP Dame Joan Ruddock, who highlighted many of the issues that were raised in the report; in common with many of the other presenters she noted that she had been responding to redevelopment proposals for this site for more than a decade, although the current application was only submitted in April 2013. Representatives of local groups such as the Lenox Project, Sayes Court Garden, Pepys Community Forum and other interested parties were allowed to speak, before the committee deliberated its decision.
The council's report details the responses to the initial application that were received (p23 onwards) including statutory consultees such as English Heritage, TFL and the Environment Agency, as well as local organisations such as the Pepys Community Forum, Greenwich Society, the Greenwich Conservation Group and other interested parties including London City Airport and the Port of London Authority.
The final section of the report (p44 onwards) sets out the main planning considerations and the council's position; many of these comments are then drawn through into the final recommendations. We have reported the main ones below, in the order they appear in the report.
Principle of redevelopment
The report is clear that the council supports the principle of the redevelopment, but raises questions about the development strategy for the site, and the interpretation and acknowledgement of the site's history in the masterplan. 'Certain aspects of the proposed development.. are considered unacceptable in their current form'.
The lack of any proposed use for the safeguarded wharf (on the northern boundary of the site) introduces an uncertainty regarding is use, in particular given the proximity of public space and residential properties. The formal process of reducing the protected wharf area also needs clarification.
The council wants a commitment to cultural uses (for example the range of projects set out in the Cultural Strategy) secured through the Section 106 agreement for the site; considers that uses across the site should be secured and the non-residential space and employment use be maximised. The report also highlights the Lenox Project as 'an important employment opportunity..with a clear link to the site's history' and recommends that the GLA should actively promote its incorporation into the site.
The lack of affordable housing that the development is offering was raised by many of the objectors, and discussed by councillors as a major issue. Although the application claims 15% of the units will be 'affordable', only 6-7% of these will be for social rent, and in fact one speaker pointed out that when assessed against Lewisham Council's definition of affordability, this falls to zero. The council report questions the robustness of the viability calculations the developer has used to assess what percentage of units should be affordable, and wants it to be reassessed. The committee also wanted a mechanism to allow periodic reassessments during the development period. The report also raises questions about whether the daylight/sunlight impact of the development has been properly assessed.
In a number of key locations, the layout fails to respond appropriately or in a meaningful way to the heritage assets on the site.
The setting of the Olympia Building does not reflect its importance to the site; the council wants the heights of the buildings which surround it to be reduced to a general height of ten storeys. In particular, the two buildings which frame the view from the Olympia Building to the river (P02 and P03) need amending to improve this visual connection. In addition the blocks next to the Master Shipwrights House should be reduced in height to respect this historic building; according to the report this request has already been made to the developer. Another area of concern is Sayes Court Garden and the site of John Evelyn's house, which are also not adequately reflected in the masterplan. The layout should be reassessed and a 'green link' between Sayes Court Garden and the site of the house should be established. The masterplan should also identify a dedicated space to allow for the construction of the Lenox.
Scale and massing
Acceptable building heights need to be fixed at this stage, and the council's report states that the proposed reduction in heights could be accommodated without reducing the overall quantum of development.
Transport, access and movement
The report questions the robustness of the transport assessment for the site, in particular the impact of the development on highway traffic, which it claims has been understated. The suggestion that the full investigation of this could be left until after the application is determined 'raises serious concerns'.
The section 106 agreement is planned to include provision of a primary school on the site, but the council also wants a contribution to secondary school provision for the borough. At the meeting the committee also requested that this recommendation be strengthened to cover other social infrastructure such as GP provision.
Environmental impact assessment
The report questions the adequacy of the applicant's Environmental Impact Assessment and whether it complies with the requirements of the Environmental Impact Assessment Regulations. It warns that 'any permission could be at risk of legal challenge on such grounds'
The recommendations that the committee approved are on pages 66 and 67 of the report - amendments agreed at the meeting strengthen them further and an additional recommendation relating to a construction code of practice was added.
The official line from GLA officers is still that a decision is intended to be made in February.