Saturday, April 20, 2019

No1 Creekside – Lewisham passes another bad scheme without any scrutiny

Chair of Lewisham’s Strategic Planning Committee, Cllr John Paschoud, recently posted on his Facebook page about the new scheme that he and three other members of the committee passed with very little scrutiny on 26th March for No1 Creekside.

A visual of  the scheme – we've incorporated the proposed Tidemill development on the left
(where 74 trees were demolished) to show the local impact – No1 Creekside on the right.
He begins: "Following the decision by Lewisham Council’s Strategic Planning Committee (of which I’m Chair) on 26th March to approve the development of 1 Creekside, Deptford, two rather poorly informed stories have circulated..."

Cllr John Paschoud's Facebook post

We wrote about the scheme when it first appeared as a detailed planning application in June last year (here and here). There were so many things wrong with the proposals, but two notable things stood out.

Firstly, the applicant’s own Air Quality Assessment stated that occupants on the lower floors would not be able to open their windows during peak traffic periods because the pollution was so high. Secondly, it was quite obviously a ‘poor door’ scheme.

The “two rather poorly informed stories” which Cllr Paschoud refers to are exactly these: the pollution on the site and the ‘poor doors’ aspect of the scheme.

The first apparently 'poorly informed' story is a Guardian report – 'Housing approved despite pollution warning to keep windows shut'.

The same story was then taken up by The Times (see below), The Independent, the Daily Mail and Sky News, who we can presume were also all poorly informed.

The Times story nicked their headline from local blogger The Deptford Dame
The story seems to have originated from a press release by Green candidate for the London Assembly Rosamund Adoo-Kissi-Debrah, who previously stood for the Greens in the Lewisham East by-election. Rosamund has been campaigning against pollution ever since her young asthmatic daughter died in 2013. The press release was well timed to coincide with Sadiq Khan’s Ultra Low Emission Zone which started on 8 April. And this week, we have Extinction Rebellion, just to rub it in.

The Guardian published the story on 12 April (though Cllr Paschoud claims it was 13 April), soon followed by the others who did a little googling and stole some headlines from local blogs, whilst Sky News popped down to film the site on the 13th for broadcast on rolling news all Saturday evening. Embarrassingly for Lewisham Council, the Sky News story also managed to capture potent images of the current protest on Tidemill Green on the other side of Deptford Church Street.

In his Facebook post, Cllr Paschoud takes issue with the Guardian report, saying, “If the Guardian journalist had read the written evidence in the public reports considered by the Planning Committee, or listened to the discussion at the meeting, she would have realised that the Council had required the developer to provide a ventilation system that will take clean air from the roof and deliver it to the first two floors of the flats…”

Cllr Paschoud's second apparently ‘poorly informed’ story was about ‘poor doors’ and stemmed from a petition begun by one Ray Woolford which was then covered by the NewShopper. Woolford doesn't have many fans in Deptford, let alone Catford, and the petition is badly worded, but Cllr Paschoud claims it was an unsubstantiated “allegation” and insisted that “The development will be made up of two blocks and will not include any ‘poor door’ entrances”.

We were at the planning meeting on March 26, so we'd like to take Cllr Paschoud’s denials one by one in the context of that meeting, and his part in it. But first, a little background…


The owner of the site is Bluecroft Property Development who bought the site in May 2014. They then began pre-planning talks with Lewisham, and in July 2016, Sir Steve Bullock’s cabinet approved the sale of public land adjacent to the site in return for commercial space in the scheme which it would lease back. No local consultation took place over the disposal of this land which had remained undeveloped since the 70s when housing was demolished to make way for road widening which didn't happen. The land grew into a wildlife space full of biodiversity and was presumed by locals to be part of the Crossfields Estate and was used by residents. It also contains several mature trees which have been mitigating the pollution at this part of Deptford Church Street where traffic slows down for the roundabout.

No1 Creekside became a co-development between Bluecroft and Lewisham Council, but at the planning meeting, only Bluecroft was identified as "the applicant" even though Lewisham Council is fully invested in it. It is intended to provide revenue for the Council through them letting so-called ‘creative space’ at ‘affordable’ rent levels. There is no contribution from the developer to subsidise the commercial space as they have already condescended to provide 11 ‘affordable’ and 9 shared ownership out of a total of 56 housing units.

Cllr Paschoud boasts this is 36% affordable housing, when the target set by Mayor Egan is 50%. Because it's not 50%, it doesn’t qualify for the GLA’s fast track subsidy. Anyway, back to those ‘poorly informed’ stories…

Poorly informed story #1 : Housing approved despite pollution warning to keep windows shut

While Cllr Paschoud criticises the Guardian journalist for not having been at the meeting, read the documents or listened to the discussions, it was as if he hadn’t been at the meeting himself.

He certainly doesn’t seem to have listened to anything said in the 20 minutes allotted to local objectors, some of whom will be directly affected by the development.

One objector spoke specifically about pollution, and handed the committee copies of a report produced by Citizen Sense, the Goldsmiths University academics now based at Cambridge University who had scientifically measured the air quality in various parts of Deptford between 2016-17. Their focus was on particulate matter PM2.5 and their research was then gathered into a set of ‘data stories’ with their overall findings for Deptford reported in the press in late 2017.

The report circulated to the committee specifically addressed their findings in Creekside (and can be found here) where the air was monitored for several months from a 4th floor flat on Crossfields. There was, perhaps, no need for the committee to read any further than the opening paragraph of this particular 'data story' which says:
“The Creekside area is adjacent to Deptford Creek, and is surrounded by busy roads, including Deptford Church Street. There are numerous construction sites in the area, as well as cultural spaces and low-rise and high-rise housing. Key findings indicate that automobile and HGV traffic  are primary sources of PM2.5 emissions, especially on Deptford Church Street. These emission levels are most likely made worse by extensive construction activity and construction-related traffic in that area.”  
The objector noted that although the planning officer acknowledged there is evidence of PM10 and NO2 in the area, he had made no mention whatsoever of PM2.5 which is the more dangerous form of pollution.

She explained to the committee that PM2.5 has a diameter of less than 2.5 micrometers, about 3% the diameter of a human hair. Since it is so small and light, it stays in the air longer than heavier particles, and can bypass the human nose and throat and penetrate deep into the lungs and blood, causing premature death from heart and lung disease, whilst worsening chronic respiratory conditions.

As we have pointed out before, the GLA includes Deptford Church Street in its Air Quality Focus Area (AQFA) monitoring, but Lewisham Council’s own monitoring concentrates on Evelyn Street only. The officer admitted in his report that there is currently no official monitoring location on Deptford Church St.

The Citizen Sense data showed that on multiple occasions, levels of PM2.5 in the area was up to SIX to EIGHT times higher than World Health Organisation guidelines. The high levels measured on the 4th floor at Crossfields were only second to the meter-breaking readings taken at Deptford Bridge at 3rd floor level above the busy A2.

The high readings at Crossfields were due to traffic on Church St to the west (including increased construction traffic and now also the Tideway site), and to the east the construction sites at Faircharm and Kent Wharf (now completed), with attendant HGVS, idling cement lorries, as well as the Tideway site at Greenwich Pumping station (on-going).

However readings taken adjacent to Tidemill Garden were within guidelines. This is where the Council has just demolished 74 trees on the same day as they passed a motion on Climate Change Emergency at Mayor & Cabinet (27th March).

Citizen Sense say the loss of vegetation in the area could influence PM2.5 levels and decrease the ability of vegetation to trap particulates. They also say that mature trees can provide effective means of trapping particulates as well as gasses such as NO2 and CO2, thereby mitigating climate change.

But the objector’s main point was that the highest readings of PM2.5 had been taken at height, and therefore drawing air via a ventilation system from the roof of No.1 Creekside would not help mitigate the air quality on the lower floors. 

Professor Jennifer Gabrys who runs the Citizen Sense project had been unable to attend the planning meeting, so we asked her to comment. She said “the idea that clean air could be taken from the roof of this development to ventilate the building does not hold up to experience – and actually sounds quite hazardous.”

A pollution map showing the accumulated effect of so many construction sites and attendant vehicles in the area was also distributed to the committee.

Click to enlarge
None of this seemed to bother them, as the planning officer proposed conditions for the scheme to mitigate the problem: the homes (and commercial spaces) on the affected lower floors would be ventilated by air drawn from higher up the building (as Cllr Paschoud said) and occupants would be informed of the health dangers of opening their windows. As the Deptford Dame wrote recently, most of those affected would be lower income families, and if the owners of private units were letting out their properties, how would the warnings be passed to the potential tenants?

Another condition proposed was that pollution monitoring would take place over a six month period before construction started – but again PM2.5 was not mentioned. Surely monitoring after an application is passed is plainly a case of locking the stable door after the horse has bolted?

Lastly, the officer’s report noted that the GLA’s Air Quality Focus Area Policy states that developers must not introduce occupiers into areas of known exceedences. Yet this is exactly what the planning officer is recommending and what the planning committee – and even the GLA itself – have approved.

Poorly informed story #2: Poor Doors

In his Facebook post, Cllr Paschoud kindly provided his understanding of 'poor doors' which he described as “separate entrances or lower quality shared amenities for tenants of social housing compared to the communal facilities enjoyed by those who have purchased flats in the building”.

Er, yeah, John, the first bit about separate entrances?

At the planning meeting, the 'poor door' element of the scheme completely escaped the attention of the committee at first. The applicant’s representative was very keen to point out a new proposal in the scheme – that residents of the two separate towers will share a third floor terrace amenity.

He said he felt this was a timely concession, considering the report in the Guardian the day before. The Guardian’s controversial story of 25 March was about a development in Lambeth where children in affordable housing were blocked from using a communal playground. The committee was so keen to pass the scheme they didn’t notice the implications of this announcement.

It was only some way later into the meeting after one of the audience shouted out “Poor Doors!” that Cabinet Member for Housing Cllr Paul Bell finally picked up on the issue. He asked for clarification. Cllr James Walsh then asked why the affordable flats were not ‘peppered’ throughout the development, as Lewisham policy demanded. The answer from the planning officer was that they would be easier to manage if they were all in one block.

Cllr Walsh then voted for the scheme along with the other three idiots, while Cllr Bell abstained.

In his Facebook post, Paschoud goes on to say “Lewisham Council already has strong planning policies to prevent such discrimination in any new development and 1 Creekside is no exception to this". He said the committee had received “comprehensive assurances that the standards of build and finish was truly ‘tenure blind’. The development will be made up of two blocks and will not include any ‘poor door’ entrances.”

He went on to persist with the red herring about shared amenity space: “Members did raise concerns about any possibility of discriminatory access centred on the communal outdoor play area (at third floor level partly to expose children to lower levels of traffic-generated pollution), and therefore members proposed the following extra condition to be attached to any Planning permission granted:
 "Communal amenity space accessibility: The entirety of the communal outdoor amenity space located at third floor level in the development shall be made fully accessible and available to all residents of the scheme hereby permitted irrespective of residential tenure and the means of access from both the north and south cores (as per approved Drawing 100/006/Rev 0) shall remain serviceable at all times and in perpetuity."

This completely fudges the fact is that there are two separate towers. The north tower will house the ‘affordable’, the south tower the ‘private’. That the towers are joined on the third floors doesn’t excuse the reality that they will have separate lifts, and the entrances to those lifts are, well, ‘entrances’. Different entrances.

The only bit of ‘peppering’ occurs in the north block where the roof will contain a private penthouse. Other than this, it’s a pretty open and shut case, and hardly ‘poorly informed’.

2+2=5…(more disgraceful double-think)

Cllr Paschoud ends his Facebook post with an image of the planned 'third' floor to illustrate how all occupants will have access to the polluted 3rd floor terrace – as evidence that this is not a 'poor door' scheme.

Click to enlarge
Changing the subject slightly, this illustration is notable in that the Planning Report states with authority that the majority of flats will be dual aspect. 'Dual aspect' refers to windows on two or more walls that allow for views in more than one direction. But the plan clearly shows that only 3 out of 7 of the flats are dual aspect on the 'third' floor.

The so-called 'second' floor plan shows that only 4 of 10 units are dual aspect. On the 'first' floor there are only 5 out of 10. Things improve on the 4th and 5th floors ((5 out of 8), but this is still a clear example of the sort of sales talk that appears in the planning report – and which the committee did not think to question.

Click to enlarge
Perhaps the most glaring fudge (or lie) is the stated heights of the buildings, which are described as 6 and 8 storeys. Objectors claim it is really 8 and 10+, but the officer insisted his numbers were perfectly accurate.

This is because he counts the double height ground floor (which has a mezzanine floor) as one storey, and does not count the roof which will house double height penthouses in both towers. To describe the scheme as “up to 8 storeys’ is duplicitous, but the committee were happy to accept the officer's explanation without question.

If the committee had bothered to look at the plans in any detail (as Cllr Paschoud claims they did) they would have been able to count for themselves. Have a look yourselves (click to enlarge).

Why lie about the true heights? Is it that so many of Lewisham's core policies are being flaunted by this scheme (including their Tall Buildings guidelines in Conservation Areas) that admitting the real heights would stop the scheme?

This is important though. Mainly because no one knows what floor is really the 'second' floor when referring to the occupants’ requirement to keep their windows shut. Nor whether the shared third floor terrace is actually safe for children to play, when it is actually the fourth floor  (the level at which Citizen Sense measured extremely high levels of PM2.5 on Crossfields – or the third floor where readings were off the scale).

More fudging: 'planning harm' not considered reason for refusal!

More ‘fudging’ comes in the form of the attention paid to BRE Guidelines and space considerations play in planning applications, hitherto an important tool for local authorities to measure 'planning harm' (eg detrimental impact to new residents and on the existing community etc). According to the officer’s report, it would seem the BRE guidelines are irrelevant – especially when you’re keen to drive a scheme through.

In the scheme itself, some windows are not BRE compliant, but apparently they are “compliant with the aspirations of the BRE guide”. Since when have ‘aspirations’ been an acceptable measure of ‘planning harm’? 

As the Deptford Dame pointed out, some of the new units will be small, poky and enjoy very little light. But of this, the officer says in his report “this is a planning harm, which when balanced against the proposal’s other planning merits and context of the site, is not considered a reason for refusal.”  

The Dame politely concluded that the report contained an awful lot of steering and not a lot of objectivity. Being less diplomatic ourselves, we'd suggest there was a deliberate attempt to mislead the committee – if indeed, the committee had any role to play in what had already been decided.

Further examples of fudging can be found in the loss of light for existing residents of Cremer, and Wilshaw blocks on Crossfields. The development is only 15m away from them, when the rules usually dictate a minimum of 21m. There is loss of light too for Frankham House and to the existing allotment and amenity areas. Transient Shadow Studies for March showed Cremer residents would lose 4 hours daylight, but none were provided for June and December, as is usually demanded of planning applications.

BRE studies were prepared by the applicant's consultants without access to floorplans, even though the affected buildings are owned by the Council and could have easily been obtained. 28 windows are identified in Frankham House as being affected, Cremer House windows were 5% below the BRE guidelines, there were shortfalls of up to 20% at Wilshaw. The impact on the Birds Nest pub was not considered because it is a pub and therefore not 'residential' even though the top floor is the landlord's residence and there’s a hostel above the pub.

853 blog reports that Cllr Paschoud engaged at the meeting after hearing the evidence from residents of Cremer House, claiming to be concerned about the 'planning harm' to them, but this was all smoothed over by the planning officer and accepted. None of the objectors could argue further as they had had their 20 minutes and were not allowed to speak during the Councillor's question time, which was comparatively short since they hardly had any questions.

According to the planning officer, the breaches in BRE guidelines was justifiable because it’s an urban location and these guidelines only apply to the suburbs. In his report the officer claimed that “BRE levels are guidance only, this is an urban site…the degree of harm is considered to be supportable”.

The attitude appears to be that if existing residents don’t like it they can move, and that they had been lucky to have lived next to a site that had remained undeveloped for nearly 50 years. In other words, their time was up.

Protecting nature and biodiversity

Getting rid of the existing trees and wildlife to make way for this roadside scheme contradicts quite a few of the Council’s policies and objectives. As we have stated before, there is a great deal of biodiversity here, but just to remind you, the applicant’s Ecological Appraisal – which found nothing of ecological value (except the trees as pollution mitigation) – was conducted in January 2017 when everything was dormant.

Not to worry though, because although 10+ pollution mitigating trees will be demolished and there is no room for trees on the site, the applicant is going to contribute a bit of cash (loads more than it is committed to pay for pollution monitoring) to replace them ‘in the surrounding area’, where they will take years to reach the same efficacy as their predecessors in carbon capture and trapping PM2.5.

Where are the new trees going to go? There was no updated Landscaping Plan to back this up and show where the new trees will go, and none of the committee thought to question it.

None of them have even been here (perhaps with the exception of Cllr Paul Bell). Back in the 70s, Cllr Nick Taylor organised a coach for the ignorant councillors at Catford, to come down and actually see Deptford, as they had no idea what they were voting to demolish. Nothing much has changed.

Back to construction pollution (and things that didn't come up at the planning meeting)

Cllr Paschoud was defiant in his Facebook post:  “There are already many older flats on Church Street, and the Council and people living there are well aware of the unacceptably high level of Nitrogen Dioxide and other pollution generated by road traffic. In the present housing crisis, nobody would propose evacuating all the residents of all those homes; what we must do instead is to tackle the causes of the pollution affecting all residents, now and in the future.”

We heard the same hollow ring from local councillor Paul Maslin who spoke in favour of the scheme at the planning meeting.

Never mind the fact that Lewisham Council demolished 74 trees at Tidemill Garden on the same day they passed a Climate Emergency motion at Mayor and Cabinet (24th March). 

Lewisham’s policy of insisting on car-free developments is all very well, but this just gives developers carte blanche to build even more densely and build more private housing than is required by the housing crisis – so dense that an air ambulance can’t find a place to land. Perhaps it would be better to provide facilities for electric vehicles on new developments rather than ban cars completely – even if it takes a while for car owners to catch up.

There is not even enough space at No1 Creekside for six disabled car parking spaces (a request from the GLA). Instead disabled folk must park on surrounding roads and somehow get to their homes or workplace despite their disability. What roads are these? No plan for that was provided.

Meanwhile, it wasn’t made clear how polluting construction vehicles will access the site and whether a build here is sustainable, let alone possible. No Construction Logistics Plan was provided.

TfL had already said no to a loading bay (for the commercial spaces) on Deptford Church Street because of bus and cycle lanes, so the only entrance for the build is on Creekside, where construction vehicles will be taking up space at the entrance to Creekside and where the road is at its narrowest.

When Faircharm was built, cement trucks queued opposite our homes and businesses with their engines idling all the way up Creekside – up to the entrance of Creekside where it meets Deptford Church Street.

But according to the officer, there’ll only be 8 vehicle movements a day, and a Logistics Plan will be secured by Condition. Surely this is something everyone would want to know in advance, before Planning was agreed. "8 vehicle movements a day" sounds rather vague when a Strategic Planning Committee is trying to make decisions about the impact of the development.

Early days on Creekside when redevelopment of Faircharm started.
Queues of cement mixers along Creekside

Nightmare of exiting and entering vehicles at Faircharm, holding up all traffic

According to the officer, the plan “will be considered by Lewisham in collaboration with the Deptford Construction Forum (or Deptford Evelyn Zonal Construction Logistics Forum), which aims to provide an overview to all construction activity and optimise operations to ensure impacts on neighbouring areas are minimised”.

First of all, one suspects that no such forum exists because the Planning Officer can't decide what it's called.

He said it was co-ordinated by the Environmental Team, which is a small team of three people who also have to deal with all sorts of other stuff as well as monitor all the developments in Lewisham.

It's likely there is NO Deptford Construction Logistics Forum. If there is one, local stakeholders have not been invited to take part. Without local representation, it cannot be called a ‘forum’. In planning terms, any mention of this should have been 'immaterial'.

Also 'immaterial' to this application was the reference to a Deptford Creekside Masterplan. This was apparently "currently being prepared" according to the officer's report. None of this was questioned by the committee.

There are apparently proposals being developed by Highways & Transport to ‘upgrade the public realm and roads of Church Street and Creekside’ but the only thing mentioned by the officer was a proposal to remove the ‘mini roundabout’ at the top of Creekside.

This is actually a triangle of pavement – not a mini roundabout. It's a traffic calming pedestrian island, not something people drive round and round. One begins to wonder if the officer has ever visited the site...

He claims that removal of the 'mini-roundabout' would "improve the environment for cyclists and pedestrians", but it’s quite obviously intended to make it easier for construction vehicles to navigate the entrance to No1 Creekside (and actually make it worse for pedestrians and cyclists). If the island wasn’t removed, the construction vehicles themselves would probably demolish it all on their own anyway.

Years ago there was talk of upgrading the main 'Birds Nest' roundabout (now referred to by some locals as the 'Democratic Republic of Roundabout'), reducing Church St to single lanes and widening the middle area into a boulevard of trees. Demolishing a small island of pavement seems to be as far as they’ve got in their Masterplan.

A note on ‘affordable housing’...

Cllr Paschoud began his Facebook post by referring to the 36% affordable housing being achieved at No.1 Creekside, explaining that this included “9 shared ownership and 11 social homes”.

This is yet another example of his disregard for what was said at the planning meeting. Moments before the meeting started, papers were hurriedly passed around as amendments to the Planning Officer’s report. Much of these amendments were corrections to typos in the poorly crafted report, but one of the corrections was revelatory:

Lewisham Planning announced that any reference to ‘social’ homes in the report should be replaced by ‘London Affordable Rents’. 

As Tidemill campaigners have been saying for the past year, LAR is 63% more than Lewisham Council Rents, so any reference to London Affordable Rent being a ‘social’ rent is wrong. Yet this is what Lewisham Council have been claiming for Tidemill (where ‘affordable rents’ will be London Affordable Rent, not ‘social rent’).

The Council (and in particular our local Councillor Joe Dromey) has been saying all this time that they are building ‘social’ homes for ‘social’ rent.

Finally Planning (from whom councillors take their cue) has admitted that these are not to be called ‘social’ – because they are not 'social'. In other words, anyone off the housing waiting list who takes up a place at Tidemill or No1 Creekside will not be able to afford the rent (£3k a year more) and is doomed to remain on housing benefit instead of being able to afford a lower rent in real ‘social’ housing.

Cllr Paschoud has not acknowledged this important amendment and continues to call London Affordable Rent ‘social’ rent. Read all the papers, eh, John?

Who is running the show?

To top it all, at No1 Creekside, there is no Social Housing Partner in place to manage the ‘affordable’ housing. This is usually something that should be sorted out before an application goes to planning, but this lot are leaving it to chance.

No one asked and no clue was given, and this important information certainly couldn't be gleaned from the financial figures published in the applicant's Viability Report which only referenced Bluecroft and not the Council's own resources. Any new deals will all go on behind closed doors as usual.

Likewise, there is no proper body to deal with managing the commercial space. The report claimed this would be a job for Shape Lewisham as if this were a credible funded body. Shape Lewisham is not a buildings manager, it is just a quango set up to explore the feasibility of creating Creative Enterprise Zones. It has £50k in funding from the GLA – not enough to manage a whelk store.

No one asked and no clue was given as to how Lewisham Council will be able to afford to let the commercial space at 'affordable' rates. Perhaps such subsidy will come from the GLA in the future, but none of this was established as solid, so is therefore 'immaterial' in planning terms, and should have led to a review, rather than an approval.

Any more shame for Lewishame?

Finally, this application was rushed through with only one public consultation in September 2017 (the bare minimum required). It was attended by 37 people, over 80% of whom did not support the scheme. The applicant claims in the report to have consulted many times with the Crossfields Tenants Association but have not been in contact with them even once.

As a result of the large number of objections to this application, a local meeting was held at Deptford Lounge in November 2018. The minutes of that meeting were never distributed to the attendees for any kind of approval in order to confirm they were an accurate record, even though email addresses were taken. Instead the shabby and, in parts unintelligible minutes were submitted as an Appendix to the Planning Committee for consideration on March 26th 2019.

What did get taken notice of however, was a 2000+ signature petition from Birds Nest pub regulars and supporters, who claimed that new private residents would get the live music venue shut down because of noise. The Planning officer had therefore sat up and organised some sound monitoring and there were lots of lame jokes at the meeting about the loud Norwegian band they’d had to listen to.

His solution was to introduce more Conditions: the Agent of Change principle would be drafted into the private leases – residents would not be allowed to complain about the noise from the pub. Another Condition was extra soundproofing for the walls but not the windows of the new building, so occupants would still be advised to keep their windows closed.

That’ll really work in summer when people are chatting loudly outside the pub and occupants want to open their windows and balcony doors. Or perhaps they won't want to open their windows because of the pollution. But it's not as though the pub itself is the cause of noise, as the Big Red (which is mostly outdoors) is already causing noise problems for local residents in April, with a different landlord who doesn't give a shit.

New to the committee, Cllr Janie Reid expressed a lot of concern for the future of the pub when it was being discussed, but none for the more worrying issues of pollution and poor doors. She voted for the development regardless.

Oddly, Cllr Abdeslam Amrani was on the committee (he asked no questions and voted in favour), although he is not listed on the official list of Strategic Planning Committee members. WTF was he doing there voting?

Turns out any Chair of the other committees A, B & C can stand in at SPC meetings to make it quorate (more than 3 people). At the time, Cllr Amrani was Chair of Planning Committee A (who deal with tiny redevelopments). Cllr Amrani is no longer Chair of anything since the reshuffle on 3 April (that was quite a reshuffle). Without Cllr Amrani and with Cllr Reid arriving late there was a point where there could have been no meeting.

Such is the state of Strategic Planning at Lewisham. In other words it's already been decided anyway.

Telling the truth

At the end of the planning meeting on 26 March, we went to the committee tables to collect all the unread material that had earlier been distributed to Councillors by the objectors. Not one Councillor had taken with them the chunky but beautifully designed and clearly laid out Citizen Sense document.

Cllr Paschoud was collecting his belongings and we asked him incredulously if he had actually read the planning application. He said “no”.

According to those who know him better, he likes to wind people up. But it would be easy to believe in this case that he was actually telling the truth for once.

Sunday, March 3, 2019

Sun Wharf planning application

Here we go again...

Application no: DC/18/110290

Demolition of all existing buildings and comprehensive redevelopment to provide 3 new buildings ranging in heights of 3 to 17 storeys to provide 233 residential units (C3 Use Class) and approximately 1,363sqm flexible commerical floorspace (B1/B2 Use Class) plus 254sqm flexible commercial floorspace (B1/B2/A3) in a container building, together with associated wheelchair accessible parking, cycle parking, landscaping, play areas, public realm, public riverside walkway and associated works at Sun Wharf Creekside SE8.

View the proposals on the Lewisham Planning Portal here (search Sun Wharf). Deadline for comments is 26 March 2019 (send to with the application number in the subject heading, and include your name & address in the content).

We have looked at the Design & Access Statement, Planning Application form, Viability Report, Community Involvement report, and the Environmental Assessment Summary (476 pages!) plus the Environmental Assessment Appendices (1276 pages!). Individual reports (such as Daylight/Sunlight studies, Transport, Air Quality etc) are usually listed separately but here they are hidden in two massive documents, which is likely to discourage many from reading them.

We last wrote about Sun Wharf in February 2016 when the first public consultation was held. There was a second consultation in May 2017 which the Deptford Dame covered, noting that all the building heights had gone up among other things. But since then there has been no further public engagement, although the proposals have changed quite a bit.

In the 2017 proposals Cockpit Arts were to get a new building within the development and their own building replaced by an 8 storey residential block on the street front. Cockpit have subsequently declined to be part of the development. The number of homes has gone from "up to 270" down to 233. Previously there were 62 podium parking spaces, now there are only 6 disabled bays. Another change is that Lewisham Council's favourite housing association Family Mosaic who own the site jointly with Bellway Homes have now merged with Tidemill developer Peabody.

Building heights (click to enlarge)
The basics:
1 x 17 storey tower (one floor higher than the Kent Wharf tower)
1 x building behind Cockpit Arts at 9 storeys going down to 8 and 5-6 storeys
1 x building next to Kent Wharf at 8 storeys (one higher than Kent Wharf) and 5-6 storeys.

233 homes:
48 'social' homes at London Affordable Rent (20%)
34 shared ownership (15%, making a total of 35% so-called "affordable")
151 private homes (65%)

10% of the site will be commercial, eg "creative business space", on the ground floors. Whilst this is described as providing "active frontages" and fulfilling Lewisham's plan for mixed employment & residential use in the area, the real reason is because they can't have residential on the ground floor in a flood plain.

All that on a 1.78 acre site. For comparison, the Tidemill site is 3.11 acres where only 209 homes are planned. This begs the question why destroy Tidemill Garden (as they did on Wednesday 27th February by demolishing 74 trees) when you can fit 233 homes into a site a third of its size?

74 trees demolished at Tidemill Garden by Peabody on Feb 27 2019

Tenure mix:
1 bed = 51 private, 13 shared ownership (SO), 19 London Affordable Rent (LAR)
2 bed = 78 private, 21 SO, 14 LAR
3 bed = 22 private, none SO, 15 LAR

Note that London Affordable Rent is 63% higher than Council Rent, but Lewisham Council calls this 'Social' Rent.

Only 16% are 3-bed family homes, none of which are shared ownership. As for shared ownership, it's assumed this is initially 25% and the rent on the remaining 75% is set as "affordable to household incomes of £51,500 – £67,500" (see Viability Report). The 'Socio-Economic' report (p269 of the 476 page Environment Statement) says that the median household income in New Cross Ward is £31,520 and in Evelyn Ward it's £30,560 (p.273). It notes the following:

Household income in New Cross (click to enlarge)
The same would be true of the 41 Shared Ownership homes offered at Tidemill (also by Peabody), so when Cllr Joe Dromey and Lewisham Council boast about housing people from the local area and off the housing waiting list, they're talking out of their arses. Local people can't afford it.

Statement of Community Involvement

As we said above, there have only been two consultations, and these were on the old proposals. The report is presented in such a way as to suggest there was a lot of support for them. But in the published comments it is clear this is not the case.

Consultation comments (click to enlarge)

130 attended the first one in Feb 2016, and 26 comments were received. Of these, nearly 60% (15) were critical or negative. Most of the comments in favour came from people who don't live in the area, eg, SE26 (Beckenham), SE9 (Sidcup), SE13 & SE12 (Lewisham), SE11 (Kennington). What are these people doing at a local consultation?

The second consultation held in May 2017 drew 22 comments, of which over 60% (16) were critical or negative. Those in favour hailed from SE4 (Brockley) and WA4 (Warrington). The exhibition boards (reproduced in the report) showed a timeline that said the application would be submitted in the summer of 2017, with work starting onsite in early 2019. Phew! Glad that deadline got put off.

There was no third consultation but the lackeys in charge of it (Your Shout) sent out an email locally to say Cockpit was no longer involved and that the site was car free with up to 230 new homes. No mention of how much was affordable, but recipients were invited to visit the website to find out more and complete an online survey. On the site, the respond button said something like "Support this proposal to find out more". So we didn't.

The previous comments still stand, only it's a bit worse now because there's no parking proposed on site. We all thought it was bad in 2016, but the traffic and parking situation on Creekside has only got worse.

Your Shout only got two responses to their third 'consultation' (undated in the report), which indicates this was hardly a proper consultation on the current plans. These were from a couple of hapless new Kent Wharf home owners, who hadn't even been in residence at the last 2017 consultation.

They were obviously shocked to find that their views and peace of mind would be disturbed by the building works and subsequent new housing blocks. A little online research might have thrown up some concerns but perhaps they relied on sales talk and their solicitor's local searches. The latter would not show up the plans unless an application was in. Any pre-planning discussions between LBL and the developers (which have been going on for some time) are invisible to everyone. But since Bellway bought the land in 2015, it was surely their responsibility as owners of Kent Wharf to warn their buyers that they intended to build next door.

Creekside Village East proposals that includes a parcel of land owned by Lewisham Council (Laban on the left, Essential Living to the right)

At Creekside Village residents have had to tolerate the building of the Essential Living towers (owned by offshore private equity 3i and funded by government Build To Rent grants) and will now have to contend with what Lewisham are allowing to happen behind the Laban where they are exchanging a parcel of public land in return for some enhancements to the Laban as part of the long awaited redevelopment of Creekside Village East (the land next to the Essential Living plots).

See the latest on this here by From The Murky Depths. Unfortunately he fails to examine Lewisham Council's contribution to the plan, but the Deptford Dame saw it coming in March 2016 before a previous application was subsequently withdrawn. The latest proposals went to Planning in August 2018, but there is no decision yet, perhaps because there is only 10% affordable on offer.

In addition, there is also a new development planned on the other side of the Creek at Saxon Wharf by so-called housing association Notting Hill Genesis, which From The Murky Depths covered in May 2018. Lovely views for the new Kent Wharf residents! Despite it being a housing association development, the affordable quota is only 35%, with 69% of that 35% being London Affordable Rent and the rest Shared Ownership, while 65%, obviously, is private.

Across the Creek at Saxon Wharf, a development by Notting Hill Genesis housing association
with only 35% 'affordable' housing.

A quick look at all the stuff in the 1752 pages of Environmental Statement & Appendices 


While it's perfectly obvious there's going to be a problem on Creekside with parking and our public transport links will be further overloaded without any promise of an increase in services, as usual, the report claims the impact will be neutral.

We're more concerned with the construction phase and which way the HGVs will be travelling. They'll be using the A2 apparently, even though Euromix is only round the corner. They say vehicles will go up Deptford Church St from the A2, along Creek Road and into Creekside at the north end, thus avoiding the south end of Creekside. There's some uncommitted nonsense about using the Creek and something about checking vehicle heights to see if they can get vehicles under the railway bridge on Creekside (in other words, south Creekside isn't ruled out). Just to show how seriously they take it, they provided this handy route map:

Construction route (click to enlarge)
LBL asked them to take into account the cumulative impact of other developments – 1 Creekside (Bluecroft and Lewisham), 2 & 3 Creekside (Artworks); Greenwich Pumping Station (Tideway); Essential Living (3i); Creekside Village East on Copperas St (LBL's co-development with Kitewood); and Tidemill (Peabody).

Oddly, but perhaps not surprisingly, LBL have left Tideway's works on Deptford Church Street off their list. They seem to be in denial about that. Or perhaps they're only listing what will be going on in 2022. However, the applicant has only looked at Kent Wharf (which is already built), No.1 Creekside and Convoys Wharf. See p.438.

The applicant is obtuse about how many deliveries per day there will be, giving figures for specific movements in different timelines, eg per day, per week or per project (eg 26 weeks) without providing a provisional table of movements per day over the course of the build.

No real construction logistics plan is provided. Drawings indicate HGVs will enter the site and turn around to exit front forwards, showing that at some point there will be some reversing within the site. This was terrible for Crossfields residents when Faircharm was in construction as the reversing happened at the entrance, and reversing vehicles use a beeping alarm which is really annoying when it happens 30 times a day. In this case, Cockpit Arts will bear the brunt of that noise, whilst Finch and Farrer Houses will be slightly shielded by the Cockpit building.

Nevertheless, as with Faircharm (when cement trucks queued with their engines running all the way up Creekside) and as with Kent Wharf (where they used Bronze Street and Creekside), this is likely to be hell for any poor soul at home during the day. Of course that all happened with assurances it wouldn't happen, and continued despite endless complaints to Lewisham Environmental Protection (charged with policing construction sites) and to 'Considerate Builders' (building industry regulators run by the building industry).

We also had to laugh at promises that construction workers will be required to use public transport! As if!

The transport report ends on a high note (summary p.442). Basically there'll be a neutral affect on Creekside because Jones's delivery vans currently generate more traffic than this construction site ever will and will be gone when it starts.


All neutral and negligible of course. Finch House will lose a bit of light at some times of the year, as will Holden House on the south side. The main impact from the building heights will be on Kent Wharf residents and new Sun Wharf residents, which it's admitted will be "major adverse". There's also a pretty sizeable and obvious impact on the Creek, but this and surrounding commercial properties (plus Creekside Centre and Laban) are not specifically addressed.

March equinox 8am (click to enlarge)

March equinox 4pm

June equinox 6am
June equinox 6pm
Dec equinox 2pm


As always, all the data is modelled so that the outcomes are neglible with no risk to health. Construction dust will be dampened down (like it wasn't at Faircharm). Exhaust emissions (PM10) from construction vehicles are not assessed. There are the usual assurances about no idling vehicles or generators (like there were at Faircharm and Kent Wharf, but never heeded).

Last week, on the same day that Peabody demolished Tidemill Garden's 74+ trees (sanctioned by Lewisham), the Council passed a motion to declare a Climate Emergency and to make Lewisham carbon free by 2030. Fair enough, the newer buildings going up are supposed to be more sustainable energy wise, and are not allowed to have any car parking, but in the meantime, we are being choked to death by construction vehicles, and there is nothing carbon neutral about demolishing buildings or constructing new ones.


Well of course this isn't relevant because precedents are already set nearby. The canyonisation of the Creek and the creation of another Lewisham Gateway continues apace, as this illustration from the Saxon Wharf planning application shows (thanks to From The Murky Depths). Note this doesn't include No.1 Creekside (12 storeys) or Tidemill (not so tall of course, though a taller building on that site could have saved the garden and demolition of Reginald House), and doesn't extend to the Seager building which started all this skyscraper malarkey around Deptford Creek.

Creek developments (click to enlarge)
An analysis of tall buildings is included in Environmental Statement under the title Townscape & Visual Impact (p.334), which refers to LBL's Tall Buildings Study. As we have noted previously in other posts, this study states that tall buildings should be avoided in "riverside environments where [they] might harm biodiversity interests through overshadowing" and where there might be "microclimatic problems at street level".

The latter is very much in evidence at Creekside Village on windy days, but of course this is all 'negligible' in relation to Sun Wharf, and the effect on the biodiversity is OK because they've taken advice from Creekside Centre.

None of Lewisham's own guidelines have been applied to any development along the Creek, just as none of their strategies on the environment are implemented when pitted against house building (even though most of this isn't providing the affordable homes required).

Apparently the proposed visual impact will have "moderate beneficial significance" for the Creek (p.364) and everywhere else of course! From Point Hill, "the project would not significantly affect the character and appearance of this ever changing London panorama...although the project is visible, it is not considered overly intrusive, unsightly or prominent...the magnitude of change is considered to be minor...".

The Creek townscape at Laban (click to enlarge)
Townscape at Creek Bridge
Townscape on Creekside
Townscape from Point Hill


Sometimes there are rewards in looking at all the local research various bodies have contributed to planning applications. In the lengthy report and appendices on the water environment, we were interested to see an updated Sewer Assets map from Thames Water (p1176 of appendices), which shows the drains on Crossfields are owned by Thames Water, not Lewisham Council.

The latter has been charging Crossfields residents for maintenance of these drains, which belong to TW (who residents also pay in their water rates). We first challenged the ownership of the drains over three years ago when Lewisham Homes got MITIE to include maintenance of them in their Major Works schedule. Thames Water finally admitted ownership, but Lewisham still won't acknowledge this. People might also be interested in the flood maps in this section (p.1095, p.1141, p.1129).

Thames Water sewer assets (click to enlarge)
Viability Report

The summary on p.121 shows the figures used to balance the books in order to provide 35% affordable housing in the scheme. It claims that revenue from the site is likely to be £100m, and the costs of building and finance also £100m, producing no surplus profit for the joint developers (though ample profit is already built into costs).

Page two of the Viability Summary (click to enlarge)
Included in the costs is the Acquisition of the site, stating a "Residualised Price" of £8,043,358. (Note that only 3.9% stamp duty is payable on a non-residential site). But according to the Viability Report for Tidemill (p13), Family Mosaic paid £15.15m for the site in February 2015.

Extract from Tidemill Viability Assessment (click to enlarge)
The Land Registry Title bears this out, except there are joint owners: Family Mosaic (Peabody) and Bellway.

Sun Wharf Title Register (click to enlarge)
However, what developers have actually paid for a site has long been irrelevant when it comes to the Viability of a project that fulfills the aims of the local authority's strategic planning and the developer's 'planning obligations'.

Instead, a 'Residual Land Value' (RLV) is arrived at through some jiggery pokery. According to Savills' explanation, the RLV = Built Value (ultimate sales values of both private & affordable homes + rental values on commercial properties) minus the Build & Finance costs (which include a guaranteed 20% profit for the developer on the private sales, 6% on the 'affordable', as well as 20% on the rentals).

Residual Land Value (click to enlarge)
It is not at all obvious how Savills arrived at an RLV of around £8m. That 'Residualised Price' is then incorporated as part of the 'Acquisition costs' in the Summary of Revenue and Costs – which are the same revenue and cost figures used in arriving at the RLV.

It's a very odd recipe. Say you want to make pancakes but don't have much time. You need flour, eggs, milk, oil and seasoning to make a batter and it takes 20 minutes to mix and cook. The recipe doesn't then say to add the batter you've made to a mixture of flour, eggs, milk etc and take another 20 minutes, thereby using twice as much ingredients and taking twice the time. Perhaps one of our readers can explain, but can a Councillor on the Strategic Planning Committee understand it?

Incidentally, the private sales values have been calculated on current prices that are likely to be much higher in 2029 when the development is complete.

Estimated sales values (click to enlarge)
But anyway, the books are balanced to allow for 35% affordable housing, and for that we should be grateful. Savills state that the project isn't viable but the applicant still wants to do it. It certainly might not be viable if the actual acquisition costs of the site (which are not mentioned at all) were taken into account. Hurrah for the bean counters.

What's a bit weird is Savill's Timescale (p.20 & p.119) which states the site will be purchased in Jan 2019. But they already bloody own it! Still, the timeline is comforting, since construction work is not planned to start till 2022 when Jones have vacated the site. (Incidentally, Jones' rent is now increasing year on year by £50kpa under the new owners).

Proposed timescale (click to enlarge)
Another point of note is the selective evidence used to make comparisons of affordable housing ratios in surrounding private developments (p.80):

Kent Wharf: 143 units – 125 private = 87% private, 13% affordable
Timberyard: 1132 units – 943 private = 83% private, 17% affordable
Bond House: 89 units – 77 private = 86% private, 14% affordable
Foundry: 316 units – 276 private = 87% private, 13% affordable
Maritime: 125 units – 81 private = 65% private, 35% affordable
Gramercy: 83 units – 54 private = 65% private, 35% affordable
Charters' Wharf: 87 units – 27 private = 31% private, 69% affordable

Charters' Wharf is a Peabody development on Deptford Creek, opposite Kent & Sun Wharves, which somehow manages to deliver 69% affordable in the borough of Greenwich, but struggles to reach 35% in Lewisham. Note that Greenwich developments are at least managing to achieve 35%, but Lewisham private developments rarely achieve more than 17%. Why is that?

Update 4 March: A reader has just alerted us to another Creek development just gone into Greenwich planning – the tallest yet at 26 storeys, 111 flats with only 26% affordable – which we previously missed on the From The Murky Depths blog.