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.