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Respond to planning application 19/AP/1867

** UPDATE 25th August**

For the second time since the application was validated a month ago, Southwark planning team have moved the commenting form for this case to a different section of the Southwark website. Whilst some comments and information are on the “old” planning register, the comments form has been moved to the “new” register. This move has not been publicised, nor is it signposted form the planning application homepage, so good luck finding it! Luckily, we provide you with a link below. The offficial deadline is 27th August 2019 but they say they will accept comments after this date.

COMMENT ON THE APPLICATION »

The planning portal was down for 4 days from Friday 9th – Tues 13th August. The deadline for comments has been extended to the end of August. The council re-built their planning portal over the weekend so old links no longer work. Please use the links below.

Confusingly, the planning application has had 3 URLs since it was uploaded in July 2019. Southwark’s planning team have been updating their portal and as a result all live planning applications  have been moved around a bit. As of 23rd August the comment section has been split in two so it’s quite hard to keep track of things, plus the number of comments does not seem to add up. Southwark says they will be transferring all of the comments data over.

The second url, which has older comments appearing:
https://planning.southwark.gov.uk/online-applications-old/applicationDetails.do?activeTab=summary&keyVal=_STHWR_DCAPR_9583549

The third url with later comments:
https://planning.southwark.gov.uk/online-applications/applicationDetails.do?activeTab=summary&keyVal=ZZZV0JKBWR961

Documents are appearing here:
http://planbuild.southwark.gov.uk/documents/?casereference=19/AP/1867&system=DC

At the last count there were 197 documents. We are combining similar documents and uploading them to our site to make it easier for you to read the plans.

Responding to planning applications is not as natural and organic a process as most people would like it to be. You can only make comments on certain aspects of the application and other types of response do not count. Please see our general advice on how to respond to planning application or read below for specific points relating to planning application 19/AP/1867.

How to respond to planning application 19/AP/1867

You only have until the 15th  27th August to send in your comments about this latest planning application. If you have an email address, you can email comments to: planning.applications@southwark.gov.uk  mentioning ref number 19/AP/1867. Or you can use the online form on Southwark Council’s website but be aware that if you include your address in your comment, it will be shown on the website publicly. Other personal data will be removed apparently (though people’s names etc do get shown!)

 

COMMENT ON THE APPLICATION »

 

Not everyone has internet access. If you need to then you can write a letter using the following address:

FAO: Wing Lau
Southwark Council,
Chief executive’s department
Planning division
Development management (5th floor – hub 2) PO Box 64529
LONDON SE1P 5LX

Please make sure that you quote ref: 19/AP/1867

Suggested points to include

Here are some suggested points to make along with their associated planning references. Feel free to use these as you see fit on your objection, though writing something yourself is ideal as it makes the comments more individual.

  • The location of the new stadium, except for the clubhouse,  is on Metropolitan Open Land which is protected under the London Plan (Section 7.17) and Southwark Plan (Policy 3.25). The areas of the new stadium that are on MOL include the 3G pitch (with underground drainage pipes), pitch over-run, crash barrier, concrete terraces, concrete concourse and fencing. These do not constitute an essential ancillary facility nor do they maintain the openness of MOL due to its enclosing wall. It would therefore be a departure from both the Southwark and London Plans.
  • The fate of a private company, Dulwich Hamlet FC Ltd, does not constitute “special circumstances” to build on MOL. This application is a departure from London Plan (Policy 7.17).
  • The proposed stadium would require building on 747 m2 of proposed SINC (Site of Importance for Nature Conservation) at Green Dale Fields OS128. This SINC site has been proposed in the New Southwark Plan. In their report dated 17/12/2015 The Ecology Consultancy recommended that Green Dale Playing Fields OS128 become a SINC because “A number of Southwark BAP species have been recorded on site including hedgehog, stag beetle, common frog and house sparrow…The site probably offers one of the few remaining accessible areas of natural habitat in the local area as most nearby open spaces are managed for amenity and recreation”. The London Plan (Policy 7.19) states that new developments should “wherever possible, make a positive contribution to the protection, enhancement, creation and management of biodiversity”.  Building on an area that meets SINC status contravenes this policy.
  • The provision of a “green link” to mitigate the loss of MOL is contrary to the London Plan (Policy 7.17), section 7.56 which states that “development that involves the loss of MOL in return for the creation of new open space elsewhere will not be considered appropriate.
  • The proposed stadium would be built on a green corridor that is used by hedgehogs and bats, though the applicant’s Ecological Assessment tries to dismiss this, hedgehogs have been seen and also footprinted where the stadium is proposed (see Appendix 6 of the council’s “Green Dale Fields Ecological Report” from July 2014). Both bats and hedgehogs are listed as important indicator species in the Southwark Biodiversity Action Plan, section 2.15. The stadium and its construction would also encroach on nesting red list whitethroat birds.
  • The proposed open access MUGA in no way compensates for the loss of the freely accessible astro turf pitch, which is used extensively by local children. The MUGA is one twentieth of the size of the current astro turf pitch. This reduction in publicly accessible sports facilities goes against policies 2.1 ‘Enhancement of community facilities’ of the Southwark Plan 2007, Strategic policies 4 ‘Places for learning, enjoyment and healthy lifestyles’ and 11 ‘Open spaces and wildlife’ of the Core Strategy 2011, and Policy 3.19 ‘Sports facilities’ of the London Plan 2016.”
  • The current DHFC stadium is protected by a restrictive covenant to ensure it can only be used for “leisure or recreational or educational purposes”. This development of 224 flats goes against this covenant and would see a large, non-ancillary development on land designated as Other Open Space. This would therefore  be contrary to policy 3.27 ‘Other Open Space’ of the saved Southwark Plan (2007).
  • The height and massing of the 224 flats is overbearing and out of scale with the surrounding dwellings. The surrounding area is already densely populated with large housing estates on all four sides.
  • The proposed stadium has a capacity of 4000 with the option of increasing it to 5000 in the future. How this expansion will be carried out is not clear from the plans and it is concerning that further enclosure or encroachment on MOL is already being suggested, as MOL surrounds the stadium on three sides.
  • According to FA rules about football grounds for National League South, the perimeter fence must “prevent individuals from viewing the game from outside the ground.. and be of a minimum height of 1.83 m as measured from outside the ground.” As there is a steep bank to the NW of the proposed stadium, the fence will have to be 1.83 m tall from the top of this bank, even when the pitch is sunk. This is a very high impermeable fence that will block views across the site and will not maintain the openness of the MOL, even if it were screened by shrubbery. This fence, as suggested on page 25 of the Landscape Design Statement, is therefore in contravention of the London Plan (Policy 7.17) and the National Planning Policy Framework (Section 145b) and yet it is a requirement of the stadium from the FA.
  • The astro turf pitch does not constitute “previously developed land” as page 55 of the National Planning Framework clearly shows that parks and recreation grounds are exempt. The developing of a large part of the stadium provision on MOL is therefore not an appropriate land use.

Area calculations to support the above

The following graphics have been created from the planning application documents themselves. All calculations have been worked out using 3d design software and are as accurate as the diagrams submitted by DHFC and the property developers. Any errors should be taken up with the applicants.

 

 

 

 

 

 

 
 

Further graphics based on those supplied by the applicants

CGI supplied by developer

Screenshot from Google Earth

 

 

Current view, page 11 of Townscape and Visual Impact Assessment

Proposed height of buildings, page 12 of Townscape and Visual Impact Assessment

More realistic view using applicants’ diagram as a base but removing trees as proposed, moving communications mast and adding in the preferred option for fencing as proposed on page 25 of the Landscaping and Open Space document