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Respond to planning application 16/AP/1232

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 16/AP/1232.

The original planning application to build on Green Dale and the documentation has been uploaded onto Southwark’s website:
Documents are appearing here:

How to respond to Greendale Property Company Ltd’s plans

The best way to respond to the planning application for the Green Dale is to write a comment via Southwark Council’s website. Your name and address will not be displayed but the comment will be made public, which means you can see what other people have written before you write your own:

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

Amy Lester
Southwark Council,
Chief Executive’s Department,
Planning Division,
Development Management,
PO Box 64529,
London SE1 5LX

Please make sure that you quote ref: 16/AP/1232

Suggested points to include – brief version

To help you respond to planning application 16/AP/1232 to build 155 flats on DHFC stadium and a 4000 seater stadium on Green Dale, here are some paragraphs that you can use as inspiration or if you need to, you can copy and paste them as your own.

Remember: it is much better to send in your own comments so if you copy/paste these, try to add some of your own words as well. Think about where you live and how the proposed development will affect you.

  • The location of the new stadium is on Metropolitan Open Land which is protected under the London Plan (Section 7.17) and Southwark Plan (Policy 3.25). The new stadium does not constitute an ancillary facility nor does it maintain the openness of MOL due to its enclosing wall. It would therefore be a departure from both the Southwark and London Plans.
  • The provision of a linear park 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 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 stadium build is therefore not an appropriate land use.
  • The affordable housing proposed in this development falls short of the 35% that Southwark requires. Only 13 – 16% of flats offered will be “affordable” (depending on whether you calculate by number of flats or square metres).
  • The proposed MUGA in no way compensates for the loss of the freely accessible astro turf pitch. It is one ninth of the size.
  • The new stadium will be built on a green corridor that is used by hedgehogs and bats (see the council’s “Green Dale Fields Ecological Report” from July 2014). The stadium build would remove hedgehog and bat habitat in Southwark when they are listed as important indicator species in the Southwark Biodiversity Action Plan, section 2.15.
  • Green Dale fields are being proposed by the council as as a Site of Importance for Nature Conservation (SINC) under the new Southwark Plan (preferred Option). This development, being so close to a SINC site, would damage its nature conservation value.
  • The footprint of the development is excessive and out of scale.
  • The height and massing of the 155 flats is overbearing and out of scale with the surrounding dwellings. It will be taller than the Sainsbury’s supermarket.
  • Noise Pollution will be a problem as the 3G pitch on the stadium means football will be able to be played all hours every day of the week.
  • The proposed flats will themselves be subjected to continuous noise from the new stadium as a result of the training which is likely to take place four or five nights a week and up till about 10.00pm.
  • Due to the increased use of the 3G pitch, light pollution will inevitably be a problem for nature and those on Wanley Rd and Abbotswood Rd.
  • The traffic plan and parking proposal do not adequately provide for the extra people in the flats nor the increase in spectators at the stadium. Local parking is already a problem on match days.
  • The high flats will overshadow St Francis Park and lead to a loss of light for the residents of Abbotswood Road.
  • The current DHFC ground is protected by a restrictive covenant to ensure it can only be used for “leisure or recreational or educational purposes”. This development of 155 flats goes against this covenant.

Suggested points to include – detailed version


Green Dale is home to a number of rare species of flora and fauna and has habitats that support bats, including the pipistrelle bat.  Hedgehogs, which are a protected species under the Wildlife and Countryside Act 1981 and The Protection of Wild Mammals Ace 1996, have been found on the site of the proposed stadium.  They use the green corridor that currently exists between the astroturf and the stadium wall. The site is also home to whitethroats, common toads, common frogs and various types of flora which are rarely seen in London.  Bats, too, are also protected under the above-mentioned legislation, as are also frogs and toads.

Southwark’s own planning policies with respect to wildlife state that:

“Developments will not be permitted which would damage the nature conservation value of Sites of Importance for Nature Conservation (SINCs) and Local Nature Reserves (LNRs) and/or damage habitats, populations of protected species or priority habitats/species identified in the United Kingdom, London or the Southwark Biodiversity Action Plan.”

Development on MOL

The proposed stadium will be built on the Green Dale which is Metropolitan Open Land, the inner city equivalent to Green Belt. 8121 square meters of MOL will be taken in the development. This land is council owned and important for the community and the future. It is maintained by community friends groups.

The notion that the MOL taken is only the astro-turf pitch and a ‘thin strip’ of other land is false. 2772 square meters of ‘virgin’ land beyond the astro-turf will be taken. This will cut into the northern bank 19m at its furthest point.

There will be significant building construction on Green Dale MOL. 1282 square meters will be concreted over to construct the covered terraces, perimeter walkways and boundary walls for the new stadium. This is equivalent to more than 36 houses from the Abbotswood estate next door.