Planning
Report
Statement
Bilfinger GVA
65 Gresham Street
London
EC2V 7NQ
Dulwich Hamlet Football Club and
Green Dale Fields
Planning Statement
March 2016
Greendale Property Company Ltd
gva.co.uk
Greendale Property Company Ltd
Contents
Contents
1. INTRODUCTION .............................................................................................................. 3 2. THE APPLICATION SITE ................................................................................................ 6 3. PLANNING HISTORY ...................................................................................................... 9 4. THE PROPOSALS AND THEIR BENEFITS .................................................................. 14 5. PLANNING POLICY FRAMEWORK .............................................................................. 21 6. PLANNING ASSESSMENT ........................................................................................... 48 7. SUMMARY AND CONCLUSIONS ................................................................................. 79 Appendices
Appendix I
LBS Sustainability Checklist
Appendix II
Alternative available open space within c. 2km
Appendix III
Draft S106 Heads of Terms
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Planning Statement
1.
Introduction
1.1
This Planning Statement has been prepared by Bilfinger GVA on behalf of Greendale
Property Company Ltd (the ‘Applicant’) in support of the application for full planning
permission for the redevelopment of the site at Dulwich Hamlet Football Club (DHFC),
Edgar Way, SE22 8BD and adjacent Green Dale Playing Fields.
1.2
The application is submitted to London Borough of Southwark (the ‘Council’). This
statement demonstrates the planning case in support of the application in the
context of relevant planning policy and guidance.
1.3
The proposed development involves the redevelopment and relocation of the DHFC
stadium, together with the provision of 155 residential units, a Multi-Use Games Area
(MUGA), linear park and improvements to Green Dale Playing Fields.
1.4
Specifically, the development delivers the following benefits to the local community:

The long term protection of a historic football club that is valued by the local
community through the provision of a new, purpose built facility based on sound
financial principles;

The transfer of the ownership of the Football Club to the local community and
fans through the establishment of a Community Benefits Society;

A management structure for the facility that will deliver a multi-purpose leisure
use that can not only be used by the Club, but also by local schools and
community groups;

Significant investment in Green Dale Playing Fields resulting in quality
improvements and enhanced community access to the open space;

The provision of new, publicly accessible open space via the development of a
new linear park which will serve as a ‘green link’ between St Francis Park and
Green Dale Playing Fields;

The provision of new, high quality, private and affordable housing which will
contribute towards Southwark’s housing need; and

Retention of the existing telecommunications equipment on site via the removal
of the existing, freestanding telecommunications mast and repositioning of
equipment on proposed residential block B.
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Planning Statement
Supporting Information
1.5
This Planning Statement should be read in conjunction with the associated
application forms and certificates, drawings, cover letter and the following
supporting documents:
Table 1 - Planning Application Supporting Documents
DOCUMENT TITLE
AUTHOR
Covering letter
Bilfinger GVA
Planning Application forms and Certificates
Bilfinger GVA
CIL form
Bilfinger GVA
Air Quality Assessment
WSP
Arboricultural Assessment
Crown Consultants
Archaeological Desk-Based Assessment
WSP
Daylight, Sunlight and Overshadowing Assessment
Delva Patman Redler
Design and Access Statement
Farrells
Ecological Habitat Assessment (incl. Bat Survey)
WSP
Energy and Sustainability Statement (including BREEAM)
BOCCA
Financial Viability Assessment (Confidential)
Savills
Flood Risk Assessment
WSP
Lighting Assessment
BOCCA
Noise Impact Assessment
Mayer Brown
Phase 1 Ground Investigation
Planning Statement (including Affordable Housing Information,
draft S106 Heads of Terms and LBS Sustainability Checklist)
Statement of Community Involvement
WSP
Townscape and Visual Assessment
Peter Stewart
Transport Statement and Travel Plan Framework
WSP
Existing and Proposed Architectural Drawings
Farrells
Landscape Strategy and Drawings
Grant Associates
Bilfinger GVA
Bellenden
Environmental Impact Assessment
1.6
A request for a Scoping Opinion was submitted to the Council on 1st July 2015 in
accordance with Regulation 13 of the Town and Country Planning (Environmental
Impact Assessment) (Amendment) Regulations 2015 (application reference
15/AP/2750). Following receipt of the Scoping Opinion, the Council on 20th
November 2015, stated that the proposals are not considered to constitute EIA
development.
1.7
The decision letter stated that the development is of a large scale, and there would
be impacts on the townscape, Metropolitan Open Land (MOL) and open space,
traffic conditions, public realm and social infrastructure. These impacts have been
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Planning Statement
considered and addressed within the supporting documents accompanying this
application for planning permission.
Pre Application Consultation
1.8
The proposed development has been subject to extensive consultation with key
stakeholders since 2014. These discussions have directly informed the scheme’s
evolution. A full schedule of pre-application meetings is provided in Appendix 1.
1.9
The project team has also engaged with the local community during the design
evolution. Three Public Exhibitions have been held, during which local businesses,
Councillors and residents were invited to comment on the emerging proposals.
Separate meetings were also held with local stakeholders, Ward Councillors and
neighbours. Extensive consultation has also been undertaken with the Football Club
committee, fans and the DHFC Supporter’s Trust. In addition, two pre-application
consultations have taken place with the GLA on 30 September 2014 and 15 January
2015 (references D&P/0083a).
1.10
A Statement of Community Involvement, prepared by Bellenden, provides further
details of the consultation exercises undertaken, and is submitted in support of this
planning application.
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Planning Statement
2.
The Application Site
2.1
The site extends to 4.7 ha and is located within the South Camberwell ward of the
London Borough of Southwark (LBS), to the west of Dog Kennel Hill. The site comprises
DHFC stadium (including car park), Green Dale Artificial Pitch and Green Dale
Playing Fields, both designated areas of MOL.
Figure 1 - Aerial view showing site location
2.2
The DHFC stadium consists of a grassed pitch, main stand (capacity 3,000 people)
and club house. There is a perimeter of hardstanding around the pitch with a smaller
covered stand on the southern side. Part of the club house is used as a gym with
other facilities, including function rooms, available for public hire. There are squash
courts located to the east of the club house, although these are not in use. The
eastern end of the site is occupied by a car park, part of which is currently used as a
hand car wash. A private access road connecting to a smaller footpath running
adjacent to the playing fields runs along the southern boundary of the site. This
borders residential development to the south.
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2.3
Planning Statement
Green Dale Playing Fields lies to the west of DHFC stadium and consists of a variety of
previously developed features. Green Dale Artificial Pitch, to the south east of the
playing fields, is in a state of disrepair and in need of replacement. Two disused and
overgrown tennis courts are located to the north of the pitch, with the remainder of
the site comprising overgrown and under maintained green space. The whole Site is
bound by perimeter fencing which has fallen down in places allowing unrestricted
access onto the site. As a result, Green Dale has become the subject of some
antisocial behaviour and inappropriate use. It also, however, provides natural habitat
for plant and animal species.
2.4
A large Sainsbury’s superstore lies immediately north of the Site, which itself is
immediately south of Dog Kennel Hill Woods. To the eastern boundary is Abbotswood
Road which separates the site from St. Francis Park, an area of open space. To the
south, the Site is largely bound by residential developments generally consisting of
two storey semi-detached dwellings. These residential properties separate the site
from East Dulwich Train Station and the line running towards West Croydon and
Wimbledon. To the south western corner of the Site, adjacent to Green Dale Playing
Fields, is a sports ground used by St. Saviours and St. Olaves School. A day nursery
adjoins the north west of the Site just below a new build residential development. A
pedestrian/cycle path runs along the western boundary that connects the housing
estates to the north and south of the Site.
2.5
The wider surrounding area is predominantly residential comprising a number of
housing estates and cul-de-sacs, consisting of a range of development including a
number of ‘mansion’ block estates.
2.6
The Site has a PTAL rating of 4, indicating its good location in terms of public transport
accessibility. The nearest rail station is East Dulwich, which is located 300m southeast
of the site along Dog Kennel Hill, being approximately 4 minutes’ walk. The station
provides services between West Croydon and Central London. Denmark Hill
Overground station is also located 1km north from the site along Dog Kennel Hill,
being approximately 12 ½ minutes’ walk. The application site is immediately
accessible to bus services at the adjacent Sainsbury’s and benefits from access to a
total of 5 frequent bus services in the local area, all of which are located within a
short three minute walk. The closest bus stop to the site is located outside Sainsbury’s,
directly opposite the site. This stop is served by route P13, and provides connections
to New Cross and Streatham.
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2.7
Planning Statement
The existing DHFC pitch is designated as ‘other open space’ within the Saved policies
of the Southwark Plan (2007), whilst Green Dale Playing Fields and Artificial Pitch are
designated Metropolitan Open Land (MOL). Adjacent are two sites of Nature
Conservation Importance (SNCI) and St Francis Park, an area of ‘Other Open Space’
as defined by the LBS Proposals Map 2014. The Site is bounded, in part, by the
boundary between the urban and suburban character zones. The Site falls within
Flood Zone Risk 1 (low risk) and within an Air Quality Management Area (AQMA).
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Planning Statement
3.
Planning History
3.1
A review of the Local Planning Authority’s Planning Applications Register returned the
following relevant planning history for the site.
Application Reference TP/2134-B/AH Granted October 1990
Location – Area immediately north of the proposal site and to include proposal site
itself.
3.2
An application for the redevelopment of the Kings College Sports Ground to provide
a retail store, coffee shop, public open space, construction of a new football
stadium, associated landscaping, car parking, access road and caretaker’s
bungalow.
3.3
The existing areas of open space located to the east of the site, St. Francis Park, and
the existing artificial football pitch, were constructed as part of the Section 106 for this
development.
3.4
The retail store referred to here is the Sainsbury’s store that is still in existence to the
north of the site today. The football stadium that was constructed as part of the
development permitted is the same that is still in existence and used by Dulwich
Hamlet Football Club today.
Application Reference 00/AP/0400 Refused 2002 and Appeal Dismissed June 2003
Location – Whole of proposal site
3.5
An application for the redevelopment of the site including the relocation of the
existing football ground onto Green Dale Fields and the erection of a new DIY store
on the football ground site.
3.6
This proposal included major development on Green Dale Fields. The scheme
proposed the relocation of the football ground onto Green Dale Fields with two
substantial stands and club house. 2 new all-weather football pitches and 5 tennis
courts were proposed to be built on the open space.
3.7
The scheme was recommended for approval by the Officer’s but was refused at
committee for the following reasons:
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Planning Statement
a) The new football ground, in particular the proposed stands and the likely
associated structures such as floodlighting and enclosures, would constitute a loss of
MOL, contrary to policy.
b) The proposal would give rise to increased traffic congestion on Dog Kennel Hill and
the roads leading to it, likely to be prejudicial to the free flow of traffic, in particular
buses, again contrary to policy.
3.8
An appeal was made but subsequently dismissed. The inspector concluded that the
development would not cause any rise in traffic levels due to it being a replacement
facility. However, it was concluded, based on the information submitted with the
application, that the development proposal for Green Dale Fields would constitute
an overdevelopment of the MOL.
Application Reference 07/AP/0580 Refused but Allowed on Appeal 7th January 2008
Location – Northern end of the car park within the proposal site boundary located
immediately east of the football ground.
3.9
An application for the continuation of use as a hand car wash operation and
retention of canopy and storage container within the car park element of the site.
3.10
The application was initially refused for the same reasons of causing a detrimental
impact upon the level of traffic at the site. However, the appeal was allowed.
Application Reference 10/AP/3161 Withdrawn 1st November 2010
Location – Entire car park site located within the proposal site boundary immediately
east of the football ground.
3.11
An application for the redevelopment of existing car park and car wash site to
provide a part 3, 4 and 5 storey building comprising 60 residential units (21 x 1-bed, 26
x 2-bed and 13 x 3-bed) with associated landscaping, amenity space and access to
basement which provides 30 car parking spaces and 70 cycle parking spaces.
3.12
This application was eventually withdrawn following a series of discussions with the
Council.
3.13
In a written response from the Council, as part of the pre-application discussions, the
principle of residential development for the car park site was agreed in principle.
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Planning Statement
Application Reference 11/AP/2280 Withdrawn 20th June 2011
Location – Entire car park site located within the proposal site boundary immediately
east of the football ground.
3.14
An application for the redevelopment of existing car park and car wash site to
provide a part 3, 4 and 5 storey building comprising 55 residential units (17 x 1-bed, 21
x 2-bed and 17 x 3-bed) with associated landscaping, amenity space and access to
the part basement which provides 28 car parking spaces and 63 cycle parking
spaces.
3.15
This scheme constituted a reduced scheme from that previously proposed under
application 10/AP/3161.
3.16
The application was withdrawn following comments from the Council.
Application Reference 11/AP/2250 Refused 14th February 2012
Location – Green Dale Fields.
3.17
An application for the development of new sports and recreation facilities to
comprise full length football pitch with associated floodlighting; 6 x Multi-Use Games
areas with associated floodlighting; BMX Track; New two storey club house with
space for 200 spectator seats; parking area for 46 cars, and coach park and
educational nature trail with new access points off Wanley Road and Green Dale
Cycle Path.
3.18
This application applied solely to Green Dale Fields. Although the application was
recommended for approval by the planning case officer, the application was
refused at committee for the following reasons:
a) Due to the inclusion in the scheme of a large number of sports pitches, with
fencing around these and floodlighting columns, this would detract from the
openness of the MOL.
b) Due to the absence of information on what species may inhabit the site, it was not
possible to assess whether an environmental statement was required.
c) Due to the absence of species surveys, in particular, bat and reptile surveys, it was
not possible to ascertain whether any protected species are present on the site.
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Planning Statement
d) Due to the inadequate assessment of transport issues, the council could not be
convinced that the scheme would not have an adverse impact on transport.
e) Due to the absence of stem diameter in the Arboricultural report, it was not
possible to determine the size and number of trees that required planting in order to
mitigate the loss of those trees that would be lost over the course of the
development.
f) The proposal would result in loss of amenity in terms of noise and light pollution for
nearby residents.
g) In the absence of a signed Section 106 or a Unilateral Undertaking to secure
mitigation for the developers impact on the site specific and strategic transport
issues, as well as open space and visitor management, there was no mechanism in
place to avoid or mitigate the impact of the proposed development on the transport
network and in relation to local improvements to the cycle network, public transport,
use of the site in terms of occupancy, and general open space improvements.
h) Due to the lack of modulation to the eastern elevation of the proposed club house
building, and the poor quality of the materials proposed to the western elevation, the
design of the club house would fail to achieve sufficient design quality in this
prominent setting and would therefore be harmful to visual amenities.
Application Reference. 13/AP/1732 Granted 21/02/14
Location - Dulwich Sports Ground, 102-106 Turney Road, SE21 7JH, Approx. 1.5km
southwest of the site.
3.19
An application was granted for the erection of a single storey timber clad building
adjacent to the existing club house, to be used as a children’s day nursery (D1)
Monday-Friday, and to provide evening and weekend sports teaching facilities (D2).
3.20
The site in question is MOL and this development constituted a departure from policy
regarding 3.25 of the UDP and Policy 7.17 of the Core Strategy.
3.21
The site is used by the community and is run by the Southwark Community Sports Trust,
a not for profit Community Interest Company as a sports ground. The company could
not meet operational costs, and as such, the introduction of a commercial use in the
form of a day nursery on the site was necessary to ensure the continued use.
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3.22
Planning Statement
The Council considered that the strong local need demonstrated by the high usage
of the site and the financial difficulties facing the site was sufficient to constitute ‘very
special circumstances’.
3.23
Other planning applications that have been submitted for the site are detailed in the
table below:
Table 2 - Other planning applications submitted on the site
Application
Ref.
Description of development
Decision
09/AP/1565
Details of colours as required by Condition 3 of appeal decision
LBS Registration No 07AP0650 APPEAL REF
APP/A5840/A/08/2077058 for continuation of use as a hand car
wash operation and retention of canopy and storage container.
Granted
09/AP/1634
Variation of conditions relating to opening hours of the car
wash(in order to operate 08:00 to 19:00 Monday to Friday, 08:00
to 17:00 on Saturdays, 11:00 to 17:00 Sundays and 09:00 to 13:00
on public holidays).
Granted
09/AP/0251
Variation of conditions relating to opening hours of the car
wash(in order to operate 08:00 to 19:00 Monday to Friday, 08:00
to 17:00 on Saturdays, 11:00 to 17:00 Sundays and 09:00 to 13:00
on public holidays).
Refused
07/AP/0580
Continuation of use as a hand car wash operation and retention
of canopy and storage container.
Allowed
on
appeal
06/AP/0185
Continuation of use as a hand car wash operation.
Refused
06/AP/0232
Retention of a freestanding banner sign.
Refused
04/CO/0082
Erection 8 no. 4.5 metre high lighting columns to the southern side
of existing footpath between Green Dale and Burrow Road.
Granted
04/AP/1276
Extension to front of retail store (Class A1) to provide additional
retail space, with repositioned coffee shop and ATMs, alterations
to car park; reconfiguration of footpath link to Denmark Hill
Estate, associated highway works and landscaping.
Granted
with legal
agreeme
nt
CO/02/0629
Installation of new path with step and ramp across playing field
for access into adjacent property (Sainsburys).
Granted
with
conditions
AP/97/0851
Use of land east & (inside the) south of stadium as an open
general market (92 stalls) every Tuesday and Thursday. West side
(including astroturf pitch) to be used for vehicle parking purposes.
Refused
AP/97/1444
Replacement of north and part of east boundary fence with 2.4m
high, steel security fence.
Granted
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Planning Statement
4.
The Proposals and their benefits
4.1
The submitted planning application seeks permission to redevelop the application
Site to include the following:
4.2

New stadium for DHFC;

155 residential units (plus 56 residential parking spaces);

Multi-use games area (MUGA);

New publically accessible linear park;

Green Dale Playing Fields landscaping improvements; and

Replacement of telecommunications mast with rooftop plant and equipment.
Each element of the development brings significant benefits to the community and
existing site, as outlined below.
New Football Club and Community Facilities
4.3
This application responds to the need to relocate and rebuild the current Champion
Hill Stadium and provide DHFC and the community with a sustainable sporting facility
that has a long term, secured future.
4.4
The current stadium was constructed in the early 1990s to include a full-sized football
pitch plus 5-a-side pitches, main stand, clubhouse and health and fitness club,
including gym and squash courts. This previous redevelopment of the Club was
intended to provide a strong and financially sustainable base for DHFC, but in reality
the Club has been unable to support the level of ancillary facilities currently provided
on site. The gym, squash courts and entertainment space have been consistent loss
makers that have resulted in a wholly financially insecure future for DHFC.
4.5
An application to register the DHFC as a community asset was made on the 9th
August 2013 by the Dulwich Hamlet Supporters Trust. This was in line with Part 5
Chapter 3 of the Localism Act 2011 which introduced a scheme known as Assets of
Community Value. The scheme allows for parish councils or groups with a connection
to the community to nominate an asset for listing. If successfully listed, the community
will then be given the right to bid on an asset should it go up for sale or be subject to
a change of ownership. If a nomination is successful, it is then at the discretion of the
local council as to whether or not it is a material consideration in a planning
application.
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4.6
Planning Statement
The application was however unsuccessful due to the Club being in financial
administration at the time. The provisions of the Insolvency Act therefore applied
which preclude a valid application from being made. The application however
epitomises the importance of the Club to the wider community and identifies the
need to protect the future of DHFC.
4.7
At the time of the application to list the building as a Community Asset, the Applicant
stepped in and quickly realised the importance of the Club to the local community.
A number of immediate measures were put in place to prevent the Club from
complete bankruptcy. This involved:

Putting in place interim management;

Settling a number of outstanding utilities and other debts;

Stopping a number of unauthorised uses of the building; and

Undertaking a comprehensive assessment of the financial health of the Football
Club.
4.8
Whilst effective measures have been put in place during the period since the
Applicant’s initial involvement, considerable regular payments have been made to
support the Club without which it would be unable to continue.
4.9
The current Club facilities also serve to inhibit the future promotion and expansion of
DHFC. The existing capacity of the Champion Hill stadium is 3,000 person. In order to
meet current FA requirements and enable progression to the National League (also
known as the Conference), DHFC must provide a stadium that can accommodate
at least 4,000 spectators, and provide specific facilities for officials and the press.
Without such provision, the Club is confined to its current position in the 7th tier of the
Football Pyramid.
4.10
Whilst improved Club facilities will directly benefit DHFC, a secure future for the Club
have far reaching implications. The Club is one of the oldest league sides in London
and has been part of the Dulwich community for over 100 years, with Champion Hill
being DHFC’s spiritual home for the majority of that period. The Club’s long term
survival plus potential for growth and promotion is therefore crucial to the identity
and sporting heritage of the local community.
4.11
Another inadequacy with the current football pitch is the limited ‘value’ it provides as
an area of open space. The current pitch is designated as ‘Other Open Space’ by
local planning policy, and is categorised as ‘Outdoor Sports Facilities – private’ within
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Planning Statement
the Southwark Open Space Strategy 2013. The Open Space Strategy assesses the
‘value’ of provision, in addition to the ‘quality’, and identities the pitch as being of
‘below average value’ with a score of 22.6%.
4.12
Value is separate to quality, and is assessed in the Strategy under the following
headings:

The context of the open space, which largely concentrates on the local open
space need within the vicinity of the space and site access.
4.13

The recreational function performed by the open space.

The structural role of open space in separating and defining communities.

The amenity value of spaces.

The ecological role performed by spaces.

The environmental value of spaces.

The existing educational value of spaces to the community.

The cultural and social value of spaces.
The current football pitch and stadium are used at limited times for football matches
and are not otherwise accessed by the community. If the Club were to fail the pitch
would become even more inaccessible to the community, its current use being solely
limited to that by DHFC. The open space is therefore of limited value in terms of
recreation and amenity. Threat of closure also jeopardises the pitch’s cultural and
social value as the historical home of DHFC.
4.14
The pitch also lacks ecological value in terms of biodiversity. There is therefore a clear
benefit in replacing the existing pitch with an improved area of open space that
provides greater value to the community and local area.
4.15
The deficiencies of the current Club facilities can therefore be summarised as follows:

Underused ancillary facilities that drain resources and result in a wholly financially
insecure future for the Club, threatening a community asset;

Insufficient stadium capacity / parking provision to meet FA requirements and
enable DHFC’s progression into upper leagues;

4.16
Low ‘value’ of current pitch, including a lack of community access and use.
The above deficiencies have guided the design of the proposed new stadium and
ancillary facilities, which has been future proofed for sustainability to include:

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New stadium to provide capacity for up to 4,000 people;
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Planning Statement

New health and fitness club, efficiently designed to meet current demand;

3G all-weather pitch at DHFC stadium that can be used throughout the year;
and

A 3G all-weather multi-use games area (MUGA) that can be used for a variety of
ball sports including netball, basketball, tennis, volley ball as well as football.
4.17
The stadium will be re-built to the west of the existing site on previously developed
land. The pitch will be largely located onto the poorly conditioned and vastly
underutilised Green Dale Artificial Pitch, designated as MOL. The main built
infrastructure, in the main stand and clubhouse, will be built outside MOL on the site
of the existing stadium. This is to ensure minimal impact on the openness of the MOL.
4.18
In addition, the proposal includes fewer floodlights than the existing provision, which
are also lower, resulting in a less intrusive impact on the MOL. Whilst a fence will run
around the pitch, to prevent casual spectators, this will be landscaped so as again to
prevent the impact on the openness of the MOL.
4.19
The new pitch will be a 3G artificial surface which has a significant number of benefits
compared to the current grass pitch. Artificial pitches can be used in much more
severe weather conditions than a grass pitch as they do not become frozen or
waterlogged. This will allow for use throughout the year, enabling maximum
community access and resulting in local health and leisure benefits.
4.20
In contrast to the current use of the grass pitch during the football season only, and
maximum of twice per week, the 3G surface can be used for up to 60 hours per week
all year round. It will therefore be available for hire and community use when not in
use by the Football Club. This benefit will be secured through a S106 planning
agreement.
4.21
The maintenance costs of an artificial pitch are also much lower, without the
constant upkeep required for a grass pitch. This will help ease the current financial
burdens on the Club whilst allowing for additional benefits such as use of the pitch for
both training and matches without the risk of deterioration. As set out above, the
pitch will also be let to the local community which will generate revenue. This will
ensure proper on-going maintenance.
4.22
It is intended that the stadium facility will be constructed and handed over to a
charitable organisation and / or the London Borough of Southwark for management.
The Football Club will then receive free use of the facility and be able to generate
income to run the team through gate receipts and bar takings on match days.
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4.23
Planning Statement
Crucially, the level of provision developed for the Club will be sufficient to support its
continued growth and enable promotion into a higher division, whilst being of an
appropriate size and operation to mitigate the current financial drain of existing
facilities. This will ensure a long term sustainable future for DHFC, protecting its
historical significance within the local area and enhancing its community value.
4.24
As set out above the Club will be transferred from private ownership to permanent
management and ownership through an appropriately established Community
Benefits Society. The applicant has been working with the Football Trust and specialist
organisations including Supporters Direct who have significant experience and
proven track record of establishing this structure. Examples include Brentford FC and
Wimbledon RFC.
Enabling Residential Development and New Linear Park
4.25
The proposals include the provision of 155 residential units to be developed on the
site of the existing Football Club, including the pitch which is currently designated as
‘Other Open Space’. This will help enable the stadium’s relocation and
redevelopment whilst delivering a vibrant community of affordable and private
homes, contributing towards the delivery of much needed housing in the Dulwich
area.
4.26
The proposals incorporate open space into the design of the residential development
through the provision of a linear park. The park will comprise a series of woodland
glades, each with their own character, to include a variety of planting typologies
and habitat opportunities. Long, linear benches will define each glade, providing
seating opportunities, and play opportunities will be provided throughout the park.
The linear park also provides an arrivals space and meeting point for the Football
Club.
4.27
The linear park reflects the character of the area and helps mitigate the loss of the
existing football pitch by providing high quality, high value and genuinely accessible
open space.
4.28
Further, the linear park will connect the existing open spaces of St. Francis Park and
Green Dale Fields, providing greater public access to these areas. The park will
therefore not only provide superior quality open space in itself, but serve to improve
the areas that it links by enhancing their ‘openness’ and subsequent value. This is
particularly significant for Green Dale Playing Fields.
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4.29
Planning Statement
The linear park will also serve to bring environmental and ecological benefits to the
development and local community. Whilst the existing football pitch offers little in the
way of biodiversity, the new linear park will comprise of a variety of landscape uses
and habitats. The planting frameworks for each glade will include specimen trees,
perennial mixes, woodland understories and species-rich meadows and lawns,
providing year-round seasonal interest and habitat creation.
4.30
The proposals therefore represent an efficient use of land, by utilising existing, low
value ‘open space’ to provide enhanced open space and sporting facilities in the
form of the new stadium, linear park and Green Dale fields improvements (see
below). The development will also take place on previously development land, in line
with national and local priorities.
Green Dale Playing Fields Improvements
4.31
Green Dale Playing Fields comprises 2.12 hectares of designated MOL and is
classified as ‘natural or semi natural green space’ in the Council’s Open Space
Strategy. The area comprises overgrown and under maintained green space. The
whole site is bound by perimeter fencing which has fallen down in places allowing
unrestricted access onto the site. As a result, Green Dale has become the subject of
some antisocial behaviour and inappropriate use.
4.32
It has long been recognised that the playing fields are in need of improvements and
there is a strong local aspiration to make Green Dale an accessible asset for the local
community. The Council’s Open Space Strategy categorises the space as being of
below average quality and value (with scores of 48.8% and 11.8% respectively), and
specifically identifies Green Dale as being particularly in need of quality
improvements.
4.33
The Council consulted twice in 2014, exploring options to make better use of the
open space at Green Dale Fields. This resulted in a scheme that incorporates;

The introduction of play equipment;

Additional habitat features to encourage wildlife;

New pathways improving access to the area;

Flower meadows;

Removal of fencing to open up the space; and

The planting of new trees.
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4.34
Planning Statement
We have incorporated the broad principles of this proposal within our landscaping
strategy with a view to formalising details during the application process with the
involvement of various stakeholders. It is anticipated that this final strategy will
delivery and secure long term benefits to the local community via the sensitive
treatment of Green Dale Fields.
Relocation of phone mast
4.35
The current site includes a telecoms mast and associated equipment room, located
to the south east of the existing DHFC pitch. The current mast stands at 32.3 meters
and forms an obtrusive feature on the current sky line. The proposals will remove the
mast, and replace with aerial equipment located on the top of block B. This will
move the mast away from existing residential, whilst reducing the scale of the
equipment and its subsequent impact on the ‘openness’ of the MOL, creating an
overall improvement.
Construction Programme
4.36
It is anticipated that the construction phase of the development will last for
approximately 30 months. The new stadium and associated facilities will be
constructed first and will comprise an off-site manufacture for reduced on-site works.
At a similar time, the existing stadium will be demolished to make way for the
proposed residential development. The construction and fit-out process for the
residential will be expected to last for approximately 18 months. The soft and hard
landscaping, environmental improvements and the MUGA will be installed last in the
development programme.
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Planning Statement
5.
Planning Policy Framework
5.1
This Proposed Development has been prepared in the context of relevant policies
from national, regional and local policy and guidance. This section of the Planning
Statement sets out the policy framework and relevant policies against which the
scheme is subsequently assessed in Section 6.
Adopted Planning Policy Framework
5.2
Section 38 (6) of the Planning and Compulsory Planning Act (2004) requires that
decisions made under the Planning Acts are determined in accordance with the
development plan unless other material considerations indicate otherwise.
5.3
The Development Plan comprises the following:

London Plan (2015) (Consolidated with Minor Alterations Since 2011)

Southwark Core Strategy (2011)

Southwark Plan (2007) (saved policies)
National Planning Policy
5.4
The National Planning Policy Framework (NPPF) was published by the Government on
27th March 2012. It sets out the Government’s national policy for planning issues in a
single, comprehensive document.
5.5
The National Planning Policy Guidance (NPPG), published online in March 2014 and
subsequently amended, streamlines previous planning guidance. The NPPG includes
guidance on matters such as flood risk, green belt protection, local plan production,
renewable energy and use of brownfield land. The NPPG has been amended to
include greater emphasis on the importance of bringing brownfield land into use and
issuing more robust guidance with regards to flood risk.
Relevant Policies of the NPPF
5.6
The NPPF states that the purpose of the planning system is to contribute to and aid in
the achievement of sustainable development. The NPPF asserts that the planning
system should carry a “presumption in favour of sustainable development” – a
“golden thread” running through the creation of development plans and in the
decisions taken by local planning authorities when determining planning
applications. In particular, paragraph 111 of the NPPF encourages the use of
previously developed (brownfield) land for new developments.
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5.7
Planning Statement
Paragraph 17 sets out 12 Core Planning Principles, to include proactively driving and
supporting sustainable economic development to deliver the homes and thriving
local places that the country needs. In doing so, every effort should be made to
objectively identify and meet housing and other development needs of an area,
responding positively to wider opportunities for growth.
Supporting high quality communications infrastructure
5.8
Chapter 5 ‘Supporting high quality communications infrastructure’ acknowledges
that high quality communications infrastructure is essential for sustainable economic
growth.
5.9
Paragraph 45 states applications for telecommunications development (including for
prior approval under Part 24 of the General Permitted Development Order) should be
supported by the necessary evidence to justify the proposed development. This
should include:

the outcome of consultations with organisations with an interest in the proposed
development, in particular with the relevant body where a mast is to be installed
near a school or college or within a statutory safeguarding zone surrounding an
aerodrome or technical site; and

for an addition to an existing mast or base station, a statement that selfcertifies that
the cumulative exposure, when operational, will not exceed International
Commission on non-ionising radiation protection guidelines; or

for a new mast or base station, evidence that the applicant has explored the
possibility of erecting antennas on an existing building, mast or other structure and a
statement that self-certifies that, when operational, International Commission
guidelines will be met.
Residential
5.10
Chapter 6 concerns the delivery of a wide choice of high quality homes. Paragraph
49 states that housing applications should be considered in the context of the
presumption in favour of sustainable development.
5.11
Paragraph 50 states that in order to deliver a wide choice of high quality homes,
widen opportunities for home ownership and create sustainable, inclusive and mixed
communities, local planning authorities should:
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
Planning Statement
plan for a mix of housing based on current and future demographic trends,
market trends and the needs of different groups in the community (such as, but
not limited to, families with children, older people, people with disabilities, service
families and people wishing to build their own homes);

identify the size, type, tenure and range of housing that is required in particular
locations, reflecting local demand; and

where they have identified that affordable housing is needed, set policies for
meeting this need on site, unless off-site provision or a financial contribution of
broadly equivalent value can be robustly justified (for example to improve or
make more effective use of the existing housing stock) and the agreed
approach contributes to the objective of creating mixed and balanced
communities. Such policies should be sufficiently flexible to take account of
changing market conditions over time.
Promoting Healthy and Communities
5.12
Chapter 8 of the NPPF outlines the national policy towards promoting healthy
communities. Paragraph 70 states that to deliver the social, recreational and cultural
facilities and services the community needs, planning policies and decisions should
plan positively for the provision and use of community facilities (including sports
venues) to enhance the sustainability of communities and residential environments.
There should be an integrated approach to considering the location of housing,
economic uses and community facilities and services.
5.13
Paragraph 73 recognises that access to high quality open spaces and opportunities
for sport and recreation can make an important contribution to the health and wellbeing of communities.
5.14
Paragraph 74 states that existing open space, sports and recreational buildings and
land, including playing fields, should not be built on unless:
a) An assessment has been undertaken which has clearly shown the open
space, buildings or land to be surplus to requirements; or
b) The loss resulting from the proposed development would be replaced by
equivalent or better provision in terms of quantity and quality in a suitable
location; or
c) The development is for alternative sports and recreational provision, the
needs for which clearly outweigh the loss.
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Planning Statement
Green Belt
5.15
National guidance on the protection of the Green Belt is outlined in Chapter 9 of the
NPPF. This is relevant because Green Dale Playing Fields and Artificial pitch are
designated as Metropolitan Open Land (MOL), which, whilst unique to London, is
granted the same protection as Green Belt.
5.16
Paragraph 87 states that as with previous Green Belt policy, inappropriate
development is, by definition, harmful to the Green Belt and should not be approved
except in very special circumstances.
5.17
Paragraph 88 states that ‘Very special circumstances’ will not exist unless the
potential harm to the Green Belt by reason of inappropriateness, and any other
harm, is clearly outweighed by other considerations.
5.18
Paragraph 89 identifies the exceptions to inappropriate development in the green
belt as:

buildings for agriculture and forestry;

provision of appropriate facilities for outdoor sport, outdoor recreation and for
cemeteries, as long as it preserves the openness of the Green Belt and does not
conflict with the purposes of including land within it;

the extension or alteration of a building provided that it does not result in
disproportionate additions over and above the size of the original building;

the replacement of a building, provided the new building is in the same use and
not materially larger than the one it replaces;

limited infilling in villages, and limited affordable housing for local community
needs under policies set out in the Local Plan; or

limited infilling or the partial or complete redevelopment of previously developed
sites (brownfield land), whether redundant or in continuing use (excluding
temporary buildings), which would not have a greater impact on the openness
of the Green Belt and the purpose of including land within it than the existing
development.
Conserving and Enhancing of the Natural Environment
5.19
Chapter 11 of the NPPF is regarding Conserving and Enhancing of the Natural
Environment. Under paragraph 109, the planning system should contribute to and
enhance the natural and local environment by minimising impacts on biodiversity
and providing net gains in biodiversity where possible.
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5.20
Planning Statement
Paragraph 111 states that planning policies and decisions should encourage the
effective use of land by re-using land that has been previously developed
(brownfield land), provided that it is not of high environmental value.
London Plan
5.21
The London Plan is the overall strategic plan for London. The document has been
recently updated and sets out an integrated economic, environmental, transport
and social framework for development up to 2036.
Health and Wellbeing
5.22
The London Plan will help deliver ‘Objective 5: Healthy Places’ of the Mayor‘s Health
Inequalities Strategy to ensure new homes and neighbourhoods are planned and
designed to promote health and reduce health inequalities. This is reiterated by
Policy 3.2 of the London Plan ‘Improving Health and Addressing Health Inequalities’
which states that new developments should be designed, constructed and
managed in ways that improve health and promote healthy lifestyles to help to
reduce health inequalities.
Sport and Recreation
5.23
The London Plan acknowledges that sports and recreation facilities are important
parts of the social infrastructure, providing a range of social and health benefits for
communities and neighbourhoods. Backed by the Mayor’s Sports Legacy Plan, these
will be given increasing prominence as part of the legacy of the 2012 Olympic and
Paralympic Games.
5.24
Policy 3.19 ‘Sports Facilities’ states that development proposals that increase or
enhance the provision of sports and recreation facilities will be supported. Proposals
that result in a net loss of sports and recreation facilities, including playing fields
should be resisted. Wherever possible, multiuse public facilities for sport and
recreation should be encouraged. Where sports facility developments are proposed
on existing open space, they will need to be considered carefully in light of policies
on Green Belt and protecting open space (Chapter 7) as well as the Borough’s own
assessment of needs and opportunities for both sports facilities and for green
multifunctional open space.
5.25
Policy 3.6 requires that development proposals that include housing should make
provision for play and informal recreation, based on the expected child population
generated by the scheme and an assessment of future needs. The Mayor’s
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Planning Statement
Supplementary Planning Guidance ‘Providing for Children and Young People’s Play
and Informal Recreation’ sets out guidance to assist in this process.
5.26
Based on the number of units and mix proposed in this application, 383.4m² of
playspace is required in accordance with the Mayoral Playspace Strategy
Housing
5.27
The Mayor is clear that London desperately needs more homes in order to promote
opportunity and real choice for all Londoners, with a range of tenures that meets
their diverse and changing needs and at prices they can afford.
5.28
Policy 3.3 sets a London-wide target to provide an annual average of 42,200 net
homes across London. Table 3.1 of the Plan sets the London Borough of Southwark a
10 year target of 27,362 with an annual monitoring target of 2,736 additional homes
per year to contribute towards the net target.
5.29
Policy 3.4 encourages the optimisation of development potential on residential sites
based on appropriate density ranges relating to setting in terms of location, existing
built form and massing and PTAL ratings set out in Table 3.2 of the Plan.
5.30
Policy 3.5 requires that housing developments should be of the highest quality
internally, externally and in relation to their context and the wider environment. Local
Development Frameworks should incorporate minimum space standards that
generally conform to London Plan Table 3.3.
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Planning Statement
Figure 2 - Minimum Space Standards New Development (London Plan)
5.31
Policy 3.8 requires developments to provide a choice of housing to accompany the
requirements set out in Policy 3.3. It notes in particular that new developments should
offer a range of housing choices, in terms of the mix of housing sizes and types, taking
account of the housing requirements of different groups and the changing roles of
different sectors in meeting these. The provision of affordable family housing shall be
addressed and all new housing is to be built to ‘The Lifetime Homes’ standard. Ten
per cent of new housing must be wheelchair accessible, or easily adaptable for
residents who are wheelchair users.
5.32
The London Plan sets out a broad 20 year requirement for 464,000 (23,200 a year)
more market homes and for 512,000 (25,600 a year), additional affordable homes
across London.
5.33
Policy 3.11 of the London Plan sets out that 60% of affordable housing provision
should be social or affordable rent and 40% intermediate housing, and that priority
should be accorded to the provision of affordable family housing.
Social Infrastructure
5.34
The London Plan defines social infrastructure as covering a wide range of facilities
including recreation and sports and leisure facilities.
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5.35
Planning Statement
Policy 3.16 states that development proposals which provide high quality social
infrastructure will be supported in light of local and strategic social infrastructure
needs assessments. Proposals which would result in a loss of social infrastructure in
areas of defined need for that type of social infrastructure without realistic proposals
for reprovision should be resisted. Facilities should be accessible to all sections of the
community (including disabled and older people) and be located within easy reach
by walking, cycling and public transport. Wherever possible, the multiple use of
premises should be encouraged
Responding to Climate Change
5.36
Policy 5.2 requires that development proposals make the fullest contribution to
minimising carbon dioxide emissions in accordance with the following energy
hierarchy:
5.37
1
Be lean: use less energy
2
Be clean: supply energy efficiently
3
Be green: use renewable energy
Policy 5.2 and Standard 35 of the London Housing SPG (2016) requires that
development proposals should meet the minimum target of 35% improvement on the
2013 Building Regulations between 2014-2016, and achieve zero carbon between
2016 – 2036. Major development proposals should include a detailed energy
assessment to demonstrate how the targets for reducing carbon dioxide emissions
are to be met within the framework of the energy hierarchy.
5.38
Policy 5.3 states that development proposals should demonstrate that sustainable
design standards are integral to the proposal, including its construction and
operation, and ensure that they are considered at the beginning of the design
process.
5.39
Major development proposals should meet the minimum standards outlined in the
Mayor’s supplementary planning guidance and this should be clearly demonstrated
within a design and access statement. The standards include measures to achieve
other policies in the London Plan and the following sustainable design principles:
a)
minimising carbon dioxide emissions across the site, including the building and
services (such as heating and cooling systems)
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Planning Statement
b)
avoiding internal overheating and contributing to the urban heat island effect
c)
efficient use of natural resources (including water), including making the most
of natural systems both within and around buildings
d)
minimising pollution (including noise, air and urban runoff)
e)
minimising the generation of waste and maximising reuse or recycling
f)
avoiding impacts from natural hazards (including flooding)
g)
ensuring developments are comfortable and secure for users, including
avoiding the creation of adverse local climatic conditions
h)
securing sustainable procurement of materials, using local supplies where
feasible, and
i)
5.40
promoting and protecting biodiversity and green infrastructure.
Policy 5.6 requires development proposals to evaluate the feasibility of Combined
Heat and Power (CHP) systems, and where a new CHP system is appropriate also
examine opportunities to extend the system beyond the site boundary to adjacent
sites.
5.41
Policy 5.7 and paragraph 5.42 require development to provide a reduction of 20% in
predicted CO2 emissions through the use of on-site renewable energy generation.
Transport
5.42
Policy 6.3 states that development proposals should ensure that impacts on transport
capacity and the transport network, at both a corridor and local level, are fully
assessed. Development should not adversely affect safety on the transport network.
5.43
Policy 6.9 requires that developments provide secure, integrated, convenient and
accessible cycle parking facilities in line with the minimum standards set out in Table
6.3 and the guidance set out in the London Cycle Design Standards (or subsequent
revisions).
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Planning Statement
Table 3 - London Plan (2015) Cycle Standards
Land Use Class
5.44
London Plan (2015)
Long stay
Short-stay
Residential Dwellings (C3)
1 space / studio / 1 bed
2 spaces per 2+bed
1 space per 40 units
(visitor)
Health Club and Sports
Centres (D2)
1 space per 8 staff
1 space per 100 sqm
Policy 6.13 sets out the maximum parking standards for new developments. In
addition, developments must:
a)
ensure that 1 in 5 spaces (both active and passive) provide an electrical
charging point to encourage the uptake of electric vehicles
b)
provide parking for disabled people in line with Table 6.2
c)
meet the minimum cycle parking standards set out in Table 6.3
d)
provide for the needs of businesses for delivery and servicing.
Table 4 - London Plan (2015) Parking Standards
Land Use Class
London Plan (2015)
Residential Dwellings (C3)
Less than 1 space per 1 – 2 bed unit
Up to 1.5 spaces per 3 bed unit
Up to 2 spaces per 4 bed unit
Health Club and Sports
Centres (D2)
Provide appropriate levels of coach parking to suit
individual demand to help reduce congestion and
visitor safety
Green Belt
5.45
Policy 7.16 requires that the strongest protection is given to London’s Green Belt, in
accordance with national guidance. Inappropriate development should be refused,
except in very special circumstances. Development will be supported if it is
appropriate and helps secure the objectives of improving the Green Belt as set out in
national guidance.
Metropolitan Open Land (MOL)
5.46
Policy 7.17 states that the strongest protection should be given to London’s
Metropolitan Open Land and inappropriate development refused, except in very
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Planning Statement
special circumstances, giving the same level of protection as in the Green Belt.
Essential ancillary facilities for appropriate uses will only be acceptable where they
maintain the openness of MOL.
Open Space
5.47
Policy 7.18 states that the loss of protected open spaces must be resisted unless
equivalent or better quality provision is made within the local catchment area.
Replacement of one type of open space with another is unacceptable unless an up
to date needs assessment shows that this would be appropriate.
Design
5.48
Under Policy 7.1 development should be designed so that the layout, tenure and mix
of uses interface with surrounding land and improve people’s access to social and
community infrastructure (including green spaces), the Blue Ribbon Network, local
shops, employment and training opportunities, commercial services and public
transport. The design of new buildings and the spaces they create should help
reinforce or enhance the character, legibility, permeability, and accessibility of the
neighbourhood.
5.49
Furthermore, Policy 7.4 emphasises that buildings, streets and open spaces should
provide a high quality design response that:
a)
has regard to the pattern and grain of the existing spaces and streets in
orientation, scale, proportion and mass
b)
contributes to a positive relationship between the urban structure and natural
landscape features, including the underlying landform and topography of an
area
c)
is human in scale, ensuring buildings create a positive relationship with street
level activity and people feel comfortable with their surroundings
d)
allows existing buildings and structures that make a positive contribution to
the character of a place to influence the future character of the area
e)
5.50
is informed by the surrounding historic environment.
In addition, Policy 7.6 notes that buildings and structures should:
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Planning Statement
a)
be of the highest architectural quality
b)
be of a proportion, composition, scale and orientation that enhances,
activates and appropriately defines the public realm
c)
comprise details and materials that complement, not necessarily replicate,
the local architectural character
d)
not cause unacceptable harm to the amenity of surrounding land and
buildings, particularly residential buildings, in relation to privacy,
overshadowing, wind and microclimate. This is particularly important for tall
buildings
e)
incorporate best practice in resource management and climate change
mitigation and adaptation
f)
provide high quality indoor and outdoor spaces and integrate well with the
surrounding streets and open spaces
g)
be adaptable to different activities and land uses, particularly at ground level
h)
meet the principles of inclusive design
i)
optimise the potential of sites
Local Plan Policy
Site Specific Policy Designations
5.51
The Adopted Policies Map (2014) (extract below) shows the site to have the following
policy designations:
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Planning Statement
Figure 3 - Southwark Proposals Map (2014)

The Dulwich Hamlet Football Club Pitch is designated as Other Open Space;

Green Dale Fields is designated as Metropolitan Open Land (MOL);

Suburban Density Zone Middle;

Air Quality Management Area (AQMA);

Flood Risk Zone 1;

A Public Transport Accessibility Level (PTAL) that ranges from 2 on the western site
to 4 on the eastern portion (where 1 is low and 6 is high).
Core Strategy (2011)
Strategic Objectives
5.52
Strategic Objective 1C (Be healthy and active) states that Southwark’s community
will be healthy and active. By delivering sustainable growth people will have access
to good health, education, sports, leisure and community facilities. Access to open
spaces and nature, opportunities for active travel and access to fresh, healthy food
will encourage healthy lifestyles. Good quality affordable and family homes will help
improve living conditions. The negative impacts of development on health will be
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Planning Statement
addressed and developments will be well designed and able to cope with climate
change.
5.53
Strategic Objective 2C (Provide more and better homes) states that the whole of the
borough will offer more housing of a range of different types to meet the needs of
the community. All the housing will be built to a high quality of design. There will be a
choice of housing types including more family housing, housing for students and
more affordable housing.
5.54
Strategic Policy 4 (Places for learning, enjoyment and healthy lifestyles) states that
there will be a wide range of well used community facilities that provide spaces for
many different communities and activities in accessible areas. Development will help
create safe, healthy and mixed communities. This will in part be achieved by
Facilitating a network of community facilities that meet the needs of local
communities and supporting the retention and improvement of facilities which
encourage physical activity and ensuring that development promotes healthy
lifestyles and addresses negative impacts on physical and mental health.
5.55
Strategic Policy 5 (Providing New Homes) sets out that development will meet the
housing needs of people who want to live in Southwark and London by providing
high quality new homes in attractive environments. A residential density of 200-350
hr/ha will be expected for sites within the suburban density zone.
5.56
Strategic Policy 6 (Homes for People on Different Incomes) requires that development
will provide homes including social rented, intermediate and private for people on a
wide range of incomes. Development should provide as much affordable housing as
is reasonably possible whilst also meeting the needs for other types of development
and encouraging mixed communities. A provision of 35% affordable housing will be
required on schemes of over 10 units, subject to viability.
5.57
Strategic Policy 7 (Family Homes) requires developments of 10 or more dwellings will
have at least 60% 2 + bedroom units and in the suburban density zone, a minimum of
30% 3, 4 or 5 bedroom dwellings. There will also be a maximum of 5% as studios and
only for private sale. All developments will be expected to meet the Council’s
minimum overall floor sizes.
5.58
Strategic Policy 11 (Open Spaces and Wildlife) will improve, protect and maintain a
network of open spaces and green corridors that will make places attractive and
provide sport, leisure and food growing opportunities for a growing population. Large
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Planning Statement
spaces of importance to all of London will be protected (Metropolitan Open Land) as
well as smaller spaces of more borough-wide and local importance (Borough Open
Land and Other Open Spaces). New development will be required to help meet the
needs of a growing population by providing space for children’s play, gardens and
other green areas and helping to improve the quality of and access to open spaces
and trees, particularly in areas deficient in open space.
5.59
Strategic Policy 13 (High Environmental Standards) requires development to meet the
highest possible environmental standards, including targets based on Code for
Sustainable Homes and BREEAM. Furthermore all new development to be designed
and built to minimise greenhouse gas emissions across its lifetime. This will be
achieved by applying the energy hierarchy;

Designing all developments so that they require as little energy as possible to
build and use.

Expecting all major developments to set up and/or connect to local energy
generation networks where possible. We will develop local energy networks
across Southwark.

5.60
Requiring developments to use low and zero carbon sources of energy.
Applicants are required to demonstrate how they will avoid waste and minimise
landfill from construction and use of a development. Developments are required to
minimise water use and use local sources of water where possible. Developments are
required to help reduce flood risk by reducing water run-off, using sustainable urban
drainage systems and avoiding the paving over of gardens and creation of hard
standing areas.
5.61
In relation to BREEAM, the Council has set a target for;

Residential development should achieve at least Code for Sustainable Homes
Level 4.

Community facilities, including schools, should achieve at least BREEAM “very
good”.

Major development should achieve a 44% saving in carbon dioxide emissions
above the building regulations from energy efficiency, efficient energy supply
and renewable energy generation

Major development must achieve a reduction in carbon dioxide of 20% from
using on-site or local low and zero carbon sources of energy.

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Major development must reduce surface water run-off by more than 50%
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
Planning Statement
Major housing developments must achieve a potable water use target of 105
litres per person per day.
Southwark Plan Saved Policies (2007)
5.62
Policy 2.1 (Enhancement of community facilities) states that planning permission for a
change of use from D class community facilities will not be granted unless:
i.
The applicant demonstrates to the satisfaction of the LPA that the community
facility is surplus to requirements of the local community and that the
replacement development meets an identified need; or
ii.
The applicant demonstrates that another locally accessible facility with similar
or enhanced provision can meet the identified needs of the local community
facility users.
5.63
Policy 2.2 (Provision of Community Facilities) states that planning permission will be
granted for new community facilities provided:
i.
Provision is made to enable the facility to be used by all members of the
community; and
ii.
The facility is not detrimental to the amenity of present and future occupiers
of the surrounding area in compliance with Policies 3.2 and 5.2; and
iii.
Where developments will generate more than 20 vehicle trips at any one time
a Transport Assessment will be required in compliance with Policies 3.3 and
5.2.
5.64
Policy 3.2 (Protection of amenity) states that planning permission for development will
not be granted where it would cause loss of amenity, including disturbance from
noise, to present and future occupiers in the surrounding area or on the application
site.
5.65
Policy 3.3 (Sustainability assessment) indicates that planning permission will not be
granted for major development unless the applicant demonstrates that the
economic, environmental and social impacts of the proposal have been addressed
through a sustainability assessment. The level of detail required in the sustainability
assessment should correspond to the scale and complexity of the development.
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5.66
Planning Statement
Policy 3.4 (Energy Efficiency) states that all developments must be designed to
maximise energy efficiency and to minimise and reduce energy consumption and
carbon dioxide (CO2) emissions. Major developments will be required to provide an
assessment of the energy demand of the proposed development (such as those
contained within the BREEAM and EcoHomes Schemes). These should also
demonstrate how the Mayor’s energy hierarchy will be applied.
5.67
The site falls within an Air Quality Management Area (AQMA). Policy 3.6 (Air quality)
indicates that planning permission will not be granted for development that would
lead to a reduction in air quality.
5.68
Furthermore, Policy 3.7 (Waste reduction) requires all developments to ensure
adequate provision of recycling, composting and residual waste disposal, collection
and storage facilities. The design of waste and recycling facilities must be easily and
safely accessible, improving local amenity
5.69
Policy 3.9 (Water) encourages all developments to incorporate measures, to:
i.
Reduce the demand for water; and
ii.
Recycle grey water and rainwater.
5.70
In addition, all new developments must use preventative measures to ensure that
they do not lead to a reduction in water quality. New developments should not result
in an increase in surface run-off, which could result in increased flood risk and
pollution. Problems arising from surface run-off can be significantly reduced in the first
instance through the careful design of developments. The LPA will require Major
Developments to incorporate sustainable methods of drainage, unless it can be
demonstrated that this is not practical.
5.71
Policy 3.11 (Efficient Use of Land) states that all developments should maximise the
efficient use of land whilst:
i.
protecting the amenity of neighbouring occupiers;
ii.
ensuring a satisfactory standard of accommodation and amenity for future
occupiers of the site;
iii.
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positively responding to the local context;
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iv.
Planning Statement
ensuring the proposal does not compromise the development potential of
neighbouring sites;
v.
makes adequate provision for servicing, circulation and access to and from
the site; and
vi.
ensures the scale of development is appropriate to the availability of public
transport and other facilities and infrastructure.
5.72
Policy 3.12 (Design) states that developments should achieve a high quality of both
architectural and urban design, enhancing the quality of the built environment in
order to create attractive, high amenity environments people will choose to live in,
work in and visit. New buildings and alterations to existing buildings should embody a
creative and high quality appropriate design solution, specific to their site’s shape,
size, location and development opportunities and where applicable, preserving or
enhancing the historic environment.
5.73
Policy 3.13 Urban Design states that in designing new developments, consideration
must be given to:
i.
Height, scale and massing of buildings – Designing a building that is
appropriate to the local context and which does not dominate its
surroundings inappropriately;
ii.
Urban structure, space and movement – Proposals should have regard to the
existing urban grain, development patterns and density in the layout of
development sites;
iii.
Townscape, local context and character – Proposals should be designed with
regard to their local context, making a positive contribution to the character
of the area and provide active frontages;
iv.
Site layout – Building location, public spaces, microclimate, and outlook, site
access and servicing, permeability, safety and ease of movement including
vehicular, pedestrians and cyclists;
v.
Streetscape – A high quality of design and materials will be required for the
street environment including street furniture, planting and public art. This
should be coordinated wherever possible, to avoid unnecessary clutter, and
ensure a safe, informative and attractive environment;
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vi.
Planning Statement
Landscaping – Where appropriate, developments should include landscape
design that enhances the area and biodiversity, for example through the use
of green roofs; and
vii.
Inclusive Design – All developments must incorporate suitable access for
people with disabilities or those who are mobility impaired.
5.74
Policy 3.24 (Telecommunications Development) states that in respect of
telecommunications equipment requiring full planning permission the LPA will not
permit proposals which:
i.
Have an unacceptable appearance by virtue of its siting or design; or
ii.
Have any adverse impact on listed buildings or Conservation Areas,
regardless of whether or not the equipment is within a Conservation Area or
the curtilage of a listed building; or
iii.
Where the applicant has not demonstrated a network need for the proposal;
or
iv.
Where the applicant has not demonstrated an absence of alternatives,
including, but not only the possibility of sharing of existing masts and sites; or
v.
Where the applicant has not provided self certification to the effect that a
mobile phone base station when operational will meet the ICNIRP guidelines;
or
vi.
Where the applicant has not provided a statement for each site indicating its
location, the height of the antenna, the frequency and modulation
characteristics and details of power output and where a mobile phone base
station is added to an external mast or site, confirmation that the cumulative
exposure will not exceed the ICNIRP guidelines. All telecommunications
equipment should be sited as far as practicably possible away from
educational and community uses.
5.75
Policy 3.25 (Metropolitan Open Land (MOL)) outlines a general presumption against
inappropriate development on MOL. Planning permission for development on MOL
will only be permitted for appropriate development which is considered to be for the
following purposes:
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Planning Statement
i.
Agriculture or forestry; or
ii.
Essential facilities for outdoor sports and outdoor recreation which preserves
the openness of the MOL and do not conflict with the purposes of including
land within the MOL; or
iii.
Extension of or alteration to an existing dwelling, providing that it does not
result in disproportionate additions over and above the size of the original
building; or
iv.
Replacement of an existing dwelling, providing that the new dwelling is not
materially larger than the dwelling it replaces.
5.76
Policy 3.27 (Other Open Space (OOS)) states that development on Other Open
Space will only be permitted if it meets the following criteria:
a)
It is ancillary to the enjoyment of open space; and
b)
It is small in scale; and
c)
It does not detract from the prevailing openness of the site or from its
character; and
d)
It positively contributes to the setting and quality of the open space; and
e)
Where appropriate it enhances public access to open space; or
f)
Land of equivalent or better size and quality is secured within the local
catchment area for similar or enhanced use before development
commences, provided that this would not result in the creation of or an
increase in district or local park deficiency.
5.77
Policy 3.28 (Biodiversity) acknowledges that the LPA will take biodiversity into
account in its determination of all planning applications and will encourage the
inclusion in developments of features which enhance biodiversity, requiring an
ecological assessment where relevant.
5.78
Policy 4.2 (Quality of Residential Accommodation) states that planning permission will
be granted for residential development, including dwellings within mixed use
schemes, provided that they:
i.
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Achieve good quality living conditions; and
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ii.
Planning Statement
Include high standards of:

Accessibility, including seeking to ensure that all new housing is built to Lifetime
Homes standards;
5.79

Privacy and outlook;

Natural daylight and sunlight

Ventilation;

Space including suitable outdoor/green space;

Safety and security; and

Protection from pollution, including noise and light pollution
Policy 4.3 (Mix of Dwellings) states that all major residential new-build development
and conversions should provide a mix of dwelling sizes and types to cater for the
range of housing needs of the area. This will include the following:
i.
The majority of units should have two or more bedrooms, and developments
of 15 or more dwellings will be expected to provide at least 10% of the units
with three or more bedrooms with direct access to private outdoor space;
and
ii.
The number of studio flats must not exceed 5% of the total number of dwelling
units within a development. Studio flats are not suitable for meeting
affordable housing need; and
iii.
At least 10% of all major new residential developments should be suitable for
wheelchair users, except where this is not possible due to the physical
constraints of the site. Permission will not be granted for the conversion of a
single dwelling house of 130 square metres or less original net internal
floorspace into 2 or more dwelling units
5.80
Policy 4.4 (Affordable Housing) requires that within the Urban and Suburban Density
Zones at least 35% of all new housing as affordable housing, for all developments
capable of providing 15 or more additional dwelling units or on sites larger than 0.5
hectare, except in accordance with Policy 4.5.
5.81
Policy 4.5 (Wheelchair Affordable Housing) states that for every affordable housing
unit which complies with the wheelchair design standards, one less affordable
habitable room will be required than otherwise stated in Policy 4.4.
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5.82
Planning Statement
Policy 5.1 (Locating Developments) requires that the location of development
throughout the borough must be appropriate to the size and trip generating
characteristics of the development. Major Developments generating a significant
number of trips should be located near transport nodes. Where new Major
Developments are not located within easy access of public transport nodes,
applicants must demonstrate that sustainable transport options are available to site
users. Where these are not available, applicants must propose measures to promote
sustainable travel.
Policy 5.2 (Transport impacts) notes that planning permission will be granted for
5.83
development unless:
i.
There is an adverse impact on transport networks for example through
significant increases in traffic or pollution; and/or
ii.
Adequate provision has not been made for servicing, circulation and access
to, from and through the site; and/or iii. Consideration has not been given to
impacts of development on the bus priority network and the Transport for
London road network.
5.84
Policy 5.3 (Walking and cycling) notes that planning permission will be granted for
development provided:
i.
There is adequate provision for pedestrians and cyclists within the
development, and where practicable within the surrounding area; and/or
ii.
There is good design, location and access arrangements, including restrictions
on parking, and the promotion of walking and cycling, with particular
emphasis on disabled people and the mobility impaired; and/or
iii.
The development creates or contributes towards more direct, safe and
secure walking and cycling routes, integrating with surrounding networks
where possible, furthering the delivery of the London Cycle Network Plus and
strategic walking routes (including the Jubilee Walkway and the Thames
Path); and
iv.
There is provision of convenient, secure and weatherproof cycle parking to
the minimum cycle parking standards set out in Tables 15.3 and 15.4 in
Appendix 15.
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5.85
Planning Statement
Policy 5.6 (Car parking) requires that all new developments should minimise the
number of parking spaces provided. Maximum car parking standards and minimum
cycle parking standards are set out in Appendix 15 of the Saved Local Plan.
Table 5 - Southwark Plan (2007) Parking Standards
Land Use Class
The Southwark Plan (July 2007)
Residential Dwellings (C3)
1 maximum space per unit
Health Club and Sports Centres
(D2)
1 space one 4 players plus one space per 5
spectators
Supplementary Planning Documents and Guidance
5.86
Supplementary planning documents and guidance (SPDs and SPGs) are used to
provide more information and guidance on the policies in the development plan.
Southwark has several adopted SPDs that of particular relevance to this planning
application, detailed below.
Residential design standards SPD
5.87
The Residential Design Standards Supplementary Planning Document (SPD) was
adopted by Cabinet on 18 October 2011. It replaced the 2008 Residential Design
Standards SPD.
5.88
Following the introduction of national technical housing standards for new dwellings
through a Written Ministerial Statement (WMS) on 25 March 2015, technical housing
standards in the Residential Design Standards SPD (2011) have been updated in the
2015 Technical Update to the Residential Design Standards SPD (2011). The key
changes are detailed below.
5.89
Code for Sustainable Homes: The Council’s Core Strategy Policy SP13 sets out the
Council’s policy on sustainable design and low carbon development based on the
CfSH. However, the Code was withdrawn by the WMS and replaced by the technical
housing standards, except for the management of legacy cases.
5.90
Water Efficiency: Approved Document G (Sanitation, Hot Water Safety and Water
Efficiency) has been updated to include an optional standard for water efficiency.
Where there is no policy requirement, and where not secured by condition, new
dwellings must achieve a water efficiency of 125 litres per person per day (Approved
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Planning Statement
Document G of the Building Regulations 36(2a)). The London Plan (2015) requires
residential development to meet a target of 105 litres or less per head per day
(excluding an allowance of 5 litres or less per head per day for external water
consumption) 36(2b). It is the council’s policy that all residential development
permitted from 1 October 2015 should secure water efficiency under 36(2b) by
planning condition.
5.91
Internal space standards: The Council’s adopted planning policies on internal space
standards (based on the London Plan), are set out in the Residential Design
Standards SPD (2011). These have been replaced by the standards in the Nationally
Described Space Standard (NDSS) within the Technical Housing Standards (below).
Table 6 - Southwark Minimum Internal Space Standards
5.92
The SPD also sets out minimum standards for room sizes in table 2.
5.93
Wheelchair User Homes: The council will require all wheelchair user dwellings to meet
the saved SELHPWHDG space standards and encourage all wheelchair user
dwellings to meet the saved South East London Housing Partnership Wheelchair
Housing Design Guide (SELHPWHDG) standards relating to access, use and fit out of
the dwelling (as detailed in the Technical Update to the Residential Design Standards
SPD and appended here).
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5.94
Planning Statement
Accessible Homes: Approved Document M introduces the category Accessible and
Adaptable Dwellings (M4(2)), which is the closest equivalent standard in the Building
Regulations to the Lifetime Homes Standard. It is the council’s policy to require all
non-wheelchair user dwellings to meet M4(2) standard where practical and viable.
Where this is not the case, the council will encourage all other homes to meet the
M4(2) standard in all respects other than providing step free access.
5.95
For the development to be considered as being of an exemplary standard of design
the SPD requires that applicants demonstrate that their proposed schemes exceed
the residential design standards as set out in the SPD. Specifically they will be
expected to:

Significantly exceed minimum floorspace standards

Provide for bulk storage

Include a predominance of dual aspect units in the development

Exceed the minimum ceiling height of 2.3 metres required by the Building
Regulations

Have natural light and ventilation in kitchens and bathrooms

Exceed amenity space standards set out in this SPD

Meet good sunlight and daylight standards

Have excellent accessibility within dwellings including meeting Approved
Document M of the Building Regulations M4(2) standard for all non wheelchairuser homes

Minimise corridor lengths by having an increased number of cores

Minimise noise nuisance in flatted developments by stacking floors so that
bedrooms are above bedrooms, lounges are above lounges etc.

Obtain Secured by Design certification

Have exceptional environmental performance that exceeds the standards set
out in the Sustainable Design and Construction Supplementary Planning
Document

Maximise the potential of the site as demonstrated in the applicant’s Design and
Access Statement. See the Design and Access Statements Supplementary
Planning Document for further guidance

Make a positive contribution to local context, character and communities,
including contributing to the streetscape
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Planning Statement
Sustainable Transport 2010
5.96
The objectives of the Sustainable Transport (2010) SPD is to provide;
1.
Guidance so all development is easily accessible and encourages people to
walk, cycle and use public transport.
2.
Guidance for new development so that it reduces congestion and pollution
within Southwark.
3.
Clear guidance about possible reasons for approval and refusal of planning
applications for development.
5.97
This document provides more detail to the Southwark Plan policies relating to
transport.
Other SPDs
5.98
The Council also has Supplementary Planning Documents guiding developers on the
production of Sustainability Assessments and Design and Access Statements to
accompany planning applications.
Sustainable Design and Construction SPD 2009
5.99
This document provides guidance on how new development in Southwark should be
designed and built so that it has a positive impact on the environment. It covers the
following topics

Energy use and minimising climate change

Adapting to climate change that is unavoidable

Avoiding pollution and environmental nuisance

Avoiding waste and minimising landfill

Protecting and enhancing biodiversity

Conserving water

Planning for flood risk.
This document outlines general design principles that new development should follow
and also sets minimum and preferred standards for each of the topics above.
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Planning Statement
Affordable Housing 2008
5.100
The purpose of this supplementary planning document (SPD) is to make sure existing
policies in the development plan achieve their objectives, and set out the issues that
the council will consider in making decisions on planning applications. The SPD
provides further guidance on Southwark Plan policies 4.3. (Mix of dwellings), 4.4
(Affordable Housing) and 4.5 (Wheelchair affordable housing).
5.101
A draft 2011 affordable housing SPD has been prepared by the Council, with
consultation closing on 30 September 2011. Following recent changes in national
planning policy, the Council will prepare further modifications for consultation prior to
adoption of a new SPD.
Section 106 Planning Obligations/CIL SPD 2015
5.102
This supplementary planning document (SPD) provides detailed guidance on the use
of section 106 planning obligations alongside the community infrastructure levy. It
replaces Southwark Council’s adopted Section 106 Planning Obligations SPD (2007).
Development Viability SPD (2016)
5.103
The Council adopted a Development Viability SPD at Cabinet on Tuesday 15 March
2016. The SPD sets out the Council’s proposed approach to viability assessments
submitted by applicants to support planning applications. The SPD focuses
specifically on development proposals which do not provide a policy compliant level
of affordable housing. The SPD proposes detailed implementation guidance on
currently adopted local planning policies related to affordable housing in the Core
Strategy (2011) and saved policies of the Southwark Plan (2007), as well as the
London Plan (2015) and the emerging policies of the New Southwark Plan.
5.104
We understand that an executive summary has to be placed on the public register
and have provided this with this planning application.
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Planning Statement
6.
Planning Assessment
6.1
This section of the Planning Statement assesses the development proposals against
the national, regional and local planning policy framework set out in Chapter 5,
together with other relevant material planning considerations.
6.2
The key considerations in assessing the proposed development are as follows:

The impact of the development on the Metropolitan Open Land and Open
Space;

Quantitative loss of sports facilities;

The provision of enhanced community facilities; and

The principle of residential development.
Other considerations addressed in this assessment are:

Residential mix;

Residential quality;

Provision of Wheelchair Units;

Affordable Housing;

Residential Density;

Noise;

Daylight, Sunlight and Overshadowing;

Transport and Access;

Service and Refuse Access;

Vehicle / Cycle Parking;

Air Quality;

Archaeology;

Ground Conditions;

Ecology / Biodiversity;

Arboricultural Assessment;

Flood Risk;

Energy and Sustainability;

Waste management;

Landscaping and Public Realm;

Lighting;
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
Design; and

Planning obligations.
Planning Statement
Impact on Metropolitan Open Land (MOL) and Open Space.
6.3
As set out in section 5 above, Policy 7.17 of the London Plan provides MOL with the
same level of protection as the green belt, which national policy protects from
development through a strong policy presumption against inappropriate
development.
6.4
Paragraph 89 of the NPPF identifies the exceptions to inappropriate development in
the green belt to include:

provision of appropriate facilities for outdoor sport, outdoor recreation and for
cemeteries, as long as it preserves the openness of the Green Belt and does not
conflict with the purposes of including land within it;

limited infilling or the partial or complete redevelopment of previously developed
sites (brownfield land), whether redundant or in continuing use (excluding temporary
buildings), which would not have a greater impact on the openness of the Green Belt
and the purpose of including land within it than the existing development.
6.5
The NPPF defines previously developed land as land which is or was occupied by a
permanent structure, including the curtilage of the developed land and any
associated fixed surface infrastructure (excluding garden land).
6.6
Where development in the green belt is considered inappropriate, paragraph 87 of
the NPPF states that it should not be approved except in very special circumstances.
The term ‘very special circumstances’ is not defined, but paragraph 88 clarifies that
such circumstances will not exist unless the potential harm to the green belt by
reason of inappropriateness, and any other harm, is clearly outweighed by other
considerations.
6.7
Mitigation by ‘very special circumstances’ is reiterated by Policies 7.16 (Green Belt)
and 7.17 (MOL) of the London Plan.
6.8
With regards to open space, Paragraph 74 of the NPPF states that existing open
space, sports and recreational buildings and land, including playing fields, should not
be built on unless:
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Planning Statement
a) An assessment has been undertaken which has clearly shown the open
space, buildings or land to be surplus to requirements; or
b) The loss resulting from the proposed development would be replaced by
equivalent or better provision in terms of quantity and quality in a suitable
location; or
c) The development is for alternative sports and recreational provision, the
needs for which clearly outweigh the loss.
6.9
Policy 7.18 of the London Plan states that the loss of protected open spaces must be
resisted unless equivalent or better quality provision is made within the local
catchment area.
6.10
Southwark Core Strategy Policy 11 states that the Council will improve, protect and
maintain a network of open spaces and green corridors that will make places
attractive and provide sport, leisure and food growing opportunities for a growing
population.
6.11
Saved Southwark Plan Policy 3.27 states that development on Other Open Space will
only be permitted if it meets the following criteria:
g)
It is ancillary to the enjoyment of open space; and
h)
It is small in scale; and
i)
It does not detract from the prevailing openness of the site or from its
character; and
j)
It positively contributes to the setting and quality of the open space; and
k)
Where appropriate it enhances public access to open space; or
l)
Land of equivalent or better size and quality is secured within the local
catchment area for similar or enhanced use before development
commences, provided that this would not result in the creation of or an
increase in district or local park deficiency.
6.12
The application site includes two areas of designated MOL; Green Dale Playing Fields
and Green Dale Artificial Pitch. Both have been categorised by Southwark’s Open
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Planning Statement
Space Strategy 2013 as being ‘below average value and quality’ and are specifically
identified as being in need of improvement.
6.13
Green Dale Artificial Pitch is poor quality and underused area of astroturf to the south
east of the MOL. The pitch is in a state of disrepair and in need of replacement. Six
floodlights are located around the perimeter of the pitch, whilst an area of
hardstanding runs along one corner. The pitch is clearly distinguishable from the
remainder of the MOL, forming an area of previously developed land.
6.14
Green Dale Playing Fields comprises the remainder of the MOL and includes a
number of previously developed features. Two disused and overgrown tennis courts
are located to the north of the pitch, with the remainder of the site comprising
overgrown and under maintained green space, together with a number of small built
structures. The whole site is bound by perimeter fencing which has fallen down in
places allowing unrestricted access onto the site. As a result, Green Dale has
become the subject of some antisocial behaviour and inappropriate use, although
equally it is clear that it provides local amenity with ecological benefits.
6.15
The current DHFC pitch, which is designated as Other Open Space in the Southwark
Plan (2007), is available only to the Football Club and used for a maximum of twice a
week during the football season. The pitch is therefore in effect privatised, vastly
underutilised and of limited value to the local community. This lack of community
benefit is reflected in the Southwark Open Space Strategy (2013) which categorises
the pitch as being of ‘below average value’.
6.16
In addition, the current pitch is grassed, making it prone to becoming waterlogged or
frozen. This limits its use whilst also generating high maintenance costs for the Club.
The current pitch also lacks ecological value in terms of biodiversity.
6.17
Further, in its current form the DHFC stadium serves as a financial drain on the Club,
which is unable to support level of ancillary facilities currently provided on site. In
particular, the gym, squash courts and entertainment space have been consistent
loss makers that have resulted in a wholly financially insecure future for DHFC. The
existing Club is in severe financial need and requires a radical restructuring in order to
ensure long term financial stability. Without a long term future for the Club, the
current open space, in the form of the DHFC pitch, would become completely
redundant.
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6.18
Planning Statement
Development proposals include the relocation and redevelopment of the DHFC
stadium to the west of existing facilities. The new stadium will provide a 3G allweather artificial playing pitch on the site of the Green Dale Artificial Pitch,
designated as MOL. The main built structures, in the form of the stadium and club
house will be built outside of the MOL on the site of the existing DHFC stadium. The
new stadium facilities will comply with FA requirements to enable progression to the
National League (also known as the Conference).
6.19
155 residential units will be built on the site of the existing DHFC stadium, including the
current pitch which is designated as Other Open Space. The new residential
development will incorporate a linear park, which will connect the existing open
spaces of St. Francis Park and Green Dale Park Fields. A MUGA is also proposed on
part of the existing pitch, providing a 3G surface suitable for a range of ball sports,
including netball, basketball, tennis and volley ball, in addition to 5-a-side football.
6.20
Finally, in terms of open space provision, the proposals incorporate improvements to
Green Dale Playing Fields, including landscaping and biodiversity enhancements,
together with the introduction of play equipment.
6.21
Proposals therefore involve development on MOL and the overall quantitative loss of
open space. There will however be an overall qualitative improvement across the
site.
6.22
The new stadium will provide high quality, modern facilities with improved community
access. The new pitch will be a 3G artificial surface, which mitigates the on-going
maintenance problems associated with the current grassed pitch and enables use
for up to 60 hours a week all year round. This will lower the Club’s on-going
maintenance costs, whilst also facilitating maximum community use. This will in turn
generate an income for the facility providers through increased community hire and
contribute towards a sustainable future for DHFC, and use for the whole community.
6.23
In addition to improved facilities, the proposed DHFC stadium will help secure DHFC’s
vitality and longevity through the provision of more appropriate facilities as well as
enabling the potential for promotion through the provision of FA compliant facilities.
The Club is the one of the oldest league clubs and is a key heritage feature of the
Dulwich area. Ensuring that the Club remains in existence, and moreover maintains its
historical home at Champion Hill, is important for the Dulwich community and local
identity.
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6.24
Planning Statement
The importance of DHFC to the wider community is illustrated by the application
made in 2013 by the Dulwich Hamlet Supporters Trust to list the Club as an Asset of
Community Value under the Localism Act 2011. Whilst the application was
unsuccessful (due to insolvency issues at the time) the attempt to list the Club as a
community asset epitomises the importance of DHFC to the wider community. The
proposed redevelopment of the Club’s facilities will help sustain a long term future for
this valuable community asset.
6.25
In terms of design, the proposal has such an orientation that the main built
infrastructure, in the main stand and clubhouse, are built outside of MOL on the site of
the existing stadium. The sensitive positioning of the proposed stadium in the lower
lying segment of the site will ensure that the development is as unobtrusive on the
landscape as is possible, whilst also safeguarding key views across the site.
6.26
In addition, the proposal includes fewer floodlights than the existing provision, which
are also lower, resulting in a less intrusive impact on the MOL.
6.27
Enhanced community access and use of open space will also be provided via the
proposed MUGA. Whilst the use of the current DHFC stadium and Green Dale
Artificial Pitch are solely restricted to football, the MUGA facility will be available for a
whole range of ball sports, including netball, basketball, tennis and volleyball. The
MUGA will therefore provide a more versatile area of open space, to be used by a
wider range of the public.
6.28
Whilst there would be a net reduction in ‘green’ area through the redevelopment of
the pitch from 37,100sqm currently across the site (including Green Dale Playing
Fields) to 28,980sqm, enhanced open space will be provided in the form of a new,
publically accessible linear park. Whilst the current pitch provides low value open
space in terms of accessibility, the linear park will provide 24 hour access and be
genuinely accessible to the local community. In addition, the linear park will connect
the existing open spaces of St. Francis Park and Green Dale Playing Fields. The park
will therefore not only provide superior quality open space in itself, but serve to
improve the areas that it links by enhancing their ‘openness’ and subsequent value.
6.29
The linear park will also bring environmental and ecological benefits to the
development and local community. Whilst the existing football pitch offers little in the
way of biodiversity, the new linear park will comprise of a variety of ecological
features to encourage habitation and biodiversity. The park will comprise a series of
woodland glades, each with their own character, to include a variety of planting
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Planning Statement
typologies and habitat opportunities. The planting frameworks for each glade will
include specimen trees, perennial mixes, woodland understories and species-rich
meadows and lawns, providing year-round seasonal interest and habitat creation.
6.30
Further, enhanced open space is provided via the proposed improvements to Green
Dale Playing Fields. It has long been recognised that the playing fields are in need of
improvements and there is a strong local aspiration to make the playing fields an
accessible asset for the local community. In addition to improved quality, Green Dale
Playing Fields will be provided with enhanced accessibility via the creation of the
linear park. This will serve to significantly improve the ‘openness’ and accessibility of
the area, in turn increasing the value of the open space.
6.31
Lastly, whilst there will be a need to provide a perimeter boundary around the new
pitch, this will be kept no higher than necessary to prevent casual spectators. It will
further be treated to reduce the impact with green screening. This is set out in the
Design and Access Statement. Taken together with the improvements in the
reduction of floodlights we believe that the impact of this boundary is both necessary
and not so significant as to be harmful to the appearance of the openness of Green
Dale as a whole.
6.32
In terms of policy compliance therefore, it is clear that the proposal to relocate the
DHFC pitch onto the site of Green Dale Artificial Pitch comprises appropriate
development within MOL, being the provision of appropriate facilities for outdoor
sport and outdoor recreation, and the redevelopment of previously developed land.
In addition, the stadium has been designed such that it not only preserves the
openness of the MOL, but enhances it via the provision of fewer and lower
floodlighting and a net gain to MOL through the pitch realignment.
6.33
If, however, the proposals were to be considered ‘inappropriate development’, there
are ‘very special circumstances’ that relate to the Club’s community value, which
outweigh any potential harm that might be considered to be caused to the MOL.
6.34
As previously explained, the current Club facilities create a financial drain that
threatens DHFC’s long term future. Champion Hill is the historical home of DHFC, and
the Club is an important feature of the local character and history of the area. This
importance is emphasised by the attempt in 2011 to list DHFC as an ‘asset of
community value’. The potential loss of the Club should be taken as a material
consideration in a planning application, amounting to ‘very special circumstances’.
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6.35
Planning Statement
Further, in its current form the Club provides limited community benefit, whilst the
proposals seek to maximise community use and provide a genuinely accessible open
space available for hire by local schools and community groups. This provision of
new, enhanced open space provision should be considered as ‘very special
circumstances’.
6.36
The circumstances surrounding the relocation and redevelopment of DHFC are
consistent with the previous decision made by the Council (application 13/AP/1732
Granted 21/02/14) as detailed in paragraph 3.20 to 3.24 of this statement, where the
Council concluded that strong local need and financial difficulties constituted ‘very
special circumstances’. This is clearly the case with DHFC and this application should
therefore be considered in the same light.
6.37
With regards to open space, whilst the proposed development will result in the overall
quantitative loss of open space this will be mitigated via the provision of enhanced
open space either on the same site as, or adjacent to, the current provision. This
enhanced provision is in the form of the new DHFC pitch, MUGA, linear park, and
Green Dale Playing Fields improvements, which provide greater access, community
benefit and biodiversity features as previously described.
6.38
The proposals are therefore policy compliant in terms of London Plan policy 7.18,
which requires equivalent or better quality provision within the local catchment area.
The NPPF however requires better provision in terms of both quantity and quality. The
enhanced quality of open space however is not possible without a quantitative loss,
given that the residential development, to be positioned on the current DHFC pitch,
will enable the redevelopment of the DHFC stadium, together with the provision of
the MUGA, linear park and green dale improvements. These qualitative
improvements should therefore be taken as material consideration, outweighing the
overall quantitative loss.
6.39
Further, whilst the proposals will result in a net quantitative loss of open space
provision, an assessment of local open space provision demonstrates that there is
sufficient alternative open space available within proximity to the site. The low value
space at DHFC’s current pitch can therefore be considered surplus to requirements,
in line with NPPF paragraph 74(c).
6.40
Southwark’s Open Space Strategy (2013) notes that Camberwell is relatively well
served by open space, with a good distribution of small parks within the area and
relatively good access to larger spaces outside of the sub-area. Specifically, the
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Planning Statement
strategy identifies that Camberwell has a number of spaces that are not fulfilling their
current potential, noting that quality improvements are particularly required to Green
Dale Playing Field (OS128) and Green Dale Artificial Pitch (OS129).
6.41
The open space strategy categorises open space according to size, characteristics
and use. The Dulwich Hamlet Football Pitch is categorised as an ‘Outdoor Sports
Facilities – private’. The table below shows that compared to other areas of the
Borough, Camberwell has a relatively high provision of outdoor sports facilities in
terms of overall area and provision per 1,000 population. Further, the site is very close
to Dulwich Sub area, which is extremely well served by outdoor sports facilities. The
table shows that Dulwich has by far the largest amount of pitch provision in the
borough, with 3.9ha per 1,000 population.
Table 7 – Outdoor Sports Facilities by Sub Area (Southwark Open Space Strategy, 2013)
6.42
The immediate area surrounding the current DHFC pitch can therefore not be
considered as deficient in terms of the provision of outdoor sports facilities and loss of
open space in terms of the current DHFC will have limited impact on the overall
quantum of provision. This is demonstrated further by the table below, which details
the available outdoor sports facilities accessible within approximately 1km, 1.5 and 2
km of the existing site. It is important to note that this only includes sites within the
Southwark Borough boundary, and there are therefore potentially further available
facilities within these distances located within the neighbouring Borough of Lambeth.
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Planning Statement
Table 8 - Alternative Outdoor Sports Facilities accessible within approximately 2km of Site
Value
Quality
Size
(ha)
Score
Above /
below
average
Score
Above /
below
average
Site ID
Name of Space
Typology
OS129
Greenfield Artificial
Playing Pitch
OSF private
1.04
15.80%
Below
51.90%
Below
OS130
Dulwich Hamlet
OSF private
0.8
22.60%
Below
79.70%
Above
Within 1km
OS139
James Allens Girls
Schools Sports Club
OSF education
1.5
17.20%
Below
74.20%
Above
OS136
Charter School
OSF education
4.14
14.70%
Below
75.00%
Above
OSF education
4.99
37.20%
Above
82.40%
Above
OSF education
3.87
33.80%
Above
78.60%
Above
OSF education
4.64
32.00%
Above
77.70%
Above
OSF private
8.32
44.70%
Above
2.70%
Below
OS140
OS147
OS135
Alleyn School
Playing Field (North
of Townley Road)
Alleyn School
Playing Field
(Carlton Avenue)
James Allens Girls
School Playing
Fields
Within 1.5km
OS146
Herne Hill Cycle
Stadium and Sports
Ground
Within 2km
6.43
OS157
DC Playing Fields
and Sports Ground
(West)
OSF education
14.93
41.30%
Above
73.20%
Above
OS161
DC Playing Fields
and Sports Ground
(East)
OSF education
4.66
30.60%
Above
77.80%
Above
OS153
Burbage Road
Playing Fields
OSF private
6.23
37.40%
Above
74.10%
Above
OS162
Southwark Sports
Ground
OSF Private
2.63
40%
Above
63.80%
Below
The above table shows that a further c. 56 ha of outdoor sports facilities are
accessible within approximately 2km of the Site, within the Southwark Borough and
not accounting for the new open space proposed in this application. Further, the
above table demonstrates that the alternative provision is largely superior to the
current DHFC pitch in terms of value, and the Green Dale Artificial in terms of value
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Planning Statement
and quality. This reiterates the qualitative improvements that will be delivered by the
new development, mitigating the overall quantitative reduction.
6.44
The above table is concerned solely with open space categorised as ‘outdoor sports
facilities’, since this is the typology of open space that will incur a net reduction with
the loss of the DHFC pitch. Appendix II however contains a full analysis of all open
space accessible within approximately 2km range of the site and demonstrates the
following:
6.45

Within 1km – c. 37 ha

Within 1.5km – c. 51 ha

Within 2km – c. 190 ha
Again this highlights the provision of alternative open space in proximity to the Site,
demonstrating that the loss of DHFC pitch will not have a significant, overall impact
on the quantum of provision in the area. As such it can be considered as ‘surplus to
requirements’, whilst the new provision will serve to enhance the local open space
offer by providing a new high quality, high value linear park and sporting facilities.
Loss of Sporting Facilities
6.46
Paragraph 74 of the NPPF states that existing open space, sports and recreational
buildings and land, including playing fields, should not be built on unless:
a) An assessment has been undertaken which has clearly shown the open space,
buildings or land to be surplus to requirements; or
b) The loss resulting from the proposed development would be replaced by
equivalent or better provision in terms of quantity and quality in a suitable
location; or
c) The development is for alternative sports and recreational provision, the needs for
which clearly outweigh the loss.
6.47
With regards to sports facilities, London Plan Policy 3.19 states that proposals resulting
in a net loss of sports and recreation facilities, including playing fields, should be
resisted.
6.48
Southwark Plan Saved Policy 2.1 (Enhancement of community facilities) states that
planning permission for a change of use from D class community facilities will not be
granted unless:
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i.
Planning Statement
The applicant demonstrates to the satisfaction of the LPA that the community
facility is surplus to requirements of the local community and that the
replacement development meets an identified need; or
ii.
The applicant demonstrates that another locally accessible facility with similar
or enhanced provision can meet the identified needs of the local community
facility users.
6.49
The proposals will result in an overall quantitative reduction of sporting facilities, via
the loss of the existing DHFC playing pitch and the reduction in ancillary facilities
currently attached to the DHFC stadium.
6.50
However, the development will result in an enhanced qualitative provision across the
Site, in the form of a new DHFC pitch and ancillary services, plus a MUGA. The benefit
of these facilities has been emphasised previously. The proposals are therefore
compliant with Southwark Plan policy 2.1 (ii) and NPPF paragraph 74 (c). The above
assessment of alternative Outdoor Sports Facilities in proximity of the Site has also
demonstrated that the loss of the current DHFC pitch will have limited impact on the
overall quantum of provision in the area.
6.51
Further, whilst the proposed stadium facilities will be smaller than the existing in terms
of ancillary services, they have been rationalised to be appropriate for a club of
DHFC’s size. At present, the Club’s ancillary facilities are surplus to their requirements
and to that of local demand, creating a financial drain that seriously jeopardises
DHFC’s future. In particular, the gym, squash courts and entertainment space are
consistent loss makers that have resulted in a wholly financially insecure future for
DHFC. In contrast, the level of proposed provision will meet local demand without
creating a financial burden. Without this redevelopment there is a serious risk of club
failure which would result in nil provision. The need for this redevelopment therefore
outweighs the quantitative loss of floor space, in line with policy requirements. The
proposals are therefore consistent with Southwark plan policy 2.1(i).
Provision of new sports facilities
6.52
The provision of new or enhanced sports facilities is supported at national, regional
and local policy level. Paragraph 70 of the NPPF states that planning policies and
decisions should plan positively for the provision and use of community facilities
(including sports venues). Paragraph 73 recognises that access to high quality open
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Planning Statement
spaces and opportunities for sport and recreation can make an important
contribution to the health and well-being of communities.
6.53
The London Plan acknowledges that sports and recreation facilities are important
parts of the social infrastructure, providing a range of social and health benefits for
communities and neighbourhoods. Policy 3.19 ‘Sports Facilities’ states that
development proposals that increase or enhance the provision of sports and
recreation facilities will be supported. In particular, wherever possible, multiuse public
facilities for sport and recreation should be encouraged. Policy 3.16 states that
development proposals which provide high quality social infrastructure (which
includes sports facilities) will be supported in light of local and strategic social
infrastructure needs assessments.
6.54
Southwark Core Strategy Strategic Objective 1c strives to promote a healthy and
active community by delivering good access to leisure, sports and community
facilities. Strategic Policy 4 states that there will be a wide range of well used
community facilities that provide spaces for many different communities and
activities in accessible areas. This will in part be achieved by facilitating a network of
improved community which encourage physical activity and promotes healthy
lifestyles.
6.55
The proposal is also in line with Saved Southwark Plan Policy 2.2 (Provision of
Community Facilities) which states that planning permission will be granted for new
community facilities provided that:
i.
Provision is made to enable the facility to be used by all members of the
community; and
ii.
The facility is not detrimental to the amenity of present and future occupiers
of the surrounding area in compliance with Policies 3.2 and 5.2; and
iii.
Where developments will generate more than 20 vehicle trips at any one time
a Transport Assessment will be required in compliance with Policies 3.3 and
5.2.
6.56
The above demonstrates strong policy support for the proposals which include new
sporting facilities via the provision of a new Football Club and Community Facilities,
plus MUGA. In addition to improved quality, the new facilities will also enable
enhanced access and use by the community, as previously described.
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Planning Statement
Principle of Development – Residential
6.57
With regards to the proposed housing, the strategic and local planning documents
have identified a need for new housing within the London Borough of Southwark
(LBS). LBS has one of the highest housing requirements of all London Boroughs, with an
updated London Plan (2015) target of 2,376 additional homes per year (combination
of new dwellings and vacant properties bought back into use) to contribute towards
the London Plan net overall target.
Table 9 - London Borough of Southwark Annual Housing Completions
2500
2187
2150
2000
1808
1498
1500
1035
1031
1000
Net
Completions
500
London Plan
Target
0
2008/09
6.58
2009/10
2010/11
2011/12
2012/13
2013/14
The Council has not produced an Annual Monitoring Report (AMR) since 2011,
however net dwelling figures are provided by the Greater London Authority in their
AMR. The figure above shows the delivery of housing completions in the Borough
against London Plan targets between 2008/09 and 2013/14 demonstrating that in four
of the past monitoring periods, delivery has fallen short of the London Plan targets.
6.59
The Preferred Options version of the New Southwark Plan notes that the Council has
no record of achieving the updated FALP target. To achieve the target of 2,367 units
a year the Council acknowledges that it will need to optimise the use of land and
build at higher densities.
6.60
In light of this increasing pressure on the Council to deliver housing, the provision of
eminently deliverable housing via this scheme must been seen favourably by the
Council.
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6.61
Planning Statement
Whilst this Site is not allocated for residential use in the Council’s Development Plan,
the benefit of windfall Sites is set out within the NPPF. In addition, the provision of
unidentified new residential units reflects the Council’s Core Strategy Policy 5 which
acknowledges that the delivery of homes to meet housing need is a core principle of
the planning system.
6.62
Furthermore, the proposed location for the residential element of the scheme is
suitable because it comprises partly previously developed land, and the loss of open
space is offset by a significant improvement to the quality of open space re-provided
in the form of a public linear park and sporting facilities. This is in line with national
policy targeting brownfield land. The NPPF seeks to proactively drive and support
sustainable economic development to deliver the homes and business units that the
country needs by encouraging the effective use of previously developed land and
by promoting mixed use development (Para 17). It is also in line with regional
objectives as set out in the London Plan, which seek to increase housing supply and
realise brownfield housing capacity (Policy 3.3).
6.63
We therefore consider the proposed residential development to be suitable in policy
terms.
Residential mix
6.64
The proposals include the following unit mix. The affordable mix has been informed by
high level viability assessment. Full details of this are set out in the accompanying
viability assessment which has been provided by Savills.
Table 10 - Proposed Mix
6.65
Unit Type
Market
Housing
Affordable
Housing
Total Mix
no.
Total Mix
%
Studio
7
0
7
5%
1 Bed
45
11
56
36%
2 Bed
39
7
46
30%
3 Bed
36
7
43
28%
4 Bed
3
0
3
2%
Total
130
25
155
100%
Southwark Strategic Policy 7 (Family Homes) requires developments of 10 or more
dwellings will have at least 60% 2 + bedroom units and in the suburban density zone,
a minimum of 30% 3, 4 or 5 bedroom dwellings. There will also be a maximum of 5% as
studios and only for private sale.
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6.66
Planning Statement
The overall proposed mix is therefore policy compliant.
Residential quality
6.67
The residential layouts have been designed to comply with the London Housing
Design Guide, and Southwark’s Residential Design Standards. These standards ensure
quality of life for residents, considering design from the front door through to internal
layouts. The units have been laid out to provide long-term adaptability to suit growing
families, new owners and tenants alike. Further detail on residential quality and
design can be found in the Design and Access Statement that accompanies this
report.
6.68
The table below assesses the development against the criteria required for a
development to be considered as being exemplary design, as outlined in
Southwark’s Residential Design SPD.
Table 11 - Southwark Residential Design SPD - 'Exemplary' criteria
Criteria Compliance
Significantly exceed minimum
floorspace standards
All units either meet or exceed both the Southwark
and GLA internal space standards
Provide for Bulk Storage
All units meet London Housing Design Guide (LHDG)
standards for internal storage
Include a predominance of dual
aspect units
The majority (60%) of units are duel aspect
Exceed the minimum ceiling height of
2.3 metres required by the Building
Regulations
All habitable rooms have a minimum ceiling height
of 2.6 meters
Have natural light and ventilation in
kitchens and bathrooms
All Kitchens are all naturally ventilated, because of
design constraints however, bathrooms are all
mechanically ventilated
Exceed amenity space standards set
out in this SPD
The development is policy compliant in terms of
private amenity space. The proposals vastly exceed
standards in terms of communal amenity space.
Meet good sunlight and daylight
standards
The proposed scheme is considered to recognise
and observe policy requirements with regards to
sunlight and daylight standards.
The Daylight, Sunlight and Overshadowing
Assessment that accompanies this application
demonstrates that all but one of the main habitable
spaces will comply with the BRE target values by
14%. Of these failures, thee are to bedrooms, which
the BRE stipulates are less important than main
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Criteria Planning Statement
Compliance
habitable spaces.
Have excellent accessibility within
dwellings including meeting
Approved Document M of the
Building Regulations M4(2) standard
for all non wheelchair-user homes
The development provides over 10% wheelchair
units, designed to the relevant standards
Minimising corridor length by having
an increased number of cores
The development does not exceed the LHDG
standard of eight units per core
Stacking of units to minimise noise
transmission
A majority of units stack throughout the
development
Obtain Secured by Design
certification
Secured by Design accreditation will be sought for
the scheme
Have exceptional environmental
performance that exceeds the
standards set out in the Sustainable
Design and Construction
Supplementary Planning Document
Development has been designed to accord with
Sustainability Assessment Checklist which refers to
minimum and prefers standards in the Sustainable
Design and Construction SPD (see Appendix I)
Maximise the potential of the site as
demonstrated in the applicant’s
Design and Access Statement
It is considered that the scheme maximises the
potential of the site without constituting
overdevelopment.
Make a positive contribution to local
context, character and communities,
including contributing to the
streetscape
It is the opinion that the scheme makes a positive
contribution to the area, in particular through public
realm and landscaping features that seek to link the
development to surrounding areas of open space
The principles of Lifetime Homes have been
incorporated into all of the residential units.
Provision of Wheelchair Units
6.69
The development provides 16 Wheelchair Accessible Units, equivalent to
approximately 10% of on-site provision, in line with requirements under London Plan
Policy 3.8 and Saved Southwark Plan Policy 4.3.
6.70
All wheelchair accessible homes are designed to comply with the South East London
Housing Partnership Wheelchair Design Guide (SELHPWDG) guidance, as required by
the Council’s Residential Design SPD.
Affordable Housing
6.71
Core strategy Strategic Policy 6 requires that 35% affordable housing is provided on
schemes of over 10 units, subject to viability. Southwark Plan Saved Policy 4.4
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Planning Statement
(Affordable Housing) states that within the Urban and Suburban Density Zones the
Council will seek to secure at least 35% of all new housing as affordable housing, for
all developments capable of providing 15 or more additional dwelling units or on
Sites larger than 0.5 hectare.
6.72
Policy 4.5 (Wheelchair Affordable Housing) states that for every affordable housing
unit which complies with the wheelchair design standards, one less affordable
habitable room will be required than otherwise stated in Policy 4.4.
6.73
The proposed number of private and affordable homes has been generated
following a viability study carried out by Savills of the whole scheme, including the
costs associated with the new Football Club facilities. The assessment accompanies
this planning application.
6.74
The affordable housing provision is split 70% affordable rented, 30% intermediate. This
tenure split reflects guidance within the Council’s Development Viability SPD. The
affordable units are provided in accordance with the tenure / size mix below,
including three wheelchair accessible units.
6.75
The scheme is tenure blind, but has been arranged so that private and affordable
rent units have separate circulation and cores for ease of separating service charges
and enabling effective management. Affordable rent units are located in the
northern half of Building A from ground, up to level 5. Intermediate units are pepper
potted around the development at ground floor.
Residential Density
6.76
The Site is located within a suburban density zone, as defined in Southwark’s Core
Strategy Strategic Policy 5. Within suburban density zones densities of 200-350 hr/ha
will be expected.
6.77
Density has been calculated in line with the ‘Maccreanor Lavington’ method as
outlined in the Mayor’s Draft Interim Housing SPG (2015) for calculating densities on
mixed use developments.
6.78
The London Plan defines density in terms of new residential site area. This relates to
the ‘‘red line’ planning application site boundary and excludes adjoining footways
and carriages, paths, rivers, canals, railway corridors and other existing open spaces.
It includes the proposed homes, non-residential uses in mixed use buildings, ancillary
uses, car and cycle areas and proposed internal access roads. It generally includes
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Planning Statement
proposed on-site open spaces (including publically accessible spaces), gardens and
children’s play areas
6.79
Because the site boundary includes large amounts of existing open space, in the
form of the existing open space at Green Dale Playing Fields, this element of the Site
has been excluded from our calculations so as not to artificially lower density
calculations.
6.80
Because the football stadium and residential buildings comprise separate buildings,
we are also of the opinion that this non-residential area of the site should be
excluded from density calculations. As ‘proposed on-site open spaces’ however, we
consider that the areas of the MUGA and linear park should be included in the
calculation.
6.81
Density calculations are show below, both including and excluding the proposed
football pitch and stadium areas. Calculations are based on 155 units / 490 habitable
rooms.
Table 12 - Density calculations
6.82
Excludes Includes ha % site residential Apportioned site area hr / ha u / ha Greendale
Playing
Fields Residential areas,
Football pitch,
Stadium, MUGA,
Linear Park, onsite
roads etc
2.42
90%
2.18
224.7
71.1
Greendale
Playing
Fields,
Football
pitch,
Stadium
Residential areas,
MUGA, Linear Park,
onsite roads etc
1.39
100%
1.39
352.0
111.4
The above shows that, regardless of site area calculations, the proposed density is
broadly in line with that required within a Suburban Density Zones. When considered
together with the significant proportion of open space provided by the development
and the strong PTAL rating of 4, the proposals are appropriate given the context and
do not represent an over development of the Site.
Daylight, Sunlight and Overshadowing
6.83
A Daylight, Sunlight and Overshadowing Assessment has been prepared by Delva
Patman Redler LLP and accompanies this application. This assessment has been
carried out in accordance with the recommendations of the Building Research
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Planning Statement
Establishment Report “Site Layout Planning for Daylight & Sunlight 2011” (BRE 209). This
is the standard identified by Council policy.
6.84
The assessment concludes that:

All of the windows assessed will fully comply with the necessary standards;

New amenity within the proposed scheme will comply with the BRE target values;

All but one of the main habitable spaces will comply with the BRE target values.
Three of these failures are to bedrooms which the BRE stipulates are less
important than main habitable spaces.

Generally the scheme is considered to have a predominately negligible impact
when measured against the significance criteria of the vertical sky component,
no sky line and the average daylight factor method for daylight assessment;

Generally the scheme is considered to have a negligible impact when measured
against the significance criteria for sunlight assessment; and

Overall, the proposed development will create a negligible impact on the
residential amenity adjacent to the development site and is considered to be
acceptable in daylight and sunlight terms on the surrounding properties.
6.85
The Assessment concludes therefore that the proposed scheme is considered to
recognise and observe the policy requirements.
Transport and Access
6.86
A Travel Assessment (TA) and Travel Plan (TP) have been prepared by WSP | Parsons
Brinckerhoff and accompany this planning application.
6.87
The TA analyses the PTAL model calculation for the Site and suggests that that some
walking routes and / or services have been ignored. The TA therefore carries out a
detailed Site-specific PTAL model to determine the true level of accessibility at the
Site. As a result, the PTAL rating is corrected to 4, illustrating that the Site has a ‘good’
level for public transport accessibility.
6.88
The development proposals are designed primarily around pedestrian and cycle
access and seek to discourage vehicles and encourage sustainable travel behaviour
for all residents, staff and stadium spectators. The proposed residential scheme will
benefit from pedestrian and cycle access from the east and southern boundaries via
Abbotswood Road and the new stadium access respectively.
6.89
The proposed football stadium will benefit from a separate access road which will be
designed to prioritise pedestrians and cyclists. The stadium access road will be a
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shared-surface and be controlled via collapsible bollards or gate to restrict vehicular
access accordingly.
6.90
Vehicular access to the residential development will be via an independent priority
junction to the east of the Site via Abbotswood Road. This will provide access to a car
park located beneath a podium deck. The stadium will be accessed separately to
the south of the scheme via a new shared surface road.
6.91
The TA demonstrates that there will be a negligible impact on the local pedestrian,
cycle, public transport and highway networks as a result of the proposed
development. This is demonstrated through a number impact assessments and
models.
Service and Refuse Access
6.92
The TA and Waste Management Strategy sets out the strategy for refuse collection. In
terms of the residential element, the overall strategy is for refuse to be sorted within
suitable bins located around the residential Site. On days of collection, bins would be
transported by internal management to the bin store next to the junction with
Abbotswood Road.
6.93
The overall strategy for all stadium and health and fitness centre refuse is for refuse to
be collected to the southwest of the Site. On days of collection, on Site management
would be available at all times during the daytime hours. All bins stores are located
within a 10m drag distance of a refuse vehicle.
6.94
The TA assesses delivery and servicing trip generation in Chapter 15 and the effect of
the proposed delivery and servicing arrangements on the local highway network in
Chapter 13.
Vehicle Parking
6.95
On the basis of census data analysis (included in the TA) the development proposals
provide residential parking spaces equivalent to approximately 0.4 spaces per
residential unit, being a total 62 spaces, of which 16 are disability accessible. All of
these will be located within the residential car park located beneath the podium
deck and accessed via Abbotswood Road.
6.96
No other car parking spaces will be provided, with the exception of 3 disabled
parking bays for DHFC use. The current stadium car park provides a total of 46
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Planning Statement
parking spaces on-Site. The proposals seek to remove this existing car park in order to
prioritise sustainable transport and encourage a reduction of car use. Spectators
and residents alike will be encouraged to travel sustainably through the adoption of
a robust Stadium Management Plan, Travel Plan and Residents Welcome / Travel
Pack. This approach is in line with saved Southwark Plan Policy 5.6 (Car parking)
which requires that all new developments should minimise the number of parking
spaces provided.
6.97
In terms of the impact of overspill parking on surrounding streets, the TA estimates that
the stadium is expected to generate an additional 34 vehicles parked on-street
during a match day (hour prior to and following a game). Factoring the removal of
46 spaces currently on-site and assuming these cars will be displaced on-street, the
baseline match day parking demand is likely to result in 297 spaces remaining
unoccupied on street. The additional 34 cars generated by the proposed stadium
would therefore result in 263 spaces remaining unoccupied on street within 400m of
the site. This demonstrates minimal impact on surrounding streets in terms of overspill
parking.
6.98
In terms of the health club, the TA estimates that the proposed facility is likely to
generate around 1 additional car being parked on-street and concludes that this
additional demand will have no material impact to the on street parking supply.
Cycle Parking
6.99
The proposals provide a total of 1 cycle space per 1 bed dwelling and 2 spaces per
2+ bed dwellings in accordance with the London Plan, being equivalent to 316
spaces, including 278 for the residential units and 38 for the community facility and
MUGA, which are located within dedicated secure stores.
6.100
As set in the TA, cycle parking for the stadium has been provided in accordance with
current demand, being an allowance for 2% of spectators to travel by bicycle. This
results in a requirement of around 27 spaces, being equivalent to 14 Sheffield stands.
These will be provided within the stadium and covered appropriately.
6.101
A total on Site provision of 10 cycle spaces / 5 Sheffield stands will be provided for the
Health Club. This provision has been calculated with reference to London Plan
standards, as detailed in the TA.
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Air Quality
6.102
The Site falls within an Air Quality Management Area (AQMA). It is therefore
necessary to demonstrate that the development does not result in a negative impact
upon local air quality and that the future residents of the development are not
subject to unacceptable levels of air pollution.
6.103
An Air Quality Assessment has been carried out by WSP | Parsons Brinckerhoff and
accompanies this application. The report addresses the potential air quality impacts
during both the construction and operational phases of the proposed Development.
6.104
The assessment of construction phase impacts associated with fugitive dust and fine
particulate matter identified that the Proposed Development is considered to be a
High to Medium Risk Site for dust soiling, and Low to Negligible risk for health effects.
However, through good Site practice and the implementation of suitable mitigation
measures, the effect of dust and PM10 releases would be significantly reduced. The
residual effects of the construction phase on air quality are considered to be
negligible.
6.105
An assessment of the impact from additional traffic and energy center emissions
during the operation of the Proposed Development has been undertaken to consider
the pollutants of NO2, PM10 and PM2.5. The assessment has shown that the impact of
emissions associated with the Proposed Development on local air quality once
operational would be negligible.
6.106
An assessment of the potential exposure of the future users of the Proposed
Development to potentially elevated pollutant concentrations found that all new
exposure receptors fall within Air Pollution Exposure Criteria Level A, based on the
London Councils guidance. Future mitigation is therefore not required.
6.107
An air quality neutral assessment of the buildings and transport related emissions
associated with the operation of the Proposed Development was also undertaken, in
accordance with Mayoral policy. The results indicate that the Proposed
Development would be better than ‘air quality neutral’ and consequently no further
mitigation is anticipated to be required.
6.108
It is therefore considered that following the implementation of any required
mitigation, the development proposals comply with national and local policy for air
quality.
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Planning Statement
Archaeology
6.109
The Site is not located within an Archaeological Priority Zone.
6.110
An Archaeological Desk Based Assessment (ADBA) has been undertaken by WSP |
Parsons Brinckerhoff and accompanies this application. The report concludes that
the potential for surviving Prehistoric, Roman, Early Medieval and Medieval remains
within the Site is low, and that any potentially surviving buried archaeological remains
within the Site boundary, would be of low value. It is concluded that the potential for
surviving Post-Medieval and Modern remains within the Site is low to moderate, and
that any potentially surviving buried archaeological remains dating to the PostMedieval and Modern period, within the Site boundary, would be of negligible to low
value.
6.111
The report therefore concludes that no designated archaeological assets will be
affected by the proposed scheme.
Ground Conditions
6.112
A Preliminary Environmental Risk Assessment has been carried out by WSP | Parsons
Brinckerhoff and accompanies this application. This desk-based study assesses
potential environmental liabilities and constraints associated with the proposed
redevelopment.
6.113
In conclusion, the preliminary risk assessment indicates a low - medium risk to human
health receptors and low risk to controlled waters receptors for a proposed
redevelopment of the Site. A limited soil, groundwater (of potential perched water
within Made Ground) and gas investigation is recommended to establish the ground
conditions and assess the ground gas regime. We anticipate that this level of Site
Investigation will be secured by a planning condition.
Ecology / Biodiversity
6.114
The following reports, carried out by WSP | Parsons Brinckerhoff, accompany this
application:

Extended Phase 1 Habitat Survey Report; and

Further Ecological Surveys Report (including botanical, amphibians, reptiles and bats)
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6.115
Planning Statement
The reports contain recommendations relating to sensitive design to avoid/mitigate
effects upon ecological receptors, enhance ecology on Site and provide
recommendations for working methods during construction.
6.116
The following recommendations are made to mitigate the impacts of the
development on habitats and species identified on the development site:

The retention and enhancement of semi-natural habitats present on Site,
including diversification of existing grassland within Green Dale Playing Fields if
possible;

A precautionary method of scrub clearance (where required) to avoid killing and
injury of amphibians and other species that may be present (e.g. hedgehogs);

The creation of log and/or brash piles to compensate for the loss of sheltering
habitat for amphibians and invertebrates;

The retention of trees considered to having bat roosting potential, or further
survey should these trees be directly impacted by the proposed development to
establish requirements for mitigation if applicable; and

The sensitive use of external lighting and flood lighting to allow continued use of
the Site by foraging and commuting bats.
6.117
Biodiversity enhancement measures for the Site have also been proposed. These
include the creation of a water-body to provide improved habitats for amphibians
and other species (invertebrates), the provision of additional roosting opportunities for
bats (bat boxes and bat tubes), the inclusion of nectar rich plant species within the
planting schedule to improve foraging opportunities on site for invertebrates and bats
and the diversification of the grassland sward.
6.118
As such, the development proposals promote and protect biodiversity. This is in line
with the NPPF objective to ‘conserve and enhance the natural environment’, and
Saved Southwark Plan Policy 3.28 which encourages the inclusion of features which
enhance biodiversity in new developments.
Arboricultural Assessment
6.119
An Arboricultural Report has been prepared by Crown Consultants and
accompanies this application. The report solely refers to the area of the Site that
excludes Green Dale Playing Fields. A separate Survey for the site has previously been
prepared commissioned and prepared for Southwark Council in relation to Green
Dale Playing Fields.
6.120
In order to facilitate the development, it is proposed to remove seventeen relatively
small, Retention Category C trees, seven Retention Category B trees and one
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Planning Statement
Retention Category U tree. The report notes that these are predominantly small trees
with a relatively low amenity value.
6.121
No pruning works are required to facilitate the proposal and no significant hard
surfacing is proposed within any Root Protection Areas.
6.122
Tree protection measures are specified throughout Section 6 of the report that will
ensure no negative impact on retained trees due to construction activity. The report
concludes that adequate space has been allowed between the proposal and all
trees such that no future pressure to overly-prune or remove trees shall occur as a
consequence of the proposal.
6.123
The Landscape Strategy that accompanies this application details the tree planting
that is proposed to take place as part of the scheme. The strategy explains that the
proposals will look to introduce a number of UK native species, in particular the Oak
tree which is prominent in Dulwich Wood, Sydenham Wood and Dulwich Upper
Wood. New planting will include trees that will reach category B once in maturity.
Flood Risk
6.124
WSP Parsons Brinckerhoff has undertaken a Flood Risk Assessment (FRA) which
accompanies this planning application.
6.125
The site is located within Flood Zone 1 (i.e. a 0.1% chance or less of flooding from rivers
and the sea in any given year) based on the EA Flood Mapping and relevant LBS
documents. Therefore the proposed development has a low risk of fluvial and tidal
flooding and meets the requirements of the Sequential Test, as set out in the PPG.
6.126
The FRA investigates all potential sources of flooding and considers the following risks:

the probability of surface water flooding is low to medium as some flooding might
occur in areas for high return period events;
6.127

the probability of sewer flooding is low to medium; and

All other sources of flooding can be considered as low.
All potential sources of flooding have been investigated and mitigated as
appropriate through the development of a surface water drainage strategy
designed for the 1 in 100 year storm event plus an allowance for climate change. This
is in line with the Council’s Strategic Policy 12 which encourages sustainable urban
drainage systems to be incorporated in new development. To this purpose green
roofs have been included as part of the development as the most appropriate
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Planning Statement
sustainable drainage system (SuDS) for the Site. Surface water from the Site will be
attenuated within cellular storage situated beneath the developments access road
before being discharged via gravity to the public drainage network.
Energy and Sustainability
6.128
An MEP and Energy statement has been prepared by BOCCA consulting and
accompanies the report. The report outlines a strategy to enable the proposals to
satisfy Southwark Borough Council’s energy policies and those of the London Plan,
including the target to reduce CO2 emission to 35 per cent below a building
compliant with Building Regulations, Part L, 2013.
6.129
The statement reports that applying the Mayor’s energy hierarchy result in savings
from energy-efficient measures and “Clean” energy supplies. No savings were found
from renewables “Green” technologies. The overall effect of these savings was
estimated to be 40 % of the regulated loads.
6.130
A BREEAM pre-assessment has been prepared by Southfacing and accompanies this
planning application. Tthe pre-assessment scores have been based on the following
scoring scenarios;
6.131

Current - The number currently achieved.

Scenario 1 - Current, plus credits which can be easily gained.

Scenario 2 - Scenario 1, plus credits which can be won but not so easily.
On this basis, the following scores are considered achievable under each scenario;
Table 13 - BREEAM Scores
6.132
Scenario Score BREEAM Rating Current 52.98
Good
Scenario 1
61.8
Very Good
Scenario 2
65.85
Very Good
LB Southwark’s Sustainability Checklist has been completed and accompanies this
this Planning Statement at appendix II.
Waste management
6.133
An Outline Site Waste Management Strategy (OSWMS) has been produced by Mayer
Brown and accompanies this application. The OSWMS has been undertaken in
accordance with the requirements of the Southwark Core Strategy, Sustainable
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Planning Statement
Design and Construction Supplementary Planning Document and Management
Guidance Notes for Residential development. Consultation has also been
undertaken with the appropriate Recycling Support Officer for LBS at Veolia.
6.134
The strategy sets out the reasonable steps necessary prior to Site works commencing
and for the management company to apply during the operational phase. This is in
order to ensure that waste duty of care is complied with, materials are handled
efficiently and waste is managed appropriately.
6.135
With regards to construction and demolition, a full Site Waste Management Plan
(SWMP) in accordance with principles detailed in the OSWMS.
6.136
In terms of operational waste, the Design and Access Statement that accompanies
this report details that residential waste and recycling will be collected from the main
bin store at the ground floor of block A. This is located within 10m of Abbotswood
Road where refuse trucks will pull in for collection. Bin stores located here have the
capacity to hold all of the required bins for the residential development. This number
has been generated using Southwark’s bin store calculator.
Noise
6.137
A noise assessment has been conducted by Mayer Brown Limited and accompanies
this planning application. The report considers site suitability for residential
development, noise intrusion, external amenity areas, operational noise and
construction noise and vibration.
6.138
The Assessment concludes that the proposed development, in both the construction
or operational phase, does not raise any significant or other adverse impacts on the
health and/or quality of life for existing residential and commercial neighbours of the
site arising from noise. It is therefore considers that the proposed development
complies fully with noise related national, regional and local planning policy and any
mitigation can, if considered necessary, be enforced by means of appropriate
planning conditions, consistent with paragraph 123 of the National Planning Policy
Framework.
6.139
The proposals are therefore in line with saved Southwark Plan Policy 3.2 which states
that planning permission for development will not be granted where it would cause
loss of amenity, including disturbance from noise, to present and future occupiers in
the surrounding area or on the application site.
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Planning Statement
External Lighting
6.140
An External Pitch Lighting Planning Statement has been produced by BOCCA and
accompanies this application.
6.141
The report clarifies that the lighting scheme to both the proposed DHFC pitch and
MUGA have been designed to the respective standards.
6.142
The Football Club Pitch is illuminated with 4 x 20m columns equipped with 2kW
floodlights with varying optics and light shields. As the Football Club Pitch is very close
to Green Dale Fields careful lighting control has been addressed to minimise light spill
into the space. This will help mitigate any negative impact to the openness of the
MOL. The proposals also represent a reduction in current floodlight provision, which
are also lower, again resulting in a less intrusive impact on the MOL, in line with policy
requirements.
6.143
The MUGA Pitch is illuminated with 4 x 8m masts equipped with 1kW lamps. As the
MUGA Pitch is close to one of the residential block careful lighting control has been
addressed to minimise light spill into the residential space.
Landscaping and Public Realm
6.144
A Landscaping Strategy has been prepared by Grants Associates and accompanies
the application. The Strategy explains how the development creates an opportunity
to connect communities, both with each other and with the landscape, and
highlights three key opportunities to enhance this connectivity:

Enhancing circulation and connecting the community by creating a clear
hierarchy of external spaces, views routes and experiences throughout the
development;

Creating a variety of landscape characters and habitats; and

Enhancing Dulwich Hamlet Football Club identity by improving the arrivals
sequence for DHFC supporters and enriching the match day experience.
6.145
Specific landscape and public realm features include;

linear park, connecting St Francis Park to Green Dale Fields whilst providing
habitat and biodiversity together with a variety of play opportunities and seating;

shared street, to create a safe, shared surface street for pedestrians and cyclist
use, connecting Abbotswood Rd to the Football Club entrance, and to Green
Dale Fields beyond;
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
Planning Statement
Community Square, to create a unified space with coherent and considered
paving strategy, providing a formal arrivals space for visitors to the Club and
community facilities; and

Green Dale Playing Fields improvements, to enhance accessibility and visibility
and introduce greater biodiversity.
6.146
The Landscape Strategy details proposed planting as part of the scheme. The
strategy explains that the proposals will look to introduce a number of UK native
species, in particular the Oak tree which is prominent in Dulwich Wood, Sydenham
Wood and Dulwich Upper Wood. New planting will include trees that will reach
category B once in maturity.
6.147
The Landscape Strategy is therefore in line with London Plan Policy 7.1, which
encourages development to be designed so that it improves people’s access to
social and community infrastructure (including green spaces) and enhances the
character, legibility, permeability, and accessibility of the neighbourhood. The
Landscape Strategy is also in line with Policy 7.4 which encourages high quality deign
that contributes to a positive relationship between the urban structure and natural
landscape features.
6.148
The Landscape Strategy also reflects Saves Southwark Plan Policy 3.13 that states that
new developments should consider the include landscape design that enhances the
area and biodiversity.
Design
6.149
A Design an Access Statement has been prepared by Farrells and accompanies this
planning application.
6.150
The design development has been a direct response to the Site analysis and the
surrounding context. The key concepts for the scheme are:

Link existing green spaces

Provide a new football pitch and facilities

Create a new linear park

Provide new community facilities

Create a residential development that is responsive to context and neighbouring
developments, and provides a positive contribution to the built form of the area
6.151
Throughout every stage of the design development, the design team have looked to
meet the requirements set out in Southwark’s Design Values and Standards, in order
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Planning Statement
to ensure that the development provides quality and life-enhancing homes and
places.
6.152
Further details of the design evolution and key principles are provided in the Design
and Access statement.
Planning obligations
6.153
Draft S106 Head of Terms (attached at Appendix III) have been prepared with
reference to Southwark Council’s Section 106 Planning Obligations and Community
Infrastructure Levy (CIL) SPD (April 2015).
6.154
The Heads of Terms proposes both Site specific S106 contributions and standard S106
charges, as detailed in Appendix 1 of the Council’s SPD.
6.155
Site specific S106 contributions include:

The transfer of the ownership and management of the DHFC to fan ownership in
the form of an appropriately established Community Benefits Society;

The ownership of stadium and associated facilities to be transferred to a
charitable leisure provider and/or LB Southwark;

Phasing of stadium construction in line with appropriate construction programme
to ensure that Dulwich Hamlet Football Club do not groundshare or are
temporarily relocated;

Improvement works at Green Dale Playing Fields to be carried out by the
Developer; and

The stadium and associated facilities shall be made available for hire by local
schools, community and sports groups.
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Planning Statement
7.
Summary and Conclusions
7.1
This Planning Statement has been prepared by Bilfinger GVA on behalf of Greendale
Property Company Ltd (the ‘Applicant’) in support of the application for full planning
permission for the redevelopment of the Site at Dulwich Hamlet Football Club (DHFC),
Edgar Way, SE22 8BD and adjacent Green Dale Playing Fields.
7.2
The proposed development involves the redevelopment and relocation of the DHFC
stadium, together with the provision of 155 residential units, a Multi-Use Games Area
(MUGA), 35m wide linear park and improvements to Green Dale Playing Fields.
7.3
Specifically, the development delivers the following benefits to the local community:

The long term protection of a historic Football Club that is valued by the local
community through the provision of a new, purpose built facility based on sound
financial principles;

The transfer of the ownership of the Football Club to the local community and
fans through the establishment of a Community Benefits Society;

A management structure for the facility that will deliver a multi-purpose leisure use
that can not only be used by the Club, but also by local schools and community
groups;

Significant investment in Green Dale Fields resulting in quality improvements and
enhanced community access to the open space;

The provision of new, publicly accessible open space via the development of a
new linear park which will serve as a ‘green link’ between St Francis park and
Green Dale Playing Fields;

The provision of new, high quality, private and affordable housing which will
contribute towards Southwark’s housing need; and

Retention of the existing telecommunications equipment on Site via the removal
of the existing, freestanding telecommunications mast and repositioning of
equipment on prosed residential block B.
7.4
The appraisal of the proposal against the relevant planning policy framework
demonstrates that in addition to all of the above benefits, it complies with all relevant
planning policies.
7.5
We therefore respectfully request that LBS grant planning permission for the proposal.
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Report
Appendices
Report
Appendix 1
LBS Sustainability Checklist
Report
Appendix 2
Alternative available open
space within c. 2km
Greendale Property Company Ltd
Planning Statement
Alternative available open space within c. 2km
Site ID
Name of Space
OS128
Green Dale Playing Field
OS129
Green Dale Artificial Playing
Pitch
OS130
Dulwich Hamlet
Typology
natural or seminatural greenspaces
Outdoor sports
facilities - private
Outdoor sports
facilities - private
Sub total
Size (ha)
Value score
(%)
Quality
Score (%)
2.12
11.80%
48.80%
1.04
15.80%
51.90%
0.8
22.60%
79.70%
Relationship between quality
and value
Below average quality and
value
Below average quality and
value
Above average quality, below
average value
3.96
Within c. 1km
OS139
James Allens Girls Schools Sports
Club
OSF - education
1.5
17.20%
74.20%
OS136
Charter School
OSF - education
4.14
14.70%
75.00%
OS140
Alleyn School Playing Field
(North of Townley Road)
OSF - education
4.99
37.20%
82.40%
OS147
Alleyn School Playing Field
(Carlton Avenue)
OSF - education
3.87
33.80%
78.60%
Above Average Quality and
Value
OS135
James Allens Girls School Playing
Fields
OSF - education
4.64
32.00%
77.70%
Above Average Quality and
Value
OS114
Lettsom Gardens
0.63
46.30%
72.50%
OS134
Nairne Grove Nature Garden
0.11
9.20%
41.30%
OS121
London Wildlife Trust Centre for
Wildlife Gardening
0.22
29.60%
78.20%
OS110
Grove Park and East Dulwich
Railway cuttings and
embankments
10.41
25.70%
75.00%
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Natural or seminatural greenspaces
Natural or seminatural greenspaces
Natural or seminatural greenspaces
Natural or seminatural greenspaces
Above Average Quality, Below
Average Value
Above Average Quality, Below
Average Value
Above Average Quality and
Value
Above Average Quality and
Value
Below Average Quality and
Value
Above Average Quality and
Value
Above Average Quality, Below
Average Value
Greendale Property Company Ltd
Planning Statement
OS119
Dog Kennel Hill Open Space
and Adventure Playground
Small Local Park
1.24
35.90%
80.30%
OS120
St. Francis’ Park
Small Local Park
0.92
31.50%
81.50%
OS122
Goose Green Common
Small Local Park
1.58
30.00%
71.20%
OS138
Sunray Gardens
Small Local Park
1.51
56.00%
82.80%
400
Bonar Road Allotments
Allotments
0.27
15.90%
75.20%
OS123
Goose Green Playground
Small Local Park
0.40
25.7%
72.8%
Sub total
Above Average Quality and
Value
Above Average Quality and
Value
Above Average Value, Below
Average Quality
Above Average Quality and
Value
Above Average Quality, Below
Average Value
Above Average Quality,
Below Average Value
36.43
Within c. 1.5km
OS146
Herne Hill Cycle Stadium and
Sports Ground
OSF - private
8.32
44.70%
2.70%
OS112
Highshore Open Space
Pocket Park
0.09
27.00%
69.80%
OS104
St Giles’ Churchyard
Small Local Park
1.05
34.10%
65.40%
OS105
Lucas Gardens
Small Local Park
1.73
49.10%
77.10%
PN3
Montague Square
Pocket Park
0.11
27.80%
68.60%
OS111
Warwick Gardens
Small Local Park
1.53
34.00%
71.70%
OS115
McDermott Grove Nature
Garden
Allotments
0.13
34.00%
71.70%
Above Average Quality and
Value
OS141
Friern Road Allotments
Allotments
0.17
12.00%
62.20%
Below Average Quality and
Value
OS148
Plough Lane Pond
Other
0.04
OS113
Holly Grove Shrubbery
Linear Open Space
0.32
22.20%
67.50%
Below Average Quality and
Value
OS131
The Gardens Square
Amenity space
0.33
17.50%
66.40%
Below Average Quality and
March 2016
gva.co.uk
Above Average Value, Below
Average Quality
Below Average Quality and
Value
Above Average Value, Below
Average Quality
Above Average Quality and
Value
Below Average Quality and
Value
Above Average Quality and
Value
Greendale Property Company Ltd
Planning Statement
Value
OS154
Dulwich Library Garden
Greenspaces within
grounds of institution
Sub total
0.34
43.90%
79.90%
Above Average Quality and
Value
14.16
Within c. 2km
OS157
DC Playing Fields and Sports
Ground (West)
OSF - education
14.93
41.30%
73.20%
Above Average Quality and
Value
OS161
DC Playing Fields and Sports
Ground (East)
OSF - education
4.66
30.60%
77.80%
Above Average Quality and
Value
OS159
Dulwich Park
Metropolitan Park
30.85
84%
84.80%
OS118
Nunhead Green
Pocket Park
0.28
35.80%
70.30%
OS116
Consort Park
Pocket Park
0.34
26.70%
67.50%
OS108
Nunhead and railway
empbankments
Natural of seminatural greenspaces
4.97
18.70%
65.40%
OS106
Bellenden Road Tree Nursery
Allotments
0.07
24.10%
66.00%
PN2
Lyndhurst Square
Amenity Greenspace
0.03
25.80%
60.00%
375
Central Venture Park
Provision for young
people and
teenagers
0.23
31.20%
80.90%
OS101
Brunswick Park
Local Plan
1.6
42.10%
79.10%
OS100
Camberwell Green
Small Local Park
0.89
39.40%
79.30%
OS160
Belair Park
Local Park
10.6
67.30%
74.60%
OS158
Dulwich Picture Gallery Grounds
2.36
49.30%
87.80%
OS155
Dawson’s Hill/Dawson Heights
2.8
29.80%
49.60%
March 2016
gva.co.uk
Greenspaces within
grounds of institutions
Natural of seminatural greenspaces
Above Average Quality and
Value
Above Average Value, Below
Average Quality
Below Average Quality and
Value
Below Average Quality and
Value
Below Average Quality and
Value
Below Average Quality and
Value
Above Average Quality and
Value
Above Average Quality and
Value
Above Average Quality and
Value
Above Average Quality and
Value
Above Average Quality and
Value
Above Average Value, Below
Average Quality
Greendale Property Company Ltd
Planning Statement
Above Average Quality and
Value
Above Average Quality and
Value
OS149
Camberwell Old Cemetery
Cemeteries
11.85
36.10%
75.30%
OS153
Burbage Road Playing Fields
OSF - private
6.23
37.40%
74.10%
OS124
Peckham Rye Park and
Common and Piermont Green
Metropolitan Park
42.75
72.30%
84.60%
Above Average Quality and
Value
OS97
Benhill Road Nature Garden
Natural or seminatural
greenspaces
0.21
16.4%
49.6%
Below Average Quality and
Value
OS102
Sumner Park
Pocket Park
0.37
28.5%
76.2%
Above Average Quality,
Below Average Value
OS10
Nelson Square Gardens
Small Local Park
0.40
23.6%
70.4%
Below Average Quality and
Value
OS11
Grotto Podiums
Outdoor Sports
Facilities
- private
0.03
13.3%
78.4%
Above Average Quality,
Below Average Value
OS162
Southwark Sports Ground
OSF - private
2.63
40.0%
63.8%
Above Average Value, Below
Average Quality
OS163
Barclay Way
Amenity space
0.39
16.3%
69.9%
Below Average Quality and
Value
Sub total
139.47
TOTAL (excluding current / proposed Site provision)
192.18
March 2016
gva.co.uk
Report
Appendix 3
Draft S106 Heads of Terms
Greendale Property Company Ltd
Planning Statement
DRAFT S106 Heads of Terms
Introduction
This appendices sets out the draft Heads of Terms for the Development and has been
considered in relation to Southwark Council’s Section 106 Planning Obligations and
Community Infrastructure Levy (CIL) SPD (April 2015).
This note has two sections. The first refers to S106 contributions that are specific to the
proposed development. The second refers to standard S106 charges, as detailed in Appendix
1 of the Council’s SPD.
Site Specific S106:
The below contributions are site-specific measures, relating to the particular nature of the
proposed development.
Item
Details / timings
Transfer of DHFC to fan
ownership and management
Following the practical completion of the stadium and associated
facilities, the ownership and management of Dulwich Hamlet
Football Club will be transferred to fan ownership in the form of an
appropriately established Community Benefit Society.
Transfer of stadium to
charitable and / or public
ownership
Following the practical completion of the stadium and associated
facilities, the ownership of said facilities will be transferred to a
charitable leisure provider and/or LB Southwark.
Completion of stadium prior to
residential development
No residential development shall commence prior to the practical
completion of the stadium and associated facilities.
Construction of stadium to
ensure minimal disruption to
DHFC
Phasing of stadium construction in line with appropriate construction
programme to ensure that Dulwich Hamlet Football Club do not
groundshare or are temporarily relocated
Open Space improvements at
Green Dale Playing Fields
The Developer will undertake improvement works at Green Dale
Playing Fields in accordance with the approved plans prior to the
occupation of 50% of residential dwellings.
Stadium made available to
local schools, community and
sports groups
The stadium and associated facilities shall be made available for use
by local schools, community and sports groups. An indicative
programme of use has been provided later in this appendix,
including an element of free use to local schools.
New vehicular access
Construction of vehicular access to stadium and highway
modifications in accordance with submitted plans.
March 2016
gva.co.uk
Greendale Property Company Ltd
Planning Statement
Standard / Financial contributions:
The below contributions have been considered under Appendix 1: ‘Standard charges and
detailed guidance’ of Southwark’s SPD. A detailed table of contributions / explanations is
included below.
Item
Contribution
Affordable Housing
Affordable housing
onsite provision - 16.12%
(unit basis) and 15.91%
(hab room basis)
Notes
n/a
Not located within archaeological priority
zone
In-kind
Scheme design compliant with carbon
reduction targets
In-kind
Scheme design complaint with play space
requirements
S106 to include
commitment to
employment and
training scheme
Targets to be agreed with Council for the
employment of unemployed Southwark
workers, short courses and apprenticeships
Employment and enterprise:
General and end-user phase
n/a
Development provides no B class space,
and only minimal, ancillary A class space
Employment and Enterprise:
Loss of employment
floorspace
n/a
No loss of employment space
Employment and enterprise:
Other obligations
n/a
Not an employment led scheme
In-kind
Scheme design compliant with outdoor
amenity space requirements
n/a
Not a student housing scheme
Archaeology
Carbon off-set – Green Fund
Children play space
Employment and Enterprise
(jobs and construction
period)
Outdoor amenity space
Student Housing: University
schemes
Public realm measures
March 2016
gva.co.uk
In -kind
Public realm improvements provided via
improvements within Red Line Boundary,
including Linear Park and Green Dale
Playing Fields improvements)
Greendale Property Company Ltd
Planning Statement
Transport measures
n/a
Wheelchair accessible
housing: Offset fund
In-kind
March 2016
gva.co.uk
Contributions for transport measures are
sought through site specific measures.
None are proposed for this site, as per the
Travel Assessment.
Scheme design compliant with wheelchair
accessible housing requirements
Greendale Property Company Ltd
Planning Statement
Standard charges and detailed guidance (Appendix 1, SPD 2015) – Explanation of contributions
DHFC Draft Heads of Terms Contributions
Summary of Policy Requirement (S106
and CIL SPD 2015)
Obligation
Policy Compliant
Contribution (£)
DHFC Financial
contributions
In kind benefits
Affordable
Housing
35% on site provision of hab rooms
n/a
n/a
Affordable housing
onsite provision 16.12% (unit basis)
and 15.91% (hab
room basis)
Archaeology
n/a
n/a
n/a
n/a
March 2016
gva.co.uk
Notes
Not located within archaeological
priority zone
Greendale Property Company Ltd
Planning Statement
DHFC Draft Heads of Terms Contributions
Obligation
Summary of Policy Requirement (S106
and CIL SPD 2015)
Policy Compliant
Contribution (£)
DHFC Financial
contributions
In kind benefits
Carbon reduction targets are set out
as minimum improvements over the
Target Emissions Rates (TER) in the
Building Regulations (Part L)
Carbon Offset - Green
Fund
The current minimum target is a 40%
improvement on the 2010 Building
Regulations for both domestic and
non-domestic buildings, as set out in
London Plan policy 5.2.
Contribution = £1,800 per tonne of
carbon dioxide shortfall below 40%
improvements on 2010 building regs
March 2016
gva.co.uk
n/a
In-kind
Scheme design
policy compliant in
terms of carbon
reduction
requirements
Notes
Greendale Property Company Ltd
Planning Statement
DHFC Draft Heads of Terms Contributions
Obligation
Children's
play space
Employment
and
Enterprise
(jobs and
construction
period)
Summary of Policy Requirement (S106
and CIL SPD 2015)
10sqm of play space per child (all
developments with an estimated
child occupancy of 10+). Shortfall
charged at £151 per sq. m
One job lasting minimum 26 weeks for
unemployed Southwark resident per
500 sqm GEA (shortfall = £4,300 per
resident)
One Southwark resident trained in pre
or post-employment short courses per
500 sqm GEA (shortfall = £150 x
shortfall)
One new apprenticeship start or in
work NVQ per 2,000 sqm (£1,500 x
shortfall)
March 2016
gva.co.uk
Policy Compliant
Contribution (£)
n/a
DHFC Financial
contributions
n/a
n/a
NIL
(assumed that
training scheme
will be provided
by applicant)
(requirement will be
met through
agreement of
targets with the
Council and an
obligation for the
Development to
provide own
programme and/or
work with council
programmes)
In kind benefits
Scheme design
policy compliant in
terms of play space
requirements
The Applicant to
discuss
commitment to an
employment and
training scheme
through the Section
106 to include
targets for the
employment of
unemployed
Southwark
workers, short
courses and
apprenticeships.
Notes
Greendale Property Company Ltd
Planning Statement
DHFC Draft Heads of Terms Contributions
Obligation
Employment
and
enterprise:
General and
end-user
phase (skills
training and
employment)
March 2016
Summary of Policy Requirement (S106
and CIL SPD 2015)
Policy Compliant
Contribution (£)
DHFC Financial
contributions
In kind benefits
Notes
Employment and training
contributions, set at the target
number of jobs, multiplied by £4,300
n/a
n/a
n/a
n/a - no B class use provided, retail
element is small / ancillary
gva.co.uk
Greendale Property Company Ltd
Planning Statement
DHFC Draft Heads of Terms Contributions
Obligation
Employment
and
enterprise:
Loss of
employment
floorspace
March 2016
Summary of Policy Requirement (S106
and CIL SPD 2015)
Policy Compliant
Contribution (£)
DHFC Financial
contributions
In kind benefits
Notes
£4,300 multiplied by 10% of FTE that
may have been provided in
equivalent amount of (net) loss
floorspace
n/a
n/a
n/a
n/a - no loss in existing employment
space
gva.co.uk
Greendale Property Company Ltd
Planning Statement
DHFC Draft Heads of Terms Contributions
Obligation
Summary of Policy Requirement (S106
and CIL SPD 2015)
Policy Compliant
Contribution (£)
DHFC Financial
contributions
In kind benefits
Notes
n/a
n/a
n/a
Not an employment led scheme
Additional employment and
enterprise obligations, may include:
Employment
and
enterprise:
Other
obligations
March 2016
- provision of affordable business or
retail units when required within area
based planning policy documents
- local procurement and supply chain
measures
relocation assistance for existing
businesses
gva.co.uk
Greendale Property Company Ltd
Planning Statement
DHFC Draft Heads of Terms Contributions
Obligation
Summary of Policy Requirement (S106
and CIL SPD 2015)
Policy Compliant
Contribution (£)
DHFC Financial
contributions
In kind benefits
Houses: A minimum of 50sqm of
private amenity space is required
Flats: A minimum of 50sqm of
communal amenity space per
development.
Outdoor
Amenity
Space
For units containing three or more
bedrooms 10sqm of private amenity
space must be provided.
For units containing two or less
bedrooms, 10sqm of private amenity
space should be provided.
Shortfall = charged at £205 per sqm
March 2016
gva.co.uk
n/a
n/a
Scheme design
policy compliant in
terms of outdoor
amenity space
requirements
Notes
Greendale Property Company Ltd
Planning Statement
DHFC Draft Heads of Terms Contributions
Summary of Policy Requirement (S106
and CIL SPD 2015)
Obligation
Public Realm
Measures
March 2016
Costed site by site
gva.co.uk
Policy Compliant
Contribution (£)
n/a
DHFC Financial
contributions
n/a
In kind benefits
Public realm
improvements
within red line e.g.
linear park, green
dale fields
improvements
Notes
Greendale Property Company Ltd
Planning Statement
DHFC Draft Heads of Terms Contributions
Obligation
Student
Housing:
University
Schemes
March 2016
Summary of Policy Requirement (S106
and CIL SPD 2015)
Policy Compliant
Contribution (£)
DHFC Financial
contributions
In kind benefits
Notes
n/a
n/a
n/a
n/a
Not a student scheme
gva.co.uk
Greendale Property Company Ltd
Planning Statement
DHFC Draft Heads of Terms Contributions
Obligation
Transport
measures
March 2016
Summary of Policy Requirement (S106
and CIL SPD 2015)
Policy Compliant
Contribution (£)
DHFC Financial
contributions
In kind benefits
Notes
Site specific
n/a
n/a
n/a
As per Travel Assessment
gva.co.uk
Greendale Property Company Ltd
Planning Statement
DHFC Draft Heads of Terms Contributions
Obligation
Wheelchair
accessible
housing:
offset fund
March 2016
Summary of Policy Requirement (S106
and CIL SPD 2015)
Mitigation will be sought where
schemes cannot meet the minimum
10% wheelchair accessible housing
requirement identified in the
Residential Design Standards SPD
(2011)
gva.co.uk
Policy Compliant
Contribution (£)
n/a
DHFC Financial
contributions
n/a
In kind benefits
Scheme design
policy compliant in
terms of wheelchair
accessible housing
requirement
Notes
Greendale Property Company Ltd
Planning Statement
Indicative usage plan - proposed DHFC pitch
Day
AM
12PM-4PM
4PM-6PM
6PM-7PM
7PM-8PM
8PM-9PM
9PM-10PM
10PM-10.30PM
Monday
COMMUNITY
COMMUNITY
ACADEMY
COMMERCIAL
COMMERCIAL
COMMERCIAL
COMMERCIAL
CLOSED
Tuesday
COMMUNITY
CHARTER
SCHOOL
ACADEMY
DHFC
DHFC
DHFC
DHFC
BUFFER
Wednesday
COMMUNITY
ACADEMY
ACADEMY
COMMERCIAL
COMMERCIAL
COMMERCIAL
COMMERCIAL
CLOSED
Thursday
COMMUNITY
CHARTER
SCHOOL
ACADEMY
DHFC
DHFC
DHFC
DHFC
CLOSED
Friday
COMMUNITY
COMMUNITY
ACADEMY
COMMERCIAL
COMMERCIAL
COMMERCIAL
COMMERCIAL
CLOSED
ACADEMY
DHFC
DHFC
DHFC
COMMERCIAL
COMMERCIAL
COMMERCIAL
CLOSED
COMMUNITY
DHFC
DHFC
COMMERCIAL
COMMERCIAL
COMMERCIAL
COMMERCIAL
CLOSED
Saturday
Sunday
March 2016
gva.co.uk
Greendale Property Company Ltd
Planning Statement
Indicative usage plan - proposed MUGA
Day
AM
12PM-4PM
4PM-6PM
6PM-7PM
7PM-8PM
8PM-9PM
9PM-10PM
10PM-10.30PM
Monday
COMMUNITY
COMMUNITY
ACADEMY
ACADEMY
ACADEMY
ACADEMY
ACADEMY
CLOSED
Tuesday
COMMUNITY
COMMUNITY
COMMUNITY
COMMERCIAL
COMMERCIAL
COMMERCIAL
COMMERCIAL
CLOSED
Wednesday
COMMUNITY
COMMUNITY
COMMUNITY
COMMERCIAL
COMMERCIAL
COMMERCIAL
COMMERCIAL
CLOSED
Thursday
COMMUNITY
COMMUNITY
COMMUNITY
COMMERCIAL
COMMERCIAL
COMMERCIAL
COMMERCIAL
CLOSED
Friday
COMMUNITY
COMMUNITY
COMMUNITY
COMMERCIAL
COMMERCIAL
COMMERCIAL
COMMERCIAL
CLOSED
Saturday
COMMUNITY
COMMUNITY
COMMUNITY
COMMERCIAL
COMMERCIAL
COMMERCIAL
COMMERCIAL
CLOSED
Sunday
COMMUNITY
COMMUNITY
COMMERCIAL
COMMERCIAL
COMMERCIAL
COMMERCIAL
COMMERCIAL
CLOSED
March 2016
gva.co.uk