Southwark Green Party objects to the proposal by Dolphin Living for the old Hunnex site at 35-39 Parkhouse Street, in Camberwell, just south of Burgess Park. This is for a 6-10 storey building with 100 flats.
This is one of several applications for tall buildings around the perimeter of Burgess Park, risking permanent destruction of the habitat and character of the park. (We have previously objected to the earlier Burgess Business Park proposal.) It is important not to set a precedent by approving this application.
Our key objections to this application are:
1) the buildings are too tall, in breach of Southwark Council policy
2) the residential density is too high, also in breach of policy
3) the development would have a detrimental impact on Burgess Park in terms of biodiversity and public use
4) lack of local public transport.
We support the building of new homes for social rent, but this development would be 65% market rent and only 15% social rent. There is no shortage of unaffordable homes in Southwark! In initial public consultations, the developers proposed to provide 50% 'affordable' homes, but this has now been reduced to 35% (the minimum required by Southwark).
1) Inappropriate site for tall buildings
Under Southwark Council’s adopted policy, this site is not suitable for tall buildings.
A tall building is one that is either over 30m or significantly taller than its surroundings. Policy 3.20 of the current Southwark Plan says “Planning permission may be granted for buildings that are significantly taller than their surroundings or have a significant impact on the skyline, on sites which have excellent accessibility to public transport facilities and are located in the Central Activities Zone.”
The Burgess Business Park area does not have excellent accessibility to public transport (see below), and it is not in the Central Activities Zone.
The draft New Southwark Plan has not yet been examined in public. Under the National Planning Policy Framework decisions should not be made on draft policy. Southwark Green Party has in any case objected to draft Policy P14 (tall buildings) with special concern about the detrimental effect of tall buildings on Burgess Park.
If approval is given for this development it would set a precedent for other tall buildings in this area, leading to a drastic change to the townscape and low-rise character. It would be fundamentally wrong to allow this to happen before the new policy has been examined in public.
The site is 0.24 hectares. Adopted policy is set out in Strategic Policy 5 of Southwark’s Core Strategy, which says urban density is expected to be 200-700 habitable rooms per hectare. Maximum density would be 168 habitable rooms (0.24 x 700 = 168 habitable rooms). The total number of habitable rooms for the proposal is 340 – double what is permitted under current policy. The excessive density is due to the excessive height of the development.
3) Detrimental impact on Burgess Park wildlife and park users
Burgess Park is a Site of Importance for Nature Conservation (SINC). This development would overshadow the nature reserve area and would therefore harm biodiversity. We appreciate the investment that has gone into Burgess Park in recent years (including the £3.5M Burgess Park West project completed in 2019), with attention to appropriate and diverse planting for bees and other pollinators. Substantial shade will change the habitat, the types of plants and reduce suitability for many insects, butterflies and moths which in turn will impact on bats and birds. To allow the nature reserve to be overshadowed would waste this vital investment at precisely the moment when every effort needs to be made to preserve and create new habitats for nature in London.
More widely, inappropriately tall buildings on the border of Burgess Park will permanently change its character. At the moment, park users can enjoy many long vistas that culminate with mature trees. This is a vital contrast to the dense urban surroundings of the park. Natural England makes a distinction between 'accessible green space' such as parks and 'natural green space' where 'human control and activities are not intensive so that a feeling of naturalness is allowed to predominate'. Such spaces can exist within urban parks, and it's important to preserve them.
Long shadows during the winter months will extend to the main path through the park, affecting the safety of the new path and cycle route. It will remain frosty all day long in the winter on the part nearest the nature reserve.
4) Inadequate public transport
There is already huge pressure on the Wells Way bus routes at rush hour, with commuters and schoolchildren unable to board buses due to overcrowding. Changes made to bus services in 2019 mean some local routes have been changed, curtailed, or had their frequency reduced.
As Wells Way Tenants and Residents Association has pointed out, the Transport Statement in the application contains a number of inaccuracies, many of which are repeated in the Framework Travel Plan, so these documents are not robust or reliable. Notably, the census data used is from Faraday ward, rather than St Giles ward.
TfL rates areas according to their Public Transport accessibility. The planning documents state that the site has a PTAL rating of 2, but wrongly say that this is ‘excellent accessibility’. PTAL 2 means poor accessibility. The documents also claim that a PTAL rating of 2 is ‘inaccurate’.
The developer assumes that the Camberwell Road buses are within walking distance. They are 700m from the site. The CIHT guidance is that most people will not walk more than 400m to a bus stop.
The planning application is here, and is open for comments until Friday 10 January. This post quotes from the analysis of the planning application carried out by members of Wells Way Tenants and Residents Association. We're grateful to them. More details here.