Comments can be made in writing or via email and sent to the following addresses. You can also leave comments on Southwark’s online consultation hub page here

You can send your comments in by:

Email: planningpolicy@southwark.gov.uk

By Post:

New Southwark Plan consultation

FREEPOST SE1919/14

Chief Executive’s Department

5th Floor Hub 2

Southwark Council

London

SE1P 5LX

The deadline for comments on the latest consultation is 12 February so don’t delay and feel free to copy us in on any responses or ask us questions.

As with the planning application comments, the Council will take more notice of unique responses rather than pro forma letters. We suggest you draw upon the following points:

East Dulwich Area Vision

Para 10.1.1 – Welcome the support for Dulwich Hamlet and suggest that this be strengthened to explicitly reference the valuable community function played by the Club.

Para 10.1.2 – When referencing development in East Dulwich, it would be helpful if the Council acknowledge the need for an improved and expanded stadium for Dulwich Hamlet. Whilst we understand within the context of the outstanding planning appeal, this may be challenging, there does appear to be little dispute over the fact that an improved facility would be to the benefit of the community; the debate is simply about where this ground should be. As such, the high level strategic nature of the Southwark Plan does not need to be prescriptive and can simply acknowledge that a bigger and better stadium would be of benefit to the local area.

Site Allocation NSP38

The allocation of 30 units figure for proposed residential development potential is highly questionable. This fails to optimise the capacity of the site and sets an unnecessarily low target that is not in general conformity with the London Plan and in particular, Policy 3.4 (Optimising Housing Potential) and Table 3.2 (the Density Matrix). The allocation of the site as being in a Suburban setting is extremely misleading in light of the clear urban context of the site and its surroundings. The London Plan defines Suburban context as being:

“areas with predominantly lower density development such as, for example, detached and semi-detached houses, predominantly residential, small building footprints and typically buildings of two to three storeys.”

Apart from a small number of late-20th Century houses immediately south of the site, no element of the area conforms to this definition.

The London Plan definition of an Urban context is as follows:

“areas with predominantly dense development such as, for example, terraced houses, mansion blocks, a mix of different uses, medium building footprints and typically buildings of two to four storeys, located within 800 metres walking distance of a District centre or, along main arterial routes”

This is a far more appropriate description of Champion Hill and its surroundings and we request that the allocation be changed to reflect this. We note that the design guidance now omits mention of mixed-use development including taller buildings. The exclusion of this wording was not noted in the consultation report. Given that a number of the existing residential buildings surrounding the site generally go up to 5 storeys high and, that the impact of taller buildings is mitigated by the gradient of the land being as it is, on a hill, we can only conclude that this has been excluded to support a lower site capacity which we have already raised concerns with in points 3-5.

The methodology paper – whilst an interesting exercise – is directly in contravention of the GLA in the London Plan and we would recommend the document be found unsound if not amended to reflect the GLA’s established, sound and well-reasoned methodology. This matter goes beyond local distinctiveness; it is effectively contradicting established policy that has already been found sound by the Secretary of State.

As a result, the allocation for NSP38 is woefully under-delivering in terms of the net housing gain it can contribute to Southwark’s housing targets.

We previously requested that the stadium itself (not just a pitch) be added to the list of required uses within the allocation with the explicit caveat that should an alternative facility be provided on Green Dale or elsewhere in close proximity, there will be no requirement to retain the existing stadium. We acknowledge the inclusion of the associated stadium facilities in the indicative development capacity however, the existing area of these facilities (1,696 sqm) has not been included. We would assume (and hope) that this is a minor error and will be corrected? If there is a reason for its exclusion we would request that an explanation is provided.

We would also note that should an alternative facility for the Football Club be provided on Green Dale or elsewhere in close proximity, then we would request that the alternative facility is completed prior to any development of the existing ground such that DHFC can continue to use the stadium without interruption before moving to the new location.

The designation of Other Open Space (OOS) for the pitch within the allocation is counterintuitive. The initial designation was put in place to secure the future of the club from unwelcome development. However, in doing so, there is now a serious risk that it now prevents a future stadium from being built in the area.

Open space and a high quality public realm is clearly an essential aspect of any new development, but this should not simply be a numbers game. The OOS designation was never about size of the space, it was about the use. If a stadium that secures the future of the club can be provided elsewhere, the OOS designation should not stunt that development.

The required uses should be revisited to provide the following:

• a football stadium containing a pitch of 7,685 sqm, ancillary club facilities (Class D2) of no less than 1,696 sqm and a capacity of no less than 3,000 spectators (should no alternative facility be provided within 250m of this site)
• C3 residential uses
• Open space commensurate with the scale of development

Request that the Site Vision be changed to ensure references to the retention of the OOS and the ground need only be retained should an alternative facility not be forthcoming.