19/AP/1867

Redevelopment of the Dulwich Hamlet Football (Champion Hill) Stadium, including the demolition of existing buildings, and use of land at Greendale, to provide: - the erection of a new stadium with relocated playing pitch with associated floodlighting and boundary treatment, and part two-part three storey clubhouse building with sports and leisure facilities, with capacity for 4,000 spectators (Use Class D2); - the construction of a multi-functional kickabout space and associated boundary treatment; - the erection of a series of buildings between four and six storeys in height to provide 219 residential dwellings, (Use Class C3); - associated car parking, cycle parking, refuse storage and access road; - creation of a new public linear park route with associated hard and soft landscaping; - the relocation of telecommunications equipment and re-provision of the substation together with plant and equipment.

GENERAL PREMISE

The application proposals, in putting forward residential dwellings, contravene the 1990 Section 106 legal agreement in relation to Dulwich Hamlet Football Ground.

The proposals include development on Metropolitan Open Land contrary to The London Plan and Southwark policy.

Should this legislation be somehow overcome then opinion is divided in the Camberwell Society regarding this application.

A summary of the opinions expressed for and against the proposed development:

SUPPORT FOR THE PROPOSALS

1. Stadium and pitch: The new stadium and football pitch will provide improved sports, leisure and social facilities for DHFC and the local community including schools and local residents. It will enable DHFC to continue with its programme of matches without interruption and facilitate its potential promotion into higher leagues. The Multi Use Games Area will also provide sporting opportunities for local people.
2. The pitch is to be sited on land at present occupied by a dilapidated and under-used astroturf pitch. As this is Metropolitan Open Land with a characteristic open aspect, it is to be sunk into the ground and with a 4.5m high mesh fence on the perimeter, with canvas screens to a height of 1.83m to be raised on match days.
3. There is some concern that this boundary arrangement does not meet with Football Association rules, so as a precaution, if planning permission were to be granted, a condition should be attached stating that a more solid boundary arrangement would not be permitted as it would damage the open-ness of the MOL.
4. The planning conditions should also stipulate that the drainage arrangements for the new sunken pitch are to be approved in advance by Building Control because of concerns that a significant amount of rainwater might need to be disposed of.
5. The remainder of the MOL: Green Dale Fields immediately to the north and west of the pitch will remain untouched by the development except for planting to improve the wildlife habitat including the old tennis courts.
6. Residential development: The residential element of the proposal, consisting of 6 blocks of flats between 4 and 6 storeys high. They are appropriate in scale for the area and will make a useful contribution to the supply of private and affordable housing.
7. Each flat will have a private balcony and each block will have a semiprivate rooftop garden for the use of the residents.
8. The Green Link: There will be landscaped public open space with pathways and children’s play areas around and between the blocks and a continuous green link between St Francis Park in the east to the MOL playing fields and Green Dale Fields in the west. Some existing mature trees will be lost as a result of the development, but 93 semi mature trees will be planted.
9. The green link would introduce planting and encourage wildlife and prove a better neighbour for the houses in Abbotswood Road and Burrow Road than the existing dead end road and 8 foot high pre-cast concrete panel fence alongside the back of the existing pitch and spectator stand.

AGAINST THE PROPOSALS

1. The Dulwich Hamlet Football Club should be obliged to continue to play on its existing site. This would be in accordance with the covenant restricting its use to recreational, leisure or educational purposes. DHFC’s chair and principal shareholder maintain that £1M worth of repairs are needed on the existing building/pitch and the Council has generously pledged to meet the cost of requisite improvements. There is no immediate requirement to do works to expand capacity to 5000 before the club gains promotion to the National League Premier, (likely to be at least 30 or 42 months away) and the League normally allows a transition period for minimum work to be done. This work could be done during a summer break and a move to a “ground share” (which would affect attendance and revenue) could be avoided if the part of the road running along the south side were used for the required additional 1,000 seating and terracing. Meadow showed us that this was part of the pitch when it erected fences during its period of evicting the club. Under DHFC future plans an increase in capacity would entail further deleterious encroachment on to, or enclosure of, MOL. As regards DHFC’s finances, when the Astro turf pitch was used for five-a-side football, it produced income of £3,000 to £4,000 a week for about 40 weeks p.a. A return to full operation (together with the rental of the ground on weekdays) would solve DHFC’s financial problems and provide a useful local amenity.

2. Theproposed Meadow pitch and terraces would be built on Metropolitan Open Land. This land is currently occupied by an Astro-turf pitch together with five-plus acres of currently semi-wild green open ground. Any building on this MOL would adversely affect areas identified as a Site of Importance for Nature Conservation (SINC).These areas are home to several protected species.

The London Plan clearly states that the strongest protection should be given to London’s MOL and inappropriate development refused, except in “very special circumstances”. “Essential ancillary facilities” for appropriate uses will only be acceptable where they “maintain the openness” of MOL.

The ostensible requirements of a private company such as DHFC does not constitute “special circumstances” such as to permit building on MOL given that it already has somewhere to play (per the Inspector who heard the appeal in 2004) - nor is the proposed stadium an “essential ancillary” facility. Given FA requirements for solid, visually impermeable 8-foot-high walls, the proposals cannot “maintain the openness of MOL”.

The London Plan states that “Development that involves the loss of MOL in return for the creation of new open space elsewhere will not be considered appropriate”, therefore the proposed narrow green link to neighbouring green spaces is not acceptable compensation for the loss of MOL on Green Dale.

3. It will be necessary to remove some 250 metric tonnes of soil on the “North bank” and even more from the pitch to construct the pitch one foot below the existing ground level; this will be disruptive and increase flood risk. The lowered ground would be susceptible to drainage problems - unacknowledged by the application. Green Dale Fields are often boggy after rainfall. Thames Water will not want all this muddy water in the sewer system, and it is unclear where it would be pumped to.

4. The proposed 1.83m (6 foot) high canvas screens to be raised around the ground when matches are in progress would not meet Football Association requirements for 8-foot solid wall perimeter screening, and are impracticable. They would necessarily be replaced with a permanent 8-foot enclosing wall. Such a structure would differ from the screens described in the application and would permanently obstruct views across the MOL, in breach of local policy.

5. The character of Greendale, unique in inner-London, would be irrevocably changed by this development, re-wilding reversed, and wildlife habitats destroyed. The development would have an unacceptably harmful impact on the proposed SINC, building on which contravenes local policy. The “green link” or “linear park” proposed in mitigation is a footpath that runs alongside a cycle path and would be heavily used by the 716 new residents of the proposed flats and the thousands of fans accessing the southern turnstiles on match days; it would therefore not be a suitable habitat for wildlife.

6. The row of mature trees at the edge of the proposed pitch which have a further life span of 20-120 years would be removed if the development were to proceed. It would be decades before new trees proposed as part of the development provided the same canopy cover and benefits to the community and to wildlife. Mature trees offer significantly more environmental protection than saplings and should be retained wherever possible in a Climate Emergency.

7. The stadium building on Green Dale and consequent floodlighting and noise pollution will impact not only the proposed Meadow flats and existing local residents but also very substantially on wildlife, including protected species such as pipistrelle bats. Phone masts may cause damage to children and young people.

8. The proposed flats of 4-6 stories are inappropriately tall in relation to the two-storey houses of Abbotswood Road, to which they would stand in proximity.The planned flats are unlikely to provide an appropriate level of affordable housing and a CPO enabling the Council to build on land adjacent to the ground would be welcomed.

9. The scheme is contrary to policy in removing ‘Open Land’ from the community: such land is a much used and needed facility for physical activity. The proposed open access MUGA to replace the currently freely accessible Astro-turf pitch is a twentieth of its size and would not be freely accessible to all.

10.The site is subject to a Section 106 agreementas part of the 1990 Planning Approval allowing the adjacent site to be developed as a Sainsbury’s supermarket and car park. This is a legally binding agreement dated 16th October 1990 stipulating “with effect from the effective date Dulwich Hamlet Football Ground shall only be used for leisure or recreational or educational purposes and buildings whether permanent or temporary shall only be built erected constructed on or overhang Dulwich Hamlet Football Ground if they are used for all or any of those purposes”.

The proposal contravenes that legal agreement and, on that basis alone, cannot be allowed.

IN CONCLUSION:

Although the Camberwell Society recognises the councils need to deliver more housing in the area, it cannot support this proposed development and in particular with reference to points 2 (MOL) and 10 (S106).

The Camberwell Society was formed in 1970 and is the recognised amenity society for those living, working or interested in Camberwell. Unusually for a planning application, there are many comments from those living far beyond the local areas and therefore we trust the Council in assessing the representations takes into account the differences between those comments of the community and those of the wider football fan base.