COMMENTS ON
REVISED 18/AP/0532
Redevelopment of the site involving the demolition of the existing
two-storey residential block and single storey garages; and the
construction of a 5-storey block on the corner of Champion Hill and Dog
Kennel Hill and a 5/6-storey block on the corner of Champion Hill and
the adjacent estate road, to provide 14 x 1 bed, 14 x 2 bed, 7 x 3 bed
and 1 x 4 bed residential units (36 units) together with associated
landscaping.
The revised application has not taken into account the Camberwell
Society’s previous comments, which are repeated and expanded upon here.
The Camberwell Society has several concerns regarding this application:
1. The first is that the proposed buildings are bigger than every other
building, existing and proposed, in the immediate vicinity of the site.
The sketch view of the area on page 8 of the Design and Access Statement
identifies all the buildings in the vicinity that are over four storeys
high, whilst ignoring the buildings opposite the site in Champion Hill,
which are the buildings closest to the site, and range from one to three
storeys.
The applicants have also sought to exaggerate the impact of the 5 storey
building proposed for 1A Dog Kennel Hill by making it seem that the 1A
DKH site and the application site are at the same level. In fact there
is a change in level equal to a storey height between the application
site and the 1A DKH site. The cross section of block B on page 30 shows
this clearly. The slope of the site makes it possible for an extra
storey to be added on the downhill site of block B, alongside the site
of 1A DKH.
The overall effect of the development is that the two new blocks are
overbearing in relation to their immediate neighbours, exacerbated by
their immediate proximity to the pavement edges of Dog Kennel Hill and
Champion Hill.
Five storey blocks of flats are well represented on the east side of Dog
Kennel Hill, but on the west side there is a more varied style of
development, including landscaped gardens, a narrow seven storey block
of flats. a children’s playground, a nursery, a car park and some two
storey semi-detached houses.
2. The second, related problem is the effect of the development,
particularly block A, on the proposed development at 1A Dog Kennel Hill.
This development of 9×5 storey houses was granted permission in March
2011 on the basis that its principal orientation was to the north, to
avoid overlooking of the houses to the south. The introduction of a 5
storey building 12m away from the 1A DKH principal elevation contravenes
the Council’s own guidelines contained in the Southwark Residential
Design Standards 2011, which specify the amount of daylight required in
habitable rooms:
Residential developments should maximise sunlight and daylight, both
within the new development and to neighbouring properties. Development
should seek to minimise overshadowing or blocking of light to adjoining
properties. A lack of daylight can have negative impacts on health as
well as making the development gloomy and Daylight and sunlight tests on
the impact of the new development on neighbouring properties Daylight
tests. This test should be used where the proposed development faces the
affected window of the neighbouring property
1. Draw a line at 25 degrees upwards from the centre of the affected
window.
2. If the proposed development is higher than this 25 degree line,
there may be an unacceptable loss of daylight to the affected window.”
The daylight received on every floor of the 1A DKH block would fail to
meet the required levels if block A were to be built. In January 2016
Bell Phillips Architects prepared a feasibility study for Southwark
Council on their proposed Seavington House development. The study
concluded that one of the risks associated with the scheme was “Close
proximity to proposed residential scheme. Note further information is
required regarding the proposed residential scheme in order to assess
the potential impact on daylight/sunlight”
and in conclusion:
“Impact of daylight and sunlight to be assessed. Particularly in
relation to the proposed development at 1A Dog Kennel Hill”
In July 2018 Point 2 Surveyors produced two surveys: Daylight and
Sunlight Report on the effects on existing buildings of the proposed
development and Scheme Internal Daylight report on the daylight inside
the proposed development. As part of the Daylight and Sunlight Report
Point 2 identified 1A Dog Kennel Lane (sic) as a building of interest,
but claimed that “We sought to undertake a detailed internal ADF
assessment on the neighbour in conjunction with the other methodologies
below, however, it transpired that the plans and elevations on Southwark
Planning Portal are not consistent with each other and, therefore, we
have not been able to complete the assessment.”
The Camberwell Society does not consider this to be an acceptable reason
for failing to carry out the tests described above because:
1. Weston Williamson have included numerous plans, sections and
elevations of the proposed houses at 1A Dog Kennel Hill as part of this
planning application, taken presumably from the application drawings on
the Planning Portal and
2. Because Block A is located 12m away from the north elevation of 1A
Dog Kennel Hill it is obvious that striking a line at an angle of 25
degrees upwards from almost any point on the elevation of 1A DKH will
show that the proposed block is too close and too high for Southwark’s
daylighting standards to be achieved. It seems likely that this is why
Point 2 Surveyors did not wish to use this method.
Point 2 Surveyors state that the 1A Dog Kennel Hill houses have been
sited close to the northern edge of the site and this has reduced the
quality of adjoining development land to the north. This would entitle
the owner of the adjoining land to meet less demanding standards of
daylight for the adjoining building than would otherwise be required:
“We refer to BRE Guidance section 2.3 entitled ‘Adjoining Development
Land’: “From a daylighting standpoint it is possible to reduce the
quality of adjoining development land by building too close to the
boundary. A well designed building will stand a reasonable distance back
from the boundaries so as to enable future nearby developments to enjoy
a similar access to daylight. By doing so it will also keep its own
natural light when the adjoining land is developed.” (BRE Guide 209,
paragraph 2.3.1).
Under the circumstances it is appropriate to consider setting
alternative target values for skylight access as detailed within
Appendix F of the BRE Guide. “…in cases where an existing building
has windows which are unusually close to the site boundary…To ensure
that new development matches the height and proportions of existing
buildings, the VSC and APSH targets could be set to those of a
‘mirror-image’ building the same height and size, an equal distance away
from either side of the boundary.”
The Camberwell Society does not consider this to be an acceptable
argument for setting a lower target for daylighting for 1A Dog Kennel
Hill because of the decision taken by the planning inspector at the
appeal on the John Smart application 05/AP/2192 for development of the
1A Dog Kennel Hill site in 2005. He wrote:
” The council expressed concern that the proposal could prejudice the
development potential of the adjoining property to the North. This is
partly a green open space with trees and partly a car park which I
understand from the appellant’s statement is used by the residents of
nearby flats. I recognise that the position of the proposed building on
the appeal site means that it would be close to the boundary with this
site. However no evidence has been submitted to indicate that there is
any prospect of the adjoining site being available for development….In
these circumstances I can attach very little weight to this matter in
determining the appeal.”
The Planning Inspector’s decision in May 2006 that the Seavington House
site was unlikely to be developed was one of the considerations which
resulted in the inspector granting planning permission for the 1A Dog
Kennel Hill development at the appeal.
It is too late now to claim that the location of the houses on the site
has caused the Seavington House site to be devalued as a development
site — it had already been decided by the planning inspector that it
had no prospect of being developed and therefore the siting of the
houses at 1A was not prejudicial to it.
Point 2 Surveyors claim that daylight to neighbouring buildings should
be treated flexibly where that the proposed development is a conversion
of an existing building:
“3.5 It is important to remember that the BRE Guide states that ‘the
advice given here is not mandatory and should not be seen as an
instrument of planning policy’. Furthermore, daylight criteria should be
‘interpreted flexibly because natural lighting is only one of many
factors’. Based upon these statements it is important to apply the
guidance and target levels sensibly and flexibly taking into account the
context of the site as a conversion of an existing building.”
The experience of the Camberwell Society Architects on the Planning Sub
Committee is that Southwark enforce their daylighting and sunlighting
guidelines assiduously in relation to private applications and that they
should do the same in relation to their own applications.
Point 2 is incorrect in stating that the Seavington House development is
a conversion of an existing building — it is clearly a new building.
3. Overlooking: The Southwark Residential Design Standards 2011 also
state that “House and flat developments should be arranged to safeguard
the amenity and privacy of occupiers and neighbours. New development,
extensions, alterations and conversions should not subject neighbours to
unacceptable noise disturbance, overlooking or loss of security. “
There are numerous vantage points for overlooking 1A DKH from block A,
including from living room windows, balconies and roof terraces, which
makes the proposals unacceptable in terms of privacy. The application
states that the 12m gap between the two buildings is council policy
(pages 19&20 of the Design and Access Statement), but the Residential
Design Standards state that this is an acceptable gap only in relation
to the front of a dwelling facing a street, and the required gap at the
back of a dwelling is 21m. This should be considered the appropriate
standard in this case.
4. The residential accommodation that is provided in this proposal
barely meets the minimum space standards required. It is difficult to
imagine for example how 6 people could live a full life in the 4 bedroom
flat apparently thought suitable for that number (page 41 of the Design
and Access Statement). There is also very little amenity space, and what
there is lies between Block A and 1A Dog Kennel Hill, and impinges on
the privacy of the prospective residents of 1A Dog Kennel Hill.
Summary:
The proposed flats are too large and domineering in the context of the
scale of the existing buildings in the immediate area. They are built on
the pavement edge whilst the existing buildings are all set back from
the pavement, giving the hilltop a feeling of open-ness and space.
They contravene Southwark guidelines for daylight and privacy in a
neighbouring building. They provide cramped accommodation and inadequate
amenity space for the prospective residents.
For these reasons the Camberwell Society objects to this application.