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.