Letter to the Lewisham planning department, April 7th 2021

I am writing on behalf of the Tewkesbury Lodge Estate Residents’ Association, which speaks for almost 300 households around the site of the proposed development described in the Lewisham Plan as “ the Havelock House/Telecom Mast/ Willow Tree House Site”.

Our Association is working closely with the Council to green our environment. We have raised the funds for 50 street trees which the Council has planted on our streets in the area of the proposed development. We are also working with the Council to develop a green area with the help of a Greening Fund Grant from the Council.

We welcome the recognition of the woodland heritage that is highlighted in Lewisham’s Plan for its West Area (The Lewisham Plan page 733) , and we are glad that proposals for development will be expected to “integrate urban greening to respond to and to connect with the remnants of the woodland” (Ie the Great North Wood (The Lewisham Plan p 737)

We have carefully considered the proposal for “The Havelock House/Telecom Mast Site / Willow Tree House Site” but at present we feel that we must oppose it for the following reasons. We think that in its present form the proposal is contrary to many of the principles that are set out in the Council’s Development Plan.

1. Green space. Within the Green Infrastructure (Section 10) section of the plan is the statement that “The Council will seek to deliver net gains in biodiversity (and support the London Plan to be 50% green by 2050”. More specifically for the West Area, Point 9 of the objectives is to “Protect and enhance open and green spaces along with the distinctive woodland character of the area” . The proposed development of The Telecom Site will reduce the area of green space within the Borough by more than any other proposed site mentioned in the development plan for Lewisham West, and possibly by more than any other proposed site in the plan for the whole of Lewisham.

2. The Great North Wood. The Development Plan for the West Area makes welcome reference to remnants of the Great North Wood that can still be seen in Forest Hill (see paras 18.2, 18.8, 18.9, 18.13). These remnants form a wildlife corridor between Sydenham Woods and One Tree Hill, both of which are recognised as Nature Reserves in the London Borough of Southwark. The proposed development site is one of the best parts of the Great North Wood that we have in Forest Hill, and for that matter in Lewisham. The Council should make sure that it retains not only all the Oak trees on the skyline but also the other areas of natural woodland that lie below, between The Telecom Mast and both Willow Tree House and Havelock House.

Wildlife habitats. On page 368 of the Plan is the statement in para 10:11 that “It is imperative that wildlife habitats are protected and appropriately managed so that their special biodiversity value is maintained and, ideally, improved over the long-term.” The current wildlife value of the site is demonstrated by the following and recent observations.

A pair of Peregrine Falcons bred there last summer. The Peregrine is at the top of the food chain, and “our” Peregrines would have preyed on small birds over the whole of the development site. A flock of 50 Redwing arrived from Scandinavia just before Christmas and 5 remained around the site until March. The site forms an important link in the wildlife corridor – see below.

3. Wildlife corridors. As described in paras 2 and 3 above, the Oak trees on the development site are part of a wildlife corridor which traces the course of the former Great North Wood from Sydenham Woods to One Tree hill. Woodland birds still migrate along this corridor.

In Spring there are Chiffchaff, Willow Warblers and Blackcap (regularly), Buzzard and Red Kite (occasionally) and Hobby and Firecrest (rarely).

In late Summer there are Chiffchaff, Willow Warblers and Garden Warblers (regularly) and Pied Flycatchers (rarely).

In Winter there are Redwing (regularly) and Brambling, Siskin and Redpoll (rarely)

4.Biodiversity. Rare downland grasses, plants and invertebrates have been found on the nearby Honor Oak Road Reservoir Site, and a similar survey of the grassy slopes of the proposed development site would be prudent. We welcome the mention in the Plan of the need to survey all mature trees. However there are areas of hedge and scrub which add to the biodiversity of the site. For example they provide nesting sites for song birds which construct open nests, which are vulnerable to predation by squirrels and domestic cats. Blackbirds in particular have almost disappeared from our area.

5. Net gains in biodiversity.We recommend that additional native trees other than Oak be planted on the proposed development site, partly to shield existing residents from the sight of the two masts that are on the site, but also to increase biodiversity. This would support the Council in its Plan “to deliver net gains in biodiversity (and support the London Plan to be 50% green by 2050)”. We are working with the Council to raise funds to plant native Hornbeam on the nearby Horniman Triangle to increase the biodiversity of our Great North Wood remnants: they are equally needed on the Telecom Site.

Other concerns. As well as our concerns for the natural environment we also have the following concerns about the development of the site.

1. If the Telecom Mast is to be retained, then the recommendations of the Stewart Report should be followed, and local accommodation should not be built in close proximity to the Mast.

2. Again if the Telecom Mast is to be retained, it would not be safe for a public footpath to pass close to such a potentially dangerous construction.

3. Also, if the Telecom mast is to be retained it will not be possible to accommodate 30 residential units without radically changing the character of the site. According to The Plan’s map, there is insufficient space for the construction of the 30 additional homes that are described in the plan, if they are to be built in the style of buildings already on the site and around it.

4. Finally, the steep gradient of the site makes the creation of “the feel of a village green” (as described in the Plan) unrealistic.

Conclusions

We recognise that there is a pressing need for additional housing, and we know that the Council is obliged to meet the target of providing 1667 new homes every year. But the Council is also committed to “to deliver net gains in biodiversity (and support the London Plan to be 50% green by 2050)”. On this site, which may be the greenest site in the Plan, we think that the needs of the environment should come first.

For these reasons we urge the Council to remove the The Telecom Mast, Willow Tree House and Havelock House from its Development Plan.

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