Chapter 3 OPEN SPACE

Introduction

1. Open space in Lewisham is one of the Borough’s greatest assets. From the large expanses of Blackheath in the north and Beckenham Place Park in the south, to the many medium sized and smaller spaces between, the range of open space is widely used and greatly appreciated by all Lewisham’s residents.

2. The policies in this Chapter can be put into four categories:
• those concerned with the largest and most significant pieces of open space, which have a value felt beyond Lewisham’s boundaries, and as a result are designated Metropolitan Open Land (MOL);
• those for open spaces which together form a green corridor or a green chain, which in some cases also attracts the protection of MOL designation;
• those for ‘other’ pieces of open land, in this sense ‘other’ meaning non-MOL, including areas of open space deficiency and temporary open space; and
• policies which specifically protect certain pieces of open space because of the use to which the land is put (sport and recreation) or some additional quality of that land (its value for nature conservation).

Part I Policies

STR.OS 1
To protect all open space in the Borough from inappropriate built development.

STR.OS 2
To seek to provide additional open space in the Borough, particularly in areas identified as deficient in accessible provision.

STR.OS 3
To protect and wherever possible enhance nature conservation and biodiversity in the Borough.

Reasons for Part I Policies

3. Open space in Lewisham, in public and private ownership, makes up nearly 14% of the Borough’s land area. There are nearly 300 hectares of Metropolitan Open Land and just over 300 hectares of land designated as Site of Nature Conservation Importance (SNCI). There are over 40 public parks, within which there are 62 football pitches, 4 cricket squares, 6 bowling greens and a public golf course. These facilities are supplemented by 20 private sports grounds.

4. The principal role of the land use planning system with respect to open space is to protect that open space from development. Without this level of basic protection from development, no active or passive recreation, no amenity or ecological benefit, and no management action to enhance the use of the open space will be possible.

5. The UDP therefore concentrates on policies that will retain and protect the existing quantum of open space in Lewisham. However, the principal ‘uses’ of open space - simply put, these are recreation, ecology and sport – are also clearly planned for. It is acknowledged that planning has a role in facilitating and promoting these ‘uses’ but their success or failure is primarily a management issue and reference is made throughout the Chapter to other policy statements of the Council that concentrate specifically on management of different aspects of open space.

6. The structure of this Chapter reflects these priorities with the protective planning policy designations addressed first, followed by the policies that address uses of open space, such as nature conservation and sport and recreation.

The Council’s Strategy

7. The value of open space in a built-up residential Borough cannot be overstated. Whether for formal participation in team sport, informal use such as walking or dog-walking, as a place to find space for peaceful relaxation, to enjoy the natural environment or simply to be reassured by its presence, open space is critical to modern urban living.

8. The protection of open space in a physically confined urban environment is essential to the smooth functioning of the urban society. The contribution open space makes to sustainability is relatively straightforward. It is on and around Lewisham’s protected open space that the bulk of the Borough’s nature conservation interest is supported and it is the same open space that through its protection today will be available for future generations to enjoy. Open space contributes to the quality of life of Lewisham residents, so in this sense also it can help to create a more sustainable environment, one in which people will continue to want to live, work and learn.

9. Equality is furthered by the Plan’s designations and protection of open space. The designations of open space distinguish those spaces that are accessible to all, as the bulk in Lewisham are, and those that are in private ownership. It is by opening up access to the spaces in private ownership that the goal of free access to all open space for all may be realised. In any event the visual benefits and calming presence of open space in the stressed urban environment are certainly enjoyed by all residents and visitors in Lewisham.

10. The protection of open spaces will assist regeneration in Lewisham. An attractive environment, in which open space makes a valuable contribution, is crucial in changing perceptions of the Borough as a place to live, work and learn. In this respect the provision of open space is one of Lewisham’s strengths.

Part II Policies

The Council will be supportive of proposals that enhance these uses and will only permit the limited extension of buildings within MOL where this would not result in a disproportionate addition over and above the size of the original building. Improved public access to appropriate land uses in MOL will be acceptable where it does not conflict with other environmental objectives.

Reasons
The main criteria for designation of MOL are:
• land which contributes to the physical structure of London by being clearly distinguishable from the built up area;
• land which includes open air facilities, especially for leisure, recreation, sport, arts and cultural activities and tourism which serve the whole or significant parts of London; and
• land which contains features or landscape of historic, recreational, nature conservation or habitat interest, of value at a metropolitan or national level.

The aim of the MOL policies is to make clear that, by analogy with Green Belt policy nationally, development in or adjacent to these areas will only be acceptable in special circumstances. The intention to protect the essentially open quality of MOL is supported by the extension of the protection to land immediately adjacent, if the development of this could result in encroachment, including visual encroachment, on the essentially open character of the MOL.

The MOL designations in Lewisham are at: Blackheath; Beckenham Place Park and the main open spaces in the South East London Green Chain; Hither Green Cemetery including land in the vicinity east of the railway line; and open land adjoining Waterlink Way. (See the Proposals Map for detailed boundaries).

RPG 3 makes clear that designation as Metropolitan Open Land of pieces of land which are either too small or only locally significant, for example, will devalue the strength of the designation as a whole. In view of this the sites at Berthon/Bronze Street and St Paul’s Churchyard in Deptford previously designated as MOL have now been redesignated as Public Open Space – see Policy OS 7. Also, the ‘built up areas’ on Blackheath, at Blackheath Vale and Hollyhedge House, which were previously omitted from MOL designation are now included.

Metropolitan Open Land in Lewisham represents the most significant areas of land of predominantly open character that have a more than Borough significance. RPG3 makes clear that the level of protection of MOL is comparable to that given to Green Belt. The policies are intended to clearly signal that no development on Lewisham’s MOL will be allowed, unless this facilitates uses that require, preserve, maximise or enhance the existing open nature and character of the MOL.

Reasons
The South East London Green Chain (SELGC) is a well established series of inter-linked open spaces that extend through Lewisham, and the neighbouring boroughs of Bexley, Greenwich and Bromley. These open spaces are in public and private ownership, largely in recreational use, and serve as a valuable amenity, landscape and conservation resource for the wider south east London region. The SELGC is of regional significance and is therefore designated as MOL. The Green Chain Walk in Lewisham is shown on the Proposals Map.

The aims of the SELGC Joint Committee (comprised of 2 members from each of the boroughs of Lewisham, Bexley, Greenwich and Bromley) have been agreed as follows:
• to improve and encourage the provision of suitable recreational facilities with an emphasis on those serving a wide area of south east London and/or requiring open land;
• to safeguard the open land from built development and maintain its structural contribution in providing a visual break in the built-up area of London;
• to conserve and enhance the visual amenity and ecological aspects of the landscape;
• to improve the public access to and through the area;
to promote an overall identity for the area in order to increase public awareness of available recreational facilities; and
• to encourage the collaboration and co-operation of the various public and private agencies, owners, organisations, clubs etc., in the area to achieve the above objectives.

Waterlink Way is a local Green Chain, within Lewisham, comprising a linked network of open spaces, waterways and pedestrian and cycle routes from Beckenham Place Park to Deptford Creek, following the line of the rivers Ravensbourne, Quaggy and Pool. This group of sites was identified as a Gateway open space and pedestrian link into the SELGC in the Green Chain Policy Document (Green Chain Joint Committee, 1977). For these reasons is it designated as MOL.

Reasons
RPG3 defines Green Corridors as extensive contiguous areas of trees and open land which straddle major routes into London. Lewisham’s transport corridors carry large volumes of traffic. The immediate environment of such corridors leaves on transport users an impression of the Borough as a place to live, work and learn. In the interests of people who regularly pass through them or live nearby these corridors should present a positive image of the Borough’s environmental quality.

Green Corridors in Lewisham consist of open spaces, together with pieces of land that link them. Several Green Corridors are designated as Sites of Nature Conservation Importance (see OS 12 and OS 13) linked by less valuable areas for nature conservation that nevertheless have significant enhancement potential. These linked open spaces can provide opportunities for informal recreation, such as walking or cycling, and are also capable of acting as a conduit for flora and fauna to penetrate the urban environment.

Public access to many of Lewisham’s green corridors is denied, for example, along railway cuttings. Following advice from the London Ecology Unit (LEU), all green corridors in Lewisham are protected and identified on the Proposals Map.

Lewisham’s rivers (a short section of the Thames, and longer stretches of the Ravensbourne and its tributaries the Pool, Quaggy and Spring Brook) provide important linear features which can form the basis for wildlife corridors, as well as the Waterlink Way (see Policy OS 4) and the Thames Path (see Policy URB 25), and are important to sustain biodiversity. The Council considers that buffer zones around watercourses can help to maintain the character of rivers and provide undisturbed refuges for wildlife. Where possible the Council will seek the implementation of these zones (see also Policy URB 26 on the Thames Foreshore). The culverting or building over of watercourses will require the consent of the Environmental Agency. The Council considers that such works can increase flood risk, and should generally be resisted as it results in a break in the continuity of river corridors, and adversely affects nature conservation interests.

Reasons
In planning terms, other open space refers to those open spaces that are not designated as Metropolitan Open Land (MOL). These spaces are designated as Public Open Space (POS) or Urban Green Space (UGS). The definitions of POS and UGS are as follows:

Public Open Space comprises public parks, commons, heaths and woodland and other open spaces with established and unrestricted public access and capable of being classified according to an open space hierarchy (though not necessarily publicly owned), which meets recreational and non-recreational needs within the urban area.

Urban Green Space is open space to which public access is restricted or not formally established but which meets or is capable of meeting recreational or non-recreational needs within the urban area.

Other open spaces are an important element of the urban structure which are not large or significant enough to merit the additional designation as MOL but are nonetheless valuable in providing breaks in the built-up area, enhancing townscape, providing space for recreation and assisting nature conservation.

All open spaces identified on the Proposals Map have been designated as either POS or UGS and set out in Table OS 5. The designation as POS or UGS is intended to ensure that these valuable open spaces of a variety of types and in a variety of uses are protected from inappropriate development.

The basis of the distinction between POS and UGS is the level of public accessibility. The UGS designation recognises that although the land may not currently be accessible it may still perform a valuable open space function, for example as a visual amenity affording a much appreciated break in the urban fabric; or simply by remaining open many residents and others value its presence. The level of planning protection offered by each designation, POS and UGS, is equal and strong.

Allotments in Lewisham are protected as Urban Green Space.

The opportunities for creating new open space in a constrained and heavily urbanised borough like Lewisham are few. However, there are opportunities for enhancing access to existing open spaces, either, for example, by negotiation with the land owner about land the subject of redevelopment proposals, or by installing new entrances to existing parks. It is through negotiations of this sort that Urban Green Space may be converted into Public Open Space thereby going some way to address the difficulties of creating new open space.

Reasons
Table OS 1 sets out the LPAC hierarchy of publicly accessible open space types in London, and Table OS 3 the classification of Lewisham’s public parks according to this hierarchy. Table OS 1 shows the type of open space, its size and characteristics and the distance from home each sort of park should be, ideally. If a residential area is more than the prescribed distance from a park of the prescribed size, then that area is said to be deficient in Public Open Space at that level of the hierarchy. The Areas of Open Space Deficiency in Lewisham (at the level of the Local Park) are shown on Map 3.1.

Open space within new housing schemes, however small, can be extremely valuable to the residents of the scheme and the Council will seek to include such space within housing schemes. Often these spaces may be centred on any existing natural feature of local value, such as a mature tree or pond.

The Council’s own research (Parks Audit 1997) showed that 73% of park users surveyed travelled less than ¼ of a mile to use a park. This emphasises the importance to dense urban areas like Lewisham of the smallest-sized parks in the LPAC hierarchy, Small Local Parks and Open Spaces, journeys to which tend to be short. And it is on the basis of access to Small Local Parks that the open space deficiency calculation has been made. Map 3.1 shows those parts of the Borough that are not within 400m of a Public Open Space.

Reasons
By bringing vacant sites into use as temporary open space the public enjoy an additional recreational resource, the Borough looks cleaner and the cost to the owner of securing the site may be reduced.

Reasons
Trees make an important contribution to the urban environment in visual terms. Many trees in Lewisham have an amenity value and merit protection by virtue of their size or the prominence of their location. Trees also contribute to biodiversity and help to abate air pollution by creating oxygen, acting as a lung for Lewisham. Trees of amenity value are often located in or on the fringe of the Borough’s open spaces. The contribution of trees in this setting is valuable to the appearance and quality of the Borough’s environment. See also Policy URB 13 Trees.

Reasons
The trend for a more active lifestyle and greater health awareness amongst the public has contributed to the growth in the leisure and recreation industry over the last decade or so. This, in combination with the continued requirements of organised outdoor team games has ensured that the sport and recreation demands on Lewisham’s open spaces remain strong.

The role of the planning system is to protect open space that is used primarily for outdoor sport and recreation from inappropriate development that would deny the residents of Lewisham and the members of its sports clubs their recreational opportunities. The Council also has a Sport and Recreation Strategy which focuses on the strategic management and planning of the sports facilities in the Borough.

The sport and recreation use of Lewisham’s open space is of great community value. This Policy is designed to protect and enhance provision for outdoor sport and recreation in the Borough and to facilitate implementation of the Council’s Sport and Active Recreation Strategy, which takes account of Sport England’s policies. The Sport and Active Recreation Strategy is based on an assessment of the likely future requirement for sports pitches in Lewisham.

Sports fields in Lewisham are already protected through their designation as either POS or UGS and in some cases MOL (see policies above), but their use for outdoor sports affords them the additional protection of this Policy.

The importance to the Government of protecting school playing fields is indicated by their recent introduction of a package of measures to prevent their loss. The Government has issued, as part of these measures, a Direction under the GPDO that makes Sport England a statutory consultee on proposals for development which affect playing fields, land used as playing fields in the last five years which remain undeveloped, or land which is identified for use as a playing field in a development plan. See also Policy LCE 3 Educational Playing Fields.

Perhaps inevitably, in light of its inner city location, Lewisham falls well short of national playing field standards, either the National Playing Field Association ‘six acre standard’ or more recent Schools Premises Regulations (1996). Yet the demand for pitches continues to increase. In order to address this apparent mismatch, the Council’s Sport and Active Recreation Strategy seeks to rationalise and maximise the use of existing space. The Strategy includes a five-point action plan specifically for sports facilities and playing fields.

The pressure for development on Lewisham’s sports fields is felt most keenly on those that are in private ownership. While all of these spaces are protected as UGS (some as MOL too) they are nonetheless often the subject of inquiries from developers, who are aware possibly that the development value created by a housing permission would be very attractive to the owners. The sites set out in Table OS 2 are those that the Council is particularly keen to see retained in outdoor sport and recreation use.

Reasons
The conservation and enhancement of Lewisham’s natural habitat is a crucial aspect of planning for the Borough. The natural habitat of the Borough encompasses :
• woodlands and scrub;
• grassland; rivers and wetlands;
• ponds and lakes;
• wastelands;
• parks and gardens; and
• cemeteries and churchyards.

In 2000 the London Ecology Unit documented sites of Nature Conservation Importance in Lewisham (see Ecology Handbook 30, Nature Conservation in Lewisham, London Ecology Unit, 2000). The LEU identified sites according to the following categories:
• Sites of Metropolitan Importance, which contain the best examples of London’s habitats;
• Sites of Borough Importance Grade 1;
• Sites of Borough Importance Grade 2, which contain sites of importance from a Borough perspective and where damage could mean a loss to the Borough; and
• Sites of Local Importance, which are sites of particular value to nearby residents and schools and are particularly important in areas that are otherwise deficient in nearby wildlife sites.

The Sites in Table OS 4 have been identified as being of the greatest nature conservation value and are protected and managed in order to enhance their value. The Sites in Table OS 4 are shown on the Proposals Map. Full details of each Site are set out in the LEU handbook, Nature Conservation in Lewisham, and a summary of their nature conservation value appears in Schedule 2. The Council recognises that other, non-designated sites can have a nature conservation value. The nature conservation interest of these will be taken into account in making planning decisions affecting them. These sites can be particularly valuable in those parts of the Borough identified in Map 3.3 as being deficient in accessible nature conservation areas.

New development should provide the opportunity to incorporate features for wildlife and to promote local biodiversity. Schemes should be designed to retain natural features on a site and to create new features to encourage wildlife and to promote local distinctiveness. New features could include green roofs which can make considerable contributions to local biodiversity. Further advice on green roofs will be contained in the Council’s forthcoming SPG on Sustainable Development.

There is also a series of potential Local Nature Reserves (LNRs) in the Borough. LNRs are designated by local authorities under Section 21 of the National Parks and Access to the Countryside Acts 1949. LNRs are habitats of local significance that make a useful contribution to nature conservation and the opportunities for the public to see, learn about and enjoy wildlife; they must be designated in consultation with English Nature (EN). Those in Lewisham remain ‘potential’ LNRs because the land ownership and management issues are not yet resolved to the standard required for EN’s authorisation. It is anticipated that during the Plan period many of these LNRs will be given formal designation by the Council and English Nature. Management briefs for the LNR sites are being prepared by LEU; this will facilitate applications for their formal designation. All potential LNRs coincide with Sites of Nature Conservation Importance (SNCIs) and are therefore protected as SNCIs by this Plan.

The Lewisham Biodiversity Action Plan (LBAP) is being prepared by a partnership of statutory and non-statutory groups (including the Council) voluntary bodies and individuals. It is more directly concerned with nature conservation and the management of land in the Borough. It is an audit of habitat and species data which incorporates habitat and species action plans and proposes monitoring and a three-yearly review to see which species and habitats have been lost and which gained. The LBAP will also identify a series of indicator species. The Biodiversity Action Plan is essentially a vehicle for the raising of public awareness of wildlife and biodiversity issues and an action plan to address those in public and private land management.

Additional advice is available from the Council’s Nature Conservation Officers and Local Agenda 21 Officers.

Reasons
LPAC in their 1997 report ‘Planning for Burial Space’ estimated that Lewisham had only a six year supply of burial space left at its four operational cemeteries. The Report recommends selective re-use of old graves as the best way of addressing this problem in London.

The land use issues surrounding a shortage of burial space primarily concern the possibility of valued open space being used for burials, or the environmental degradation of existing cemeteries, many of which have significant nature conservation value, by squeezing in new graves, or through landraising. For these reasons the LPAC report recommends selective re-use of graves. Certain changes in legislation and public opinion may be required before re-use can be entertained as a viable solution and until these changes are made, the role of the planning system is limited.

Reasons
The Register of Historic Parks, Gardens and Landscapes carries no statutory force but the Council must take care in carrying out its development control functions so that historic gardens and other historic parks, gardens and landscapes are not affected by encroaching or adjacent new development. The Council will investigate opportunities for reinstating historic landscape settings and links between them, including avenue planting and vistas.

The following sites in Lewisham are included in the Register, together with plans defining the relevant areas:
• Horniman Gardens, Grade II; and
• Manor House Gardens, Grade II

Both Gardens have the added protection of being within Conservation Areas.

The Borough also has a number of ‘London Squares’ protected from development by the London Squares Act 1932. The Council will seek to protect and enhance these Squares. Their location is shown on Map 3.2.
The Council is also preparing a list of Public Parks, Gardens, Square, Cemeteries and Churchyards of Local Historic Interest, which are protected by various policies in this Plan, and which will be available as Supplementary Planning Guidance.

Reasons
The Member States of UNESCO adopted the Convention concerning the Protection of World Cultural and Natural Heritage in 1972. This Convention provided for the creation of the World Heritage Committee which, in 1997, inscribed the area formed by Greenwich Town Centre and Greenwich Park as one of fourteen World Heritage Sites in the United Kingdom and dependencies. This area has thus been recognised as being of ‘outstanding universal value from the historical, aesthetic, ethnological or anthropological point of view’.

A World Heritage Site ‘Buffer Zone’ has been declared for Blackheath in order to provide an area of special policy consideration for developments that may be visible from within the World Heritage site.

Although no additional statutory controls flow from the inclusion of a site in the World Heritage List, or the declaration of an area as a Buffer Zone, the inclusion does highlight the outstanding international importance of the site as a key material consideration to be taken into account when determining planning and listed building consent applications. PPG 15 ‘Planning and the Historic Environment’ places great emphasis on the need to protect them for future generations as well as our own. Development proposals affecting these sites or their settings need to be compatible with this objective and require careful scrutiny, often by way of formal environmental assessments, to ensure that their immediate impact and their implications for the long term are fully evaluated. The Buffer Zone is also protected by Conservation Area designation.

Reasons
According to PPG 9 ‘Nature Conservation’ the presence of a protected species or its habitat is a material consideration when the local planning authority is considering a development proposal which if implemented would be likely to result in harm to the species or habitat. Certain plant and animal species, including all wild birds, are protected under the Wildlife and Countryside Act 1981. Where development is permitted that may affect protected species, the Council will impose conditions where appropriate, and seek to use its powers to enter into planning agreements to: facilitate the survival of individual members of the species; reduce disturbance to a minimum; and provide adequate alternative habitats to sustain at least the current levels of the population. The Act sets out the nationwide protection afforded to certain rare or under threat wild animals and plants.

Table OS1

Table OS2

Table OS3

Table OS4

Table OS5

Map 3.1

Map 3.2

Map 3.3