Response to the Greenwich Local Plan

EGRA are in the process of drafting our response to the Local Plan’s latest round of consultation. You can see the main points below - anyone who is interested is very welcome to feedback or get in touch on info@egra.london

You can see the documents for the Local Plan on the Council Website here

1. Executive Summary & Context 

The East Greenwich Residents Association (EGRA) welcomes the publication of the Regulation 19 Draft Local Plan and the accompanying Consultation Statement. While we recognize the Council’s efforts to respond to initial community feedback from the Regulation 18 consultation, significant gaps remain between high-level policy intent and the lived, daily experience of East Greenwich residents.  

East Greenwich is an urban neighbourhood within the Greenwich, Westcombe Park, and Blackheath spatial area. It faces unique development pressures, sitting between major Opportunity Areas (Greenwich Peninsula and Charlton Riverside), carrying designated high-density growth while retaining historic, low-rise residential streets. Below, we review areas where the Council has addressed our concerns, identify unresolved issues, and submit further feedback on specific policies, including Controls on Houses in Multiple Occupation (HMOs).  

2. Assessment of Addressed vs. Unaddressed Issues from EGRA’s Initial Feedback 

East Greenwich District Centre & Infrastructure

The initial feedback highlighted issues regarding overdevelopment, a lack of social facilities, severe pressure on open space, and the failure of the district centre to adequately serve local residents. In response, the Council has partially addressed these concerns by strengthening Policy P1 in the Regulation 19 draft, introducing clearer place-based criteria and higher expectations for social infrastructure, active frontages, public realm upgrades, and community uses. However, EGRA maintains an ongoing concern that detailed implementation mechanisms and dedicated Section 106 or CIL funding ring-fenced specifically for East Greenwich infrastructure remain unclear.

Tall Buildings & WHS Heritage Protection

EGRA previously expressed concerns regarding over-density along the riverfront, the encroaching impact of tall buildings on low-rise residential areas, and potential harm to the setting and views of the Maritime Greenwich World Heritage Site (WHS) buffer zone. The Council partially addressed this by updating Policies P1 and DH5 to emphasize the protection of Outstanding Universal Value (OUV) and require Heritage Impact Assessments. Despite these additions, safeguards against tall building encroachment directly adjacent to low-rise residential areas along the East Greenwich riverfront remain unaddressed and require much stronger boundary definitions.

Open Space & Urban Greening

Initial representations stressed that East Greenwich suffers from a severe deficiency in open space without any dedicated funding or spatial remedies identified. The Council has addressed this in part by expanding Policy P1 to enhance green and blue infrastructure, improve ecological quality along Deptford Creek and the Thames, and introduce stronger urban greening criteria. Nevertheless, the issue remains unaddressed at a practical level, as the Plan still lacks firm capital allocations or site acquisitions to cure local open space deficits.

Student Housing (PBSA) & Conversions

Concerns were raised regarding the overconcentration of Purpose Built Student Accommodation (PBSA) and the ongoing trend of family housing developments morphing into student blocks. In the Regulation 19 draft, Policy H5/H6 partially addresses this by retaining overconcentration safeguards and introducing a cascade mechanism to prioritize lettings for local higher education providers. However, the Plan still fails to provide an explicit policy mechanism preventing developers from converting consented family housing schemes directly into PBSA.

Delivery, Takeaways & Gig Economy Logistics

EGRA submitted evidence of persistent nuisance, illegal and dangerous driving—such as on Fingal Street—and severe pavement obstruction caused by commercial delivery fleets and courier operations. This issue remains entirely unaddressed in the revised draft; while Policy TC6 manages hot food takeaways in a general sense, it omits mandatory off-street parking, waiting, and loading requirements for delivery scooters and e-bikes. Action is urgently required to mandate off-street delivery management and implement physical street-filtering measures through development management conditions.

Short-Term Lets (Airbnb)

Previous feedback pointed to a glaring omission regarding the proliferation of short-term holiday lets, which drain permanent housing stock and erode community cohesion in high-density tourist areas. This issue remains unaddressed, as the Local Plan still lacks an explicit local policy constraint or dedicated planning enforcement framework to manage and cap short-term holiday conversions. EGRA requires formal monitoring thresholds and active planning enforcement policies for short-term lets across high-tourist zones.

Bugsby’s Way / Charlton Retail Corridor

The initial submission highlighted the Council's failure to recognize the commercial retail clusters along Bugsby’s Way as a de facto town centre, leaving major pedestrian safety hazards unaddressed. This area remains unaddressed within spatial Policy P3, where it continues to be designated strictly for industrial/mixed-use without formalizing active travel or safe pedestrian crossing upgrades along the corridor. EGRA requests immediate modal-share data collection and mandatory pedestrian safety improvements along this primary shopping destination.

3. Specific Policy Feedback: Houses in Multiple Occupation (HMOs) & Shared Living (Policies H6 / H8) 

While Policy P1 describes East Greenwich alongside wider spatial designations, its character is fundamentally defined by dense, urban, Victorian and Edwardian terraced streets. We note that the Council has combined HMOs and Shared Living policies under unified management in the Regulation 19 draft (combining former H5/H7 into Policy H6/H8).  

EGRA Feedback on Revised HMO Controls: 

• Support for Increased Thresholds: EGRA strongly supports raising the minimum original property size threshold for HMO conversions from 90 sq m to 130 sq m. This directly protects smaller 2–3 bedroom Victorian terraced homes in East Greenwich from sub-division, preserving vital family housing stock.  

• Support for Street-Level Assessment: Moving overconcentration assessments from a ward-wide metric to a street-level assessment is a critical, positive step. Ward-level data obscured localized clusters where individual streets faced severe parking, waste, and anti-social behavior pressures.  

• Concerns on Contextual Classification: The Plan’s justification text implies tighter HMO restrictions are intended primarily for "suburban" settings. EGRA stresses that urban, high-density residential areas like East Greenwich are even more susceptible to overcrowding and street-level degradation than traditional suburbs.  

• Policy Requirement: Policy H6 must explicitly state that the 130 sq m threshold, street-level saturation caps, and mandatory off-street waste/cycle storage apply equally to dense urban terraced contexts as well as suburban housing, preventing high-density neighborhoods from being designated as "higher capacity" dumping grounds for low-quality conversions.  

4. Concluding Recommendations 

To ensure the Regulation 19 Local Plan is found sound and effective, EGRA requests the following minor modifications before submission:  

1. Enforce Developer Delivery on Riverfront & Public Realm: Strengthen Policy P1/DH8 to mandate strict enforcement on industrial operators (e.g., along Tunnel Avenue and river wharves) to complete agreed Thames Path upgrades and public realm maintenance.  

2. Implement Deliveroo/Delivery Hub Controls: Update Policy TC6 to require physical, off-street waiting spaces for commercial delivery fleets and enforce vehicle filters on narrow residential side streets (e.g., Fingal Street).  

3. Protect Consented Family Housing: Add clear policy wording under Policy H1/H3 preventing the conversion of approved C3 residential schemes into PBSA or Co-Living space via non-material amendments.  

Our previous recommendations from the earlier round of community feedback are below:

Context and Introduction

The East Greenwich Residents Association (EGRA) has officially submitted our response to the Royal Borough of Greenwich Draft Local Plan (Regulation 18) consultation. As a community-led organisation, our mission is to create a cleaner, safer, and more vibrant neighbourhood where everyone can thrive.

While we support the broad ambition for sustainable growth, we have voiced significant concerns that the current draft risks facilitating over-development without the necessary infrastructure, eroding our local character, and failing to address the day-to-day realities of our residents.

Housing, density, and heritage

We are deeply concerned by the potential dilution of safeguards regarding tall buildings. The designation of the East Greenwich riverside for tall buildings risks encircling our low-rise neighbourhoods with out-of-scale tower blocks, potentially eroding the value of the Maritime Greenwich World Heritage Site.

Furthermore, we have observed a worrying trend of projects intended for family homes morphing into Purpose Built Student Accommodation (PBSA). These units do not alleviate local housing pressure and are difficult to repurpose. We are calling for:

• Reinstatement of explicit protections for low-rise residential amenity.

• Strict controls to prevent the loss of family housing to student units.

• A robust strategy to manage the proliferation of short-term holiday lets (like Airbnb).

Retail and town centres

EGRA believes that Greenwich Town Centre has effectively ceased to serve local residents, as it is dominated by chain outlets catering to tourists. Simultaneously, the Plan continues to ignore the reality of the Charlton Retail Zone (Bugsby’s Way), which serves as the primary shopping area for our community. We urgently need:

• A management plan that prioritises resident needs alongside tourism.

• Formal recognition of the Bugsby's Way retail clusters to justify vital investment in pedestrian and cycle safety.

Community facilities and open space

East Greenwich is an area of open space deficiency, yet money from the Community Infrastructure Levy (CIL) and Section 106 often flows elsewhere. It is unacceptable that local children must be bused to other areas for sports because of a lack of local facilities. We are requesting:

• Dedicated CIL/S106 funding specifically for open space and play provision within East Greenwich.

• The revitalization of The Greenwich Centre’s community functions.

• A clear roadmap for a permanent home for the borough’s archives.

Transport, maintenance, and the 'gig economy'

The ambition for a "high-quality public realm" is currently undermined by a collapse in basic maintenance and the chaos caused by poorly managed delivery hubs.

EGRA has provided the Council with firsthand evidence from Fingal Street, where delivery drivers illegally use residential roads as cut-throughs, mount pavements, and pose serious safety hazards—including a reported incident where a child was struck. To fix this, we are demanding:

• Mandatory off-street provision for all new commercial developments intended for delivery operations.

• Enforceable physical measures to prevent illegal access to residential "rat runs".

• A proactive maintenance plan for the Thames Path and increased street cleaning in high-footfall areas.

Conclusion and next steps

EGRA wishes to see a Local Plan that reflects the reality of life in our neighbourhood. We urge the Council to provide concrete protections and infrastructure investment that matches the pace of development.