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Planning Committee

30 November

20 I0

'The Quill'
The Context
The site for the proposed 'Quill' is immediately outside the Bermondsey Street Conservation Area. It is within a newly proposed high-rise z:one that is presently under- consultation and is the subject of strong local opposition. This local opposition is both on account of the substance of the high-rise plan and the secretive way in which the planners hatched it behind closed doors with vested commercial interests - to the exclusion of the local community. BYAG was born out of the groundswell of local opinion that the planners needed to be brought to account for their plans - which are in open conflict with local opinion. For the six weeks of the recent consultation on the local SPD, BVAG operated an information office and cafe on Bermondsey Street to consult local people. This consultation process highlighted the fact that, among local people, there is little or no support for the belief that St Thomas Street and Bermondsey Street are suitable locations for high-rise buildings. This opinion is shared by English Heritage (p.l) One look at the fantastical proposal for the Quill in its context - between the listed railway viaduct in St Thomas Street and the Bermondsey Street Conservation Area is enough to persuade anyone without an appetite for bizarre juxtaposition of its incongruity. It is grossly at odds with its immediate surroundings in height, in materials and in mass. With narrow roads and pavements, negligible provision of public space or service access, the sheer density of the population it pt"Oposes to house makes the proposal unserviceable and inaccessible by all conventional planning standards. It is only the extraordinary culture of omniscience that has taken hold of Southwark's planners that allows a proposal of this arrogance to see the light of day.

Naturally enough, omniscient planners consider local consultation to be a tedious legal necessity to be disregarded and, if possible, circumvented. 50 it has been with consultation over the Quill. Statutory local consultation notices were issued carrying unlawfully short deadlines for responses from neighbours to the proposed development. When invited to square their consultation process with their legal obligations by issuing a correction, the planning department bluntly refused (p.2). Local consultation in fact produced hundreds of letters of opposition to the Quill and the high-rise treatment of St Thomas St it seeks to herald. Only the planners and the developers who stand to profit have a voice here. To appmve th is scheme in the face of such unanimous local opposition would be to make a mockery of the consultation process supposedly underway - revealing it as a charade. The applicants have taken a similarly dismissive attitude to local people, having twice agreed to provide a presentation for BVAG and twice cancelled at the last minute.

Office space/Employment
CAZ policy calls for the preservation and addition of office space. This proposal eliminates from the CAZ ten floors of office space. The applicants attempt to deny this with the extraordinary reasoning that the offices and office workers in Capital House can first be re-defined as 'ancillary educational support facilities/workers'. Once re-defined they can be eliminated without conflict with the policy of preserving office employment space. In case the planners didn't swallow this one the applicants have a reserve argument: that there is too much office space anyway. No need for them to worry however, the planners are quite happy with the idea of re-defining offices out of existence. (See par-a. 40 of the officers' report)

Social Housing
Forthcoming policy puts an end to the anomaly wher-eby student housing developments are exempt from the social housing obligations attaching to other pr-ivate sector residential development. This application is being hurried through in an attempt to reap the (tax-free) profits of the land value hike to be obtained from evading policy requiring social housing provision.

London Bridge and Guys Hospital Campus Character Area Appraisal
Although directly concerned with the proposed Quill site, this policy document appears to have been disregarded by the planners. Policies on pavement width, building height and public space and landscaping have all been ignored in the officers' report. Indeed, it is unclear whether the author of the report was even aware of the existence of this policy document.

The imposition of a building of this scale in a medieval street pattern imposes obvious logistic and access problems that have been ridden over by the planners' report. Even daily ser-vicing of a building housing 500 people is hopelessly inadequately addressed by the proposal in terms of vehicle access. The moving in/moving out plan for the twice-termly occupation and vacation of the building by some 475 students is laughable (para. I 14). Based on the 20 minute slot plan and a twelve hour daily an-ivai period it will take several days of car-efully timed arrivals/departures to fill and empty the building of its student population. The junction of St Thomas St and Weston St would inevitably become a routine bottleneck.

What the planners say:
"The dramatic fifth elevation, the angled this development a dynamic sustainable the facade is in a dramatic glazed facade glazing introducing colour to accentuate the scheme" roof, is to be in photovoltaic glazing to give face. In the reveal between the two towers in a combination of clear and tr-anslucent the contrast and emphasise the verticality of

What CABE say:
"we think the 'quill' narrative is working against the integrity and sustainability of the architectur-e, the quality of the student accommodation and the image of the university. In particular, the form and detailing are over complex and the internal planning is convoluted. The scheme does not meet the standards set out in CABE/English Her-itage's Guidance on tall buildings and we are unable to support the planning application." (p.J)

Apart from 'dr-amatic', the second favourite adjective of the planners' report is 'generous'. All references to the 'generosity' of the building should be read in the context of its LIse to descr-ibe thetreatment by the proposal of the St Thomas St pavement: This is to reduce the present 11.7m pavement by 60% to 4,8m. With their unshakeable belief in their own alchemy the planners describe this confiscation of public space thus: 'the building line in St Thomas St has been set back to provide a generous 4,8m pavement that not only provides a greater space in terms of the setting for- a tall building. but it will also accommodate the greater" number" of pedestrians expected,. .'. Policy requires that the pavement in St Thomas Stis at least 10m wide.

Both the greatly increased height and the bringing forward of the building towar-ds St Thomas St combine to vastly increase the extent of the overshadowing of the listed Railway viaduct arches. The emerging Community Plan for St Thomas Street will call for restoration of the arches and realization of their huge potential to transform St Thomas St into an attractive and historic pedestrian-friendly environment. This proposal gr"avely jeopardizes the success of such a plan, and its ability to be selffinancing. by casting the arches into deep shadow and through wind tunneling. This massive injury to the potential of the ar-ches outweighs many times over the derisory £50 000 proposed in the 5.106 agreement as a contribution to offset loss of amenity.

What King's College says:
'nobody expects the final building to actually look like that.'

What CAB E says:
Finally, the detailing of the envelope to realise the 'quill' concept is over complicated and we doubt that the building is credible to build to the level of quality required for a tall building, either- technically or financially. We note that the same number of bedrooms building of about 17 storeys with a consistent could be accommodated floor plate. (p.3) in a single

What the planners say:
"architect has confirmed the building can be constructed as proposed"


The 'Visual Assessment' of the development produced by the applicant is inaccurate. BVAG has investigated only one view presently, namely 2AI from Par-liament Hill (their view 16). Our- investigation indicates that the applicants have misrepresented the view of the development from this point and thereby considerably understated the impact on the backdrop to the western towers of St Paul's Cathedral (p.4). They have refused to participate in a crucial experiment to determine whether" they or BVAG are right. (p.S). This approach is not surprising as the planners are happy to tell anyone who inquires that any views they choose to submit will be taken as accurate without any verification"

Tower of London
What the planners say:
When viewed from the Tower of London the top of the building appear"s as an incidental element alongside existing chimneys and other" elements on the roof of the Queen's House.

What English Heritage


In our view, this intrusion will harm the Outstanding Universal Value of the Tower of London Vv'orld Heritage Site. For this reason, English Heritage objects to the proposal in its submitted form and its revised form, (p.6)

I rregu lariti es
The 'Client'
The application documents (p.7) claim that the 'client' for the proposal is King's College London. Th is is untrue. BVAG has established that there is no contractual agreement between King's College and the applicant. King's College has been embarrassed by the application being passed off as theirs (p.B). The client is in fact a tax-avoidance company based in Jersey (p.9, I 0).

The Freeholder
The officers' report claims that the freeholder of the site is Investream. This is untrue. The freeholder is the Jersey based company, Bilford Ltd (p.9, I 0)

The terms of the s.1 06 agreement are vague, misleading and largely unenforceable, Obviously they are also irrelevant if, as is generally believed, the proposal will never be built.

onclusl n
So why the planner's purple prose in support them and the developer wants? of a scheme that nobody other- than

For the applicants it all makes good sense: Make lots of tax-free money by establishing pr-ecedent for' a 3 I-storey building (with a few large pigeon spikes to take it up to 33 or 34) that can never be built. The dealer' can then sell the site to a developer who comes up with a non-fantasy proposal for 2S floors that the planners cannot refuse. On their own website, the applicant, Investream, states this to be their business. But what's in it for' the planners to pile praise on this off-shore money maker?

The recent consultation on the proposed tall building zone in the local SPD has exposed how far out of synch the planners are with local opinion on the matter. So much so that BVAG's campaign for accountability in the planning department has forced them into grudging r-etreat on the high-rise zone and has sown the seeds of a community plan for the area that better accords with the views of local people. Such a plan will frustr-ate the planners' exaggerated sense of autonomy and selfimportance. The enthusiastic endor-sement of the Quill is a rearguard, scor-chedearth policy to under-mine any emergent community plan that will be bound to scupper their' high-rise vision with its attendant opportunities for' selfaggrandlzement, That's one theory.

Southwark Council Planning Policy and Research Team Regeneration and Neighbourhood Department PO Box 64529 London SEIP 5LX

Your Ref: Our Ref: Direct Dial: Direct Fax: iE-mail: HD/P5028! 020 7973 3736 28th October 20 I 0


Dear Sir/Madam London Borough of Southwark Bankside, Borough and London Bridge Supplementary 2010)

Planning Document



English Heritage has been made aware of the re-consultation on the above document, although we have not been for-mally consulted by the Council. We understand that the document is unchanged from the earlier period of consultation in February/March of this year, and therefore the comments we made in our letter dated 26th March 20 I 0 (enclosed) still stand. We would however', like to take this opportunity to make some additiorlal comments in light of our recent involvement in the Examination of the Core Strategy, the progression of proposals for further tall buildings in the London Br-idge area, and the sensitivities in this part of Southwark. Planning Policy Statement 12 states clearly that 'Area Action Plans should be used when there is a need to provide the planning framework for" areas where significant change or conservation is needed', English Heritage remains of the view that this area, which will experience considerable change over the duration of the plan, also has some very significant conservation issues which we believe would best be dealt with through an AAP DPD, This would enable the propositions put for-ward with in the document to be fully scrutinised by the Planning Inspectorate and other interested parties at Examination. Evidence Base Our previous representations determine 'appropriate ar-eas' English Heritage has worked respect of the Co re Strategy.

ralsed concerns for' tall bullding with the Council English Heritage

as to the robustness of the evidence base used to development, Since making these representations, to arrive at a Statement of Common Ground in withdrew representations into the soundness of the

1 WATERHOUSE SQUARE, 138 - 142 HOLBORN, LONDON, EC1N 2ST Toteptiotie 020 79733000 Facsimile 020 7973 3001 LVWW, english -tient age. org. uk Please note Ihal English Heritage operates an access to information policy. Correspondence or information whicil you send us may therefore become publicly available


plan, but we r-eiterated our concerns that the process employed by the Council failed to comply completely with the EH/CABE Guidance on Tall Buildings (2007), and that sub-area policies did not adequately recognise sensitivities of heritage assets and local context in arriving at areas appropriate for tall buildings. The agreed revised text to the Core Strategy Policy 12 (subject to acceptance by the Inspector') recognises that within areas identified as appropriate for tall buildings, there will be sensitive areas where more detailed guidance will be needed [0 determine acceptable locations for tall buildings. The BBLB SPD, once adopted will form part of this guidance and we maintain that at present, the SPD is in places, contradictory, unclear and not backed up with a sufficiently robust evidence base. It should reflect draft Policy 12 of the Core Strategy by recognising sensitive areas to tall buildings, as set out in the EH/CABE guidance. English Heritage is also concerned that a full and proper assessment does not appear to have been undertaken in respect of the Council's overarching vision for tall buildings in the BBLB area, both in terms of heritage assets in the immediate area, and also the relationship with the Tower of London World Heritage Site and views to and from it. The SPD should provide greater clarity as to whether a cluster approach is proposed, and if this is the case, should provide evidence of 3D modelling that demonstrates the intended profile of any such clusters as viewed from the BBLB area and beyond. Bermondsey Street conservation area English Heritage has consistently raised concerns about ambiguity in the draft SPD, which does not at all times conform to the published evidence base or the Council's own stated objectives elsewhere in the SPD. Page 36 of the draft BBLB SPD clearly states that tall buildings are 'not appropriate ... in the Borough High Street conservation area, Tooley Street North and South conservation areas or Bennondsey Street conservation area'. However, the area indicated as appropriate for tall buildings intrudes into and immediately abuts Berrnondsey Street conservation area and is also adjacent to the Borough High Street and Tooley Street North and South conservation areas. PPSS Policy HE I0 seeks to preserve the setting of heritage assets. The area indicated as appropriate for tall buildings extends over sites at the corner of Bermondsey Street and Thomas Street, While outside of the conservation area, the proposed tall building zone abuts it, and as such the tests of Policy HE I0 will need to be applied should any future proposal come forward. We are concerned that tall buildings in this location could cause substantial harm to the character and setting of the Bermondsey Street conservation area, and views looking north along Bermondsey Street. We therefore urge the Council to revise the boundary of the proposed tall buildings zone to reduce the potential for any such harm to the conservation area. The Berrnondsey Street Conservation Area Character Appraisal should also form part of the evidence base Lipan which areas for tall buildings are determined. It identifies buildings at Vinegar Yard as in need of renovation stating that 'any renovation should also consider the yards and spaces around it, which are currently used for car parking'. Specifically, the building at 9·17 Vinegar Yard is identified in the Appraisal as a building that makes a positive contribution to the conservation area. PPSS requires local authorities to pay special regard to preserving or enhancing the conservation area and we consider that tall buildings may not be the appropriate design response for sites adjacent to this conservation area boundary. The SPD should be revised to recognise and respond appropriately to the council's own evidence base as set out in the SPD, background papers and conservation area character appraisals. English Heritage supports the continued involvement of staff with expertise in heritage matters throughout the preparation of the Bankside, Borough and London Bridge SPD and supporting


background paper·s. as they are often best placed to advise on; local historic environment issues and priorities, sources of data and consideration of options relating to the historic environment. This opinion is based on the information provided by you. To avoid any doubt, this does not affect our obligation to provide further advice and, potentially, object to specific proposals. which may subsequently arise where we consider that these would have an adverse effect upon the historic environment. In the meantime, we welcome the opportunity [Q work with officers on the development of this important planning document. Yours sincerely

Samantha Coates Regional Planning Advisor LONDON REGION


From: Subject: Dale: To: Mr John/Ms Attached

Russell Gray <> Fwd: Quill consultation 13 October 2010 10:21:55 BST, Shepperd with Mr Rice, Head of Development Management. to correctly notify consultees

please find self explanatory email correspondence

It seems to me astonishing that that he believes he is free to disregard a statutory requirement of their right to comment on a crucial planning application. It also seems to me that it would leave the Council open to judicial review. Please may I have your comments. Begin forwarded message:

From: "Hice, Gary" <> Date: 12 October 201013:42:11 GMT+Ol :00 To: "russell gray" <> Cc: <Iiz@bvag.nel>, "Adams, Gordon" <> Subject: RE: Quill consultation
No such retraction or correclionis Regards, Gary Rice From: russell gray [mailto: rllssell(6lbvag.netj Sent: 12 October 2010 13:39 To: Rice, Gary
Cc: russell(iUbvaq,net; Iiz{!

required, so I decline your demand.


Re: Quill consultation

Please confirm that those who received letters will be receiving a retraction and correction of tile false information, You should do this by telephone as I requested since I am not always in a position to collect email and this may be the case for the rest of today, Regards On 11 Oct 2010, at 10:32, Rice, Gary wrote:
Dear [vlr Gray, III response
. leiters were to your CI118il 0110 sent 27109 October,

I provide ttle fonowing informatlon:

press notice 30109 . site notice 05!10 The statutory 21 day nonce period tuns from Iho latest of Ihe above: as such, the slal\llo;-)' public consultation period expires 011 2G!1012010 however Acolaid acids 1\'10 dAYS so il is listed as expiring on 28110 on the websilo However, Ille Counci's slamiarcJ practice is to accept ally submission lip unlil the elate 8 declsion is made. At this point ill lime. it is likely that tile anplicaticn will be presented 10 the pl,1!llling committee on
NO'Jember 30. By 1;1\".',the Council is only to carry out {lH three melhorts of

n,'() statutorv irillCsc?lcs for consultaucn can be fGllnd at: http://wwwlegislationgov.ukluksi/1995/419/article/8/made requlr8d to lSSU~ i] press noUce '::lIlG either [I site notio .. 01' letters to ne3rl1y occupiers" ~ IS lne Council's policv COIl5ulia!:on


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wc sron

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p: /I H' Il Kroc~1gn- rcnew/qu111- weston ..suec

The government's advisor on architecture. urban design and public space



Oe sinn review


l atest desiqn reviews



House, \-\'eslon


Capital House, Weston Street
Proposal open for a 21· ancl31-storey Designed building to provide

470 student


a bar, gym,




a cafe,


an area

of public



20 September
Planning Tagged

2010 10lAPI2754
and colleges

referenco; with:


I Design



I London I Tall


We accept tall building. view from proposed the proposals Olaf, in policy terms, We find the impact Ihis site is app.opriate of the height proposed of exisling for a on the and

the inner ward of the Tower of London will form part of a background including accessible student that student accommodation location housing, While we support the client's buildings

acceplable; and the

City Hall, More London

Shard. We think use in this highly College deliver narrative campus.

is a suitable aspiration to of

at the edge of the King's we think the 'quill' and sustainabllity accommodation the form and planning is set out _

high quality is working

against tile integrity

the architecture, and the image detailing convoluted. are unable

the Quality of the student of the university. and the internal

In particular,

are over complex The scheme to supporlthe Heritage's

does not meet the standards planning application.

in C}\BE/Englisil

Cuulence on Itll/ buildings and we'

Site layout
We are not convinced of streets account succeed. and spaces. of the current The 'bulge' that lhe amount context opposite of new public space should a servicing entrance proposed in Ihis location or diagonal route through the sile is needed environmenl in relation to Ihe wider to network

We think that aclivity

be focussed

on the existing


The localion

and orientation

of the open space


fails to take

to the hospltal.

In our view, this will be a cllallenging is a weak gesture

tor a new public space the relative

at Ihe lower levels where 1I1e proposed

route goes under the building

lhat undermines

clarity of the form at

lower levels. In building right up to Ihe site boundary with Beckel! House. we are concerned will prevent lhat the scheme will compromise direct views. the future redevelopment of the adjacent site;

we are not convinced

thai the angled glazing

on the east elevation

The 'Quill' concept two elements internal

and planning
has resulted in an unpainly form, and awkward and inefficient spaces on plan. This has been further exacerbated by splitting nurnber the building into

and losing the single curved massing and environmenlal in a single building of about

at the upper levels. The resulting we think the scheme worked floor plate

floor area to facade ratio is highly inefficient. better as a single form We note that the same

In terms of the massing, of bedrooms Gould



be accommodated

17 storeys with a consistent
in size and amenity

There is a lack of conviction perceived both towers The pl8nning students layouts. Finally, required the detailing in principle. size of the typical should

and control

in lhe varialior; to wheelchair is illogical

of the student

rooms, many of which where

are either



or very s1T1811. The rooms in

room is lhe lenqth of a single users.

bed and some rooms

have only one window


have up to six /\11of the student

be fully accessible spaces

of the circulation through the connections

and lacks generosity. to expect circulation

For example. students on level

the ground

tloor entrance

and lift lobby appears While

too small for the number to the idea of bridges Ihe roorn



the space;

we feRI it is optrrnistic

to walk up to the fir st floor to gather 16. Rotating tile bridge aliqnmcnts

we do nol object

only work v/ilh the proposed

on tevels 12 and 20 compromises

of the envelope

to realise

111e'quill" concept

is over complicated

and we doubt that the building

is credible

to bUild to tile level of quality

for a lall buitdin9.

either technically

or financially.



2')111110 III II



From: Subject: DDle:

Russell Gray <Russell@bvag.nel> Fwd.: View 2A.1 29 November 201012:00:20 GMT To: Liz Ruffell <>

Begin forwarded message: From: Russell Gray <> Date: 26 November 2010 19:28:39 GMT To: Anthony Plurnbly <> Co: Michael Tsoukaris <> Subject: Re: View 2A.1 Constant repetition does not make your clients right. An honest and very simple experiment is ali that is required to prove it one way or another. Your client's reluctance is at odds with their professed confidence in their results. Regards On 26 Nov 2010, at 17: 15, Anthony Plumbly wrote: Mr Gray

By way of update:
We have gone back to Ole wider team on your Further analysis on view 2A.1. Your comments and requests to tether a 21Ft helium balloon to the existing building on site are being considered and further re-testinq is currently taking place. in detail

Pip-ase note that the appointed consultants are the industry leaders in this field (indeed they worked collaborattvely the GLA. on the LVr/1F) and the analysis is robust.


vVe will issues further re-assurance to you on this, as well as your requests, as soon as we are able.
Kind regards, Anthony

- -- +Oriqinal ~'lessage-- --From: Russell Gray [mailto:russeIICWlordshiva.netJ Sent: 2Ll November 2010 15: 13 To: Anthony Plumbly Cc: iv1ichael Tsoukaris Subject: Re: View 2A.l It does 110t appear that you are ready to engage in an honest investigation engenders suspicion. of this matter. This obstruction obviously

We used various methods to evaluate the impact of the proposed development

on the 2A.l view.


OUi' photograph was taken tram precisely the position dictated by the LVfvlF document, however, the emphasis you have placed on this question demonstrates how limiterj is vour unrierstanrlinq of the principles behind the view management iSSUE: parallax errors occasioned by even several metres. of deviation from the prescribed spot would be insignificant in this situation because of the relative distances of St PaUlS, The Shard (mel Capital House from the viewing position. position is derived fi om a V211 iety of different invcstiqations. These include the direct line of sight experiment with tile rockets, projection or COIl1[)CiSS bearings from the Capita! House site and establishment of sight hnes 011 a map. Obvroustv, all these techniques have margins of error and hence ours position is based 011 the kind of 'trianqulation' principle that IS adopted in almost all naviqational techniques, Including GPS, aviation radio beacon positioning by VOR and ADF and offslime methods such as sextants ami RDF.

r here is of course no substitute for the evidence of tile E~yes and hence ~ve are suspicious of; your client's resistance to OUf

slm pie and cheap sight line experiment. Once again, please put me in touch with your 'experts'.

On 24 Nov 2010, at 14:04, Anthony Plumbly wrote:

Mr Gray
We can only again offer our apologies for not being able to attend tonight. outside of our control. We are confident that the view, as submitted, in response to the firework query. is correct. As previously explained, this is for reasons

This has been re-established

in the information

issued to you

As you have not provided any information as to how you have come to place the building in the position in your second attachment, we would be most grateful for a description of your working methods so we can pass this onto our visualisation specialist for consideration. We would also be grateful for confirmation or evidence that the photograph taken is on the spot dictated by the LVMF, as previously requested. We have replied separately to Liz on your request to tether a balloon to the building and have recently received a response. I will come back on this as soon as possible. If you wish to inform us of any other anomalies that require clarification in advance of tonight, please let me know. will endeavour to respond as soon as possible but will be in meetings out of the office all afternoon. My response may therefore be delayed. Kind regards, Anthony - -- --Original fvlessage- ---From: Russell Gray [mallto:] Sent: 24 November 2010 11 :43 To: Anthony Plumbly Cc: Midlael Tsoukaris Subject: View 2A.1 Mr Plumbly It is unfortunate that for the second time you have cancelled your proposed attendance and presentation to our members. This is particularly regrettable as now that the Southwark planners report is available there are a large number of anomalies that require clarification prior to the planning committee meeting next Tuesday. As far as possible we shall put these to you by email. your behalf at our meeting tonight. Please revert to us asap so that we can answer questions on

As a start, please confirm that your clients are ready to agree to the production viewpoint 2A.l.

of an accurate view simulation


We have asked for your agreement to tethering a helium balloon from Capital House to be photographed from the viewpoint on Parliament Hill. We have some confidence that this method will be workable on a clear day. Since you can obviously have no health and safety objections to this method, please confirm your client's agreement. ['vleanwhile, please put me in touch with the 'experts' responsible for your view preparations in relation to viewpoints 2A.l and 3A.l so that we can establish INlly our results differ. Attached, to illustrate tile problem, is a 'with and Without' view from Parliament Hill. Presently it is constructed with the best elevation of the Quill we can obtain. You may be able to supply a better one as viewed from the North West. The problem, however, is that the position differs considerably from that presented by your client. Your view does also appear to be at odds with the recent response you sent to us in relation to the position Investigation we conducted with a firework early this month. If you have the experts give me a call I am sure we can establish why there is this discrepancy. Regards



Richard Coleman
City Designer 14 Lower Grosvenor

Telephone: Place Fax: Date:

0207 973 3769 0207973 3792 20 I0



24th September

Dear Richard

Thank you for the Yer'y helpful briefing at City Hall On 25\11August on the revised proposals for the redevelopment of this site with a building of 3[ storeys at IOB,7m in height to provide 470 units of student accommodation with some retail accommodation, Branded as 'The Quill'. it seeks to evoke a quill pen in a stand to relate to the strong literary associations of this area of London. This revised proposal, which is intended to be submitted for planning permission in lieu of the earlier proposal submitted earlier this year, incorporates a number of changes, the most notable of which is the separacouofthe l>lIBJi"g'-into -two ---distinct" tower s, each with a distinctive sloping roof, The development site is on the south side of St Thomas Street at the junction with Weston Street, On the opposite side of St Thomas Street stands the grade II listed wall and trainshed of London Bridge Station, There are no other listed buildings in close proximity to the development site, The site is not within a conservation area but the north western corner of the Berrnondsey Street Conservation Area forms runs along the centre of Mellior Street which forms the southern boundary of the development site, In looking at the emerging proposals, it has been made clear at previous pre-application discussions that the key issue for English Heritage would be the impact that a building of this height and form would have upon protected views, upon views from the Tower of London World Heritage Site (WHS) and lipan London's wider' historic environment. There will undoubtedly be some impact upon local views - and particular-ly views from within the Berrnondsey Street Conservation Ar. - and we have concluded that this issue can best be dealt with by Southwark Council. SCANNE~

19 OCT 20W



Please Correspondence

Telephone 020 79733000 Facsimile 020 79733001 IW/\'f,english-heritar;Q_org uk note/hal English Hcril<Jge ooetete» an access /0 tntormoiion polir.y_ or intcrmetion wllieh you selld US may IIIp.refor& become publicly available


IMPACT UPON PROTECTED VIEWS - The Heritage, Townscape and Visual Assessment submitted with the original application looked at a number of protected vlews identified within the London View Management Framework as being worthy of management, namely the views from Kenwood and Parliament Hill and from Tower Bridge, Southwark Bridge and the Millennium Footbridge. In the case of the Kenwood and Parliament; Hill views, the building as first proposed would appear in close proximity to the dome and peristyle of St Paul's Cathedral, the focus of these protected views. However, all but the v·ery top sections of the proposed .. uilding would be b screened by existing tall buildings seen in the view. We note however that in both views, the proposed building would be completely hidden behind the very tall building known as The Shard when the latter is completed. . As for the views from the River Thames bridges that were modelled, the building as originally proposed would be seen as part of the skyline that already includes a number of tall buildings and other new developments including More London that occupies a pr-ominent position in the view from Tower Bridge. Inevitably The Shard will also have a significant visual impact in a.1Ithese views. .. ' .. ,,;\ .~ .. .... In assessing the originally submitted scheme, we concluded that it would have some visual impact upon these designated views but, on balance, the net effect was not considered to be harmful. None of these views incorporating the latest proposal has been presented. for assessment but in view of the redesign of its upper storeys, i think. it is unlikely that our' assessment on this issue will change Significantly.

- the impact that the proposed development will have upon views from within the Tower - and by definition the WHS - and contextual views of The Tower from public spaces to the north is potentially more significant. The original Townscape and Visual Assessment modelled two viewpoints. from north of The Tower and two views from within the inner ward of The Tower'. As far as the former are concerned, we concluded that the views from these viewpoints would not be significantly affected, The assessment .demonstrated that the proposed building Would be Visible, a matter of some concern, but that it would be seen as par-r of the visual 'clutter' that includes, for example, Guy's Hospital Tower. When completed, The Shard will, be a dominant feature in these views. Again, the design changes to the upper storeys of the revised proposal suggest that its visual impact in these views will beno greater - and perhaps slightly less - th-an-originally envisaged. Our greatest concern is reserved for' the impact that the proposed building would have upon views from within The Tower's inner' ward and especially upon the view looking south west from north of Tower Green. This view is very much focussed upon The Queen's
• A·



·.1 WA1H'lHOUSE SQUARE, 138~l42
, Totoptione

020 7973 3001

020 7973 3000 Facsimile

W.W/. english·hen·

. Please note tnet Eng/isl! Heri/age operates an access (0 information poltc». Correspondence or information wtuct: YO(l sono us may inetetore become publicly available



House, a much-restored range of mid-1540's bulldlngs with attractive multi-gabled timber framed facades over a brick ground floor, This range of buildings represents an exceptionally rare survival within Central London, its location within The Tower enabling it to escape the ravages of the Great Fire in 1666.

In the view rendered in the submitted T ownscape and Visual Assessment, the upper storeys of the proposed building were visible above the ridge line of the Queen's House at the point where the facade turns within the south west corner of the inner ward, When we flrst looked at the scheme, it concluded that this would represent an unwelcome intrusion upon one of the key views within the WHS. Notwithstanding the substantial presence that the completed Shard will have upon the views from this part of The Tower's inner ward, there is currently very little modern visual lnrruslon,
The Government's Circular 07/2009 Circular on the protection otvvorki Heritage Sites makes it clear that, "the setting of a. Wortd Heritage Site is the area around it (including any buffer zone as defined below) in which change or development is capable of having an adverse impact on the World Heritage Site, including impact on views to or from the Site". English Heritage has issued its own guidance - English Heritage guidance note to Circular (or England on the protection of World Heritage Sites »- to be read in conjunction With the Circular. This recognises the plan-led approach to managing change in the historic environment and advises planning authorities of the need to consider the impact that planning applications within the settings of World Heritage Sites might have upon the Outstanding Universal Value, authenticity and integrity of those sites.
A second draft Supplementary Planning Guidance (SPG) for the Bankside, Borough and London Bridge area has recently been released for public consultation. In general terms, we we!come a plan-led approach to the management of tall building proposals but we expressed some concern with the first draft as to the way in which assessments are to be carried out. We hope this has been addressed in the second draft upon which we hope to comment soon. So far as the Capital House site is concerned, the draft SPG identifies it as one that is appropriate for a tall building (see figure.20) but it also recognises that the setting of The Tower of London WHS is a matter for consideration (Section 4,2.2). Section 4.2.12 gives detailed requirements in respect of proposals for tall buildings. Section 5.6 gives more detailed advice on the Capital House and Becket House Opportunity Site including, "views from within the Tower ofLondon are also (an) important consideration". Policy. HEIO of Planning Policy Statement 5 Planning for the Historic Environment gives guidance for' considering applications for development that affect the setting of a designated het';tage asset. The redevelopment of Capital House with a tall building will have an impact upon a number of designated assets in addition to the setting of the WHS and consideration needs to be given whether or' not this development preserves, "those elements of the


" ! WATERHOUSE SQUARE,138 ":142 r~OLBORN, LOt~DON, P:C1N ?Sf 020 7973 3000 FaGsimile 020 7973 3001 1\~\wenglislJ-llOriI8ge.ofg.LJk note Ih8/ English Heritilge cperetes an access 10 information po/icy' or intosmntion wbict: you send us mey tberotora become publicly oveitebl« Telephone

Please Coaesucndenc»




setting that make a positive contribution to or better reveal the significance of the asset'{s), If the application is considered not to do this then any harm that is caused by the proposed development needs to be balanced against the wider benefits of the application, although the greater the negative impact upon the significance of the heritage asset(s), the greater the benefits that will be needed to justify approval. English Heritage and the Commission for Architecture and the Built Environment (CASE) have jointly published Guidance on mil buildings in July 2007, This guidance sets out "a process for evaluating proposals for tall buildings and puts forward criteria by which this evaluation should be fully addressed; Paragraph 4,1.1 in particular points out the need to assess,"The effect "on the historic context, including the need to ensure that the proposal will preserve and/or' enhance historic buildings, sites, landscapes and skylines, Tall building proposals must address their effect on the setting of, and views to and from historic buildings. sites and landscapes over a wide area including world heritage sites", The Townscape and Visual Assessment already referred to points out that detailed assessments of sensitive views have been carried out, It concludes that. "the results are not considered to be of Significance" (8,9.5). In respect of the impact upon the Tower Green view, the Assessment concludes that. "There is a 'moderate' impact in quantum, but one which only avoids being adverso by the high quality of the:" architecture, "It is classed. therefore, as 'adverse mitigated' in terms of character", The question of the quality of the architecture is perhaps a key issue here and we note with interest the contents of the "fetter dated 20'" September from Lucy Carmichael at CABE to Gordon Adams at Southwark Council. In looking at the original proposal. we were concerned about whether the proposed building would be of sufficiently high quality to mitigate the impact that it would have upon the view from Within the inner ward of The Tower. We concluded then that the likely effect would be to add discord and visual clutter to this key view and that the net effect would be harmful, We recognise, of course, that one of the outcomes of the latest redesign is that the portion of the building that will be visible within this view might be described as rather more spire-like. We also recognise - and welcome ~ the additional work that has been carried out to begin to analyse this particular view in a more dynamic way, This analysis has demonstr-ated that as one moves further' to the south west towards Tower Green and what is known as the Interpretation Point the impact of the proposed building upon the setting of The Queen's House reduces and eventually it no longer appears in the view, However, it remains our view that any intrusion into this view is harmful. CONCLUSION - Within The Tower - and within the inner ward in particular - the imposing qualities of the military architecture combined with the domestic scale of the Queen's House are a dominant theme that enables visitors to the Wodd Heritage Site to readily understand and appreciate the heritage sigriificance of The Tower of London and rhus
.1 WATERHOUSE SQUARE. 13.3-142 HOL80RN, LONDON, ECIN 2ST Telephone 020 7973 3000 Facsimile 02019733001 WIWI. eng/is/! -lleritaQ8.oTQ" uk Pleaso note thai English rieritage operates lin access /0 infamlalioll policy. Conesponcience or iofol)llalion Which you send us mDy therefore become publicly available



of the WHS itself. We have concluded that in respect of the views of The Tower in its setting, especially from the north, the impact of the proposed building in its original and its amended form would not be significant However, it is the impact that the proposed. building will have upon views from within The Tower - and especially from within the inner ward - that are more significant. This proposal will only serve to re-enforce the sense of the intrusion of the modern world upon the strong historic and architectural character and appearance of the Tower's inner sanctum. In our view, this intrusion, which is likely to be multiplied by other tall buildings proposals that are emerging in this area of North Southwark,· will harm the Outstanding Universal Value of the Tower of London 'World Heritage Site. For this reason, English Heritage objects to the proposal in its submitted form and in its revised form,

I am copying this letter to Gordon

Adams at Southwark

Council for his information.

E-mail: malcolm. wood'@Eflglish-he(,,uk

1 WATERHOUSE SQUARE,13&Telephone 02079733000

142 HOLBORN, LONDON,FeiN Ffjcsimil$ 02079733001
org. ok



Pieuse note tnet Engiis/) Herdage operates an 8~'1::eSS10 information policy Ccrrespcnaence or information which you send us may therefore become publicly availob/a




in association with Investream Ltd

Planning Property:


40-46 Weston street, London SEI
0802 Version VII

Project ref: Date: Prepared Checked by: by:

01.09.2010 TOM
jjf/GF response for the site has drawn upon the following guidance:

The architectural

• •

London Plan London Plan - London View Management London Borough of Southwark UDP Draft Bankside, Borough and London

Framework Bridge

SPG Planning


Document (SPD) PPG 15 - Planning and the Historic Environment CABE/EH Guidance on Tall Buildings

From: Subi€:CI: Dato:

Russell Gray <> Fwd: FOIA request 10 November 201011 :11 :20 GMT 10: Liz Ruffell <liz®'lordslliva. net>

Begin forwarded message: From: Russell Gray <RlIssell@bvag.nel> Date: 4 November 2010 15:02:13 GMT To: Cc: Amanda Way <, Subject: FOJA request

Alison Hobbs -calison.hobbs»

As you have still declined my request (see below) to make a statement treat this email as an ForA request.

about KCL's involvement

in tile Quill project, please

(1) Please provide copies of any documents recording all meetings or transactions with Investream to the redevelopment of Capital House.
(2) Please provide copies of the internal plans formulated Capital House. by KCL for the re-location

or their agents relating

of the KCL staff presently working in

(3) Please provide a copy of the lease on Capital House together with any documents (letters, notices or minutes) relating
to its re-negotiation Please acknowledge Russell Gray Begin forwarded message: or surrender. receipt of this request.

From: Hussell Gray <> Date: 2 i'lovember 201008:57:00 GMT To: Amanda Way <> Subject: Fwd: Unsatisfactory answers

Hr Trainor I enclose a further copy of the email thread to which vou have declined to reply. This is unacceptable.

That Kings College is being represented as the client in a 11ighly significant planning proposal with numerous irregularities is not a matter on which yOLI call stay silent. J'.'lr Caldwell is not the person to respond as he has clearly either been taken for a fool or exceeded his brief - neither of which he is going to be quick to admit. In all the circumstances surroundinq the Quill proposal there are obviously strong suspicions of impropriety in various quarters and I would urge you to make a statement that stops avoiding tile issue of whether the use of KCL's good name as 'client' to support an application where the client is in reality a tax -heven company was with or without your , agreement. I would also welcome a cal! from you so that I can fuily understand you position prior to a briefing for local people that we have scheduled for tornor row on the Quill. Regards Begin


From: Russell Gray <Russell<0bvaq.llel> Date: 26 October2010 18:49:16GMT+01:00 To: principal(c.) Subject: unsanstactory answers fYlr Trainor

Please will you address the serious matter of misrepresentation of KCL referred to in the email correspondence Not surprisingly, Mr Caldwell is reluctant to tackle it square on. Regards Russell Begin Gray forwarded message:


From: Russell Gray <> Date: 26 October 201 0 17:14:30 GMT +01 :00 To: "Hobbs, Alison" Amanda Way <amanda,way@kcLac.ub, Subject: Re: Reply re your fax Mr Caldwell No this does not conclude the matter. company that does, Please confirm. Investream does not own the building. I trust you are aware of the offshore

Also please confirm that you are not the 'client' for the application as has been stated in the application documents. Alternatively, if you maintain you are the client, please provide details of all contractual arrangements with Investream or its agents, Please inform us of what steps you have taken to correct the false impression that has been created by the applicants over the provenance of the application. Regards Russell Gray On 26 Oct 2010, at 16:48, Hobbs, Alison wrote: Dear Russell and Liz As you note, the College has an interest in this building by virtue of its current lease. King's is supportive of the proposals and is satisfied with ils working relationship to work with Investream as the application moves forward. The location of Investrearn is not relevant to the planning application, with Investrearn. We will continue

I trust this concludes the matter, Kind regards Ian


Caldwell Director of Estates and Facilities

Alison R Hobbs Directorate of Estates and Facilities King's College London 3rd Floor Capital House 42 Weston Street London SEl 3QD Tel 0207848 6914 Fax 020 7848 6915 esta tes. sC'c©Jkcl.Ie. uk (



N011inai Capital

GBP W.OOO.DO divided



N~nlber of shares

issued as at 01 Jan 2010

To!al amount




premiums: GBP 776.00

Total amount

of calls unpaid at 01 Jan 2010

Number of Shares

Forieiled: shares: shares:

Amounl p<1id on sale of f0l1oited Amount realised A FUll

on salo of forfeiled

list of Shareholders

is given overleaf

Presented Mouralil

by: & Co. limited

PO Sox 87 22 Grenville Street SI Helier Jersey C I JE48PX l/we declare thai this document is complete and accurate in all respects








If Ihe company is a PubliC Company. annexed. (Form C21)

or a subsidiary

of a Public Company.

ihe particufani

of Directors.

must be


Tnis rotorn must he delivered 10 Ihe Regislrar o( Companies. P.O. Box 267. 14-18 Castle Streel. Sl Helier. Jersey. JE4 BTP nol later Ihan th8 last day of February with payment of 1M relevanl Fee. If Ihe return is delivered <lrter thai dille. an addillonal Late Fee will be required. Cheques are to be made payable to •Jersey Financial Services Commission'.


Anrilial Returns cannot be accepled untillhey rneel tha refluirements olthe Companies (Jersey) Law 1991, 85 amendod. If Ihey ha1l8 to be relurned (or any reason It,e lime involved mal' mean thnt the correct Annual Return IS nol delivered on time and a penalty will be incurred.

" 11111 DTRYPARIO " 1111111111111




in Elilford


on 01 Jan 2010 showing

their names

and addresses

and details

or the shares

so hold:
Name and address Share Class Number of shares held at the dale of the 'return Amount thai has been paid or credited as paidup on each share

Misha ZeclI Morris
22 Bramplon Grove





United Kingclom







20 Raleigh Close

Uniled Kmgdoll1

Total number of shares held




SGL470623 w i t h by Land Registry, Telford Office.

Thi.s title

is dealt

The following extract contains information taken from the register of the above title number. A full copy of the register accompanies this document and you should read that in order to be sure that these brief details are complete. Neither this extract nor the full copy is an 'Official Copy' of the register. An official copy of the register is admissible in evidence in a court to the same extent as the original. A person is entitled to be indemnified by the registrar if he suffers loss by reason of a mistake in an official copy. This extract shows information current on 4 OCT 2010 at 16:21:07 and so does not take account of any application made after that time even if pending in the Land Registry whe n this extract wa s issued.





of Property



42 Weston



(SE1 3QD)




Reg is tered

owne r (s )

BILFORD LIMITED (incorporated in Jersey) (UK Regn. No. Y) care of Nabarro Nathanson, Lacon House, Theobald's Road, London WC1X8RW.


Berlin-Hannoversche Aktiengesellschaft



1 of 3

This is a copy of the register of the title number set out immediately beloVl, showing the entries in the register on 4 OCT 2010 at 16:21:07. This copy does not take account of any application made after that time even if still pending in the Land Registry when this copy was issued. This copy is not an 'Official Copy' of the register. An official copy of the register is admissible in evidence in a court to the same extent as the original. A person is entitled to be indemnified by the registrar if he suffers loss by reason of a mistake in an official copy. If you want to obtain an official copy, the Land Registry web site explains how to do this.

A: Property


This register describes the land and estate comprised in the title.
The Freehold land shown edged with red on the plan of the above Title filed at the Registry and being Capital House, 42 Weston Street, London (SE1 3QD).

B: Proprietorship


This register specifies the class of title and identifies the owner. It contains any entries that affect the right of disposal.

Title absolute
1 (16.11.2001) PROPRIETOR: BILFORD LIMITED (incorporated in Jersey) (UK Regn. No. Y) care of Nabarro Nathanson, Lacon House, Theobald's Road, London wc ixaaw. (16.11.2001) The price was £6,000,000. stated to have been paid on 24 October 2001

2 3

(25.10.2007) RESTRICTION: No disposition of the registered estate by the proprietor of the registered estate or by the proprietor of any registered charge is to be registered without a written consent signed by the proprietor for the time being of the Charge dated 11 October 2007 in favour of Berlin-Hannoversche Hypothekenbank Aktiengesellschaft referred to in the charges Register.

C: Charges Register
This register contains that affect the land.

any charges

and other matters
to of

(12.07.2006) The parts of the land affected thereby are subject the rights granted by the Lease of a Transformer Chamber, 40/46 Iveston Street dated 21 January 1964 referred to in the schedule leases hereto. The parts of the land affected thereby are subject to the leases set out in the schedule of leases hereto. The leases grant and reserve easements as therein mentioned. (25.10.2007) REGISTERED October 2007. CHARGE contained in a Debenture dated




(25.10.2007) proprietor: BERLIN-HANNOVERSCHE AKTIENGESELLSCHAFT (incorporated in Germany) 10787, Berlin, Germany.

HYPOTHEKENBANK of Budapester Str.1,

Schedule of notices of leases
2 of 3


of notices of leases continued
Transformer Weston Chamber, 40/46 21.01.1964 Street Register (Ninth 60 years from 25.12.1963 relating to the rights 02.06.2008 From 24/04/2007 23/04/2022 to 12,07.2006 TGL275682


NOTE: See entry in the charges granted by this lease 2 17.07.2008 TGL311401

Part of Roof


End of register


J of J