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GLOBE HOUSE 37 BERMONDSEY STREET SE1 3JW BVAG.NET Rt Hon. Eric Pickles MP Secretary of State for Communities and Local Government Eland House Bressenden Place SW1E 5DU BY HAND The Quill, SE1 Dear Sir I wrote to you on 13 December on behalf of our group requesting a call-in of the application for a new high-rise building at London Bridge, dubbed The Quill, that had recently been approved by Southwark Council. Subsequently, on 15 December, the proposal was endorsed by the GLA but almost simultaneously, I understand, Southwark Council were directed to refer the application to your Department as a consequence of the proposals impact on the Tower of London WHS. Only the day before, Southwarks planners had told us that they were unaware of the Circular obliging them to refer to DCLG and had no intention of doing so. I have submitted a file of our various representations to your Mr McNally but I should like briefly to summarise why we believe that the application in question requires the full scrutiny that a call-in implies. Firstly, I should say that ever since BVAG became aware of the application for The Quill it was clear from our inquiries of the Local Authority and the GLA that between them and the applicant they had agreed that the proposal would be approved and that consultation would be a formality. And so it was that objections from CABE, English Heritage, Historic Royal Palaces, local Councillors and a couple of hundred local residents and workers were simply ignored. It is this kind of inside-job in the local planning process that has brought about the total distrust of our local planners and that, in turn, has given rise to our group and to the Community Plan that is in gestation locally. Along with a wide variety of other interested parties, BVAG hope and expect to contribute to the development of a Community Plan for our neighbourhood that will demonstrate exactly why the current reform of the planning process is desperately needed and how local people must be re-enfranchised. 22 December 2010

Clearly, just how incensed local people are at being excluded from the planning process depends on the significance to their community of the proposals from which they are excluded. In the case of The Quill we would suggest that the significance is enormous, both locally and for London as a whole. We are aware that the test to determine whether an application should be called-in by your Department is that it has implications of more than local significance. In this case I believe this test is satisfied under two slightly different interpretations: The first is the obvious material effect this high-rise proposal has on views from much further afield than the Borough of Southwark. The second is the implications for London and nationally that the principles applied locally to approval of this application would have if generally adopted.

Tall buildings in sensitive locations

Views Three different categories of views require consideration in this application. The applicants have submitted a Heritage, Townscape and Visual Assessment (HTVA) as part of their application but it has some obvious errors of representation. (a) Views from the Tower of London WHS The HTVA is entirely misleading in respect of this view. The proposed building is referred to in the text but invisible in the images presented at least on the copy provided to us. The use of photographs taken when the trees are in full leaf clearly is not capable of giving the whole picture. English Heritage and Historic Royal Palaces have objected to the impact of the proposal on the views from the inner ward, which brings the application within the scope of para. 19 of the DCLG circular on the Protection of World Heritage Sites. However, para. 20 recognises the adverse impact that can occur from creeping incremental development, which is also an important consideration in this case. Both Southwark Council and the applicants have promoted this development as a catalyst, or facilitator of further high-rise proposals that would extend steadily to the East along St Thomas St. (See clusters, below.) (b) Views from various observation points protected under the London View Management Framework We have made a study of the LVMF view 2A.1 from Parliament Hill (see enclosure) and have obtained results that do not correspond with those presented by the applicants in their HTVA (view 16). In their analysis the proposed building is entirely hidden in the view from Parliament Hill by the Shard. This is inconsistent with our results and also with their response to

our line-of-sight experiments (also with enclosure) since they accepted our position for the SW corner of the proposed building. This result would mean that the position claimed for the NW extremity of the building cannot be where it is shown in their HTVA view 16 (i.e. virtually on the centerline of the Shard) since the building footprint does not correspond to such a large arc of horizon. The impairment of the view and the appreciation of the Western Towers of St Pauls Cathedral is in question and because of the close proximity of The Shard to the proposed site this effect is highly sensitive to precise positioning in the simulation. We consider our experiments, the scant comment in the HTVA and the outline representation of the building form in the cumulative effect presented to beg the question: Is the building truly invisible, as is claimed, or would it present a visual intrusion onto the Bell Tower as we believe? Our attempts to verify the applicants claims in relation to the LVMF views have been obstructed by their refusal to provide the data necessary to have an independent 3d modeling company perform an analysis (see enclosure). We are now planning to employ a laser location method that will provide a definitive position of the proposed building on the horizon as viewed from Parliament Hill. This method is free of all modeling errors and we believe should be employed in all cases where the results are so finely balanced. (c) Views affecting the local context The site borders the Bermondsey St Conservation area, it is immediately across St Thomas St from the listed London & Brighton railway viaduct and there are numerous other listed buildings in the close vicinity. Views in relation to these landmarks have been partially considered in the HTVA. That there have been some obvious errors in the visual assessment however is apparent from view 8 from the southern approach to Tower Bridge. This shows the proposed building as a backdrop to the listed Lambeth College. The representation is clearly wrong in that it shows the building as being behind Guys Tower whereas it is in fact in the foreground. A further consideration in respect of these views is the way the impact of the proposal has been evaluated in relation to heritage assets. Typically this amounts to the glib and highly subjective assertion that the building is so beautiful as to flatter any visually contiguous building (see design below). General The first two view categories above are clearly matters of more than local significance, as is the third, in so far as it relates to the context of listed buildings (defined as being of national importance) . Further, we would argue, so is the principle of purely subjective evaluation of the effect on the outlook from a local conservation area.

The views presented in the HTVA are selective and in some cases obviously erroneous. Given that neither the local authority nor the GLA have checked the views presented by the applicants, the only way such an essential scrutiny can now be applied is through a call-in. Design All planning policy of which we are aware makes design a key consideration where tall buildings are to be considered in historic or otherwise sensitive locations. This constraint becomes meaningless if some strikingly ill-qualified local planners can simply overrule the objections of better-trained, betterinformed and more objective authorities such as CABE and English Heritage. That is precisely what has happened in the case of The Quill and the contrasting language in the local planning officers report and the obviously more aware CABE panel makes the point admirably. If policy is formulated in terms of design quality it cannot be for a local case officer to declare a proposal to be to his liking and thereby square it with such policy.

Local people had been led to believe by Southwark Planners that the introduction of high-rise buildings in this location was a matter of consultation and that a draft SPD for the area establishing the high-rise principle was to be developed with the input of local opinion. On this basis, BVAG commissioned a model to facilitate the exploration of the impact of a high-rise zone in St Thomas Street. In practice it appears that the consultation process in relation to the high-rise zone in general is as much of a sham as the consultation in relation to The Quill itself. The current proposal will in effect establish a high-rise cluster that doesnt presently exist (see domino effect below). This raises the question of whether it is acceptable that a high-rise cluster of buildings can be established by default by local planners and without local or external consultation. Taken together with the other arrogated powers deployed by Southwark Council in this case a high-rise cluster of buildings can be established at London Bridge with negligible outside reference. Such self-contained authority to create high-rise building clusters by unaccountable local authorities has obvious implications of more than local significance for the planning process. Clusters and tall building domino effect: The Quill is a building of 31 floors and an overall height of 108m (+ spikes). The applicants and the planners have sought to justify the building by reference to the nearby Shard under construction and the 1970s Guys Tower. There is an important principle in question of whether any tall building automatically justifies one on its neighbouring sites. Our recollection is that this issue was rehearsed when the Shard was approved many years ago and it was resolved on the basis that it was emphatically not the case and that The Shard was to be a special case to stand in isolation and not to

serve as an umbrella for a high-rise free-for-all. This was always a principle in danger of being conveniently forgotten, exactly as it has. In this particular case the application in hand is declaredly a first domino in a high-rise strategy, supported only by planners and developers, that would see a wall of high-rise development in what by all conventional planning wisdom is an entirely inappropriate location. Clearly the domino principle needs to be checked and this application provides an exemplary case. The points we raise here are matters we believe to have more than local significance and thus relevance to the question of whether this application should be called-in. Other matters of concern to us as a local community group are raised in our submissions to both Southwark Council and the GLA, copies of which have all been provided to Mr McNally. They include a number of irregularities in the planning process at the local level that we believe may be grounds for challenge to the approval at that level. Yours faithfully

Russell Gray Encl. Analysis of LVMF view 2A.1

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