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GLOBE HOUSE Mr Boris Johnson Mayor of London GLA City Hall BY HAND Dear Mr Johnson A few hundred metres from the GLA building stands the historic London & Greenwich (later London & Brighton) Railway viaduct. Dating from 1836, this structure heralded and symbolised the great age of the railways, being the first commuter line in the world. When the viaduct was widened in the 1860s it was given one of its most architecturally imposing features, the ornate, carved York stone and elaborately detailed brickwork arches in St Thomas St and Crucifix Lane. The double height section of this structure and the ironwork roof to London Bridge Station that it supports are listed and English Heritage is currently considering our application to remove an anomaly by listing the single tier section to the East. About 60 metres to the south of the railway arches is the Bermondsey Street Conservation Area. This is an area of medieval streets with a character that evolved from the era of dominance by its monastries, starting in the 7th century, through preindustrial craftsmanship and Victorian trade and industry to post-war dereliction. Today it has been revived with a resurgence of creative, small/medium sized businesses to whom its history and non-corporate, mixed character is a major attraction. On a small site in the 60m strip separating Bermondsey St Conservation Area from its natural boundary the railway viaduct presently stands an unimposing but archetypal 60s office block of modest bulk and intrusion on the senses, called Capital House. Nobody who has read what you have said about the right places for tall buildings in London could have imagined that your administration would identify the narrow strip between the railway arches and the Conservation Area, including the Capital House site, as being among them. And yet it appears that extensive negotiation and discussion has taken place between your staff and the proposers of a steel and glass tower of more than three times the height and bulk of Capital House. This appears to have taken place against a background of presumed acceptability of such proposals despite the fact that local people have been led to believe that the very issue of such a high-rise treatment of a historic area was in consultation. 37 BERMONDSEY STREET SE1 3JW BVAG.NET 7 December 2010

A large number of residents from what Southwark planners have dubbed slightly patronizingly Bermondsey Village attended the Planning Committee meeting at Southwark Town Hall on Tuesday night for the hearing of this application. Particularly those with no experience of the local planning process watched in bemusement as five out of seven members of Southwark Councils Planning Committee nodded through the proposal. With the creditable exception of two of the Liberal Democrat members, ex-leader of the Council, Nick Stanton and exmayor, Jeff Hook, the Committee demonstrated little interest or understanding of the nature, implications or significance of what they were voting on. Less still were they ready, willing or able to question the irregularities in the vigorous promotion (often to the point of gross misrepresentation) of the proposal by Southwarks planners. BVAG has grown out of a community incensed by a recent history of the planners formulating local planning policy in secret collusion with developers with vested commercial interests. A string of meetings at which private developers literally dictated the wording they expected the planners to incorporate into the local plan has recently been uncovered through our FOIA requests. Needless to say, the resultant policy disregards local opinion entirely and feeds unbridled greed in developers. As we understand its effect, the forthcoming Decentralisation and Localism Bill could have been conceived in response to Southwarks planners: a textbook case of a planning department out of control and in collusion with developers against the Community. (To our surprise, our long-standing local MP, Simon Hughes, was happy to confirm this impression when he came to speak to us recently.) Since it now falls to you to consider the Quill for approval we are asking (and expecting) that you will bring a much more informed, critical and balanced judgment to bear on the proposal. Paramount in any such balanced appraisal would be a visit to the site and an acquaintance with the local community to understand the strength of feeling locally and the sheer common sense of the alternative plan for realization of the regeneration potential in the area. In our newly established community information and planning office we have assembled plans, documents and an architectural model of the area to show how the secret collusion between planners and developers has brought us to our present position. Going forward, it will become a hub for the formulation of the alternative community plan for the area that is now in gestation, specifically in relation to St Thomas Street. At the heart of the issue is the correct treatment of St Thomas Street so far as high buildings are concerned. The Council have drawn supposedly for consultation, but apparently now pre-determined by approval of the Quill a two dimensional plan zoning the South side of St Thomas St and part of Bermondsey St for tall buildings.

As well as BVAG, English Heritage have questioned the evidence base (EHs words) for this plan. There is an abundance of evidence that it was conceived entirely in collusion with developers and without any rationale beyond accommodating them. This evidence is extensive enough that it would have to be the subject of a personal meeting to explore fully. However, the fact that the high-rise zone was unsustainable on scrutiny as the planners had contrived to try and ensure never happened is evident from the re-drawing that our campaign has already forced them into. Their response has been to retreat the zone from Bermondsey St with no account of how it came to be there in the first place. Further obvious evidence that the zone was a hastily contrived bunk-up for favoured developers is the fact that even as it stands after amendment the high rise zone significantly overlays the Bermondsey Street Conservation Area. The planners have been invited to show how a tall building zone can intelligibly incorporate part of a conservation area. Their response, as ever when they dont like a question, is to avoid the issue. It was in the (now seemingly naive) belief that the announced consultation process in relation to the high-rise zone was not a sham that BVAG commissioned an architectural model on which a coherent three dimensional envelope for tall buildings could be explored by local people and if they were willing the planners themselves. The model has been on display at the BVAG information office throughout the recent consultation which drew around two hundred letters of objection to the local SPDs high-rise plan for St Thomas Street. Unfortunately, although among local people there is a very high level of consensus as to how St Thomas Street should be treated, the planners have shown no readiness to engage in a dialog with us. We are therefore relying on the forthcoming changes in legislation to force them to do so. We would urge you to take advantage of our model, our preliminary sketches and our research to inform your judgment on whether the Quill should be approved at a stage of such prematurity in the emergence of the local plan on which it relies for its justification. It is against this background that we submit the application for the Quill must be understood. It has been hurried through by Southwark Council, even to the point of issuing consultation letters in contravention of required time windows for responses. There is an obvious question mark over the feasibility of the building. The CABE report on the proposal is an informed and reasoned commentary in stark contrast to the comically effusive eulogy that is the Southwark planners report. CABE points out that the building is a very dubious proposition technically and commercially, that its internal design is unpersuasive and that the same number of student rooms could be accommodated on a building of a much lesser height. Even Mr Caldwell (the man from the Estates department of kings College now in difficulty over authorizing the applicants to use the Kings College name as the Client instead of the Jersey Company that is in fact) freely acknowledged when he visited our information office that nobody expected the building to be built as presented.

Making planning applications for buildings that are not intended for building is of course a liberating experience. Fanciful designs, freedom to offer generous s.106 agreements, no concerns over falsehoods in application documents particularly the visual impact assessments are all notable benefits. So why is a building that nobody expects to be built of such importance? The answer is of course for the precedent it establishes in favour of high-rise buildings in this sensitive location. For the applicants, Investream, it means they have done what they say they do on their website: add value to land through obtaining planning consents. This enables the off-shore client company to sell the site at a handsome tax-free profit to a developer with a more commercially realistic plan. For the planners it offers them a chance to put a stake in the ground for a counter-attack on behalf of their high-rise plans that are in retreat as a result of a rebellion in the local community and where a new legislative framework may further undermine their freedom to operate in defiance of local opinion. The issues addressed here have been set before Southwarks planners but they have become as brazen as they are arrogant and they have taken little notice. I enclose the representations we made in relation to the Quill application together with a summary of our points of concern, along with supporting documents, that was put before all members of the Planning Committee before their meeting last Tuesday. I would particularly draw your attention to the issues relating to views of the proposed development. These include the local views from the conservation area and from the Tower of London (to which English Heritage object) and those from the viewing points protected by the LVMF. We have not been able to secure the cooperation of the applicants in verification of these views. The location of the proposal makes it easy for a small error to substantially diminish the effect on protected views. There is of course considerable incentive for applicants to make such errors particularly as planning policy, in Southwark at least, is not to check them. The enclosures address numerous issues that demonstrate the considerable potential that approval of the Quill has for becoming a seminal planning mistake in the area. We urge you to take every step to ensure that you have satisfied yourself that approval, if granted, is not the result of a failure to fully consider all the implications. One such step, we suggest, should be a site visit, including a briefing in our information office, assisted by the drawings, images, model and research we have compiled. Yours sincerely

Russell Gray c.c. Sir Simon Milton, Deputy Mayor and Chief of Staff Giles Dolphin, Head of Planning Decisions Gemma Kendall, Case Officer

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