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GLOBE HOUSE 37 BERMONDSEY STREET SE1 3JW BVAG.NET Mr Gary Rice Head of Planning Development Southwark Council 160-162 Tooley Street SE1P 5LX BY HAND 26 October 2010 The Quill, Weston Street Dear Mr Rice I write to register our objections to the proposal for the redevelopment of the site in Weston St and St Thomas St, presently Capital House. We do not dispute that Capital House is a building of little or no architectural merit and that a well considered redevelopment could significantly benefit the community and the visual amenity of the buildings immediate environment. The proposal on the table, however, has little or nothing to commend it. It is quite obvious to all that the plans submitted are not for building but are a PR and paper exercise in uplifting the value of the Capital House site. You will be aware that both CABE and Kings College (falsely stated in the application to be the Client) have stated that the building will never be built for technical and economic reasons. You will also know that the instigators of the proposal, Investream, promote themselves as asset managers, specializing in making money through planning applications. The real client is therefore the tax-haven based company that owns Capital House, Bilford Ltd. Little information is available on Bilford because of its Jersey domicile and Investream refuse to identify its beneficial owners. Obviously, however, the application for The Quill is intended to generate windfall gains for the owners of the site that are sheltered from UK taxation. What has induced Southwark planners to go along with this scheme is a mystery. The s.106 agreements referred to in the application documents are one obvious explanation and we hereby request a copy of the Heads of Terms referred to. The other is of course an evident desire among certain members of the planning department to circumvent public consultation about the principle of high-rise buildings in St Thomas St. To approve the Quill application now would obviously be to sabotage the consultation process that is revealing huge community suspicion of the proposed high-rise zone in St Thomas Street.

To enumerate our objections under specific planning heads: Prematurity The proposal is obviously premature in both planning terms and in common sense. In planning terms, as mentioned above, it pre-empts and pre-judges the supposed community consultation on the very issue of high-rise buildings in the Bermondsey village area and as your Head of Planning Policy, Simon Bevan, recently publicly admitted the high-rise zone has yet to be considered in detail (see protected view comment below). In common sense terms, it is obvious that the Shard is going to have a major impact on the London Bridge area and, as the CABE design review of the project stressed long ago, the capacity of the surrounding infrastructure to handle the population influx is questionable. In the same way, so is the impact on the quality of the public space around the building in respect of overshadowing, wind-tunnelling and traffic management. With all of these variables still of unknown impact it is only blind dogma that could assert the benefit of lining the south side of St Thomas St with high-rise blocks at this stage. The Quill would obviously establish the process in a way that could not subsequently be reversed. Protected views The Mayor of Londons London View Management framework protects the view from Parliament Hill towards St Pauls Cathedral (Protected Vista from Assessment Point 2A.1). According to Mr Bevan, the high-rise zone that this development seeks to initiate has not yet been assessed for its impact on this protected view. We are currently constructing our own visual representation of the effect the proposal would have on this viewing corridor. It indicates that there would be some obscuring impact on the secondary towers of St Pauls Cathedral by presenting a busy background with a dazzle camouflage effect detracting from visual definition. The views presented by the applicant, on our analysis, understate this effect. This matter should clearly have been carefully considered and Mr Bevans assertion that it has not is surprising. The views to be considered are easily susceptible to subtle variation and no approval should be given prior to an accurate visual representation being produced and consulted upon. Impact on heritage assets and the Bermondsey St Conservation Area The proposal shows a disregard for the Bermondsey Street Conservation area immediately to the South of the proposed site, notable local buildings and views and to the presently (but erroneously) unlisted London & Brighton Railway viaduct in St Thomas Street and Crucifix Lane. High-rise in the proposed locatiojn will inevitably create an undesirable wind tunnel effect in St Thomas Street as well as casting the

north side of the street and the historic railway viaduct into deep shade. This will have the effect of making almost impossible the realization of the potential of the decorative arches and St Thomas Street to afford a pedestrian-friendly retail and restaurant environment as they are so obviously capable of doing. Such a lost opportunity threatens the ability of the environment to absorb the shock on the infrastructure that the Shard will deliver. (See CABE Design Review 2003) Policy dictates that tall buildings must not detract from buildings of significance or the character of the Bermondsey Street Conservation Area. This proposal obviously has a highly destructive effect on the Conservation Area visually overwhelming many notable buildings and views from within the conservation area. To specify a few: Isambard House in Weston St and the view along the street looking North towards St Thomas St through overbearing, the railway viaduct through overshadowing and overwhelming, views from the Tower of London and Tower bridge. Employment and Opportunity Area Although nobody believes the proposal will ever be built, it is submitted as a Student housing scheme and it is therefore on this basis that it must be assessed. The CAZ policy applicable to the area calls for employment (and housing). Student accommodation provides neither. The extravagant plans would inevitably put the accommodation at a high premium to conventional student housing. There is no demonstrable demand for such premium student accommodation in the area. The proposal, therefore, does not provide any of the affordable student accommodation for which the applicants cite a demand. This is implicit in the acknowledgment by Kings College that the proposed building cannot actually be realized. In the applicants Planning Statement, in a parody of plannababble there is an absurd justification of a loss of office employment space by redefining it as ancillary educational support facilities. Ergo, there is no loss of office space. Presumably not even the people who wrote it believe this. The existing building on the site, Capital House, is undeniably of negligible architectural merit. The only argument for its retention would be an environmental one. The concrete framed existing structure is certainly capable of being retained and re-worked to provide good quality offices to meet contemporary market demand. The applicants argument to the contrary is empty and unsupported by any evidence. An aesthetically better option for redevelopment of Capital House in line with CAZ policy would be to replace the building with a building of higher quality. This can quite easily be of comparable scale and massing and can provide the employment or housing accommodation that policy calls for. Policy for the CAZ looks much further ahead than a short-term surplus of office accommodation and indeed such surpluses can drive building owners to precisely the upgrading and refurbishment of the office stock that is required in the area. The convoluted arguments of the applicants are clearly invalid and the replacement of the present building with student accommodation which provides minimal employment would obviously represent a loss of employment space that is contrary to policy for the area.

Student accommodation also sidesteps the necessity to create affordable homes that other residential development entails. On this the applicant seeks to get in before the emerging policy dictating that student accommodation cannot be used to circumvent social housing obligations on developers. (Core Strategy Policy 8) Transport and Infrastructure The proposal fails to address the traffic issues that such a high-density development will inevitably generate. The proposed use of the building as student accommodation does not imply there will be no vehicular traffic generated. In fact, the nature of student housing dictates a high degree of transience. At the beginning of an academic term there would be some 500 students arriving by car with their belongings for the term. The proposal makes no realistic allowance for how this weight of vehicular traffic could be handled by the facilities at street level.

On a less technical and policy-focused level, BVAG has now conducted a widespread consultation with the local community about the high-rise zone proposed in the forthcoming SPD and about the pre-emptive Quill proposal. There is considerable local dissatisfaction with the way this policy has been formulated and there is a strong local interest in the opportunity that the forthcoming Decentralisation and Localism Bill will offer for more community responsive planning policy formulation. This sentiment is reinforced by the recognition that local people overwhelmingly do not want or believe in the necessity for high-rise buildings in St Thomas Street. A forthcoming community plan that has now been discussed with the local MP, Simon Hughes, and English Heritage offers a far more popular vision for the treatment of St Thomas Street. This vision places the Railway viaduct in its rightful place as a major asset to the Bermondsey Village area. The viaduct presents a natural boundary to the historically and architecturally well-defined area to the South. Visitors and locals alike are generally astonished at the insensitivity of plans to create a wall of high-rise development dividing Bermondsey Village from its greatest architectural asset. In a community-backed plan, restoration of the railway arches would create of St Thomas St precisely the public space that the CABE design review of the Shard recognized was essential to the success of the building and the area. St Thomas St can be a welcoming and pedestrian friendly public space making a decisive contribution to the neighbourhood. This opportunity would be lost by the introduction of a wall of high-rise on the south side of St Thomas St. The restoration of the arches would not be viable unless they could create the beautiful, restaurant/retail spaces of which they are so obviously capable. Casting them into a wind-tunnel and permanently depriving them of sunlight would make the community vision unrealizable. Approval of the Quill would be nothing short of sabotage of a community plan that has the potential to demonstrate precisely why the kind of thinking that has driven the Decentralisation and Localism Bill is long overdue.

The Bermondsey Village community has a wealth of professional skills and passionate commitment to the area. It should be given a chance to show exactly why planners should listen to such communities. Yours sincerely

Russell Gray cc. Peter John, Leader of the Council, Southwark Council Simon Bevan, Head of Planning Policy, Southwark Council Boris Johnson, Mayor of London Gemma Kendall, Case Officer, GLA

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