OLD BERMONDSEY

OBNF
NEIGHBOURHOOD FORUM
WWW.OLDBERMONDSEYFORUM.ORG

JOHN FINLAYSON
Head of Development Management
City Hall
The Queen's Walk
London
SE1 2AA

7th June 2019

Dear Mr Finlayson,

Re: GLA/4917/01/JM Bermondsey and Snowsfields Southwark Application 19/AP/0404

Strategic Planning Application Stage 1 Referral

As discussed at our meeting yesterday morning, I write to set out the issues that you were
unfortunately unable to address at the meeting itself. This was disappointing as we thought our
purpose was perfectly clear. It was for us to understand the thinking behind certain of the
observations and conclusions in your Stage 1 report. Clearly, you are thumbing through the report,
apparently reading it for the first time yourself, was not going to assist us in that regard.

The issues about which we therefore left the meeting none the wiser, but which you agreed to
research and respond to us upon are:

How you concluded that there was little to be concerned about by way of adverse
impact on heritage

1. What expertise or specialist advice was engaged by the Mayor in arriving at his opinion on
the significance of the heritage implications of this application? How was the advice of
Historic England, SAVE and The Victorian Society sought and taken into account by the case
officer? Did the case officer even have before her the comments of these bodies when
expressing her opinion in the Stage 1 report? If not, why not?

T: 02073780707 E: info@oldbermondseyforum.org
2. What precisely are the heritage benefits “resulting from the renovation and repair of the existing
warehouse” [para 42] as proposed by this scheme? Given that it guts the historic interior
along with most of the external fabric and drives a 17 storey tower through and above the
building why was this considered to be a preferable treatment of a heritage asset to its
comprehensive restoration which, you are aware, is a perfectly viable alternative?

3. In so far as the Mayor relied upon ‘public benefits’ other than ‘heritage benefits’ in
justification of the adverse effect of this scheme on heritage assets what are those benefits
perceived as being?

4. What consideration was given to the precedent that approval of this application would set
for acceptable regard for heritage in this type of situation? Do you consider that a generally
acceptable means of compliance with local and national heritage policy in London includes
the complete internal demolition of any non-designated (or even designated) heritage asset
with the retention of only its exterior walls and the construction of anything, to any height,
over and above, including in a conservation area? If so, what expert opinion do you rely on
for this view and why do you reject the contrary opinion of Historic England as expressed in
their consultation response of 18 April 2019 and their pre-application advice to the applicant
given in 2018.

5. The Bermondsey Street Conservation Area is characterised by its smaller scale and the
“clear change of character… evident in its quieter, smaller scale” from London Bridge and
Guy’s Hospital (as noted in the Conservation Area Appraisal, paragraph 3.1.1). Why does
the report fail to evaluate the harm that will be caused by the proposed height and massing
to this Conservation Area, specifically characterised by its small scale?

6. The report noted that “the proposed heights are appropriate (for this highly accessible location
within an opportunity area)” [30]. In coming to this conclusion, what consideration and weight
was given to the following?

● Bermondsey Street Conservation Area Appraisal

● Draft New London Plan (2018) Policies D1A2, D1A12, 3.1.1, 3.1.2, HC1C and 7.1.7

T: 02073780707 E: info@oldbermondseyforum.org
 7. In the view of the GLA, is the significance of a conservation area in an Opportunity Area
[‘OA’] or Central Activities Zone? [‘CAZ’] the same as that of a conservation area not in an
OA or CAZ? If not, please explain how and on what policy foundation the GLA believes it
differs.

8. The Bermondsey St Conservation Area Appraisal specifically identifies yellow London stock
brick as the area’s defining material. Why has the report failed to consider the suitability of
the proposed dominant building material (glass) on a 17-storey building atop an iconic yellow
stock warehouse which will dominate views within the conservation area, but at the same
time focused on the unsuitability of this material for the Bermondsey Street buildings, which
are outside the conservation area?

The GLA’s procedure with regard to consultation

9. What is the GLA’s obligation to consider representations from ((a) statutory consultees; (b)
heritage bodies, including Historic England; (c) local amenity groups and; (d) the public at
large at Stage 1, according to DMPO Article 33. (1)(a) and/or the Mayoral Order? With
regard to the former, please state whether you consider this applies to the GLA at all, and if
so, how consultees can ensure its provisions are engaged by their responses.

We look forward to receiving your replies to these questions, as you proposed, within 7 days.

Yours sincerely,

Russell Gray

(Coordinator)
OBNF
Cc:
Juliemma McLoughlin, Chief Planner
Allison Flight, Deputy Head of Development Management
Justine Mahanga, Senior Strategic Planner, Case Officer

T: 02073780707 E: info@oldbermondseyforum.org