Cabinet: 28 January 2014 Blackfriars Road Supplementary Planning Document

Transcription

1 Cabint: 28 January 2014 Blackfriars Road Supplmntary Planning Documnt No. Titl Hld at Appndix A Appndix B Appndix C Appndix D Blackfriars Road supplmntary planning documnt, 2014 Rprsntations rcivd and th officr commnts (Appndix J of th consultation rport) Trackd changd vrsion of th Blackfriars Road supplmntary planning documnt, 2014 Consultation rport including a sparat documnt containing appndics A-I Two sparat documnts Hard copy providd with th rport Availabl on th wb at: mnts.aspx?cid=302&mid=4554&vr=4 Availabl on th wb at: mnts.aspx?cid=302&mid=4554&vr=4 Availabl on th wb at: mnts.aspx?cid=302&mid=4554&vr=4 Appndix E Equalitis analysis Availabl on th wb at: cumnts.aspx?cid=302&mid=4554&vr=4 Appndix F Sustainability appraisal Availabl on th wb at: mnts.aspx?cid=302&mid=4554&vr=4 Appndix G Sustainability statmnt Availabl on th wb at: mnts.aspx?cid=302&mid=4554&vr=4 Appndix H Appropriat assssmnt Availabl on th wb at: mnts.aspx?cid=302&mid=4554&vr=4 Appndix I Urban dsign study Availabl on th wb at: mnts.aspx?cid=302&mid=4554&vr=4 Appndix J Businss and mploymnt background papr Availabl on th wb at: mnts.aspx?cid=302&mid=4554&vr=4

2 Appndix J of th Blackfriars Road SPD, 2014 Consultation rport REPRESENTATIONS AND OFFICER RESPONSES ON THE DRAFT BLACKFRAIRS ROAD SUPPLEMENTARY PLANNING DOCUMENT, 2013 Rp Obj Rf Rf Nam Dtails of Rprsntation Stphn Darcy I am gratly concrnd about th proposd dvlopmnts at th southrn nd of Blackfriars Rd. Whil I wlcom th badly ndd rdvlopmnt of th road I am concrnd about th hight of th proposd towr at St. Gorg's Circus. It is too high and not in kping with th othr buildings. Officr Rspons to Rprsntation A tall building up to 70m in hight providd that it complis with th dtaild guidanc outlind in SPD 5 and th xisting planning policy framwork (th rlvant savd Southwark Plan policis, Cor Stratgy Policy SP12, th rlvant policis of th London Plan and othr planning documnts/guidanc) could b appropriat at th southrn nd of Blackfriars Road. Also th proposal for th railway sidings at St Gorg's Circus along th back of Gladston st: attntion must b paid to th uniqu attraction of this strt. I suggst a park. Th Blackfriars Road SPD urban dsign study sts out th robust vidnc bas. In light of consultation rsponss and to add clarity to th guidanc rlating to St Gorg s Circus in SPD 5, th SPD has bn updatd to clarify that a tall building could provid a focal point at th southrn nd of Blackfriars Road and should b st back from St Gorg s Circus. Th tall building should also sustain, nhanc or bttr rval th local hritag assts. Th TfL Bakrloo sidings sit (Sit 43 in Figur 5/Tabl 1 in th draft SPD, but r-numbrd as Sit 47 in Figur 6/Tabl 1 in th updatd SPD) has bn includd as a potntial dvlopmnt sit, du to its rcognisabl dvlopmnt potntial. Any dvlopmnt at th sit would b assssd and dtrmind at th planning application stag, taking th local hritag contxt into account. Th SPD stats that th list of potntial dvlopmnt sits is illustrativ of th hug opportunity for chang within th ara and th nd for a cohrnt framwork. It has also bn updatd to clarify that th list of sits is not xhaustiv and othr sits may com forward for

3 Rp Obj Rf Rf Nam Dtails of Rprsntation John Bourn Th two aspcts of th SPD that w find most 1 3 objctionabl ar: 1: Provision for a towr block 70 mtrs high at St Gorg s Circus 2: Th dsignation of th Bakrloo sidings sit (which is immdiatly bhind Gladston Strt) as a potntial dvlopmnt sit Officr Rspons to Rprsntation dvlopmnt. Som of th sits will b compltly rdvlopd, whilst othr sits may xprinc lss chang such as rfurbishmnt or improvmnts to th xisting buildings or surroundings. Th formal idntification of proposals sits within th ara will b considrd as part of th prparation of th Nw Southwark Plan. It is rcognisd that thr is a dficincy in opn spac within th SPD ara. Howvr th opportunity for nw parks is limitd. Th SPD cannot dsignat nw opn spacs, but dos ncourag nw public spac and landscaping within SPD 3. A tall building up to 70m in hight providd that it complis with th dtaild guidanc outlind in SPD 5 and th xisting planning policy framwork (th rlvant savd Southwark Plan policis, Cor Stratgy Policy SP12, th rlvant policis of th London Plan and othr planning documnts/guidanc) could b appropriat at th southrn nd of Blackfriars Road. Th Blackfriars Road SPD urban dsign study sts out th robust vidnc bas. In light of consultation rsponss and to add clarity to th guidanc rlating to St Gorg s Circus in SPD 5, th SPD has bn updatd to clarify that a tall building could provid a focal point at th southrn nd of Blackfriars Road and should b st back from St Gorg s Circus. Th tall building should also sustain, nhanc or bttr rval th local hritag assts. Th TfL Bakrloo sidings sit (Sit 43 in Figur 5/Tabl 1 in th draft SPD, but r-numbrd as Sit 47 in Figur 6/Tabl 1 in th updatd SPD) has bn includd as a potntial dvlopmnt sit, du to its rcognisabl dvlopmnt potntial. Any dvlopmnt at th sit would b assssd and dtrmind at th planning application stag, taking into account local contxt. Th SPD stats that th list of potntial dvlopmnt sits ar illustrativ of th hug opportunity for chang within th ara and th nd for a cohrnt framwork. It has also bn updatd to clarify that th list of sits is not xhaustiv and othr sits may com forward for dvlopmnt. Som of th sits will b compltly rdvlopd, whilst othr sits may xprinc lss chang such as rfurbishmnt or improvmnts to th xisting

4 Rp Obj Rf Rf Nam Dtails of Rprsntation John Bourn Th SPD proposs that Blackfriars Road b dvlopd 2 3 solly as a sris of tall buildings with infill of significant hight. Whr is th vidnc to support this vision for th ara rathr than som altrnativ dvlopmnt plan? Which othr plans wr considrd and rjctd? During consultation w hav bn informd that no particular nd us is nvisagd for any of th sits dsignatd for dvlopmnt. Whr is th justification for ignoring th suitability of particular sits of th dsignatd aras for any particular form of dvlopmnt, givn th snsitiv natur of th hritag contxt? It sms clar to us that th rol of th Local Authority in connction with th SPD is that of a dvlopmnt nablr rathr than a rgulator. This throws onto th community th rsponsibility to act as a rgulator John Bourn In including larg aras of land that hav nothing to do 3 3 with Blackfriars Road, Southwark Council will undrmin Nighbourhood Forums (South Bank and Watrloo Nighbourhood Forum and th Banksid Officr Rspons to Rprsntation buildings or surroundings. Th formal idntification of dvlopmnt sits within th ara will b considrd as part of th prparation of th Nw Southwark Plan. Th mrging vision for th SPD ara builds on th adoptd visions within th Cor Stratgy and London Plan and is considrd to b consistnt with th NPPF (2012), th London Plan (2011), th Cor Stratgy (2011) and th savd Southwark Plan (2007), taking into account changs in th surrounding contxt sinc dvloping th Cor Stratgy vision in 2009/2010. Th London Plan, Cor Stratgy and savd Southwark Plan form th dvlopmnt plan for Southwark, with th NPPF stting out national guidanc. Th dvlopmnt plan sts out th policis for tall buildings. Th guidanc in th SPD provids dtail on how to implmnt ths dvlopmnt plan policis spcific to Blackfriars Road, and sts out that building hights should b lowr away from Blackfriars Road. This approach is supportd by our vidnc bas including th Blackfriars Road Urban Dsign Study which has bn prpard in accordanc with CABE and English Hritag Guidanc on Tall Buildings, SPD 5 sts out clar guidanc for th ara, and that building hights should b lowr away from Blackfriars Road. Th SPD dos not dsignat proposals sits or provid sit spcific guidanc, as this would byond th scop of th SPD. It dos idntify potntial dvlopmnt sits which ar illustrativ of th hug opportunity for chang within th ara and th nd for a cohrnt framwork. Th SPD has also bn updatd to clarify that th list of sits is not xhaustiv and othr sits may com forward for dvlopmnt. Som of th sits will b compltly rdvlopd, whilst othr sits may xprinc lss chang such as rfurbishmnt or improvmnts to th xisting buildings or surroundings. An xplanation of th boundary is st out within th SPD. It includs th whol of th Blackfriars Road and som of th surrounding ara. It includs th surrounding ara as th surrounding ara is also likly to s som dvlopmnt and improvmnts, particularly possibl

5 Rp Obj Rf Rf Nam Dtails of Rprsntation Nighbourhood Forum) and th Localism Act Can th council dmonstrat that th SPD will giv a bttr outcom than thos nvisagd by Nighbourhood Forums Officr Rspons to Rprsntation improvmnts to public ralm. Wording has bn addd to th SPD to mak it clarr that th charactr and historic valu of much of th surrounding ara will continu to b protctd and nhancd. It has also bn mad clar that th aras which ar prdominantly housing will mostly continu to b so, with rsidnts bnfitting from th incrasd rang of activitis on th Blackfriars Road John Bourn Dvlopmnt Sit 43 Th Bakrloo Sidings Any dvlopmnt on this sit will intrfr with long viws into th Wst Squar Consrvation Ara valud by Southwark Planning. What considration has bn givn to ths in th prparation of this SPD? What is th vidnc to support its suitability as a dvlopmnt sit as opposd to ducational, opn spac or othr us? Undr th Elphant & Castl Entrpris Quartr SPD Southwark should hav consultd TfL. Undr th Localism Act consults ar duty bound to co-oprat so whr may w s TfL s rspons? Any building on this sit will advrsly affct th stting of hritag assts. Th Elphant & Castl Entrpris Ara SPD mntiond a landmark building. W find rfrnc to any such building on this sit dply concrning givn Figur 3 of th SPD illustrats th rlationship btwn diffrnt planning documnts including supplmntary planning documnts and nighbourhood plans. Th SPD has bn updatd to mak it clar th nighbourhood plans ar currntly bing prpard. Onc adoptd a nighbourhood plan will hav mor wight than a SPD in th planning procss as it will form part of th council's dvlopmnt plan. At prsnt thr is no adoptd nighbourhood plan for any of th ara covrd by th Blackfriars Road SPD. Th SPD may nd to b rviwd in th futur if a nighbourhood plan is adoptd for any of th SPD ara. Th TfL Bakrloo sidings sit (Sit 43 in Figur 5/Tabl 1 in th draft SPD, but r-numbrd as Sit 47 in Figur 6/Tabl 1 in th updatd SPD) has bn includd as a potntial dvlopmnt sit, du to its rcognisabl dvlopmnt potntial. Any dvlopmnt at th sit would b assssd and dtrmind at th planning application stag, taking into account local contxt, which includs th local hritag assts. Th SPD dos not dsignat proposals sits or provid sit spcific guidanc, as this would byond th scop of th SPD. It dos idntify potntial dvlopmnt sits which ar illustrativ of th hug opportunity for chang within th ara and th nd for a cohrnt framwork. Th SPD has also bn updatd to clarify that th list of sits is not xhaustiv and othr sits may com forward for dvlopmnt. Som of th sits will b compltly rdvlopd, whilst othr sits may xprinc lss chang such as rfurbishmnt or improvmnts to th xisting buildings or surroundings. TfL, GLA and Ntwork Rail wr all consultd as part of th

6 Rp Obj Rf Rf Nam Dtails of Rprsntation th proximity not only to our own listd houss but also th listd oblisk, St Gorg s RC Cathdral and Imprial War Musum, th lattr two bing th landmark buildings in this location. How ar ths proposals affctd by th Blackfriars Road SPD? Officr Rspons to Rprsntation consultation procss. Th Blackfriars Road SPD consultation rport summariss all th rsponss rcivd and changs subsquntly mad to th SPD. Th full rprsntations rcivd from ths bodis and th council s rspons to thm is includd within Appndix J of th Blackfriars Road SPD consultation rport John Bourn Stratgic viws St Gorg s Circus and Tall Buildings St Gorg s Circus is a fin xampl of Gorgian town planning with its focal point at its cntr, th Grad 2* listd oblisk. SPD 5 Building Hights proposs a tall building of hight up to 70 mtrs should provid a focal point at St Gorg s Circus. This statmnt displays a fundamntal ignoranc of this circus. A tall building will affct th stting of not only th oblisk, an important hritag asst, but also th listd Gorgian trracs in London Road. Plas dmonstrat undr London Plan CDR1 how tall building dvlopmnt, a fundamntal chang in architctur, will not advrsly affct th local charactr. Whr is th comprhnsiv urban dsign analysis of th local charactr and historic contxt? (CABE and English Hritag Guidanc on Tall Buildings CDN25) St Gorg s Circus is statd on pag 29 of th SPD to b a transport nod. It cannot, by th accptd dfinition of a transport nod, b so dscribd. Dvlopmnt sits 39, 40, 41 and 43 dirctly affct th Circus and othr hritag assts. Council officrs hav statd that tall buildings at St Gorg s Circus would not b a conflict with th adjoining hritag assts. Th Elphant and Castl SPD was adoptd on 20 March 2012 and rplacd th Elphant and Castl Entrpris Quartr SPD (2008) and th Walworth Road SPD (2008). Th Blackfriars Road SPD will rplac th Elphant and Castl SPD/OAPF guidanc for th ovrlapping aras. Th SPD has bn updatd to mak this clarr. A tall building up to 70m in hight could b appropriat at th southrn nd of Blackfriars Road providd that it complis with th dtaild guidanc outlind in SPD 5 and th currnt dvlopmnt plan that includs th rlvant policis of th savd Southwark Plan (2007), Cor Stratgy (2011), London Plan (2011) and othr planning documnts/guidanc, including th NPPF (2012). Th dvlopmnt plan sts out th policis for tall buildings. Th guidanc in th SPD provids dtail on how to implmnt ths dvlopmnt plan policis spcific to Blackfriars Road. Th approach is supportd by our vidnc bas including th Blackfriars Road Urban Dsign Study which has bn prpard in accordanc with CABE and English Hritag Guidanc on Tall Buildings, In light of consultation rsponss and to add clarity to th guidanc rlating to St Gorg s Circus in SPD 5, th SPD has bn updatd to clarify that a tall building could provid a focal point at th southrn nd of Blackfriars Road up to 70ms. A tall building should also sustain, nhanc or bttr rval th local hritag assts. Th SPD dos not dsignat proposals sits or provid sit spcific guidanc, as this would byond th scop of th SPD. It dos idntify potntial dvlopmnt sits which ar illustrativ of th hug opportunity for chang within th ara and th nd for a cohrnt framwork. Th SPD has also bn updatd to clarify that th list of sits is not xhaustiv and othr sits may com forward for

7 Rp Obj Rf Rf Nam Dtails of Rprsntation Whr is th vidnc that this is not a conflict? In dtrmining tall building hight limits within th SPD of 70 mtrs, whr is th assssmnt of thr dimnsional modlling to dtrmin th potntial ffct on th local contxt? (CABE and English Hritag Guidanc on Tall Buildings CDN John Bourn Why ar hotls bing promotd (SPD 3.10) as viabl us whn Southwark has alrady achivd or is clos to achiving th rquirmnts. Th figurs for hotl rooms in th SPD mak it clar that, of th 2500 bdrooms rquird by th GLA s Hotl Dmand Study 2006 by 2026, all but 75 hav ithr bn built or ar in th piplin. Officr Rspons to Rprsntation dvlopmnt. Som of th sits will b compltly rdvlopd, whilst othr sits may xprinc lss chang such as rfurbishmnt or improvmnts to th xisting buildings or surroundings. Any dvlopmnt of th potntial dvlopmnt sits would b assssd and dtrmind at th planning application stag, taking into account local contxt, which includs th local hritag assts. Th London Plan sks to achiv 40,000 nt additional hotl bdrooms by 2031.Th stimat of th approximat nt and gross hotl rooms rquird ovr th priod for Southwark, as st out in th GLA s Hotl Dmand Study, is basd on assssmnt of factors including transport links to cntral London and connctions to airports, proximity of tourist attractions/businss locations, cafs and rstaurants in th ara, night tim conomy, cultural facilitis and attractions, and rgnration initiativs and sit availability. Th forcast for Southwark should b tratd as indicativ only, and local circumstancs should also b factord in. It is important to considr that th SPD ara is within th Cntral Activitis Zon, Banksid, Borough and London Bridg Opportunity Ara and part of th Elphant and Castl Opportunity Ara which ar aras promotd in th London Plan to accommodat stratgically important hotl provision. Arts, cultural and tourism activitis hav flourishd in Southwark in th last dcad, particularly in th Stratgic Cultural Ara, which is within th CAZ. Banksid, Borough and London Bridg has consquntly xprincd a growth in th numbr of hotls to support this incrasing visitor conomy. Th SPD2 provids guidanc to support Cor Stratgy policy 10 Jobs and businss which sts out th council will allow th dvlopmnt of hotls within th town cntrs, th stratgic cultural aras, and placs with good accss to public transport srvics, providing that ths do not harm th local charactr. Policy 10 and SPD 2 ar also supplmntd by th savd policy 1.12 of th Southwark Plan which addrsss visitor accommodation. Nw hotl proposals in th ara will b assssd against ths rlvant planning policis and a considration of th impact upon local amnity and th balanc of land

8 Rp Obj Rf Rf Nam Dtails of Rprsntation John Bourn Travl SPD6 givs no spcific information as Blackfriars Road falls undr th jurisdiction of TfL. Undr th Localism Act both TfL and Southwark Council ar duty bound to shar any consultation information rgarding activ travl. What plans hav bn proposd? John Bourn Gnral Th documnt rfrs to shops along th whol of Blackfriars Road but maks no rfrnc to a rtail impact study, indicating dmand for ths or th ffct on nighbouring shops John Bourn No mntion is mad of nvironmntal impact assssmnts, wind and daylight modlling, which ar fundamntal rquirmnts in considring proposals of this natur, particularly considring th difficultis with th Palstra and Walki Talki buildings John Bourn Th documnt stats that crim will b rducd yt thr is no rfrnc to xisting or anticipatd crim statistics. Has th Mtropolitan Polic bn consultd? If ths studis hav bn obtaind and modlling carrid out thn ths should b in th public domain and not withhld. Plas advis whr ths may b sn. Officr Rspons to Rprsntation uss will also b takn into account. Th txt within SPD 6 has bn updatd to clarify that Blackfriars Road falls undr th jurisdiction of TfL. A consultation rport has bn prpard summarising rsponss to th consultation on th draft Blackfriars Road SPD. All rsponss to th SPD consultation will b publishd on th Council's wbsit prior to th SPD bing takn to Cabint for adoption. TfL hav now announcd that TfL ar proposing to introduc a Cycl Suprhighway on Blackfriars Road, with consultation proposd for summr Rsults of this consultation would b shard on TfL's wbsit. Th SPD businss and rtail background vidnc papr sts out furthr dtail to SPD2 and th futur rtail capacity for th Banksid and Borough district town cntr. This dtail has bn rfrncd from th Southwark Rtail Capacity Study. Th study valuats th vitality and viability of th town cntr, in trms of its rtail prformanc and it idntifid that th focus should b on continuing to mt th nds of workrs, tourists and visitors in th town cntr. Th study concludd that nw rtail schms will b supportd by an incras in population in th ara, through nw rsidnts, workrs and visitors and ths will com forward on an incrmntal basis. Ths mattrs would b assssd at th planning application stag through th rlvant savd Southwark Plan policis, Cor Stratgy Policy SP12 and th rlvant policis of th London Plan and othr planning guidanc. Bullt-point 14 of SPD 5 sts out furthr guidanc rgarding microclimat. Th Mtropolitan Polic ar on th planning policy's mailing list and wr consultd as part of th consultation on th Blackfriars Road SPD. Th sustainability appraisal and th sustainability appraisal scoping rport which both informd th prparation of th SPD provid furthr information on th possibl impact of th SPD on crim. Th sustainability appraisal assssd th impact of th SPD guidanc on sustainability objctiv SDO4: To rduc th incidnc of crim and far of crim, and finds that th SPD is likly to ovrall hav a positiv

9 Rp Obj Rf Rf Nam Dtails of Rprsntation John Bourn Why has Wst Squar Consrvation Ara not bn 1 3 mntiond in SPD4 and SPD5? Th tall buildings proposd affct th stting of this Consrvation Ara and its Listd Buildings Officr Rspons to Rprsntation impact. Th sustainability scoping rport also provids furthr information stting out information on th Indics of Multipl Dprivation which includs crim as on of its six indicators. Both documnts ar availabl to viw on th council's wb sit at: and Th Wst Squar consrvation ara is situatd outsid th Blackfriars Road SPD ara, but would still b considrd within SPD 3, 4 and 5 as a hritag asst. Any dvlopmnt proposal would b assssd at th planning application stag against th rlvant savd Southwark Plan policis, Cor Stratgy Policy SP12 and th rlvant policis of th London Plan and othr planning guidanc John Bourn This SPD has 1 Businss Spac, 2 Mixd Us Town Th SPD sts out that it provids furthr guidanc to xisting planning 2 3 Cntr, 3 Public Ralm and Opn Spac, 4 Built Form policis in th Cor Stratgy and savd Southwark Plan. It dos not and Hritag, 5 Building Hights and 6 Activ Travl. It rpat borough wid policis and th SPD must b rad alongsid dos not hav a Stratgy or Guidanc for Housing. othr planning documnts. Housing is not givn its own sction within Why not? th SPD bcaus th borough-wid housing policis and guidanc alrady covr housing adquatly. This includs policis in th Cor Stratgy and savd Southwark Plan and SPDs on affordabl housing and rsidntial dsign standards. Th vision alrady rfrs to housing dvlopmnt. Housing will b ncouragd on appropriat sits. In ordr to mak this clarr, w hav updatd SPD 2: Mixd us town cntr to includ rsidntial dvlopmnt as on of th uss to b ncouragd alongsid th provision of a mixtur of nw town cntr uss. Th fact box on town cntr uss has also bn updatd in accordanc with th National Planning Policy Framwork dfinition to mak it clar that rsidntial dvlopmnt is not a main town cntr us but it can play an important rol in nsuring th vitality of town cntrs. W hav also insrtd a nw appndix (appndix A) listing th ky borough wid Southwark planning policis and supplmntary

10 Rp Obj Rf Rf Nam Dtails of Rprsntation Officr Rspons to Rprsntation planning guidanc to mak it clarr that ths policis nd to b rad alongsid th Blackfriars Road SPD. Sction 1 of th SPD has bn updatd to rfr to this nw appndix John Bourn Th Council s Cor Stratgy 2010 dos not support tall Th policy approach and mrging vision within th SPD is considrd 3 3 buildings in Blackfriars Road South, as thy do not to b consistnt with th NPPF (2012), th London Plan (2011), th mt th critria for vision vibrancy and lif. Why Cor Stratgy (2011) and th savd Southwark Plan (2007), taking dos th Council s vision now diffr from th Cor into account changs in th surrounding contxt sinc dvloping th Stratgy? Cor Stratgy vision in 2009/2010. Th London Plan, Cor Stratgy and savd Southwark Plan form th dvlopmnt plan for Southwark, with th NPPF stting out national guidanc. Th dvlopmnt plan sts out th policis for tall buildings. Ky policis ar: London Plan policy 7.7 which idntifis that tall and largr buildings should gnrally b limitd to sits in th Cntral Activitis Zon, opportunity aras, aras of intnsification or town cntrs that hav good accss to public transport John Bourn In 2012 UNESCO notd in its convntion brifing papr that in April 2011 Southwark s Cor Stratgy includs an mphasis on hritag assts and rviss thir approach to tall buildings on th ara. Why has th council rngd on this? UNESCO s World Hritag Committ Rport Jun 2012 nots th intntion of Southwark Council to dvlop a Supplmntary Planning documnt to clarify how and whr dvlopmnt can tak plac and to dfin Blackfriars Road lis within th Cntral Activitis Zon, is an opportunity ara and a town cntr with good accss to public transport. Cor Stratgy stratgic policy 12 rquirs tall buildings to hav an xmplary standard of dsign and idntifis locations whr tall buildings could go. Th Cor Stratgy vision for Banksid and Borough rfrs to th council stting out in dtail which sits ar appropriat, snsitiv and inappropriat for tall buildings through th supplmntary planning documnt/opportunity ara framwork. Savd Southwark Plan policy 3.20 sts out critria for considring applications for tall buildings and applis across th borough. Th UNESCO papr rlats to th ara around London Bridg and th potntial impact of tall buildings on th stting of th Towr of London World Hritag Sit. Th hights proposd in th Blackfriars Road SPD building hights stratgy ar consistnt with Southwark s dvlopmnt plan consisting of th savd Southwark Plan polics, Cor Stratgy and th London Plan. Our tsting shows that th proposd hights would not impact th stting of th Towr of London sit. Th proposd 70m thrshold guidanc for th southrn nd of Blackfriars Road rsponds to th snsitivity of th Palac of

11 Rp Obj Rf Rf Nam Knnth Hays Blackfri 5 6 ars Road Nighb ourhoo d Dtails of Rprsntation building hight thrsholds so as to inform th appropriatnss of subsqunt dvlopmnt proposals. Is this th said SPD? Thank you for your mail datd 23rd August last with th mting nots of th Consultation Mting on 17th August. Ths ar an accurat rsum of th viws xprssd at th mting. Howvr I wondr how many of ths viws will b takn into account. With th Planning Application approval of th Blackfriars Road Rdvlopmnt last wk, in spit of vry strong local objctions if this consultation is just cosmtic Th local authority ownd th Frhold of this sit,but chos to sll out to a Privat Dvlopr rathr than build affordabl homs on this formr Council Rsidntial sit that has mainly lain drlict sinc WW 11. This ara of Southwark was formrly a mixd Industrial / Rsidntial ara and than changd to mainly Offic buildings post WW11. Mixd communitis work wll and ghttos, Rich or Poor do not.. This gnration must prsrv what is good from th past nurtur it and pass it on to futur gnrations. Dvloprs ar only intrstd in thir profit margins not th Communitis thy ar in many cass dstroying. Th 'rap' of Blackfriars Road will continu if our plannrs and political mastrs giv way to th Dvloprs. Consrvation aras man nothing if thy ar not nforcd,.g Borough High Strt Andrw Brton Grantd th invitability of dvlopmnt along Blackfriars Road, it is still alarming to discovr th xtnt to which this involvs th wholsal rplacmnt of th xisting building stock rathr than, at last som, rstoration and rnwal. Southwark Strt is still intrsting and attractiv bcaus of th mixd ag and varying footprint siz of its buildings. Officr Rspons to Rprsntation Wstminstr World Hritag sit. A consultation rport has prpard alongsid th Blackfriars Road SPD. This sts out a summary of th rprsntations rcivd and how w hav takn ths into account in prparing th final vrsion of th SPD. Th appndics also st out all of th rprsntations rcivd and officr commnts on how ths commnts hav bn takn into account, and whthr th SPD has bn updatd as a rsult. Th Planning Committ rport for Blackfriars Road sts out th dtail in rfrnc to th spcific application rfrrd to. Th rol of th SPD is to provid furthr guidanc for th Blackfriars Road ara and on how th xisting dvlopmnt plan policis should b implmntd. Th SPD is consistnt with th savd hritag policis of th Southwark Plan, Cor Stratgy policy 12 and London Plan, as wll as national guidanc in th National Planning Policy Framwork (NPPF). All ths policis ncourag th rus of hritag buildings whr appropriat, consistnt with thir significanc.

12 Rp Obj Rf Rf Nam Dtails of Rprsntation Contrast this with Blackfriars Road whr almost all surviving structurs from th 20th cntury (and bfor) ar st to b lost and whr ovrsizd and actually rpllnt structurs such as "Palstra" (and what's now bing built or in planning) hardly rflct th idntity of th immdiat surroundings. Manwhil plans for th wholsal rdvlopmnt of th Valntin Plac ara ar a mattr of concrn as this still an intrsting arly 20th mixd-us nclav, and th loss of 21 Wbbr Strt would b a ral loss Jams Barbr Rading through th Blackfriars Road SPD I was surprisd to s som cycling provision had droppd out. Prviously it had bn agrd to targt rstablishing th Hopton Road through to Uppr Ground undr Blackfriars Road bridg link. Th original tunnl for th Thams Path undr Blackfriars Bridg was fundd from cycling budgts but du to ballooning of pdstrian numbrs is no longr suitabl for rgular cycling. R stablishing this lost East-Wst corridor, much of which is still in plac physically, would giv a practical rout for cyclists. Th currnt cycl divrsion via Southwark Strt isn't practical and is ignord. Pag 23 Figur 6 shows pdstrian routs but not East-Wst through routs and rstrictd to pdstrians. Idally indicativ cycl link would b clarly markd on figur 6. How can w gt this East- Wst link for cyclists put back into Southwark plans? Jant Amry Para Pag 7. Not clar what you man by intnsification. Dos that man mor popl? If so, th ara around London Bridg and that nd of Borough High Strt is alrady a vry crowdd plac and at th vry last, th pavmnts would nd to b widnd to accommodat this. Improving rivr passngr transport is somthing that would b bnficial but th prics would nd to b what Officr Rspons to Rprsntation Th council ar committd to improving cycling provision in th ara and ar working with both TfL and dvloprs to stablish a suitabl ast-wst link to th north of Blackfriars Road. Although a fasibl option has yt to b idntifid, th council will continu to work with TfL and dvloprs to idntify a suitabl a rout. Th figur has bn updatd to dmonstrat this aspiration. Th vision rfrrd to in paragraph is th xisting vision in th London Plan. Th SPD cannot chang th London Plan vision.

13 Rp Obj Rf Rf Nam Dtails of Rprsntation rsidnts as wll as tourists could afford to pay Jant Amry Pag 9 first para. Rcntly, rsidnts hav lost local 9 5 facilitis; what will Southwark Council b doing to ncourag th kind of businsss that ar ndd in ordr to allow local popl to provid for thir day to day livs, locally, g laundrtts (not vryon has washing machins), nwsagnts, dryclanrs, shomndrs, chmists, who ar willing to provid a hom dlivry srvic of mdicin for doctors patints who cannot gt to th chmist? Jant Amry Para 3. I not that Southwark is plasd to ncourag 0 5 cycling, rathr than car us, which is a good thing But som cyclists assum that thy hav a right to b on th pavmnt and, unlss thy ar a child or a vry nrvous larnr, thy should not b thr. Dos Southwark hav any proposals to nforc or instil good road/pavmnt bhaviour in cyclists? Jant Amry I am plasd to s that Southwark ar rcognising th valu of th historic aras around Borough Markt and Southwark Cathdral. What will you b doing to nsur that it is not damagd by th railway, or othr potntially damaging, works? Jant Amry Para Pag 10. I am concrnd about th phras 2 5 livly and vibrant to dscrib th Council s vision for Blackfriars Road. As a rsidnt of th ara, I look forward to a pacful and rstorativ hom. Livly and vibrant so oftn mans crowdd and noisy Officr Rspons to Rprsntation Th SPD ncourags th provision of nw town cntr uss through guidanc SPD 2: Mixd us town cntr. It ncourags spac to b dsignd flxibly to accommodat a rang of unit sizs. It is not possibl within th planning systm to rquir spcific uss such as dryclanrs or shomndrs within a dvlopmnt. Cycling on th pavmnt is illgal and is nforcabl by th polic. Th council will pass on complaints rcivd to nsur any hostpots for illgal pavmnt cycling ar targtd. This bhaviour is oftn incrasd in aras whr a cyclist dos not fl scur on th carriagway and thrfor masurs to incras cycl safty on and off strt will continu to b prioritisd. It has bn announcd that TfL ar proposing to introduc a Cycl Suprhighway on Blackfriars Road, including a sgrgatd cycl lan. Th council will support TfL and work with thir dsign tam to nsur th lan is fit for purpos which should rduc ncroachmnt onto th footway unlss sufficint spac for shard us facilitis ar providd. Th SPD has bn updatd to rfr to th work bing carrid out by TfL. Borough Markt and Southwark Cathdral and thir surroundings falls outsid th boundary of th SPD ara. Existing dvlopmnt plan policis which incorporats policis from th London Plan, Cor Stratgy and savd Southwark Plan provid th policy framwork for protcting and nhancing our historic nvironmnt. A hritag SPD will also b prpard to provid mor guidanc in Th guidanc in th SPD sks to nsur that thr is a balancd mix of town cntr uss. For xampl guidanc in SPD 2 includs information on considring th impact of all proposals for nw or xpandd food, drink, vning on th ovrall mix of uss and on local amnity. Similarly policis in th savd Southwark Plan rquir

14 Rp Obj Rf Rf Nam Dtails of Rprsntation Officr Rspons to Rprsntation mayb ok to visit but not plasant to liv n. Currntly, dvlopmnt to considr its impact on local amnity. Th guidanc on th road dos fl fairly calm and spacious, without building hights is st out in SPD 5: Building hights. Th urban bing dad. Pag 11 scond para. Why do you think dsign study sts out th vidnc undrpinning th guidanc. Thr that it is only tall buildings that can provid an obvious ar a numbr of critria within SPD 5 nsuring a high quality dsignd gatway? Th most significant gatway in this ara tall building including critria to allow adquat sunlight and daylight is Blackfriars Bridg, which is low and th buildings and avoid harmful microclimat and shadowing ffcts or advrs which hav th most impact along th Thams, ar affcts on local amnity. Thr is also xisting policy in Southwark thos such as Somrst Hous and th Houss of Plan policy 3.2 Protction of amnity which sks to protct Parliamnt, rlativly low but dsignd, or using nighbour's amnity. This is cross rfrrd to within appndix A. matrials, to catch th y in a favourabl way. Lowr floor rsidnts in Union Strt, nar th Blackfriars Road junction, lost quit a lot of daylight whn Palstra was built. Som daylight is still availabl via th Cut and ovr th roof of Southwark tub station but this will b gratly diminishd if a tall structur is prmittd abov th station Jant Amry Para 3.6 Pag 15. If thr is somthing that this ara SPD2 rcogniss thr is an opportunity to promot a much widr mix 3 5 has plnty of and dos not nd mor of it is cafs and of town cntr uss as part of th dvlopmnt of th potntial rstaurants! Tak a walk along th Cut, for xampl, opportunity sits. This includs a rang of diffrnt typs and sizs of which has a junction with Blackfriars Road and you will rtailrs, to hlp boost th local conomy by gnrating additional s thr ar svral, nxt door to ach othr. spnding and inward invstmnt in othr businsss and providing an Rfrring back to my commnts r Pag 9, first para, incrasd numbr of mploymnt opportunitis. Th SPD cannot whr ar th local shops and facilitis for rsidnts dsignat land us on potntial dvlopmnt sits, howvr w will and ncouragmnt for indpndnt rtailrs in your considr th rang of uss that would b appropriat for dvlopmnt proposals? sits through th prparation of th Nw Southwark Plan. Furthr dtail on th council s stratgy on rtail provision is st out in th SPD s businss and rtail background vidnc papr Jant Amry Pag 19. I am plasd to s thoughts for grning Notd. Nw strt trs, as part of nhancd provision of soft 4 5 strts and rinforcing planting, spcially of trs. landscaping and grn infrastructur ar ncouragd by th SPD Th trs on th wstrn sid of Blackfriars Road, g, giv a vry plasant fl to th road. Parts of th local ara can look vry barrn howvr and nd trs, not just for softning but for shad and to hlp improv th air quality, dpltd by havy traffic. St Gorg s Circus g is vry barrn, on a gry day vry

15 Rp Obj Rf Rf Nam Dtails of Rprsntation dprssing looking and badly nds to b mad mor attractiv Jant Amry Pag 20. I cannot agr that allowing tall buildings, such as th 27 story on mootd by Lindn, (rcntly forcd by local prssur to b gratly rducd), will do anything to mak Blackfriars Road fl comfortabl or look attractiv. Tall buildings ar wll known to produc a concrt canyon ffct, which rsults in wind spds bing raisd to uncomfortabl lvls, and advrsly affcting tmpraturs, du to bing channlld through tightr spacs. This is apart from blocking daylight to both rsidnts and workrs. Officr Rspons to Rprsntation Th mrging vision for Blackfriars Road sts out a rang of building hights up to th maximum hights st out in SPD 5, with lowr hights away from th road. Ths mattrs would b assssd at th planning application stag through th rlvant savd Southwark Plan policis, Cor Stratgy Policy 12 and th rlvant policis of th London Plan and othr rlvant planning guidanc. Bullt-point 14 of SPD 5 sts out furthr guidanc rgarding microclimat, whil SPD3 sts out guidanc on landscaping Jant Amry My gnral fl of your proposals is that thy ar A consultation rport has prpard alongsid th Blackfriars Road 6 5 dsignd to bring mony, via tourism and prstigious SPD. This sts out a summary of th rprsntations rcivd and businsss, into th ara and that to do this, th how w hav takn ths into account in prparing th final vrsion of Council is prpard to ignor, or only pay lip srvic th SPD. Th appndics also st out all of th rprsntations to, th vryday nds of th local rsidnts. rcivd and officr commnts on how ths commnts hav bn Rsidnts can hlp to provid a stabl point in an ara takn into account, and whthr th SPD has bn updatd as a and it is w who hlp visitors to th ara whn thy gt rsult. Th SPD sks to mt th nds of xisting and nw lost. Visitors to th Unitd Kingdom don t usually com rsidnts and updats hav bn mad to th SPD to mak this for our tall buildings or our sunshin but for our clarr. history and to s what w, th British ar lik Sbastia n Vrny 1: Provision for a towr block 70 mtrs high at St Gorg s Circus, London SE1 St Gorg s Circus is a fin xampl of Gorgian town planning with its focal point at its cntr, th Grad 2* listd oblisk. SPD 5 Building Hights proposs a tall building of hight up to 70 mtrs should provid a focal point at St Gorg s Circus. This statmnt displays a fundamntal ignoranc of this circus. A tall building will affct th stting of not only th oblisk, an important hritag asst, but also th listd Gorgian trracs in London Road. A tall building up to 70m in hight could b appropriat at th southrn nd of Blackfriars Road providd that it complis with th dtaild guidanc outlind in SPD 5 and th currnt dvlopmnt plan that includs th rlvant policis of th savd Southwark Plan (2007), Cor Stratgy (2011), London Plan (2011) and othr planning documnts/guidanc, including th NPPF (2012). Th dvlopmnt plan sts out th policis for tall buildings. Th guidanc in th SPD provids dtail on how to implmnt ths dvlopmnt plan policis spcific to Blackfriars Road. Th approach is supportd by our vidnc bas including th Blackfriars Road Urban Dsign Study which has bn prpard in accordanc with CABE and English Hritag Guidanc on Tall

16 Rp Obj Rf Rf Nam Dtails of Rprsntation Officr Rspons to Rprsntation Buildings, In light of consultation rsponss and to add clarity to th guidanc rlating to St Gorg s Circus in SPD 5, th SPD has bn updatd to clarify that a tall building could provid a focal point at th southrn nd of Blackfriars Road up to 70ms. A tall building should also sustain, nhanc or bttr rval th local hritag assts Sbastia n Vrny Plas dmonstrat undr London Plan CDR1 how tall building dvlopmnt, a fundamntal chang in architctur, will not advrsly affct th local charactr. Th SPD dos not dsignat proposals sits or provid sit spcific guidanc, as this would byond th scop of th SPD. It dos idntify potntial dvlopmnt sits which ar illustrativ of th hug opportunity for chang within th ara and th nd for a cohrnt framwork. Th SPD has also bn updatd to clarify that th list of sits is not xhaustiv and othr sits may com forward for dvlopmnt. Som of th sits will b compltly rdvlopd, whilst othr sits may xprinc lss chang such as rfurbishmnt or improvmnts to th xisting buildings or surroundings. Any dvlopmnt of th potntial dvlopmnt sits would b assssd and dtrmind at th planning application stag, taking into account local contxt, which includs th local hritag assts. Th building hights guidanc for th SPD ara is consistnt with th xisting dvlopmnt plan and its dsign, hritag and tall building policis, which includs th rlvant savd Southwark Plan policis, Cor Stratgy Policy 12 and th rlvant policis of th London Plan. Th approach is supportd by our vidnc bas including th Blackfriars Road Urban Dsign Study which has bn prpard in accordanc with CABE and English Hritag Guidanc on Tall Buildings, In light of consultation rsponss and to add clarity to th guidanc rlating to St Gorg s Circus in SPD 5, th SPD has bn updatd to clarify that a tall building could provid a focal point at th southrn nd of Blackfriars Road up to 70ms. A tall building should also sustain, nhanc or bttr rval th local hritag assts. Th ara has a mix of charactr that rprsnts diffrnt priods of dvlopmnt. Any nw

17 Rp Obj Rf Rf Nam 668 Sbastia n 668 Sbastia n Vrny Vrny Dtails of Rprsntation Whr is th comprhnsiv urban dsign analysis of th local charactr and historic contxt? (CABE and English Hritag Guidanc on Tall Buildings CDN25) Officr Rspons to Rprsntation dvlopmnt would b assssd and dtrmind at th planning application stag, taking local charactr and hritag contxt into account. Th Blackfriars Road SPD urban dsign study sts out th vidnc bas. Th urban dsign study utiliss a robust mthodology that has prviously bn agrd with English Hritag, and 3D modlling tchniqus to assss th potntial impact on hritag assts. St Gorg s Circus is statd on pag 29 of th SPD to A tall building up to 70m in hight could b appropriat at th southrn b a transport nod. It cannot, by th accptd nd of Blackfriars Road providd that it complis with th dtaild dfinition of a transport nod, b so dscribd. guidanc outlind in SPD 5 and th currnt dvlopmnt plan that Dvlopmnt sits 39, 40, 41 and 43 dirctly affct th includs th rlvant policis of th savd Southwark Plan (2007), Circus and othr hritag assts. Council officrs hav Cor Stratgy (2011), London Plan (2011) and othr planning statd that tall buildings at St Gorg s Circus would documnts/guidanc, including th NPPF (2012). Th dvlopmnt not b a conflict with th adjoining hritag assts. plan sts out th policis for tall buildings. Th guidanc in th SPD Whr is th vidnc that this is not a conflict? provids dtail on how to implmnt ths dvlopmnt plan policis spcific to Blackfriars Road. Th approach is supportd by our vidnc bas including th Blackfriars Road Urban Dsign Study which has bn prpard in accordanc with CABE and English Hritag Guidanc on Tall Buildings, In light of consultation rsponss and to add clarity to th guidanc rlating to St Gorg s Circus in SPD 5, th SPD has bn updatd to clarify that a tall building could provid a focal point at th southrn nd of Blackfriars Road up to 70ms. A tall building should also sustain, nhanc or bttr rval th local hritag assts. Th SPD dos not dsignat proposals sits or provid sit spcific guidanc, as this would byond th scop of th SPD. It dos idntify potntial dvlopmnt sits which ar illustrativ of th hug opportunity for chang within th ara and th nd for a cohrnt framwork. Th SPD has also bn updatd to clarify that th list of sits is not xhaustiv and othr sits may com forward for dvlopmnt. Som of th sits will b compltly rdvlopd, whilst othr sits may xprinc lss chang such as rfurbishmnt or improvmnts to th xisting buildings or surroundings. Any

18 Rp Obj Rf Rf Nam 668 Sbastia n 668 Sbastia n Vrny Vrny Dtails of Rprsntation In dtrmining tall building hight limits within th SPD of 70 mtrs, whr is th assssmnt of thr dimnsional modlling to dtrmin th potntial ffct on th local contxt? (CABE and English Hritag Guidanc on Tall Buildings CDN25) Why ar hotls bing promotd (SPD 3.10) as viabl us whn Southwark has alrady achivd or is clos to achiving th rquirmnts. Th figurs for hotl rooms in th SPD mak it clar that, of th 2500 bdrooms rquird by th GLA s Hotl Dmand Study 2006 by 2026, all but 75 hav ithr bn built or ar in th piplin. Officr Rspons to Rprsntation dvlopmnt of th potntial dvlopmnt sits would b assssd and dtrmind at th planning application stag, taking into account local contxt, which includs th local hritag assts. Th Blackfriars Road SPD urban dsign study sts out th vidnc bas and justification for this, and also informs th guidanc within th SPD. Th urban dsign study utiliss a robust mthodology that has prviously bn agrd with English Hritag, and 3D modlling tchniqus to assss th potntial impact on hritag assts. Th London Plan sks to achiv 40,000 nt additional hotl bdrooms by 2031.Th stimat of th approximat nt and gross hotl rooms rquird ovr th priod for Southwark, as st out in th GLA s Hotl Dmand Study, is basd on assssmnt of factors including transport links to cntral London and connctions to airports, proximity of tourist attractions/businss locations, cafs and rstaurants in th ara, night tim conomy, cultural facilitis and attractions, and rgnration initiativs and sit availability. Th forcast for Southwark should b tratd as indicativ only, and local circumstancs should also b factord in. It is important to considr that th SPD ara is within th Cntral Activitis Zon, Banksid, Borough and London Bridg Opportunity Ara and part of th Elphant and Castl Opportunity Ara which ar aras promotd in th London Plan to accommodat stratgically important hotl provision. Arts, cultural and tourism activitis hav flourishd in Southwark in th last dcad, particularly in th Stratgic Cultural Ara, which is within th CAZ. Banksid, Borough and London Bridg has consquntly xprincd a growth in th numbr of hotls to support this incrasing visitor conomy. Th SPD2 provids guidanc to support Cor Stratgy policy 10 Jobs and businss which sts out th council will allow th dvlopmnt of hotls within th town cntrs, th stratgic cultural aras, and placs with good accss to public transport srvics, providing that ths do not harm th local charactr. Policy 10 and SPD 2 ar also supplmntd by th savd policy 1.12 of th Southwark Plan which addrsss visitor accommodation. Nw hotl proposals in th ara will

19 Rp Obj Rf Rf Nam 668 Sbastia n Vrny Dtails of Rprsntation 2: Th dsignation of th Bakrloo sidings sit (which is immdiatly bhind Gladston Strt) as a potntial dvlopmnt sit (Dvlopmnt Sit 43 Th Bakrloo Sidings) Any dvlopmnt on this sit will intrfr with long viws into th Wst Squar Consrvation Ara valud by Southwark Planning. What considration has bn givn to ths in th prparation of this SPD? What is th vidnc to support its suitability as a dvlopmnt sit as opposd to ducational, opn spac or othr us? Officr Rspons to Rprsntation b assssd against ths rlvant planning policis and a considration of th impact upon local amnity and th balanc of land uss will also b takn into account. Th approach is supportd by our vidnc bas including th Blackfriars Road Urban Dsign Study which has bn prpard in accordanc with CABE and English Hritag Guidanc on Tall Buildings, In light of consultation rsponss and to add clarity to th guidanc rlating to St Gorg s Circus in SPD 5, th SPD has bn updatd to clarify that a tall building could provid a focal point at th southrn nd of Blackfriars Road up to 70ms. A tall building should also sustain, nhanc or bttr rval th local hritag assts. Th TfL Bakrloo sidings sit (Sit 43 in Figur 5/Tabl 1 in th draft SPD, but r-numbrd as Sit 47 in Figur 6/Tabl1 in th updatd SPD) has bn includd as a potntial dvlopmnt sit, du to its rcognisabl dvlopmnt potntial. Any dvlopmnt at th sit would b assssd and dtrmind at th planning application stag, taking th local hritag contxt into account. Th SPD dos not dsignat proposals sits or provid sit spcific guidanc, as this would byond th scop of th SPD. It dos idntify potntial dvlopmnt sits which ar illustrativ of th hug opportunity for chang within th ara and th nd for a cohrnt framwork. Th SPD has also bn updatd to clarify that th list of sits is not xhaustiv and othr sits may com forward for dvlopmnt. Som of th sits will b compltly rdvlopd, whilst othr sits may xprinc lss chang such as rfurbishmnt or improvmnts to th xisting buildings or surroundings. Any dvlopmnt of th potntial dvlopmnt sits would b assssd and dtrmind at th planning application stag, taking into account local contxt, which includs th local hritag assts. Th impact on stting of hritags assts including listd buildings and th Wst Squar consrvation ara would b assssd at planning application stag Sbastia Vrny Any building on this sit will advrsly affct th TfL wr consultd on th draft SPD as a statutory consult. TfL s

20 Rp Obj Rf Rf Nam Dtails of Rprsntation 5 n stting of hritag assts. Th Elphant & Castl Entrpris Ara SPD mntiond a landmark building. W find rfrnc to any such building on this sit dply concrning givn th proximity not only to our own listd houss but also th listd oblisk, St Gorg s RC Cathdral and Imprial War Musum, th lattr two bing th landmark buildings in this location. How ar ths proposals affctd by th Blackfriars Road SPD? 664 Jssica Knnd y I am writing to OBJECT to aspcts of th draft Blackfriars Road Supplmntary Planning Documnt. I am a rsidnt of Gladston Strt, bordring on th ara undr discussion, and a mmbr of our rsidnts association, th Albrt Association. Th two aspcts of th SPD that w find most objctionabl ar: 1: Provision for a towr block 70 mtrs high at St Gorg s Circus 2: Th dsignation of th Bakrloo sidings sit (which is immdiatly bhind Gladston Strt) as a potntial dvlopmnt sit. Officr Rspons to Rprsntation rspons is publishd as part of th consultation rport on th Blackfriars Road SPD. Th impact of th proposd building hight thrsholds on th stting of hritag assts and th dtaild guidanc for tall buildings st out in SPD5, was assssd as part of th SPD. Th approach is supportd by our vidnc bas including th Blackfriars Road Urban Dsign Study which has bn prpard in accordanc with CABE and English Hritag Guidanc on Tall Buildings, A tall building up to 70m in hight could b appropriat at th southrn nd of Blackfriars Road providd that it complis with th dtaild guidanc outlind in SPD 5 and th currnt dvlopmnt plan that includs th rlvant policis of th savd Southwark Plan (2007), Cor Stratgy (2011), London Plan (2011) and othr planning documnts/guidanc, including th NPPF (2012). Th dvlopmnt plan sts out th policis for tall buildings. Th guidanc in th SPD provids dtail on how to implmnt ths dvlopmnt plan policis spcific to Blackfriars Road. Th approach is supportd by our vidnc bas including th Blackfriars Road Urban Dsign Study which has bn prpard in accordanc with CABE and English Hritag Guidanc on Tall Buildings, In light of consultation rsponss and to add clarity to th guidanc rlating to St Gorg s Circus in SPD 5, th SPD has bn updatd to clarify that a tall building could provid a focal point at th southrn nd of Blackfriars Road up to 70ms. A tall building should also sustain, nhanc or bttr rval th local hritag assts. Th TfL Bakrloo sidings sit (Sit 43 in Figur 5/Tabl 1 in th draft SPD, but r-numbrd as Sit 47 in Figur 6/Tabl1 in th updatd SPD) has bn includd as a potntial dvlopmnt sit, du to its rcognisabl dvlopmnt potntial. Any dvlopmnt at th sit would b assssd and dtrmind at th planning application stag, taking into account local contxt, which includs th local hritag assts. Th SPD dos not dsignat proposals sits or provid sit spcific

21 Rp Obj Rf Rf Nam 664 Jssica Knnd y Dtails of Rprsntation Officr Rspons to Rprsntation guidanc, as this would byond th scop of th SPD. It dos idntify potntial dvlopmnt sits which ar illustrativ of th hug opportunity for chang within th ara and th nd for a cohrnt framwork. Th SPD has also bn updatd to clarify that th list of sits is not xhaustiv and othr sits may com forward for dvlopmnt. Som of th sits will b compltly rdvlopd, whilst othr sits may xprinc lss chang such as rfurbishmnt or improvmnts to th xisting buildings or surroundings. Any dvlopmnt of th potntial dvlopmnt sits would b assssd and dtrmind at th planning application stag, taking into account local contxt, which includs th local hritag assts. Boundary In including larg aras of land that hav An xplanation of th boundary is st out within th SPD. It includs nothing to do with Blackfriars Road, Southwark th whol of th Blackfriars Road and som of th surrounding ara. It Council will undrmin Nighbourhood Forums (South includs th surrounding ara as th surrounding ara is also likly to Bank and Watrloo Nighbourhood Forum and th s som dvlopmnt and improvmnts, particularly possibl Banksid Nighbourhood Forum) and th Localism Act improvmnts to public ralm. Wording has bn addd to th SPD to Can th council dmonstrat that th SPD will mak it clarr that th charactr and historic valu of much of th giv a bttr outcom than thos nvisagd by surrounding ara will continu to b protctd and nhancd. It has Nighbourhood Forums? also bn mad clar that th aras which ar prdominantly housing will mostly continu to b so, with rsidnts bnfitting from th incrasd rang of activitis on th Blackfriars Road. Figur 3 of th SPD illustrats th rlationship btwn diffrnt planning documnts including supplmntary planning documnts and nighbourhood plans. Th SPD has bn updatd to mak it clar th nighbourhood plans ar currntly bing prpard. Onc adoptd a nighbourhood plan will hav mor wight than a SPD in th planning procss as it will form part of th council's dvlopmnt plan. At prsnt thr is no adoptd nighbourhood plan for any of th ara covrd by th Blackfriars Road SPD. Th SPD may nd to b rviwd in th futur if a nighbourhood plan is adoptd for any of th SPD ara Jssica Knnd y Dvlopmnt Sit 43 Th Bakrloo Sidings Any dvlopmnt on this sit will intrfr with long viws into th Wst Squar Consrvation Ara valud by Th TfL Bakrloo sidings sit (Sit 43 in Figur 5/Tabl 1 in th draft SPD, but r-numbrd as Sit 47 in Figur 6/Tabl1 in th updatd SPD) has bn includd as a potntial dvlopmnt sit, du to its

22 Rp Obj Rf Rf Nam 664 Jssica Knnd y Dtails of Rprsntation Southwark Planning. What considration has bn givn to ths in th prparation of this SPD? What is th vidnc to support its suitability as a dvlopmnt sit as opposd to ducational, opn spac or othr us? Undr th Elphant & Castl Entrpris Quartr SPD Southwark should hav consultd TfL. Undr th Localism Act consults ar duty bound to co-oprat so whr may w s TfL s rspons? Any building on this sit will advrsly affct th stting of hritag assts. Th Elphant & Castl Entrpris Ara SPD mntiond a landmark building. W find rfrnc to any such building on this sit dply concrning givn th proximity not only to our own listd houss but also th listd oblisk, St Gorg s RC Cathdral and Imprial War Musum, th lattr two bing th landmark buildings in this location. How ar ths proposals affctd by th Blackfriars Road SPD? Stratgic viws St Gorg s Circus and Tall Buildings St Gorg s Circus is a fin xampl of Gorgian town planning with its focal point at its cntr, th Grad 2* listd oblisk. SPD 5 Building Hights proposs a tall building of hight up to 70 mtrs should provid a focal point at St Gorg s Circus. This statmnt displays a fundamntal ignoranc of this circus. A tall building will affct th stting of not only th oblisk, an important hritag asst, but also th listd Gorgian trracs in London Road. Plas dmonstrat undr London Plan CDR1 how tall Officr Rspons to Rprsntation rcognisabl dvlopmnt potntial. Any dvlopmnt at th sit would b assssd and dtrmind at th planning application stag, taking into account local contxt, which includs th local hritag assts. Th SPD dos not dsignat proposals sits or provid sit spcific guidanc, as this would byond th scop of th SPD. It dos idntify potntial dvlopmnt sits which ar illustrativ of th hug opportunity for chang within th ara and th nd for a cohrnt framwork. Th SPD has also bn updatd to clarify that th list of sits is not xhaustiv and othr sits may com forward for dvlopmnt. Som of th sits will b compltly rdvlopd, whilst othr sits may xprinc lss chang such as rfurbishmnt or improvmnts to th xisting buildings or surroundings. TfL, GLA and Ntwork Rail wr all consultd as part of th consultation procss. Th Blackfriars Road SPD consultation rport summariss all th rsponss rcivd and changs subsquntly mad to th SPD. Th full rprsntations rcivd from ths bodis and th council s rspons to thm is includd within Appndix J of th Blackfriars Road SPD consultation rport. Th Elphant and Castl SPD was adoptd on 20 March 2012 and rplacd th Elphant and Castl Entrpris Quartr SPD (2008) and th Walworth Road SPD (2008). Th Blackfriars Road SPD will rplac th Elphant and Castl SPD/OAPF guidanc for th ovrlapping aras. Th SPD has bn updatd to mak this clarr. A tall building up to 70m in hight could b appropriat at th southrn nd of Blackfriars Road providd that it complis with th dtaild guidanc outlind in SPD 5 and th currnt dvlopmnt plan that includs th rlvant policis of th savd Southwark Plan (2007), Cor Stratgy (2011), London Plan (2011) and othr planning documnts/guidanc, including th NPPF (2012). Th dvlopmnt plan sts out th policis for tall buildings. Th guidanc in th SPD provids dtail on how to implmnt ths dvlopmnt plan policis spcific to Blackfriars Road. Th approach is supportd by our vidnc bas including th

23 Rp Obj Rf Rf Nam Dtails of Rprsntation building dvlopmnt, a fundamntal chang in architctur, will not advrsly affct th local charactr. Whr is th comprhnsiv urban dsign analysis of th local charactr and historic contxt? (CABE and English Hritag Guidanc on Tall Buildings CDN25) St Gorg s Circus is statd on pag 29 of th SPD to b a transport nod. It cannot, by th accptd dfinition of a transport nod, b so dscribd. Dvlopmnt sits 39, 40, 41 and 43 dirctly affct th Circus and othr hritag assts. Council officrs hav statd that tall buildings at St Gorg s Circus would not b a conflict with th adjoining hritag assts. Whr is th vidnc that this is not a conflict? In dtrmining tall building hight limits within th SPD of 70 mtrs, whr is th assssmnt of thr dimnsional modlling to dtrmin th potntial ffct on th local contxt? (CABE and English Hritag Guidanc on Tall Buildings CDN25) Officr Rspons to Rprsntation Blackfriars Road Urban Dsign Study which has bn prpard in accordanc with CABE and English Hritag Guidanc on Tall Buildings, In light of consultation rsponss and to add clarity to th guidanc rlating to St Gorg s Circus in SPD 5, th SPD has bn updatd to clarify that a tall building could provid a focal point at th southrn nd of Blackfriars Road up to 70ms. A tall building should also sustain, nhanc or bttr rval th local hritag assts. Th GLA s rprsntation confirms that th Mayor supports th council s approach on tall buildings, but suggsts that th SPD should b mor flxibl in rlation to building hights, and that buildings in th rgion of 70/30m would b appropriat. Th council disagrs with this proposd amndmnt as it could allow buildings that ar gratr than th 70m/30m thrshold, which would b considrd inappropriat basd on our vidnc. As such, th council considrs SPD 5 to balanc local charactr and dvlopmnt potntial. Th TfL Bakrloo sidings sit (Sit 43 in Figur 5/Tabl 1 in th draft SPD, but r-numbrd as Sit 47 in Figur 6/Tabl1 in th updatd SPD) has bn includd as a potntial dvlopmnt sit, du to its rcognisabl dvlopmnt potntial. Any dvlopmnt at th sit would b assssd and dtrmind at th planning application stag, taking into account local contxt, which includs th local hritag assts. Th SPD dos not dsignat proposals sits or provid sit spcific guidanc, as this would byond th scop of th SPD. It dos idntify potntial dvlopmnt sits which ar illustrativ of th hug opportunity for chang within th ara and th nd for a cohrnt framwork. Th SPD has also bn updatd to clarify that th list of sits is not xhaustiv and othr sits may com forward for dvlopmnt. Som of th sits will b compltly rdvlopd, whilst othr sits may xprinc lss chang such as rfurbishmnt or improvmnts to th xisting buildings or surroundings. Any dvlopmnt of th potntial dvlopmnt sits would b assssd and dtrmind at th planning application stag, taking into account local contxt, which includs th local hritag assts Jssica Knnd Why ar hotls bing promotd (SPD 3.10) as viabl h London Plan sks to achiv 40,000 nt additional hotl

24 Rp Obj Rf Rf Nam Dtails of Rprsntation 0 y us whn Southwark has alrady achivd or is clos to achiving th rquirmnts. Th figurs for hotl rooms in th SPD mak it clar that, of th 2500 bdrooms rquird by th GLA s Hotl Dmand Study 2006 by 2026, all but 75 hav ithr bn built or ar in th piplin. Officr Rspons to Rprsntation bdrooms by 2031.Th stimat of th approximat nt and gross hotl rooms rquird ovr th priod for Southwark, as st out in th GLA s Hotl Dmand Study, is basd on assssmnt of factors including transport links to cntral London and connctions to airports, proximity of tourist attractions/businss locations, cafs and rstaurants in th ara, night tim conomy, cultural facilitis and attractions, and rgnration initiativs and sit availability. Th forcast for Southwark should b tratd as indicativ only, and local circumstancs should also b factord in. It is important to considr that th SPD ara is within th Cntral Activitis Zon, Banksid, Borough and London Bridg Opportunity Ara and part of th Elphant and Castl Opportunity Ara which ar aras promotd in th London Plan to accommodat stratgically important hotl provision. Arts, cultural and tourism activitis hav flourishd in Southwark in th last dcad, particularly in th Stratgic Cultural Ara, which is within th CAZ. Banksid, Borough and London Bridg has consquntly xprincd a growth in th numbr of hotls to support this incrasing visitor conomy. Th SPD2 provids guidanc to support Cor Stratgy policy 10 Jobs and businss which sts out th council will allow th dvlopmnt of hotls within th town cntrs, th stratgic cultural aras, and placs with good accss to public transport srvics, providing that ths do not harm th local charactr. Policy 10 and SPD 2 ar also supplmntd by th savd policy 1.12 of th Southwark Plan which addrsss visitor accommodation. Nw hotl proposals in th ara will b assssd against ths rlvant planning policis and a considration of th impact upon local amnity and th balanc of land uss will also b takn into account. Th txt within SPD 6 has bn updatd to clarify that Blackfriars Road falls undr th jurisdiction of TfL. A consultation rport has bn prpard summarising rsponss to th consultation on th draft Blackfriars Road SPD. All rsponss to th SPD consultation will b publishd on th Council's wbsit prior to th SPD bing takn to Cabint for adoption. TfL hav now announcd that TfL ar proposing to introduc a Cycl Suprhighway on Blackfriars Road, with Jssica Knnd y Travl SPD6 givs no spcific information as Blackfriars Road falls undr th jurisdiction of TfL. Undr th Localism Act both TfL and Southwark Council ar duty bound to shar any consultation information rgarding activ travl. What plans hav bn proposd?

25 Rp Obj Rf Rf Nam 664 Jssica Knnd y 664 Jssica Knnd y 664 Jssica Knnd y Dtails of Rprsntation Gnral Th documnt rfrs to shops along th whol of Blackfriars Road but maks no rfrnc to a rtail impact study, indicating dmand for ths or th ffct on nighbouring shops. No mntion is mad of nvironmntal impact assssmnts, wind and daylight modlling, which ar fundamntal rquirmnts in considring proposals of this natur, particularly considring th difficultis with th Palstra and Walki Talki buildings. Th documnt stats that crim will b rducd yt thr is no rfrnc to xisting or anticipatd crim statistics. Has th Mtropolitan Polic bn consultd? If ths studis hav bn obtaind and modlling carrid out thn ths should b in th public domain and not withhld. Plas advis whr ths may b sn. Officr Rspons to Rprsntation consultation proposd for summr Rsults of this consultation would b shard on TfL's wbsit. Th SPD businss and rtail background vidnc papr sts out furthr dtail to SPD 2 and th futur rtail capacity for th Banksid and Borough district town cntr. This dtail has bn rfrncd from th Southwark Rtail Capacity Study. Th study valuats th vitality and viability of th town cntr, in trms of its rtail prformanc and it idntifid that th focus should b on continuing to mt th nds of workrs, tourists and visitors in th town cntr. Th study concludd that nw rtail schms will b supportd by an incras in population in th ara, through nw rsidnts, workrs and visitors and ths will com forward on an incrmntal basis. Nw schms will also b assssd in lin with th critria in th savd Southwark Plan policy 1.7 Dvlopmnt in town and local cntrs. Ths mattrs would b assssd at th planning application stag through th rlvant savd Southwark Plan policis, Cor Stratgy Policy 12 and th rlvant policis of th London Plan and othr rlvant planning guidanc. Bullt-point 14 of SPD 5 sts out furthr guidanc rgarding microclimat. Th Mtropolitan Polic ar on th planning policy's mailing list and wr consultd as part of th consultation on th Blackfriars Road SPD. Th sustainability appraisal and th sustainability appraisal scoping rport which both informd th prparation of th SPD provid furthr information on th possibl impact of th SPD on crim. Th sustainability appraisal assssd th impact of th SPD guidanc on sustainability objctiv SDO4: To rduc th incidnc of crim and far of crim, and finds that th SPD is likly to ovrall hav a positiv impact. Th sustainability scoping rport also provids furthr information stting out information on th Indics of Multipl Dprivation which includs crim as on of its six indicators. Both documnts ar availabl to viw on th council's wb sit at: and

26 Rp Obj Rf Rf Nam 664 Jssica Knnd y 664 Jssica Knnd y Dtails of Rprsntation Why has Wst Squar Consrvation Ara not bn mntiond in SPD4 and SPD5? Th tall buildings proposd affct th stting of this Consrvation Ara and its Listd Buildings. Officr Rspons to Rprsntation Th Wst Squar consrvation ara is situatd outsid th Blackfriars Road SPD ara. It would still b considrd as a hritag asst in rlation to th guidanc st out in SPD 3, 4 and 5. Any dvlopmnt proposal would b assssd at th planning application stag against th rlvant savd Southwark Plan policis, Cor Stratgy Policy SP12 and th rlvant policis of th London Plan and othr planning guidanc. This SPD has 1 Businss Spac, 2 Mixd Us Town Th SPD sts out that it provids furthr guidanc to xisting planning Cntr, 3 Public Ralm and Opn Spac, 4 Built Form policis in th Cor Stratgy and savd Southwark Plan. It dos not and Hritag, 5 Building Hights and 6 Activ Travl. It rpat borough wid policis and th SPD must b rad alongsid dos not hav a Stratgy or Guidanc for Housing. othr planning documnts. Housing is not givn its own sction within Why not? th SPD bcaus th borough-wid housing policis and guidanc alrady covr housing adquatly. This includs policis in th Cor Stratgy and savd Southwark Plan and SPDs on affordabl housing and rsidntial dsign standards. Th vision alrady rfrs to housing dvlopmnt. Housing will b ncouragd on appropriat sits. In ordr to mak this clarr, w hav updatd SPD 2: Mixd us town cntr to includ rsidntial dvlopmnt as on of th uss to b ncouragd alongsid th provision of a mixtur of nw town cntr uss. Th fact box on town cntr uss has also bn updatd in accordanc with th National Planning Policy Framwork dfinition to mak it clar that rsidntial dvlopmnt is not a main town cntr us but it can play an important rol in nsuring th vitality of town cntrs Jssica Knnd y Th Council s Cor Stratgy 2010 dos not support tall buildings in Blackfriars Road South, as thy do not mt th critria for vision vibrancy and lif. Why dos th Council s vision now diffr from th Cor W hav also insrtd a nw appndix (appndix A) listing th ky borough wid Southwark planning policis and supplmntary planning guidanc to mak it clarr that ths policis nd to b rad alongsid th Blackfriars Road SPD. Sction 1 of th SPD has bn updatd to rfr to this nw appndix. Th building hights stratgy for th SPD ara is consistnt with th xisting planning policy framwork of dsign, hritag and tall building policis, which includs th rlvant savd Southwark Plan policis, Cor Stratgy Policy SP12, th rlvant policis of th London Plan

27 Rp Obj Rf Rf Nam 664 Jssica Knnd y Bn Sandrs 9 0 on Bn Sandrs 0 0 on Stratgy? Dtails of Rprsntation In 2012 UNESCO notd in its convntion brifing papr that in April 2011 Southwark s Cor Stratgy includs an mphasis on hritag assts and rviss thir approach to tall buildings on th ara. Why has th council rngd on this? UNESCO s World Hritag Committ Rport Jun 2012 nots th intntion of Southwark Council to dvlop a Supplmntary Planning documnt to clarify how and whr dvlopmnt can tak plac and to dfin building hight thrsholds so as to inform th appropriatnss of subsqunt dvlopmnt proposals. Is this th said SPD? Th guidanc st out in draft SPD on tall buildings btwn Th Cut/Union Strt and St Gorg s Circus is dirctly contrary to adoptd National, Rgional and Local Policis and consquntly byond th rmit of a SPD. Accordingly, it is submittd that th draft SPD cannot b lgally adoptd in its prsnt form. If it wr to b adoptd in its prsnt form, thr is a significant risk that th dcision would b challngd in th form of judicial rviw procdings. Building hights and th spcial stting of St Gorg s Circus Th proposd guidanc on tall buildings in th draft SPD is contrary to xisting adoptd policis rgarding prsrving th stting of listd buildings and consrvation aras, th viws in and out of consrvation aras and th appropriat location of tall buildings. In accordanc with th Cor Stratgy, it should b notd that a tall building is any building that Officr Rspons to Rprsntation and th NPPF. Th approach is supportd by our vidnc bas including th Blackfriars Road Urban Dsign Study which has bn prpard in accordanc with CABE and English Hritag Guidanc on Tall Buildings, As st out within th SPD th mrging vision will b dvlopd fully through th prparation of th Nw Southwark Plan. Th UNESCO papr rlats to th ara around London Bridg and th potntial impact of tall buildings on th stting of th Towr of London World Hritag Sit. Th hights proposd in th Blackfriars Road SPD building hights stratgy ar consistnt with Southwark s dvlopmnt plan consisting of th savd Southwark Plan polics, Cor Stratgy and th London Plan. Our tsting shows that th proposd hights would not impact th stting of th Towr of London sit. Th proposd 70m thrshold guidanc for th southrn of Blackfriars Road rsponds to th snsitivity of th Palac of Wstminstr World Hritag sit. Th guidanc st out within th SPD is consistnt with th xisting planning policy framwork of dsign, hritag and tall building policis, which includs th rlvant savd Southwark Plan policis, Cor Stratgy Policy SP12, th rlvant policis of th London Plan and th NPPF. Th guidanc falls within th rmit of an SPD. It is not an AAP and dos not propos nw policy for th ara. Th guidanc st out within th SPD is consistnt with th xisting planning policy framwork of dsign, hritag and tall building policis, which includs th rlvant savd Southwark Plan policis, Cor Stratgy Policy SP12, th rlvant policis of th London Plan and th NPPF. Th approach is supportd by our vidnc bas including th Blackfriars Road Urban Dsign Study which has bn prpard in accordanc with CABE and English Hritag Guidanc on Tall Buildings, In light of consultation rsponss and to add clarity

28 Rp Obj Rf Rf Nam Dtails of Rprsntation is significantly highr than surrounding buildings vn if it is lowr than 30 mtrs. Th proposal for a tall building of up to 70 mtrs in hight adjacnt to St Gorg s Circus shows a profound disrgard for th important historic stting and xisting policy. Th proposal for a tall building, whthr situatd within or immdiatly adjacnt to th St Gorg's Circus Consrvation Ara and th nationally important Grad II* Oblisk shows littl rgard for th prvailing listd architctur on th Circus itslf and th adjoining London Road and Borough Road. Th draft guidanc that thr should also b building hights of 70 mtrs at Southwark Station and St Gorg's Circus is contrary to th xisting policy on tall buildings, particularly vry tall buildings, bing rstrictd to th north of th road. It rods th concpt of sparat 'Town Cntr' aras at th north nd of Blackfriars Road and at th Elphant and Castl. It is also contrary to th xisting policy that tall buildings should not isolatd ntitis that hav no connction with thir local contxt. Th Southwark tub station is alrady dfind by th 11 story, 56 mtr Palstra building and although it is accptd that th singl story station nds furthr dvlopmnt, any nw building should b lowr than Palstra and rspct th stting of th Ring pub and th listd Gorgian houss in Blackfriars Road. Th proposal to hav a 70 mtr towr as a focus at or in th vicinity of St Gorg's Circus shows that planning policy is bing drivn by commrcial aims. Th Circus is dscribd by LBS only as a 'main junction' which compltly undrplay its historical significanc as th most important surviving xampl of Gorgian town planning in South London, gracd by 34 listd Officr Rspons to Rprsntation to th guidanc rlating to St Gorg s Circus in SPD 5, th SPD has bn updatd to clarify that a tall building could provid a focal point at th southrn nd of Blackfriars Road up to 70ms. A tall building should also sustain, nhanc or bttr rval th local hritag assts.

29 Rp Obj Rf Rf Nam Dtails of Rprsntation Officr Rspons to Rprsntation buildings including th nationally important Grad II* Oblisk. It has dfind th southrn nd of Blackfriars Road sinc 1771 and should continu to do so. If LBS Planning was sriously committd to nhancing th Circus as an important nod, rathr than satisfying th commrcial dsirs of dvloprs, th SPD should follow th xisting guidanc in th St Gorg's Circus CAA (2005). It should rcommnd a building to complt th vacant NE Quadrant that matchd th 4- story Duk of Clarnc in hight, bulk and mass (whilst rspcting th adjacnt 2-story St Gorg th Martyr library) Bn Sandrs 1 0 on Buildings at th southrn nd of Blackfriars Road to rplac th 1960s Erlang and Hill Houss should satisfy Sction 9 (Stting of th Ara, Significant Viws and Landmarks) and rspct th hight of th listd Pabody Estat opposit. LBS Planning should also nsur that any dvlopmnt of th TfL Bakrloo sidings prsrvs and nhancs th historic stting of St Gorg's Circus and th rar viw of Gladston Strt, which is Grad II listd and within th Wst Squar Consrvation Ara. Existing Policy Th nw guidanc for building hights along Blackfriars Road south of Th Cut and 70 mtr towrs at Southwark Station and, at St Gorg's Circus is contrary to th following policis: 1. NPPF 2012 Part 12: Consrving and Enhancing th Historic Environmnt Sctions: 129, and London Plan 2011 Chaptr 7: London's Living Placs and Spacs Policis 7.4. A, 7.4.B(a,c,d,), 7.6.A, B(b,d), 7.7. A, C(b,c,d), D(b), E, 7.8.D, 7.9.B 3. Southwark's Cor Stratgy 2011 Policis 4.16, 5.114, Figur Savd Southwark Plan Policis 2013 Policis 3.11(iii), 3.12(i,ii,iii), 3.15, 3.18(i,ii,iii,iv), 3.20(i,ii,iv,v), Elphant and Castl SPD/OAPF A tall building up to 70m in hight could b appropriat at th southrn nd of Blackfriars Road providd that it complis with th dtaild guidanc outlind in SPD 5 and th currnt dvlopmnt plan that includs th rlvant policis of th savd Southwark Plan (2007), Cor Stratgy (2011), London Plan (2011) and othr planning documnts/guidanc, including th NPPF (2012). Th dvlopmnt plan sts out th policis for tall buildings. Th guidanc in th SPD provids dtail on how to implmnt ths dvlopmnt plan policis spcific to Blackfriars Road. Th approach is supportd by our vidnc bas including th Blackfriars Road Urban Dsign Study which has bn prpard in accordanc with CABE and English Hritag Guidanc on Tall

30 Rp Obj Rf Rf Nam Dtails of Rprsntation Officr Rspons to Rprsntation 2012 St Gorg's Circus and Erlang Hous ar within Buildings, In light of consultation rsponss and to add clarity this SPD/OAPF's Entrpris Quartr. Policis 2.3.6, to th guidanc rlating to St Gorg s Circus in SPD 5, th SPD has 3.2.9, , 16, SPDs 16, 17 and 51 For xampl: bn updatd to clarify that a tall building could provid a focal point at St. Gorg s Circus, improvmnts should focus on th southrn nd of Blackfriars Road up to 70ms. A tall building should rinforcing th charactr of th circus, incrasing th also sustain, nhanc or bttr rval th local hritag assts. ara of usabl pdstrian spac around th primtr of th circus and nhancing th stting of listd buildings and th oblisk Consrv or nhanc th significanc of th St Gorg s Circus consrvation ara through: Providing high quality, wll dsignd buildings that complt th built frontag to th circus. Enhancing viws towards th oblisk. Improving th public ralm. Bringing th listd buildings on th south-ast cornr of th circus back into activ us. (SPD 51 Built Environmnt) Tall buildings should: Hlp dfin th gatways into th cntral ara shown on Figurs 14 and 15. Thy should diminish in hight moving north along Nwington Causway and London Road to manag th transition to surrounding building dvlopmnt. (pag 125 undr hading Building Hights Thr may b opportunitis to introduc tallr buildings along Nwington Causway, marking th gatway into th cntral ara. Ths should diminishing in hight towards Borough Road to th north and also to intgrat with xisting hights around Kyworth Strt. Ky snsitivitis in th ara ar impact on th stting of St Gorg s Circus and th listd buildings around it, Borough High Strt and Grad II listd St Thomas hospital. (paragraph ) 6. St Gorg's Circus CAA 2005 Policy 9 Policy 12.4 (should th nw guidanc apply to th Consrvation Ara) For xampl: McLarn Hous, howvr, which occupis th adjacnt, north wst, quadrant, although its front follows th curv of th Circus, has not bn includd in th dsignatd ara, as its 9/10 story hight and ovrpowring mass

31 Rp Obj Rf Rf Nam Bn Sandrs 2 0 on Dtails of Rprsntation sriously dtract from th charactr and apparanc of th ara. This opprssiv bulk and mass should on no account b allowd to st a prcdnt for th consrvation ara s ky vacant sit at th Circus s north ast quadrant btwn Blackfriars Road and Borough Road. (Paragraph 10.2) Th stting of th oblisk, th rtntion of xisting building lins and th snsitivity to th xisting scal ar th primary critria whn assssing nw dvlopmnt. (Paragraph ) Th Guidanc includd in th SPD for building hights south of Th Cut/ Union Strt is also contrary to th rcommndations in th following rlvant, but not formally adoptd documnts: 7. Draft Banksid, Borough and London Bridg SPD/OAPF 2010 Policis 3.1, 3.2, , CDD2 Banksid, Borough and London Bridg Stag 1 Tall Building Study 2010 Sctions 4, 5: Th aras that would not support tall building dvlopmnt and thrfor not suitabl locations for tall buildings ar Blackfriars Road South 9. Banksid, Borough and London Bridg Charactri Study 2013 Sctions 3.2.4, 6, 8, 9 and 10. Officr Rspons to Rprsntation Th draft SPD. Th guidanc st out within th SPD is consistnt with th xisting planning policy framwork of dsign, hritag and tall building policis, A SPD coms at th bottom of th planning hirarchy which includs th rlvant savd Southwark Plan policis, Cor and consquntly must conform to xisting policis Stratgy Policy SP12, th rlvant policis of th London Plan and th and not introduc guidanc that is in conflict with thos NPPF. Th guidanc proposd falls within th rmit of an SPD. It is policis. Howvr, th draft SPD sts out guidanc on not an AAP and dos not propos nw policy for th ara. building hights south of Th Cut/Union Strt which is in conflict with xisting policis as st out abov. Thr is no attmpt in th draft SPD to xplain or justify this chang in position. As th guidanc is contrary to all adoptd policis, th SPD fails to xplain how th local charactr and historic nvironmnt of th St Gorg's Circus Consrvation Ara. Th dtaild critiqu of th draft SPD providd by th St Gorg s Circus Group

32 Rp Obj Rf Rf Nam Dtails of Rprsntation datd 3 Sptmbr 2013 is adoptd and r-statd in its ntirty. Conclusion Th SPD includs nw guidanc for building hights btwn Th Cut/Union Strt and St Gorg's Circus that appars to hav bn writtn solly for, if not by, dvloprs and is dirctly contrary to xisting adoptd policis. This is byond th rmit of a SPD and in its prsnt form it cannot b lgally adoptd and thr is a significant risk of lgal challng. Eithr th SPD must b withdrawn until a nw Southwark Plan is adoptd and thn rwrittn to b compatibl with that plan, or all nw guidanc for building hights south of Th Cut/Union Strt must b rmovd Andy Clark I was absolutly appalld at your plans for Blackfriars 3 2 Road. Its nugatory accommodation for saf cycling looks lik a utopian motor-cntric plan from th 1970s. Do you raliz th graphic shows what looks lik half a mil of road with mayb 3 or 4 motor vhicls on it not th sthing stinking quus of traffic that infct rality? Givn th currnt zitgist and thinking on urban transport, I don t think you can b anything othr than compltly mbarrassd at such an dlusional, ill-considrd and patntly anachronistic schm. I urg you to rconsidr this, bcaus vn if you r not mbarrassd by it now, you will b by th tim it s compltd Clint Sidl Plas nsur sgrgatd cycl lans ar providd on 4 3 what is a vry wid boulvard. It would mak it a mor plasant nvironmnt for vryon :) Officr Rspons to Rprsntation Th graphic was providd as an indication of th xpans of Blackfriars Road and th potntial varying uss of th carriag way. Although th graphic was not includd as a proposal and is not to scal it has rcivd complaints and for this rason a diffrnt imag has now b usd for th front covr of th SPD. Any changs to Blackfriars Road layout will b takn forward in consultation with th community. Although no dsigns hav bn mad availabl at this stag - TfL hav announcd that thy ar proposing a Cycl Suprhighway on Blackfriars Road with sgrgatd cycl lans. Th council support this proposal and will work with TfL to nsur dsigns ar fit for purpos and balanc th nds of all usrs, taking into account xisting traffic flows. Th SPD has bn updatd to rfr to th work bing carrid out by TfL. Sinc th publication of th draft SPD it has bn announcd that TfL ar proposing to introduc a Cycl Suprhighway on Blackfriars Road. Th council support TfL's proposals to introduc a sgrgatd cycl lan and th SPD has bn updatd to rfr to this work Ekn Ikdif W nd a Charli Chaplin statu in Elphant! Th SPD covrs Blackfriars Road and only a small part of th 5 4 Elphant and Castl Opportunity Ara. It would also not b appropriat to provid that lvl of dtail in a SPD Jack Grgory In particular I wish to rfr to pags which carry It is appropriat to includ sit 26 within figur 6 (prviously figur 5)

33 Rp Obj Rf Rf Nam Dtails of Rprsntation 6 5 an illustrativ plan (figur 5) and a tabl of potntial dvlopmnt sits within th SPD ara. I not that sit 26 is listd among ths, and rspctfully rqust that this is rmovd. This sit, Blackfriars Road is a block calld Bridghous Court and I am an ownr of proprty within this. A larg majority of th flats ar ithr ownr-occupid or lt to long trm tnants. Th frhold ownr also owns svral proprtis within th block and nithr h nor any of th othr proprty ownrs hav any intntion of slling up for rdvlopmnt of what is a vry plasant plac to liv. Equally, th ground floor rtail units ar all occupid by stablishd local businsss and provid a larg prcntag of th othrwis lacking activ frontag currntly prsnt on th road. Indd, th clustr of shops hr was idntifid in th rcntly commissiond Allis and Morrison rport as bing on of th fw hubs of activity along an othrwis spars road Jack Grgory A third point which may b of intrst is a suggstion 7 5 to add th nw building locatd at Wbbr Strt (Tridnt Hous) to th list, as a compltd dvlopmnt. This was compltd last yar and consists of a pair of mixd us blocks which rplacd a drlict two-story light industrial unit with a mor appaling brick structur. Th stat agnts markting th offic sction hav it listd on thir wbsit hr: /tridnths.aspx I would b most obligd if you could acknowldg rcipt of ths commnts and advis of Officr Rspons to Rprsntation and th tabl of potntial dvlopmnt sits as it could potntially b brought forward for dvlopmnt, rdvlopmnt or mor minor improvmnts in th futur. Th figur and tabl within th SPD show potntial dvlopmnt sits. Ths sits ar idntifid by officrs as sits with th potntial for som chang to th building or its surroundings. Som of th sits hav planning prmission, som ar undr construction, som ar going through th planning procss, and som hav no known plans as yt. Th list and figur has bn updatd following consultation to tak into account suggstions from land ownrs and rsidnts. Furthr wording has also bn addd to th SPD to mak it clar that th list of sits is not xhaustiv and that whilst som of th sits will b compltly rdvlopd othr sits might xprinc lss chang such as rfurbishmnt or improvmnts to th xisting buildings or surroundings. Th SPD is not allocating sits as proposals sits and so dos not provid policis on th land uss within ach of th sits. Th allocation of proposals sits is don through a dvlopmnt plan documnt. Currnt dsignations for Blackfriars Road ar in th savd Southwark Plan (2007) which is currntly bing rviwd through th prparation of th Nw Southwark Plan. As part of this rviw w will b looking at whthr w should allocat mor and/or chang xisting proposals sits dsignations and updat th adoptd policis map. Full consultation will b carrid out on th Nw Southwark Plan in accordanc with our SCI and th rlvant rgulations. It would not b appropriat to includ th suggstd sit as th figur shows potntial dvlopmnt sits rathr than compltd dvlopmnt sits to highlight th potntial for chang.

34 Rp Obj Rf Rf Nam thir inclusion or othrwis. Dtails of Rprsntation Liz Almond As a Walworth rsidnt I would lik to commnt on th 8 6 Blackfriars Road plans for rdvlopmnt. I think that th plan idntifis som important aras for improvmnt, as currntly Blackfriars Road is an undr-usd, unwlcoming strt to walk or cycl along. Thr's not much going on at strt lvl and it rally fls quit drlict in placs. Improvmnts to th public ralm ar vry much ndd hr. Officr Rspons to Rprsntation Notd. SPD 3 stats that th council will sk to work with landownrs and TfL to crat improvd public ralm and ncourag activ uss at strt lvl Liz Almond I was also ncouragd by th way th plan idntifis Sinc th publication of th draft SPD it has bn announcd that TfL 9 6 activ travl, spcifically walking and cycling, as on of ar proposing to introduc a Cycl Suprhighway on Blackfriars Road. th ky aims of th rdvlopmnt. As your stratgy Th council support TfL's proposals to introduc a sgrgatd cycl points out, th road is alrady vry popular with popl lan and th SPD has bn updatd to rfr to this. SPD 6 sts out cycling from South London towards th city, and th aspirations to improv junctions along th strt spcifically during th morning pak popl on biks mak up Stamford Strt and th council will work with TfL to nsur a holistic 25% of th traffic, qual to th numbr of cars. approach whn dvloping dsigns for th cycl suprhighway that Thrfor, I was surprisd that th artist's imprssion balanc th nds of all usrs and improv conditions and facilitis for dosn't show any cycl infrastructur othr than a pdstrians. TfL hav advisd that a consultation will tak plac ovr paintd bik lan, which I'm sur you undrstand th summr dosn't provid any ral protction to cyclists, and ar frquntly ignord by drivrs parking in thm, as shown hr. Sinc a ky aim of th rdvlopmnt must b to mak it safr and mor appaling for popl to choos to cycl, I would thrfor urg you to considr protctd bik lans on ithr sid of th carriagway, which ar wid nough for th larg volums of popl who us this rout, and which offr a saf, plasant nvironmnt. Camdn council ar planning to do just this on Royal Collg Strt, which provids a good xampl of what this kind of bik track can look lik. I would also urg you to rviw th junction of Blackfriars Road at Stamford Strt, which currntly has no saf pdstrian phas for popl walking on

35 Rp Obj Rf Rf Nam Patricia Shph 0 7 ard- Rogrs Patricia Shph 1 7 ard- Rogrs Dtails of Rprsntation th wstrn sid of th pavmnt. It's vry unplasant to hav to dash across th road btwn gaps in traffic, which is what you hav to do unlss you want to cross th road four tims just to continu your journy. If you'v got a buggy or hav mobility difficultis, th situation is much wors. I undrstand you'll b working with TfL on ths changs and will want to consult with local businsss and community groups. I'd b happy to mt with you to discuss this furthr and shar xampls of good (and not so good!) practic in trms of making Southwark a mor poplfrindly plac. 1. Plas nsur thr is a spac for a simpl playground for young childrn; this is currntly a major lack. 2. It would b grat to hav mor support for bicyclists (such as a sction of th South Bank walk that is markd as for cyclists' priority) Officr Rspons to Rprsntation Th SPD dos not allocat sits for spcific land uss. SPD 3: Public ralm and opn spacs cross rfrs to th council's Opn Spacs Stratgy 2012 which looks at diffrnt typs of opn spacs and includs rcommndations for improvmnts. Th Stratgy will inform th prparation of th Nw Southwark Plan which can mak land us dsignations. Thr is also alrady a rquirmnt through th council's Rsidntial Dsign Standards SPD to mak provision for childrn's play within nw dvlopmnts. Southwark Council ar committd to improv cycling provision in th ara and ar working with both TfL and dvloprs to stablish a suitabl East-wst link to th north of Blackfriars Road. Although a fasibl option has yt to b idntifid, th council will continu to work with TfL and dvloprs to idntify a suitabl rout Patricia Shph 2 7 ard- Rogrs 3. W nd th full rang of shops to mt daily living nds. Ths would includ (in addition to th chmist that w alrady hav): - a larg suprmarkt - lctrical, building, houshold supplis - clanr, sho Th figur has bn updatd to dmonstrat this aspiration. Sinc th publication of th draft SPD it has also bn announcd that TfL ar proposing to introduc a Cycl Suprhighway on Blackfriars Road. Th council support TfLs proposals to introduc a sgrgatd cycl lan and th SPD has bn updatd to dmonstrat our support. SPD 2 rcogniss thr is an opportunity to promot a much widr mix of town cntr uss as part of th dvlopmnt of th potntial opportunity sits st out th SPD ara. This includs a rang of diffrnt typs and sizs of rtailrs, to hlp boost th local conomy

36 Rp Obj Rf Rf Nam Dtails of Rprsntation rpair, ky makr - habrdashry, nwsagnts, grtings cards, tc - cloths, spcially undrcloths (including socks, tights, tc) - bank and cashpoints Officr Rspons to Rprsntation by gnrating additional spnding and inward invstmnt in othr businsss and providing an incrasd numbr of mploymnt opportunitis. Th SPD cannot dsignat land us on dvlopmnt sits, howvr w will considr th rang of uss that would b appropriat for allocatd dvlopmnt sits through th prparation of th Nw Southwark Plan and its accompanying proposal sits and adoptd policis map Craig Runyon Today I hav rcivd th laflt "Rvitalis SPD 2 rcogniss thr is an opportunity to promot a much widr 3 8 Blackfriars Road (SPD) Hav Your Say" A larg mix of town cntr uss as part of th dvlopmnt of th potntial suprmarkt is ndd for th rsidnts of this ara. opportunity sits st out th SPD ara. This includs a rang of All w hav ar th ovr pricd limitd rang of Tsco diffrnt typs and sizs of rtailrs, to hlp boost th local conomy Mtro and Sainsbury's local. Lowr Marsh is no longr by gnrating additional spnding and inward invstmnt in othr a markt for domstic shopping or grocris. Only a businsss and providing an incrasd numbr of mploymnt tokn amount of markt stalls ar lft and us locals opportunitis. Th SPD cannot dsignat land us on potntial lav th ara to do srious grocry shopping. Isn't it dvlopmnt sits, howvr w will considr th rang of uss that strang how in cntral London. Hr in an ara whr would b appropriat for dvlopmnt sits through th prparation of th population gts dnsr and dnsr with all th nw th Nw Southwark Plan. Furthr dtail on th council s stratgy on hotls, offics and nw apartmnts. No provision is rtail provision is st out in th SPD s businss and rtail background mad for a good larg chap suprmarkt. Whn an vidnc papr. oldr building bcoms mpty its always roccupid by a rstaurant, bar or mad into offics. For xampl th largst businss on th Cut is Byron th burgr bar or th Fir Station on Watrloo Road is a Bar. Th ground floor of on of thos larg offic blocks on Blackfriars Road would mak a grat Supr Markt. Plas considr my ida Ian Aldrso 4 9 Lighton n Th St Gorg 's Circus Group On bhalf of SGCG, I submit that th nw guidanc for tall buildings btwn Th Cut/Union Strt and St Gorgs Circus includd in th SPD is dirctly contrary to adoptd National, Rgional and Local Policis and consquntly byond th rmit of a SPD. W contnd that th nw guidanc on tall buildings (rmmbring that a 'Tall Building' is not only on that is highr than 30 mtrs, but also on that is 'significantly highr than surrounding buildings') is in Th guidanc st out within th SPD is consistnt with th xisting planning policy framwork of dsign, hritag and tall building policis, which includs th rlvant savd Southwark Plan policis, Cor Stratgy Policy SP12, th rlvant policis of th London Plan and th NPPF. Th guidanc proposd falls within th rmit of an SPD. It is not an AAP and dos not propos nw policy for th ara. Th ara has a mix of charactr that rprsnts diffrnt priods of dvlopmnt. Any nw nvlopmnt would b assssd and dtrmind at th planning application stag, taking local charactr

37 Rp Obj Rf Rf Nam Ian Aldrso 5 9 Lighton n Th St Gorg 's Circus Group Dtails of Rprsntation Officr Rspons to Rprsntation conflict with xisting adoptd policis rgarding and hritag contxt into account. In light of consultation rsponss prsrving th stting of listd buildings and and to add clarity to th guidanc rlating to St Gorg s Circus in consrvation aras, th viws in and out of SPD 5, th SPD has bn updatd to clarify that a tall building could consrvation aras and th appropriat location of Tall provid a focal point at th southrn nd of Blackfriars Road up to Buildings. W also bliv that th nw guidanc fails 70ms. A tall building should also sustain, nhanc or bttr rval th to rcognis th distinctiv charactr of southrn local hritag assts. Blackfriars Road as a mainly low-ris ara with many historic listd and non-listd buildings. It is compltly diffrnt from that north of Th Cut/Union Strt. It rinforcs th gradation in hight from th vry tall buildings north of Stamford/Southwark Strts, through th transition zon to Th Cut/Union Strt and on to th Gorgian focus of th St Gorg's Circus Consrvation Ara and th nationally important Grad II* Oblisk. London Road, with its listd Gorgian buildings also rcogniss th significanc of th Oblisk as a focal point and continus th low-ris thm in its modrn buildings bfor rising in th south to th tall buildings at th Elphant and Castl. Th SPD is unclar as to whthr its guidanc for building hights applis within th St Gorg's Circus Consrvation Ara. It is includd in th SPD (although within th adoptd Elphant and Castl SPD/OAPF boundary) yt th guidanc is for Blackfriars Road 'btwn Southwark tub station and St Gorg's Circus.' W hav consquntly assumd, naivly probably as it is known that Barratt London wish to build a tall building thr, that this dos not includ th Consrvation Ara. Should our assumption b incorrct, all th objctions numratd for Blackfriars Road south of Th Cut/Union Strt apply with vn gratr forc within th Consrvation Ara. A tall building up to 70m in hight could b appropriat at th southrn nd of Blackfriars Road providd that it complis with th dtaild guidanc outlind in SPD 5 and th currnt dvlopmnt plan that includs th rlvant policis of th savd Southwark Plan (2007), Cor Stratgy (2011), London Plan (2011) and othr planning documnts/guidanc, including th NPPF (2012). Th dvlopmnt plan sts out th policis for tall buildings. Th guidanc in th SPD provids dtail on how to implmnt ths dvlopmnt plan policis spcific to Blackfriars Road. Th approach is supportd by our vidnc bas including th Blackfriars Road Urban Dsign Study which has bn prpard in accordanc with CABE and English Hritag Guidanc on Tall Buildings, In light of consultation rsponss and to add clarity to th guidanc rlating to St Gorg s Circus in SPD 5, th SPD has bn updatd to clarify that a tall building could provid a focal point at th southrn nd of Blackfriars Road up to 70ms. A tall building should

38 Rp Obj Rf Rf Nam Ian Aldrso 6 9 Lighton n Ian Aldrso 7 9 Lighton n Th St Gorg 's Circus Group Th St Gorg 's Circus Group Dtails of Rprsntation Th guidanc that thr should also b building hights of 70 mtrs at Southwark Station and St Gorg's Circus is contrary to th xisting policy on tall buildings, particularly vry tall buildings, bing rstrictd to th north of th road. It rods th concpt of sparat 'Town Cntr' aras at th north nd of Blackfriars Road and at th Elphant and Castl. It is also contrary to th xisting policy that tall buildings should not isolatd ntitis that hav no connction with thir local contxt. Th Southwark tub station is alrady dfind by th 11 story, 56 mtr Palstra building and although w accpt that th singl story station nds furthr dvlopmnt, any building should b lowr than Palstra and rspct th stting of th Ring pub and th listd Gorgian houss in Blackfriars Road. Officr Rspons to Rprsntation also sustain, nhanc or bttr rval th local hritag assts. A tall building up to 70m in hight could b appropriat at th southrn nd of Blackfriars Road providd that it complis with th dtaild guidanc outlind in SPD 5 and th currnt dvlopmnt plan that includs th rlvant policis of th savd Southwark Plan (2007), Cor Stratgy (2011), London Plan (2011) and othr planning documnts/guidanc, including th NPPF (2012). Th dvlopmnt plan sts out th policis for tall buildings. Th guidanc in th SPD provids dtail on how to implmnt ths dvlopmnt plan policis spcific to Blackfriars Road. Th approach is supportd by our vidnc bas including th Blackfriars Road Urban Dsign Study which has bn prpard in accordanc with CABE and English Hritag Guidanc on Tall Buildings, In light of consultation rsponss and to add clarity to th guidanc rlating to St Gorg s Circus in SPD 5, th SPD has bn updatd to clarify that a tall building could provid a focal point at th southrn nd of Blackfriars Road up to 70ms. A tall building should also sustain, nhanc or bttr rval th local hritag assts. A tall building up to 70m in hight could b appropriat at th southrn nd of Blackfriars Road providd that it complis with th dtaild guidanc outlind in SPD 5 and th currnt dvlopmnt plan that includs th rlvant policis of th savd Southwark Plan (2007), Cor Stratgy (2011), London Plan (2011) and othr planning documnts/guidanc, including th NPPF (2012). Th dvlopmnt plan sts out th policis for tall buildings. Th guidanc in th SPD provids dtail on how to implmnt ths dvlopmnt plan policis spcific to Blackfriars Road. Th approach is supportd by our vidnc bas including th Blackfriars Road Urban Dsign Study which has bn prpard in accordanc with CABE and English Hritag Guidanc on Tall Buildings, In light of consultation rsponss and to add clarity to th guidanc rlating to St Gorg s Circus in SPD 5, th SPD has bn updatd to clarify that a tall building could provid a focal point at

39 Rp Obj Rf Rf Nam Ian Aldrso 8 9 Lighton n Th St Gorg 's Circus Group Dtails of Rprsntation Th proposal to hav a 70 mtr towr as a focus at, but st back from, St Gorg's Circus (a contradiction) is an act of vandalism that could only hav bn thought up by a dvlopr. Th Circus is dscribd only as a 'main junction' compltly ignoring its historical significanc as th most important surviving xampl of Gorgian town planning in South London, gracd by 34 listd buildings including th nationally important Grad II* Oblisk. It has dfind th southrn nd of Blackfriars Road sinc 1771 and should continu to do so. If LBS Planning was sriously intrstd in nhancing th Circus as an important nod, rathr than satisfying th commrcial dsirs of dvloprs, th SPD should follow th xisting guidanc in th St Gorg's Circus CAA (2005). It should rcommnd a building to complt th vacant NE Quadrant that matchd th 4- story Duk of Clarnc in hight, bulk and mass (whilst rspcting th adjacnt 2-story St Gorg th Martyr library). Buildings at th southrn nd of Blackfriars Road to rplac th 1960s Erlang and Hill Houss should satisfy Sction 9 (Stting of th Ara, Significant Viws and Landmarks) and rspct th hight of th listd Pabody Estat opposit. If th guidanc is implmntd it will dstroy th sparation of th two 'Town Cntrs' and rsult in a stril, unwlcoming sction of road with th historic, nonlistd buildings that now contribut so much to its charactr dmolishd and rplacd by a 29.9 mtr canyon of blocks intrruptd only by thos listd buildings that cannot b dmolishd, but whos stting has bn dstroyd. It will b a sction of road whr no on will 'want to liv, work or visit'. Officr Rspons to Rprsntation th southrn nd of Blackfriars Road up to 70ms. A tall building should also sustain, nhanc or bttr rval th local hritag assts. A tall building up to 70m in hight could b appropriat at th southrn nd of Blackfriars Road providd that it complis with th dtaild guidanc outlind in SPD 5 and th currnt dvlopmnt plan that includs th rlvant policis of th savd Southwark Plan (2007), Cor Stratgy (2011), London Plan (2011) and othr planning documnts/guidanc, including th NPPF (2012). Th dvlopmnt plan sts out th policis for tall buildings. Th guidanc in th SPD provids dtail on how to implmnt ths dvlopmnt plan policis spcific to Blackfriars Road. Th approach is supportd by our vidnc bas including th Blackfriars Road Urban Dsign Study which has bn prpard in accordanc with CABE and English Hritag Guidanc on Tall Buildings, In light of consultation rsponss and to add clarity to th guidanc rlating to St Gorg s Circus in SPD 5, th SPD has bn updatd to clarify that a tall building could provid a focal point at th southrn nd of Blackfriars Road up to 70ms. A tall building should also sustain, nhanc or bttr rval th local hritag assts.

40 Rp Obj Rf Rf Nam Ian Aldrso 9 9 Lighton n Ian Aldrso 0 9 Lighton n Th St Gorg 's Circus Group Th St Gorg 's Circus Group Dtails of Rprsntation THE SPD xplains 'Th SPD provids furthr guidanc to xisting policis in our Cor Stratgy and savd Southwark Plan' and shows in Figur 3 that a SPD coms at th bottom of th planning hirarchy and consquntly must conform to xisting policis and not introduc guidanc that is in conflict with thos policis. Howvr, contrary to this statmnt th guidanc on building hights south of Th Cut/Union Strt is in conflict with xisting policis in both th Cor Stratgy and th savd Southwark Plan (as wll as NPPF and th London Plan). 2.1 dscribs th currnt vision, which is consistnt with th Cor Stratgy and th savd Southwark Plan policis (and by rquirmnt PPS [rplacd without substantiv chang by NPPF] and th London Plan) 'Figur 4 illustrats th Cor Stratgy vision'. This shows that th appropriat ara for tall buildings on Blackfriars Road is rstrictd to th northrn nd. This is rinforcd in th sction on Blackfriars Road 'Thr will b a clustr of tall buildings around th northrn nd of Blackfriars Road'. Thr is no suggstion that tall buildings ar appropriat in th southrn sction of th road. Th background papr CDD2 Banksid, Borough &London Bridg Stag 1 Tall Building Study 2010 Sction 5.1 is clar 'Th aras that would not support tall building dvlopmnt and thrfor not suitabl locations for tall buildings ar Blackfriars Road South,... ' sts out th justifications for crating th SPD. Howvr, th chang from PPS to NPPF and th Localism Act introduc no changs that justify nw policis rgarding building hights. Th nw dvlopmnts at th Elphant and Castl, Watrloo and north of th rivr hav bn plannd for yars, ar not rlvant to th southrn part of th road and ar compatibl with Southwark's policy of high-ris 'Town Officr Rspons to Rprsntation Th guidanc st out within th SPD is consistnt with th xisting planning policy framwork of dsign, hritag and tall building policis, which includs th rlvant savd Southwark Plan policis, Cor Stratgy Policy SP12, th rlvant policis of th London Plan and th NPPF. Th guidanc proposd falls within th rmit of an SPD. It is not an AAP and dos not propos nw policy for th ara. Th ara has a mix of charactr that rprsnts diffrnt priods of dvlopmnt. Any nw nvlopmnt would b assssd and dtrmind at th planning application stag, taking local charactr and hritag contxt into account. In light of consultation rsponss and to add clarity to th guidanc rlating to St Gorg s Circus in SPD 5, th SPD has bn updatd to clarify that a tall building could provid a focal point at th southrn nd of Blackfriars Road up to 70m. A tall building should also sustain, nhanc or bttr rval th local hritag assts. Th GLA s rprsntation confirms that th Mayor supports th council s approach on tall buildings, but suggsts that th SPD should b mor flxibl in rlation to building hights, and that buildings in th rgion of 70/30m would b appropriat. Th council disagrs with this proposd amndmnt as it could allow buildings that ar gratr than th 70m/30m thrshold, which would b considrd inappropriat basd on our vidnc bas. As such, th council considrs SPD 5 to balanc local charactr and dvlopmnt potntial. Th guidanc st out within th SPD is consistnt with th xisting planning policy framwork of dsign, hritag and tall building policis, which includs th rlvant savd Southwark Plan policis, Cor Stratgy Policy SP12, th rlvant policis of th London Plan and th NPPF. Th guidanc proposd falls within th rmit of an SPD. It is not an AAP and dos not propos nw policy for th ara. Th Blackfriars Road SPD urban dsign study sts out th vidnc

41 Rp Obj Rf Rf Nam Ian Aldrso 1 9 Lighton n Th St Gorg 's Circus Group Dtails of Rprsntation Cntrs' at th Elphant and Castl, London Bridg, North Blackfriars Road and in Lambth, Watrloo sparatd and dfind, by low-ris aras in btwn. This lavs only 'Nw applications hav com forward on th Blackfriars Road' or is it just coincidnc that Lindn Homs, aftr discussions with LBS Planning, hav submittd an application to dmolish th historic, C18th, thr-story Imbib pub and St Gorg's Mansions (both buildings with activ frontags at strt lvl srving local nds) to build a 29.9 mtr block and that Barratt London, again aftr discussions with LBS Planning, hav a Scoping Opinion application for building hights of 27 storys (approximatly 70 mtrs) adjacnt to th St Gorg's Circus Consrvation Ara and th listd Pabody Estat? Ths applications also show, as no doubt LBS Planning intndd, what 'up to' 30 or 70 mtrs rally implis suggsts that th Cor Stratgy and th London Plan should b r-xamind. Possibly, but for LBS th ordr should b th Cor Stratgy/Southwark Plan, which has to b consistnt with NPPF and th London Plan, is subjct to xtrnal Planning Inspctorat xamination and consquntly has som validity, and thn a SPD, whr th 'consultation' (xcpt with dvloprs) is no mor than a tokn tick-box xrcis whr th viws of rsidnts ar 'considrd' and thn ignord. Th sction on building hights south of Th Cut/Union Strt is a blatant attmpt to bring in nw policis by th back door and circumvnt th indpndnt valuation that th stablishd dmocratic procss rquirs accpts that 'w cannot formally adopt a vision for an ara through a SPD' and rprsnts th SPD as just 'som idas that w will look at furthr as w prpar th nw Southwark Plan.' Yt you propos to submit th SPD, Officr Rspons to Rprsntation bas and justification for SPD 5. Th urban dsign study utiliss a robust mthodology that has prviously bn agrd with English Hritag, and 3D modlling tchniqus to assss th potntial impact on hritag assts. Th study updats th tsting from th prvious urban dsign studis in light of guidanc st out in th NPPF, th London Plan that was adoptd aftr th Cor Stratgy, schms that alrady hav bn consntd within th ara and xisting dvlopmnt prssur that could lad to picmal dvlopmnt within th ara. Th guidanc st out within th SPD is consistnt with th xisting planning policy framwork of dsign, hritag and tall building policis, which includs th rlvant savd Southwark Plan policis, Cor Stratgy Policy 12, th rlvant policis of th London Plan and th NPPF. Th guidanc falls within th rmit of an SPD. It is not an AAP and dos not propos nw policy for th ara. In light of consultation rsponss and to add clarity to th guidanc rlating to St Gorg s Circus in SPD 5, th SPD has bn updatd to clarify that a tall building could provid a focal point at th southrn nd of Blackfriars Road up to 70m. A tall building should also sustain, nhanc or bttr rval th local hritag assts.

42 Rp Obj Rf Rf Nam Ian Aldrso 2 9 Lighton n Th St Gorg 's Circus Group Dtails of Rprsntation which contains nw guidanc rgarding building hights that is in conflict with th NPPF, London Plan, Cor Stratgy, savd Southwark Plan policis, SPD/OAPFs for th ara and th St Gorg's Circus CAA, to th LBS Cabint for formal adoption (rubbr stamping). Just anothr xampl of LBS Planning's contmpt for local rsidnts (but not big dvloprs) and th dmocratic procss crats th nw guidlin 'Thr will also b tallr buildings at th important locations of Southwark tub station and on th main junction of St Gorg's Circus.' (my mphasis) and maks th ridiculous claim that ths 'will nhanc th local charactr, sustaining and nhancing th historic nvironmnt.' Unsurprisingly, as th guidanc is contrary to all adoptd policis, th SPD fails to xplain how th local charactr and historic nvironmnt of th St Gorg's Circus Consrvation Ara consisting of 2-4 story listd, mainly Gorgian buildings including th nationally important Grad II* Oblisk and th listd, 4-5 story Pabody and Wbr Row Estats ar sustaind or nhancd by a 70 mtr (SPD 5) towr in thir immdiat stting. Unsurprisingly again, th guidanc is compltly in accordanc with Barratt London's policy. SPD 5 corrctly proposs dvlopmnt on main routs 'with appropriat hights up to 30 mtrs dpnding upon contxt.' (my mphasis). Thn, in dirct contradiction, ncourags 'Buildings up to 30 mtrs along Blackfriars Road btwn Southwark tub station and St Gorg's Circus.' whr th prvailing contxt is 3-5 storys (only fiv buildings including Erlang and Hill Houss, which ar du for rdvlopmnt, on th ast sid and only McLarn Hous on th wst ar ovr 5 storys). Most of th road is also, as shown in Figur 7, within th stting of Officr Rspons to Rprsntation Th proposd building hights guidanc and stratgy st in SPD 5 is consistnt with th xisting planning policy framwork of dsign, hritag and tall building policis (th rlvant savd Southwark Plan policis, Cor Stratgy Policy SP12, th rlvant policis of th London Plan and th NPPF). Th guidanc is supportd by vidnc in th urban dsign study. Th urban dsign study utiliss a robust mthodology that has prviously bn agrd with English Hritag, and 3D modlling tchniqus to assss th potntial impact on hritag assts.

43 Rp Obj Rf Rf Nam Ian Aldrso 3 9 Lighton n Th St Gorg 's Circus Group Dtails of Rprsntation th listd Gorgian trrac in th north, th listd Victorian Pabody Estat and 1906 Wbr Row buildings as wll as th King's Bnch and Valntin Plac Consrvation Aras in th cntr and th listd Gorgian and Victorian buildings of th St Gorg's Circus Consrvation Ara in th south. Onc mor, th only policis this is consistnt with ar thos of Lindn Homs and Barratt London. SPD 5 also quantifis th hight of th 'tallr buildings' in as 'up to 70 mtrs'. Apart from bing contrary to National, Rgional or Local policis and unaccptabl in th local contxt, Figur 8 shows that, sn from a distanc ths towrs will only bring confusion and diminish th impact of th 'Town Cntrs' of North Blackfriars Road and th Elphant and Castl. As in Figur 7, Figur 9 (probably unintntionally) dmonstrats th local, low-ris contxt of Blackfriars Road south of Th Cut/Union Strt with its consrvation aras and listd buildings. Officr Rspons to Rprsntation It is significant that this SPD, unlik that for th Buildings that contribut positivly to th charactr of consrvation Elphant and Castl (2012) dos not hav a list of aras, buildings of townscap mrit or hritag valu outsid of buildings that ar or hav th potntial to b locally consrvation aras ar idntifid on Figur 5 in th updatd SPD. listd. Is it that th Ring pub (C19), th Imbib pub (a Guidanc and th idntification of buildings will b addrssd in a nw C18th historic building), th Crown pub (1883), th Hritag SPD that will b prpard alongsid th Nw Southwark Sons of Tmpranc Frindly Socity (1910), St Plan. Gorg's Mansions (~ 1900), th Blackfriars Foundry (1819) and th adjacnt Laughing Gravy Rstaurant building ar not worth considration or is it that as thy ar all 3-5 storys (and most hav activ strt lvl frontags srving local nds) and any impdimnt to thir dmolition would intrfr with th dvloprs aim of turning Blackfriars Road south of Th Cut/Union Strt into a blank, unwlcoming canyon of 29.9/70 mtr blocks? Ian Aldrso Th St EXISTING POLICIES Th nw guidanc for building Th guidanc st out within th SPD is consistnt with th xisting

44 Rp Obj Rf Rf Nam 4 9 Lighton n Gorg 's Circus Group Ian Aldrso 5 9 Lighton n Th St Gorg 's Circus Group Dtails of Rprsntation hights along Blackfriars Road south of Th Cut and 70 mtr towrs at Southwark Station and St Gorg's Circus is contrary to th following policis. NPPF 2012 Part 12: Consrving and Enhancing th Historic Environmnt Sctions: 129, and 137 London Plan 2011 Chaptr 7: London's Living Placs and Spacs Policis 7.4. A, 7.4.B(a,c,d,), 7.6.A, B(b,d), 7.7. A, C(b,c,d), D(b), E, 7.8.D, 7.9.B Southwark's Cor Stratgy 2011 Policis 4.16, 5.114, Figur 12 Savd Southwark Plan Policis 2013 Policis 3.11(iii), 3.12(i,ii,iii), 3.15, 3.18(i,ii,iii,iv), 3.20(i,ii,iv,v), 3.22 Elphant and Castl SPD/OAPF 2012 St Gorg's Circus and Erlang Hous ar within this SPD/OAPF's Entrpris Quartr. Policis 2.3.6, 3.2.9, , 16, SPDs 16, 17 and 51 St Gorg's Circus CAA 2005 Policy 9 Policy 12.4 (should th nw guidanc apply to th Consrvation Ara) OTHER DOCUMENTS Th Guidanc includd in th SPD for building hights south of Th Cut/ Union Strt is also contrary to th rcommndations in th following rlvant, but not formally adoptd documnts. Draft Banksid, Borough and London Bridg SPD/OAPF 2010 Policis 3.1, 3.2, , 12 CDD2 Banksid, Borough and London Bridg Stag 1 Tall Building Study 2010 Sctions 4, 5 Banksid, Borough and London Bridg Charactri Study 2013 Sctions 3.2.4, 6, 8, 9 and 10. SUMMARY Th SPD includs nw guidanc for building hights btwn Th Cut/Union Strt and St Gorg's Circus that appars to hav bn writtn solly for, if not by, dvloprs and is dirctly contrary to xisting adoptd policis. This is byond th rmit of a SPD and in its prsnt form it cannot b lgally adoptd. Eithr th SPD must b withdrawn until a nw Southwark Plan is adoptd and thn rwrittn to b compatibl with that plan, or all nw guidanc for Officr Rspons to Rprsntation planning policy framwork of dsign, hritag and tall building policis, which includs th rlvant savd Southwark Plan policis, Cor Stratgy Policy SP12, th rlvant policis of th London Plan and th NPPF. Th guidanc proposd falls within th rmit of an SPD. It is not an AAP and dos not propos nw policy for th ara. Th Blackfriars Road SPD urban dsign study sts out th vidnc bas and justification for SPD 5 and th building hights stratgy for th SPD ara. Th urban dsign study utiliss a robust mthodology that has prviously bn agrd with English Hritag, and 3D modlling tchniqus to assss th potntial impact on hritag assts. Th GLA s rprsntation confirms that th Mayor supports th council s approach on tall buildings, but suggsts that th SPD should b mor flxibl in rlation to building hights, and that buildings in th rgion of 70/30m would b appropriat. Th council disagrs with this proposd amndmnt as it could allow buildings that ar gratr than th 70m/30m thrshold, which would b considrd inappropriat. As such, th council considrs SPD5 to balanc local charactr and dvlopmnt potntial. Th guidanc st out within th SPD is consistnt with th xisting planning policy framwork of dsign, hritag and tall building policis, which includs th rlvant savd Southwark Plan policis, Cor Stratgy Policy SP12, th rlvant policis of th London Plan and th NPPF. Th guidanc proposd falls within th rmit of an SPD. It is not an AAP and dos not propos nw policy for th ara. Th approach is supportd by our vidnc bas including th Blackfriars Road Urban Dsign Study which has bn prpard in

45 Rp Obj Rf Rf Nam Cian McCarri 6 0 ck Dtails of Rprsntation building hights south of Th Cut/Union Strt must b rmovd. I would lik to rais my objctions to th Draft Blackfriars Road Supplmntary Planning Documnt, in particular th following two points: 1: Provision for a towr block 70 mtrs high at St Gorg s Circus 2: Th dsignation of th Bakrloo sidings sit (which is immdiatly bhind Gladston Strt) as a potntial dvlopmnt sit. Th SPD proposs that Blackfriars Road b dvlopd solly as a sris of tall buildings with infill of significant hight. Whr is th vidnc to support this vision for th ara rathr than som altrnativ dvlopmnt plan? Which othr plans wr considrd and rjctd? During consultation w hav bn informd that no particular nd us is nvisagd for any of th sits dsignatd for dvlopmnt. Whr is th justification for ignoring th suitability of particular sits of th dsignatd aras for any particular form of dvlopmnt, givn th snsitiv natur of th hritag contxt? It sms clar to m that th rol of th Local Authority in connction with th SPD is that of a dvlopmnt nablr rathr than a rgulator. This throws onto th community th rsponsibility to act as a rgulator. Officr Rspons to Rprsntation accordanc with CABE and English Hritag Guidanc on Tall Buildings, In light of consultation rsponss and to add clarity to th guidanc rlating to St Gorg s Circus in SPD 5, th SPD has bn updatd to clarify that a tall building could provid a focal point at th southrn nd of Blackfriars Road up to 70ms. A tall building should also sustain, nhanc or bttr rval th local hritag assts. A tall building up to 70m in hight could b appropriat at th southrn nd of Blackfriars Road providd that it complis with th dtaild guidanc outlind in SPD 5 and th currnt dvlopmnt plan that includs th rlvant policis of th savd Southwark Plan (2007), Cor Stratgy (2011), London Plan (2011) and othr planning documnts/guidanc, including th NPPF (2012). Th dvlopmnt plan sts out th policis for tall buildings. Th guidanc in th SPD provids dtail on how to implmnt ths dvlopmnt plan policis spcific to Blackfriars Road. Th approach is supportd by our vidnc bas including th Blackfriars Road Urban Dsign Study which has bn prpard in accordanc with CABE and English Hritag Guidanc on Tall Buildings, In light of consultation rsponss and to add clarity to th guidanc rlating to St Gorg s Circus in SPD 5, th SPD has bn updatd to clarify that a tall building could provid a focal point at th southrn nd of Blackfriars Road up to 70ms. A tall building should also sustain, nhanc or bttr rval th local hritag assts. Th TfL Bakrloo sidings sit (Sit 43 in Figur 5/Tabl 1 in th draft SPD, but r-numbrd as Sit 47 in Figur 6/Tabl1 in th updatd SPD) has bn includd as a potntial dvlopmnt sit, du to its rcognisabl dvlopmnt potntial. Any dvlopmnt at th sit would b assssd and dtrmind at th planning application stag, taking th local hritag contxt into account. Th SPD stats that list of potntial dvlopmnt sits is illustrativ of th hug opportunity for chang within th ara and th nd for a cohrnt framwork. It has also bn updatd to clarify that th list of sits is not xhaustiv and

46 Rp Obj Rf Rf Nam Cian McCarri 7 0 ck Dtails of Rprsntation In including larg aras of land that hav nothing to do with Blackfriars Road, Southwark Council will undrmin Nighbourhood Forums (South Bank and Watrloo Nighbourhood Forum and th Banksid Nighbourhood Forum) and th Localism Act Can th council dmonstrat that th SPD will giv a bttr outcom than thos nvisagd by Nighbourhood Forums? Officr Rspons to Rprsntation othr sits may com forward for dvlopmnt. Som of th sits will b compltly rdvlopd, whilst othr sits may xprinc lss chang such as rfurbishmnt or improvmnts to th xisting buildings or surroundings. Th formal idntification of proposals sits within th ara will b considrd as part of th prparation of th Nw Southwark Plan. An xplanation of th boundary is st out within th SPD. It includs th whol of th Blackfriars Road and som of th surrounding ara. It includs th surrounding ara as th surrounding ara is also likly to s som dvlopmnt and improvmnts, particularly possibl improvmnts to public ralm. Wording has bn addd to th SPD to mak it clarr that th charactr and historic valu of much of th surrounding ara will continu to b protctd and nhancd. It has also bn mad clar that th aras which ar prdominantly housing will mostly continu to b so, with rsidnts bnfitting from th incrasd rang of activitis on th Blackfriars Road Cian McCarri 8 0 ck Figur 3 of th SPD illustrats th rlationship btwn diffrnt planning documnts including supplmntary planning documnts and nighbourhood plans. Th SPD has bn updatd to mak it clar th nighbourhood plans ar currntly bing prpard. Onc adoptd a nighbourhood plan will hav mor wight than a SPD in th planning procss as it will form part of th council's dvlopmnt plan. At prsnt thr is no adoptd nighbourhood plan for any of th ara covrd by th Blackfriars Road SPD. Th SPD may nd to b rviwd in th futur if a nighbourhood plan is adoptd for any of th SPD ara. Dvlopmnt Sit 43 Th Bakrloo Sidings - any Th TfL Bakrloo sidings sit (Sit 43 in Figur 5/Tabl 1 in th draft dvlopmnt on this sit will intrfr with long viws SPD, but r-numbrd as Sit 47 in Figur 6/Tabl1 in th updatd into th Wst Squar Consrvation Ara valud by SPD) has bn includd as a potntial dvlopmnt sit, du to its Southwark Planning. What considration has bn rcognisabl dvlopmnt potntial. Any dvlopmnt at th sit givn to ths in th prparation of this SPD? What is would b assssd and dtrmind at th planning application stag, th vidnc to support its suitability as a dvlopmnt taking th local hritag contxt into account. sit as opposd to ducational, opn spac or othr us? Undr th Elphant & Castl Entrpris Quartr Th SPD stats that list of potntial dvlopmnt sits is illustrativ of

47 Rp Obj Rf Rf Nam Dtails of Rprsntation SPD Southwark should hav consultd TfL. Undr th Localism Act consults ar duty bound to co-oprat so whr may w s TfL s rspons? Any building on this sit will advrsly affct th stting of hritag assts. Th Elphant & Castl Entrpris Ara SPD mntiond a landmark building. W find rfrnc to any such building on this sit dply concrning givn th proximity not only to our own listd houss but also th listd oblisk, St Gorg s RC Cathdral and Imprial War Musum, th lattr two bing th landmark buildings in this location. How ar ths proposals affctd by th Blackfriars Road SPD? Officr Rspons to Rprsntation th hug opportunity for chang within th ara and th nd for a cohrnt framwork. It has also bn updatd to clarify that th list of sits is not xhaustiv and othr sits may com forward for dvlopmnt. Som of th sits will b compltly rdvlopd, whilst othr sits may xprinc lss chang such as rfurbishmnt or improvmnts to th xisting buildings or surroundings. Th formal idntification of proposals sits within th ara will b considrd as part of th prparation of th Nw Southwark Plan. TfL, GLA and Ntwork Rail wr all consultd as part of th consultation procss. Th Blackfriars Road SPD consultation rport summariss all th rsponss rcivd and changs subsquntly mad to th SPD. Th full rprsntations rcivd from ths bodis and th council s rspons to thm is includd within Appndix J of th Blackfriars Road SPD consultation rport Cannon 9 1 John O'Tool St I writ on bhalf of St Gorg s Roman Catholic Gorg 's RC Cathd ral Cathdral, Lambth Road, London SE1 6HR and aftr consultation with th Had tachr of Notr Dam Girls School, 118 St Gorg s Road, London SE1 6EX. W not with intrst th potntial dvlopmnt sits in our local ara (spcially Nos 41, 42 and 43 as listd on pag 12 of th Draft Blackfriars Road Supplmntary Planning Documnt). As w would b dirctly affctd by any futur dvlopmnt so clos to us w would gratly apprciat bing kpt fully informd on any futur dvlopmnts that may b considrd and w would b agr to s and to commnt on any spcific proposals/options that might b put forward in rlation to ths sits. Th Elphant and Castl SPD was adoptd on 20 March 2012 and rplacd th Elphant and Castl Entrpris Quartr SPD (2008) and th Walworth Road SPD (2008). Th Blackfriars Road SPD will rplac th Elphant and Castl SPD/OAPF guidanc for th ovrlapping aras. Th SPD has bn updatd to mak this clarr. Notd. W hav addd th contact dtails providd to our planning policy mailing list for all futur planning policy consultations.

48 Rp Obj Rf Rf Nam Dtails of Rprsntation Officr Rspons to Rprsntation Tanja Martin Thank you for th rcnt Draft supplmntary planning Th SPD sts out th council's mrging vision for th Blackfriars 0 2 documnt in viw of coordinating th growth of Road ara, with dtaild guidanc to achiv this. It includs guidanc Blackfriars road. I'm afraid th proposd stratgy is not on ncouraging a rang of diffrnt businsss uss, town cntrs somthing which supports rsidnts nds or works uss, cultural uss, as wll as many othr uss. It also ncourags towards making this primarily a rsidntial ara, as th supporting infrastructur to support growth. Th SPD sks to statd in th documnt. Prmitting th rmoval of mt th nds of rsidnts whilst also managing th prssur for almost all of th historic building long Blackfriars road nw dvlopmnt. Th SPD has bn updatd to mak it clarr that and rplacing ths with tall glass structurs dosn't th mrging vision and th SPD sks to nsur that dvlopmnt support th nds of rsidnts. Ths structurs ar mts th nds of xisting and nw rsidnts whilst also attracting rmoving any charactr in th road and blocking th nw dvlopmnt. Rsidnts will bnfit from th incras rang of light from our homs and livs. Th mix of shops is uss including mor shops, srvics and businsss along th bing rducd to an abundanc of Tsco's, Blackfriars Road. Sainsbury s locals and prt a mangr outlts, which do not provid a srvic to rsidnts. Ths small chain suprmarkts and chain rstaurants and coff shops hav alrady closd a numbr of th businsss which gnuinly contribut to this community and provid a srvic to rsidnts. W all undrstand th nd to bring mony into th ara but could w hav som mor considration of what th normal rsidnts nd to b abl to liv hr on a prmannt basis, its not mor hotls, studnt halls of rsidnc buildings or chain sandwich shops Transp 1 ort for Londo n Th following rspons contains commnts from TfL to LB Southwark rgarding th draft Blackfriars Road Supplmntary Planning Documnt (SPD), with dtaild mattrs outlind blow. Th cor ara of th documnt s focus is th Blackfriars Road alignmnt, running from Blackfriars Bridg in th north to St Gorgs Circus in th south. Blackfriars Road forms part of th Transport for London Road Ntwork (TLRN) for which TfL is th highway authority. Parts of Stamford Strt and Southwark Strt ar also covrd by th documnt, and ths roads ar also part of th TLRN. A numbr of bus routs oprat within th SPD ara, providing links to th north, Notd. LBS will continu to support improvmnts to th TLRN within Southwark and nsur any proposals that may impact th TLRN ar dlivrd in partnrship with TfL.

49 Rp Obj Rf Rf Nam Transp 2 ort for Londo n Transp 3 ort for Londo n Transp 4 ort for Londo n Dtails of Rprsntation south, ast and wst. Th Public Transport Accssibility (PTAL) of th ara is highst in th northrn part of Blackfriars Road (6a), with Blackfriars Station, Watrloo East and Southwark Station providing links to both National Rail and London Undrground srvics. Th southrn sction of Blackfriars Road also bnfits from a high PTAL. Banksid & Borough Opportunity Ara TfL wish to not that thr is an aspiration to crat an additional point of accss at strt lvl to th Eastrn nd of Watrloo East station. Howvr, this may conflict with LB Southwark s aspiration to work with Ntwork Rail to rfurbish spac undr railway archs to provid modrn accommodation for small businsss. TfL ncourags LB Southwark to ngag furthr with Ntwork Rail and South Eastrn to discuss futur options for Watrloo East furthr. Officr Rspons to Rprsntation Notd - w will continu to ngag ffctivly with Ntwork Rail and South Eastrn to discuss futur options for rfurbishmnts of th railway archs and nsur this dos not prclud potntial options for additional points of accss to Watrloo East Station. In addition, btwn 2015 & 2018 th Thamslink Notd. An additional bullt point has bn addd to SPD 6. Upgrad Programm will man that srvics to Cannon Strt and Charing Cross will not b abl to stop at London Bridg station. As such, th considration of th phasing of dvlopmnts in th ara during th priod of works, to facilitat asir accss to/from Watrloo East would b ncouragd. In addition, TfL ncourags LB Southwark, and Ntwork Rail to work towards th improvmnt of wayfinding from Watrloo East to assist dirct passngrs who would hav othrwis for alightd or changd onto London Undrground srvics at London Bridg. Blackfriars Road Vision (P11) TfL rqusts that this sction is rvisd to rflct th mrging proposals in light of th publication of th Mayor s Vision for Cycling in London which was publishd in March As part of this focus on cycling, Cycl Suprhighway North- South has bn announcd. Th rout will run Notd - th SPD has bn updatd following this announcmnt to rfr to this. Both SPD 6 and th idas for an mrging vision for Blackfriars Road hav both bn updatd.

50 Rp Obj Rf Rf Nam Transp 5 ort for Londo n Dtails of Rprsntation btwn Kings Cross and Elphant & Castl, crossing th Thams at Blackfriars Bridg, bfor running along Blackfriars Road. This will introduc significant improvmnts for cyclists including sgrgatd cycl tracks and junction upgrads along Blackfriars Road. Th rout will also includ nhancmnt to th urban ralm and planting. Public consultation will tak plac in 2014 with rout launchd by TfL ar working closly with LB Southwark, local stakholdrs and dvloprs to nsur that proposd changs align with widr aspirations for th ara. TfL not and wlcom LB Southwark s aspirations to improv conditions along Blackfriars Road for pdstrians and cyclists. Howvr, TfL rqust that rfrnc to nsuring vhicular traffic continus to mov smoothly is rmovd. As part of th Cycl Suprhighway projct, TfL will undrtak dtaild local and London wid traffic modlling to tst dsign options alongsid othr larg scal projcts. Howvr, at this arly stag TfL ar unabl to dtrmin th likly impact of proposals upon vhicular traffic. TfL not aspirations to nhanc and protct aras of th grn stat surrounding and upon th TLRN, as wll dlivr lighting improvmnts and strt art. As notd abov, TfL is in th arly stags of th dsign of urban ralm improvmnts along Blackfriars Road, and thus ar unabl to support spcific proposals at this point in tim. Howvr, in rspct of th public ralm schm which will b dlivrd by TfL upon th public highway. TfL will b working closly with LB Southwark, local stakholdrs and land ownrs/dvloprs to nsur proposals, satisfy th broad rang of strt usrs who rquir us of Blackfriars Road and th surrounding ara Jrmy Lach South W wlcom th mphasis on pdstrians as st out Notd. Officr Rspons to Rprsntation Notd - SPD 6 has bn updatd to rfr spcifically to Blackfriars Road bing part of th TLRN and that th council will work with TfL as wll as othr ky stakholdrs to nsur that dvlopmnt and invstmnt on and around Blackfriars Road taks plac in a coordinatd way.

51 Rp Obj Rf Rf Nam 6 wark Living Strts 137 Jrmy Lach South wark Living Strts 137 Jrmy Lach South wark Living Strts Dtails of Rprsntation in th final paragraph of th vision (on pag 11). In ordr to giv mor substanc to this, w wish to mak th following commnts on th draft documnt. 1. North of Southwark Station. Dvlopmnt is alrady wll advancd but w wlcom th numbr of proposd and improvd pdstrian links particularly through larg dvlopmnt sits. Th SPD should nsur ths ar wlcoming, prmannt and nithr rstrictd to th hours of businss nor ncumbrd by aggrssiv scurity popl and obstructions. Christchurch and Paris Gardns ar th main opn aras and w should lik to s ths nhancd, xtnding th grn rout from th rivr south to Th Cut and to Southwark tub station. With incrasing numbrs of pdstrians, spcially arriving and laving from Blackfriars Station and th narby major nw buildings, w bliv a crossing at Stamford Strt along th lins of that at Oxford Circus with its many dirction pdstrian phas but littl strt cluttr would b bnficial. Crossing any of th arms of this junction on foot is at prsnt dangrous, intimidating and unplasant. A wll dsignd Oxford Circus layout should b an objctiv of dvlopmnt policy hr. 2. South of Southwark Station. Fw pdstrian routs and no nw grn spacs hav bn idntifid in this southrn sction with its high population dnsity. W propos that Dvlopmnt Sit 27 should hav a through pdstrian rout btwn a small grn ara alongsid Blackfriars Road and a grn spac at th rar and accss to Friars Primary School. Southwark Living Strts dlivrd a rport (attachd) St Gorg s Circus Rcrating Th Gatway to London to th London Borough of Southwark, amongst othrs, in July In this, w rmarkd that far from th original dsignrs vision of a gatway, th Officr Rspons to Rprsntation SPD 6 mphasiss th council's commitmnt to improv th pdstrian nvironmnt, with Stamford Strt junction spcifid. Th layout of this junction diffrs in both scal and opration to Oxford Circus and thrfor cannot fasibly accommodat an option for multiway crossings. Th council will continu to lobby and work with TfL. This will includ to look at th layout of th junction and signal timings and dvloping thir dsigns for this road to nsur any options addrss pdstrian priority, convninc and safty at this junction. Sinc th publication of th draft SPD it has bn announcd that TfL ar proposing to introduc a North South Cycl Suprhighway along Blackfriars Road linking up to Kings Cross in th north, and Elphant and Castl south of Blackfriars Road. Th council support TfL's proposals and th SPD txt has bn updatd to rfr to this. W will work with TfL to nsur a holistic approach whn dvloping dsigns for th cycl suprhighway to nsur thy balanc th nds of all usrs and improv conditions and facilitis for pdstrians. TfL hav advisd that a consultation will tak plac ovr summr As part of th dvlopmnt for th cycl suprhighway, TfL will nd to rviw St Gorgs Circus.

52 Rp Obj Rf Rf Nam 137 Jrmy Lach South wark Living Strts 137 Jrmy Lach South wark Living Strts Dtails of Rprsntation Circus has, for mor than a dcad, bn a barrir to pdstrian movmnt. It is also woful for th incrasing numbr of cyclists who now mov through this ara in all dirctions. With th imminnt opning of th LSBU Entrpris Cntr and th dvlopmnt at Erlang Hous, th SPD should b clarr about rquirmnts at this intrsction. Th cntral island nds to b linkd to its surroundings by pdstrian crossings of th road round th oblisk with synchronisd pdstrian phass across th whol (again, lik Oxford Circus). This would provid mor dirct walking routs, and, if wll dsignd, could bttr accommodat cyclists whil maintaining vhicl flows. 3. Tall Buildings, Wind and Trs. With a larg numbr of tall buildings forming a canyon and in clos proximity to rsidntial proprtis w ar concrnd that swirling winds will caus pdstrians difficultis. Also ar th xisting trs bing kpt or rplacd? Th illustration in th SPD shows smallr varitis than th prsnt plan trs. Whil an avnu of matur plan trs can b majstic, othr and smallr trs may b prfrabl for a popl-frindly strt in crtain locations. W rcommnd that th SPD should incorporat a tr stratgy, dvisd with profssional arboricultur input mph. W fl that with th advnt of far gratr numbrs of rsidnts and workrs to th ara and th larg numbrs of xisting and nw pdstrians and cyclists likly to us th proposd north-south cycl rout, a strong cas should b mad for a 20mph spd limit throughout th ara and most spcially on Blackfriars Rd itslf. Making this dcision will allow all road dsign changs to b mad to 20mph spd limits which will hav a significant impact on th dsign Officr Rspons to Rprsntation Ths mattrs would b assssd at th planning application stag through th rlvant savd Southwark Plan policis, Cor Stratgy Policy SP12 and th rlvant policis of th London Plan and othr planning guidanc. Bullt-point 14 of SPD 5 sts out furthr guidanc rgarding microclimat. Strts trs ar supportd by th SPD within SPD 3, and would b addrssd on a sit or projct basis. TfL ar th Highway Authority for Blackfriars Road and as such st th spd limit. Southwark Council support th introduction of 20mph limits on our rsidntial strts. Th SPD dos not list spcific road safty intrvntions, howvr if a 20mph limit wr to b introducd by TfL this would b supportd by xisting policis (including th Cor Stratgy and th Transport Plan) and th guidanc within this SPD.

53 Rp Obj Rf Rf Nam Anonym 1 5 ous 1 Dtails of Rprsntation making it far mor popl frindly (with tightr radius junctions for xampl) that can assist in rducing vhicl spds. Much rsarch has shown that slowr spds hav th gratst impact on incrasing road safty and ncouraging mor activ forms of travl. W hop that you will tak ths points into considration and incorporat thm in th nxt itration of th SPD. Proposd hight at Station way to high. Should not us Palstra buildings as a rfrnc point for hight us historical and hritag building for both hight and apparanc. Oblisk at St Gorgs Circus is th focal point for that sit, don t NEED a tall building thr. Officr Rspons to Rprsntation A tall building up to 70m in hight could b appropriat at th southrn nd of Blackfriars Road providd that it complis with th dtaild guidanc outlind in SPD 5 and th currnt dvlopmnt plan that includs th rlvant policis of th savd Southwark Plan (2007), Cor Stratgy (2011), London Plan (2011) and othr planning documnts/guidanc, including th NPPF (2012). Th dvlopmnt plan sts out th policis for tall buildings. Th guidanc in th SPD provids dtail on how to implmnt ths dvlopmnt plan policis spcific to Blackfriars Road Anonym 2 5 ous Anonym 3 5 ous 1 Limit fast food/takaway provision in nw dvlopmnts in Blackfriars Road. Encourag and support xisting artisan /small businsss, nsur Union thatr rmains opn ncourag th `cultural corridor` from Old Vic to Tat Th approach is supportd by our vidnc bas including th Blackfriars Road Urban Dsign Study which has bn prpard in accordanc with CABE and English Hritag Guidanc on Tall Buildings, In light of consultation rsponss and to add clarity to th guidanc rlating to St Gorg s Circus in SPD 5, th SPD has bn updatd to clarify that a tall building could provid a focal point at th southrn nd of Blackfriars Road up to 70ms. A tall building should also sustain, nhanc or bttr rval th local hritag assts. In prparing th Nw Southwark Plan, which will rplac th Cor Stratgy (2011) and savd Southwark Plan policis (2007), w will b considring as part of th arly issus and options tsting, whthr w should prpar mor dtaild planning policis to hlp manag th mix of rtail uss such as rstaurants, bars, cafs and hot food takaways. Th north of th SPD ara lis within th Stratgic Cultural Ara (Southbank/ Banksid/ London Bridg) which is a dsignatd ara rcognisd through planning policis in th London Plan and th Cor

54 Rp Obj Rf Rf Nam Anonym 4 5 ous Anonym 5 5 ous 1 Dtails of Rprsntation Modrn/Glob as a concpt and tourist attraction. Employmnt opportunitis locals don t gt mployd in th nw Tscos tc. LBS should nforc thir own affordabl /social housing % in nw dvlopmnts Support indpndnt tradrs. Hav a propr vision (g. Isablla Strt) Officr Rspons to Rprsntation Stratgy. This ara is whr London s intrnationally rnownd historic nvironmnt, natural landscap and cultural institutions, including musums, gallris and thatrs, and othr major visitor attractions ar protctd and nhancd. SPD2 ncourags th dvlopmnt of nw arts, cultural, lisur and ntrtainmnt uss in mixd us dvlopmnt throughout th ara to hlp consolidat this clustr of arts and cultural facilitis. Through SPD1, w support th provision of small businss floorspac, such as small offic/studio workshop spac, to hlp to provid appropriatly sizd modrn nw spac for a varity of small businsss to us, including th crativ and cultural sctor. Th council s Economic Wll-bing Stratgy ( ) sts out th ambition for rgnration and dvlopmnt to provid lasting jobs for rsidnts in both th construction of dvlopmnt and also in th final dvlopmnt itslf through training and skills programms. Th council s adoptd Sction 106 Planning Obligations SPD provids th basis for scuring planning obligations from nw dvlopmnt for mploymnt and ntrpris masurs which includ initiativs to crat jobs and training in th final dvlopmnt, and also jobs and training during th construction priod of th dvlopmnt. Th borough-wid affordabl housing policy within th Cor Stratgy (2011) rquirs th provision of at last 35% provision in nw housing dvlopmnts. Th adoptd Affordabl Housing SPD (2008) and draft Affordabl Housing SPD (2011) st out furthr dtail to implmnting th policy, including th guidanc on addrssing th squntial approach to th provision of affordabl housing. Th priority for th council is for affordabl housing to b providd on-sit. Th dvlopr nds to submit justification to th council in circumstancs whr this may not b possibl. Th SPD dos not nd any furthr spcific guidanc in rlation to affordabl housing as this is covrd in xisting borough-wid policis and associatd guidanc. SPD 1 and SPD 2 ncourags a rang of unit sizs and that spacs should b dsignd flxibility to mt a rang of diffrnt nds. Th

55 Rp Obj Rf Rf Nam Anonym 6 5 ous 1 GP/Dntist/schools Dtails of Rprsntation Officr Rspons to Rprsntation mrging vision is st out in th SPD, and as xplaind in th SPD will b dvlopd furthr into dvlopmnt plan policy through th prparation of th Nw Southwark Plan. Th SPD and othr planning policy documnts provid th framwork for th provision of infrastructur to support dvlopmnt. SPD 2: Mixd us town cntr sts out that w will support th provision of nw social infrastructur and community facilitis as part of mixd us dvlopmnts. SPD 3: Public ralm and opn spac rfrs to th continud protction of th thr protctd opn spacs and ncouraging furthr linkags and nw spacs. Updats hav bn mad to th SPD to rfr to ncouraging a rang of diffrnt uss including halth facilitis Sction 4 of th SPD rfrs spcifically to infrastructur, crossing rfrring to th community infrastructur lvy (CIL) and sction 106 planning obligations to hlp nsur th dlivry of ky infrastructur to mitigat th impact of dvlopmnt. Infrastructur is covrd within borough-wid planning documnts with th ovrarching policy 14 of th Cor Stratgy rcognising that nw dvlopmnt in th borough nds to b supportd by adquat infrastructur, including social, nvironmntal and physical infrastructur. Th borough s Infrastructur Plan, idntifis stratgic infrastructur which is ndd to support growth and dvlopmnt in th borough ovr th liftim of th Cor Stratgy ( ). Whr possibl it idntifis th cost of infrastructur to providd, any committd sourcs of funding which will b usd to dlivr it and th organis rsponsibl. It also idntifis th funding gap i.. th gap btwn known commitmnts and th total cost of infrastructur rquird. Whn it is adoptd, Southwark s CIL will b usd to contribut towards bridging this funding gap. Funds armarkd for infrastructur in th Council s capital invstmnt programm also will hlp to improv infrastructur provision. Th council ar currntly prparing our draft community infrastructur charging schdul and an

56 Rp Obj Rf Rf Nam Dtails of Rprsntation Jan Bats 38, 39, 40 No high ris buildings bcaus of th skylin, light and wind factors. No building ovr 30 mtrs tall in kping th hight of xisting buildings Jan Bats On sits 10, 18 and 19 a park for childrn and adults. W will nd mor parks for all th childrn bing born and tnagrs. Officr Rspons to Rprsntation updatd sction 106 SPD. Adoption is plannd for It is appropriat to look at th provision of infrastructur at a borough-wid lvl through ths ddicatd documnts rathr than through th Blackfriars Road SPD. Th approach is supportd by our vidnc bas including th Blackfriars Road Urban Dsign Study which has bn prpard in accordanc with CABE and English Hritag Guidanc on Tall Buildings, In light of consultation rsponss and to add clarity to th guidanc rlating to St Gorg s Circus in SPD 5, th SPD has bn updatd to clarify that a tall building could provid a focal point at th southrn nd of Blackfriars Road up to 70ms. A tall building should also sustain, nhanc or bttr rval th local hritag assts. Th figur and tabl within th SPD shows potntial dvlopmnt sits. Ths sits ar idntifid by officrs as sits with th potntial for som chang to th building or its surroundings. Som of th sits hav planning prmission, som ar undr construction, som ar going through th planning procss, and som hav no known plans as yt. Th list and figur has bn updatd following consultation to tak into account suggstions from land ownrs and rsidnts. Furthr wording has also bn addd to th SPD to mak it clar that th list of sits is not xhaustiv and that whilst som of th sits will b compltly rdvlopd othr sits might xprinc lss chang such as rfurbishmnt or improvmnts to th xisting buildings or surroundings. Th SPD is not allocating sits as proposals sits and so dos not provid policis on th land uss within ach of th sits. Th allocation of proposals sits is don through a dvlopmnt plan documnt. Currnt dsignations for Blackfriars Road ar in th savd Southwark Plan (2007) which is currntly bing rviwd through th prparation of th Nw Southwark Plan. As part of this rviw w will b looking at whthr w should allocat mor and/or chang xisting proposals sits dsignations and updat th adoptd policis map.

57 Rp Obj Rf Rf Nam Dtails of Rprsntation Jan Bats Mor halth and doctor surgris and mor NOT lss 9 fir stations with all th nw flats bing build so clos togthr Officr Rspons to Rprsntation Full consultation will b carrid out on th Nw Southwark Plan in accordanc with our SCI and th rlvant rgulations. Th SPD and othr planning policy documnts provid th framwork for th provision of infrastructur to support dvlopmnt. Updats hav bn mad to th SPD to rfr to ncouraging a rang of diffrnt uss including halth facilitis. SPD 2: Mixd us town cntr sts out that w will support th provision of nw social infrastructur and community facilitis as part of mixd us dvlopmnts. SPD 3: Public ralm and opn spac rfrs to th continud protction of th thr protctd opn spacs and ncouraging furthr linkags and nw spacs. Sction 4 of th SPD rfrs spcifically to infrastructur, crossing rfrring to th community infrastructur lvy (CIL) and sction 106 planning obligations to hlp nsur th dlivry of ky infrastructur to mitigat th impact of dvlopmnt. Infrastructur is covrd within borough-wid planning documnts with th ovrarching policy 14 of th Cor Stratgy rcognising that nw dvlopmnt in th borough nds to b supportd by adquat infrastructur, including social, nvironmntal and physical infrastructur. Th borough s Infrastructur Plan, idntifis stratgic infrastructur which is ndd to support growth and dvlopmnt in th borough ovr th liftim of th Cor Stratgy ( ). Whr possibl it idntifis th cost of infrastructur to providd, any committd sourcs of funding which will b usd to dlivr it and th organis rsponsibl. It also idntifis th funding gap i.. th gap btwn known commitmnts and th total cost of infrastructur rquird. Whn it is adoptd, Southwark s CIL will b usd to contribut towards bridging this funding gap. Funds armarkd for infrastructur in th Council s capital invstmnt programm also will hlp to improv infrastructur provision. Th council ar currntly prparing our draft community infrastructur charging schdul and an

58 Rp Obj Rf Rf Nam Dtails of Rprsntation Officr Rspons to Rprsntation updatd sction 106 SPD. Adoption is plannd for It is appropriat to look at th provision of infrastructur at a borough-wid lvl through ths ddicatd documnts rathr than through th Blackfriars Road SPD Jan Bats Nw building bing built should hav light cladding and Th SPD cannot provid such a dtaild guidanc. Howvr, w hav 0 glass dsignd with a dsign to fit in with xisting updatd wording of SPD 4 to that it matrials and faturs considr buildings. (xampl how not to do it) g. 1 Valntin th idntity of th surroundings, taking th local historic nvironmnt Plac nxt to a pub with lovly brickwork. 1 Valntin into considration. Plac looks a right y sor, nothing lik th photos bfor th building was built. I hav photos of thss bfor it was built, it has light colour cladding Jan Bats This is a nic quit ara which is how w would lik it 1 kpt So no MacDonald s or Btting shops. As somon who was born and livd in Southwark most of my lif it saddns m to think that w locals ar not bing listnd to. W s how th flats and building going up with no considration for our plac of living Jan Bats Th flats ar bing built too clos togthr. This is a 2 chang to mak th ara a plac of Bauty not Ghttos for th futur. I bt 2Boris would not liv with a high ris nxt to his hous. Thank you for rading this and having th mting. I njoyd it and look Th SPD ara is locatd within th Banksid, Borough and London Bridg Opportunity Ara and part of th Elphant and Castl Opportunity Ara and also th Cntral Activitis Zon, which ar aras rcognisd in th London Plan and Southwark s Cor Stratgy suitabl for chang and to accommodat nw housing and an incras in jobs. Th SPD focuss on Blackfriars Road, whr most of th chang will tak plac, but also taks in som of th surrounding ara which will also s dvlopmnt and improvmnts, particularly to its public ralm. Th SPD provids furthr guidanc to xisting planning policis in our Cor Stratgy and savd Southwark Plan. It dos not rpat borough wid policis and so th SPD must b rad alongsid our othr planning documnts. Th SPD guidanc promots a widr mix of shops and srvics to mt local popl s nds as wll as th nds of offic workrs and tourists, in lin with xisting planning policy. In prparing th Nw Southwark Plan, which will rplac th Cor Stratgy (2011) and savd Southwark Plan policis (2007), th council will b considring whthr w should prpar mor dtaild policis to manag th numbr and typ of uss on our high strts Existing borough-wid policis nsur high quality rsidntial dvlopmnt of appropriat dnsitis. This includs guidanc in th council's Rsidntial Dsign Standards SPD on distancs btwn rsidntial buildings.

59 Rp Obj Rf Rf Nam 635 c/o Agnt 635 c/o Agnt 635 c/o Agnt 635 c/o Agnt 635 c/o Agnt Londo n South Bank Univr sity Londo n South Bank Univr sity Londo n South Bank Univr sity Londo n South Bank Univr sity Londo n South Bank Univr Dtails of Rprsntation Officr Rspons to Rprsntation forward to th nxt on. 1.1.a. Amndmnt to txt: W will work with th No chang. LSBU includd in othr stakholdrs Gratr London Authority (GLA), Transport for London (TfL), English Hritag, dvloprs, landownrs, Banksid Nighbourhood Forum, London South Bank Univrsity, Lambth Council, th community, and othr stakholdrs to provid a high quality dsign of public squars, strts and spacs. SPD 3 Public ralm and opn spac, p b. Amndmnt to txt: W will work with th In this contxt LSBU would fall undr landownrs. W hav updatd Gratr London Authority (GLA), Transport for London txt whr rlvant to includ LSBU howvr in this instanc it is not (TfL), dvloprs, landownrs, Banksid appropriat to list any individual stakholdrs. W hav also updatd Nighbourhood Forum, London South Bank Univrsity, this to tak out any spcific forum and rfr to 'Nighbourhood Lambth Council, th community and othr Forums'. stakholdrs to:. SPD 6 Activ travl, p c. Amndmnt to txt: W will work closly with TfL, Banksid Nighbourhood Forum, London South Bank Univrsity and Lambth Council para 3.39 p As a gnral point, rfrnc to London South Bank Univrsity should b consistnt throughout th SPD (amndmnts undrlind): 1.2.a. Amndmnt to txt: South Bank Employrs Group, London South Bank Univrsity, tnants and rsidnts associations Blackfriars Road Vision, p b. Amndmnt to txt: SE1 Safr Road Forum, London South Bank Univrsity, Banksid Nighbourhood Forum Implmntation, para p W also rqust that th basmaps, for figurs 2, 5, 6 and 7, ar updatd to includ th compltd (Rf: 11-AP-3529) London South Bank Univrsity s Th Clarnc Cntr for Entrpris and Innovation (formrly known as Th Entrpris Cntr). In this contxt LSBU would fall undr landownrs who ar rfrrd to xplicitly within th first sntnc of SPD 6. It is not appropriat to spcify th individual landownrs or dvloprs who would b involvd at this sction of th SPD. Notd, this has bn updatd throughout th SPD. Notd. Th bas map has bn updatd.

60 Rp Obj Rf Rf Nam 635 c/o Agnt 635 c/o Agnt 635 c/o Agnt sity Londo n South Bank Univr sity Londo n South Bank Univr sity Londo n Dtails of Rprsntation 2. Th Rol of London South Bank Univrsity 2.1. In Support notd. gnral w support th vision, and spcifically th aspiration to maximis opportunitis to incras th amount and typ of flxibl innovativ businss spac W support policy SPD 1, whr it rcogniss th rgnration bnfits that can b gnratd by strngthning links btwn businsss and ducation institutions such as London South Bank Univrsity, which runs a succssful sris of initiativs to fostr ntrpris and businss start ups. Howvr, th importanc of such links should b clarly statd in th main txt of SPD 1 to mphasis th importanc of crating opportunitis for flxibl innovativ businss spac and symbiotic rlationships btwn businsss and larning institutions. As such w propos th following amndmnts (undrlind): 2.2.a. Additional bullt point: Encourag th dvlopmnt of businss and ntrpris by crating and rinforcing links btwn businsss, ntrpriss and institutions of ducation and art, including supporting co-location and provision of incubator facilitis. SPD 1 Businss Spac p b. Supporting txt amndmnt: thr is potntial for nw businss spac in th southrn ara to tak advantag of opportunitis in strngthning businss links with th two larning cntrs (London Collg of Communication and London South Bank Univrsity), building on th foundation of London South Bank Univrsity s ntrpris cntr situatd at St. Gorg s Circus. Businss spac, para 3.3 p To achiv th vision of crating opportunitis for flxibl innovativ businss spac, it is also important Officr Rspons to Rprsntation Support notd. W hav amndd th supporting txt to includ rfrnc to th Clarnc cntr for ntrpris and innovation. W do not considr th suggstd additional bullt point to b ncssary, as this is sufficintly covrd in th supporting txt W hav mad an amndmnt to SPD1 bullt point 1 to includ rfrnc to small and start-up businsss. W hav also insrtd

61 Rp Obj Rf Rf Nam 635 c/o Agnt 635 c/o Agnt South Bank Univr sity Londo n South Bank Univr sity Londo n South Bank Univr sity Dtails of Rprsntation Officr Rspons to Rprsntation for SPD 1 to promot th cration and support start up additional supporting txt to highlight th growth of SMEs in th ara. businsss and ntrpriss. W thrfor propos th addition of a nw bullt point: 2.3.a. Additional bullt point: Promot opportunitis to dvlop nw start up businsss to support nw ntrpriss and contribut to a sustainabl conomy. SPD 1 Businss Spac p LSBU plays a vital rol within th local community W hav amndd th supporting txt to rfr to London South Bank of Southwark by providing major social infrastructur, Univrsity and its outrach programms. coordinating a numbr of outrach programms and community initiativs. Th univrsity also provids a rang of sport and fitnss facilitis including a gym and a sports hall, which ar opn to th widr community. As such, LSBU should b rcognisd in th SPD as a notabl pic of social infrastructur and a community facility and suggst th following (undrlind): 2.4.a. Amndmnt to txt: Notably, th Blackfriars Sttlmnt has bn providing support and rsourcs to th community for 125 yars, and is an important asst to th ara providing mting rooms, facilitis and community vnts. London South Bank Univrsity provids a rang of community outrach programms to support businss, ntrpris and ducation within th community in addition to providing sport and fitnss facilitis, including a gym and sports hall. Mixd us town cntr, para 3.14 p Th SPD Boundary 3.1. Th draft Blackfriars Road Th boundary of th southrn part of th SPD boundary has bn SPD boundary ovrlaps that of th Adoptd Elphant amndd to includ th boundary suggstd by LSBU. It is and Castl SPD (March, 2012), with partial inclusion of appropriat to includ part of th Elphant and Castl Opportunity th LSBU campus. To provid clar and unambiguous ara with th Blackfriars Road SPD to nsur clar guidanc for policy guidanc thr should b a consistnt approach dvlopmnt fronting onto historic St. Gorg's Circus. Th SPD has btwn th two SPDs Following our mting bn updatd to rfr to th xisting SPD/OAPF and that th with LBS w undrstand that th mor rcnt Blackfriars Road SPD will rplac th guidanc for th ovrlapping documnt, th Blackfriars Road SPD, will tak ara. prcdnc whr thr ar sits covrd by both

62 Rp Obj Rf Rf Nam 635 c/o Agnt 635 c/o Agnt 635 c/o Agnt Londo n South Bank Univr sity Londo n South Bank Univr sity Londo n South Dtails of Rprsntation SPDs, it would b hlpful for this to b clarly statd within th documnt. Officr Rspons to Rprsntation 3.3. In ordr to avoid confusion, w would additionally Th boundary of th southrn part of th SPD boundary has bn prfr a consistnt approach to guidanc whr amndd to includ th boundary suggstd by LSBU. Th SPD has possibl btwn th SPDs. For xampl, whr a sit bn updatd to rfr to th xisting SPD/OAPF and that th is covrd by multipl SPDs th proposals for that sit Blackfriars Road SPD will rplac th guidanc for th ovrlapping should b consistnt in both documnts. This is not ara. always achivd in th Blackfriars Road SPD, whr a numbr of dvlopmnt opportunity sits within th LSBU campus ar includd in th Elphant and Castl SPD but omittd from th draft Blackfriars Road SPD. For consistncy and to avoid ambiguity w thrfor propos that th following dvlopmnt sits, indicatd on pag 18 of th Elphant and Castl SPD (March, 2012), should b includd as dvlopmnt sits within th Blackfriars Road SPD, as illustratd in Appndix A: Sit boundd by Rotary Strt, Thomas Doyl Strt and London Road (s sit 1 in Appndix A); and Chapl Borough Road (s sit 2 in Appndix A) Th quadrant in th north ast of th LSBU Th boundary has bn updatd as rqustd. campus is known as th Anchor 2 sit. It is boundd by London Road, Borough Road, Thomas Doyl Strt and Kyworth Strt, and includs th rcntly compltd Clarnc Cntr for Entrpris and Innovation. This ara is part of th univrsity s stats stratgy as a potntially comprhnsiv dvlopmnt opportunity and w thrfor rqust that th boundary is xtndd to includ ach block to th ast and th wst of Rotary Strt. Plas s th mark up at Appndix A which illustrats th proposd boundary amndmnt London Road is important not only as a ky point Notd. S officr rsponss to dtaild suggstions. of arrival to LSBU, but mor prominntly as a main link to th widr rgnration of th Blackfriars Road and

63 Rp Obj Rf Rf Nam 635 c/o Agnt 635 c/o Agnt 635 c/o Agnt Bank Univr sity Londo n South Bank Univr sity Londo n South Bank Univr sity Londo n South Bank Univr Dtails of Rprsntation Elphant and Castl aras. Whil w do not considr it ncssary to amnd th boundary to includ th whol of London Road, w propos a numbr of amndmnts to rinforc its significanc W not that th stratgic importanc of providing connctions from th City along Blackfriars Road to Elphant and Castl is rcognisd throughout th draft SPD, in accordanc with Stratgic Policy 2 Sustainabl Transport of th Southwark Cor Stratgy (April, 2011). Howvr, London Road is not spcifically statd in th SPD as providing this stratgic connction. To mphasis th important rol of London Road in conncting surrounding rgnration aras w thrfor propos th following amndmnt (undrlind): 3.6.a. Amndmnt to txt: Improv Blackfriars Road as a ky walking and cycling rout linking Elphant and Castl, th Rivr and th City of London, including improvmnts to London Road. SPD 6 Activ travl p W support th rcognition of th importanc of th rout by th principl for London Road to bcom a grn rout and a ky approach, as illustratd on figur 6 Indicativ movmnt/public ralm/opn spacs diagram. Howvr, givn its importanc, London Road should b tratd consistntly and thrfor w rqust that th grn rout and ky approach ar xtndd to includ th full lngth of London Road as pr th mark up of figur 6 Indicativ movmnt/public ralm/opn spacs diagram at Appndix B W undrstand that London Road is currntly th focus of a public ralm study by Allis and Morrison. W trust that this study will considr th principls includd within th Elphant and Castl SPD (March, 2012), such as th rquirmnt to xplor Officr Rspons to Rprsntation Th SPD focuss on Blackfriars Road, this is mad clar within th SPD itslf. Only a small part London Road falls within th SPD ara. It is not within th scop of th SPD to rfr to mor improvmnts along London Road. Howvr this will b lookd at in dtail through TfL's work on th Cycl Suprhighway. Sinc th first draft of th Blackfriars Road SPD was rlasd, TfL hav announcd proposals for Cycl Suprhighway North - South to link Elphant and Cast to Kings Cross. Th council will work with TfL to nsur any dsigns balanc th nds of all usrs along this rout and provid an improvd connctions for pdstrians as wll as cyclists. Th SPD has bn updatd within SPD 6: Activ travl and th idas of an mrging vision for Blackfriars Road to rfr to th work bing carrid out by TfL. Th SPD focuss on Blackfriars Road, this is mad clar within th SPD itslf. Only a small part London Road falls within th SPD ara. It is not within th scop of th SPD to rfr to mor improvmnts or possibl grn routs along London Road Th SPD dos not contain dtail on spcific dsign options, rathr it mphasiss th mrging vision for th ara and th council's objctivs and considrations for dvlopmnts in th ara. Any futur proposals for ithr London Road or othr nighbouring strts should b in lin with th London Plan and Southwark policis and would

64 Rp Obj Rf Rf Nam 635 c/o Agnt 635 c/o Agnt sity Londo n South Bank Univr sity Londo n South Bank Univr sity Dtails of Rprsntation opportunitis to crat a public transport-only strt along London Road. Should th findings of that study altr th natur of th proposals for London Road, it may b ncssary to considr including London Road within th Blackfriars Road SPD boundary and providing furthr guidanc thrin W also undrstand that TfL ar undrtaking modlling of Blackfriars Road and w strongly rcommnd that thir study is xtndd to includ th whol of London Road givn its rol and importanc in th ara. This should includ considration of potntial futur vhicl, public transport and cycl movmnts along this important rout. Officr Rspons to Rprsntation thrfor not altr th vision of this documnt. W will b dvloping th vision mor thoroughly through prparation of th Nw Southwark Plan. This is outsid th scop of th SPD. Howvr sinc th publication of th draft SPD it has bn announcd that TfL ar proposing to introduc a North South Cycl Suprhighway linking Elphant and Castl through Blackfriars Road to th rivr and continuing a northrn alignmnt to Kings Cross. Th council support TfL's proposals and th SPD txt has bn updatd to rfr to this. W will work with TfL to nsur a holistic approach whn dvloping dsigns for th cycl suprhighway to nsur thy balanc th nds of all usrs and improv conditions and facilitis for all usrs. TfL hav advisd that a consultation will tak plac ovr summr Potntial Additional Dvlopmnt Sits 4.1. Th Th appropriat figurs hav bn updatd to includ ths sits. vacant grad II listd Passmor Edwards Library/12 Borough Road and Caxton Hous, currntly 50% vacant, prsnt opportunitis for futur dvlopmnt to th north of Borough Road. Thr is potntial to improv th public ralm and gnrat activity along Borough Road. A combination of rfurbishmnt and nw build could bring th buildings back to lif; consrving and nhancing xisting hritag assts, whilst producing nw uss and gratly improving th quality of th nvironmnt. Thrfor w rqust th following addition: 4.1.a. Includ th following additional dvlopmnt sits, as shown on figur 5 (plas s Appndix A) and associatd tabl 1 (p12 13): Caxton Hous on Borough Road (s sit 3 in Appndix A); and Th Passmor Edwards Library/12 Borough Road on Borough Road (s sit 4 in Appndix A) c/o Londo 4.2. Thr is also a furthr opportunity to support th Th appropriat figurs hav bn updatd to includ this sit.

65 Rp Obj Rf Rf Nam 1 Agnt n South Bank Univr sity 635 c/o Agnt 635 c/o Agnt 635 c/o Agnt Londo n South Bank Univr sity Londo n South Bank Univr sity Londo n South Bank Univr sity Dtails of Rprsntation comprhnsiv dvlopmnt of LSBU s Anchor 2 sit by including th Pabody Hugh Astor Court housing on Thomas Doyl Strt as a potntial dvlopmnt opportunity. As such w propos th following addition: 4.2.a. Includ th following dvlopmnt sit as shown on figur 5 (plas s Appndix A) and associatd tabl 1 (p12 13): Pabody Hugh Astor Court housing on Thomas Doyl Strt (s sit 5 in Appndix A). Officr Rspons to Rprsntation 5.1. Arts, cultur, lisur and ntrtainmnt uss ar Highr ducation uss hav bn addd to SPD 2: Mixd us town important in improving activity, vibrancy and achiving cntr and also to th mrging vision. an ara which is activ during both day and night. W thrfor support th positiv viw of proposals for arts, cultur, lisur and ntrtainmnt uss. In addition howvr, highr ducation should b rcognisd as a complimntary land us which crats divrsity, activity and vibrancy, as such w hav proposd th following amndmnts (undrlind) in accordanc with Stratgic Policy 4 Placs for Larning, Enjoymnt and Halthy Lifstyls of th Southwark Cor Stratgy (April, 2011): 5.1.a. Amndmnt to txt: Highr ducation, cultural, lisur, arts and ntrtainmnt uss will also b ncouragd which will bnfit local rsidnts and hlp mak Blackfriars Road a dstination, linking to many cultural facilitis along th South Bank, Th Cut and Watrloo. Vision p b. Additional bullt point: Th continuous dvlopmnt of highr ducation uss will b ncouragd, contributing to widr rgnration through bnfits such as ducational attainmnt, mploymnt, community outrach, vibrancy and improvmnts to th physical nvironmnt. Mixd us town cntr p. 16. Th mrging vision has bn updatd to includ highr ducation uss. Th suggstd chang is not considrd ncssary as w hav alrady covrd it lswhr in th SPD. W hav amndd th mrging vision for th ara, to includ rfrnc to highr ducation uss bing ncouragd in th ara. W hav amndd bullt point 3 of SPD2 to includ rfrnc to ducation uss. W hav also amndd Bullt 5 of SPD2 to laborat on nw social infrastructur (which includs schools). Th supporting txt has bn amndd to includ rfrnc to opportunitis to incras and improv th rang

66 Rp Obj Rf Rf Nam 635 c/o Agnt 635 c/o Agnt 635 c/o Agnt Londo n South Bank Univr sity Londo n South Bank Univr sity Londo n Dtails of Rprsntation Amndmnt to txt: Failing th addition of th abov bullt point w ask for th following amndmnt as a minimum: Encouraging a mix of complmntary highr ducation, arts, cultural, lisur and ntrtainmnt uss, taking into account thir conomic bnfit to th ara, thir impact on halth and wllbing and thir ability to add vibrancy to th strt scn. Mixd us town cntr p Blackfriars Road includs a divrs mix of land uss. W support th ncouragmnt of th ara as a plac for businss, cultur, lisur, arts, community and ntrtainmnt. In addition howvr, providing high quality and affordabl studnt accommodation is a ky priority for th univrsity and nds to b dlivrd in suitabl locations with appropriat dsigns to maximis its contribution to th dvlopmnt of a sustainabl and divrs community, in accordanc with Stratgic Policy 8 Studnt Homs of th Southwark Cor Stratgy (April, 2011) and Policy 4.7 Non-Slf Containd Housing for Idntifid Usr Groups of th Southwark plan (July, 2007). As such, thr will b circumstancs whr accommodation should not ncssarily b rstrictd to uppr floors, such as aras away from main dstinations whr mixd us may not b fasibl. W thrfor suggst th following minor amndmnt (undrlind): 5.2.a. Thr will also b many nw homs, primarily on th uppr floors of commrcial dvlopmnt, offring a rang of housing typs and sizs. Vision p W not that whilst rsidntial land us, including studnt accommodation, is not spcifically addrssd Officr Rspons to Rprsntation of infrastructur and facilitis bing maximisd including looking at halth facilitis and community facilitis. Th suggstd chang is not considrd ncssary as w hav alrady covrd it lswhr in th SPD. W hav amndd th mrging vision for th ara, to includ rfrnc to highr ducation uss bing ncouragd in th ara. W hav amndd bullt point 3 of SPD2 to includ rfrnc to ducation uss. W hav also amndd Bullt 5 of SPD2 to laborat on nw social infrastructur (which includs schools). Th supporting txt has bn amndd to includ rfrnc to opportunitis to incras and improv th rang of infrastructur and facilitis bing maximisd including looking at halth facilitis and community facilitis. Th vision has bn updatd to rflct this. Housing is not givn its own sction within th SPD bcaus th borough-wid housing policis and guidanc alrady covr housing

67 Rp Obj Rf Rf Nam 635 c/o Agnt 635 c/o Agnt 635 c/o Agnt South Bank Univr sity Londo n South Bank Univr sity Londo n South Bank Univr sity Londo n Dtails of Rprsntation within th SPD, currnt policy namly; Policy 1.7 Dvlopmnt within Town and Local Cntrs and Policy 4.7 Non-Slf Containd Housing for Idntifid Usr Groups of th Southwark plan (July, 2007) and Stratgic Policy 8 Studnt Homs of th Southwark Cor Stratgy (April, 2011) allow for th provision of rsidntial dvlopmnt including studnt accommodation within local district and major town cntrs, including LSBU s campus 6.1. W ar gnrally supportiv of th SPDs Notd. approach to promoting high quality dsign. LSBU is committd to achiving a high quality nvironmnt with a divrs mixtur of uss, which is saf, stimulating and rinforcs local distinctivnss. Whil many of th principls in th SPD will hlp to achiv an activ, vibrant, and high quality nvironmnt thr ar som aras that could b strngthnd to prsnt and promot th highst quality of dsign, as st out blow 6.2. W ar gnrally supportiv of th building hights stratgy in th draft SPD, spcifically th provisions to nsur high quality dsign and th idntification of St. Gorg s Circus as a suitabl location for a tall building. Howvr, w would lik furthr clarification in rlation to th capacity for tall buildings at St. Gorg s Circus, for xampl whthr it is nvisagd as a singl tall building or a clustr of tall buildings. It would also b bnficial in trms of dsign to includ rcognition and promotion of th rol tall buildings and public ralm nhancmnts in signalling stratgic gatways and contributing to townscap lgibility and wayfinding. As such w hav suggstd th following amndmnts (undrlind): 6.2.a. Amndmnt to txt: Ths landmarks will highlight th importanc of Blackfriars Road as a Officr Rspons to Rprsntation adquatly. This includs policis in th Cor Stratgy and savd Southwark Plan and SPDs on affordabl housing and rsidntial dsign standards. As rfrrd to within th rprsntation xisting policis xist for studnt accommodation. W hav also insrtd a nw appndix (appndix A) listing th ky borough wid Southwark planning policis and supplmntary planning guidanc to mak it clarr that ths policis nd to b rad alongsid th Blackfriars Road SPD. Sction 1 of th SPD has bn updatd to rfr to this nw appndix. Notd. No chang.

68 Rp Obj Rf Rf Nam 635 c/o Agnt 635 c/o Agnt 635 c/o Agnt 635 c/o Agnt South Bank Univr sity Londo n South Bank Univr sity Londo n South Bank Univr sity Londo n South Bank Univr sity Londo n South Bank Univr sity Dtails of Rprsntation gatway to Southwark and crat nw focal points at main transport nods and th junction btwn Blackfriars Road and Elphant and castl, contributing to a mor lgibl nvironmnt. Building hights, p. 27. Officr Rspons to Rprsntation 6.2.b. Additional bullt point: Tall buildings should b No chang. This is broadly notd within th SPD 5 alrady. promotd at stratgic gatways as shown in figur 6. - Building hights, p. 27. (plas s Appndix B for a mark-up of figur 6 to includ stratgic gatways). 6.2.c. Additional bullt point: At stratgic gatway locations us public opn spac to announc a point of arrival and grss. Public ralm and opn spac stratgy, p Viws along th Thams and th Blackfriars Road corridor mak a significant contribution to th charactr of Blackfriars Road and as a rsult w rqust that guidanc sks to protct ths viws, and suggst th following amndmnts (undrlind): 6.3.a. Amndmnt to txt: Dmonstrat a considrd rlationship with othr tall buildings and building hights in th immdiat contxt in viws, including viws along th Rivr Thams and th Blackfriars Road Corridor. Building hights, p.28 No chang. Th locations ar acknowldgd within th txt. Amndmnt has bn mad to support considration of linar viws along Blackfriars Road. SPD 5 has bn updatd accordingly In gnral w support th public ralm and opn Notd. No chang. Th locations ar acknowldgd within th xisting spac stratgy includd within th draft SPD. LSBU is txt. committd to contributing positivly to th widr stting of Blackfriars Road by crating a campus for studnts and th local community. Thr ar a numbr of opportunitis to furthr improv th potntial of th public ralm and w thrfor propos th following amndmnts to figur 6 in accordanc with th mark

69 Rp Obj Rf Rf Nam 635 c/o Agnt 635 c/o Agnt 635 c/o Agnt Londo n South Bank Univr sity Londo n South Bank Univr sity Londo n South Bank Univr sity Dtails of Rprsntation up providd in Appndix B, to rflct ths opportunitis and th suggstd amndmnts to th SPD boundary: 6.4.a. Mark on stratgic gatway locations at St. Gorg s Circus and to th north of Blackfriars Road to rinforc thir importanc of its ky gatways 6.4.b. Includ a principl for improvd pdstrian links along Thomas Doyl Strt and Kyworth Strt to incras prmability and hlp to intgrat LSBU s Campus into its stting W support th approach of th SPD to ncourag pdstrian orintatd and humanistic nvironmnts to gnrat a rang of activitis and rcognis th rol activity plays in rinforcing charactr, crating vibrancy and aiding scurity. Howvr, it is also important to crat activity both during th day and night. Thrfor w suggst th following amndmnt (undrlind): 6.5.a. Amndmnt to txt: Contribut to th cration of a sns of plac and ncourag a varity of activity which supports us during day and night tim. - SPD 3 Public ralm and opn spac stratgy, p W support th additional principls laid out for St. Gorg s Circus and its importanc as a public spac and ky nod conncting Elphant and Castl and th City. Th Circus currntly lacks activ frontags and instad is bound by larg inactiv facads. Thr is a nd to promot public ralm improvmnts with activ frontags to improv th stting and stablish it as a dstination in its own right, as such w rcommnd th following amndmnt (undrlind): 6.6.a. Amndmnt to txt: Incras th amount of Officr Rspons to Rprsntation Th council will continu to look at routs and connctions across th borough. Allis and Morrison ar working with LSBU to look at prmability in th ara and any dsigns that com forward will b in lin with Southwark policis and will thrfor do not rquir chang to this documnt. Furthrmor SPD 3: Public ralm and opn spac alrady rfrs to nding to ncourag movmnts and intgrating Blackfriars Road with th surrounding strts and aras. No chang, as th commitmnt to strt activity is alrady covrd in th SPD. No chang. This guidanc is alrady covrd in SPD 3.

70 Rp Obj Rf Rf Nam 635 c/o Agnt 635 c/o Agnt 635 c/o Agnt Londo n South Bank Univr sity Londo n South Bank Univr sity Londo n South Bank Univr sity Dtails of Rprsntation usabl pdstrian spac around th primtr and at th cntr of th Circus, supportd by activ frontags to bring vibrancy to th strt scn and promot th Circus as a dstination. SPD 3 Public ralm and opn spac stratgy, p. 20 Officr Rspons to Rprsntation 6.7. W rcognis th valu of tr planting and No chang. Fasibility would b assssd at th planning application support th proposals for th cration of grn stag linkags, including rinforcing th boulvard charactr along Borough Road, Blackfriars Road and London Road. Planting should howvr b subjct to fasibility for xampl in rlation to xisting utilitis. Thrfor w suggst th following amndmnts (undrlind): 6.7.a. Amndmnt to txt: Us trs and landscaping to grn strts and spacs and rinforc planting whr trs ar intgral to th historic townscap charactr whr appropriat and fasibl. SPD 3 Public ralm and opn spac stratgy, p b. Amndmnt to txt: Thr ar a numbr of historic trs that ar protctd. W will rquir nw strt trs and th rinforcmnt of planting trs whr thy ar intgral to th historic charactr, such as thos on Blackfriars Road, whr appropriat and fasibl. SPD 3 Public ralm and opn spac stratgy, p. 22 No chang. Fasibility would b assssd at th planning application stag W support th focus of th SPD to consrv and W hav updatd SPD 4 so that matrials and faturs considr th nhanc hritag assts and nsur that high quality idntity of th surroundings, taking th local historic nvironmnt into dsign and architctur mak a positiv contribution to considration. Dtaild dsign would b assssd at th planning local charactr and distinctivnss. Th SPD should application stag. howvr, also b flxibl to allow contmporary dsign whr it is snsitiv to and rspcts th xisting vrnacular, As such w propos th following amndmnt (undrlind): 6.8.a. Amndmnt to txt: Ensur that matrials and faturs rflct th idntity of th surroundings, taking th local historic nvironmnt into considration, whilst incorporating

71 Rp Obj Rf Rf Nam 635 c/o Agnt Londo n South Bank Univr sity Dtails of Rprsntation nw sustainabl and contmporary dsign that is snsitiv to and nhancs th historic stting. Draft Businss and Rtail Background Papr In addition to th abov suggstd amndmnts to th draft Blackfriars Road SPD, w would also lik to tak this opportunity to clarify th rol of LSBU with rgard to mploymnt activity statd in th Draft Businss and Rtail Background Papr (August, 2013). W provid th following statmnts for inclusion in that documnt on th univrsity s rol in local businss and ntrpris, and thir rol in providing social and community infrastructur: In many ways LSBU is configurd as an ngin for urban rgnration. Th univrsity s location, positiv approach to community ngagmnt, and support for local businss, offr considrabl dvlopmnt capacitis that support futur dvlopmnt in Southwark. Th univrsity has four facultis, ach with a strong vocational pdigr: Arts and Human Scincs; Businss Computing and Information Managmnt; Enginring, Scinc and th Built Environmnt; and Halth and Social Car. LSBU placs particular mphasis on prparation for mploymnt and, for studnts alrady in work (th univrsity has a high proportion of postgraduat, parttim, and profssional study), a focus on up to dat cours contnt immdiatly rlvant to today s work plac. Ovr 50% of studnts ar from SE London, and th univrsity clbrats a vry wid thnic and cultural mix (60% of studnts ar from thnic minoritis). Many studnts ar studying for profssional qualifications or highr dgrs, but th univrsity also works in partnrship with local schools and Furthr Education collgs to provid accss to highr ducation through Lvl 3 courss (A-lvl quivalnt). A high proportion of studnts ar matur (90% agd 20 or oldr), and th univrsity ncourags Officr Rspons to Rprsntation W hav includd amndmnts to th SPD Businss and Rtail background papr to highlight th rol of th univrsity in local businss and ntrpris.

72 Rp Obj Rf Rf Nam Colom bo Strt Colom bo Strt Colom bo Dtails of Rprsntation applications from studnts rturning to ducation with non-traditional qualifications (ovr 80% of studnts ntr th univrsity through this rout). Thr is a vry wid programm of courss, backd by nich rsarch (mainly applid) and links with businss. W hav to dat bn activ in commnting on th nw policy documnts publishd by th Council and in gnral w support th work th Council is undrtaking and fl that in du cours th Blackfriars Road SPD will bcom a usful and rspctd documnt. W wish to confirm our support for th ovrall vision for th ara. Howvr, thr ar a numbr of aras of w wish to ris, which w hav st out blow. Th first commnt rlats to Figur 5 / Tabl 1 and th list of potntial dvlopmnt sits. W wish to put forward th Colombo Strt sit, for mixd us rdvlopmnt. As it currntly stands th sit rprsnts a highly infficint us of land that is indfnsibl in light of currnt planning guidanc. A nw dvlopmnt could offr th opportunity for a win win outcom whrby nw, much ndd housing can b providd in a highly sustainabl mannr alongsid rplacmnt, upgradd community spac. Th London Plan is a strong advocat of this approach, pushing for th rdvlopmnt of this typ of sit to ncourag mor fficint us of land. Th Plan sks to nsur that dnsitis of dvlopmnt in appropriat locations b maximisd and ncourags rsidntial dvlopmnts such as this proposal. Givn this, w considr that Colombo Strt should b includd in th list of sits at Figur 5 and Tabl 1. Officr Rspons to Rprsntation Notd. Officr commnts ar st out in rspons to th dtaild commnts. Th appropriat figurs and tabl hav bn updatd to includ this sit. It is also important to not that th SPD is not allocating sits as proposals sits. Th allocation of proposals sits is don through a dvlopmnt plan documnt. Currnt dsignations for Blackfriars Road ar in th savd Southwark Plan (2007) which is currntly bing rviwd through th prparation of th Nw Southwark Plan. As part of this rviw w will b looking at whthr w should allocat mor and/or chang xisting proposals sits dsignations and updat th adoptd policis map. Full consultation will b carrid out on th Nw Southwark Plan in accordanc with our SCI and th rlvant rgulations. In trms of th rmaindr of th SPD, w would Th SPD sts out that it provids furthr guidanc to xisting planning qustion if thr should b a policy on rsidntial uss. policis in th Cor Stratgy and savd Southwark Plan. It dos not Th SPD covrs businss spac and town cntr rpat borough wid policis and th SPD must b rad alongsid

73 Rp Obj Rf Rf Nam Dtails of Rprsntation Strt uss, but almost fails to mntion rsidntial compltly. Thr can b no doubt that rsidntial uss will b coming forward on som sits within th SPD, so it sms strang thr is so littl rfrnc to thm. It may b considrd that th Cor Stratgy policis ar considrd to provid sufficint guidanc for rsidntial us. Howvr, if this is th cas, thn it would b hlpful if this could b mad clar, othrwis thr appars to b a gap within th documnt. 45 Colom bo Strt 45 Colom bo Strt W hav to dat bn activ in commnting on th nw policy documnts publishd by th Council and in gnral w support th work th Council is undrtaking and fl that in du cours th Blackfriars Road SPD will bcom a usful and rspctd documnt. W wish to confirm our support for th ovrall vision for th ara. Howvr, thr ar a numbr of aras of w wish to ris, which w hav st out blow. Th first commnt rlats to Figur 5 / Tabl 1 and th list of potntial dvlopmnt sits. 45 Colombo Strt sit is listd as sit 7, and w wish to support this allocation. As it currntly stands th sit rprsnts a highly infficint us of land that is indfnsibl in light of currnt planning guidanc. A nw dvlopmnt could offr th opportunity for a win win outcom Officr Rspons to Rprsntation othr planning documnts. Housing is not givn its own sction within th SPD bcaus th borough-wid housing policis and guidanc alrady covr housing adquatly. This includs policis in th Cor Stratgy and savd Southwark Plan and SPDs on affordabl housing and rsidntial dsign standards. Thr is nothing additional that nds furthr spcific guidanc for Blackfriars Road. Th vision alrady rfrs to housing dvlopmnt. Housing will b ncouragd on appropriat sits. In ordr to mak this clarr, w hav updatd SPD 2: Mixd us town cntr to includ rsidntial dvlopmnt as on of th uss to b ncouragd alongsid th provision of a mixtur of nw town cntr uss. Th fact box on town cntr uss has also bn updatd in accordanc with th National Planning Policy Framwork dfinition to mak it clar that rsidntial dvlopmnt is not a main town cntr us but it can play an important rol in nsuring th vitality of town cntrs. W hav also insrtd a nw appndix (appndix A) listing th ky borough wid Southwark planning policis and supplmntary planning guidanc to mak it clarr that ths policis nd to b rad alongsid th Blackfriars Road SPD. Sction 1 of th SPD has bn updatd to rfr to this nw appndix. Notd. Officr commnts ar providd for th dtaild rprsntations. Support notd. It is also important to not that th SPD is not allocating sits as proposals sits. Th allocation of proposals sits is don through a dvlopmnt plan documnt. Currnt dsignations for Blackfriars Road ar in th savd Southwark Plan (2007) which is currntly bing rviwd through th prparation of th Nw Southwark Plan. As part of this rviw w will b looking at whthr w should allocat mor and/or chang xisting proposals sits

74 Rp Obj Rf Rf Nam Dtails of Rprsntation whrby nw, much ndd housing can b providd in a highly sustainabl mannr alongsid rplacmnt, upgradd community spac. Th London Plan is a strong advocat of this approach, pushing for th rdvlopmnt of this typ of sit to ncourag mor fficint us of land. Th Plan sks to nsur that dnsitis of dvlopmnt in appropriat locations b maximisd and ncourags rsidntial dvlopmnts such as this proposal. Givn this, w support th inclusion of 45 Colombo Strt in th list of sits at Figur 5 and Tabl Eiln Conn In trms of Policy SPD 2, w also wlcom th rfrnc to support for th provision of nw social infrastructur and community facilitis as part of mixd us dvlopmnts Colom bo Strt 45 Colom bo Strt Figur 6 shows opportunity sits, but ths ar mor limitd than th dvlopmnt sits shown in Figur 5. W assum thy rlat to opportunity sits with a public ralm aspct, but would suggst th labl b changd to avoid confusion, prhaps to public ralm opportunity sits. In gnral trms w support th objctivs of Policy SPD 5 on Building Hights, but do qustion th scond bullt point undr th All tall buildings ovr 25 mtrs / 30 mtrs must.. sction. Clarly som sits ar largr than othrs, and thus abl to Officr Rspons to Rprsntation dsignations and updat th adoptd policis map. Full consultation will b carrid out on th Nw Southwark Plan in accordanc with our SCI and th rlvant rgulations. Support notd. W hav updatd th figur for consistncy and amndd th ky from opportunity sits to potntial dvlopmnt sits. Th SPD dos not dsignat proposals sits or provid sit spcific guidanc, as this would byond th scop of th SPD. It dos idntify potntial dvlopmnt sits which ar illustrativ of th hug opportunity for chang within th ara and th nd for a cohrnt framwork. Th SPD has also bn updatd to clarify that th list of sits is not xhaustiv and othr sits may com forward for dvlopmnt. Som of th sits will b compltly rdvlopd, whilst othr sits may xprinc lss chang such as rfurbishmnt or improvmnts to th xisting buildings or surroundings. Any dvlopmnt of th potntial dvlopmnt sits would b assssd and dtrmind at th planning application stag, taking into account local contxt, which includs th local hritag assts. Supportd notd. No chang to guidanc. Th siz of th sit would b a considration at th planning application stag, alongsid th hight of any proposd dvlopmnt.

75 Rp Obj Rf Rf Nam 45 Colom bo Strt Dtails of Rprsntation provid mor public spac. W would suggst that rfrnc to th siz of th sit is addd to th scond sntnc, as follows-..public spac should b proportionat to th hight of th building, th siz of th sit and th importanc of th location in th town cntr. In trms of th rmaindr of th SPD, w would qustion if thr should b a policy on rsidntial uss. Th SPD covrs businss spac and town cntr uss, but almost fails to mntion rsidntial compltly. Thr can b no doubt that rsidntial uss will b coming forward on som sits within th SPD, so it sms strang thr is so littl rfrnc to thm. It may b considrd that th Cor Stratgy policis ar considrd to provid sufficint guidanc for rsidntial us. Howvr, if this is th cas, thn it would b hlpful if this could b mad clar, othrwis thr appars to b a gap within th documnt. Officr Rspons to Rprsntation Th SPD sts out that it provids furthr guidanc to xisting planning policis in th Cor Stratgy and savd Southwark Plan. It dos not rpat borough wid policis and th SPD must b rad alongsid othr planning documnts. Housing is not givn its own sction within th SPD bcaus th borough-wid housing policis and guidanc alrady covr housing adquatly. This includs policis in th Cor Stratgy and savd Southwark Plan and SPDs on affordabl housing and rsidntial dsign standards. Th vision alrady rfrs to housing dvlopmnt. Housing will b ncouragd on appropriat sits. In ordr to mak this clarr, w hav updatd SPD 2: Mixd us town cntr to includ rsidntial dvlopmnt as on of th uss to b ncouragd alongsid th provision of a mixtur of nw town cntr uss. Th fact box on town cntr uss has also bn updatd in accordanc with th National Planning Policy Framwork dfinition to mak it clar that rsidntial dvlopmnt is not a main town cntr us but it can play an important rol in nsuring th vitality of town cntrs. W hav also insrtd a nw appndix (appndix A) listing th ky borough wid Southwark planning policis and supplmntary planning guidanc to mak it clarr that ths policis nd to b rad alongsid th Blackfriars Road SPD. Sction 1 of th SPD has bn updatd to rfr to this nw appndix William Waring I am xtrmly concrnd about building hights along Th dtaild guidanc outlind in SPD 5 and th xisting planning 2 0 th road having a ngativ impact on historic buildings policy framwork of dsign, hritag and tall building policis (th such as th Wbbr Row and Pabody Squar rlvant savd Southwark Plan policis, Cor Stratgy Policy SP12 stats. It sms lik it will b a giant Nw-York styl and th rlvant policis of th London Plan and th NPPF) would wind tunnl, which is not in kping with th hritag nsur appropriat dvlopmnt along Blackfriars Road.

76 Rp Obj Rf Rf Nam Dtails of Rprsntation natur of th ara. It will also impact on th light availabl to pdstrians William Waring I am also worrid that our tight-knit local community will b transformd into a district of offic blocks and sandwich shops that clos up at 4pm. It sms as if w will hav a hug tmporary population ris in th ara, straining all th local srvics, to th dtrimnt of th popl who liv hr William Waring It also sms as though too littl considration has bn givn to th vry valid concrns and worris of local rsidnts in a rushd consultation procss. I trust that th draft documnt givs som wight to local rsidnts who objct to th scal of th dvlopmnt. Officr Rspons to Rprsntation Th approach is supportd by our vidnc bas including th Blackfriars Road Urban Dsign Study which has bn prpard in accordanc with CABE and English Hritag Guidanc on Tall Buildings, Mattrs rgarding th impact of tall buildings would b assssd at th planning application stag through th rlvant savd Southwark Plan policis, Cor Stratgy Policy SP12 and th rlvant policis of th London Plan and othr planning guidanc. Bullt-point 14 of SPD 5 sts out furthr guidanc rgarding microclimat. Th SPD is intndd to bnfit a wid rang of groups including xisting and nw rsidnts. Th mrging vision has bn updatd to mak this clarr. Th SPD has also bn updatd within th supporting txt to SPD 2: Mixd us town cntr, that th SPD ara is mixd with both commrcial and rsidntial dvlopmnt. Th SPD, in particular SPD 2 sks to ncourag a rang of diffrnt town cntr uss as wll as businss uss to ncourag appropriat uss throughout and day and vning. Th SPD sks to mt th nds of rsidnts whilst also managing th prssur for nw dvlopmnt. Th SPD has bn updatd to mak it clarr that th mrging vision and th SPD sks to nsur that dvlopmnt mts th nds of xisting and nw rsidnts whilst also attracting nw dvlopmnt. Rsidnts will bnfit from th incras rang of uss including mor shops, srvics and businsss along th Blackfriars Road. A consultation rport has prpard alongsid th Blackfriars Road SPD. This sts out a summary of th rprsntations rcivd and how w hav takn ths into account in prparing th final vrsion of th SPD. Th appndics also st out all of th rprsntations rcivd and officr commnts on how ths commnts hav bn takn into account, and whthr th SPD has bn updatd as a rsult. Th SPD was consultd on in accordanc with th council's Statmnt of Community Involvmnt (SCI) (2008) and xcdd th consultation rquirmnts of both th SCI and th rlvant

77 Rp Obj Rf Rf Nam Ornda O'Brin Davis Ornda O'Brin Davis Ornda O'Brin Davis Dtails of Rprsntation 1. Building hights In 2009 th Tall Building Study carrid out by Southwark Council did not rcommnd any aras south of Th Cut as appropriat for tall buildings. But th draft SPD has a policy of ncouraging tall buildings all th way down to St Gorg's Circus. This mans buildings up to 30m (approx 10 storys high), plus a 70m (25 to 30 storys high) towr to b built on top of Southwark tub station and anothr 70m towr whr Erlang Hous is on Blackfriars Road (nar St Gorg's Circus). This hight of buildings will hav a big impact on how our local ara looks and fls. Som ky concrns ar: loss of light, wind tunnl ffct of tall buildings, loss of viws, and loss of privacy from bing ovrlookd. Officr Rspons to Rprsntation rgulations. Th consultation rport summariss th consultation carrid out. Th dtaild guidanc outlind in SPD 5 and th xisting planning policy framwork of dsign, hritag and tall building policis (th rlvant savd Southwark Plan policis, Cor Stratgy Policy SP12 and th rlvant policis of th London Plan and th NPPF) would nsur appropriat dvlopmnt along Blackfriars Road. Th approach is supportd by our vidnc bas including th Blackfriars Road Urban Dsign Study which has bn prpard in accordanc with CABE and English Hritag Guidanc on Tall Buildings, Mattrs rgarding th impact of tall buildings would b assssd at th planning application stag through th rlvant savd Southwark Plan policis, Cor Stratgy Policy SP12 and th rlvant policis of th London Plan and othr planning guidanc. Bullt-point 14 of SPD 5 sts out furthr guidanc rgarding microclimat. 2. Tim givn for th draft SPD consultation Th draft A consultation rport has prpard alongsid th Blackfriars Road SPD was announcd to th prss on 21 Jun 2013 SPD. This sts out a summary of th rprsntations rcivd and and on 24 July 2013 th Wbbr Row Estat rcivd how w hav takn ths into account in prparing th final vrsion of important laflts through th doors about th th SPD. Th appndics also st out all of th rprsntations consultation. So many popl alrady lost almost 5 rcivd and officr commnts on how ths commnts hav bn wks of th 12-wk consultation priod to think takn into account, and whthr th SPD has bn updatd as a about what is bing proposd. And now th dadlin is rsult. Th SPD was consultd on in accordanc with th council's almost hr. I would lik to s a much longr Statmnt of Community Involvmnt (SCI) (2008) and xcdd th consultation priod, with lots of xhibitions and consultation rquirmnts of both th SCI and th rlvant workshops for rsidnts and local businsss to mak rgulations. Th consultation rport summariss th consultation thir viws hard, just lik thr was for th Hygat carrid out. Estat rdvlopmnt. Thr ar in fact lots of rsidnts living in this ara, and w car about whr w liv. 3. Commrcial dvlopmnt and rsidnts Th draft SPD placs a rally big mphasis on commrcial dvlopmnt, tall buildings and mor hotls in th ara. Thr is almost no mntion of xisting rsidnts, Th SPD is intndd to bnfit a wid rang of groups including xisting and nw rsidnts. Th mrging vision has bn updatd to mak this clarr. Th SPD has also bn updatd within th supporting txt to SPD 2: Mixd us town cntr, that th SPD ara is

78 Rp Obj Rf Rf Nam Ornda O'Brin Davis Dtails of Rprsntation so th nds of our big and long-stablishd communitis, spcially south of Th Cut, hav not bn includd in th documnt. Thr is also vry littl clar provision for affordabl housing in th draft SPD. In trms of hotls, w alrady hav H10, Watrloo Road (13 storys, 177 rooms), Travlodg, Baron's Plac (5 storys, 279 rooms) and soon th Hilton, Watrloo Road (9 storys, 278 rooms), so w hav rally don our bit in accpting big hotls right on our doorstp, and Quntin Hous is now sandwichd btwn two hotls, th Travlodg and th Hilton. In announcing th draft SPD, Councillor Ptr John dscribd our ara as having "pockts of rsidntial" but prhaps a visit is ndd to our local ara as w ar much mor than just "pockts" it is our rsidntial communitis that mak up th ral charactr of this part of Southwark. 4. Small businsss I was disappointd whn in August of this yar, Southwark Council's planning committ votd by a majority of on to allow Ntwork Rail to rdvlop prmiss undr th archs at Union Strt. This mans that th small businsss which hav workd from ths prmiss for many yars will hav to lav bcaus th rnts will b too high. I was again vry disappointd whn last wk th planning committ again votd by a majority of on to approv th dmolition of th Imbib pub and St Gorg's Mansions (hom of th Blackfriars Caf for 20 yars, a dry clanrs and a nwsagnt) to mak way for Lindn Homs to build a tn-story block for larg businss spac, privat flats and a vry small amount of affordabl homs. Th London Plan and th Southwark Plan ar official policis which mak vry clar that local councils ar mant to mak sur that thr ar suitabl spacs for small businsss, but th rcnt bhaviour of Southwark Council is not mting Officr Rspons to Rprsntation mixd with both commrcial and rsidntial dvlopmnt. Th SPD sks to mt th nds of rsidnts whilst also managing th prssur for nw dvlopmnt. Th SPD has bn updatd to mak it clarr that th mrging vision and th SPD sks to nsur that dvlopmnt mts th nds of xisting and nw rsidnts whilst also attracting nw dvlopmnt. Rsidnts will bnfit from th incras rang of uss including mor shops, srvics and businsss along th Blackfriars Road. In lin with th Cor Stratgy, th SPD ncourags th provision of flxibly dsignd small businss spac. W hav amndd bullt 1 of SPD1 to includ ncouraging th provision of small and start-up businsss in th ara. Bullt 2 of SPD1 ritrats borough wid planning policy of rquiring th rtntion or rplacmnt of businss floorspac, and this will continu to b on of a numbr of prioritis for th council to nsur that th concntration of businss floorspac in th ara is maintaind or rplacd. In addition, th supporting txt outlins borough wid policy on small businss spac, including mploymnt spac availabl within th railway archs. Ths spacs can b usd for a varity of mploymnt opportunitis. W hav also addd additional rfrnc into th supporting txt rgarding th savd Southwark Plan Policy 1.5 in ordr to highlight that this policy aims to protct small businss units in proposals for rdvlopmnt or chang of us of mploymnt sits, by rquiring th quivalnt provision for small units within th rplacmnt floorspac, subjct to xcption critria. W hav also insrtd additional txt to bullt 1 of SPD2 to ncourag th flxibl

79 Rp Obj Rf Rf Nam Ornda O'Brin Davis Dtails of Rprsntation ths policis, so vn though th draft SPD talks about looking aftr small businsss, is this rally likly to happn? What ar th safguards for local businsss? 5. Facilitis Th local population in this ara is going to rally xplod with all of th proposd dvlopmnt. This mans that w will nd th following: schools, youth cntrs, nursris, playgrounds, opn spacs, GP surgris, halth cntrs, fir srvics, polic srvics, tc. But th draft SPD dosn't contain any dtail of how which of ths facilitis ar going to b providd, or whr, or whn. I'm rally worrid about this. Officr Rspons to Rprsntation dsign of nw unit sizs for nw town cntr us in nw mixd us dvlopmnt. Th assssmnt and dtail of th Lindn Homs planning application is availabl in th Planning Committ rport which is availabl in th link blow. WRAP&RIPNAME=Root.PgRsultDtail&ThSystmky= Th SPD and othr planning policy documnts provid th framwork for th provision of infrastructur to support dvlopmnt. Updats hav bn mad to th SPD to rfr mor to othr uss including halth and community facilitis. Updats hav bn mad to th SPD to rfr to ncouraging a rang of diffrnt uss. SPD 2: Mixd us town cntr sts out that w will support th provision of nw social infrastructur and community facilitis as part of mixd us dvlopmnts. SPD 3: Public ralm and opn spac rfrs to th continud protction of th thr protctd opn spacs and ncouraging furthr linkags and nw spacs. Sction 4 of th SPD rfrs spcifically to infrastructur, crossing rfrring to th community infrastructur lvy (CIL) and sction 106 planning obligations to hlp nsur th dlivry of ky infrastructur to mitigat th impact of dvlopmnt. Infrastructur is covrd within borough-wid planning documnts with th ovrarching policy 14 of th Cor Stratgy rcognising that nw dvlopmnt in th borough nds to b supportd by adquat infrastructur, including social, nvironmntal and physical infrastructur. Th borough s Infrastructur Plan, idntifis stratgic infrastructur which is ndd to support growth and dvlopmnt in th borough ovr th liftim of th Cor Stratgy ( ). Whr possibl it idntifis th cost of infrastructur to providd, any committd sourcs of funding which will b usd to dlivr it and th

80 Rp Obj Rf Rf Nam Ornda O'Brin Davis Ornda O'Brin Davis Dtails of Rprsntation Officr Rspons to Rprsntation organis rsponsibl. It also idntifis th funding gap i.. th gap btwn known commitmnts and th total cost of infrastructur rquird. Whn it is adoptd, Southwark s CIL will b usd to contribut towards bridging this funding gap. Funds armarkd for infrastructur in th Council s capital invstmnt programm also will hlp to improv infrastructur provision. Th council ar currntly prparing our draft community infrastructur charging schdul and an updatd sction 106 SPD. Adoption is plannd for It is appropriat to look at th provision of infrastructur at a borough-wid lvl through ths ddicatd documnts rathr than through th Blackfriars Road SPD 6. Historic buildings Th London Plan and th Th SPD sts out clar guidanc for hritag considrations which Southwark Plan ar official policis which mak vry sits within a widr hritag policy framwork such as th rlvant clar that local councils ar mant to try and consrv savd Southwark Plan policis, Cor Stratgy Policy SP12 and th and nhanc hritag whrvr possibl. But in our rlvant policis of th London Plan and th NPPF. As such, local ara thr is much mor of a tndncy to knock dvlopmnt would b assssd at th planning application stag down our historic buildings to mak room for big offic through th rlvant savd Southwark Plan policis blocks. This is what happnd in 2010 whn th lovly Victorian warhous at 1 Valntin Plac was knockd down. And now w ar going to also los th historic Imbib pub and th Victorian St Gorg's Mansions nxt to it in ordr to mak way for th Lindn Homs nw 10-story block which is just yt anothr modrn building with no distinctiv charactr. 7. Potntial dvlopmnt sits On of th most disturbing aspcts of th draft SPD is th list of 46 potntial dvlopmnt sits. Thr ar no dtails about which buildings ths ar or what thy ar usd for at th momnt. My nighbour wnt through th whol list and has lt m know hr findings. Sh was horrifid to s that lots of ths ar bautiful buildings, som from historic tims and som modrn builds. Thy all look good and ar bing usd as small businss spac and/or rsidntial accommodation. Th figur and tabl within th SPD shows potntial dvlopmnt sits. Ths sits ar idntifid by officrs as sits with th potntial for som chang to th building or its surroundings. Som of th sits hav planning prmission, som ar undr construction, som ar going through th planning procss, and som hav no known plans as yt. Th list and figur has bn updatd following consultation to tak into account suggstions from land ownrs and rsidnts. Furthr wording has also bn addd to th SPD to mak it clar that

81 Rp Obj Rf Rf Nam Dtails of Rprsntation Evn Bridghous Court (whr th suprmarkt is on th cornr of Wbbr Strt and Blackfriars Road) has bn armarkd as a dvlopmnt sit what is wrong with this building as it is now? Is this whr Southwark Council is mayb thinking of building on of its tall buildings? On th original list was vn includd Block T of Pabody Squar on Blackfriars Road but it is a Grad II listd building! Th plannrs latr said this had bn a mistak, but I am worrid about how could thy gt it so wrong. Do thy not hav nough local knowldg to know about ach of ths 46 sits? Th plannrs hav vn includd th bautiful grn building at 209/215 Blackfriars Road on thir list. I would lik to s full dtails about vry on of thos 46 sits and to know why thy ar on this list and what th plans for dvlopmnt ar Nathan Phillips I'd lik provid on major point of fdback rlating to 2 2 th Blackfriars Road SPD, namly that th prsumption of 70m buildings at St Gorg's circus dos not appar wll vidncd, appropriat to th obvious smooth trajctory of th strt from high to low ris, or in th intrst of local rsidnts. Th prsumption of 30m construction along th southrn half of th strt appars ntirly valid for th full strtch south of Southwark tub, inclusiv of ky junctions- as vidncd by th succss of th Palstra building and studnt accommodation on th wstrly sid of St Gorg's circus. I vry much hop this viw can b takn into account Officr Rspons to Rprsntation th list of sits is not xhaustiv and that whilst som of th sits will b compltly rdvlopd othr sits might xprinc lss chang such as rfurbishmnt or improvmnts to th xisting buildings or surroundings. Th SPD is not allocating sits as proposals sits and so dos not provid policis on th land uss within ach of th sits. Th allocation of proposals sits is don through a dvlopmnt plan documnt. Currnt dsignations for Blackfriars Road ar in th savd Southwark Plan (2007) which is currntly bing rviwd through th prparation of th Nw Southwark Plan. As part of this rviw w will b looking at whthr w should allocat mor and/or chang xisting proposals sits dsignations and updat th adoptd policis map. Full consultation will b carrid out on th Nw Southwark Plan in accordanc with our SCI and th rlvant rgulations. Block T was a naming rror on th figur, and has bn updatd in th final SPD. Notd support for th proposd hight thrshold of 30m along th southrn sction of Blackfriars Road. A tall building up to 70m in hight could b appropriat at th southrn nd of Blackfriars Road providd that it complis with th dtaild guidanc outlind in SPD 5 and th currnt dvlopmnt plan that includs th rlvant policis of th savd Southwark Plan (2007), Cor Stratgy (2011), London Plan (2011) and othr planning documnts/guidanc, including th NPPF (2012). Th dvlopmnt plan sts out th policis for tall buildings. Th guidanc in th SPD provids dtail on how to implmnt ths dvlopmnt plan policis spcific to Blackfriars Road. Th approach is supportd by our vidnc bas including th Blackfriars Road Urban Dsign Study which has bn prpard in accordanc with CABE and English Hritag Guidanc on Tall Buildings, In light of consultation rsponss and to add clarity to th guidanc rlating to St Gorg s Circus in SPD 5, th SPD has

82 Rp Obj Rf Rf Nam Dtails of Rprsntation Sam Wst I am writing to objct to aspcts of th draft Blackfriars 3 3 Road Supplmntary Planning Documnt. I am a rsidnt of Gladston Strt, bordring on th ara undr discussion, and a mmbr of our rsidnts association, th Albrt Association. I am vry supportiv of dvlopmnt in th ara howvr thr ar a coupl of aspcts of th SPD that I objct to: 1: Provision for a towr block 70 mtrs high at St Gorg s Circus 2: Th dsignation of th Bakrloo sidings sit (which is immdiatly bhind Gladston Strt) as a potntial dvlopmnt sit. During consultation w hav bn informd that no particular nd us is nvisagd for any of th sits dsignatd for dvlopmnt. Whr is th justification for ignoring th suitability of particular sits of th dsignatd aras for any particular form of dvlopmnt, givn th snsitiv natur of th hritag contxt? Officr Rspons to Rprsntation bn updatd to clarify that a tall building could provid a focal point at th southrn nd of Blackfriars Road up to 70ms. A tall building should also sustain, nhanc or bttr rval th local hritag assts. A tall building up to 70m in hight could b appropriat at th southrn nd of Blackfriars Road providd that it complis with th dtaild guidanc outlind in SPD 5 and th currnt dvlopmnt plan that includs th rlvant policis of th savd Southwark Plan (2007), Cor Stratgy (2011), London Plan (2011) and othr planning documnts/guidanc, including th NPPF (2012). Th dvlopmnt plan sts out th policis for tall buildings. Th guidanc in th SPD provids dtail on how to implmnt ths dvlopmnt plan policis spcific to Blackfriars Road. Th approach is supportd by our vidnc bas including th Blackfriars Road Urban Dsign Study which has bn prpard in accordanc with CABE and English Hritag Guidanc on Tall Buildings, In light of consultation rsponss and to add clarity to th guidanc rlating to St Gorg s Circus in SPD 5, th SPD has bn updatd to clarify that a tall building could provid a focal point at th southrn nd of Blackfriars Road up to 70ms. A tall building should also sustain, nhanc or bttr rval th local hritag assts. Th TfL Bakrloo sidings sit (Sit 43 in Figur 5/Tabl 1 in th draft SPD, but r-numbrd as Sit 47 in Figur 6/Tabl1 in th updatd SPD) has bn includd as a potntial dvlopmnt sit, du to its rcognisabl dvlopmnt potntial. Any dvlopmnt at th sit would b assssd and dtrmind at th planning application stag, taking th local hritag contxt into account. Th SPD stats that list of potntial dvlopmnt sits is illustrativ of th hug opportunity for chang within th ara and th nd for a cohrnt framwork. It has also bn updatd to clarify that th list of sits is not xhaustiv and othr sits may com forward for dvlopmnt. Som of th sits will b compltly rdvlopd, whilst othr sits may xprinc lss chang such as rfurbishmnt or improvmnts to th xisting buildings or surroundings. Th formal idntification of proposals sits within th ara will b considrd as part of th prparation of th Nw

83 Rp Obj Rf Rf Nam Dtails of Rprsntation Sam Wst Boundary Dvlopmnt Sit 43 Th Bakrloo Sidings. 4 3 Any dvlopmnt on this sit will intrfr with long viws into th Wst Squar Consrvation Ara valud by Southwark Planning. What considration has bn givn to ths in th prparation of this SPD? What is th vidnc to support its suitability as a dvlopmnt sit as opposd to ducational, opn spac or othr us? Any building on this sit will advrsly affct th stting of hritag assts. Th Elphant & Castl Entrpris Ara SPD mntiond a landmark building. Rfrnc to any such building on this sit dply concrning givn th proximity not only to our own listd houss but also th listd oblisk, St Gorg s RC Cathdral and Imprial War Musum, th lattr two bing th landmark buildings in this location. How ar ths proposals affctd by th Blackfriars Road SPD? Sam Wst Stratgic viws St Gorg s Circus is a fin xampl of 5 3 Gorgian town planning with its focal point at its cntr, th Grad 2* listd oblisk. SPD 5 Building Hights proposs a tall building of hight up to 70 mtrs should provid a focal point at St Gorg s Circus. A tall building will affct th stting of not only th oblisk, an important hritag asst, but also th listd Gorgian trracs in London Road. Plas dmonstrat undr London Plan CDR1 how tall building dvlopmnt, a fundamntal chang in architctur, will not advrsly affct th local charactr. Whr is th comprhnsiv urban dsign analysis of th local charactr and historic contxt? (CABE and English Hritag Guidanc on Tall Buildings CDN25) Dvlopmnt sits 39, 40, 41 and Southwark Plan. Officr Rspons to Rprsntation Th TfL Bakrloo sidings sit (Sit 43 in Figur 5/Tabl 1 in th draft SPD, but r-numbrd as Sit 47 in Figur 6/Tabl1 in th updatd SPD) has bn includd as a potntial dvlopmnt sit, du to its rcognisabl dvlopmnt potntial. Any dvlopmnt at th sit would b assssd and dtrmind at th planning application stag, taking th local hritag contxt into account. Th SPD stats that list of potntial dvlopmnt sits is illustrativ of th hug opportunity for chang within th ara and th nd for a cohrnt framwork. It has also bn updatd to clarify that th list of sits is not xhaustiv and othr sits may com forward for dvlopmnt. Som of th sits will b compltly rdvlopd, whilst othr sits may xprinc lss chang such as rfurbishmnt or improvmnts to th xisting buildings or surroundings. Th formal idntification of proposals sits within th ara will b considrd as part of th prparation of th Nw Southwark Plan. Th impact of dvlopmnt is assssd at th planning application stag and would hav to comply with th guidanc st out in th SPD and widr policy framwork. A tall building up to 70m in hight could b appropriat at th southrn nd of Blackfriars Road providd that it complis with th dtaild guidanc outlind in SPD 5 and th currnt dvlopmnt plan that includs th rlvant policis of th savd Southwark Plan (2007), Cor Stratgy (2011), London Plan (2011) and othr planning documnts/guidanc, including th NPPF (2012). Th dvlopmnt plan sts out th policis for tall buildings. Th guidanc in th SPD provids dtail on how to implmnt ths dvlopmnt plan policis spcific to Blackfriars Road. Th approach is supportd by our vidnc bas including th Blackfriars Road Urban Dsign Study which has bn prpard in accordanc with CABE and English Hritag Guidanc on Tall Buildings, In light of consultation rsponss and to add clarity to th guidanc rlating to St Gorg s Circus in SPD 5, th SPD has

84 Rp Obj Rf Rf Nam Dtails of Rprsntation 43 dirctly affct th Circus and othr hritag assts. Council officrs hav statd that tall buildings at St Gorg s Circus would not b a conflict with th adjoining hritag assts. Whr is th vidnc that this is not a conflict? In dtrmining tall building hight limits within th SPD of 70 mtrs, whr is th assssmnt of thr dimnsional modlling to dtrmin th potntial ffct on th local contxt? (CABE and English Hritag Guidanc on Tall Buildings CDN25) Officr Rspons to Rprsntation bn updatd to clarify that a tall building could provid a focal point at th southrn nd of Blackfriars Road up to 70ms. A tall building should also sustain, nhanc or bttr rval th local hritag assts. Th GLA s rprsntation confirms that th Mayor supports th council s approach on tall buildings, but suggsts that th SPD should b mor flxibl in rlation to building hights, and that buildings in th rgion of 70/30m would b appropriat. Th council disagrs with this proposd amndmnt as it could allow buildings that ar gratr than th 70m/30m thrshold, which would b considrd inappropriat basd on our vidnc bas. As such, th council considrs SPD 5 to balanc local charactr and dvlopmnt potntial Sam Wst No mntion is mad of nvironmntal impact assssmnts, wind and daylight modlling, which ar fundamntal rquirmnts in considring proposals of this natur, particularly considring th difficultis with th Palstra and Walki Talki buildings Sam Wst Why has Wst Squar Consrvation Ara not bn 7 3 mntiond in SPD4 and SPD5? Th tall buildings proposd affct th stting of this Consrvation Ara and its Listd Buildings. Th SPD dos not dsignat proposals sits or provid sit spcific guidanc, as this would byond th scop of th SPD. It dos idntify potntial dvlopmnt sits which ar illustrativ of th hug opportunity for chang within th ara and th nd for a cohrnt framwork. Th SPD has also bn updatd to clarify that th list of sits is not xhaustiv and othr sits may com forward for dvlopmnt. Som of th sits will b compltly rdvlopd, whilst othr sits may xprinc lss chang such as rfurbishmnt or improvmnts to th xisting buildings or surroundings. Any dvlopmnt of th potntial dvlopmnt sits would b assssd and dtrmind at th planning application stag, taking into account local contxt, which includs th local hritag assts. Ths mattrs would b assssd at th planning application stag through th rlvant savd Southwark Plan policis, Cor Stratgy Policy 12 and th rlvant policis of th London Plan and othr planning guidanc. Bullt-point 14 of SPD 5 sts out furthr guidanc rgarding microclimat Th Wst Squar consrvation ara is situatd outsid th Blackfriars Road SPD ara. It would still b considrd as a hritag asst in rlation to th guidanc st out in SPD 3, 4 and 5. Any dvlopmnt proposal would b assssd at th planning application stag against

85 Rp Obj Rf Rf Nam Dtails of Rprsntation Officr Rspons to Rprsntation th rlvant savd Southwark Plan policis, Cor Stratgy Policy 12 and th rlvant policis of th London Plan and othr planning guidanc Sam Wst Th Council s Cor Stratgy 2010 dos not support tall Th policy approach within th SPD is considrd to b consistnt 8 3 buildings in Blackfriars Road South, as thy do not with th NPPF (2012), th London Plan (2011), th Cor Stratgy mt th critria for vision vibrancy and lif. Why (2011) and th savd Southwark Plan (2007), taking into account dos th Council s vision now diffr from th Cor changs in th surrounding contxt sinc dvloping th Cor Stratgy? Stratgy vision in 2009/2010. Th London Plan, Cor Stratgy and savd Southwark Plan form th dvlopmnt plan for Southwark, with th NPPF stting out national guidanc. Th dvlopmnt plan sts out th policis for tall buildings. Ky policis ar: London Plan policy 7.7 which idntifis that tall and largr buildings should gnrally b limitd to sits in th Cntral Activitis Zon, opportunity aras, aras of intnsification or town cntrs that hav good accss to public transport. Blackfriars Road lis within th Cntral Activitis Zon, is an opportunity ara and a town cntr with good accss to public transport. Cor Stratgy stratgic policy 12 rquirs tall buildings to hav an xmplary standard of dsign and idntifis locations whr tall buildings could go. Th Cor Stratgy vision for Banksid and Borough rfrs to th council stting out in dtail which sits ar appropriat, snsitiv and inappropriat for tall buildings through th supplmntary planning documnt/opportunity ara framwork. Savd Southwark Plan policy 3.20 sts out critria for considring applications for tall buildings and applis across th borough It should b notd that th GLSA is supportiv of th proposd building hights stratgy. Th GLA s rprsntation confirms that th Mayor supports th council s approach on tall buildings, but suggsts that th SPD should b mor flxibl in rlation to building hights, and that buildings in th rgion of 70/30m would b appropriat. Th council disagrs with this proposd amndmnt as it could allow buildings that ar gratr than th 70m/30m thrshold, which would b considrd inappropriat basd on our vidnc bas. As such, th council considrs SPD 5 to balanc local charactr and dvlopmnt potntial

86 Rp Obj Rf Rf Nam Dtails of Rprsntation Sam Wst In 2012 UNESCO notd in its convntion brifing papr that in April 2011 Southwark s Cor Stratgy includs an mphasis on hritag assts and rviss thir approach to tall buildings on th ara. Why has th council rngd on this? UNESCO s World Hritag Committ Rport Jun 2012 nots th intntion of Southwark Council to dvlop a Supplmntary Planning documnt to clarify how and whr dvlopmnt can tak plac and to dfin building hight thrsholds so as to inform th appropriatnss of subsqunt dvlopmnt proposals. Is this th said SPD? Polly Rossdal Polly Rossdal Building hights In 2009 th Tall Building Study carrid out by Southwark Council did not rcommnd any aras south of Th Cut as appropriat for tall buildings. But th draft SPD has a policy of ncouraging tall buildings all th way down to St Gorg's Circus. Thr ar likly to b knock-on dltrious ffcts such as loss of light, wind tunnl ffct of tall buildings, loss of viws, and loss of privacy (from bing ovrlookd). My own viws which currntly xtnd to Blackfriars Rd (from Wbbr St cornr) would b impactd and much of th plasing mixd charactr of th buildings (rsidntial flats, old warhous, rnovatd warhous, th Shard, nw offic block) would b lost. 2. Inadquat consultation tim. I only rcivd laflts about th consultation procss at th nd of July. This is insufficint tim for th community to considr such larg-scal plans. Officr Rspons to Rprsntation Th UNESCO papr rlats to th ara around London Bridg and th potntial impact of tall buildings on th stting of th Towr of London World Hritag Sit. Th hights proposd in th Blackfriars Road SPD building hights stratgy ar consistnt with Southwark s dvlopmnt plan consisting of th savd Southwark Plan polics, Cor Stratgy and th London Plan. Our tsting shows that th proposd hights would not impact th stting of th Towr of London sit. Th proposd 70m thrshold guidanc for th southrn of Blackfriars Road rsponds to th snsitivity to th Palac of Wstminstr World Hritag sit. Th guidanc st out within th SPD is consistnt with th xisting planning policy framwork of dsign, hritag and tall building policis, which includs th rlvant savd Southwark Plan policis, Cor Stratgy Policy SP12, th rlvant policis of th London Plan and th NPPF. Th guidanc proposd falls within th rmit of an SPD and dos not propos nw policy for th ara. Th approach is supportd by our vidnc bas including th Blackfriars Road Urban Dsign Study which has bn prpard in accordanc with CABE and English Hritag Guidanc on Tall Buildings, A consultation rport has prpard alongsid th Blackfriars Road SPD. This sts out a summary of th rprsntations rcivd and how w hav takn ths into account in prparing th final vrsion of th SPD. Th appndics also st out all of th rprsntations rcivd and officr commnts on how ths commnts hav bn takn into account, and whthr th SPD has bn updatd as a rsult. Th SPD was consultd on in accordanc with th council's Statmnt of Community Involvmnt (SCI) (2008) and xcdd th consultation rquirmnts of both th SCI and th rlvant

87 Rp Obj Rf Rf Nam Polly Rossdal 2 4 Dtails of Rprsntation 3. Insufficint considration givn to th impact on local rsidnc. Prioriti on larg scal Commrcial concrns ovr local rsidnts & small businsss. Existing rsidnts - who ar th hart of th currnt community - ar barly mntiond. Thr is also littl mntion of affordabl housing. As it stands thr is a ral risk that Blackfriars will simply b a soullss wastland - populatd by short trm visitors and chain cafs / shops who contribut littl socially, culturally or in long conomic trms. What fforts will b mad to nsur that Blackfriars Rd is not simply a long lin of Sainsbury s, Tsco s, at, prt a mangr tc tc? This ara dos not any mor of nd that. W nd ral community invstmnt - buildings that ar civic and not solly commrcial in natur. Thr should b joind up thinking with th South Bank's cultural zon - which could b xtndd down Blackfriars Rd. Othrwis thr is nothing lur visitors away from th South Bank to anothr row of idntikit shops and offics Officr Rspons to Rprsntation rgulations. Th consultation rport summariss th consultation carrid out. Th guidanc focuss primarily on Blackfriars Road, whr most of th chang will occur. This is mad clar within th SPD. This is st out in sction 1 of th SPD. Th mrging vision aspirs for Blackfriars Road to hav its own distinct idntity as a livly and vibrant ara, bcoming an xciting plac whr popl want to work, liv and visit. In trms of providing furthr guidanc on affordabl housing, th SPD provids furthr guidanc to xisting planning policis in th Cor Stratgy and savd Southwark Plan. It dos not rpat borough wid policis and th SPD must b rad alongsid othr planning documnts. Housing is not givn its own sction within th SPD bcaus th borough-wid housing policis and guidanc alrady covr housing adquatly. This includs policis in th Cor Stratgy and savd Southwark Plan and SPDs on affordabl housing and rsidntial dsign standards. SPD1 supports th provision of small businss floorspac, such as small offic/studio workshop spac, to hlp to provid appropriatly sizd modrn nw spac for crativ and cultural businsss to locat in th ara. SPD2 rcogniss thr is an opportunity to promot a much widr mix of town cntr uss as part of th dvlopmnt of th potntial sits idntifid in th SPD ara. This includs a rang of diffrnt typs and sizs of rtailrs. Th SPD cannot dsignat land us on potntial dvlopmnt sits, howvr w will considr th rang of uss that would b appropriat for dvlopmnt sits through th prparation of th Nw Southwark Plan. Th north of th SPD ara lis within th Stratgic Cultural Ara (Southbank/ Banksid/ London Bridg) which is a dsignatd ara rcognisd through planning policis in th London Plan and th Cor

88 Rp Obj Rf Rf Nam Polly Rossdal David Watkins on Grat r Londo n Authori ty Dtails of Rprsntation Officr Rspons to Rprsntation Stratgy. Th SPD2 guidanc ncourags th dvlopmnt of nw arts, cultural, lisur and ntrtainmnt uss in mixd us dvlopmnt throughout th ara to hlp consolidat this clustr of arts and cultural facilitis. Furthr dtail on th council s stratgy on rtail provision is st out in th SPD s businss and rtail background vidnc papr 4. Historic buildings Th London Plan and th Th SPD sts out clar guidanc for hritag considrations which Southwark Plan ar official policis which mak vry sits within a widr hritag policy framwork such as th rlvant clar that local councils ar mant to try and consrv savd Southwark Plan policis, Cor Stratgy Policy 12 and th and nhanc hritag whrvr possibl. But in our rlvant policis of th London Plan and th NPPF. As such, local ara thr is much mor of a tndncy to knock dvlopmnt would b assssd at th planning application stag down our historic buildings to mak room for big offic through th rlvant savd Southwark Plan policis blocks. This is what happnd in 2010 whn th lovly Victorian warhous at 1 Valntin Plac was knockd down. And now w ar going to also los th historic Imbib pub and th Victorian St Gorg's Mansions nxt to it in ordr to mak way for th Lindn Homs nw 10-story block which is just yt anothr modrn building with no distinctiv charactr. I would wlcom furthr dtaild information about th 46 potntial dvlopmnt sits mntiond in th SPD. Givn th Council's prior rcord on failur to protct historic buildings this is all th mor important. Thank you for consulting th Mayor of London on th draft stag of Blackfriars Road Supplmntary Planning Documnt (SPD). Th Mayor has affordd m dlgatd authority to mak commnts on his bhalf on mrging SPDs. Th GLA wlcoms th opportunity to considr th documnt at this draft stag. Ths commnts ar officr lvl only and do not prclud any furthr commnt th Mayor may mak on futur consultation phass of th Council s Local Dvlopmnt Framwork. Th SPD appars comprhnsiv and should prov to b a usful tool for both plannrs and prospctiv dvloprs Notd.

89 Rp Obj Rf Rf Nam 196 David Watkins on Grat r Londo n Authori ty Dtails of Rprsntation Th Mayor particularly supports Southwark Council s approach to tall buildings and its building hight stratgy in th Blackfriars ara. Howvr, SPD5 appars too prscriptiv in trms of building hights. In th Vauxhall Nin Elms Battrsa (VNEB) OAPF som hights wr limitd to avoid thm apparing in th Mayor s stratgic viws. As this is not th cas on Blackfriars Road, th Mayor would wlcom a mor flxibl approach to building hights and suggsts that th wording up to 70/30 mtrs is rplacd by in th rgion of 70/30mtrs. As statd in th SPD, it will b important to dmonstrat that th buildings contribut positivly to th London s skylin John Tolson 1. It's important to nsur that th SPD is consistnt 6 7 with th dsign principls arising from th Public Ralm Study and to tak full account of th public concrns that mrgd from that consultation procss John Tolson 2. Fulfilling th aims of th plan do not dpnd on th 7 7 construction of th two tall buildings at Southwark Station and St Gorg's Circus. Both ar quit out of scal and kping with th surrounding aras and thr is no magic about having "landmark" buildings at "ky nods". Th oblisk is alrady th ky landmark to th south and so to in its own way is th Palstra building at th station. I am not opposd to building on ithr sit but it nds to b of a scal and bulk to complmnt, not shout at, th xisting built nvironmnt. Any loss of offic and rsidntial spac is balancd by th xtnsiv dvlopmnt alrady taking pac and plannd on Blackfriars Road. Alrady w ar up to th Council's plannd capacity for hotl rooms rflcting this progrss. Officr Rspons to Rprsntation Minor changs hav bn mad to th wording of SPD5. Th approach is supportd by our vidnc bas including th Blackfriars Road Urban Dsign Study which has bn prpard in accordanc with CABE and English Hritag Guidanc on Tall Buildings This vidnc bas shows that hights that xcd thos outlind in th guidanc could b inappropriat. Th proposd amndmnt to In th rgion could allow gratr hights that may hav advrs impact. Th BBLB Charactri Study (2013) also informs this vidnc bas. Notd. Th SPD has bn updatd in light of th consultation. A tall building up to 70m in hight could b appropriat at th southrn nd of Blackfriars Road providd that it complis with th dtaild guidanc outlind in SPD 5 and th currnt dvlopmnt plan that includs th rlvant policis of th savd Southwark Plan (2007), Cor Stratgy (2011), London Plan (2011) and othr planning documnts/guidanc, including th NPPF (2012). Th dvlopmnt plan sts out th policis for tall buildings. Th guidanc in th SPD provids dtail on how to implmnt ths dvlopmnt plan policis spcific to Blackfriars Road. Th approach is supportd by our vidnc bas including th Blackfriars Road Urban Dsign Study which has bn prpard in accordanc with CABE and English Hritag Guidanc on Tall Buildings, In light of consultation rsponss and to add clarity to th guidanc rlating to St Gorg s Circus in SPD 5, th SPD has bn updatd to clarify that a tall building could provid a focal point at th southrn nd of Blackfriars Road up to 70m. A tall building should also sustain, nhanc or bttr rval th local hritag assts.

90 Rp Obj Rf Rf Nam Dtails of Rprsntation John Tolson 3. Dvlopmnt of local infrastructur and amnitis 8 7 must b includd in th plan on a scal to match th proposd dvlopmnt. This mans schools, doctors and dntists, childrn's play and othr opn aras (th xisting ons ar undr incrasing prssur) as wll as local rtail. Officr Rspons to Rprsntation Th SPD and othr planning policy documnts provid th framwork for th provision of infrastructur to support dvlopmnt. Updats hav bn mad to th SPD to rfr mor to othr uss including halth and community facilitis. SPD 2: Mixd us town cntr sts out that w will support th provision of nw social infrastructur and community facilitis as part of mixd us dvlopmnts. SPD 3: Public ralm and opn spac rfrs to th continud protction of th thr protctd opn spacs and ncouraging furthr linkags and nw spacs. Sction 4.4 of th SPD rfrs spcifically to infrastructur, crossing rfrring to th community infrastructur lvy (CIL) and sction 106 planning obligations to hlp nsur th dlivry of ky infrastructur to mitigat th impact of dvlopmnt. Infrastructur is covrd within borough-wid planning documnts with th ovrarching policy 14 of th Cor Stratgy rcognising that nw dvlopmnt in th borough nds to b supportd by adquat infrastructur, including social, nvironmntal and physical infrastructur. Th borough s Infrastructur Plan, idntifis stratgic infrastructur which is ndd to support growth and dvlopmnt in th borough ovr th liftim of th Cor Stratgy ( ). Whr possibl it idntifis th cost of infrastructur to providd, any committd sourcs of funding which will b usd to dlivr it and th organis rsponsibl. It also idntifis th funding gap i.. th gap btwn known commitmnts and th total cost of infrastructur rquird. Whn it is adoptd, Southwark s CIL will b usd to contribut towards bridging this funding gap. Funds armarkd for infrastructur in th Council s capital invstmnt programm also will hlp to improv infrastructur provision. Th council ar currntly prparing our draft community infrastructur charging schdul and an updatd sction 106 SPD. Adoption is plannd for It is appropriat to look at th provision of infrastructur at a borough-wid

91 Rp Obj Rf Rf Nam Dtails of Rprsntation Officr Rspons to Rprsntation lvl through ths ddicatd documnts rathr than through th Blackfriars Road SPD John Tolson 4. Propr attntion must b givn to th sid strts off SPD 4 and 5 sts out guidanc for th aras off Blackfriars Road. 9 7 Blackfriars Road. Ths aras should b highlightd as intgral to th plan's succss. Thy hav thir own charactr and will b a big attraction - hlping to draw nw popl to liv, work and njoy th ara and hnc ralising th vision. It follows that building hights must b significantly lowr than for Blackfriars Road to nhanc and prsrv this charactr and "hritag "assts in thir widst sns must b prsrvd Andrw Thomas 0 6 Quinn Whil I strongly support th council's aim of Th SPD 2 provids guidanc to support stratgic policy 10 Jobs and rdvloping th ara and crating a mixd us ara, I businss of th Cor Stratgy (2011) which sts out th council will qustion som of th mthods listd in th plan. In allow th dvlopmnt of hotls within th town cntrs, th stratgic particular, th mphasis on hotls in th plan as cultural aras, and placs with good accss to public transport crucial to rdvlopmnt is incorrct. Although th srvics, providing that ths do not harm th local charactr. This hotls hav providd som mixd us spac in th policy is also supplmntd by th savd policy 1.12 of th Southwark form of bars and rstaurants, I would ncourag th Plan which addrsss visitor accommodation. Nw hotl proposals will Council to survy usrs of thos spacs to s how b assssd against ths rlvant planning policis and a many of thm ar rsidnts or workrs in th ara and considration of th impact upon local amnity and th balanc of land Gratr London. In my xprinc, ths spacs ar uss will also b takn into account, including local mploymnt ntirly ignord by rsidnts/workrs in London, who ffcts. Th promotion of ancillary facilitis to b part of th dsign of instad tnd to patronis local or small businsss. hotl dvlopmnts will hlp to ncourag widr us of th building Furthrmor, givn that th ara is alrady on track to and contribut to th vibrancy of th ara. Th London Plan sks to mt its targt of 2,500 hotl rooms in advanc of th achiv 40,000 nt additional hotl bdrooms by 2031.Th stimat of 2026 dadlin, it sms pointlss for Southwark th approximat nt and gross hotl rooms rquird ovr th priod Council to ncourag th building of mor high quality for Southwark, as st out in th GLA s Hotl Dmand hotls. Study, is basd on assssmnt of factors including transport links to cntral London and connctions to airports, proximity of tourist attractions/businss locations, cafs and rstaurants in th ara, night tim conomy, cultural facilitis and attractions, and rgnration initiativs and sit availability. Th forcast for Southwark should b tratd as indicativ only, and local circumstancs should also b factord in. It is important to considr that th SPD ara is within th Cntral Activitis Zon, Banksid, Borough and London Bridg

92 Rp Obj Rf Rf Nam Andrw Thomas 1 6 Quinn Tanya Hasma 2 5 n Dtails of Rprsntation Officr Rspons to Rprsntation Opportunity Ara and part of th Elphant and Castl Opportunity Ara which ar aras promotd in th London Plan to accommodat stratgically important hotl provision. Arts, cultural and tourism activitis hav flourishd in Southwark in th last dcad, particularly in th Stratgic Cultural Ara, which is within th CAZ. Banksid, Borough and London Bridg has consquntly xprincd a growth in th numbr of hotls to support this incrasing visitor conomy. In addition, I would lik to s mor concrt Sinc th publication of th draft SPD it has bn announcd that TfL proposals on th dvlopmnt of bttr pdstrian and ar proposing to introduc a Cycl Suprhighway on Blackfriars Road. cycl facilitis on Blackfriars, givn som rcnt Th council support TfL's proposals to introduc a sgrgatd cycl accidnts that hav occurrd thr. I do apprciat th lan and th SPD has bn updatd to dmonstrat our support. TfL mphasis placd on cycling and pdstrian facilitis in hav advisd that a consultation will tak plac ovr summr th plan. Finally, as an urban plannr in th ara, SPD 6: Activ travl, sts out th aspirations to improv junctions plas lt m know if thr's any way I could along th strt spcifically Stamford Strt and St Gorg's circus contribut to th ara's rdvlopmnt. and will work with TfL to nsur a holistic approach whn dvloping dsigns for th cycl suprhighway that balanc th nds of all usrs and improv conditions and facilitis for pdstrians. Dvlopmnt Sit 43 Th Bakrloo Sidings 1. Any dvlopmnt on this sit will intrfr th hritag Wst Squar Consrvation Ara, prviously valud by Southwark Planning. What considration has bn givn to th natur and spcial charactristics of this ara in th prparation of this SPD? 2. What is th vidnc to support its suitability as a dvlopmnt sit as opposd to ducational, opn spac or othr us? 3. Any building on this sit is likly to advrsly affct th stting of hritag assts. Th Elphant & Castl Entrpris Ara SPD mntiond a landmark building. Tall buildings on this sit will affct th proximity not only to our own listd houss but also th listd oblisk, St Gorg's RC Cathdral and Imprial War Musum, th lattr two bing th landmark buildings in this location. 4. St Gorg's Circus and Tall Buildings. St Gorg's Circus is a fin xampl of Gorgian town planning with its focal point at its Th TfL Bakrloo sidings sit (Sit 43 in Figur 5/Tabl 1 in th draft SPD, but r-numbrd as Sit 47 in Figur 6/Tabl1 in th updatd SPD) has bn includd as a potntial dvlopmnt sit, du to its rcognisabl dvlopmnt potntial. Any dvlopmnt at th sit would b assssd and dtrmind at th planning application stag, taking into account local contxt, which includs th local hritag assts. Th SPD dos not dsignat proposals sits or provid sit spcific guidanc, as this would byond th scop of th SPD. It dos idntify potntial dvlopmnt sits which ar illustrativ of th hug opportunity for chang within th ara and th nd for a cohrnt framwork. Th SPD has also bn updatd to clarify that th list of sits is not xhaustiv and othr sits may com forward for dvlopmnt. Som of th sits will b compltly rdvlopd, whilst othr sits may xprinc lss chang such as rfurbishmnt or improvmnts to th xisting buildings or surroundings.

93 Rp Obj Rf Rf Nam Tanya Hasma 3 5 n Dtails of Rprsntation cntr, th Grad 2* listd oblisk. A tall building will affct th stting of not only th oblisk, an important hritag asst, but also th listd Gorgian trracs in London Road. 5. Dvlopmnt sits 39, 40, 41 and 43 dirctly affct th Circus and othr hritag assts. Council officrs hav statd that tall buildings at St Gorg's Circus would not b a conflict with th adjoining hritag assts. Whr is th vidnc that this is not a conflict? 6. Why ar hotls bing promotd (SPD 3.10) as viabl us whn Southwark has alrady achivd or is clos to achiving th rquirmnts. Th figurs for hotl rooms in th SPD mak it clar that, of th 2500 bdrooms rquird by th GLA's Hotl Dmand Study 2006 by 2026, all but 75 hav ithr bn built or ar in th piplin. Travl Officr Rspons to Rprsntation TfL, GLA and Ntwork Rail wr all consultd as part of th consultation procss. Th Blackfriars Road SPD consultation rport summariss all th rsponss rcivd and changs subsquntly mad to th SPD. Th full rprsntations rcivd from ths bodis and th council s rspons to thm is includd within Appndix J of th Blackfriars Road SPD consultation rport. Th Elphant and Castl SPD was adoptd on 20 March 2012 and rplacd th Elphant and Castl Entrpris Quartr SPD (2008) and th Walworth Road SPD (2008). Th Blackfriars Road SPD will rplac th Elphant and Castl SPD/OAPF guidanc for th ovrlapping aras. Th SPD has bn updatd to mak this clarr. Th London Plan sks to achiv 40,000 nt additional hotl bdrooms by 2031.Th stimat of th approximat nt and gross hotl rooms rquird ovr th priod for Southwark, as st out in th GLA s Hotl Dmand Study, is basd on assssmnt of factors including transport links to cntral London and connctions to airports, proximity of tourist attractions/businss locations, cafs and rstaurants in th ara, night tim conomy, cultural facilitis and attractions, and rgnration initiativs and sit availability. Th forcast for Southwark should b tratd as indicativ only, and local circumstancs should also b factord in. It is important to considr that th SPD ara is within th Cntral Activitis Zon, Banksid, Borough and London Bridg Opportunity Ara and part of th Elphant and Castl Opportunity Ara which ar aras promotd in th London Plan to accommodat stratgically important hotl provision. Arts, cultural and tourism activitis hav flourishd in Southwark in th last dcad, particularly in th Stratgic Cultural Ara, which is within th CAZ. Banksid, Borough and London Bridg has consquntly xprincd a growth in th numbr of hotls to support this incrasing visitor conomy. Th SPD2 provids guidanc to support Cor Stratgy policy 10 Jobs and businss which sts out th council will allow th dvlopmnt of hotls within th town cntrs, th stratgic cultural aras, and placs with good accss to public transport srvics, providing that ths do

94 Rp Obj Rf Rf Nam Tanya Hasma 4 5 n Tanya Hasma 5 5 n Tanya Hasma 6 5 n Dtails of Rprsntation 7. SPD6 givs no spcific information as Blackfriars Road falls undr th jurisdiction of TfL. Undr th Localism Act both TfL and Southwark Council ar duty bound to shar any consultation information rgarding activ travl. What plans hav bn proposd? 8. Why has Wst Squar Consrvation Ara not bn mntiond in SPD4 and SPD5? Th tall buildings proposd affct th stting of this Consrvation Ara and its Listd Buildings 9. This SPD has 1 Businss Spac, 2 Mixd Us Town Cntr, 3 Public Ralm and Opn Spac, 4 Built Form and Hritag, 5 Building Hights and 6 Activ Travl. It dos not hav a Stratgy or Guidanc for Housing. Why not? Officr Rspons to Rprsntation not harm th local charactr. Policy 10 and SPD 2 ar also supplmntd by th savd policy 1.12 of th Southwark Plan which addrsss visitor accommodation. Nw hotl proposals in th ara will b assssd against ths rlvant planning policis and a considration of th impact upon local amnity and th balanc of land uss will also b takn into account. Th txt within SPD 6 has bn updatd to clarify that Blackfriars Road falls undr th jurisdiction of TfL. A consultation rport has bn prpard summarising rsponss to th consultation on th draft Blackfriars Road SPD. All rsponss to th SPD consultation will b publishd on th Council's wbsit prior to th SPD bing takn to Cabint for adoption TfL hav now announcd that TfL ar proposing to introduc a Cycl Suprhighway on Blackfriars Road, with consultation proposd for summr Rsults of this consultation would b shard on TfL's wbsit. Th Wst Squar consrvation ara is situatd outsid th Blackfriars Road SPD ara. It would still b considrd as a hritag asst in rlation to th guidanc st out in SPD 3, 4 and 5. Th SPD sts out that it provids furthr guidanc to xisting planning policis in th Cor Stratgy and savd Southwark Plan. It dos not rpat borough wid policis and th SPD must b rad alongsid othr planning documnts. Housing is not givn its own sction within th SPD bcaus th borough-wid housing policis and guidanc alrady covr housing adquatly. This includs policis in th Cor Stratgy and savd Southwark Plan and SPDs on affordabl housing and rsidntial dsign standards. Th vision alrady rfrs to housing dvlopmnt. Housing will b ncouragd on appropriat sits. In ordr to mak this clarr, w hav updatd SPD 2: Mixd us town cntr to includ rsidntial dvlopmnt as on of th uss to b ncouragd alongsid th provision of a mixtur of nw town cntr uss. Th fact box on town cntr uss has also bn updatd in accordanc with th National

95 Rp Obj Rf Rf Nam Dtails of Rprsntation Officr Rspons to Rprsntation Planning Policy Framwork dfinition to mak it clar that rsidntial dvlopmnt is not a main town cntr us but it can play an important rol in nsuring th vitality of town cntrs Tanya Hasma 7 5 n CERE P Samps on Hous, CERE P Ludgat Hous Th Council's Cor Stratgy 2010 dos not support tall buildings in Blackfriars Road South, as thy do not mt th critria for 'vision vibrancy and lif'. Why dos th Council's vision now diffr from th Cor Stratgy? In 2012 UNESCO notd in its convntion brifing papr that in April 2011 Southwark's Cor Stratgy "includs an mphasis on hritag assts and rviss thir approach to tall buildings on th ara". Why has th council rngd on this? UNESCO's World Hritag Committ Rport Jun 2012 "nots th intntion of Southwark Council to dvlop a Supplmntary Planning documnt to clarify how and whr dvlopmnt can tak plac and to dfin building hight thrsholds so as to inform th appropriatnss of subsqunt dvlopmnt proposals". Gnrally, th draft SPD is wlcomd as stablishing Notd. th Borough s vision for th Ara, namly potntial for intnsification, high quality landmark buildings and th stratgic provision of offics and housing. Dtaild commnts ar providd blow which rlat to th nd for th Ara s dsignation as an Opportunity Ara (OA) to b rcognisd and, spcifically, for rsidntial dvlopmnt to b fully acknowldgd as a valuabl contributor towards th cration of mixd and sustainabl communitis. W hav also insrtd a nw appndix (appndix A) listing th ky borough wid Southwark planning policis and supplmntary planning guidanc to mak it clarr that ths policis nd to b rad alongsid th Blackfriars Road SPD. Sction 1 of th SPD has bn updatd to rfr to this nw appndix. Th UNESCO papr rlats to th ara around London Bridg and th potntial impact of tall buildings on th stting of th Towr of London World Hritag Sit. Th hights proposd in th Blackfriars Road SPD building hights stratgy ar consistnt with Southwark s dvlopmnt plan consisting of th savd Southwark Plan polics, Cor Stratgy and th London Plan. Our tsting shows that th proposd hights would not impact th stting of th Towr of London sit. Th proposd 70m thrshold guidanc for th southrn of Blackfriars Road rsponds to th snsitivity to th Palac of Wstminstr World Hritag sit.

96 Rp Obj Rf Rf Nam & Carlyl Ral Estat LLP CERE P Samps on Hous, CERE P Ludgat Hous & Carlyl Ral Estat LLP CERE P Samps on Hous, CERE P Ludgat Hous & Carlyl Ral Estat LLP Dtails of Rprsntation Boundaris of th SPD ara (pag 5) Figur 1 (pag 4) nots th location of svral Opportunity Aras (OAs) in Southwark, most significantly th Banksid, Borough and London Bridg OA which th whol of th Blackfriars Road SPD Ara falls within. Figur 2 nots both th Watrloo and Elphant and Castl OAs, howvr, thr is no indication of Banksid, Borough and London Bridg. An OA dsignation infrs that an Ara is affctd by a numbr of significant local and rgional policis rlating to appropriat land uss, dvlopmnt targts and lvls of intnsiv dvlopmnt. This discrpancy should thrfor b corrctd and th OA dsignation idntifid. Notd. Officr Rspons to Rprsntation Figur 1 shows th location of Blackfriars Road, and illustrats th surrounding opportunity aras at Watrloo and Elphant and Castl. It also shows th Banksid, Borough and London Bridg Opportunity Ara. Th Blackfriars Road SPD ara falls mostly within th Banksid, Borough and London Bridg Opportunity Ara with a small part lying within th Elphant and Castl Opportunity Ara. This is mad clar in th SPD - in figur 1 and in th txt. Figur 1 has bn updatd to show th ovrlapping boundaris mor clarly. Figur 2 simply shows th boundaris of th SPD ara. Th figur has bn updatd to rmov rfrnc to th opportunity aras to incras th focus on th actual boundary and to avoid any confusion.

97 Rp Obj Rf Rf Nam CERE P Samps on Hous, CERE P Ludgat Hous & Carlyl Ral Estat LLP CERE P Samps on Hous, CERE P Ludgat Hous & Carlyl Ral Estat LLP Dtails of Rprsntation Banksid and Borough (pag 9) Thr ar dvlopmnt opportunitis throughout th ara, but th largst dvlopmnts will b around Blackfriars Road and Banksid This is in lin with th currnt planning application which sks to rmov xisting barrirs to th rivr, improv th rlationship btwn th rivr and rivrsid buildings and maximis th significant capacity of this part of th OA for housing and commrcial dvlopmnt, improvmnts to th public ralm and accss to public transport. Blackfriars Road will continu to hav a mix of shops, srvics and offics srvicing both a local and widr nd. Thr is no rfrnc to th continud provision of housing hr although it is listd as on of th Aras strngths that should b dvlopd on pag 7 ( Thr is scop to dvlop th strngths of th Ara for stratgic offic provision as wll as housing ). It is suggstd that this sntnc is amndd to includ rsidntial uss within th mix of uss at Blackfriars Road. This commnt is also mad in rspct of pag 11 whr th sntnc is rpatd. Notd. Officr Rspons to Rprsntation Th SPD sts out that it provids furthr guidanc to xisting planning policis in th Cor Stratgy and savd Southwark Plan. It dos not rpat borough wid policis and th SPD must b rad alongsid othr planning documnts. Housing is not givn its own sction within th SPD bcaus th borough-wid housing policis and guidanc alrady covr housing adquatly. This includs policis in th Cor Stratgy and savd Southwark Plan and SPDs on affordabl housing and rsidntial dsign standards. Th vision alrady rfrs to housing dvlopmnt. Housing will b ncouragd on appropriat sits. In ordr to mak this clarr, w hav updatd SPD 2: Mixd us town cntr to includ rsidntial dvlopmnt as on of th uss to b ncouragd alongsid th provision of a mixtur of nw town cntr uss. Th fact box on town cntr uss has also bn updatd in accordanc with th National Planning Policy Framwork dfinition to mak it clar that rsidntial dvlopmnt is not a main town cntr us but it can play an important rol in nsuring th vitality of town cntrs. W hav also insrtd a nw appndix (appndix A) listing th ky borough wid Southwark planning policis and supplmntary

98 Rp Obj Rf Rf Nam CERE P Samps on Hous, CERE P Ludgat Hous & Carlyl Ral Estat LLP CERE P Samps on Hous, CERE P Ludgat Hous & Carlyl Ral Estat LLP Dtails of Rprsntation Thr will b a rang of building hights along Blackfriars Road, with th tallst buildings at th north nd of th road, signifying th gatway to Cntral London and th gatway to Southwark This aim is supportd and it is consistnt with othr local guidanc. Th Cor Stratgy rfrs to th northrn nd of Blackfriars Road as an Ara whr a tall building would b appropriat (Figur 12: Banksid, Borough and London Bridg, pag 41) and also confirms th draft Banksid, Borough and London Bridg SPD (2010) which rfrs to a clustr of tall buildings in this location and th uniqu opportunity thy provid to act as a stimulus for rgnration and boosting th local conomy. SPD 1 Businss spac (pag 14) W will ncourag th gnration of nw jobs and businsss in th Blackfriars Road ara to hlp consolidat and xpand th xisting businss srvic clustr and rinforc th ara as a stratgic offic mploymnt location Rquiring xisting businss floorspac (B1) to b rtaind or rplacd, unlss an xcption can b dmonstratd in accordanc with our borough wid mploymnt policis. Although stratgic offic uss in Blackfriars Road ar supportd w objct to this policy as it could ngativly impact on support for othr typs of dvlopmnt, namly rsidntial. This draft policy is not rflctiv of guidanc containd in th National Planning Policy Framwork, 2012 (NPPF) which stats that local planning authoritis should normally approv planning applications for chang to rsidntial us whr thr is an idntifid nd for additional housing Officr Rspons to Rprsntation planning guidanc to mak it clarr that ths policis nd to b rad alongsid th Blackfriars Road SPD. Sction 1 of th SPD has bn updatd to rfr to this nw appndix. Support notd. W do not considr th proposd chang to SPD 1 is appropriat. It is important for th SPD guidanc to b rad in conjunction with adoptd planning policy. Th Cor Stratgy sts out th borough s stratgy for housing and th targts ovr th plan priod, which includ th targt for th opportunity ara. W hav amndd SPD 2 to mak it clar that spac for town cntr uss should b dvlopd alongsid both rsidntial dvlopmnt and also businss uss. Th rquirmnt to rtain or rplac xisting businss spac is consistnt with borough-wid policis and is justifid by th council s vidnc bas which points to th nd to protct and intnsify mploymnt land and businss floorspac ovr th plan priod. Cor Stratgy policy 10 and savd Southwark Plan policy 1.4 rquir applicants to dmonstrat th loss of businss floorspac (B1, B2 and B8) against a rang of xcption critria whr th sit falls within a

99 Rp Obj Rf Rf Nam CERE P Dtails of Rprsntation providd that thr ar not strong conomic rasons why such dvlopmnt would b inappropriat (paragraph 51). Subsquntly, w do not considr that thr ar strong conomic rasons that indicat rsidntial uss within th Blackfriars Road SPD Ara would b inappropriat. Th SPD Ara also falls within th adoptd Cntral Activitis Zon (CAZ) as shown on Figur 1. Th associatd London Plan CAZ policis simply idntify offic floorspac as an appropriat land us (policis 2.10, 2.11 and 2.12) do not sk to protct or prioritis it. Th London Plan contains housing targts for all boroughs and supports incrasd housing dvlopmnt across London; Southwark s housing targt is to provid 20,050 nw dwllings in th priod 2011 to 2021 (Tabl 3.1) particularly in aras with high lvls of accssibility. Th prssing nd for additional housing in London is not acknowldgd by this draft policy nor is th gnral, widr nd to crat mixd and sustainabl communitis and dlivr a wid rang of high quality homs, as pr th NPPF. In addition, th Banksid, Borough and London Bridg OA has a targt of 1,900 nw homs which applis to th whol SPD Ara, this is furthr dvlopd by th London Plan which considrs OA targts to b a minimum to b xcdd. Th draft policy would thrfor b at last inconsistnt if not contrary to achiving ths targts. It is considrd that draft policy SPD 1 unduly constrains th dlivry of adoptd housing targts and is considrd to b contrary to adoptd policy. Th wording should thrfor b amndd to acknowldg that th loss of offic floorspac is accptabl whr it is rplacd by rsidntial floorspac, rathr than rquiring a cas to b mad against its rtntion. Fact box: Town cntr uss (pag 16) Rsidntial us is appropriat in town cntrs but is not a town cntr Officr Rspons to Rprsntation rang of locations, which includ (amongst othrs) th CAZ. Land outsid ths locations can b rlasd for othr uss. This stratgy nsurs th rtntion of xisting businss floorspac whr this is appropriat, to nsur thr continus to b spac availabl for stablishd businsss to mov into th ara and for start up businsss to stablish thmslvs. Th council considrs that it is rasonabl to xpct applicants to dmonstrat that in th aras whr businss floorspac is protctd that thr is a lack of dmand or viability, or physical and/or nvironmntal constraints which prclud r-provision or an uplift of mploymnt spac (s savd Southwark Plan Policy 1.4). It is considrd that this is consistnt with paragraphs 21 and 22 of th NPPF. Southwark CAZ was also xmptd from th govrnmnt s rcnt chang to th Gnral Prmittd Dvlopmnt Ordr to allow offic buildings to convrt to rsidntial. Th CAZ has bn rcognisd by th govrnmnt as bing a nationally significant ara of conomic activity. W also ncourag through our planning policis th dvlopmnt of othr mploymnt gnrating town cntr uss such as cultural/community, rtail and lisur to b providd alongsid B1 uss and rsidntial us. Rsidntial dvlopmnt can play an important rol in nsuring th vitality of town cntrs but is not a main town cntr us whn planning for comptitiv town cntrs that provid customr choic and a divrs offr and xprinc in th contxt of Southwark s planning policis. W will b considring dvlopmnt sit allocations through th prparation of th Nw Southwark Plan. Th SPD idntifis possibl dvlopmnt opportunitis, som of which may b complt rdvlopmnt, and som may b mor minor changs or improvmnts. W hav amndd th fact box to st out furthr clarification. Th dfinition of town cntr uss now rflcts th NPPF dfinition of main

100 Rp Obj Rf Rf Nam Samps on Hous, CERE P Ludgat Hous & Carlyl Ral Estat LLP CERE P Samps on Hous, CERE P Ludgat Hous & Carlyl Ral Estat LLP CERE P Samps on Hous, CERE P Dtails of Rprsntation us for th purpos of Southwark s Local Plan. This is not consistnt with th NPPF which stats that LPA s should rcognis that rsidntial dvlopmnt can play an important rol in nsuring th vitality of cntrs and st out policis to ncourag rsidntial dvlopmnt on appropriat sits (paragraph 23); w thrfor objct to this statmnt. SPD 3 Public ralm and opn spac (pag 19) Public ralm should: Provid and promot nw links that ar saf, dirct and convnint for pdstrians and cyclists Crat nvironmnts that ar inclusiv and follow Scurd by Dsign principls such as nsuring spacs ar wll lit, ovrlookd and fl saf at diffrnt tims of th day and in th vning. This is consistnt with th draft Banksid, Borough and London Bridg SPD (Fbruary 2010) which stats that nw dvlopmnt will b complmntd by major public ralm improvmnts that includ accss to and along th rivrsid and to and from Blackfriars station. SPD 5 Building hights (pag 27) Buildings which ar significantly highr than 50 mtrs must dmonstrat that thy contribut positivly to London s skylin, whn viwd locally and in mor distant viws, particularly on th rivr front and that thy mak xcptional contribution to th rgnration of th ara. All tall buildings ovr 25 mtrs / 30 mtrs Officr Rspons to Rprsntation town cntr uss. W hav also mad it mor clar within th fact box that whilst rsidntial dvlopmnt can play an important rol in nsuring th vitality of town cntrs, is not a main town cntr us whn planning for comptitiv town cntrs which nd to provid customr choic and a divrs rtail offr and xprinc in th contxt of Southwark s Local Plan. Support notd. Support notd.

101 Rp Obj Rf Rf Nam Ludgat Hous & Carlyl Ral Estat LLP CERE P Samps on Hous, CERE P Ludgat Hous & Carlyl Ral Estat LLP CERE P Samps on Hous, CERE P Ludgat Dtails of Rprsntation must: Dmonstrat an xmplary standard of dsign, provid high quality accommodation which significantly xcds minimum spac standards and promot housing choic by providing a mix of unit typs. Achiving high quality urban dsign is a ky planning objctiv throughout all lvls of policy and a ky drivr for th currnt proposals which ar locatd on th rivrsid and thrfor subjct to mor rigorous standards of dsign. This objctiv is thrfor supportd and th potntial for tall building and high quality architctur to act as a catalyst for widr rgnration is rcognisd. SPD 5 Building hights (pag 28) In addition to th abov critria, buildings which ar significantly highr than 70 mtrs must: Includ a publicly accssibl ara on uppr floors whr fasibl in th tallst buildings in th north of Blackfriars Road. This would b ovrly-prscriptiv; in particular thr ar scurity issus associatd with allowing accss to uppr floors which rquir considrabl managmnt. Th provision of such an ara would also impact significantly on th amount of usabl floorspac as a rsult of th nd to provid a ddicatd cor which would unduly constrain th final dsign. W thrfor objct to th proposd rquirmnt to provid public aras at uppr lvls. Officr Rspons to Rprsntation This rquirmnt is consistnt with London Plan 7.7. Th viability and fasibility of a publically accssibl spac would b assssd at planning application stag. Th SPD has bn updatd to chang th word "must" to "should". Building hights (pag 29, paragraph 3.33) Th No chang. Sit contxt and constraints would b assssd at amount of public spac at th bas of th building planning application stag should rlat to its hight Although thr is a rlationship btwn hight and th amount of public spac at th bas of a building this statmnt is qurid bcaus it is also affctd by othr factors such as th constraints of th sit and th contxt of surrounding buildings and public ralm. It is not always

102 Rp Obj Rf Rf Nam 443 Andrw Richard son 443 Andrw Richard son Hous & Carlyl Ral Estat LLP Banksi d Rsid nts Forum Banksi d Rsid nts Forum Dtails of Rprsntation possibl to provid a significant amount of public spac at th bas of a building, howvr, this may b consistnt with charactr of an ara or complmntd by opn spacs availabl narby. Th forum is disappointd that consultation on this important documnt has bn timd for th pak summr holiday priod and limitd to only ight wks. Notwithstanding:- 1. Quality of Lif Th SPD ara is mixd rsidntial and commrcial, with larg numbrs of visitors at th northrn nd. Th documnt maks littl or no mntion of th nds of xisting or futur rsidnts and barly acknowldgs thir xistnc. W do agr that a balancd mix of shops is ndd, with a varity of small indpndnt shops to b ncouragd. Th mphasis on th sitting of tall buildings dos not mntion factors such as wind tunnls, ovrshadowing and sound amplification which affct rsidnts both at hom and on th strt. Visitors ar hardly mntiond in th SPD and should b considrd as thir activitis imping on th lif of rsidnts, in trms of numbrs and night tim activitis in particular. Thr is a particular urgnt nd for th provision of public toilts and/or a community toilt schm. Officr Rspons to Rprsntation A consultation rport has prpard alongsid th Blackfriars Road SPD. This sts out a summary of th rprsntations rcivd and how w hav takn ths into account in prparing th final vrsion of th SPD. Th appndics also st out all of th rprsntations rcivd and officr commnts on how ths commnts hav bn takn into account, and whthr th SPD has bn updatd as a rsult. Th SPD was consultd on in accordanc with th council's Statmnt of Community Involvmnt (SCI) (2008) and xcdd th consultation rquirmnts of both th SCI and th rlvant rgulations. Th consultation rport summariss th consultation carrid out. Th SPD is intndd to bnfit a wid rang of groups including xisting and nw rsidnts. Th SPD has bn updatd to mak this clarr. Th vision has bn updatd. Th SPD has also bn updatd within th supporting txt to SPD 2: Mixd us town cntr, that th SPD ara is mixd with both commrcial and rsidntial dvlopmnt. Support notd r ncouraging a mixtur of shops. SPD 5: Building hights provids guidanc within th critria for tall buildings, including a bullt point on avoiding harmful microclimat and shadowing ffcts. Savd Southwark Plan policy 3.2 also nsur adquat protction of amnity. Visitors ar mntiond xplicitly in th supporting txt and guidanc in SPD 2 looking at ncouraging a mixd us town cntr. Savd Southwark Plan policy 1.7: Dvlopmnt

103 Rp Obj Rf Rf Nam 443 Andrw Richard son 443 Andrw Richard son 443 Andrw Richard son Banksi d Rsid nts Forum Banksi d Rsid nts Forum Banksi d Rsid nts Dtails of Rprsntation 2. Additional prssurs? Th SPD documnt spaks at lngth about incrasd commrcial dvlopmnt, notably B1 offic building and of hotls tc on many potntial sits but littl about th ffct of incrasd numbrs of popl passing through th ara or accssing facilitis. It fails to idntify sits for th nw or nlargd nursry schools, clinics, surgris, primary schools and othr community facilitis that will b rquird to srv th additional businss and rsidntial accommodation. W also not th significant amount of un-lt offic spac both locally and in th City, which dos not nhanc any strt or locality. 3. Complmnting th xisting nvironmnt? Although th Consrvation Aras and listd buildings ar shown on th maps th documnt is wak on idntifying and giving protction to historic and architctural buildings, and othr structurs of quality which giv th ara its charactr and intrst. Th consrvation and nhancmnt of th rmaining hritag buildings is not considrd. Thr is no list of buildings of particular intrst; w rcommnd on should b attachd to this documnt. In particular th businss uss of th railways archs and as both wst-ast and north-south routs could b faturd much mor strongly. Th historic nvironmnt of St Gorg s Circus is not givn du considration. 4. Maintnanc and managmnt High lvls of maintnanc and managmnt should b writtn in to vry planning application, spcially with rgard to dsign solutions to th nois issus rlating to sitting Officr Rspons to Rprsntation within town and local cntrs alrady sts th framwork to nsur proposals in town cntrs provid amnitis for usrs of th sit such as public toilts, whr appropriat. Th SPD supports adoptd planning policy and it provids furthr ara guidanc to hlp to dlivr and implmnt th ovrarching policis. It cannot allocat sits for dvlopmnt. W will b considring dvlopmnt sit allocations through th prparation of th Nw Southwark Plan. Th SPD idntifis possibl dvlopmnt opportunitis, som of which may b complt rdvlopmnt, and som may b mor minor changs or improvmnts Policy 14 of th Cor Stratgy rcogniss that nw dvlopmnt in th borough nds to b supportd by adquat infrastructur, including social, nvironmntal and physical infrastructur. Sction 4.4 of th SPD on infrastructur, sts out that much of th funding for infrastructur to support growth will b raisd through th Community Infrastructur Lvy, and sit spcific mitigation of dvlopmnt impacts will b scurd through sction 106 planning obligations. SPD4 is rad in conjunction with th xisting hritag policy framwork and dsignations. Guidanc and th idntification of buildings will b addrssd in a nw Hritag SPD that will b prpard alongsid th Nw Southwark Plan. Savd Southwark Plan policy 3.2 Protction of amnity, sts out that planning prmission will not b grantd whr it would caus loss of amnity, including disturbanc from nois, to prsnt and futur occupirs in th surrounding ara or on th application sit. Furthr

104 Rp Obj Rf Rf Nam 443 Andrw Richard son 443 Andrw Richard son Dtails of Rprsntation Forum of proposd housing on major transport routs as wll as nuisanc and nois arising from rfus collction from and srvicing of shops, bars, rstaurants, and othr lowr floor uss. Banksi d Rsid nts Forum Banksi d Rsid nts Forum 5. Long trm bnfit for Banksid? In th long trm Banksid should continu to hav a mixd rsidntial community, with all typs of housing provision availabl to support community lif and activity. Th currnt proposals, whil aspiring to build 1500 homs, mak no mntion of th provision of affordabl housing to nsur a social mix of popl, including th childrn of xisting familis who wish to continu to liv and work in thir hom ara. 6. Rlationship to highr lvl planning documnts. Planning and planning policy documnts ar undrstood to procd from th gnral to th particular, for obvious and sound rasons, and th highr lvl documnt taks prcdnc ovr th lowr lvl on, which should confin itslf to mor dtaild policy within th framwork of highr lvl on. Th lgal standing of this SPD documnt is thrfor unclar to us. W look forward to contributing to many aspcts of th nw Southwark Plan in du cours. Officr Rspons to Rprsntation guidanc is also st out in th Rsidntial Dsign Standards SPD, Sustainabl Transport SPD and th Sustainabl Dsign and Construction SPD. Frquntly planning conditions or sction 106 planning obligations ar rquird as part of a planning prmission to nsur minimal impact and whr appropriat to nsur construction managmnt plans. Th Blackfriars Road SPD also rfrs dirctly to rquiring construction managmnt plans in sction 4. Th SPD sts out that it provids furthr guidanc to xisting planning policis in th Cor Stratgy and savd Southwark Plan. It dos not rpat borough wid policis and th SPD must b rad alongsid othr planning documnts.. Housing is not givn its own sction within th SPD bcaus th borough-wid housing policis and guidanc alrady covr housing adquatly. This includs policis in th Cor Stratgy and savd Southwark Plan and SPDs on affordabl housing and rsidntial dsign standards. Existing policis and guidanc provid clar policis for affordabl housing. W hav also insrtd a nw appndix (appndix A) listing th ky borough wid Southwark planning policis and supplmntary planning guidanc to mak it clarr that ths policis nd to b rad alongsid th Blackfriars Road SPD. Sction 1 of th SPD has bn updatd to rfr to this nw appndix. Figur 3 of th SPD illustrats th rlationship btwn diffrnt planning documnts including supplmntary planning documnts and nighbourhood plans. Th SPD sts out that it provids furthr guidanc to xisting planning policis in th Cor Stratgy and savd Southwark Plan. It dos not rpat borough wid policis and th SPD must b rad alongsid othr planning documnts. W hav also insrtd a nw appndix (appndix A) listing th ky borough wid Southwark planning policis and supplmntary planning guidanc to mak it clarr that ths policis nd to b rad alongsid th Blackfriars Road SPD. Sction 1 of th SPD has bn updatd to rfr to this nw appndix Andrw Richard Banksi 7. Gnral Dvlopmnt is, by its natur, largly Notd. On of th ky purposs of th SPD, as st out within th SPD

105 Rp Obj Rf Rf Nam 7 son d Rsid nts Forum 443 Andrw Richard son 443 Andrw Richard son Banksi d Rsid nts Forum Banksi d Rsid nts Forum Dtails of Rprsntation picmal, but thr is a strong fling that thr could b mor working togthr by thos involvd in dvlopmnt, and approval of it, to produc an improvd living and working nvironmnt in th ara. Anything that th plan and plannrs can do to ncourag this would b wlcom. 8. Blackfriars Road Thr is no dtail rlating to th plans for Blackfriars Road itslf and th ky objctivs for it ar not splld out in th plan. Dtaild Commnts: Sction 2: Vision for Blackfriars Road p.7, Para stats that fig. 4 illustrats th cor stratgy vision dvlopd in consultation. This shows th main focus of dvlopmnt nding just south of th Stamford St./ Southwark Strt/ Blackfriars Rd. junction and not xtnding furthr south as is now proposd in this documnt. An xtnsion of tall buildings south of this ara is contrary to th policy that is th outcom of rlativly rcnt consultation, thus undrmining th confidnc in consultation by th council. Officr Rspons to Rprsntation is to provid a stratgic framwork and dtaild guidanc to coordinat futur growth. Th SPD has bn updatd within th vision and SPD 6: Activ travl to rfr to th council working with Transport for London to dlivr a sgrgatd cycl rout along Blackfriars Road. At th tim of prparing this SPD thr is not furthr dtail as yt to includ in th SPD as plans ar still bing drawn up by TfL. With rgards to consultation, a consultation rport has prpard alongsid th Blackfriars Road SPD. This sts out a summary of th rprsntations rcivd and how w hav takn ths into account in prparing th final vrsion of th SPD. Th appndics also st out all of th rprsntations rcivd and officr commnts on how this commnts hav bn takn into account, and whthr th SPD has bn updatd as a rsult. Both th London Plan and th Cor Stratgy idntify Banksid, Borough and London Bridg, and Elphant and Castl opportunity aras as aras for chang and dvlopmnt. Th Cor Stratgy sts out that both th opportunity aras ar growth aras. Th whol of th Blackfriars Road SPD ara lis within ths opportunity aras and is alrady idntifid as a growth ara and ara for chang and dvlopmnt Andrw Richard son Banksi d Rsid nts Forum Th prsnt sit of high buildings at ths junctions (and at th Elphant & Castl) has a crtain rational in that thy ar significant bus and rail/tub junctions, but high building at St. Gorg s Circus, as nvisagd in p.11, para.2 dos not hav this justification. It is also contrary to th sntimnts xprssd in p.25, para.3.29 rgarding th stting of narby listd buildings and consrvation aras. For clarification, figur 4, th Cor Stratgy vision has bn rmovd from th SPD. A tall building up to 70m in hight could b appropriat at th southrn nd of Blackfriars Road providd that it complis with th dtaild guidanc outlind in SPD 5 and th currnt dvlopmnt plan that includs th rlvant policis of th savd Southwark Plan (2007), Cor Stratgy (2011), London Plan (2011) and othr planning documnts/guidanc, including th NPPF (2012). Th dvlopmnt plan sts out th policis for tall buildings. Th guidanc in th SPD provids dtail on how to implmnt ths dvlopmnt plan policis

106 Rp Obj Rf Rf Nam Dtails of Rprsntation Officr Rspons to Rprsntation spcific to Blackfriars Road Andrw Richard son 443 Andrw Richard son Banksi d Rsid nts Forum Banksi d Rsid nts Forum P.8 Th currnt vision of providing ovr 1,900 nw homs, 665 affordabl housing units and around 25,000 nw jobs in th Banksid, Borough and London Bridg opportunity ara is wlcom. Ralization of th affordabl homs lmnt is of crucial importanc to th viability, vitality and safty of this mixd community but this commitmnt to affordabl housing and hnc to a viabl mixd community dos not appar to b carrid through to th draft SPD in any significant way. W ar concrnd that th Council s Affordabl Housing policy alrady has littl crdibility in Banksid so offrs no rassuranc, spcially sinc hotls, commrcial, offics, rtail, studnt accommodation (which impact on rsidntial provision) ARE all mntiond in th SPD. If this is to b a mixd and sustainabl community, rsidntial provision, including affordabl, nds to b activly writtn in. Th approach is supportd by our vidnc bas including th Blackfriars Road Urban Dsign Study which has bn prpard in accordanc with CABE and English Hritag Guidanc on Tall Buildings, In light of consultation rsponss and to add clarity to th guidanc rlating to St Gorg s Circus in SPD 5, th SPD has bn updatd to clarify that a tall building could provid a focal point at th southrn nd of Blackfriars Road up to 70m. A tall building should also sustain, nhanc or bttr rval th local hritag assts. Th SPD sts out that it provids furthr guidanc to xisting planning policis in th Cor Stratgy and savd Southwark Plan. It dos not rpat borough wid policis and th SPD must b rad alongsid othr planning documnts.. Housing is not givn its own sction within th SPD bcaus th borough-wid housing policis and guidanc alrady covr housing adquatly. This includs policis in th Cor Stratgy and savd Southwark Plan and SPDs on affordabl housing and rsidntial dsign standards. Existing policis and guidanc provid clar policis for affordabl housing. W hav also insrtd a nw appndix (appndix A) listing th ky borough wid Southwark planning policis and supplmntary planning guidanc to mak it clarr that ths policis nd to b rad alongsid th Blackfriars Road SPD. Sction 1 of th SPD has bn updatd to rfr to this nw appndix. Th SPD sts out that it provids furthr guidanc to xisting planning policis in th Cor Stratgy and savd Southwark Plan. It dos not rpat borough wid policis and th SPD must b rad alongsid othr planning documnts. Housing is not givn its own sction within th SPD bcaus th borough-wid housing policis and guidanc alrady covr housing adquatly. This includs policis in th Cor Stratgy and savd Southwark Plan and SPDs on affordabl housing and rsidntial dsign standards. Existing policis and guidanc provid clar policis for affordabl housing.

107 Rp Obj Rf Rf Nam 443 Andrw Richard son 443 Andrw Richard son 443 Andrw Richard son Banksi d Rsid nts Forum Banksi d Rsid nts Forum Banksi d Rsid nts Forum Dtails of Rprsntation Innr London is about half th rsidntial dnsity of Paris or Nw York and thr is scop for a considrabl incras in th SDP ara. Howvr th lssons from dmolishd 60 s towr blocks ar that all nw accommodation nds to b built to high spac and construction standards and must b appropriat for thos who ar to liv in thm. Th bottom of p.8 stats that Southwark ar working with landownrs, Bttr Banksid and Cross Rivr Partnrship to nhanc th ara s mix of cultur, history and businss in a way that is snsitiv to it s rsidnt communitis, but thr is no mntion of rsidnt involvmnt. How ar thir viws and nds to b xprssd and fully takn into account? Officr Rspons to Rprsntation Thr is nothing additional that nds furthr spcific guidanc for Blackfriars Road in rlation to affordabl housing. W hav also insrtd a nw appndix (appndix A) listing th ky borough wid Southwark planning policis and supplmntary planning guidanc to mak it clarr that ths policis nd to b rad alongsid th Blackfriars Road SPD. Sction 1 of th SPD has bn updatd to rfr to this nw appndix. Notd. Existing policis in th Cor Stratgy st out th approach to dnsity. Th Cntral Activitis Zon is on of th aras whr a highr lvl of dnsity may b prmittd if th dvlopmnt is of an xmplary dsign and provids xcllnt living accommodation. Sction 4 of th SPD on implmntation highlights th importanc of working with all our partnrs including rsidnts and th local community. It rfrs spcifically to continuing to ngag with th local community and rsidnts, and also rfrs to continuing to ngag with many groups and ky stakholdrs as wll as look at opportunitis for ngagmnt with othr groups and rsidnts. Furthrmor, a consultation rport has prpard alongsid th Blackfriars Road SPD. This sts out a summary of th rprsntations rcivd and how w hav takn ths into account in prparing th final vrsion of th SPD. Th appndics also st out all of th rprsntations rcivd and officr commnts on how ths commnts hav bn takn into account, and whthr th SPD has bn updatd as a rsult. Undr th hading mrging idas for a vision for Exmplary dsign is alrady covrd in adoptd planning policy Blackfriars Road, p.11, Para 2 stats dvlopmnt will documnts and thr is no nd to rpat xisting borough-wid b of xcptional dsign and will nhanc th local policy and guidanc. Ovrarching dsign policis in th Cor Stratgy charactr, sustain and nhanc th local and th savd Southwark Plan rquir high quality dsign. Existing nvironmnt. Howvr, xcptional dsign is not guidanc in sction 2.2 of th council's Rsidntial Dsign Standards dfind and tall buildings, as proposd at St. Gorg s SPD sts out th critria for a dvlopmnt to b considrd as bing Circus will hav th opposit ffct, diminishing th of xmplary standard of dsign It includs critria such as "mak a

108 Rp Obj Rf Rf Nam 443 Andrw Richard son 443 Andrw Richard son 443 Andrw Richard son Banksi d Rsid nts Forum Banksi d Rsid nts Forum Banksi d Rsid nts Forum Dtails of Rprsntation narby consrvation aras and listd buildings. Out of city cntr offic blocks and hotls ar oftn bland and lacking in quality and a wall of glass clad buildings of similar ag and styl of th kind currntly mrging along Blackfriars Road will not nhanc th local charactr or th local nvironmnt as statd. Idntity can b prsrvd and cratd by a good mix of nw and old, but consnt for dstruction of buildings such as th Papr Moon pub, rcntly dmolishd nar Christ Church, dtracts from a strt that has all too fw such buildings of charactr and rplacs thm with nw buildings all of on ra, with no links to th past and that gnrally look just lik nw buildings anywhr ls. (This is contrary to th sntimnts xprssd in p.25, Para on.) Emrson Studios in Emrson St., th S.E Railway Offics in Tooly St. and a numbr of othr cass illustrat th sam lack of adquat application of this principl lswhr in th borough. Sction 3: Stratgis & guidanc. SPD1: Businss Spac. p.15, Para Th railway archs ar a hritag asst to th ara as wll as a vnu for small businss. Wll and snsitivly dvlopd thy can provid a wid varity of businss spac radily accssibl to th public and of gnral bnfit in th ara too. Th spac in front of thm has th potntial to crat an attractiv and rlativly saf rout-way for pdstrians and cyclists throughout th ara. A rout-way from th City ovr a nw bridg using th pirs of th old London Chatham and Dovr Railway bridg and thn continuing south to cross Union Strt, from which an idntifiabl rout xists all th way to th Elphant & Castl (and byond) appars achivabl using land primarily providing srvic accss spac for maintnanc of th railway viaducts. Officr Rspons to Rprsntation positiv contribution to local contxt, charactr and communitis, including contributing to th strtscap". SPD 5 of th Blackfriars Road SPD has bn updatd to mak it clarr th a tallr building could b at th southrn nd of Blackfriars Road. Wording has also bn updatd to rfr spcifically to th hritag assts and thir sttings. Th SPD provids guidanc on hritag assts and would b rad in conjunction with th xisting hritag policy framwork and dsignations. Notd. Th SPD ncourags th snsitiv rus of th railway archs and public ralm improvmnts in and around thm. Th SPD sts out a vision for th ara. Th council will continu to work with TFL, and dvloprs and land ownrs to improv walking and cycling routs in th ara and this is st out in SPD 6 with aspirations for improvd routs and links in th figur. Th SPD is not th appropriat documnt to st out th prcis dtail on how this will b achivd and thus sts out ovrarching idas to nsur any futur dsign options ar not ruld out such as this.

109 Rp Obj Rf Rf Nam 443 Andrw Richard son 443 Andrw Richard son 443 Andrw Richard son Banksi d Rsid nts Forum Banksi d Rsid nts Forum Banksi d Rsid nts Forum Dtails of Rprsntation This should form part of th vision for th ara and b incorporatd in th SPD as a long-trm aspiration. Affordabl businss spac is ndd and should b providd in nw dvlopmnt if local mploymnt and amnitis ar to b protctd. If local businsss ar displacd, nw dvlopmnt should b rquird to provid affordabl accommodation for thm so that thy ar not lost to th ara. SPD 2, Mixd us town cntr. Pag 16 rfrs to town cntrs. (Is Blackfriars Road rally dfind as a town cntr?) Th fact box stats that rsidntial us is appropriat in town cntrs but is not a town cntr us for th purposs of Southwark s local plan. Howvr, p.11, para.1 says thr will b many nw houss on th uppr floors of commrcial dvlopmnts offring a rang of housing typs and sizs yt th following SPD2 maks no mntion of housing. Rathr SPD 2 says it will support proposals for hotls and othr visitor accommodation (C1), howvr, P.17, para 3.10 says th rcnt provision has alrady mt th GLA (2006) study rquirmnt for hotl bdrooms to Para says w will support nw high quality hotls but th transport, parking and loading and unloading implications of this ar not addrssd. Th ara has alrady rachd th local quota on nw hotl bds. Rsidnts would lik to s mor bnfits Officr Rspons to Rprsntation In lin with th Cor Stratgy Policy 10 Jobs and Businss, SPD 1 ncourags th provision of flxibly dsignd nw businss floorspac in a rang of unit sizs to catr for diffrnt sizd businsss. This includs small offic/studio/workshop businss spac. Th SPD also rpats th rquirmnt st out in borough-wid policy for th rtntion or rplacmnt of xisting businss spac in dvlopmnts to mt th nds of th SE1 offic markt. Thr is no particular vidnc that subsidisd businss spac is rquird at th momnt. W hav insrtd additional txt to bullt 1 of SPD1 to st out that w will ncourag th provision of small and start-up businsss in th ara. Th Blackfriars Road SPD ara is locatd within th Borough, Banksid and London Bridg district town cntr, which is idntifid in th Cor Stratgy and on our adoptd policis map. W hav amndd SPD 2 to mak it clar that spac for town cntr uss should b dvlopd alongsid both rsidntial dvlopmnt and also businss uss. W hav amndd th fact box to st out furthr clarification on town cntr uss. Th dfinition of town cntr uss now mirrors th NPPF dfinition of main town cntr uss. W hav also mad clarr that whilst rsidntial dvlopmnt can play an important rol in nsuring th vitality of town cntrs, is not a main town cntr us whn planning for comptitiv town cntrs which nd to provid customr choic and a divrs rtail offr and xprinc in th contxt of Southwark s Local Plan. Th London Plan sks to achiv 40,000 nt additional hotl bdrooms by 2031.Th stimat of th approximat nt and gross hotl rooms rquird ovr th priod for Southwark, as st out in th GLA s Hotl Dmand Study, is basd on assssmnt of factors including transport links to cntral London and connctions to airports, proximity of tourist attractions/businss locations, cafs and rstaurants in th ara, night tim conomy, cultural facilitis and attractions, and rgnration initiativs and sit availability. Th forcast for Southwark should b tratd as indicativ only, and local

110 Rp Obj Rf Rf Nam 443 Andrw Richard son Banksi d Rsid Dtails of Rprsntation Officr Rspons to Rprsntation from any nw hotls, including a local rat for visitors circumstancs should also b factord in. to rsidnts, and ngotiatd us of sport or gym facilitis for local popl. If housing on uppr floors of It is important to considr that th SPD ara is within th Cntral commrcial proprtis is to form part of th plan, futur Activitis Zon, Banksid, Borough and London Bridg Opportunity r-dvlopmnt nds to b considrd as housing Ara and part of th Elphant and Castl Opportunity Ara which ar ovr offics may pos rdvlopmnt problms in th aras promotd in th London Plan to accommodat stratgically futur as, basd on post war xprinc, good important hotl provision. Arts, cultural and tourism activitis hav housing will usually hav a significantly longr lif that flourishd in Southwark in th last dcad, particularly in th Stratgic offic buildings. Cultural Ara, which is within th CAZ. Banksid, Borough and London Bridg has consquntly xprincd a growth in th numbr of hotls to support this incrasing visitor conomy. Th SPD guidanc nds to b rad in conjunction with borough-wid adoptd policis in th Cor Stratgy and savd Southwark Plan. SPD2 provids guidanc to support Cor Stratgy policy 10 Jobs and businss which sts out that th council will allow th dvlopmnt of hotls within th town cntrs, th stratgic cultural aras, and placs with good accss to public transport srvics, providing that ths do not harm th local charactr. Policy 10 and SPD 2 ar also supplmntd by th savd policy 1.12 of th Southwark Plan which addrsss visitor accommodation. Nw hotl proposals in th ara will b assssd against ths rlvant planning policis and a considration of th impact upon local amnity and th balanc of land uss will also b takn into account. SPD2 and th supporting txt sts out that proposals for hotls should sk to includ ancillary facilitis which can ncourag th widr us of th building to bnfit th local community and passing public. Th SPD also sts out guidanc on th built form, which includs guidanc for dvlopmnt to rinforc th civic scal along th main routs by incorporating flxibility in th dsign of non rsidntial buildings which prmit adaptability for multipl uss, and applying inclusiv dsign principls for all building and spacs. Ths guidlins will hlp to nsur that mixd us dvlopmnt can mak a positiv contribution to th local charactr and distinctivnss of th ara. All nw housing should mt good spac standards, b of good quality matrials and dsign and, if on uppr floors, should adquatly addrss th nd for Notd. Th SPD sts out that it provids furthr guidanc to xisting planning policis in th Cor Stratgy and savd Southwark Plan. It dos not rpat borough wid policis and th SPD must b rad

111 Rp Obj Rf Rf Nam 443 Andrw Richard son nts Forum Banksi d Rsid nts Forum Dtails of Rprsntation altrnativ lift accss in th vnt of lift failur. It should also provid dsign solutions to th nois issus of location on major transport routs as wll as nuisanc and nois arising from rfus collction from and srvicing of shops, bars, rstaurants, shops and othr lowr floor uss. p18, 3.14 says Nw housing and businss floor spac will also incras th rsidnt and working population and it is important to s that infrastructur is in plac to support th community. Howvr, th plan dos not idntify sits for th nw or nlargd clinics, surgris, nursry schools, primary schools, play aras, parks and othr community facilitis that will bcom ncssary in th significantly nlargd community. Sits nd to b idntifid and safguardd if thy ar to b convnintly sitd to mt futur usrs nds. Officr Rspons to Rprsntation alongsid othr planning documnts. Housing is not givn its own sction within th SPD bcaus th borough-wid housing policis and guidanc alrady covr housing adquatly. This includs policis in th Cor Stratgy and savd Southwark Plan and SPDs on affordabl housing and rsidntial dsign standards. Ths xisting policis and guidanc includ rquirmnts such as minimum spac standards. Existing policy documnts also dal with rquiring high quality dsign and to addrss potntial issus such as nois spcifically savd Southwark Plan policy 3.2: Protction of amnity as wll as guidanc in th Rsidntial Dsign Standards SPD, Sustainabl Dsign and Construction SPD and Sustainabl Transport SPD. Th SPD and othr planning policy documnts provid th framwork for th provision of infrastructur to support dvlopmnt. Updats hav bn mad to th SPD to rfr mor to othr uss including halth and community facilitis. SPD 2: Mixd us town cntr sts out that w will support th provision of nw social infrastructur and community facilitis as part of mixd us dvlopmnts. SPD 3: Public ralm and opn spac rfrs to th continud protction of th thr protctd opn spacs and ncouraging furthr linkags and nw spacs. Sction 4.4 of th SPD rfrs spcifically to infrastructur, crossing rfrring to th community infrastructur lvy (CIL) and sction 106 planning obligations to hlp nsur th dlivry of ky infrastructur to mitigat th impact of dvlopmnt. Infrastructur is covrd within borough-wid planning documnts with th ovrarching policy 14 of th Cor Stratgy rcognising that nw dvlopmnt in th borough nds to b supportd by adquat infrastructur, including social, nvironmntal and physical infrastructur. Th borough s Infrastructur Plan, idntifis stratgic infrastructur which is ndd to support growth and dvlopmnt in

112 Rp Obj Rf Rf Nam 443 Andrw Richard son 443 Andrw Richard son Banksi d Rsid nts Forum Banksi d Rsid nts Forum Dtails of Rprsntation Th rcnt spat of nw hotls and aspirations in th SPD p.18, para.3.13, for mor on Blackfriars Road all signal growth of a night-tim conomy. Th implications of controlling and srvicing this nd to b addrssd, paying particular attntion to nois nuisanc to narby rsidnts and control of drunknnss tc. (Th ara is alrady dsignatd an alcohol control zon bcaus of past problms, but this is not acknowldgd in th plan) Th provision of 24 hour wc s nds to b addrssd and providd for if this part of th plan is to rmain. Th plan should addrss th nd for shops to b sprad around th ara. Th tndncy for suprmarkts to group in on ara with nothing in anothr dos not rcogniz that rsidnts ar sprad throughout th SPD ara and look for vryday nds shops to b rasonably clos at hand. Aftr a darth of suprmarkts of any siz, thr ar now too many of th sam kind Andrw Richard Banksi SPD 3, Public ralm and opn spac. Th proposd Notd. Officr Rspons to Rprsntation th borough ovr th liftim of th Cor Stratgy ( ). Whr possibl it idntifis th cost of infrastructur to providd, any committd sourcs of funding which will b usd to dlivr it and th organis rsponsibl. It also idntifis th funding gap i.. th gap btwn known commitmnts and th total cost of infrastructur rquird. Whn it is adoptd, Southwark s CIL will b usd to contribut towards bridging this funding gap. Funds armarkd for infrastructur in th Council s capital invstmnt programm also will hlp to improv infrastructur provision. Th council ar currntly prparing our draft community infrastructur charging schdul and an updatd sction 106 SPD. Adoption is plannd for It is appropriat to look at th provision of infrastructur at a borough-wid lvl through ths ddicatd documnts rathr than through th Blackfriars Road SPD. W hav amndd th SPD to includ rfrnc to th Borough and Banksid licnsing saturation ara, which is a local policy that addrsss th cumulativ impact of licnsd prmiss. All applications for nw or varid prmiss licncs for night-clubs, public houss and bars, rstaurants and cafs, off-licncs, suprmarkts and grocrs nd to addrss th saturation concrns st out in th council s licnsing policy within th prmiss oprating schdul. Our savd Southwark plan policy 1.7 on town cntr dvlopmnt rquirs proposals to provid amnitis for usrs of th sit such as public toilts, whr appropriat. SPD2 alrady promots th dvlopmnt of a much widr mix of town cntr uss alongsid businss and rsidntial. This should includ a rang of diffrnt typs and sizs of rtailrs, to hlp boost th local conomy by gnrating additional spnding and inward invstmnt in othr businsss and providing an incrasd numbr of mploymnt opportunitis. Th SPD cannot dsignat land us on dvlopmnt sits, howvr w will considr th rang of uss that would b appropriat for allocatd dvlopmnt sits through th prparation of th Nw Southwark Plan and its accompanying adoptd policis map.

113 Rp Obj Rf Rf Nam 6 son d Rsid nts Forum 443 Andrw Richard son 443 Andrw Richard son 443 Andrw Richard son Banksi d Rsid nts Forum Banksi d Rsid nts Forum Banksi d Rsid Dtails of Rprsntation widning of footpaths, boulvard tr planting, and incrasd road frontag activity is wlcom, togthr with th introduction of cycl lans and th rsultant narrowing of th main carriagway. Good landscapd spacs, comparabl with.g. th City s high quality small parks, ar important too. Opn Spac should b opn and not ovrshadowd by nighbouring tall buildings. Largr schms should b rquird to provid som gnuin nw, attractiv and usful public opn spac as part of th dvlopmnt. Th ida proposd in p23, fig. 6 of a grn rout down Blackfriars Road is strtching th trm too far for a rout-way that is (appropriatly) dscribd in p.31, para as part of th A201, a stratgic N/S corridor btwn th Elphant & Castl in th south and King s Cross in th north, and is stratgically important for busss, fright, pdstrians and cyclists. P.20, last para. includs an aim to nhanc th stting of th consrvation ara, listd buildings and th listd oblisk. This will not b achivd by Officr Rspons to Rprsntation Notd. This guidanc is st out in SPD 3. Our Opn Spac Stratgy(2013) idntifis how links btwn opn spacs can hav a varity of diffrnt functions and charactristics dpnding on thir siz and location. Diffrnt typs of grn links can includ: Grn links - ths ar links which join on grn spac to anothr by xtnding th amount of grn btwn th two. Ths can form pdstrian pathways and woodland dgs. Ths links can improv biodivrsity by providing habitats and nabling wildlif to mov btwn opn spacs. Quit grn routs ths ar links which ar lightly traffickd roads and strts usd by cyclists with trs and othr planting dsignd to slow car traffic and to improv and grn th ovrall nvironmnt. Crating thm can involv widning or building out pavmnts or planting mor trs and othr forms of grnry. Grnd main roads - ths ar links that ar oftn alrady havily plantd with matur trs. In many cass this planting is part of th historic townscap which contributs significantly to thir charactr and rinforcs th prcption of thm as plasant and attractiv routs. Th ida of promoting a "grn rout" along Blackfriars Road would b mor in lin with th concpt of a grnd main road as idntifid abov. A tall building up to 70m in hight could b appropriat at th southrn nd of Blackfriars Road providd that it complis with th dtaild guidanc outlind in SPD 5 and th currnt dvlopmnt plan that

114 Rp Obj Rf Rf Nam 443 Andrw Richard son nts Forum Banksi d Rsid nts Forum Dtails of Rprsntation allowing tall buildings in this part of th SPD ara. Rathr th possibility of altring th gyratory traffic pattrn to allow th circus to b attachd to th adjoining proposd larg dvlopmnt sit to th south wst should b pursud and th opportunity takn to nabl th circus to bcom part of a safly accssd high quality pockt park xtnding into th adjoining dvlopmnt sit. (Similar idas hav bn pursud lswhr, most notably in Trafalgar Squar and ar bing considrd on th A1 at Highbury Cornr and Highgat roundabouts.) P.21 para 3.20 stats W will ncourag th introduction of activity and movmnt undr and around th ara s railway viaduct archs so that thr ar mor vibrant placs for popl and businsss to us. As mntiond abov, this could bst b achivd by a policy of opning up ths largly continuous routs along on sid of ths archs to crat a saf and attractiv landscapd pdstrian cycl rout from th rivr, bsid th nw Blackfriars station Banksid ntranc, crossing Union Strt and continuing to th Elphant & Castl (and byond). This would intrsct with a similar ast-wst rout from London Bridg to Watrloo (th Low-Lin ) now mrging as part of th Banksid Nighbourhood Plan. Fig.6, p.23 should b dvlopd to includ ths through railway sid routs as proposd and improvd pdstrian links and cycl links. Officr Rspons to Rprsntation includs th rlvant policis of th savd Southwark Plan (2007), Cor Stratgy (2011), London Plan (2011) and othr planning documnts/guidanc, including th NPPF (2012). Th dvlopmnt plan sts out th policis for tall buildings. Th guidanc in th SPD provids dtail on how to implmnt ths dvlopmnt plan policis spcific to Blackfriars Road. Th approach is supportd by our vidnc bas including th Blackfriars Road Urban Dsign Study which has bn prpard in accordanc with CABE and English Hritag Guidanc on Tall Buildings, In light of consultation rsponss and to add clarity to th guidanc rlating to St Gorg s Circus in SPD 5, th SPD has bn updatd to clarify that a tall building could provid a focal point at th southrn nd of Blackfriars Road up to 70m. A tall building should also sustain, nhanc or bttr rval th local hritag assts. With rgards to th gyratory, w will continu to work with TfL on improving th traffic managmnt within th ara. Th council will work with Ntwork Rail and landownrs to improv th prmability of th ara and opn up routs whr fasibl. W hav rcivd confirmation that ntwork rail support proposals for th Low Lin and a north south link also Andrw Richard Banksi P.22, para An incras in th public ralm and Guidanc for nw public spacs and improvd public ralm is st out

115 Rp Obj Rf Rf Nam 1 son d Rsid nts Forum 443 Andrw Richard son 443 Andrw Richard son 443 Andrw Richard son 443 Andrw Richard son Banksi d Rsid nts Forum Banksi d Rsid nts Forum Banksi d Rsid nts Forum Banksi d Rsid nts Forum Dtails of Rprsntation (whr appropriat and usful) xisting opn spacs, should b tradd with dvloprs as a quid pro quo for any bnficial chang of us or incrasd hight and dnsity grantd to thm by a planning consnt. Th ara is short of opn spac and whr it is achivd th plan should rquir it to b of th sort of high dsign and quality found in th many City of London parks. Th dsignation of SLOAP (spac lft ovr aftr planning) as public opn spac, to b maintaind at public xpns but of vry littl us to it, should b avoidd. Th plan s mntion of linking saf grn routs through th ara is wlcomd, but mor nds to b said to dfin whr ths might b and what thy might link. Thr nds to b mor considration of th way in which pdstrians currntly cross Blackfriars Road and making ths safr with controlld crossings, zbra crossings or cntral rfugs as appropriat g at th Burrll Strt/Colombo Strt crossing point. It would b hlpful if th SPD includd a plan showing th xtnt of Council ownd land. Officr Rspons to Rprsntation in SPD 3. Our Opn Spac Stratgy (2013) has idntifid a dficincy in opn spacs within thn ara; howvr givn th limitd opportunitis for th cration of opns, our priority is to focus on improving out xisting opn spacs. W will sk to provid nw opn spac and grning as st in th stratgy. A nw paragraph has bn addd to SPD 3 "w ar doing this bcaus" to provid furthr background on th Opn Spacs Stratgy rcommndations. Our Opn Spac Stratgy (2013) has idntifid a dficincy in opn spacs within thn ara; howvr givn th limitd opportunitis for th cration of opns, our priority is to focus on improving out xisting opn spacs. W will sk to provid nw opn spac and grning as st in th stratgy. Nw opn spacs cannot b dsignatd through an SPD. This may addrssd through th nw Southwark Plan. A nw paragraph has bn addd to SPD 3 "w ar doing this bcaus" to provid furthr background on th Opn Spacs Stratgy rcommndations. Indicativ grn links hav bn idntifid through th borough, our Opn Spac Stratgy sts out furthr dtail on th diffrnt typs and charactristics of grn links that may b ncourags within th borough. This could includ saf grn routs btwn xisting opn spacs and ky dstinations. A nw paragraph has bn addd to SPD 3 "w ar doing this bcaus" to provid furthr background on th Opn Spacs Stratgy rcommndations. Notd. Th council will work with TfL to nsur Blackfriars Road is saf for all usrs. SPD 6: Activ travl has bn updatd to rfr to TfL's proposals for a sgrgatd cycl lan on Blackfriars Road. It is not appropriat to includ a figur on council ownrship within a planning documnt Andrw Richard Banksi SPD4, Built form and hritag. Good public ralm is SPD 4 is rad in conjunction with th xisting hritag policy

116 Rp Obj Rf Rf Nam 6 son d Rsid nts Forum 443 Andrw Richard son 443 Andrw Richard son Banksi d Rsid nts Forum Banksi d Rsid nts Forum Dtails of Rprsntation achivd by mor than good urban landscap tratmnt of th spac btwn buildings. It is important to kp good old buildings of charactr and ons associatd with th history of th ara as wll as to achiv good quality, wll-dsignd nw dvlopmnt. It is gnrally th oldr buildings and structurs that giv an ara it s uniqu charactr and sns of continuity and history, and this is particularly tru of th Banksid ara. Loss of buildings such as th Papr Moon pub, th S.E. railway offics in Tooly Strt and th pnding loss of Emrson Strt Studios, among othrs, diminish th uniqu charactr of th ara. Thr ar all too fw such buildings in th Blackfriars Road SPD ara and thos that still xist nd to b idntifid, protctd and rtaind Blackfriars Road, also now undr thrat, is a short run of charactrful priod buildings incorporating usful shops for local popl of th kind that th road nds to kp amongst th nw dvlopmnt if it is not to los its sns of plac and history and it s uniqu charactr. No 169 could radily tak a mansard typ xtra story. Th ara is rich in social history and industrial archaology and its charactr largly stms from this. (Th Tmpranc Socity Building is just on xampl) This should to b apprciatd and acknowldgd by th plan and policis for protcting it should b givn gratr wight and prominnc. Th inclusion of buildings shown on th policy map Fig 7 as buildings of townscap mrit or hritag valu outsid of consrvation aras should b nough to rsult in thir rtntion within nw surrounding dvlopmnt. All such buildings in th ara should b idntifid and shown on th policy map and, whr clos to narby consrvation aras, ths should b Officr Rspons to Rprsntation framwork and dsignations. Appndix A has bn addd to th SPD to cross rfr to th ky policis in th Cor Stratgy and savd Southwark Plan. Guidanc and th idntification of buildings will b addrssd in a nw Hritag SPD that will b prpard alongsid th Nw Southwark Plan. SPD 4 is rad in conjunction with th xisting hritag policy framwork, th charactri study and dsignations. Appndix A has bn addd to th SPD to cross rfr to th ky policis in th Cor Stratgy and savd Southwark Plan. Guidanc and th idntification of buildings will b addrssd in a nw Hritag SPD that will b prpard alongsid th Nw Southwark Plan. SPD 4 is rad in conjunction with th xisting hritag policy framwork, th charactri study and dsignations. Appndix A has bn addd to th SPD to cross rfr to th ky policis in th Cor Stratgy and savd Southwark Plan. Guidanc and th idntification of buildings and consrvations aras will b addrssd in a nw Hritag SPD that will b prpard alongsid th Nw Southwark Plan.

117 Rp Obj Rf Rf Nam 443 Andrw Richard son 443 Andrw Richard son 443 Andrw Richard son 443 Andrw Richard son 443 Andrw Richard son Banksi d Rsid nts Forum Banksi d Rsid nts Forum Banksi d Rsid nts Forum Banksi d Rsid nts Forum Banksi d Dtails of Rprsntation xtndd to accommodat thm as was rcntly (2012) don with Valntin s Plac CA. Whr groups of listd buildings such as th Pabody Estat, at th south nd of Blackfriars Road, xist, a consrvation ara should also b cratd thr and includ nar-by buildings of townscap mrit or hritag valu. Fig. 7 p.26 is worryingly mislading. It is an out of dat map that fails to show th Valntin s Plac ara as a consrvation ara. This was dsignatd in It is vital that it is shown as such on this map as this dsignation should giv th protction ndd to th numbr of buildings of charactr and mrit thr. Th Colorama buildings, in Lancastr Strt, ar of som mrit and charactr but ar alrady approvd for dmolition. Howvr, th buildings at th north nd of narby Boyfild Strt and Silx Strt ar listd and thos continuing th trrac to th south, on th ast sid of Silx Strt should b includd as of mrit in th fig.7 map. Th possibility of adding th buildings of mrit in fig.7 on King Jams Strt and btwn Lancastr Strt and Borough Road into an xtndd St. Gorg s Circus consrvation ara should b considrd. It is not just charactrful, good or historic buildings that nd to b idntifid and protctd but also passagways, yards and othr, somtims hiddn, spacs too. Th approach to r-dvlopmnt of th ara should b basd on th modls providd in othr succssful urban aras with distinctiv local charactr drivd from thir history and xisting priod architctur, such as Covnt Gardn, King s Cross and York Way, Islington. P.24, Pnultimat bullt point, lins 2&3. Th commnts abov rlating to P.21 para 3.20 ar also Officr Rspons to Rprsntation Notd. Th figur has bn updatd. Guidanc and th idntification of buildings and consrvations aras will b addrssd in a nw Hritag SPD that will b prpard alongsid th Nw Southwark Plan. Guidanc and th idntification of buildings and consrvations aras will b addrssd in a nw Hritag SPD that will b prpard alongsid th Nw Southwark Plan. Guidanc and th idntification of buildings and consrvations aras will b addrssd in a nw Hritag SPD that will b prpard alongsid th Nw Southwark Plan. Notd. SPD 3 provids guidanc for public ralm opportunitis in and around th viaducts, whil th guidanc st out in SPD 1, 2 and 4 also

118 Rp Obj Rf Rf Nam 443 Andrw Richard son 443 Andrw Richard son Rsid nts Forum Banksi d Rsid nts Forum Banksi d Rsid nts Forum Dtails of Rprsntation rlvant hr. Th railway viaducts in th SPD ara ar an important part of th district s charactr and hritag and offr th chanc of dvloping linar strips and rout-ways of ral charactr with a grat varity of small businss, rtail, rcration and community accommodation tc. making us of th spacs bnath th viaduct archs. Th railway s viaduct structurs in th ara hav, hithrto, largly bn sn as an unsightly disadvantag and buildings hav turnd thir backs on thm and th intrvning spac has oftn bcom unsightly and ill card for. Howvr, if opnd up, with imaginativ dvlopmnt and rspct for th dramatic, somtims multi-lvl, Victorian nginring structurs, thy could provid grat opportunitis for th whol district and contribut to th plan s aim of attracting popl south from th mor popular aras around th rivr. applis. Officr Rspons to Rprsntation Th triangular spac accssd from Grat Suffolk Th SPD cannot includ this lvl of dtail, howvr th aspiration is Strt and at th multi-lvl junction of th E-W and N- notd and would b includd undr th guidanc in SPD 3. S high lvl Low Lin routs (and hnc at th nod points of th potntial pdstrian/ cycl routs proposd lswhr in this documnt) has hug potntial as an urban spac of normous charactr. It and th vaultd aras across th strt (just outsid th SPD ara) hav th potntial to match spacs lik Birmingham s Gas Strt Basin, th Covnt Gardn Markt building, parts of th nw mrging King s Cross and othr industrial hritag sits as a grat and vibrant urban spac. It is not difficult to imagin it, for instanc as a Camdn Markt, south of th rivr! Th gnral tnor of paras to 3.29 indicat that thr is a significant diffrnc btwn th typ of dvlopmnt appropriat at th north nd as opposd to th south nd of Blackfriars Road: but this is at varianc with othr parts of th SPD that nvisag a SPD5 sts out guidanc building hights and should b rad alongsid guidanc in th rst of th SPD. As st out in th SPD, it is appropriat for th highst building hights to b locatd at th northrn nd of Blackfriars Road. Th guidanc in SPD 3 sks a cohsiv approach to th public ralm to nsur an improvd

119 Rp Obj Rf Rf Nam 443 Andrw Richard son 443 Andrw Richard son Banksi d Rsid nts Forum Banksi d Rsid nts Forum Dtails of Rprsntation similar tratmnt for th lngth of th road and tall buildings at it s major junctions, including at St. Gorg s Circus. Th changing charactr of th road and it s distanc from th ral commrcial cntrs/ transport nods ar currntly not rcognizd by th plan which appars to s th ntir road as suscptibl to th sam gnral tratmnt and planning approach, prhaps all th way to th Elphant & Castl, dspit th hug diffrncs of th various parts of th rout and th aras bhind. SPD5, Building hights. P.27 stats A tall building of a hight of up to 70m [c.21 storys] should provid a focal point at St Gorg s Circus. Thr is an obvious and stablishd planning rational in locating tall buildings clos to significant bus and rail/tub junctions, but St. Gorg s Circus dos not hav this justification. Thr is also a widsprad accptanc that tall buildings ar bst in groups (as in th City, Canary Wharf, and proposd at th north nd of Blackfriars Road and at Watrloo) rathr than in isolation (as Cntrpoint at Tottnham Court Road or, as is currntly (tmporarily) th cas, at th Elphant & Castl). BRF mmbrs far that th council has in mind that a group of tall buildings might also b rctd on th prsnt Bakrloo sidings sit, though no mntion is mad in th plan of what dvlopmnt might b appropriat thr. Th plan should addrss th issu. A group of towrs at St Gorg s Circus would not b appropriat. It is not a transport intrchang and th Officr Rspons to Rprsntation pdstrian xprinc along th lngth of th road. A tall building up to 70m in hight could b appropriat at th southrn nd of Blackfriars Road providd that it complis with th dtaild guidanc outlind in SPD 5 and th currnt dvlopmnt plan that includs th rlvant policis of th savd Southwark Plan (2007), Cor Stratgy (2011), London Plan (2011) and othr planning documnts/guidanc, including th NPPF (2012). Th dvlopmnt plan sts out th policis for tall buildings. Th guidanc in th SPD provids dtail on how to implmnt ths dvlopmnt plan policis spcific to Blackfriars Road. Th approach is supportd by our vidnc bas including th Blackfriars Road Urban Dsign Study which has bn prpard in accordanc with CABE and English Hritag Guidanc on Tall Buildings, In light of consultation rsponss and to add clarity to th guidanc rlating to St Gorg s Circus in SPD 5, th SPD has bn updatd to clarify that a tall building could provid a focal point at th southrn nd of Blackfriars Road up to 70m. A tall building should also sustain, nhanc or bttr rval th local hritag assts. A tall building up to 70m in hight could b appropriat at th southrn nd of Blackfriars Road providd that it complis with th dtaild guidanc outlind in SPD 5 and th currnt dvlopmnt plan that includs th rlvant policis of th savd Southwark Plan (2007), Cor Stratgy (2011), London Plan (2011) and othr planning documnts/guidanc, including th NPPF (2012). Th dvlopmnt plan sts out th policis for tall buildings. Th guidanc in th SPD

120 Rp Obj Rf Rf Nam 443 Andrw Richard son Banksi d Rsid nts Forum Dtails of Rprsntation construction of any high buildings in this ara would diminish and dtract from th stting of th adjoining listd buildings and th buildings in th narby consrvation aras. It dos not nd a high building to giv it idntity: this is alrady achivd by th circus and oblisk. It is ths faturs that should b nhancd. Th only principl that is offrd about marking nods with tall buildings has not justifid on architctural, public ralm or vn convninc grounds; BRF strongly suspcts this principl is just a currnt planning fad. Why dos a nod nd marking by a tall building? W hav obsrvd ovr th last fw yars of rgnration that whn a tall building is givn planning prmission, a nw bnchmark is st for building hights in th vicinity. This is a furthr caus for concrn at both Southwark tub and St Gorg s Circus. Th proposal for a singl towr at Southwark Tub station is undsirabl for th sam rasons, though it dos hav th justification of bing a significant transport intrchang P.27, final para. All nw housing should includ its full prcntag of social housing. Th ara currntly has a mixd community and it is important that this rmains th cas for social stability and for accommodating mploys for vital public srvics in th ara. Officr Rspons to Rprsntation provids dtail on how to implmnt ths dvlopmnt plan policis spcific to Blackfriars Road. Th approach is supportd by our vidnc bas including th Blackfriars Road Urban Dsign Study which has bn prpard in accordanc with CABE and English Hritag Guidanc on Tall Buildings, In light of consultation rsponss and to add clarity to th guidanc rlating to St Gorg s Circus in SPD 5, th SPD has bn updatd to clarify that a tall building could provid a focal point at th southrn nd of Blackfriars Road up to 70m. A tall building should also sustain, nhanc or bttr rval th local hritag assts. Th TfL Bakrloo sidings sit (Sit 43 in Figur 5/Tabl 1 in th draft SPD, but r-numbrd as Sit 47 in Figur 6/Tabl1 in th updatd SPD) has bn includd as a potntial dvlopmnt sit, du to its rcognisabl dvlopmnt potntial. Any dvlopmnt at th sit would b assssd and dtrmind at th planning application stag, taking into account local contxt, which includs th local hritag assts. Th SPD dos not dsignat proposals sits or provid sit spcific guidanc, as this would byond th scop of th SPD. It dos idntify potntial dvlopmnt sits which ar illustrativ of th hug opportunity for chang within th ara and th nd for a cohrnt framwork. Th SPD has also bn updatd to clarify that th list of sits is not xhaustiv and othr sits may com forward for dvlopmnt. Som of th sits will b compltly rdvlopd, whilst othr sits may xprinc lss chang such as rfurbishmnt or improvmnts to th xisting buildings or surroundings. Th SPD sts out that it provids furthr guidanc to xisting planning policis in th Cor Stratgy and savd Southwark Plan. It dos not rpat borough wid policis and th SPD must b rad alongsid othr planning documnts. Housing is not givn its own sction within th SPD bcaus th borough-wid housing policis and guidanc alrady covr housing adquatly. This includs policis in th Cor Stratgy and savd Southwark Plan and SPDs on affordabl housing

121 Rp Obj Rf Rf Nam Dtails of Rprsntation Officr Rspons to Rprsntation and rsidntial dsign standards. Existing policis and guidanc provid clar policis for affordabl housing Andrw Richard son 443 Andrw Richard son Banksi d Rsid nts Forum Banksi d Rsid nts Forum P.28 para & 31 stat that th London Plan and Cor Stratgy policy 12 say that tall buildings may b appropriat at th north nd of Blackfriars Road. By implication, thrfor, thy ar not appropriat at th south nd, at St. Gorg s Circus, and prhaps at Th Cut/Union Strt junction ara, yt th draft SPD sks to promot tall buildings in ths aras on th basis that it will giv th ara idntity. It might, but not in a dsirabl way or on that would prsrv or nhanc th charactr of th adjoining consrvation aras, nighbouring listd buildings or th listd oblisk monumnt. Th circus is also citd as a transport nod but it is srvd by busss only and is in no way comparabl with Watrloo, London Bridg, th Elphant and Castl or vn th junction of Blackfriars Road with Stamford Strt/Southwark Strt. It is undrstood that th vidnc basis for othr policis has bn prpard by outsid consultants, whist that for tall buildings has bn don in-hous. W bliv th rsultant lack of indpndnt viw givs th outcom lss crdibility. W hav also insrtd a nw appndix (appndix A) listing th ky borough wid Southwark planning policis and supplmntary planning guidanc to mak it clarr that ths policis nd to b rad alongsid th Blackfriars Road SPD. Sction 1 of th SPD has bn updatd to rfr to this nw appndix. Th guidanc st out within th SPD is consistnt with th xisting planning policy framwork of dsign, hritag and tall building policis, which includs th rlvant savd Southwark Plan policis, Cor Stratgy Policy SP12, th rlvant policis of th London Plan and th NPPF. Th guidanc proposd falls within th rmit of an SPD. It is not an AAP and dos not propos nw policy for th ara. In light of consultation rsponss and to add clarity to th guidanc rlating to St Gorg s Circus in SPD 5, th SPD has bn updatd to clarify that a tall building could provid a focal point at th southrn nd of Blackfriars Road up to 70m. A tall building should also sustain, nhanc or bttr rval th local hritag assts. Th GLA s rprsntation also confirms that th Mayor supports th council s approach on tall buildings, but suggsts that th SPD should b mor flxibl in rlation to building hights, and that buildings in th rgion of 70/30m would b appropriat. Th council disagrs with this proposd amndmnt as it could allow buildings that ar gratr than th 70m/30m thrshold, which would b considrd inappropriat basd on our vidnc bas. As such, th council considrs SPD5 to balanc local charactr and dvlopmnt potntial Th council's vidnc bas for its planning policis and planning guidanc coms from a wid rang of sourcs. Som is prpard intrnally, som is prpard by consultants on bhalf of th council, and som is information obtaind from othr sourcs such as th Cnsus. In th cas of this SPD with rfrnc to tall buildings, th charactri study has bn prpard by xtrnal consultants and

122 Rp Obj Rf Rf Nam 443 Andrw Richard son 443 Andrw Richard son 443 Andrw Richard son Banksi d Rsid nts Forum Banksi d Rsid nts Forum Banksi d Rsid nts Forum Dtails of Rprsntation SPD 6. Activ travl. Prsumably th plan is thin in this ara bcaus th road is controlld by TfL. Rathr than sparat a cycl lan (or lans) by a whit lin or unsightly upstanding krb (as on Southwark Bridg) a slightly raisd shrub planting bordr, with priodic gaps for pdstrian crossing, would rduc th xcssiv width givn ovr to traffic, add to th grning of th road, bttr sparat th uss, appar lss tmporary, incras safty and gnrally contribut to humanizing th road. (A similar ida is currntly bing implmntd by Camdn but uss rathr insubstantial raisd planting boxs (watring and maintnanc of which will b mor difficult). Notwithstanding, aspirations for th public ralm ar includd arlir in th plan and th illustration on th covr shows a (prhaps rathr optimistic) viw of th road in th futur. Th plan should go furthr and addrss issus such as floating bus stops, pdstrian crossings, parking, widnd pavmnts, matur tr planting (and thir maintnanc) and th nd for a cycl lan on ach sid of th road. Th nd for bttr provision for saf pdstrian crossing is important and gratst towards th busir northrn nd of th road. Many cyclists and pdstrians prfr to us smallr scal, quitr, routs away from major roads whr ths ar availabl and whr thy do not involv any significantly gratr travl distancs. This should b rflctd in th plan s vision and proposals. Traffic spds and pdstrian and cyclist safty around St. Gorg s Circus and at th major junctions nds to b flaggd up as dsrving particular attntion by TfL in conjunction with Southwark. Officr Rspons to Rprsntation th urban dsign study has bn prpard in hous. Sinc th publication of th draft SPD it has bn announcd that TfL ar proposing to introduc a North South Cycl Suprhighway along Blackfriars Road linking up to Kings Cross and Elphant and Castl. TfL ar th Highway Authority for Blackfriars Road howvr th council support TfL's proposals and th SPD txt has bn updatd to rfr to this. W will work in partnrship with TfL to nsur a holistic approach whn dvloping dsigns for th cycl suprhighway to nsur thy balanc th nds of all usrs and improv conditions and facilitis for pdstrians. This is rcognisd and th council is working on routs for quitr strts. Th ky indicativ potntial connctions ar shown in th figur. Notd. Th council will continu to work with both TfL and th polic to nsur roads in th borough ar saf for all usrs.

123 Rp Obj Rf Rf Nam 443 Andrw Richard son 443 Andrw Richard son Banksi d Rsid nts Forum Banksi d Rsid nts Forum Dtails of Rprsntation P.31. Commnts on SPD3, p.21 para ar again rlvant to this sction too. Thy rfr to th potntial for us of th xisting and largly continuous routs along on sid of th railway viaducts to crat a saf and attractiv landscapd pdstrian cycl rout from th rivr, bsid th nw Blackfriars station Banksid ntranc, and Union Strt to th Elphant & Castl (and byond). This would intrsct with a similar astwst rout from London Bridg to Watrloo (th Low- Lin ) which forms part of th mrging Banksid Nighbourhood Plan. Ths routs provid a potntial safr, quitr and halthir pdstrian and cycl rout north-south and ast-wst across th ntir SDP ara and should b incorporatd in th plan as a long-trm aim to b achivd incrmntally. Accss routs ar gnrally availabl on both sids of th viaducts and on sid should b dsignatd for vhicl accss and srvicing whilst th othr provids a landscapd pdstrian/ cycl rout. Dvlopmnt by Ntwork Rail has impactd havily on th ara in rcnt yars and continus to do so, particularly now at London Bridg station whr chang and disruption is hug. Consnts for chang of us and dvlopmnt of archs to mor lucrativ uss ar bing grantd too. Th community dsrvs a substantial quid pro quo for this dvlopmnt. Making th routs along on sid of thir viaducts availabl for us as pdstrian cycl routs (laving th othr sid to provid vhicl accss to th archs bnath) would b an appropriat gstur and would surly hav long trm advantags for Ntwork Rail too. 4. Implmntation. P.33 para Thr may hav bn 300 nw homs built in th last fw yars, but fw, if any, hav providd social housing. A propr mix of accommodation is ncssary in th ara if a saf and viabl businss and rsidntial community is to b Officr Rspons to Rprsntation Th SPD sts out idas for an mrging vision for th ara. Th council will continu to work with dvloprs and land ownrs, including Ntwork Rail to improv walking and cycling routs in th ara and this is st out in SPD 6 with aspirations for improvd routs and links in th rlvant figur. Th SPD dos not st out how all th dtail of how this will b achivd. This nsurs that any futur dsign options ar not ruld out. Th SPD sts out that it provids furthr guidanc to xisting planning policis in th Cor Stratgy and savd Southwark Plan. It dos not rpat borough wid policis and th SPD must b rad alongsid othr planning documnts. Housing is not givn its own sction within th SPD bcaus th borough-wid housing policis and guidanc

124 Rp Obj Rf Rf Nam 443 Andrw Richard son Banksi d Rsid nts Forum Wbb r & Qunti n TRA Dtails of Rprsntation cratd. Th 1,500 dwllings nvisagd for th nighbourhood by this SDP must thrfor includ thir full shar of social and affordabl housing. Th plan should stat this clarly and unambiguously. On of th aims of th plan is statd to b to crat local mploymnt, but if low paid popl cannot afford to liv in th ara jobs will b takn by popl living furthr away, producing an unbalancd community and adding to th burdn on public transport and doing nothing to allviat local unmploymnt. P.33, para Th 70m hight for blocks at th north nd of Blackfriars Road is alrady gratly xcdd by th approvd 170m high towr at 1 Blackfriars, thus undrmining confidnc in any proposd planning control in th ara, and particularly on hight limits st out in th draft SDP and othr plans. 1. Availability of information and timscals of th draft SPD I am vry concrnd about th timings involvd in th issuing of information about th draft SPD to consults, and about th lack of information providd at local lvl on th proposd dvlopmnt. Thr was a fiv-wk gap btwn th prss announcmnt of th SPD and th dlivry of th Rvitalis Hav your say laflt to housholds (on th Wbbr Row Estat at last). Th documnt Urban Dsign Principls was publishd in August 2013, six wks into th consultation priod. Southwark Council did not mov th xhibition which was hld for svn days from 21 Jun 2013 at Stor Strt WC1,to a subsqunt location on Blackfriars Road (.g. Erlang Hous)so that rsidnts, workrs and businsss most likly to b affctd by th SPD could accss th information locally throughout th consultation priod. Th first dat to ask qustions of councillors from Officr Rspons to Rprsntation alrady covr housing adquatly. This includs policis in th Cor Stratgy and savd Southwark Plan and SPDs on affordabl housing and rsidntial dsign standards. Existing policis and guidanc provid clar policis for affordabl housing. W hav also insrtd a nw appndix (appndix A) listing th ky borough wid Southwark planning policis and supplmntary planning guidanc to mak it clarr that ths policis nd to b rad alongsid th Blackfriars Road SPD. Sction 1 of th SPD has bn updatd to rfr to this nw appndix. Th paragraph has bn updatd. Th guidanc for th northrn nd of Blackfriars Road is st out in SPD 5. A consultation rport has prpard alongsid th Blackfriars Road SPD. This sts out a summary of th rprsntations rcivd and how w hav takn ths into account in prparing th final vrsion of th SPD. Th appndics also st out all of th rprsntations rcivd and officr commnts on how this commnts hav bn takn into account, and whthr th SPD has bn updatd as a rsult. Th SPD was consultd on in accordanc with th council's Statmnt of Community Involvmnt (SCI) (2008) and xcdd th consultation rquirmnts of both th SCI and th rlvant rgulations. Th consultation rport summariss th consultation carrid out.

125 Rp Obj Rf Rf Nam Dtails of Rprsntation Borough, Banksid & Walworth Community Council was organisd to tak plac just fiv days aftr th prss announcmnt. Southwark Council st th consultation priod to run throughout th summr priod, whn many consults wr away on holiday. Qustions rgarding th abov points Considring its rol as a ky documnt to rad alongsid th draft SPD, why was th Urban Dsign Principls documnt not mad availabl until six wks aftr th announcmnt of th draft SPD? Why did Southwark Council wait fiv wks btwn th prss announcmnt of th draft SPD to dlivr th Rvitalis Hav your say laflt (Jun 2013) to housholds? Why did Southwark Council not provid an xhibition in th SPD ara for th duration of th consultation? Why was th first opportunity to ask qustions of councillors st so soon aftr th prss announcmnt, whn many consults would not hav bn awar of th nws, lt alon hav had tim to study th whn consults wr unlikly to hav had sufficint tim to study th dtail of th draft SPD? Givn th scal of th draft SPD and th xtnsiv rang of documnts rlating to it (London Plan, Southwark Plan, Urban Dsign Principls, Borough and London Bridg Stag 2 Tall Building Study, Localism Act), was it rasonabl to run th consultation priod during th summr whn many popl ar away on holiday? Dos th approach takn by Southwark Council to all of th abov points comply with policy rquirmnt No. 4in th Communitis and Local Govrnmnt documnt, Local planning rgulations: Consultation : Consultation xrciss should b dsignd to b accssibl to, and clarly targtd at, thos popl th xrcis is intndd to rach." and to sction 1.46 of th London Plan in rfrnc to th Localism Bill: Th Officr Rspons to Rprsntation

126 Rp Obj Rf Rf Nam Wbb r & Qunti n TRA Dtails of Rprsntation Govrnmnt has indicatd its intntion to chang th planning systm radically, to giv nighbourhoods far mor ability to dcid th shap of th placs whr popl liv.? 2. Scal of th draft SPD I am vry concrnd that popl hav not bn givn nough tim to undrstand th scal of th Blackfriars Rod dvlopmnt and that an xtndd priod for consultation is rquird. Th Blackfriars Road dvlopmnt is on a scal comparabl with th Hygat Estat: th Hygat was part of th vision for Elphant and Castl, as dscribd in th Southwark Plan as follows: Southwark s vision for th Elphant and Castl is for: A thriving and succssful mixd us major town cntr that is saf, full of vitality and accssibl to and from a highly intgratd public transport systm; combining historic charactr with a high quality dsign and layout of nw buildings; a plac whr popl will want to liv, work and visit for shopping and lisur. ; th Hygat was also assignd mastrplan status and accordd a consultation priod which ran from July 2011 to March 2012, comprising various public consultation vnts (xhibitions and workshops) to inform th local community of th proposals, gathr commnts and shar ths with th dsign tam to fd back into th mastrplan; th outlin planning application was finally submittd to th Planning Committ in January By contrast, th larg scal dvlopmnt of Blackfriars Road has bn accordd only draft SPD status, with a documnt totalling only 34 pags. Qustions rgarding th abov points Givn that in languag and intnt, th vision for Elphant and Castl is almost idntical to that of th draft SPD s vision for Blackfriars Road, why has Blackfriars Road not bn assignd mastrplan status in ordr to provid a full rang of information to Officr Rspons to Rprsntation With rgards to consultation, th rquirmnts for consultation on supplmntary planning documnts is st out within th council's Statmnt of Community Involvmnt (SCI) (2008) and th Town and Country Planning (Local Planning) (England) Rgulations Th consultation on th Blackfriars Road SPD has mt and xcdd both ths sts of rquirmnts. A consultation rport has bn prpard as part of th Blackfriars Road SPD adoption, and this summariss th consultation carrid out and how it has mt and xcdd ths rquirmnts. With rgards to th commnt about mastrplan status, th SPD is not a mastrplan. It provids guidanc and furthr information on implmnting xisting Cor Stratgy and savd Southwark Plan policis. Sction 1 of th Southwark Plan, as rfrrd to within th rprsntation is no longr usd as this was not "savd" in 2010 as part of th application to "savd" Southwark Plan policis. Furthrmor sits ar not allocatd for spcific land uss within th SPD as this will b lookd at through th prparation of th Nw Southwark Plan, which can allocat proposals sits on th adoptd policis map

127 Rp Obj Rf Rf Nam Wbb r & Qunti n TRA Dtails of Rprsntation consults ovr a longr tim priod and to allow thm tim to mak sns of an xtnsiv rang of documnts rlating to th dvlopmnt (Blackfriars Road draft SPD, London Plan, Southwark Plan, Banksid, Borough and London Bridg Stag 2 Tall Building Study, Urban Dsign Principls, Localism Act)? By assigning SPD rathr than mastrplan status to Blackfriars Road, to what xtnt has Southwark Council complid with policy rquirmnt No 2. in th Communitis and Local Govrnmnt documnt, Local planning rgulations Consultation : Consultations should normally last for at last 12 wks with considration givn to longr timscals whr fasibl and snsibl. and points109 and 110 of policy 11.4 Mastrplans or Dvlopmnt Framworks of th Southwark Plan: 109 Th council may also produc from tim to tim mor dtaild action plans for widr aras in th form of mastr plans or dvlopmnt framworks; 110 Ths may includ rfrncs to th council s aspirations for th ara whn it is acting as a rgnration agncy in partnrship with othr organis and landownrs. Ths mastr plans or framworks will not st planning policy for an ara but must rflct it.? 3. Shap of th proposd SPD ara I do not undrstand why th proposd shap of th SPD ara and I bliv that this will hav a ngativ impact on trying to crat a common idntity for th ara. Th proposd ara to th north of Surry Row and Boundary Row compriss a logical shap and rach in trms of th corridor rfrrd to by Councillor Ptr John in his announcmnt of th draft SPD to th prss on 21 Jun 2013, i.. ncompassing Blackfriars Road itslf and a numbr of strts within rlativly clos proximity to Blackfriars Road. South of Surry Row and Boundary Row, howvr, th proposd ara Officr Rspons to Rprsntation An xplanation of th boundary is st within th SPD It includs th whol of th Blackfriars Road and som of th surrounding ara. It includs th surrounding ara as th surrounding ara is also likly to s som dvlopmnt and improvmnts, particularly possibl improvmnts to public ralm. Wording has bn addd to th SPD to mak it clarr that th charactr and historic valu of much of th surrounding ara will continu to b protctd and nhancd. Figur 3 of th SPD illustrats th rlationship btwn diffrnt planning documnts including supplmntary planning documnts and nighbourhood plans. Th SPD has bn updatd to mak it clar th nighbourhood plans ar currntly bing prpard. Onc adoptd a

128 Rp Obj Rf Rf Nam Dtails of Rprsntation Officr Rspons to Rprsntation xpands significantly outwards, losing this mostly nighbourhood plan will hav mor wight than a SPD in th planning uniform corridor shap and th ky common procss as it will form part of th council's dvlopmnt plan. At charactristic of bing locatd on or within clos prsnt thr is no adoptd nighbourhood plan for any of th ara proximity to Blackfriars Road. This causs th covrd by th Blackfriars Road SPD. Th SPD may nd to b proposd ara to tak in aras which do not naturally rviwd in th futur if a nighbourhood plan is adoptd for any of blong to Blackfriars Road, both gographically and in th SPD ara. W hav also insrtd a nw appndix (appndix A) trms of usag and idntity. Exampls includ: o To listing th ky borough wid Southwark planning policis and th wst thr is a strtch of Watrloo Road running supplmntary planning guidanc to mak it clarr that ths policis from Gray Strt to St Gorg s Circus; howvr, nd to b rad alongsid th Blackfriars Road SPD. Sction 1 of th Watrloo Road is a compltly diffrnt strt to SPD has bn updatd to rfr to this nw appndix. Blackfriars Road with its own distinct physical history and idntity gaind from acting as a gatway to Watrloo Station and onwards into Covnt Gardn and th Wst End, rathr than its countrpart Blackfriars Road s rol as a gatway into th City. Morovr, this sction of Watrloo Road diffrs quit significantly in usag from Blackfriars Road: th formr compriss significant rsidntial populations across thr housing stats (Quntin Hous on Gray Strt, Cooprs Clos on Watrloo Road and th Wbbr Row Estat) and individual priod houss on Watrloo Road (south of Mawdly Hous), local businsss, a housing trust, two hotls, two studnt accommodation blocks and a rlativly small numbr of offics; and th lattr is split largly into offic accommodation, hotls and pubs to th north of Th Cut, and rsidntial stats, small businsss and shops, pubs and offic accommodation to th south of Th Cut. o Furthr wst, th proposd ara xtnds out vn furthr to tak in a larg sction of both Wstminstr Bridg Road and Lambth Road; th rational is said to b that this is th boundary btwn Lambth and Southwark, howvr, taking an approach along borough dmarcations is likly to caus problms in trying to crat on common vision and idntity for th whol SPD ara, sinc ths wstrn parts ar vastly

129 Rp Obj Rf Rf Nam Wbb r & Qunti n TRA Dtails of Rprsntation diffrnt to th main strtch of Blackfriars Road itslf. o To th ast, th proposd ara xtnds at its furthst point to tak in Southwark Bridg Road. Again, nothing about this ara in trms of gographical layout or usag would suggst that it forms a natural part of th Blackfriars Road ara. Qustions rgarding th abov points What is th rational for this proposd shap of th SPD ara and what is th plan for crating a common charactr across such a larg ara of such diffring idntitis, populations and usags? Would it not b mor logical to maintain th intgrity of th corridor shap which dfins th ara north of Surry Row and Boundary Row and apply this also to th sction south of this junctur, thus crating a straightr lin on th wst sid (and thus xcluding most of th southrn sction of Watrloo Road) and xcluding all of th proposd Wstminstr Road and Lambth Road sctions; and crating a straightr lin to th ast along th lin of th railway? 4. Vision and charactr I am concrnd that th draft SPD focuss so prdominantly on larg commrcial dvlopmnt that th nds of small businsss and rsidnts hav not bn sufficintly considrd or providd for in th draft SPD. In announcing th draft SPD to th prss on 21 Jun 2013, Councillor Ptr John said that th documnt was intndd to "giv furthr confidnc to potntial invstors and comfort to local rsidnts and businsss that w ar sking to protct and nhanc th charactr and idntity of this historic borough". Of th vision for Blackfriars Road, point of th draft SPD stats, To hlp crat a succssful plac whr popl want to work, liv and visit, w nd a vision which rflcts th nds and aspirations of th community, businsss, rsidnts, landownrs and local stakholdrs. Th Rvitalis Hav your say (Jun 2013) laflt stats, Our Officr Rspons to Rprsntation Th SPD is intndd to bnfit a wid rang of groups including xisting and nw rsidnts. Th mrging vision has bn updatd to mak this clarr. Th SPD has also bn updatd within th supporting txt to SPD 2: Mixd us town cntr, that th SPD ara is mixd with both commrcial and rsidntial dvlopmnt.

130 Rp Obj Rf Rf Nam Wbb r & Qunti n TRA Wbb r & Qunti n TRA Wbb r & Qunti n TRA Dtails of Rprsntation stratgy is to provid a mixd us town cntr supporting a rang of town cntr uss alongsid th xisting prdominant businss us. W ncourag mor shops, rstaurants, cafs and bars. W also support nw hotls and ncourag a mix of arts, cultural, lisur and ntrtainmnt uss. W ncourag nw and improvd social infrastructur and community facilitis as part of mixd us dvlopmnts. Qustions rgarding th abov points Givn th prdisposition to ncourag landownrs to rais rnts for xisting small businsss (.g. th rcnt cas of Ntwork Rail and small businsss in Union Strt) and to approv th dmolition of unlistd historic buildings (1 Valntin Plac, Blackfriars Road and 173 Blackfriars Road), what vidnc can Southwark Council provid rgarding its commitmnt, as statd by Councillor Ptr John, that th draft SPD will protct and nhanc th charactr and idntity of this historic borough"? Givn th prdominanc of commrcial dvlopmnt in th draft SPD, to what xtnt hav th authors of th draft SPD consultd with th rsidnts mntiond in point of th draft SPD ( businsss, rsidnts, landownrs and local stakholdrs ) and whr can th rsults of this rsarch b found? A town cntr is usually charactrisd by a prdominanc of offic and rtail spac, plus small numbrs of rsidnts (who gnrally rquir a highrthan-avrag lvl of disposabl incom in ordr to Officr Rspons to Rprsntation Th SPD guidanc nds to b rad in conjunction with borough-wid adoptd policis in th Cor Stratgy and savd Southwark Plan. This is mad clar within th SPD. W hav amndd th mrging vision for Blackfriars Road in th SPD to rinforc that much of th charactr and historic valu of th surrounding ara, particularly th consrvation aras and listd buildings will b continu to b protctd and nhancd. A consultation rport has prpard alongsid th Blackfriars Road SPD. This sts out a summary of th rprsntations rcivd and how w hav takn ths into account in prparing th final vrsion of th SPD. Th appndics also st out all of th rprsntations rcivd and officr commnts on how this commnts hav bn takn into account, and whthr th SPD has bn updatd as a rsult. Th SPD was consultd on in accordanc with th council's Statmnt of Community Involvmnt (SCI) (2008) and xcdd th consultation rquirmnts of both th SCI and th rlvant rgulations. Th consultation rport summariss th consultation carrid out. Th Blackfriars Road SPD ara is locatd within th Borough and Banksid district town cntr which is idntifid in th Cor Stratgy s hirarchy of town cntrs. Policy 3 of th Cor Stratgy stats that w will support th provision of nw shopping spac in th ara, and this

131 Rp Obj Rf Rf Nam Wbb r & Qunti n TRA Dtails of Rprsntation afford prmium-pricd, cntrally locatd accommodation); howvr, sinc th ara south of Th Cut actually has a larg numbr of local rsidnts, is Southwark Council s vision of a mixd us town cntr rally an appropriat on for this sction of Blackfriars Road? 5. Building hights Tall buildings ar most appropriat and accptabl whn thy ar clustrd togthr in a purly commrcial district, such as Canary Wharf. Thy ar not appropriat to an ara lik Blackfriars Road, which has many pr-xisting buildings of much lowr hight, and larg communitis of rsidnts who do not want to liv with th ngativ ffcts of tall buildings. It is all vry wll for th Mayor to favour tall buildings whn h himslf livs in a priod hous on a strt in Islington whr thr is virtually zro risk of a high ris towr vr bing built on his doorstp! Th Rvitalis Hav your say laflt (Jun 2013) says of building hights, W rquir dvlopmnt to b of an appropriat hight, ncouraging tall buildings at th ky gatways and nods. Th Banksid, Borough and London Bridg Stag 2 Tall Building Study (Dcmbr 2009) idntifid aras in Blackfriars Road which wr appropriat for tall buildings. Ths aras wr all situatd north of Th Cut. Th Banksid, Borough and London Bridg Stag 2 Tall Building Study (Dcmbr 2009) statd in point ( Summary of snsitivitis in Blackfriars Road): W hav clustrd sits togthr whr thy hav th sam snsitivitis. Nw tall building dvlopmnt should considr its rlationship to th xisting and proposd tall buildings in th mrging clustr. Nw tall buildings should provid a transition from th scal of xisting tall buildings towards lowr hight dvlopmnt in th surrounds. Th Banksid, Officr Rspons to Rprsntation should includ both food and non-food spac and aim to mt th nds of local rsidnts, as wll as visitors and businsss. W hav amndd SPD 2 to mak it clar that spac for town cntr uss should b dvlopd alongsid rsidntial dvlopmnt and businss uss. SPD2 also sts out that w will considr th impact of all nw proposals on th ovrall mix of uss in th ara and also on local amnity. Th guidanc st out within th SPD is consistnt with th xisting planning policy framwork of dsign, hritag and tall building policis, which includs th rlvant savd Southwark Plan policis, Cor Stratgy Policy SP12, th rlvant policis of th London Plan and th NPPF. Th Blackfriars Road SPD urban dsign study sts out th vidnc bas. Th urban dsign study utiliss a robust mthodology that has prviously bn agrd with English Hritag, and 3D modlling tchniqus to assss th potntial impact on hritag assts. Th study updats th tsting from th prvious urban dsign studis in light of guidanc st out in th NPPF, th London Plan that was adoptd aftr th Cor Stratgy, schms that alrady hav bn consntd within th ara and xisting dvlopmnt prssur that could lad to picmal dvlopmnt within th ara. Mattrs rgarding th impact of tall buildings would b assssd at th planning application stag through th rlvant savd Southwark Plan policis, Cor Stratgy Policy SP12 and th rlvant policis of th London Plan and othr planning guidanc. Bullt-point 14 of SPD 5 sts out furthr guidanc rgarding microclimat, whil SPD3 sts out guidanc on landscaping. Figur 5 - now Figur 6 - has bn updatd with a rvisd potntial dvlopmnt sits list.

132 Rp Obj Rf Rf Nam Dtails of Rprsntation Borough and London Bridg Stag 2 Tall Building Study (Dcmbr 2009) statd in point 5.1 of Conclusions : Snsitivitis for tall buildings Th snsitivitis which could provid constraints for tall building dvlopmnt includ: Nw dvlopmnt should b snsitiv to th xisting and proposd surrounds so that nw tall buildings ar not out of charactr with th surrounds or prov dominant or ovrbaring. Nw tall buildings dvlopmnt should considr its potntial impact on th local stting and charactr of th gnral ara in viws that could b xprincd vry day by visitors, local rsidnts, community groups and workrs. Locations whr tall buildings would not b appropriat. Th Banksid, Borough and London Bridg Stag 2 Tall Building Study (Dcmbr 2009) studid a numbr of locations as potntial sits for tall buildings. From th original list of locations idntifid, th following wr ruld out in point by rason of bing gnrally locatd in aras whr nw significantly tallr dvlopmnt would b out of contxt with th surrounds, ar not at a gatway or point of landmark significanc, or hav littl opportunity for public ralm opportunitis: o Sampson Hous o 231 to 241 Blackfriars Road o 6 Paris Gardn & Hatfilds o Wdg Hous o Blackfriars Road o Colombo Hous and Tlphon Exchang Dspit this, all of th abov-mntiond sits hav subsquntly bn listd in Tabl 1. Potntial dvlopmnt sits of th draft SPD, but no dtail has bn providd about th plans for ths sits. Th Palstra building alrady provids a hug landmark of hight and mass at th junction of Blackfriars Road and Union Strt; howvr, th draft SPD also proposs an additional nod comprising a 70m towr on top of Southwark tub station, in clos proximity to low ris buildings along Th Cut, Gorgian Officr Rspons to Rprsntation

133 Rp Obj Rf Rf Nam Dtails of Rprsntation buildings on th wst sid of Blackfriars Road, and social housing at Nlson Squar. Of Southwark tub station, th Banksid, Borough and London Bridg Stag 2 Tall Building Study (Dcmbr 2009) concludd th following: Point of Summary of snsitivitis in Blackfriars Road : Southwark tub station Should provid a transition from th proposd nw scal of dvlopmnt towards lowr hight surrounds. Should considr th group of listd buildings along Blackfriars Road south of Th Cut. Should considr its rlationship to th xisting landmark of Palstra on th opposit sid of Blackfriars Road. Point 5.1 of Conclusions : Th Southwark tub station sit at th cornr of Blackfriars Road and Th Cut has th potntial for a nw landmark building which could mark th location of th train station and provid a countrpoint of similar hight to Palstra on th opposit sid of Blackfriars Road. Th draft SPD proposs a 70m towr on Blackfriars Road nar St Gorg s Circus and planning is alrady wll advancd in this rspct, as vidncd by an xhibition hld at Erlang Hous by Barratt Homs in May 2013, showing visuals of a 30-story towr and a full scal 3D modl of Blackfriars Road; th 3D modl showd vry clarly th xtnt to which a 70m towr in this location would dwarf vry othr building on Blackfriars Road. Dspit bing a wid boulvard, th impact of tall buildings on Blackfriars Road is clar to s on sunny days: in th morning, any tall buildings locatd on th astrn sid of th strt cast a larg shadow across th road, with th rvrs occurring in th aftrnoon onc th sun has movd astwards. Existing rsidnts who liv in th ara 24/7 ar likly to fl th impact of tall buildings mor than anyon ls. From a prsonal prspctiv, as a rsidnt who has livd on th fifth story of a Officr Rspons to Rprsntation

134 Rp Obj Rf Rf Nam Wbb r & Qunti n TRA Wbb r & Qunti n TRA Dtails of Rprsntation block in Wbbr Row sinc 1990, I hav sn firsthand th impact of tall buildings on local viws. Tn yars ago I had a clar viw of th following ky rivr landmark buildings: Th London Ey, th Oxo Towr, St Paul s Cathdral and Tat Modrn. Urban living can b asthtically harsh but ths viws gav m a daily apprciation of this grat city and addd positivly to my quality of lif. Today, du to th construction of incrasingly tall and bulky buildings, th only rmaining landmark I can now s on th skylin is th Oxo Towr; all of th othr landmarks ar hiddn by tall and/or bulky nw buildings. I miss ths viws of London and fl strongly that th scal of dvlopmnt of tall buildings is svrly roding local rsidnts visual njoymnt of living in innr London. In th printd prsntation ntitld Draft Blackfriars Road supplmntary planning documnt (SPD) datd August 2013, th plan in 1. Building hights contains th following rror: 16. is markd as Pabody stat but th ara markd in purpl as Pabody Estat has bn shadd in to also includ th Grad II listd Wbbr Row Estat and th Grad II listd Cntr for Litracy in Primary Education in Wbbr Row/Wbbr Strt, which ar compltly sparat ntitis to th Pabody Estat. This rror nds to b corrctd. Qustions rgarding th abov points In th statmnt in th Rvitalis Hav your say laflt (Jun 2013), W rquir dvlopmnt to b of an appropriat hight... what is th dfinition of appropriat - i.. appropriat to what? In strongly ncouraging a stratgy of ncouraging tall buildings south of Th Cut, is th draft SPD in conflict with th following points in th Banksid, Borough and London Bridg Stag 2 Tall Building Study (Dcmbr 2009): 2.3 Blackfriars Road Nw tall building Officr Rspons to Rprsntation Appropriat dvlopmnt maximiss th dvlopmnt potntial of a sit whil considring its contxt. Th guidanc st out within th SPD is consistnt with th xisting planning policy framwork of dsign, hritag and tall building policis, which includs th rlvant savd Southwark Plan policis, Cor Stratgy Policy SP12, th rlvant policis of th London Plan and th NPPF.

135 Rp Obj Rf Rf Nam Dtails of Rprsntation dvlopmnt in this location should considr th following:... Rlationship to surrounding buildings and spacs. Impact on local amnity of nighbouring proprtis. 3.2 Th following urban dsign considrations and rflct thos indicatd in th Southwark Plan (CDL1) Policy 3.20 and draft rplacmnt London Plan (CDR2) Policy 7.7 that rquir tall buildings: Rlat wll to th surrounding scal and charactr of dvlopmnt, so as not to b ovrbaring or rpat th mistaks of th past. and with th following policis in th Southwark Plan: 3.13 Urban dsign 272 Principls of good urban dsign must b takn into account in all dvlopmnts. Urban dsign is th rlationship btwn diffrnt buildings and strts, squars, parks and watrways and othr spacs that mak up th public domain; th natur and quality of th public domain itslf; th rlationship of on part of an urban ara to anothr; and th pattrn of movmnt and activity. 273 In dsigning nw dvlopmnts, considration must b givn to: i. Hight, scal and massing of buildings Dsigning a building that is appropriat to th local contxt and which dos not dominat its surroundings inappropriatly.? Dos th insistnc on ncouraging tall buildings south of Th Cut conflict with th following policis of Th Town and Country Planning (Local Planning) (England) Rgulations 2012 (3) Any policis containd in a supplmntary planning documnt must not conflict with th adoptd dvlopmnt plan. (4) Subjct to paragraph (5), th policis containd in a local plan must b consistnt with th adoptd dvlopmnt plan. (5) Whr a local plan contains a policy that is intndd to suprsd anothr policy in th adoptd dvlopmnt plan, it must stat that fact and idntify th suprsdd policy.? Officr Rspons to Rprsntation Th approach is supportd by our vidnc bas including th Blackfriars Road Urban Dsign Study which has bn prpard in accordanc with CABE and English Hritag Guidanc on Tall Buildings, In light of consultation rsponss and to add clarity to th guidanc rlating to St Gorg s Circus in SPD 5, th SPD has bn updatd to clarify that a tall building could provid a focal point at th southrn nd of Blackfriars Road up to 70m. A tall building should also sustain, nhanc or bttr rval th local hritag assts. Th GLA s rprsntation confirms that th Mayor supports th council s approach on tall buildings, but suggsts that th SPD should b mor flxibl in rlation to building hights, and that buildings in th rgion of 70/30m would b appropriat. Th council disagrs with this proposd amndmnt as it could allow buildings that ar gratr than th 70m/30m thrshold, which would b considrd inappropriat basd on our vidnc bas. As such, th council considrs SPD 5 to balanc local charactr and dvlopmnt potntial.

136 Rp Obj Rf Rf Nam Wbb r & Qunti n TRA Wbb r & Qunti n TRA Dtails of Rprsntation Dos th statd intntion in th draft SPD to allow a 70m building on top of Southwark tub station constitut a failur to comply with th following policy in ( Summary of snsitivitis in Blackfriars Road ): Nw tall building dvlopmnt should considr its rlationship to th xisting and proposd tall buildings in th mrging clustr. Nw tall buildings should provid a transition from th scal of xisting tall buildings towards lowr hight dvlopmnt in th surrounds. Southwark tub station Should provid a transition from th proposd nw scal of dvlopmnt towards lowr hight surrounds. Should considr th group of listd buildings along Blackfriars Road south of Th Cut. Should considr its rlationship to th xisting landmark of Palstra on th opposit sid of Blackfriars Road.? Why has Southwark Council not mad availabl clar visuals (photos and 3D modls) of how Blackfriars Road looks now and how it would look aftr th proposd tall buildings had bn constructd? Barratt Homs was abl to produc architct s imprssions and a larg 3D modl for its proposd plans at its xhibition arlir this yar at Erlang Hous, which is just on individual dvlopmnt; why, thn, givn th scal of th Blackfriars Road dvlopmnt, has Southwark Council not producd similar visuals and mad ths availabl to consults? Officr Rspons to Rprsntation Th guidanc st out within th SPD is consistnt with th xisting planning policy framwork of dsign, hritag and tall building policis, which includs th rlvant savd Southwark Plan policis, Cor Stratgy Policy SP12, th rlvant policis of th London Plan and th NPPF. Th approach is supportd by our vidnc bas including th Blackfriars Road Urban Dsign Study which has bn prpard in accordanc with CABE and English Hritag Guidanc on Tall Buildings, In light of consultation rsponss and to add clarity to th guidanc rlating to St Gorg s Circus in SPD 5, th SPD has bn updatd to clarify that a tall building could provid a focal point at th southrn nd of Blackfriars Road up to 70m. A tall building should also sustain, nhanc or bttr rval th local hritag assts. Th GLA s rprsntation also confirms that th Mayor supports th council s approach on tall buildings, but suggsts that th SPD should b mor flxibl in rlation to building hights, and that buildings in th rgion of 70/30m would b appropriat. Th council disagrs with this proposd amndmnt as it could allow buildings that ar gratr than th 70m/30m thrshold, which would b considrd inappropriat basd on our vidnc bas. As such, th council considrs SPD 5 to balanc local charactr and dvlopmnt potntial. Th approach is supportd by our vidnc bas including th Blackfriars Road Urban Dsign Study which has bn prpard in accordanc with CABE and English Hritag Guidanc on Tall Buildings, In light of consultation rsponss and to add clarity to th guidanc rlating to St Gorg s Circus in SPD 5, th SPD has bn updatd to clarify that a tall building could provid a focal point at th southrn nd of Blackfriars Road up to 70m. A tall building should also sustain, nhanc or bttr rval th local hritag assts Wbb In prparing th draft SPD, to what xtnt has A tall building up to 70m in hight could b appropriat at th southrn

137 Rp Obj Rf Rf Nam 9 9 r & Qunti n TRA Dtails of Rprsntation Southwark Council studid th impact of a 70m towr at St Gorg s Circus on th stting of th consrvation ara and th listd Oblisk (which is alrady a landmark historic ntranc to th approach to th City), and issus affcting quality of lif, such as loss of light? Officr Rspons to Rprsntation nd of Blackfriars Road providd that it complis with th dtaild guidanc outlind in SPD 5 and th currnt dvlopmnt plan that includs th rlvant policis of th savd Southwark Plan (2007), Cor Stratgy (2011), London Plan (2011) and othr planning documnts/guidanc, including th NPPF (2012). Th dvlopmnt plan sts out th policis for tall buildings. Th guidanc in th SPD provids dtail on how to implmnt ths dvlopmnt plan policis spcific to Blackfriars Road Wbb r & Qunti n TRA Wbb r & Qunti n TRA To what xtnt hav th following dsign principls which mrgd from th work carrid out by urban practitionrs Allis and Morrison -as publishd by Southwark Council in th Blackfriars Public Ralm Study-bn takn into account whn considring tall buildings as a stratgy in th draft SPD: o Provid a cohsiv landscaping of Blackfriars Road whilst rcognising th nd to acknowldg its diffrnt sctions. o Rcognis and rspond to th charactr and hritag of Blackfriars Road and its surroundings.? What is Southwark Council s rspons to th strong concrns xprssd by rsidnts rgarding th following ffcts of tall buildings on thir quality of lif and nvironmnt: o loss of light o loss of viws o wind tunnl ffct o lack of human scal o ovr dominanc by tall buildings of xisting buildings (spcially rsidntial) o loss of historic buildings (whr Th approach is supportd by our vidnc bas including th Blackfriars Road Urban Dsign Study which has bn prpard in accordanc with CABE and English Hritag Guidanc on Tall Buildings, In light of consultation rsponss and to add clarity to th guidanc rlating to St Gorg s Circus in SPD 5, th SPD has bn updatd to clarify that a tall building could provid a focal point at th southrn nd of Blackfriars Road up to 70m. A tall building should also sustain, nhanc or bttr rval th local hritag assts. Th principls st out in th Allis and Morrison study has informd th prparation of th SPD, spcially SPD 3: Public ralm and opn spac. Ths mattrs would b assssd at th planning application stag through th rlvant savd Southwark Plan policis, Cor Stratgy Policy 12 and th rlvant policis of th London Plan and planning rgulations. Bullt-point 14 of SPD 5 sts out furthr guidanc rgarding microclimat, whil SPD3 sts out furthr guidanc on landscaping.

138 Rp Obj Rf Rf Nam Wbb r & Qunti n TRA Wbb r & Qunti n TRA Wbb r & Qunti n TRA Dtails of Rprsntation dmolition of historic buildings is carrid out in ordr to mak way for nw buildings) o rosion of community fling o loss of small businsss? Has Southwark Council considrd an altrnativ vision for th southrn sction of Blackfriars Road, with a focus on options than simply tall buildings? 6. Build form and hritag With a prdominant mphasis on larg commrcial dvlopmnt and a clar pr-xisting tndncy to dmolish unlistd historic assts to mak room for tall buildings, th draft SPD contains no substanc rlating to how policy rquirmnts on consrving and nhancing Southwark s build form and hritag will b mt. In announcing th draft SPD to th prss on 21 Jun 2013, Councillor Ptr John said that th documnt was intndd to "giv furthr confidnc to potntial invstors and comfort to local rsidnts and businsss that w ar sking to protct and nhanc th charactr and idntity of this historic borough". Th Rvitalis Hav your say laflt (Jun 2013) stats, Our guidanc rquirs high quality nw dvlopmnt that maks a positiv contribution to local charactr and distinctivnss, including considration of th historic nvironmnt. Qustions rgarding th abov points How can Councillor Ptr John s claim that th draft SPD s intnt is to protct and nhanc th charactr and idntity of this historic borough b sn to b valid whn thr is a clar prdisposition on th part of Southwark Council to allow th dmolition of historic assts in favour of nw commrcial buildings which ar out of kping with th charactr of othr buildings Officr Rspons to Rprsntation Th Blackfriars Road SPD Sustainability Appraisal asssss th impact of th SPD in rlation to diffrnt options. It should b notd that th aim of th SPD is to provid furthr guidanc for th ara that is xprincing intns dvlopmnt prssur and avoid picmal or inappropriat dvlopmnt Th urban dsign study also asssss th impact of diffrnt building hight options along Blackfriars Road. Th SPD provids guidanc on th hritag assts and would b rad in conjunction with th xisting hritag policy framwork and dsignations, including th savd Southwark Plan policis, Cor Stratgy, London Plan and NPPF. Th potntial loss of any hritag would b assssd at th planning application stag. Th SPD provids guidanc on hritag assts and would b rad in conjunction with th xisting hritag policy framwork and dsignations, including th savd Southwark Plan policis, Cor Stratgy, London Plan and NPPF. Th potntial loss of any hritag would b assssd at th planning application stag.

139 Rp Obj Rf Rf Nam Dtails of Rprsntation in an ara? Rcnt xampls includ: o Th dmolition of a suprbly rstord Victorian warhous at 1 Valntin Plac which was in us as businss prmiss, so that th mpty land could b usd as a dpot yard to srvic th building of a nw svnstory building (107 Blackfriars Road) which, by Southwark Council s own admission, is so out of kping with th surrounding buildings that in March 2012 it rfusd to includ this nw building in th nwly dsignatd Valntin Plac Consrvation Ara. o Th dcision of th planning committ on 2 Sptmbr 2013 to approv th dmolition of an 18th cntury public hous at 173 Blackfriars Road and th adjacnt Victorian St Gorg s Mansions at Blackfriars Road in favour of a tn-story modrn building which will offr largly B1 offic spac, privat accommodation, and a quota of affordabl housing that is blow th rquird prcntag. In th light of this tndncy towards th rmoval of unlistd hritag buildings in favour of commrcial dvlopmnt, ar Southwark Council s planning committ s ovrall dcisions in conflict with th following policis: London Plan: 1.44 protcting and nhancing what is distinctiv about th city and its nighbourhoods, scuring a sns of plac and blonging through high quality architctur and dsign that sits wll with its surroundings. and on of th ky statd objctivs of th Mayor that London should b 4. A city that dlights th snss and taks car ovr its buildings and strts, having th bst of modrn architctur whil also making th most of London s built hritag Southwark Plan: SP 13 Dsign and hritag All dvlopmnts should prsrv or nhanc th charactr and vitality of Southwark through xcllnc in dsign, and th protction and nhancmnt of th historic nvironmnt.? Officr Rspons to Rprsntation

140 Rp Obj Rf Rf Nam Wbb r & Qunti n TRA Wbb r & Qunti n TRA Dtails of Rprsntation To what xtnt dos th draft SPD comply with th following point in Th National Planning Policy Framwork (March 2012): 12. Consrving and nhancing th historic nvironmnt 126. Local planning authoritis should st out in thir Local Plan a positiv stratgy for th consrvation and njoymnt of th historic nvironmnt, including hritag assts most at risk through nglct, dcay or othr thrats. In doing so, thy should rcognis that hritag assts ar an irrplacabl rsourc and consrv thm in a mannr appropriat to thir significanc. In dvloping this stratgy, local planning authoritis should tak into account: th dsirability of sustaining and nhancing th significanc of hritag assts and putting thm to viabl uss consistnt with thir consrvation; th widr social, cultural, conomic and nvironmntal bnfits that consrvation of th historic nvironmnt can bring; th dsirability of nw dvlopmnt making a positiv contribution to local charactr and distinctivnss; and opportunitis to draw on th contribution mad by th historic nvironmnt to th charactr of a plac.? Why at planning committ lvl dos thr not appar to b a solid st of guidlins on what compriss xmplary dsign in a building? For xampl, at th planning committ mting on hld at Tooly Strt on 3 Sptmbr 2013, a numbr of councillors rpatdly askd th dvloprs and planning dpartmnt rprsntativs to xplain why th proposd building was of xmplary dsign ; this qustion faild rpatdly to b answrd to th satisfaction of thos posing th qustion and no-on rfrrd to th availability of an agrd st of guidlins on th ky critria for xmplary dsign. Givn this situation, ar th planning committ procdurs in conflict with th following policis in th Officr Rspons to Rprsntation Th guidanc st out within th SPD is consistnt with th xisting planning policy framwork of dsign, hritag and tall building policis, which includs th rlvant savd Southwark Plan policis, Cor Stratgy Policy SP12, th rlvant policis of th London Plan and th NPPF. Th rprsntation rfrs to planning committ dcision-making and not th SPD. It should b notd that th dfinition of xmplary dsign is st out in th adoptd Rsidntial Dsign Standards SPD (2012). An indpndnt dsign rviw panl is also usd for th largr schms.

141 Rp Obj Rf Rf Nam Wbb r & Qunti n TRA Wbb r & Qunti Dtails of Rprsntation Southwark Plan: 3.12 Quality in dsign 266 Dvlopmnts should achiv a high quality of both architctural and urban dsign, nhancing th quality of th built nvironmnt in ordr to crat attractiv, high amnity nvironmnts popl will choos to liv in, work in and visit. Nw buildings and altrations to xisting buildings should mbody a crativ and high quality appropriat dsign solution, spcific to thir sit s shap, siz, location and dvlopmnt opportunitis and whr applicabl, prsrving or nhancing th historic nvironmnt. and 3.15 Consrvation of th historic nvironmnt 283 Dvlopmnt should prsrv or nhanc th spcial intrst or historic charactr or apparanc of buildings or aras of historical or architctural significanc. Planning proposals that hav an advrs ffct on th historic nvironmnt will not b prmittd.? Do th abov-mntiond potntial conflicts with policy constitut a gnral failur to comply with th following points in Th Town and Country Planning (Local Planning) (England) Rgulations 2012: Form and contnt of local plans and supplmntary planning documnts: gnral 8... (3) Any policis containd in a supplmntary planning documnt must not conflict with th adoptd dvlopmnt plan. (4) Subjct to paragraph (5), th policis containd in a local plan must b consistnt with th adoptd dvlopmnt plan. (5) Whr a local plan contains a policy that is intndd to suprsd anothr policy in th adoptd dvlopmnt plan, it must stat that fact and idntify th suprsdd policy.? Hotls Local popl, who for th past 15 yars hav had to accpt a vry rapid rat of building around thm, ar vry unhappy about th numbr of larg Officr Rspons to Rprsntation Th SPD accords with th rquirmnts of th Th Town and Country Planning (Local Planning) (England) Rgulations It is consistnt with and not in conflict with th adoptd dvlopmnt plan. Th SPD and figur 3 of th SPD clarly sts out that th SPD provids guidanc on our dvlopmnt plan: th London Plan, Cor Stratgy and savd Southwark Plan. Th London Plan sks to achiv 40,000 nt additional hotl bdrooms by 2031.Th stimat of th approximat nt and gross hotl rooms rquird ovr th priod for Southwark, as st

142 Rp Obj Rf Rf Nam Dtails of Rprsntation Officr Rspons to Rprsntation n TRA hotls constructd, with som proprtis now bing sandwichd btwn larg hotls ithr sid. Dspit bing nar a major railway station (Watrloo) this is not a purly commrcial cntr, and th fling from rsidnts who cam to this ara whn no-on ls out in th GLA s Hotl Dmand Study, is basd on assssmnt of factors including transport links to cntral London and connctions to airports, proximity of tourist attractions/businss locations, cafs and rstaurants in th ara, night tim conomy, cultural facilitis and attractions, and rgnration initiativs and sit availability. Th wantd to liv hr and built up thriving communitis is forcast for Southwark should b tratd as indicativ only, and local that w hav nough hotls now and that this ara has circumstancs should also b factord in. It is important to considr don its part in contributing to th 2026 targt rooms quota. During th past tn yars thr has bn an xponntial incras in th numbr of larg hotls in th SPD ara: H10, Watrloo Road (13 storys, 177 rooms) Ibis, Blackfriars Road (7 storys, 297 rooms) Travlodg, Union St (5 storys, 202 rooms) Travlodg, Baron s Plac (5 storys, 279 rooms) Hilton, Watrloo Road (9 storys, 278 rooms) undr that th SPD ara is within th Cntral Activitis Zon, Banksid, Borough and London Bridg Opportunity Ara and part of th Elphant and Castl Opportunity Ara which ar aras promotd in th London Plan to accommodat stratgically important hotl provision. Arts, cultural and tourism activitis hav flourishd in Southwark in th last dcad, particularly in th Stratgic Cultural Ara, which is within th CAZ. Banksid, Borough and London Bridg has consquntly xprincd a growth in th numbr of hotls to construction. Pag 9 of th draft SPD stats, W will support this incrasing visitor conomy. Th SPD2 provids guidanc look at ways to control licnsd prmiss and hotls to to support Cor Stratgy policy 10 Jobs and businss which sts out nsur a good balanc of uss and protct th charactr of th rsidntial aras. Th sitting of th Travlodg (5 storys, 279 rooms) in Baron s Plac and th Hilton (9 storys, 278 rooms) on Watrloo Road has ffctivly rsultd in Quntin Hous, a rsidntial block built in th 1950s, bcoming sandwichd btwn two vry larg hotls. Th draft SPD contains a cas study (CitiznM) which appars to suggst that hotls can asily dvlop a th council will allow th dvlopmnt of hotls within th town cntrs, th stratgic cultural aras, and placs with good accss to public transport srvics, providing that ths do not harm th local charactr. Policy 10 and SPD 2 ar also supplmntd by th savd policy 1.12 of th Southwark Plan which addrsss visitor accommodation. Nw hotl proposals in th ara will b assssd against ths rlvant planning policis and a considration of th impact upon local amnity and th balanc of land uss will also b takn into account. SPD2 ncourags any nw hotl proposal to cultur of offring ancillary srvics, including facilitis includ ancillary facilitis. This will hlp to nsur that ths for non-gusts, Howvr, as a rsidnt of this ara, I dvlopmnts ar mor intgratd into th strt scn and provid a happn to know CitiznM and its thos xtrmly wll widr bnfit. Th inclusion of th cas study on Citizn M hotl on and in my xprinc it is absolutly uniqu in Lavington Strt provids contxt by providing an xampl of how a providing a highly wlcoming walk-in spac for nongusts, hotl can offr a rang of uss and incorporat activ frontags. which is rootd in its xmplary company cultur and staff attitud; I hav nvr sn any othr hotl in my local ara us this particular typ of approach. Qustions rgarding th abov points Wbb Is th xponntial ris in th building of hotls in Th SPD 2 provids guidanc to support Cor Stratgy policy 10

143 Rp Obj Rf Rf Nam 9 9 r & Qunti n TRA Wbb r & Qunti n TRA Wbb r & Qunti n TRA Dtails of Rprsntation Officr Rspons to Rprsntation conflict with th draft SPD statmnt (pag 9), W will Jobs and businss which sts out th council will allow th look at ways to control licnsd prmiss and hotls to dvlopmnt of hotls within th town cntrs, th stratgic cultural nsur a good balanc of uss and protct th aras, and placs with good accss to public transport srvics, charactr of th rsidntial aras? providing that ths do not harm th local charactr. Policy 10 and SPD 2 ar also supplmntd by th savd policy 1.12 of th Southwark Plan which addrsss visitor accommodation. Nw hotl proposals in th ara will b assssd against ths rlvant planning policis and a considration of th impact upon local amnity and th balanc of land uss will also b takn into account. Dos th sitting of two larg hotls ithr sid of Quntin Hous in Gray Strt constitut a failur to mt th following promis st out in Southwark Council s A fairr futur for all in Southwark Intrim prformanc rport 2012/13 : Trating rsidnts as w would wish mmbrs of our own familis to b tratd.? Is th ncouragmnt of mor hotl building, particularly of th typ witnssd in Watrloo Road (Hilton) and Baron s Plac (Travlodg) in conflict with policy 1.12 ( Hotls and visitor accommodation ) in th Southwark Plan: 193 Hotls and visitor accommodation will not b prmittd whr thy would rsult in a loss of xisting rsidntial accommodation, or an ovr dominanc of visitor accommodation in th locality.? If so, dos this also constitut a failur to comply with th following points in Th Town and Country Planning (Local Planning) (England) Rgulations 2012: Form and contnt of local plans and supplmntary planning documnts: gnral 8... (3) Any policis containd in a supplmntary planning documnt must not conflict with th adoptd dvlopmnt plan. (4) Subjct to paragraph (5), th Th SPD provids furthr guidanc to xisting planning policis in our Cor Stratgy and savd Southwark Plan. It dos not rpat borough wid policis and so th SPD must b rad alongsid our othr planning documnts. Th guidanc focuss primarily on Blackfriars Road, whr most of th chang will occur. Th mrging vision aspirs for Blackfriars Road to hav its own distinct idntity as a livly and vibrant ara, bcoming an xciting plac whr popl want to work, liv and visit. Th spcific dtails for th assssmnt of th hotl dvlopmnts within individual applications nds to b rfrrd to within th Planning Committ rports. Th SPD provids furthr guidanc to xisting planning policis in our Cor Stratgy and savd Southwark Plan. It dos not rpat borough wid policis and so th SPD must b rad alongsid our othr planning documnts. Th guidanc focuss primarily on Blackfriars Road, whr most of th chang will occur. Th SPD2 provids guidanc to support Cor Stratgy policy 10 Jobs and businss which sts out th council will allow th dvlopmnt of hotls within th town cntrs, th stratgic cultural aras, and placs with good accss to public transport srvics, providing that ths do not harm th local charactr. Policy 10 and SPD 2 ar also supplmntd by th savd policy 1.12 of th Southwark Plan which addrsss visitor accommodation. Nw hotl proposals in th ara will b assssd against ths rlvant planning policis and a considration of th impact upon local amnity and th balanc of land uss will also b takn into account.

144 Rp Obj Rf Rf Nam Wbb r & Qunti n TRA Wbb r & Qunti n TRA Dtails of Rprsntation policis containd in a local plan must b consistnt with th adoptd dvlopmnt plan. (5) Whr a local plan contains a policy that is intndd to suprsd anothr policy in th adoptd dvlopmnt plan, it must stat that fact and idntify th suprsdd policy.? What is th valu of including a cas study in th draft SPD about th CitiznM hotl whn it has a uniqu thos rootd in its company cultur, and whn Southwark Council has no powrs to nforc a similar cultur at othr hotls?. Rsidnts Thr ar larg numbrs of xisting rsidnts in th proposd SPD ara, particularly south of Th Cut. Dspit this, th draft SPD taks no account of ths xisting communitis and thir nds. In announcing th draft SPD to th prss on 21 Jun 2013, Councillor Ptr John said that th documnt was intndd to "giv furthr confidnc to potntial invstors and comfort to local rsidnts and businsss that w ar sking to protct and nhanc th charactr and idntity of this historic borough". Th draft SPD sts out our aspirations for growth, hlping to mak Blackfriars Road a dstination whr popl want to liv, work and visit. Th languag of th draft SPD frquntly rfrs to making Officr Rspons to Rprsntation Th SPD provids furthr guidanc to xisting planning policis in our Cor Stratgy and savd Southwark Plan. It dos not rpat borough wid policis and so th SPD must b rad alongsid our othr planning documnts. Th guidanc focuss primarily on Blackfriars Road, whr most of th chang will occur. Th SPD2 provids guidanc to support Cor Stratgy policy 10 Jobs and businss which sts out th council will allow th dvlopmnt of hotls within th town cntrs, th stratgic cultural aras, and placs with good accss to public transport srvics, providing that ths do not harm th local charactr. Policy 10 and SPD 2 ar also supplmntd by th savd policy 1.12 of th Southwark Plan which addrsss visitor accommodation. Nw hotl proposals in th ara will b assssd against ths rlvant planning policis and a considration of th impact upon local amnity and th balanc of land uss will also b takn into account. Th SPD is intndd to bnfit a wid rang of groups including xisting and nw rsidnts. Th mrging vision has bn updatd to mak this clarr. Th SPD has also bn updatd within th supporting txt to SPD 2: Mixd us town cntr, that th SPD ara is mixd with both commrcial and rsidntial dvlopmnt. Th SPD and othr planning policy documnts also provid th framwork for th provision of infrastructur to support dvlopmnt which will b usd by both nw and xisting rsidnts. SPD 2: Mixd us town cntr sts out that w will support th provision of nw social infrastructur and community facilitis as part of mixd us dvlopmnts.

145 Rp Obj Rf Rf Nam Dtails of Rprsntation Blackfriars Road a plac whr popl want to liv, work and visit (.g. in point 1.1.2). Howvr, nowhr in th ntir draft SPD is thr any rfrnc to th fact that th SPD ara in particular south of Th Cut is alrady hom to larg and long-stablishd rsidntial populations and small businss ownrs who hav bn in th ara for many yars and hav mad a major contribution to its charactr by building up thriving rsidntial and businss communitis. Th draft SPD maks no rfrnc to th fact that thr ar major diffrncs btwn th aras to th north and south of Th Cut: th northrn sction is clarly prdominantly commrcial (offic spac and hotls) with small pockts of rsidntial, whil th southrn sction is prdominantly rsidntial and includs also a rang of small businsss and a small numbr of largr businsss. Long-stablishd rsidntial populations in th sction south of Th Cut ar locatd at Nlson Squar, Pakman Hous, Blackfriars Road (Gorgian houss), Grat Surry Strt, Bridghous Court, Wbbr Row Estat, Quntin Hous Estat, Brookwood Hous, Silx Strt, Boyfild Strt, Library Strt, Pabody Squar, Gladston Strt, and Cooprs Clos. Ths rsidnts ar part of th fabric and charactr of this particular sction of Blackfriars Road. Th draft SPD contains 15 mntions of th word rsidnts but nowhr is a distinction mad as to whthr this mans xisting rsidnts, nw rsidnts, or both. Th lack of provision for xisting rsidnts within th draft SPD suggsts that its authors hav not considrd thir nds and hav not takn into account th findings of rsarch such as th Blackfriars Public Ralm Study, and that priority has bn givn to commrcial dvlopmnt ovr th nds of rsidnts. Whr rfrnc is mad to issus that Officr Rspons to Rprsntation SPD 3: Public ralm and opn spac rfrs to th continud protction of th thr protctd opn spacs and ncouraging furthr linkags and nw spacs. Sction 4 of th SPD rfrs spcifically to infrastructur, crossing rfrring to th community infrastructur lvy (CIL) and sction 106 planning obligations to hlp nsur th dlivry of ky infrastructur to mitigat th impact of dvlopmnt. Infrastructur is covrd within borough-wid planning documnts with th ovrarching policy 14 of th Cor Stratgy rcognising that nw dvlopmnt in th borough nds to b supportd by adquat infrastructur, including social, nvironmntal and physical infrastructur. Th borough s Infrastructur Plan, idntifis stratgic infrastructur which is ndd to support growth and dvlopmnt in th borough ovr th liftim of th Cor Stratgy ( ). Whr possibl it idntifis th cost of infrastructur to providd, any committd sourcs of funding which will b usd to dlivr it and th organis rsponsibl. It also idntifis th funding gap i.. th gap btwn known commitmnts and th total cost of infrastructur rquird. Whn it is adoptd, Southwark s CIL will b usd to contribut towards bridging this funding gap. Funds armarkd for infrastructur in th Council s capital invstmnt programm also will hlp to improv infrastructur provision. Th council ar currntly prparing our draft community infrastructur charging schdul and an updatd sction 106 SPD. Adoption is plannd for It is appropriat to look at th provision of infrastructur at a borough-wid lvl through ths ddicatd documnts rathr than through th Blackfriars Road SPD.

146 Rp Obj Rf Rf Nam Wbb r & Qunti n TRA Wbb r & Qunti n TRA Wbb r & Qunti n TRA Dtails of Rprsntation rlat to th daily nds of rsidnts and local workrs,.g. infrastructur, accss to small businsss, opn spacs, this is don without any actual dtail on th what, whr and how of achiving this. Qustions rgarding th abov points What calculation basis was usd for Councillor Ptr John s dscription of th SPD ara having pockts of rsidntial whn th draft SPD was launchd on 21 Jun 2013, and how can such a dscription b sn to b valid for th ara south of Th Cut? To what xtnt has Southwark Council considrd th larg xisting rsidntial communitis, spcially south of Th Cut, in drafting th SPD, and thir clar contribution to th xisting charactr of Blackfriars Road? A town cntr is usually charactrisd by a prdominanc of offic and rtail spac, and small numbrs of rsidnts (who gnrally nd a with a highr-than-avrag lvl of disposabl incom in ordr to afford cntrally locatd accommodation). Givn th larg numbrs of local rsidnts south of Officr Rspons to Rprsntation Th SPD is intndd to bnfit a wid rang of groups including xisting and nw rsidnts. Th mrging vision has bn updatd to mak this clarr. Th SPD has also bn updatd within th supporting txt to SPD 2: Mixd us town cntr, that th SPD ara is mixd with both commrcial and rsidntial dvlopmnt. Th SPD sks to mt th nds of rsidnts whilst also managing th prssur for nw dvlopmnt. Th SPD has bn updatd to mak it clarr that th mrging vision and th SPD sks to nsur that dvlopmnt mts th nds of xisting and nw rsidnts whilst also attracting nw dvlopmnt. Rsidnts will bnfit from th incras rang of uss including mor shops, srvics and businsss along th Blackfriars Road. Th SPD is intndd to bnfit a wid rang of groups including xisting and nw rsidnts. Th mrging vision has bn updatd to mak this clarr. Th SPD has also bn updatd within th supporting txt to SPD 2: Mixd us town cntr, that th SPD ara is mixd with both commrcial and rsidntial dvlopmnt. Th SPD sks to mt th nds of rsidnts whilst also managing th prssur for nw dvlopmnt. Th SPD has bn updatd to mak it clarr that th mrging vision and th SPD sks to nsur that dvlopmnt mts th nds of xisting and nw rsidnts whilst also attracting nw dvlopmnt. Rsidnts will bnfit from th incras rang of uss including mor shops, srvics and businsss along th Blackfriars Road. Th Blackfriars Road SPD ara is locatd within th Borough and Banksid district town cntr which is idntifid in th Cor Stratgy s hirarchy of town cntrs. Policy 3 of th Cor Stratgy stats that w will support th provision of nw shopping spac in th ara, and this should includ both food and non-food spac and aim to mt th nds of local rsidnts, as wll as visitors and businsss. W hav

147 Rp Obj Rf Rf Nam Wbb r & Qunti n TRA Wbb r & Qunti n TRA Dtails of Rprsntation Th Cut, is th vision of a mixd us town cntr rally an appropriat on for this part of Blackfriars Road? To what xtnt hav th following principls in th Allis and Morrison Blackfriars Road Public Ralm Study which rlat to quality of nvironmnt for rsidnts bn takn into account in th draft SPD: o Enhanc and xtnd grnry to provid visual and acoustic softning, and prvnt watr run off; o Rcognis and rspond to th charactr and hritag of Blackfriars Road and its surroundings, with ky anchors bing Pabody Estat, th viaduct, community gardns and public spac, Christ Church and its yard, and th rivrfront; o Landscaping along th strt should rspond to ths buildings, matrials and provid a suitabl stting for thm. o Provid a cohsiv landscaping of Blackfriars Road whilst rcognising th nd to acknowldg its diffrnt sctions? Is th non-acknowldgmnt of th xisting rsidntial population and th lack of substanc rgarding how and whr infrastructur will b providd in conflict with th statd aim rgarding vision in th draft SPD point 2.1.1: To hlp crat a succssful plac whr popl want to work, liv and visit, w nd a vision which rflcts th nds and aspirations of th community, businsss, rsidnts, landownrs and local stakholdrs and th following cor principl containd in Southwark Council s A fairr futur for all in Southwark Intrim prformanc rport 2012/13 : Trating rsidnts as w would wish mmbrs of our own familis to b tratd.? Officr Rspons to Rprsntation amndd SPD 2 to mak it clar that spac for town cntr uss should b dvlopd alongsid rsidntial dvlopmnt and businss uss. SPD2 also sts out that w will considr th impact of all nw proposals on th ovrall mix of uss in th ara and also on local amnity. Th principls st out in th Allis and Morrison study has informd th prparation of th SPD. Th SPD is intndd to bnfit a wid rang of groups including xisting and nw rsidnts. Th mrging vision has bn updatd to mak this clarr. Th SPD has also bn updatd within th supporting txt to SPD 2: Mixd us town cntr, that th SPD ara is mixd with both commrcial and rsidntial dvlopmnt. Th SPD sks to mt th nds of rsidnts whilst also managing th prssur for nw dvlopmnt. Th SPD has bn updatd to mak it clarr that th mrging vision and th SPD sks to nsur that dvlopmnt mts th nds of xisting and nw rsidnts whilst also attracting nw dvlopmnt. Rsidnts will bnfit from th incras rang of uss including mor shops, srvics and businsss along th Blackfriars Road Wbb In placing th mphasis on commrcial dvlopmnt It is important to considr that th SPD provids furthr guidanc to

148 Rp Obj Rf Rf Nam 9 9 r & Qunti n TRA Dtails of Rprsntation Officr Rspons to Rprsntation ovr rsidnts nds, is th draft SPD in conflict with xisting planning policis in our Cor Stratgy and savd Southwark th following policis du to th hug impact of such Plan. It dos not rpat borough wid policis and so th SPD must larg-scal commrcial building on th distinctivnss b rad alongsid our othr planning documnts. Th guidanc of xisting nighbourhoods and factors such as loss of focuss primarily on Blackfriars Road, whr most of th chang will light, wind tunnl ffct, rosion of communitis, loss occur. SPD4 Built form and hritag addrsss th importanc of of small businsss, lack of affordabl housing and dvlopmnts to provid a high quality of dsign and architctur to lack of human scal in buildings: London Plan ( Quality nsur that th civic charactr and scal of th historic nvironmnt is of Lif ): 1.44 At its bst, London can provid what is sustaind or nhancd. Th supporting txt to SPD4 highlights th amongst th highst quality of lif to b found ara has having an xisting mix of charactr, scal and massing of anywhr. Unfortunatly, this is not th univrsal buildings, and that nw dvlopmnt must also considr th distinctiv xprinc of Londonrs, as indicators lik th charactr and contxt of th surroundings. In addition, SPD 5 Building disparitis in lif xpctancy in diffrnt placs across hights rfrs to tall buildings allowing adquat sunlight and daylight th city show. Thr is also a prcivd tnsion into strts, public spacs and courtyards, as wll as nsuring thr is btwn th dmands of growth and th conditions for no harmful microclimat and shadowing ffcts on local amnity. Th a good and improving quality of lif, and a concrn Blackfriars Road SPD ara is also locatd within th Borough and about th loss of things that hav mad living in Banksid district town cntr which is idntifid in th Cor Stratgy s London and its nighbourhoods a distinctiv hirarchy of town cntrs. Policy 3 of th Cor Stratgy stats that w xprinc.? 1.56 Th Mayor s commitmnt to will support th provision of nw shopping spac in th ara, and this nsuring all Londonrs can njoy a good, improving should includ both food and non-food spac and aim to mt th and sustainabl quality of lif now, ovr th priod to nds of local rsidnts, as wll as visitors and businsss. W hav 2031 and into th futur, undrpins th vision and amndd SPD 2 to mak it clar that spac for town cntr uss objctivs. Th quality of lif that Londonrs should b dvlopd alongsid rsidntial dvlopmnt and businss xprinc whn living, working, visiting and moving uss. SPD2 also sts out that w will considr th impact of all nw around London is fundamntal to how thy fl about proposals on th ovrall mix of uss in th ara and also on local th city and to how th capital is prcivd from amnity, and th charactr of th ara. W hav addd additional txt outsid. Th dcisions w mak about our city now will into th mrging vision for Blackfriars Road to mak clar that much shap th quality of lif of thos who com aftr us of th charactr and historic valu of th surrounding ara, particularly and thir viw of how succssful w hav bn in our th consrvation aras and listd buildings will continu to b stwardship of London.? Southwark Plan: 9.9 protctd and nhancd. Nighbourhood Aras 61 Nighbourhoods ar important bcaus shopping and commrcial cntrs oftn dfin a nighbourhood, providing a focus for th community. Thy provid a wid rang of shops and othr srvics usd by local communitis. Gnrally thr ar fw larg dvlopmnt sits within th nighbourhood cntrs. Th focus of planning

149 Rp Obj Rf Rf Nam Wbb r & Qunti n TRA Wbb r & Qunti n TRA Dtails of Rprsntation guidanc is on protcting, improving, and bringing back into us rtail and rsidntial uss, spcially abov shops.? Do th abov-mntiond potntial conflicts with policy constitut a failur to comply with th following points in Th Town and Country Planning (Local Planning) (England) Rgulations 2012: Form and contnt of local plans and supplmntary planning documnts: gnral 8... (3) Any policis containd in a supplmntary planning documnt must not conflict with th adoptd dvlopmnt plan. (4) Subjct to paragraph (5), th policis containd in a local plan must b consistnt with th adoptd dvlopmnt plan. (5) Whr a local plan contains a policy that is intndd to suprsd anothr policy in th adoptd dvlopmnt plan, it must stat that fact and idntify th suprsdd policy.? 9. Businsss Th draft SPD focuss prdominantly on larg businsss and maks almost no provision for small businsss. Small businsss ar alrady losing thir prmiss du to this focus on larg commrcial dvlopmnt and rlatd rnt riss, dspit having opratd succssfully in th ara for many yars and mad a hug contribution to th divrs businss charactr of th ara and providing an xcllnt rang of srvics to th businss and rsidntial community. Th Rvitalisd Hav your say laflt (Jun 2013) stats that th draft SPD...focuss on ncouraging flxibl spac for a rang of diffrnt businsss, hlping both small and largr businsss bnfit from this cntral London location and its grat transport links. On pag 11 of th draft SPD, rfrnc is mad to Encouraging flxibl businss us. On pag 11 of th draft SPD, Southwark Council stats, W will work with Ntwork Officr Rspons to Rprsntation Th SPD accords with th rquirmnts of th Town and Country Planning (Local Planning) (England) Rgulations It is consistnt with and not in conflict with th adoptd dvlopmnt plan and th NPPF. Th SPD sts out that it provids furthr guidanc to xisting planning policis in th dvlopmnt plan: th London Plan, Cor Stratgy and savd Southwark Plan. It dos not rpat borough wid policis and th SPD must b rad alongsid othr planning documnts. In accordanc with th Cor Stratgy, th SPD ncourags th provision of flxibly dsignd small businss spac. W hav insrtd additional txt to bullt 1 of SPD1 to add som furthr clarification. This includs ncouraging th provision of small and start-up businsss in th ara. Bullt 2 of SPD1 ritrats borough wid planning policy of rquiring th rtntion or rplacmnt of businss floorspac, and this will continu to b on of a numbr of prioritis for th council to nsur that th concntration of businss floorspac in th ara is maintaind. Th supporting txt outlins borough wid policy on small businss spac, including mploymnt spac availabl within th railway archs. Ths spacs can b usd for a varity of mploymnt opportunitis. W hav also addd additional rfrnc into th supporting txt rgarding th savd Southwark Plan Policy 1.5 in ordr to highlight that this policy aims to protct small businss units in proposals for rdvlopmnt or chang of us of mploymnt sits, by rquiring th quivalnt provision for small units within th rplacmnt floorspac, subjct to xcption critria. W hav also insrtd additional txt to bullt 1 of SPD2 to ncourag th flxibl

150 Rp Obj Rf Rf Nam Wbb r & Qunti n TRA Dtails of Rprsntation Rail to rfurbish spac undr railway archs to provid a rang of uss including small businsss, shops, cafs and rstaurants. Howvr, rcnt vnts at planning committ lvl hav shown a complt disrgard for th principl of ncouraging and hlping small businsss. Prim xampls of this ar: o Th dcision in August to allow Ntwork Rail to incras rnts in Union Strt to such an xtnt that longstablishd and succssful small businsss will b forcd to lav thir prmiss. Th planning committ votd by a majority of on to ovrrid th hug opposition to this mov which had bn voicd by th dputy ladr of th Libral Dmocrat party, Cathdral ward councillors, and mor than 8,000 signatoris of a ptition. o Four small businsss (a caf, a dry claning company, a nwsagnt and a historic public hous) at Blackfriars Road and 173 Blackfriars Road, which for many yars hav providd highly usful srvics to th local community of rsidnts and workrs, will los thir prmiss du to dmolition of th xisting buildings and th dvloprs stratgy to construct a nw building which will offr mainly B1 us at ground floor lvl this dspit strong opposition from businsss, local rsidnts and ward councillors. Qustions rgarding th abov points Givn th rcnt vnts rgarding small businsss in Union Strt and Blackfriars Road, how can th statd aims in th draft SPD (...focuss on ncouraging flxibl spac for a rang of diffrnt businsss, hlping both small and largr businsss bnfit from this cntral London location and its grat transport links and Encouraging flxibl businss us ) b considrd to b valid? Officr Rspons to Rprsntation dsign of nw unit sizs for nw town cntr us in nw mixd us dvlopmnt. Th assssmnt and dtail of th Blackfriars Road planning application is availabl in th Planning Committ rport which is availabl in th link blow. WRAP&RIPNAME=Root.PgRsultDtail&ThSystmky= It is important to considr that th SPD provids furthr guidanc to xisting planning policis in our Cor Stratgy and savd Southwark Plan. It dos not rpat borough wid policis and so th SPD must b rad alongsid our othr planning documnts. Th SPD supports th provision of flxibl small businss spac and planning applications nd to addrss th rquirmnts in our adoptd policis and guidanc, and st out appropriat justification for a dvlopmnt schm Wbb If Southwark Council s claim on pag 11 of th draft SPD 1: Businss spac sts out guidanc in supporting th us of

151 Rp Obj Rf Rf Nam 3 9 r & Qunti n TRA Wbb r & Qunti n TRA Wbb r & Qunti n TRA Wbb r & Qunti n TRA Dtails of Rprsntation SPD to b working with Ntwork Rail to provid a rang of uss including small businsss.. is tru, why did it agr at planning committ lvl to a Ntwork Rail stratgy that would invitably s th rmoval of th xisting small businsss from Union Strt? What dos Southwark Council propos to do in trms of crating implmntabl policy to nsur that small businsss ar protctd from landownrs imposing unrasonabl rnt incrass which ultimatly forc ths small businsss out of thir prmiss in ordr to mak way for larg companis with th walth to afford rnts for B1 us? Why is Southwark Council not working with Ntwork Rail to nsur that th lattr maks a firm commitmnt to providing flxibl spac and rnts? Dos th loss of small businsss in Union Strt and at Blackfriars Road and 173 Blackfriars Road constitut a failur to comply with th following policis in th Southwark Plan: 10.2 Tackling povrty and ncouraging walth cration 69 Thr ar narly 11,000 businsss in Southwark of which 9,000 ar small businsss. Ths ar vry divrs in thir natur and rflct th social and thnic divrsity of th borough. Th prsnc of a larg numbr of vry divrs small businsss hlps to bring local opportunitis to popl in th mor dprivd parts of th borough. Th prsnc of small businsss also rflcts an ntrprnurial cultur and th importanc of th rol of businss start-up and slf mploymnt as an ffctiv mans for many of ovrcoming th barrirs to work and providing a way out of povrty. 71 Tackling povrty is on of th fiv prioritis of th Officr Rspons to Rprsntation railway archs for a rang of businss us including small businss spac, crativ and cultural industris, light industrial and appropriat A or D class uss. Th supporting txt has bn mad clarr to cross rfr to savd Southwark Plan policy 1.5 which also aims to protct small businss units in proposals or rdvlopmnt of chang of us of mploymnt sits. In accordanc with th Cor Stratgy Policy 10, th SPD ncourags th provision of flxibly dsignd nw businss floorspac in a rang of unit sizs. This includs small offic/studio/workshop businss spac. Th SPD also ritrats th rquirmnt for th rtntion or rplacmnt of xisting businss spac in dvlopmnts to mt th nds of th SE1 offic markt. This is subjct to xcption critria st out in savd Southwark Plan policy 1.4. Thr is no particular vidnc that subsidisd businss spac is rquird at th momnt. Th council will continu to work with Ntwork Rail to nsur dvlopmnt is in lin with our vision, policis and guidanc for th ara. Th council s Economic Wll-bing Stratgy ( ) sts out what w want to achiv btwn now and 2020, and how w aim to work across th Council and with our partnrs in th privat, public and voluntary sctors in ordr to mak Southwark a plac: whr popl, spcially our young popl, ar quippd with th skills and ambition to mak th most of our cntral London location; whr businsss grow and prospr; whr town cntrs and high strts thriv and whr our rsidnts ar financially indpndnt. In accordanc with th Cor Stratgy Policy 10 and in support of th objctivs of th Economic Wll-bing Stratgy, th SPD ncourags th provision of flxibly dsignd nw businss floorspac in a rang of unit sizs. This includs small offic/studio/workshop businss spac. Th SPD also ritrats th rquirmnt for th rtntion or rplacmnt of xisting businss spac in dvlopmnts to mt th nds of th SE1 offic markt. This is subjct to xcption critria st out in savd Southwark Plan policy 1.4.

152 Rp Obj Rf Rf Nam Wbb r & Qunti n TRA Wbb r & Qunti n TRA Dtails of Rprsntation Southwark Community Stratgy. On of th main ways in which this will b achivd is to continu to ncourag walth cration and crat mor jobs. This is dvlopd in Southwark s Entrpris Stratgy which has four main objctivs: 1. To build an ntrprnurial cultur 2.To rtain and support xisting businsss and promot inward invstmnt? 3. To nhanc ntrpris opportunitis in th ky businss districts and town cntrs and 72 Th Southwark Plan provids th land us and dvlopmnt policis to support this. It sks to maintain th provision of a rang of businss prmiss to suit th nds of all businss sctors, including small businsss.? Do th abov-mntiond potntial conflicts with policy constitut a failur to comply with th following points in Th Town and Country Planning (Local Planning) (England) Rgulations 2012: Form and contnt of local plans and supplmntary planning documnts: gnral 8... (3) Any policis containd in a supplmntary planning documnt must not conflict with th adoptd dvlopmnt plan. (4) Subjct to paragraph (5), th policis containd in a local plan must b consistnt with th adoptd dvlopmnt plan. (5) Whr a local plan contains a policy that is intndd to suprsd anothr policy in th adoptd dvlopmnt plan, it must stat that fact and idntify th suprsdd policy.? 10. Affordabl housing Official policis which sit abov th draft SPD clarly acknowldg th nd for local councils to provid sufficint affordabl housing so that popl from all walks of lif can continu to liv in aras such as Blackfriars Road. Dspit this, th draft SPD contains an xtrmly worrying amount of dtail on th provision of such housing. In th 34-pag draft SPD thr is on mntion of affordabl housing: W Officr Rspons to Rprsntation Th SPD accords with th rquirmnts of th Town and Country Planning (Local Planning) (England) Rgulations It is consistnt with and not in conflict with th adoptd dvlopmnt plan and th NPPF. Th SPD sts out that it provids furthr guidanc to xisting planning policis in th dvlopmnt plan: th London Plan, Cor Stratgy and savd Southwark Plan. It dos not rpat borough wid policis and th SPD must b rad alongsid othr planning documnts. Th SPD sts out that it provids furthr guidanc to xisting planning policis in th Cor Stratgy and savd Southwark Plan. It dos not rpat borough wid policis and th SPD must b rad alongsid othr planning documnts. Housing is not givn its own sction within th SPD bcaus th borough-wid housing policis and guidanc alrady covr housing adquatly. This includs policis in th Cor Stratgy and savd Southwark Plan and SPDs on affordabl housing and rsidntial dsign standards. Existing policis and guidanc

153 Rp Obj Rf Rf Nam Wbb r & Qunti n TRA Wbb r & Qunti n TRA Dtails of Rprsntation ar working with th local community and landownrs to dlivr larg scal dvlopmnt and improvmnts, providing ovr 1,900 nw homs, 665 affordabl housing units and around 25,000 nw jobs by (pag 8). On pag 11 of th draft SPD, it is statd, Thr will also b many nw homs on th uppr floors of commrcial dvlopmnts, offring a rang of housing typs and sizs. but no rfrnc is mad as to whthr this will includ both privat and affordabl housing. Qustions rgarding th abov points With th xpctd incras in population numbrs in th SPD ara, will Southwark Council xplain why th draft SPD only maks on rfrnc to affordabl housing? In stating Thr will also b many nw homs on th uppr floors of commrcial dvlopmnts, offring a rang of housing typs and sizs, dos Southwark Council intnd to nforc clar policis rgarding ratios of affordabl housing on th uppr floors of commrcial dvlopmnts? If so, what proportion of affordabl housing will it xpct dvloprs to dlivr? Officr Rspons to Rprsntation provid clar policis for affordabl housing. W hav also insrtd a nw appndix (appndix A) listing th ky borough wid Southwark planning policis and supplmntary planning guidanc to mak it clarr that ths policis nd to b rad alongsid th Blackfriars Road SPD. Sction 1 of th SPD has bn updatd to rfr to this nw appndix. Th SPD sts out that it provids furthr guidanc to xisting planning policis in th Cor Stratgy and savd Southwark Plan. It dos not rpat borough wid policis and th SPD must b rad alongsid othr planning documnts. Housing is not givn its own sction within th SPD bcaus th borough-wid housing policis and guidanc alrady covr housing adquatly. This includs policis in th Cor Stratgy and savd Southwark Plan and SPDs on affordabl housing and rsidntial dsign standards. Existing policis and guidanc provid clar policis for affordabl housing. W hav also insrtd a nw appndix (appndix A) listing th ky borough wid Southwark planning policis and supplmntary planning guidanc to mak it clarr that ths policis nd to b rad alongsid th Blackfriars Road SPD. Sction 1 of th SPD has bn updatd to rfr to this nw appndix. Th SPD sts out that it provids furthr guidanc to xisting planning policis in th Cor Stratgy and savd Southwark Plan. It dos not rpat borough wid policis and th SPD must b rad alongsid othr planning documnts. Housing is not givn its own sction within th SPD bcaus th borough-wid housing policis and guidanc alrady covr housing adquatly. This includs policis in th Cor Stratgy and savd Southwark Plan and SPDs on affordabl housing and rsidntial dsign standards. Existing policis and guidanc provid clar policis for affordabl housing.

154 Rp Obj Rf Rf Nam Wbb r & Qunti n TRA Dtails of Rprsntation With th xpctd incras in population numbrs in th SPD ara, will Southwark Council xplain why th draft SPD only maks on rfrnc to affordabl housing? In stating Thr will also b many nw homs on th uppr floors of commrcial dvlopmnts, offring a rang of housing typs and sizs, dos Southwark Council intnd to nforc clar policis rgarding ratios of affordabl housing on th uppr floors of commrcial dvlopmnts? If so, what proportion of affordabl housing will it xpct dvloprs to dlivr? In making so littl rfrnc to, and provision for, affordabl housing, is th draft SPD in conflict with th following policis: London Plan ( Stratgy: Th Mayor s vision and objctivs): This high lvl, ovr-arching vision is supportd by six dtaild objctivs. Ths mbody th concpt of sustainabl dvlopmnt. Thy giv mor dtail about how th vision should b implmntd, and link into th dtaild policis in th following chaptrs:... Ensuring London is: 1. A city that mts th challngs of conomic and population growth in ways that nsur a sustainabl, good and improving quality of lif and sufficint high quality homs and nighbourhoods for all Londonrs, and hlp tackl th hug issu of dprivation and inquality among Londonrs, including inquality in halth outcoms.? London Plan ( A nw focus on quality of lif ): 1.44 At its bst, London can provid what is amongst th highst quality of lif to b found anywhr. Unfortunatly, this is not th univrsal xprinc of Londonrs, as indicators lik th disparitis in lif Officr Rspons to Rprsntation W hav also insrtd a nw appndix (appndix A) listing th ky borough wid Southwark planning policis and supplmntary planning guidanc to mak it clarr that ths policis nd to b rad alongsid th Blackfriars Road SPD. Sction 1 of th SPD has bn updatd to rfr to this nw appndix. Th SPD sts out that it provids furthr guidanc to xisting planning policis in th Cor Stratgy and savd Southwark Plan. It dos not rpat borough wid policis and th SPD must b rad alongsid othr planning documnts. Housing is not givn its own sction within th SPD bcaus th borough-wid housing policis and guidanc alrady covr housing adquatly. This includs policis in th Cor Stratgy and savd Southwark Plan and SPDs on affordabl housing and rsidntial dsign standards. Existing policis. W hav also insrtd a nw appndix (appndix A) listing th ky borough wid Southwark planning policis and supplmntary planning guidanc to mak it clarr that ths policis nd to b rad alongsid th Blackfriars Road SPD. Sction 1 of th SPD has bn updatd to rfr to this nw appndix.

155 Rp Obj Rf Rf Nam Wbb r & Qunti n TRA Dtails of Rprsntation xpctancy in diffrnt placs across th city show...it is unsurprising, thrfor, that consultation on proposals for this Plan hav shown a growing concrn with quality of lif issus, such as: nsuring thr ar nough homs mting th nds of Londonrs at all stags of thir livs and whatvr thir circumstancs, and dsignd so thy activly nhanc th quality of th nighbourhoods in which thy ar locatd. Southwark Plan: 3.2 National Policy 10 Th Plan must comply with govrnmnt policis including thos st out in Planning Policy Guidanc (PPG) and Planning Policy Statmnts (PPS), unlss local circumstancs justify a dpartur. On of th major planks of cntral govrnmnt policy is sustainability particularly mor rus of prviously dvlopd land, which is dtaild in Sction 13. Four furthr aras of cntral govrnmnt policy ar particularly rlvant i. Th Govrnmnt is sking to incras th quality and supply of housing whr it is ndd and, in particular, to nsur that thr is affordabl housing in a rang of tnurs whrvr it is ndd. It also wants to s mor r-us of dvlopd land in citis for nw housing and this will hav th addd advantag of rducing th nd for nw dvlopmnt in th opn countrysid. [PPS 3- Housing] Southwark Plan: SP 17 Housing All dvlopmnts should, whr appropriat, provid mor high quality housing of all kinds, particularly affordabl housing.? Southwark Plan: Undr 10.5 Housing London Plan rquirmnts 88 Fifty prcnt of nw dwllings should b affordabl. This will includ social rntd and intrmdiat housing including homs for ky workrs.? In making so littl rfrnc to, and provision for, affordabl housing, dos th draft SPD fails to dal with th following principls in Southwark Council s A fairr futur for all in Southwark Intrim prformanc Officr Rspons to Rprsntation Th SPD sts out that it provids furthr guidanc to xisting planning policis in th Cor Stratgy and savd Southwark Plan. It dos not rpat borough wid policis and th SPD must b rad alongsid othr planning documnts. Housing is not givn its own sction within

156 Rp Obj Rf Rf Nam Wbb r & Qunti n TRA Dtails of Rprsntation rport 2012/13 : With a growing borough population w undrstand th urgncy of addrssing th acut nd for mor good quality affordabl housing. W ar thrfor bringing forward plans to build 1,000 nw council homs within th borough bfor W shall also targt 50% of th nw homs spcifically for lttings to local rsidnts in priority nd, nabling th council to rlt xisting homs crating bttr mobility on stats and providing popl with appropriat housing suitd to thir nds. [Extract] W rcognis that accss to affordabl housing is a major issu for th borough and on that is important in ordr for local popl to b abl to accss mploymnt and othr opportunitis that cntral London offrs. W commissiond an indpndnt housing commission to look at th futur of council housing in th borough. It lookd at solutions byond 2015/16 that ar sustainabl and affordabl to council tnants and hom ownrs in th long trm, with th aim to brak th currnt cycl of an scalating dmand for rsourcs in ordr to maintain quality of th stock. Th commission submittd a final rport to th council proposing long trm idas for innovativ yt practical solutions to th unprcdntd dmand for council housing. This will ultimatly provid for a fairr futur for gnrations of familis who wish to rach thir potntial within th hart of cntral London.? Do th abov-mntiond potntial conflicts with policy constitut a failur to comply with th following points in Th Town and Country Planning (Local Planning) (England) Rgulations 2012: Form and contnt of local plans and supplmntary planning documnts: gnral 8... (3) Any policis containd in a supplmntary planning documnt must not conflict with th adoptd dvlopmnt plan. (4) Subjct to paragraph (5), th policis containd in a local plan Officr Rspons to Rprsntation th SPD bcaus th borough-wid housing policis and guidanc alrady covr housing adquatly. This includs policis in th Cor Stratgy and savd Southwark Plan and SPDs on affordabl housing and rsidntial dsign standards. Existing policis and guidanc provid clar policis for affordabl housing. W hav also insrtd a nw appndix (appndix A) listing th ky borough wid Southwark planning policis and supplmntary planning guidanc to mak it clarr that ths policis nd to b rad alongsid th Blackfriars Road SPD. Sction 1 of th SPD has bn updatd to rfr to this nw appndix. Th SPD accords with th rquirmnts of th Town and Country Planning (Local Planning) (England) Rgulations It is consistnt with and not in conflict with th adoptd dvlopmnt plan and th NPPF. Th SPD sts out that it provids furthr guidanc to xisting planning policis in th dvlopmnt plan: th London Plan, Cor Stratgy and savd Southwark Plan. It dos not rpat borough wid policis and th SPD must b rad alongsid othr planning documnts.

157 Rp Obj Rf Rf Nam Wbb r & Qunti n TRA Dtails of Rprsntation must b consistnt with th adoptd dvlopmnt plan. (5) Whr a local plan contains a policy that is intndd to suprsd anothr policy in th adoptd dvlopmnt plan, it must stat that fact and idntify th suprsdd policy.? 11. Infrastructur and facilitis Th local population of workrs, rsidnts and tourists in this ara will xplod with th proposd lvl of dvlopmnt in th draft SPD. W will nd schools, nursris, youth cntrs, local group cntrs, playgrounds, opn spacs, GP surgris, halth cntrs, fir srvics and polic srvics. Dspit this, th draft SPD contains an alarming lack of dtail on how this lvl of infrastructur will b providd. Th Rvitalis Hav your say (Jun 2013) laflt stats that th 18 dvlopmnt projcts in th piplin alrady will crat in xcss of 10,000 jobs, 1,500 nw homs and 1,000 hotl rooms. In addition to this, th proposd dvlopmnt of th Blackfriars Road ara will crat an additional 2,000 rsidnts and thousands of additional workrs as wll as an incrasing amount of tourists as Southwark continus to work towards its 2026 targt quota for hotl rooms. An xpansion in population of this scal will rquir an xtnsiv infrastructur comprising th following facilitis and srvics: schools, youth cntrs, nursris, playgrounds, opn spacs, GP surgris, halth cntrs, fir srvics, polic srvics, tc. Th draft SPD maks on mntion of schools and on mntion of youth cntrs (but no dtail as to what or whr),and no mntions of GP surgris, halth cntrs, nursris, community cntrs, local group cntrs, fir stations or polic stations. Th draft SPD stats that infrastructur nds will b addrssd through xtrnal stakholdr s asst managmnt plans and through th Council s Capital programm. Officr Rspons to Rprsntation It is important to considr that th SPD provids furthr guidanc to xisting planning policis in our Cor Stratgy and savd Southwark Plan. It dos not rpat borough wid policis and so th SPD must b rad alongsid our othr planning documnts. Policy 14 of th Cor Stratgy rcogniss that nw dvlopmnt in th borough nds to b supportd by adquat infrastructur, including social, nvironmntal and physical infrastructur. Sction 4.4 of th SPD on infrastructur, sts out that much of th funding for infrastructur to support growth will b raisd through th Community Infrastructur Lvy, and sit spcific mitigation of dvlopmnt impacts will b scurd through sction 106 planning obligations. Th borough s Infrastructur Plan, idntifis stratgic infrastructur which is ndd to support growth and dvlopmnt in th borough ovr th liftim of th Cor Stratgy ( ). Whr possibl it idntifis th cost of infrastructur to providd, any committd sourcs of funding which will b usd to dlivr it and th organis rsponsibl. It also idntifis th funding gap i.. th gap btwn known commitmnts and th total cost of infrastructur rquird. Whn it is adoptd, Southwark s CIL will b usd to contribut towards bridging this funding gap. Funds armarkd for infrastructur in th Council s capital invstmnt programm also will hlp to improv infrastructur provision. W hav amndd th supporting txt to improv clarity on infrastructur funding.

158 Rp Obj Rf Rf Nam Dtails of Rprsntation Officr Rspons to Rprsntation Wbb r & Qunti n TRA Qustions rgarding th abov points Can Southwark Council plas xplain in lay trms what is mant by th statmnt in th draft SPD that infrastructur nds will b addrssd through xtrnal stakholdr s asst managmnt plans and through th Council s Capital programm? Linkd to Sction 4.4 of th SPD on infrastructur, th borough s Infrastructur Plan, idntifis stratgic infrastructur which is ndd to support growth and dvlopmnt in th borough ovr th liftim of th Cor Stratgy ( ). Whr possibl it idntifis th cost of infrastructur to providd, any committd sourcs of funding which will b usd to dlivr it and th organis rsponsibl. It also idntifis th funding gap i.. th gap btwn known commitmnts and th total cost of infrastructur rquird. Whn it is adoptd, Southwark s CIL will b usd to contribut towards bridging this funding gap. Funds armarkd in th Council s capital programm also will hlp to improv infrastructur provision. Stakholdr asst managmnt plans ar thos prpard by bodis such as th Mtropolitan polic, Thams Watr, London Fir and mrgncy planning authority, and othr utility providrs. Thy also nd to b rfrncd bcaus thy also dlivr improvmnts to thir own srvics and infrastructur to accommodat growth. Howvr, w hav amndd th supporting txt to improv clarity on infrastructur funding. Th figur and tabl within th SPD shows potntial dvlopmnt sits. Ths sits ar idntifid by officrs as sits with th potntial for som chang to th building or its surroundings. Som of th sits hav planning prmission, som ar undr construction, som ar going through th planning procss, and som hav no known plans as yt. Th list and figur has bn updatd following consultation to tak into account suggstions from land ownrs and rsidnts. Furthr wording has also bn addd to th SPD to mak it clar that th list of sits is not xhaustiv and that whilst som of th sits will b compltly rdvlopd othr sits might xprinc lss chang such as rfurbishmnt or improvmnts to th xisting buildings or surroundings Wbb r & Qunti n TRA Why ar non of th 45 proposd dvlopmnt sits bing considrd as sits for ssntial facilitis such as schools, halth cntrs, opn spacs or affordabl housing Th SPD is not allocating sits as proposals sits and so dos not provid policis on th land uss within ach of th sits. Th allocation of proposals sits is don through a dvlopmnt plan documnt. Currnt dsignations for Blackfriars Road ar in th savd Southwark Plan (2007) which is currntly bing rviwd through th

159 Rp Obj Rf Rf Nam Wbb r & Qunti n TRA Wbb r & Qunti n TRA Dtails of Rprsntation Why, at a SPD workshop on Monday 19th August 2013 with plannrs from Southwark Council, in rspons to a rsidnt s qustion about provision for schools, did th rply com in th form of Would you lik to suggst som suitabl sits? Surly Southwark Council should b taking th lad on crating a clar stratgy of what,, whr and how schools provision will b achivd to a lvl that will match th xpctd incras in rsidnts in th SPD ara? Dos this lack of substanc rgarding th typ, numbr and location of infrastructural facilitis man that Southwark Council is likly to fail to dlivr on th following promiss in Southwark Council s A fairr futur for all in Southwark Intrim prformanc rport 2012/13 : Trating rsidnts as w would wish mmbrs of our own familis to b tratd. Making Officr Rspons to Rprsntation prparation of th Nw Southwark Plan. As part of this rviw w will b looking at whthr w should allocat mor and/or chang xisting proposals sits dsignations and updat th adoptd policis map. Full consultation will b carrid out on th Nw Southwark Plan in accordanc with our SCI and th rlvant rgulations. Th figur and tabl within th SPD shows potntial dvlopmnt sits. Ths sits ar idntifid by officrs as sits with th potntial for som chang to th building or its surroundings. Som of th sits hav planning prmission, som ar undr construction, som ar going through th planning procss, and som hav no known plans as yt. Th list and figur has bn updatd following consultation to tak into account suggstions from land ownrs and rsidnts. Furthr wording has also bn addd to th SPD to mak it clar that th list of sits is not xhaustiv and that whilst som of th sits will b compltly rdvlopd othr sits might xprinc lss chang such as rfurbishmnt or improvmnts to th xisting buildings or surroundings. Th SPD is not allocating sits as proposals sits and so dos not provid policis on th land uss within ach of th sits. Th allocation of proposals sits is don through a dvlopmnt plan documnt. Currnt dsignations for Blackfriars Road ar in th savd Southwark Plan (2007) which is currntly bing rviwd through th prparation of th Nw Southwark Plan. As part of this rviw w will b looking at whthr w should allocat mor and/or chang xisting proposals sits dsignations and updat th adoptd policis map. Full consultation will b carrid out on th Nw Southwark Plan in accordanc with our SCI and th rlvant rgulations. Th SPD and othr planning policy documnts provid th framwork for th provision of infrastructur to support dvlopmnt. Updats hav bn mad to th SPD to rfr to ncouraging a rang of diffrnt uss/ SPD 2: Mixd us town cntr sts out that w will support th provision of nw social infrastructur and community facilitis as part

160 Rp Obj Rf Rf Nam Dtails of Rprsntation Officr Rspons to Rprsntation Southwark a plac to b proud of.? of mixd us dvlopmnts. SPD 3: Public ralm and opn spac rfrs to th continud protction of th thr protctd opn spacs and ncouraging furthr linkags and nw spacs. Sction 4.4 of th SPD rfrs spcifically to infrastructur, crossing rfrring to th community infrastructur lvy (CIL) and sction 106 planning obligations to hlp nsur th dlivry of ky infrastructur to mitigat th impact of dvlopmnt Wbb r & Qunti n TRA Is th lack of concrt plans for infrastructur in th draft SPD in conflict with th following policis: London Plan: 1.40 In addition to this hard infrastructur, a growing and incrasingly divrs population will crat dmand for mor social infrastructur, ranging from Infrastructur is covrd within borough-wid planning documnts with th ovrarching policy 14 of th Cor Stratgy rcognising that nw dvlopmnt in th borough nds to b supportd by adquat infrastructur, including social, nvironmntal and physical infrastructur. Th borough s Infrastructur Plan, idntifis stratgic infrastructur which is ndd to support growth and dvlopmnt in th borough ovr th liftim of th Cor Stratgy ( ). Whr possibl it idntifis th cost of infrastructur to providd, any committd sourcs of funding which will b usd to dlivr it and th organis rsponsibl. It also idntifis th funding gap i.. th gap btwn known commitmnts and th total cost of infrastructur rquird. Whn it is adoptd, Southwark s CIL will b usd to contribut towards bridging this funding gap. Funds armarkd for infrastructur in th Council s capital invstmnt programm also will hlp to improv infrastructur provision. Th council ar currntly prparing our draft community infrastructur charging schdul and an updatd sction 106 SPD. Adoption is plannd for It is appropriat to look at th provision of infrastructur at a borough-wid lvl through ths ddicatd documnts rathr than through th Blackfriars Road SPD. Th SPD and othr planning policy documnts provid th framwork for th provision of infrastructur to support dvlopmnt. Updats hav bn mad to th SPD to rfr mor to othr uss including halth and community facilitis.

161 Rp Obj Rf Rf Nam Dtails of Rprsntation schools, collgs and univrsitis, thatrs, musums and libraris through halth facilitis to spacs for local groups and placs of worship. A grn infrastructur of grn and othr opn spacs also has a crucial part to play in nsuring good halth and a high quality of lif as wll as hlping to addrss th challngs of climat chang. London Plan ( Planning for growth ): 1.48 In practical trms this mans planning for: A growing population nsuring London has th homs, jobs, srvics, infrastructur and opportunitis a growing and vr mor divrs population rquirs; An vr mor divrs population nsuring London has th schools and othr facilitis ndd by a growing numbr of youngr popl, whil also addrssing th nds of an aging population, with homs and nighbourhoods suitabl for popl at all stags of thir livs. W will also nd to plan for th whol rang of othr social infrastructur London s communitis and nighbourhoods will nd to support a high and improving quality of lif. Southwark Plan10.3. ( Lif chancs ): Community and halth srvics 73 Southwark s Community Stratgy and th London Plan highlight th importanc of facilitis to nabl local communitis to bcom mor cohsiv, and th important rol of voluntary organis in building communitis, rducing social problms and assisting local popl with planning issus. Southwark nds mor halth srvics to provid for th growth in population and to improv halth provision for local popl dlivring national, London-wid and local objctivs and stratgis. Community and halthcar provision is a ky rquirmnt in Sction 8 and 9 policis for all dvlopmnts within Opportunity and Action Aras whr th largst growth in population is prdictd to tak plac. Community facility and halth provision Officr Rspons to Rprsntation SPD 2: Mixd us town cntr sts out that w will support th provision of nw social infrastructur and community facilitis as part of mixd us dvlopmnts. SPD 3: Public ralm and opn spac rfrs to th continud protction of th thr protctd opn spacs and ncouraging furthr linkags and nw spacs. Sction 4 of th SPD rfrs spcifically to infrastructur, crossing rfrring to th community infrastructur lvy (CIL) and sction 106 planning obligations to hlp nsur th dlivry of ky infrastructur to mitigat th impact of dvlopmnt. Infrastructur is covrd within borough-wid planning documnts with th ovrarching policy 14 of th Cor Stratgy rcognising that nw dvlopmnt in th borough nds to b supportd by adquat infrastructur, including social, nvironmntal and physical infrastructur. Th borough s Infrastructur Plan, idntifis stratgic infrastructur which is ndd to support growth and dvlopmnt in th borough ovr th liftim of th Cor Stratgy ( ). Whr possibl it idntifis th cost of infrastructur to providd, any committd sourcs of funding which will b usd to dlivr it and th organis rsponsibl. It also idntifis th funding gap i.. th gap btwn known commitmnts and th total cost of infrastructur rquird. Whn it is adoptd, Southwark s CIL will b usd to contribut towards bridging this funding gap. Funds armarkd for infrastructur in th Council s capital invstmnt programm also will hlp to improv infrastructur provision. Th council ar currntly prparing our draft community infrastructur charging schdul and an updatd sction 106 SPD. Adoption is plannd for It is appropriat to look at th provision of infrastructur at a borough-wid lvl through ths ddicatd documnts rathr than through th Blackfriars Road SPD.

162 Rp Obj Rf Rf Nam Wbb r & Qunti n TRA Dtails of Rprsntation should b an intgral part of mastrplans and largr dvlopmnts. Th typ and quantity of provision should b st through discussions with local community and halth providrs spcially th Local Stratgic Partnrship, Stratgic Halth Authority, Primary Car, Acut and Foundation Trusts and hospitals. This will b masurd as a rquirmnt of th sustainability assssmnt policy, which rquirs considration of halth and community issus in th contxt of th social, conomic and nvironmntal impacts of major dvlopmnts. Thr is a gnral chang in halth provision towards mor halthy living cntrs, doctors and satllit hospital facilitis within rsidntial aras srving th local population in addition to th larg cntralisd sits. Southwark Plan ( Part two: Th policis ): Sction on: Tackling povrty and ncouraging walth cration SP 6 Accssibl srvics All dvlopmnts should, whr appropriat, improv th rang and quality of srvics availabl in Southwark and nsur that ths ar asily accssibl by all sctions of th community, particularly by foot, cycl and public transport. Do th abov-mntiond potntial conflicts with policy constitut a failur to comply with th following points in Th Town and Country Planning (Local Planning) (England) Rgulations 2012: Form and contnt of local plans and supplmntary planning documnts: gnral 8... (3) Any policis containd in a supplmntary planning documnt must not conflict with th adoptd dvlopmnt plan. (4) Subjct to paragraph (5), th policis containd in a local plan must b consistnt with th adoptd dvlopmnt plan. (5) Whr a local plan contains a policy that is intndd to suprsd anothr policy in th adoptd dvlopmnt plan, it must stat that fact and idntify th suprsdd policy.? Officr Rspons to Rprsntation Th SPD accords with th rquirmnts of th Town and Country Planning (Local Planning) (England) Rgulations It is consistnt with and not in conflict with th adoptd dvlopmnt plan and th NPPF. Th SPD sts out that it provids furthr guidanc to xisting planning policis in th dvlopmnt plan: th London Plan, Cor Stratgy and savd Southwark Plan. It dos not rpat borough wid policis and th SPD must b rad alongsid othr planning documnts.

163 Rp Obj Rf Rf Nam Wbb r & Qunti n TRA Wbb r & Qunti n TRA Dtails of Rprsntation Officr Rspons to Rprsntation Community spacs Th SPD ara alrady suffrs from Th SPD cannot provid sit spcific guidanc. a lack of community spac, and th draft SPD maks no provision for how this might b improvd, spcially in viw of th fact that thousands of additional workrs, rsidnts and tourists ar xpctd to populat th ara in th coming yars. In th ntir proposd boundary ara of Blackfriars Road, which taks in a hug ara of both offic us and rsidntial aras, particularly to th south of Th Cut, thr ar only thr protctd opn spacs, two of which ar north of Th Cut at Paris Gardns and Christchurch. Considring th fact that th draft SPD is ncouraging policis that will a massiv incras in th numbr of popl in th ara, this is a compltly inadquat amount of opn spac for a population that is alrady growing and is st to grow vn mor if th scal of dvlopmnt proposd in th draft SPD gos ahad. Qustions rgarding th abov points Ar any of th Th figur and tabl within th SPD shows potntial dvlopmnt 46 sits idntifid as potntial dvlopmnt sits bing sits. Ths sits ar idntifid by officrs as sits with th potntial considrd for us as opn spac? for som chang to th building or its surroundings. Som of th sits hav planning prmission, som ar undr construction, som ar going through th planning procss, and som hav no known plans as yt. Th list and figur has bn updatd following consultation to tak into account suggstions from land ownrs and rsidnts. Furthr wording has also bn addd to th SPD to mak it clar that th list of sits is not xhaustiv and that whilst som of th sits will b compltly rdvlopd othr sits might xprinc lss chang such as rfurbishmnt or improvmnts to th xisting buildings or surroundings. Th SPD is not allocating sits as proposals sits and so dos not provid policis on th land uss within ach of th sits. Th allocation of proposals sits is don through a dvlopmnt plan documnt. Currnt dsignations for Blackfriars Road ar in th savd Southwark Plan (2007) which is currntly bing rviwd through th prparation of th Nw Southwark Plan. As part of this rviw w will

164 Rp Obj Rf Rf Nam Wbb r & Qunti n TRA Wbb r & Qunti n TRA Wbb r & Qunti n TRA Dtails of Rprsntation Why dos th draft SPD mak no attmpt to crat nforcabl policy with landownrs and dvloprs to crat such spac? Is th lack of concrt plans for opn spacs in th draft SPD in conflict with th following policy: Southwark Plan 10.4 Clan and grn 83 Opn spacs significantly contribut to th charactr of th borough, contributing to natur consrvation and providing spac for lisur and rcration activitis. Opn spacs hav bn givn thr tirs of protction: Mtropolitan Opn Land (MOL), Borough Opn Land (BOL) and Othr Opn Spac all of which ar idntifid on th Proposals Map. Sits of importanc for natur consrvation and local natur rsrvs ar also protctd. Do th abov-mntiond potntial conflicts with policy risk constituting a failur to comply with th following points in Th Town and Country Planning (Local Planning) (England) Rgulations 2012: Form and contnt of local plans and supplmntary planning documnts: gnral 8 (3) Any policis containd in a supplmntary planning documnt must not conflict with th adoptd dvlopmnt plan. (4) Subjct to paragraph (5), th policis containd in a local plan must b consistnt with th adoptd dvlopmnt plan. (5) Whr a local plan contains a policy that is intndd to suprsd anothr policy in th adoptd dvlopmnt plan, it must stat that fact and idntify th suprsdd policy.? Officr Rspons to Rprsntation b looking at whthr w should allocat mor and/or chang xisting proposals sits dsignations and updat th adoptd policis map. Full consultation will b carrid out on th Nw Southwark Plan in accordanc with our SCI and th rlvant rgulations. This rquirmnt would b outsid th scop of th SPD. No. Policy 10.4 has not bn savd and is now out of dat Th SPD is consistnt with th our opn spac stratgy which has idntifid a dficincy in opn spacs within thn ara; howvr givn th limitd opportunitis for th cration of opns, our priority is to focus on improving out xisting opn spacs. W will sk to provid nw opn spac and grning as st in th stratgy. Th SPD accords with th rquirmnts of th Town and Country Planning (Local Planning) (England) Rgulations It is consistnt with and not in conflict with th adoptd dvlopmnt plan and th NPPF. Th SPD sts out that it provids furthr guidanc to xisting planning policis in th dvlopmnt plan: th London Plan, Cor Stratgy and savd Southwark Plan. It dos not rpat borough wid policis and th SPD must b rad alongsid othr planning documnts Wbb 13. Potntial dvlopmnt sits Th draft SPD Th figur and tabl within th SPD shows potntial dvlopmnt

165 Rp Obj Rf Rf Nam 6 9 r & Qunti n TRA Wbb r & Qunti n TRA Dtails of Rprsntation contains a list of 46 potntial dvlopmnt sits with no accompanying dtail whatsovr on what ths ar, why thy hav bn slctd and what th plans/idas ar. A closr look at ths sits rvals an xtrmly worrying trnd of armarking buildings - both priod and modrn - which ar alrady fit for purpos in trms of srving th businss and rsidntial communitis wll by mting ky policy issus such as th prsrvation of hritag assts, th provision of small businss spac and th provision of rsidntial accommodation. Th complt lack of dtail in th draft SPD about th 46 potntial dvlopmnt sits ffctivly mans that consults hav bn givn no opportunity to commnt on this xtrmly important aspct of th draft SPD. Officr Rspons to Rprsntation sits. Ths sits ar idntifid by officrs as sits with th potntial for som chang to th building or its surroundings. Som of th sits hav planning prmission, som ar undr construction, som ar going through th planning procss, and som hav no known plans as yt. Th list and figur has bn updatd following consultation to tak into account suggstions from land ownrs and rsidnts. Furthr wording has also bn addd to th SPD to mak it clar that th list of sits is not xhaustiv and that whilst som of th sits will b compltly rdvlopd othr sits might xprinc lss chang such as rfurbishmnt or improvmnts to th xisting buildings or surroundings. Th SPD is not allocating sits as proposals sits and so dos not provid policis on th land uss within ach of th sits. Th allocation of proposals sits is don through a dvlopmnt plan documnt. Currnt dsignations for Blackfriars Road ar in th savd Southwark Plan (2007) which is currntly bing rviwd through th prparation of th Nw Southwark Plan. As part of this rviw w will b looking at whthr w should allocat mor and/or chang xisting proposals sits dsignations and updat th adoptd policis map. Full consultation will b carrid out on th Nw Southwark Plan in accordanc with our SCI and th rlvant rgulations. Qustions rgarding th abov point Prior to Th figur and tabl within th SPD shows potntial dvlopmnt slcting th 46 sits, did th authors of th draft SPD physically walk around th ntir proposd ara and look in dtail at vry on of ths buildings in ordr to assss thir architctur, dsign and currnt usag? sits. Ths sits ar idntifid by officrs as sits with th potntial for som chang to th building or its surroundings. Som of th sits hav planning prmission, som ar undr construction, som ar going through th planning procss, and som hav no known plans as yt. Th list and figur has bn updatd following consultation to tak into account suggstions from land ownrs and rsidnts. Furthr wording has also bn addd to th SPD to mak it clar that th list of sits is not xhaustiv and that whilst som of th sits will b compltly rdvlopd othr sits might xprinc lss chang such as rfurbishmnt or improvmnts to th xisting buildings or surroundings. Th SPD is not allocating sits as proposals sits and so dos not provid policis on th land uss within ach of th sits.

166 Rp Obj Rf Rf Nam Dtails of Rprsntation Officr Rspons to Rprsntation Th allocation of proposals sits is don through a dvlopmnt plan documnt. Currnt dsignations for Blackfriars Road ar in th savd Southwark Plan (2007) which is currntly bing rviwd through th prparation of th Nw Southwark Plan. As part of this rviw w will b looking at whthr w should allocat mor and/or chang xisting proposals sits dsignations and updat th adoptd policis map. Full consultation will b carrid out on th Nw Southwark Plan in accordanc with our SCI and th rlvant rgulations Wbb r & Qunti n TRA Do any of th authors of th draft SPD liv in, or clos to, th proposd ara and thus possss vital local knowldg of its physical apparanc and local charactr, and th rol playd by ach of th 46 sits in both th rsidntial and businss communitis? Th figur and tabl within th SPD shows potntial dvlopmnt sits. Ths sits ar idntifid by officrs as sits with th potntial for som chang to th building or its surroundings. Som of th sits hav planning prmission, som ar undr construction, som ar going through th planning procss, and som hav no known plans as yt. Th list and figur has bn updatd following consultation to tak into account suggstions from land ownrs and rsidnts. Furthr wording has also bn addd to th SPD to mak it clar that th list of sits is not xhaustiv and that whilst som of th sits will b compltly rdvlopd othr sits might xprinc lss chang such as rfurbishmnt or improvmnts to th xisting buildings or surroundings Wbb r & Qunti n TRA Th SPD is not allocating sits as proposals sits and so dos not provid policis on th land uss within ach of th sits. Th allocation of proposals sits is don through a dvlopmnt plan documnt. Currnt dsignations for Blackfriars Road ar in th savd Southwark Plan (2007) which is currntly bing rviwd through th prparation of th Nw Southwark Plan. As part of this rviw w will b looking at whthr w should allocat mor and/or chang xisting proposals sits dsignations and updat th adoptd policis map. Full consultation will b carrid out on th Nw Southwark Plan in accordanc with our SCI and th rlvant rgulations. Whn will Southwark Council b issuing th following Th figur and tabl within th SPD shows potntial dvlopmnt dtails to all partis in this consultation rgarding vry sits. Ths sits ar idntifid by officrs as sits with th potntial on of ths 46 sits in th form of visuals for som chang to th building or its surroundings. Som of th sits (photographs), and dtails on currnt usag, why thy hav planning prmission, som ar undr construction, som ar

167 Rp Obj Rf Rf Nam Dtails of Rprsntation Officr Rspons to Rprsntation hav bn slctd for dvlopmnt and what dvlopmnts ar bing considrd (visuals plus dscriptions)? going through th planning procss, and som hav no known plans as yt. Th list and figur has bn updatd following consultation to tak into account suggstions from land ownrs and rsidnts. Furthr wording has also bn addd to th SPD to mak it clar that th list of sits is not xhaustiv and that whilst som of th sits will b compltly rdvlopd othr sits might xprinc lss chang such as rfurbishmnt or improvmnts to th xisting buildings or surroundings Wbb r & Qunti n TRA Wbb r & In particular, will Southwark Council plas commnt on th following sits markd as potntial dvlopmnt sits: o ID11: This svn-story building at 209/215 Blackfriars Road has a finly rstord facad and is in activ us by major intrnational businsss such as PR Nwswir Europ. Th building clarly alrady mts policy rquirmnts rgarding hritag and businsss in th London Plan and th Southwark Plan. Michal Tsoukaris, Group Managr, Dsign & Consrvation at Southwark Council said of this building on 19 Sptmbr 1012: No is a fin building and rtains many of its original faturs. Givn ths facts, why has this building bn slctd for potntial dvlopmnt and do th plans ntail? o ID 14: 200 Union Strt is marktd via a high quality wbsit as nwly rfurbishd Entir 1st and Th SPD is not allocating sits as proposals sits and so dos not provid policis on th land uss within ach of th sits. Th allocation of proposals sits is don through a dvlopmnt plan documnt. Currnt dsignations for Blackfriars Road ar in th savd Southwark Plan (2007) which is currntly bing rviwd through th prparation of th Nw Southwark Plan. As part of this rviw w will b looking at whthr w should allocat mor and/or chang xisting proposals sits dsignations and updat th adoptd policis map. Full consultation will b carrid out on th Nw Southwark Plan in accordanc with our SCI and th rlvant rgulations. Th SPD dos not dsignat proposals sits or provid sit spcific guidanc, as this would byond th scop of th SPD. It dos idntify potntial dvlopmnt sits which ar illustrativ of th hug opportunity for chang within th ara and th nd for a cohrnt framwork. Th SPD has also bn updatd to clarify that th list of sits is not xhaustiv and othr sits may com forward for dvlopmnt. Som of th sits will b compltly rdvlopd, whilst othr sits may xprinc lss chang such as rfurbishmnt or improvmnts to th xisting buildings or surroundings. Th SPD dos not dsignat proposals sits or provid sit spcific guidanc, as this would byond th scop of th SPD. It dos idntify

168 Rp Obj Rf Rf Nam Qunti n TRA Wbb r & Qunti n TRA Wbb r & Qunti n TRA Dtails of Rprsntation Part Ground Floor Comprhnsivly Rfurbishd Mdia Styl Offics comprising th following: nw VRF air conditioning (xposd srvics), plastr ciling with nw suspnddlg7 sympathtic lighting, rfurbishd mal and fmal WCs, 13 prson passngr lift, bicycl storag, 24 hour accss and xcllnt 24 hour accss. Givn th fact that this building alrady mts policy rquirmnts rgarding businsss in th London Plan and th Southwark Plan, why has it bn idntifid as a sit for dvlopmnt and what do th plans ntail? Officr Rspons to Rprsntation potntial dvlopmnt sits which ar illustrativ of th hug opportunity for chang within th ara and th nd for a cohrnt framwork. Th SPD has also bn updatd to clarify that th list of sits is not xhaustiv and othr sits may com forward for dvlopmnt. Som of th sits will b compltly rdvlopd, whilst othr sits may xprinc lss chang such as rfurbishmnt or improvmnts to th xisting buildings or surroundings o ID15: Block T, Pabody Squar, Blackfriars Road is Block T was addd in rror to th draft list. Th figur has bn a Grad II listd building which forms an intgral part updatd and is now Figur 6. of this historic stat, constructd in 1871 by th Pabody Donation Fund and fundd by th visionary Amrican bankr, diplomat and philanthropist Gorg Pabody to tackl th povrty h saw in London and provid dcnt housing for artisans. Givn th major significanc of th Pabody Estat in trms of its contribution to London Plan and Southwark Plan policis rgarding th prsrvation of hritag and th provision of affordabl housing to a long-stablishd community of rsidnts, and th fact that, vn without a physical visit to th stat, som simpl dsk rsarch would hav rvald its rol in and importanc to th local ara, how and why did Block Tnd up on th list of 46potntial dvlopmnt sits? Dos this suggst that th authors of th SPD lack vital local knowldg and/or hav not carrid out sit visits to th potntial dvlopmnt sits? o ID 17: Union Strt is a modrn building of modst dsign and provids on of th fw rmaining viws for rsidnts of Applgarth Hous, a building which has bn svrly impactd by th Palstra building dirctly opposit it on Union Strt. Why is Th SPD dos not dsignat proposals sits or provid sit spcific guidanc, as this would byond th scop of th SPD. It dos idntify potntial dvlopmnt sits which ar illustrativ of th hug opportunity for chang within th ara and th nd for a cohrnt framwork. Th SPD has also bn updatd to clarify that th list of

169 Rp Obj Rf Rf Nam Wbb r & Qunti n TRA Wbb r & Qunti n TRA Wbb r & Qunti n TRA Dtails of Rprsntation this building on this list and what ar th plans in rgard to proposd hight, massing and usag? o ID 20: Southwark Collg in Th Cut undrwnt a rfurbishmnt svral yars ago which rsultd in an asthtically plasing modrn building of a scal which is in complt harmony rgarding hight and massing of th buildings along Th Cut. Furthrmor, at th rar of th Collg thr is an ara of land which is allocatd as grn spac and could b dvlopd furthr for us by studnts and vn by local rsidnts who do not hav accss to a gardn spac, as a gardning/food growing spac. Givn ths facts, why is this building on th list of 46 sits and what do th plans ntail? o ID 24: Markd on Tabl 1 as Fridn Hous, Blackfriars Road, this is an rror as on Figur 5 th building numbrd appars to b 2-10 Valntin Plac, which is part of th dsignatd Valntin Plac Consrvation Ara. Can Southwark Council plas confirm that this rror will b rctifid on Tabl 1 and Figur 5 and that ths documnts will b mad availabl publicly to all consults? o ID 25: Also markd on Tabl 1 as Fridn Hous, Blackfriars Road, on Figur 5 th numbring of ID 25 appars to b Wbbr Strt, 21 Wbbr Strt, 17/19 (odd) Valntin Plac, 3-5 Valntin Plac and a gap sit at 1 Valntin Plac, all of which ar buildings in th Valntin Plac Consrvation Ara: Can Southwark Council plas confirm that this rror will b rctifid on Tabl 1 and Figur 5 and that ths documnts will b mad availabl publicly to all consults? Officr Rspons to Rprsntation sits is not xhaustiv and othr sits may com forward for dvlopmnt. Som of th sits will b compltly rdvlopd, whilst othr sits may xprinc lss chang such as rfurbishmnt or improvmnts to th xisting buildings or surroundings. Th SPD dos not dsignat proposals sits or provid sit spcific guidanc, as this would byond th scop of th SPD. It dos idntify potntial dvlopmnt sits which ar illustrativ of th hug opportunity for chang within th ara and th nd for a cohrnt framwork. Th SPD has also bn updatd to clarify that th list of sits is not xhaustiv and othr sits may com forward for dvlopmnt. Som of th sits will b compltly rdvlopd, whilst othr sits may xprinc lss chang such as rfurbishmnt or improvmnts to th xisting buildings or surroundings Notd. Th figur has bn updatd. Notd. Th figur has bn updatd Wbb o ID 26: Blackfriars Road is a thr-story Th figur and tabl within th SPD shows potntial dvlopmnt

170 Rp Obj Rf Rf Nam 7 9 r & Qunti n TRA Wbb r & Qunti n TRA Dtails of Rprsntation purpos-built structur comprising privat rsidntial accommodation on th uppr floors, intrnal rsidntial and businss garag parking, and four wllstablishd small businsss on th ground floor providing highly usful srvics to th community, including: an xtndd hours (7am to 11pm)food stor, nwsagnts and off licnc; a hairdrssing and bauty salon; a shipping srvic; and th highly popular Caf Pronto/Mastrs Catring. Morovr, th building s architctural styl, hight and massing ar in harmony with th adjacnt Valntin Plac Consrvation Ara. Givn th fact that this building alrady mts London Plan and Southwark Plan policis rgarding th provision of spac for small businsss, th provision of quality accommodation, and cohsivnss with th surrounding buildings (and with th adjacnt consrvation ara in particular), why has it bn slctd as a potntial dvlopmnt sit? o ID 28: 57 Wbbr Strt appars to b th sit of th cartakr s prmiss for Friars Primary Foundation School. Why has this sit bn slctd for potntial dvlopmnt? Officr Rspons to Rprsntation sits. Ths sits ar idntifid by officrs as sits with th potntial for som chang to th building or its surroundings. Som of th sits hav planning prmission, som ar undr construction, som ar going through th planning procss, and som hav no known plans as yt. Th list and figur has bn updatd following consultation to tak into account suggstions from land ownrs and rsidnts. Furthr wording has also bn addd to th SPD to mak it clar that th list of sits is not xhaustiv and that whilst som of th sits will b compltly rdvlopd othr sits might xprinc lss chang such as rfurbishmnt or improvmnts to th xisting buildings or surroundings. Th SPD is not allocating sits as proposals sits and so dos not provid policis on th land uss within ach of th sits. Th allocation of proposals sits is don through a dvlopmnt plan documnt. Currnt dsignations for Blackfriars Road ar in th savd Southwark Plan (2007) which is currntly bing rviwd through th prparation of th Nw Southwark Plan. As part of this rviw w will b looking at whthr w should allocat mor and/or chang xisting proposals sits dsignations and updat th adoptd policis map. Full consultation will b carrid out on th Nw Southwark Plan in accordanc with our SCI and th rlvant rgulations. Th figur and tabl within th SPD shows potntial dvlopmnt sits. Ths sits ar idntifid by officrs as sits with th potntial for som chang to th building or its surroundings. Som of th sits hav planning prmission, som ar undr construction, som ar going through th planning procss, and som hav no known plans as yt. Th list and figur has bn updatd following consultation to tak into account suggstions from land ownrs and rsidnts. Furthr wording has also bn addd to th SPD to mak it clar that th list of sits is not xhaustiv and that whilst som of th sits will b compltly rdvlopd othr sits might xprinc lss chang such as rfurbishmnt or improvmnts to th xisting buildings or surroundings. Th SPD is not allocating sits as proposals sits and so dos not

171 Rp Obj Rf Rf Nam Wbb r & Qunti n TRA Wbb r & Qunti Dtails of Rprsntation o ID 29: 61 Wbbr Strt is a thr-story modrn building providing offic spac. Its hight and massing ar in harmony with all of th surrounding buildings and allow light and viws to b availabl to thr longstablishd communitis of rsidnts in th ara dirctly opposit (Boyfild Strt, Silx Strt and Wbbr Strt) in buildings ranging btwn 3 and 5 storys. Givn th fact that 61 Wbbr Strt mts London Plan and Southwark Plan policis rgarding th provision of spac for small businsss and cohsivnss with th surrounding buildings, why has it bn slctd for potntial dvlopmnt and what is th natur of th dvlopmnt plans/ idas? o ID 33 & ID 35: 63 Wbbr Strt / 94 Wbbr Strt is a handsom thr story priod building currntly in us as small businss offic spac on th ground floor Officr Rspons to Rprsntation provid policis on th land uss within ach of th sits. Th allocation of proposals sits is don through a dvlopmnt plan documnt. Currnt dsignations for Blackfriars Road ar in th savd Southwark Plan (2007) which is currntly bing rviwd through th prparation of th Nw Southwark Plan. As part of this rviw w will b looking at whthr w should allocat mor and/or chang xisting proposals sits dsignations and updat th adoptd policis map. Full consultation will b carrid out on th Nw Southwark Plan in accordanc with our SCI and th rlvant rgulations. Th figur and tabl within th SPD shows potntial dvlopmnt sits. Ths sits ar idntifid by officrs as sits with th potntial for som chang to th building or its surroundings. Som of th sits hav planning prmission, som ar undr construction, som ar going through th planning procss, and som hav no known plans as yt. Th list and figur has bn updatd following consultation to tak into account suggstions from land ownrs and rsidnts. Furthr wording has also bn addd to th SPD to mak it clar that th list of sits is not xhaustiv and that whilst som of th sits will b compltly rdvlopd othr sits might xprinc lss chang such as rfurbishmnt or improvmnts to th xisting buildings or surroundings. Th SPD is not allocating sits as proposals sits and so dos not provid policis on th land uss within ach of th sits. Th allocation of proposals sits is don through a dvlopmnt plan documnt. Currnt dsignations for Blackfriars Road ar in th savd Southwark Plan (2007) which is currntly bing rviwd through th prparation of th Nw Southwark Plan. As part of this rviw w will b looking at whthr w should allocat mor and/or chang xisting proposals sits dsignations and updat th adoptd policis map. Full consultation will b carrid out on th Nw Southwark Plan in accordanc with our SCI and th rlvant rgulations. Th figur and tabl within th SPD shows potntial dvlopmnt sits. Ths sits ar idntifid by officrs as sits with th potntial for som chang to th building or its surroundings. Som of th sits

172 Rp Obj Rf Rf Nam Dtails of Rprsntation n TRA and what appars to b rsidntial accommodation on th uppr floors, with a sparat gatd ntranc in Rushworth Strt. Givn th fact that this building alrady mts London Plan and Southwark Plan policis rgarding th provision of spac for small businsss, th provision of quality accommodation, and th prsrvation of hritag, why has it bn slctd for potntial dvlopmnt and what is th natur of th dvlopmnt plans/idas? Wbb r & Qunti n TRA o ID 34: 96 Wbbr Strt is a charactrful hritag asst comprising a two story priod building. Th stting and dsign of th building ar in prfct harmony with th xisting railway archs immdiatly to th south. Th building provids accommodation for local small crativ businss ownrs, including a photographic studio, a carpntr and a antiqu furnitur rstorr. Givn th fact that this building alrady mts London Plan and Southwark Plan policis rgarding th provision of spac for small businsss and th prsrvation of hritag, why has it bn slctd for potntial dvlopmnt and what is th natur of th dvlopmnt plans/idas? Officr Rspons to Rprsntation hav planning prmission, som ar undr construction, som ar going through th planning procss, and som hav no known plans as yt. Th list and figur has bn updatd following consultation to tak into account suggstions from land ownrs and rsidnts. Furthr wording has also bn addd to th SPD to mak it clar that th list of sits is not xhaustiv and that whilst som of th sits will b compltly rdvlopd othr sits might xprinc lss chang such as rfurbishmnt or improvmnts to th xisting buildings or surroundings. Th SPD is not allocating sits as proposals sits and so dos not provid policis on th land uss within ach of th sits. Th allocation of proposals sits is don through a dvlopmnt plan documnt. Currnt dsignations for Blackfriars Road ar in th savd Southwark Plan (2007) which is currntly bing rviwd through th prparation of th Nw Southwark Plan. As part of this rviw w will b looking at whthr w should allocat mor and/or chang xisting proposals sits dsignations and updat th adoptd policis map. Full consultation will b carrid out on th Nw Southwark Plan in accordanc with our SCI and th rlvant rgulations. Th figur and tabl within th SPD shows potntial dvlopmnt sits. Ths sits ar idntifid by officrs as sits with th potntial for som chang to th building or its surroundings. Som of th sits hav planning prmission, som ar undr construction, som ar going through th planning procss, and som hav no known plans as yt. Th list and figur has bn updatd following consultation to tak into account suggstions from land ownrs and rsidnts. Furthr wording has also bn addd to th SPD to mak it clar that th list of sits is not xhaustiv and that whilst som of th sits will b compltly rdvlopd othr sits might xprinc lss chang such as rfurbishmnt or improvmnts to th xisting buildings or surroundings. Th SPD is not allocating sits as proposals sits and so dos not provid policis on th land uss within ach of th sits. Th allocation of proposals sits is don through a dvlopmnt plan

173 Rp Obj Rf Rf Nam Wbb r & Qunti n TRA Wbb r & Qunti n TRA Dtails of Rprsntation ID 30: Rushworth Strt is a two story priod building srving as businss spac. Its hight and massing ar in complt harmony with th surrounding buildings and th provision of small businss spac and largr businss spac. Givn th fact that this building alrady mts London Plan and Southwark Plan policis rgarding th provision of spac for small businsss and th prsrvation of hritag, why has it bn slctd for potntial dvlopmnt and what is th natur of th dvlopmnt plans/idas? o ID Lancastr Strt is a four story building providing affordabl social housing. Givn th fact that this building alrady mts building alrady mts London Plan and Southwark Plan policis rgarding social housing, why has it bn slctd for potntial Officr Rspons to Rprsntation documnt. Currnt dsignations for Blackfriars Road ar in th savd Southwark Plan (2007) which is currntly bing rviwd through th prparation of th Nw Southwark Plan. As part of this rviw w will b looking at whthr w should allocat mor and/or chang xisting proposals sits dsignations and updat th adoptd policis map. Full consultation will b carrid out on th Nw Southwark Plan in accordanc with our SCI and th rlvant rgulations. Th figur and tabl within th SPD shows potntial dvlopmnt sits. Ths sits ar idntifid by officrs as sits with th potntial for som chang to th building or its surroundings. Som of th sits hav planning prmission, som ar undr construction, som ar going through th planning procss, and som hav no known plans as yt. Th list and figur has bn updatd following consultation to tak into account suggstions from land ownrs and rsidnts. Furthr wording has also bn addd to th SPD to mak it clar that th list of sits is not xhaustiv and that whilst som of th sits will b compltly rdvlopd othr sits might xprinc lss chang such as rfurbishmnt or improvmnts to th xisting buildings or surroundings. Th SPD is not allocating sits as proposals sits and so dos not provid policis on th land uss within ach of th sits. Th allocation of proposals sits is don through a dvlopmnt plan documnt. Currnt dsignations for Blackfriars Road ar in th savd Southwark Plan (2007) which is currntly bing rviwd through th prparation of th Nw Southwark Plan. As part of this rviw w will b looking at whthr w should allocat mor and/or chang xisting proposals sits dsignations and updat th adoptd policis map. Full consultation will b carrid out on th Nw Southwark Plan in accordanc with our SCI and th rlvant rgulations. Th figur and tabl within th SPD shows potntial dvlopmnt sits. Ths sits ar idntifid by officrs as sits with th potntial for som chang to th building or its surroundings. Som of th sits hav planning prmission, som ar undr construction, som ar going through th planning procss, and som hav no known plans

174 Rp Obj Rf Rf Nam Dtails of Rprsntation Officr Rspons to Rprsntation dvlopmnt and what is th natur of th dvlopmnt plans/idas? as yt. Th list and figur has bn updatd following consultation to tak into account suggstions from land ownrs and rsidnts. Furthr wording has also bn addd to th SPD to mak it clar that th list of sits is not xhaustiv and that whilst som of th sits will b compltly rdvlopd othr sits might xprinc lss chang such as rfurbishmnt or improvmnts to th xisting buildings or surroundings Wbb r & Qunti n TRA Transp 5 ort for Londo n Transp 6 ort for Londo Can Southwark Council plas tak into account th following buildings of intrst in th SPD ara: Huntr Hous, St Jams Strt Gardnr Hous, Lancastr Strt Th Bridg Hous, Lancastr Strt Murphy Hous, Borough Road Albury Buildings and Clandon Buildings, Boyfild Strt Parish of St Gorg th Martyr Public Libary, Borough Road Ovrall TfL Proprty supports th land us principls and vision for Blackfriars Road, in particular on TfL land idntifid as (i) Dvlopmnt Sit 18, Southwark Tub Station, Blackfriars Road; and (ii) Dvlopmnt Sit 43, TfL Bakrloo Sidings and 7 St. Gorg s Circus. This Rprsntation rlats spcifically to dvlopmnt sits 18 and 43. Th SPD is not allocating sits as proposals sits and so dos not provid policis on th land uss within ach of th sits. Th allocation of proposals sits is don through a dvlopmnt plan documnt. Currnt dsignations for Blackfriars Road ar in th savd Southwark Plan (2007) which is currntly bing rviwd through th prparation of th Nw Southwark Plan. As part of this rviw w will b looking at whthr w should allocat mor and/or chang xisting proposals sits dsignations and updat th adoptd policis map. Full consultation will b carrid out on th Nw Southwark Plan in accordanc with our SCI and th rlvant rgulations. Th idntification of buildings will b addrssd in a nw Hritag SPD that will b prpard alongsid th Nw Southwark Plan. Th Hritag SPD will also provid guidanc. Notd. Dvlopmnt Sit 18: Southwark Station TfL Proprty Notd. A tall building up to 70m in hight could b appropriat at th supports th principl of dvlopmnt on Dvlopmnt southrn nd of Blackfriars Road providd that it complis with th Sit 18. Howvr, draft Policy SPD 5 (Building dtaild guidanc outlind in SPD 5 and th currnt dvlopmnt plan

175 Rp Obj Rf Rf Nam Transp 7 ort for Londo n n Dtails of Rprsntation Hights) of th SPD spcifically stats that a tall building, of a hight of up to 70 mtrs should provid a focal point at Southwark tub station. Whilst a tall building is wlcomd at this location, this can only b achivd if th structural capacity of th xisting station structur and any supplmntary structur will rmain unaffctd and disruption to th opration of th London Undrground tub ntwork is not incurrd. TfL Proprty is undrtaking furthr fasibility work to ascrtain th appropriat building structur and thus hight which could b accommodatd on th sit subjct to satisfying (i) oprational nginring constraints to nsur th opration of th tub ntwork is not compromisd; and (ii) othr tchnical issus for xampl Rights of Light ar rsolvd. Thrfor until th work is complt, TfL Proprty cannot confirm whthr a dvlopmnt of 70m in hight is achivabl and dlivrabl on th sit. To nsur draft Policy SPD 5 is flxibl as pr paragraph 182 of th National Planning Policy Framwork (NPPF), TfL Proprty would wlcom th inclusion of additional txt within th xplanatory txt to draft Policy SPD 5 rflcting th oprational and nginring constraints. Dvlopmnt Sit 43, TfL Bakrloo Sidings and 7 St. Gorg s Circus Again, TfL Proprty supports th principl of dvlopmnt on th sit. Draft Policy SPD5 nots a tall building of up to 70m could b accommodatd in St. Gorg s Circus, a principl and approach which TfL Proprty support howvr th xact location for this building is not spcifid within th SPD. Draft Policy SPD 3 rlats to public ralm and stats dvlopmnt must contribut to th importanc of St Gorg s Circus as a stratgic gatway. Currntly th sit 1.2ha in siz, is opn cutting and compriss of offics and sidings for stabling trains associatd with th Bakrloo lin. Th Officr Rspons to Rprsntation that includs th rlvant policis of th savd Southwark Plan (2007), Cor Stratgy (2011), London Plan (2011) and othr planning documnts/guidanc, including th NPPF (2012). Th dvlopmnt plan sts out th policis for tall buildings. Th guidanc in th SPD provids dtail on how to implmnt ths dvlopmnt plan policis spcific to Blackfriars Road. Th approach is supportd by our vidnc bas including th Blackfriars Road Urban Dsign Study which has bn prpard in accordanc with CABE and English Hritag Guidanc on Tall Buildings, In light of consultation rsponss and to add clarity to th guidanc rlating to St Gorg s Circus in SPD 5, th SPD has bn updatd to clarify that a tall building could provid a focal point at th southrn nd of Blackfriars Road up to 70m. A tall building should also sustain, nhanc or bttr rval th local hritag assts. Thr is no nd for furthr updat within th SPD as th fasibility of dvlopmnt on this sit would b assssd at th pr-application and planning application stag. At this stag oprational constraints and tchnical issus tc would b discussd. Support notd. A tall building up to 70m in hight could b appropriat at th southrn nd of Blackfriars Road providd that it complis with th dtaild guidanc outlind in SPD 5 and th currnt dvlopmnt plan that includs th rlvant policis of th savd Southwark Plan (2007), Cor Stratgy (2011), London Plan (2011) and othr planning documnts/guidanc, including th NPPF (2012). Th dvlopmnt plan sts out th policis for tall buildings. Th guidanc in th SPD provids dtail on how to implmnt ths dvlopmnt plan policis spcific to Blackfriars Road. Th approach is supportd by our vidnc bas including th Blackfriars Road Urban Dsign Study which has bn prpard in accordanc with CABE and English Hritag Guidanc on Tall

176 Rp Obj Rf Rf Nam Malcolm Souch NHS 8 3 Londo Dtails of Rprsntation sit in its currnt form dos littl to contribut to th SPD s aspiration of a stratgic gatway. Thr ar currntly no plans to rlocat th currnt Bakrloo oprations thrfor any form of dvlopmnt on th sit can only b achivd with th construction of a dckd structur. As xprincd with similar schms, this is a vry complx structur that will nd to tak into account th currnt oprational nginring constraints, as such significant abnormal costs will b xprincd which will nd to b born by th schm. A modst or low dnsity schm is considrd to b an unviabl solution and thus unralistic for th sit, as such th proposals for th sit within th SPD would not b in accordanc with paragraph 154 of th NPPF. Th NPPF stats plans should proactivly driv and support sustainabl conomic dvlopmnt in addition to providing a framwork whrby dcisions can b mad with a high dgr of prdictability (para 17). To nsur th dvlopmnt aspirations for th sit can b ralisd and a viabl schm dlivrd, planning policy support is rquird for a tall structur at this location. Without th support of this policy position, thr is no dgr of crtainty that a tall schm would b considrd accptabl on th sit. Th sit rprsnts an xcllnt opportunity to bring forward significant dvlopmnt in a sustainabl urban location. In addition, th sit is situatd in th prominnt location of St Gorg s Circus btwn Blackfriars Road and On th Elphant, thus any futur dvlopmnt schm on th sit has th potntial to provid a landmark building acting as a stratgic gatway btwn ths locations and th ability to contribut positivly to th local charactr of th surrounding ara Th ara covrd by th draft SPD lis within th Banksid, Borough and London Bridg Opportunity Officr Rspons to Rprsntation Buildings, In light of consultation rsponss and to add clarity to th guidanc rlating to St Gorg s Circus in SPD 5, th SPD has bn updatd to clarify that a tall building could provid a focal point at th southrn nd of Blackfriars Road up to 70m. A tall building should also sustain, nhanc or bttr rval th local hritag assts. It should b notd that th SPD dos not provid sit spcific guidanc for sits and so thr is no dtaild guidanc for th Bakrloo sidings sit. Any dvlopmnt at th sit would b assssd and dtrmind at th planning application stag, taking th local hritag contxt into account. Th SPD stats that list of potntial dvlopmnt sits is illustrativ of th hug opportunity for chang within th ara and th nd for a cohrnt framwork. It has also bn updatd to clarify that th list of sits is not xhaustiv and othr sits may com forward for dvlopmnt. Som of th sits will b compltly rdvlopd, whilst othr sits may xprinc lss chang such as rfurbishmnt or improvmnts to th xisting buildings or surroundings. Th formal idntification and allocation of proposals sits within th ara will b considrd as part of th prparation of th Nw Southwark Plan. Th SPD and othr planning policy documnts provid th framwork for th provision of infrastructur to support dvlopmnt. Updats

177 Rp Obj Rf Rf Nam n Halth y Urban Dvlo pmnt Unit Dtails of Rprsntation Ara and adjoins th Elphant and Castl and Watrloo Opportunity Aras. Togthr ths aras hav to potntial to provid a minimum of 7,800 nw homs and 40,000 nw jobs. As such, dvlopmnt in th widr ara nds to tak plac in a coordinatd way and th cumulativ impact of dvlopmnt on social infrastructur, including on halthcar facilitis and srvics should b addrssd. Southwark and Lambth PCTs hav prviously xprssd th nd for nw or nhancd halth infrastructur in th Elphant and Castl and Watrloo aras Officr Rspons to Rprsntation hav bn mad to th SPD to rfr to ncouraging a rang of diffrnt uss/ SPD 2: Mixd us town cntr sts out that w will support th provision of nw social infrastructur and community facilitis as part of mixd us dvlopmnts. SPD 3: Public ralm and opn spac rfrs to th continud protction of th thr protctd opn spacs and ncouraging furthr linkags and nw spacs. Sction 4 of th SPD rfrs spcifically to infrastructur, crossing rfrring to th community infrastructur lvy (CIL) and sction 106 planning obligations to hlp nsur th dlivry of ky infrastructur to mitigat th impact of dvlopmnt. Infrastructur is covrd within borough-wid planning documnts with th ovrarching policy 14 of th Cor Stratgy rcognising that nw dvlopmnt in th borough nds to b supportd by adquat infrastructur, including social, nvironmntal and physical infrastructur. Th borough s Infrastructur Plan, idntifis stratgic infrastructur which is ndd to support growth and dvlopmnt in th borough ovr th liftim of th Cor Stratgy ( ). Whr possibl it idntifis th cost of infrastructur to providd, any committd sourcs of funding which will b usd to dlivr it and th organis rsponsibl. It also idntifis th funding gap i.. th gap btwn known commitmnts and th total cost of infrastructur rquird. Whn it is adoptd, Southwark s CIL will b usd to contribut towards bridging this funding gap. Funds armarkd for infrastructur in th Council s capital invstmnt programm also will hlp to improv infrastructur provision. Th council ar currntly prparing our draft community infrastructur charging schdul and an updatd sction 106 SPD. Adoption is plannd for It is appropriat to look at th provision of infrastructur at a borough-wid lvl through ths ddicatd documnts rathr than through th Blackfriars Road SPD.

178 Rp Obj Rf Rf Nam Malcolm Souch NHS 9 3 Londo n Halth y Urban Dvlo pmnt Unit Dtails of Rprsntation W support th intntion, in paragraph 3.15, to sk improvmnts to social infrastructur and kp th nd for nw infrastructur undr rviw as th ara changs. Howvr, thr is th nd to addrss th immdiat and futur impact of housing and population growth in Blackfriars Road and in th widr ara and work with srvic providrs and stakholdrs to plan for futur provision and addrss xisting capacity issus. Futur provision should addrss xisting and futur halthcar nds. Furthr discussions ar ndd with Southwark Clinical Commissioning Group and th Council s public halth tam. Officr Rspons to Rprsntation Th SPD and othr planning policy documnts provid th framwork for th provision of infrastructur to support dvlopmnt. Updats hav bn mad to th SPD to rfr to ncouraging a rang of diffrnt uss. SPD 2: Mixd us town cntr sts out that w will support th provision of nw social infrastructur and community facilitis as part of mixd us dvlopmnts. SPD 3: Public ralm and opn spac rfrs to th continud protction of th thr protctd opn spacs and ncouraging furthr linkags and nw spacs. Sction 4 of th SPD rfrs spcifically to infrastructur, crossing rfrring to th community infrastructur lvy (CIL) and sction 106 planning obligations to hlp nsur th dlivry of ky infrastructur to mitigat th impact of dvlopmnt. Infrastructur is covrd within borough-wid planning documnts with th ovrarching policy 14 of th Cor Stratgy rcognising that nw dvlopmnt in th borough nds to b supportd by adquat infrastructur, including social, nvironmntal and physical infrastructur. Th borough s Infrastructur Plan, idntifis stratgic infrastructur which is ndd to support growth and dvlopmnt in th borough ovr th liftim of th Cor Stratgy ( ). Whr possibl it idntifis th cost of infrastructur to providd, any committd sourcs of funding which will b usd to dlivr it and th organis rsponsibl. It also idntifis th funding gap i.. th gap btwn known commitmnts and th total cost of infrastructur rquird. Whn it is adoptd, Southwark s CIL will b usd to contribut towards bridging this funding gap. Funds armarkd for infrastructur in th Council s capital invstmnt programm also will hlp to improv infrastructur provision. Th council ar currntly prparing our draft community infrastructur charging schdul and an updatd sction 106 SPD. Adoption is plannd for It is appropriat to look at th provision of infrastructur at a borough-wid

179 Rp Obj Rf Rf Nam Malcolm Souch NHS 0 3 Londo n Halth y Urban Dvlo pmnt Unit Malcolm Souch NHS 1 3 Londo n Halth y Urban Dvlo pmnt Unit Dtails of Rprsntation Th list of potntial dvlopmnt sits (Tabl 1) provids no indication of plannd or potntial housing capacity. A Dvlopmnt Capacity Assssmnt for th ara was undrtakn in July 2011 and w would wlcom an updatd assssmnt. From a quick rviw of planning prmissions and applications in th Blackfriars Road ara thr is narly 2,000 rsidntial units in th piplin. Thr is littl rfrnc to th provision of affordabl housing and no commitmnt to a rang of unit sizs, including family housing. W would wlcom a widr commitmnt to tackl dprivation in trms of improving halth, crim and accss to mploymnt and housing. Officr Rspons to Rprsntation lvl through ths ddicatd documnts rathr than through th Blackfriars Road SPD. Th SPD sts out that it provids furthr guidanc to xisting planning policis in th Cor Stratgy and savd Southwark Plan. It dos not rpat borough wid policis and th SPD must b rad alongsid othr planning documnts. This is particularly th cas for housing, including affordabl housing. Housing is not givn its own sction within th SPD bcaus th borough-wid housing policis and guidanc alrady covr housing adquatly. This includs policis in th Cor Stratgy and savd Southwark Plan and SPDs on affordabl housing and rsidntial dsign standards. W ar currntly rviwing our Cor Stratgy and savd Southwark Plan and prparing th Nw Southwark Plan which will look at allocating proposals sits on th adoptd policis map. W will updat our dvlopmnt capacity assssmnt as part of this procss alongsid our currnt work on fding into th Mayor's Stratgic Housing Land Availability Assssmnt. In trms of widr commitmnt to tackling dprivation, this is covrd within xisting policis. Th sustainability appraisal also asssss th likly impact of th SPD guidanc on social, nvironmntal and conomic sustainability, including on indicators of halth, crim, mploymnt and housing. Ovrall it shows a likly positiv impact. Thr is no rfrnc to or analysis of currnt uss on Th figur and tabl within th SPD shows potntial dvlopmnt th 43 dvlopmnt sits or th potntial to rplac or provid nw social infrastructur. This includs Sit No 7 (45 Colombo Strt) which includs th Blackfriars Mdical Practic whr thy mayb opportunitis to rdvlop th halth cntr as part of a mixd-us dvlopmnt. sits. Ths sits ar idntifid by officrs as sits with th potntial for som chang to th building or its surroundings. Som of th sits hav planning prmission, som ar undr construction, som ar going through th planning procss, and som hav no known plans as yt. Th list and figur has bn updatd following consultation to tak into account suggstions from land ownrs and rsidnts. Furthr wording has also bn addd to th SPD to mak it clar that th list of sits is not xhaustiv and that whilst som of th sits will b compltly rdvlopd othr sits might xprinc lss chang such as rfurbishmnt or improvmnts to th xisting buildings or

180 Rp Obj Rf Rf Nam Dtails of Rprsntation Officr Rspons to Rprsntation surroundings Malcolm Souch NHS 2 3 Londo n Halth y Urban Dvlo pmnt Unit Malcolm Souch NHS 3 3 Londo n Halth y Urban Dvlo pmnt Unit Malcolm Souch NHS 4 3 Londo n Halth y W support th intntion to manag th provision of Notd. studnt accommodation as a concntration of studnt housing can hav a significant impact on halthcar srvics. Furthr discussions ar ndd as to th futur of th St Gorgs Halth Cntr (Sit No 38) and th Blackfriars Road Community Drug and Alcohol Tam providd by South London and Maudsly NHS Foundation Trust. W support SPD 2 Mixd us town cntr which ncourags a mix of uss taking into thir conomic and halth and wllbing impacts. Nw halthcar facilitis and srvics can contribut to th vitality and viability of cntrs. W support SPD 3 Public ralm and opn spac and SPD 6 Activ travl rcognising th nd to improv th nvironmntal quality of Blackfriars Road and th conditions for pdstrians and cyclists and th opportunity to manag traffic and crat a continuous Th SPD is not allocating sits as proposals sits and so dos not provid policis on th land uss within ach of th sits. Th allocation of proposals sits is don through a dvlopmnt plan documnt. Currnt dsignations for Blackfriars Road ar in th savd Southwark Plan (2007) which is currntly bing rviwd through th prparation of th Nw Southwark Plan. As part of this rviw w will b looking at whthr w should allocat mor and/or chang xisting proposals sits dsignations and updat th adoptd policis map. Full consultation will b carrid out on th Nw Southwark Plan in accordanc with our SCI and th rlvant rgulations. Support notd. Notd.

181 Rp Obj Rf Rf Nam Raul Pschir 5 2 a Raul Pschir 6 2 a Raul Pschir 7 2 a Urban Dvlo pmnt Unit Dtails of Rprsntation grn rout linking opn and public spacs. W wlcom th commitmnt to strngthn ast-wst links across Blackfriars Road btwn Watrloo and th South Bank, Banksid and London Bridg. I would lik to add my concrn and disappointmnt to th Blackfriars SPD, as it givs vry littl rfrnc to th ffcts on th local communitis who liv thr. I think that th Council and dvloprs should b much mor awar of th communitis that currntly liv in this ara, thir nds (currnt and futur) and how any dvlopmnt affcts thir livs now and for futur gnrations. Nowhr is thr any undrstanding or clar acknowldgmnt of how th dvlopmnt will actually bnfit popl who liv hr. Alrady w ar prssd on all sids by no lss than 6 hotls and vn mor studnt housing. With such a grat and growing transitory population, businsss ar not catring for local stablishd communitis but to th rquirmnt of tourists and short trm rsidnts. It is a moral obligation for th Council to support and prioritis th communitis that thy rprsnt. By favouring th rquirmnts of dvloprs and hotls abov th nds of local popl, th Council is rnging on its cntral obligation In this dvlopmnt thr is no quartr givn to th local popl. Vry tall offic blocks ar blocking light, Officr Rspons to Rprsntation Th SPD is intndd to bnfit a wid rang of groups including xisting and nw rsidnts. Th mrging vision has bn updatd to mak this clarr. Th SPD has also bn updatd within th supporting txt to SPD 2: Mixd us town cntr, that th SPD ara is mixd with both commrcial and rsidntial dvlopmnt. Th SPD sks to mt th nds of rsidnts whilst also managing th prssur for nw dvlopmnt. Th SPD has bn updatd to mak it clarr that th mrging vision and th SPD sks to nsur that dvlopmnt mts th nds of xisting and nw rsidnts whilst also attracting nw dvlopmnt. Rsidnts will bnfit from th incras rang of uss including mor shops, srvics and businsss along th Blackfriars Road. Th SPD is intndd to bnfit a wid rang of groups including xisting and nw rsidnts. Th mrging vision has bn updatd to mak this clarr. Th SPD has also bn updatd within th supporting txt to SPD 2: Mixd us town cntr, that th SPD ara is mixd with both commrcial and rsidntial dvlopmnt. Th SPD sks to mt th nds of rsidnts whilst also managing th prssur for nw dvlopmnt. Th SPD has bn updatd to mak it clarr that th mrging vision and th SPD sks to nsur that dvlopmnt mts th nds of xisting and nw rsidnts whilst also attracting nw dvlopmnt. Rsidnts will bnfit from th incras rang of uss including mor shops, srvics and businsss along th Blackfriars Road. Ths mattrs would b assssd at th planning application stag through th rlvant savd Southwark Plan policis, Cor Stratgy

182 Rp Obj Rf Rf Nam Raul Pschir 8 2 a Raul Pschir 9 2 a Raul Pschir 0 2 a Dtails of Rprsntation marring th local skylin and dvastating th sns of community (whil tall buildings look lgant in an architct's modl, th human xprinc and scal is compltly missd, crating wind tunnls, blak landscaps of glass and faturlss strtscaps that asthtically and litrally damag th local ara - tak th nw City building whos dsign litrally blinds and burns thos unlucky nough not in its hug dominant shadow ). Officr Rspons to Rprsntation Policy SP12 and th rlvant policis of th London Plan and planning rgulations. Bullt-point 14 of SPD 5 sts out furthr guidanc rgarding microclimat. You cannot in good conscinc allow dvloprs fr Th SPD provids guidanc intndd to bnfit a wid rang of rin in ovr-dvloping an ara to maximis thir groups including xisting and nw rsidnts. Existing policis in th profits at a hug cost on th living standards of th Cor Stratgy and savd Southwark Plan as wll as guidanc in topic communitis on th ground. Our historic quartr is basd SPDs provid th framwork alongsid this SPD, th NPPF bing dmolishd systmatically whil nothing of qual and th London Plan to dlivr sustainabl dvlopmnt. This or bttr dsign or purpos is built instad. Our includs policis and guidanc on th historic nvironmnt. Th SPD location is our gratst asst and w can dmand sks to mt th nds of rsidnts whilst also managing th dvloprs to know tow to local nds and provid prssur for nw dvlopmnt. Th SPD has bn updatd to mak it bautiful architctur bcaus this is an ara popl clarr that th mrging vision and th SPD sks to nsur that want to visit and liv dvlopmnt mts th nds of xisting and nw rsidnts whilst also attracting nw dvlopmnt. Rsidnts will bnfit from th incras rang of uss including mor shops, srvics and businsss along th Blackfriars Road. Improv th ara - ys, of cours! But allowing yourslvs to b hoodwinkd into bliving that xtrmly tall, imprsonal buildings, dstruction of historical buildings and contributing to an unsustainabl dnsity of hotls is th only way to attract dvlopmnt isn't bst foolish and at worst criminal W dsrv bttr. Southwark dsrvs bttr. W hav th talnt in city planning hr in this borough - rmmbr Coin Strt! - that can dsign profitably, culturally and asthtically whil cntring it all on th nds of th local community. By dmanding mor and rquiring mor from dvloprs, w can achiv Notd. Th SPD is intndd to bnfit a wid rang of groups including xisting and nw rsidnts. Th SPD sks to mt th nds of rsidnts whilst also managing th prssur for nw dvlopmnt. Th SPD has bn updatd to mak it clarr that th mrging vision and th SPD sks to nsur that dvlopmnt mts th nds of xisting and nw rsidnts whilst also attracting nw dvlopmnt.

183 Rp Obj Rf Rf Nam Dtails of Rprsntation this. And this SPD is not it. Not by a mil Esthr Bll I am writing to objct to th building of a towr block at 1 3 St Gorg s Circus and th dsignation of th Bakrloo sidings sit as a potntial dvlopmnt sit. Both of ths proposals would hav a ngativ impact on th local community. Any dvlopmnt on th Bakrloo sidings will intrfr with long viws into th Wst Squar Consrvation Ara valud by Southwark Planning. What considration has bn givn to ths in th prparation of this SPD? What is th vidnc to support its suitability as a dvlopmnt sit as opposd to ducational, opn spac or othr us? Any building on this sit will advrsly affct th stting of hritag assts. Th Elphant & Castl Entrpris Ara SPD mntiond a landmark building. W find rfrnc to any such building on this sit dply concrning givn th proximity not only to our own listd houss but also th listd oblisk, St Gorg s RC Cathdral and Imprial War Musum, th lattr two bing th landmark buildings in this location. How ar ths proposals affctd by th Blackfriars Road SPD? Esthr Bll St Gorg s Circus is a fin xampl of Gorgian town 2 3 planning with its focal point at its cntr, th Grad 2* listd oblisk. SPD 5 Building Hights proposs a tall building of hight up to 70 mtrs should provid a focal point at St Gorg s Circus. A tall building will affct th stting of not only th oblisk, an important hritag asst, but also th listd Gorgian trracs in London Road. Plas dmonstrat undr London Plan CDR1 how tall building dvlopmnt, a fundamntal chang in architctur, will not advrsly affct th Officr Rspons to Rprsntation Rsidnts will bnfit from th incras rang of uss including mor shops, srvics and businsss along th Blackfriars Road. A tall building up to 70m in hight could b appropriat at th southrn nd of Blackfriars Road providd that it complis with th dtaild guidanc outlind in SPD 5 and th currnt dvlopmnt plan that includs th rlvant policis of th savd Southwark Plan (2007), Cor Stratgy (2011), London Plan (2011) and othr planning documnts/guidanc, including th NPPF (2012). Th dvlopmnt plan sts out th policis for tall buildings. Th guidanc in th SPD provids dtail on how to implmnt ths dvlopmnt plan policis spcific to Blackfriars Road. Th approach is supportd by our vidnc bas including th Blackfriars Road Urban Dsign Study which has bn prpard in accordanc with CABE and English Hritag Guidanc on Tall Buildings, In light of consultation rsponss and to add clarity to th guidanc rlating to St Gorg s Circus in SPD 5, th SPD has bn updatd to clarify that a tall building could provid a focal point at th southrn nd of Blackfriars Road up to 70m. A tall building should also sustain, nhanc or bttr rval th local hritag assts. Th Elphant and Castl SPD was adoptd on 20 March 2012 and rplacd th Elphant and Castl Entrpris Quartr SPD (2008) and th Walworth Road SPD (2008). Th Blackfriars Road SPD will rplac th Elphant and Castl SPD/OAPF guidanc for th ovrlapping aras. Th SPD has bn updatd to mak this clarr. A tall building up to 70m in hight could b appropriat at th southrn nd of Blackfriars Road providd that it complis with th dtaild guidanc outlind in SPD 5 and th currnt dvlopmnt plan that includs th rlvant policis of th savd Southwark Plan (2007), Cor Stratgy (2011), London Plan (2011) and othr planning documnts/guidanc, including th NPPF (2012). Th dvlopmnt plan sts out th policis for tall buildings. Th guidanc in th SPD provids dtail on how to implmnt ths dvlopmnt plan policis spcific to Blackfriars Road.

184 Rp Obj Rf Rf Nam local charactr. Dtails of Rprsntation Esthr Bll No mntion is mad of nvironmntal impact assssmnts, wind and daylight modlling, which ar fundamntal rquirmnts in considring proposals of this natur, particularly considring th difficultis with th Palstra and Walki Talki buildings Esthr Bll Th documnt stats that crim will b rducd yt thr is no rfrnc to xisting or anticipatd crim statistics. Has th Mtropolitan Polic bn consultd? If ths studis hav bn obtaind and modlling carrid out thn ths should b in th public domain and not withhld. Plas advis whr ths may b sn. Officr Rspons to Rprsntation Th approach is supportd by our vidnc bas including th Blackfriars Road Urban Dsign Study which has bn prpard in accordanc with CABE and English Hritag Guidanc on Tall Buildings, In light of consultation rsponss and to add clarity to th guidanc rlating to St Gorg s Circus in SPD 5, th SPD has bn updatd to clarify that a tall building could provid a focal point at th southrn nd of Blackfriars Road up to 70m. A tall building should also sustain, nhanc or bttr rval th local hritag assts. Th GLA s rprsntation confirms that th Mayor supports th council s approach on tall buildings, but suggsts that th SPD should b mor flxibl in rlation to building hights, and that buildings in th rgion of 70/30m would b appropriat. Th council disagrs with this proposd amndmnt as it could allow buildings that ar gratr than th 70m/30m thrshold, which would b considrd inappropriat basd on our vidnc bas. As such, th council considrs SPD 5 to balanc local charactr and dvlopmnt potntial. Ths mattrs would b assssd at th planning application stag through th rlvant savd Southwark Plan policis, Cor Stratgy Policy SP12 and th rlvant policis of th London Plan and planning rgulations. Bullt-point 14 of SPD 5 sts out furthr guidanc rgarding microclimat. Th Mtropolitan Polic ar on th planning policy's mailing list and wr consultd as part of th consultation on th Blackfriars Road SPD. Th sustainability appraisal and th sustainability appraisal scoping rport which both informd th prparation of th SPD provid furthr information on th possibl impact of th SPD on crim. Th sustainability appraisal assssd th impact of th SPD guidanc on sustainability objctiv SDO4: To rduc th incidnc of crim and far of crim, and finds that th SPD is likly to ovrall hav a positiv impact. Th sustainability scoping rport also provids furthr information stting out information on th Indics of Multipl Dprivation which includs crim as on of its six indicators. Both documnts ar availabl to viw on th council's wb sit at:

185 Rp Obj Rf Rf Nam Dtails of Rprsntation Maxin Walkr Th SPD has vry littl to say about th social and 5 7 nvironmntal issus arising from intnsiv dvlopmnt. Indd it sms to hav largly forgottn th communitis who liv hr. It dos not addrss th gratst social problm facing aras such as this, th driving out of working class communitis as rnts gt highr and affordabl housing rmains byond th rach of vast parts of th population. In that sns its thos is simply that dvlopmnt is good, irrspctiv of whr it lads. I would argu that if dvlopmnt is not for popl thn who is it for? Maxin Walkr Although th SPD assrts that dvlopmnt crats mploymnt, it dos not offr any vidnc about th kind of mploymnt it crats or whthr local popl ar abl to tak up ths opportunitis. Indd th SPD has scant vidnc of any of its assrtions. For xampl it says thr will b a mix of shops for th local communitis and visitors. Currnt vidnc would indicat that this is not th cas with th Cut, for xampl dominatd by rstaurants and th normal highly pricd Sainsbury s and Tsco s and th loss of varid shops and a much missd laundrtt. Officr Rspons to Rprsntation and Th SPD sts out that it provids furthr guidanc to xisting planning policis in th Cor Stratgy and savd Southwark Plan. It dos not rpat borough wid policis and th SPD must b rad alongsid othr planning documnts. Housing is not givn its own sction within th SPD bcaus th borough-wid housing policis and guidanc alrady covr housing adquatly. This includs policis in th Cor Stratgy and savd Southwark Plan and SPDs on affordabl housing and rsidntial dsign standards. Existing policis and guidanc provid clar policis for affordabl housing. W hav also insrtd a nw appndix (appndix A) listing th ky borough wid Southwark planning policis and supplmntary planning guidanc to mak it clarr that ths policis nd to b rad alongsid th Blackfriars Road SPD. Sction 1 of th SPD has bn updatd to rfr to this nw appndix. Th SPD promots th dvlopmnt of a wid rang of town cntr uss, which will hlp to crat a varid mix of mploymnt opportunitis, such as rtail, offic, light industry, crativ and cultural jobs. Th council s Economic Wll-bing Stratgy ( ) sts out th ambition for rgnration and dvlopmnt to provid lasting jobs for rsidnts in both construction and rlatd industris and nd us job in dvlopmnts, through training and skills programms. Th council s adoptd Sction 106 Planning Obligations SPD sts out th dtail on scuring planning obligations from nw dvlopmnt for mploymnt and ntrpris masurs which includ initiativs to crat jobs and training in th final dvlopmnt, and also jobs and training during th construction priod of th dvlopmnt. Th council currntly sks to scur a contribution of th quivalnt cost of providing a Work Plac Coordinator to assist in th placmnt of unmployd jobskrs from th local ara into jobs within th final dvlopmnt ithr through an xisting programm, or through stting up a nw training and skills programm to targt th mploymnt sctor of th final dvlopmnt Th SPD provids furthr guidanc to

186 Rp Obj Rf Rf Nam Dtails of Rprsntation Maxin Walkr Although it assrts that it will tak th local historic nvironmnt into account, thr is no sign of this with th dmolition of th only surviving trrac on Blackfriars Road. Indd thr is littl sign in th documnt that anyon knows th history of th ara. Th proposal to hav vry tall buildings at th junction of Blackfriars Road/th Cut and St Gorg s has no mrit at all ithr in dsign, architctural, social or nvironmntal trms. Thy will b out of plac, ovrshadow rsidntial aras, crat mor wind tunnls (as Palstra has in Union Strt) and b alinating. Ths two aras alrady hav focal points, th monumnt at St Gorg s and th tub station at Southwark Maxin Walkr Although thousands of nw rsidntial units ar plannd thr ar no nw social amnitis. Whr ar ths childrn to play? Whr in th midst of hug uphaval and social chang ar childrn to mt, mak frinds? This is spcially important givn that nw dvlopmnts ar consistntly allowd to provid no play spac contrary to Mayor s rcommndations. If a plan dos not giv sufficint priority to childrn, thn what is it worth? Officr Rspons to Rprsntation xisting borough-wid planning policis. Th xisting adoptd policis ar basd upon a robust vidnc bas. For ky issus w hav st out furthr dtail in th businss and rtail background vidnc papr. A tall building up to 70m in hight could b appropriat at th southrn nd of Blackfriars Road providd that it complis with th dtaild guidanc outlind in SPD 5 and th currnt dvlopmnt plan that includs th rlvant policis of th savd Southwark Plan (2007), Cor Stratgy (2011), London Plan (2011) and othr planning documnts/guidanc, including th NPPF (2012). Th dvlopmnt plan sts out th policis for tall buildings. Th guidanc in th SPD provids dtail on how to implmnt ths dvlopmnt plan policis spcific to Blackfriars Road. Th approach is supportd by our vidnc bas including th Blackfriars Road Urban Dsign Study which has bn prpard in accordanc with CABE and English Hritag Guidanc on Tall Buildings, In light of consultation rsponss and to add clarity to th guidanc rlating to St Gorg s Circus in SPD 5, th SPD has bn updatd to clarify that a tall building could provid a focal point at th southrn nd of Blackfriars Road up to 70m. A tall building should also sustain, nhanc or bttr rval th local hritag assts. Th SPD and othr planning policy documnts provid th framwork for th provision of infrastructur to support dvlopmnt. Updats hav bn mad to th SPD to rfr to ncouraging a rang of diffrnt uss. SPD 2: Mixd us town cntr sts out that w will support th provision of nw social infrastructur and community facilitis as part of mixd us dvlopmnts. SPD 3: Public ralm and opn spac rfrs to th continud protction of th thr protctd opn spacs and ncouraging furthr linkags and nw spacs. Sction 4.4 of th SPD rfrs spcifically to infrastructur, crossing

187 Rp Obj Rf Rf Nam Dtails of Rprsntation Officr Rspons to Rprsntation rfrring to th community infrastructur lvy (CIL) and sction 106 planning obligations to hlp nsur th dlivry of ky infrastructur to mitigat th impact of dvlopmnt Maxin Walkr Planning should bgin with popl. In that sns th only documnt which givs any considration to social issus is th Equality Impact Assssmnt of th SPD. It too is ntirly dvoid of vidnc for any of its assrtions. For xampl it says: Th scal of chang proposd may potntially hav a ngativ/uncrtain impacts on som groups, and so th guidanc in Th implmntation sction sks to minimis this by rquiring construction managmnt plans and ncouraging dvloprs and contractors to work togthr and with th Banksid and London Bridg Logistics Group to coordinat all aspcts of th Infrastructur is covrd within borough-wid planning documnts with th ovrarching policy 14 of th Cor Stratgy rcognising that nw dvlopmnt in th borough nds to b supportd by adquat infrastructur, including social, nvironmntal and physical infrastructur. Th borough s Infrastructur Plan, idntifis stratgic infrastructur which is ndd to support growth and dvlopmnt in th borough ovr th liftim of th Cor Stratgy ( ). Whr possibl it idntifis th cost of infrastructur to providd, any committd sourcs of funding which will b usd to dlivr it and th organis rsponsibl. It also idntifis th funding gap i.. th gap btwn known commitmnts and th total cost of infrastructur rquird. Whn it is adoptd, Southwark s CIL will b usd to contribut towards bridging this funding gap. Funds armarkd for infrastructur in th Council s capital invstmnt programm also will hlp to improv infrastructur provision. Th council ar currntly prparing our draft community infrastructur charging schdul and an updatd sction 106 SPD. Adoption is plannd for It is appropriat to look at th provision of infrastructur at a borough-wid lvl through ths ddicatd documnts rathr than through th Blackfriars Road SPD Th SPD is intndd to bnfit a wid rang of groups including xisting and nw rsidnts. Th qualitis analysis has bn undrtakn alongsid th sustainability appraisal to assss th likly impact of th SPD on th nin protctd charactristic groups and a rang of sustainability indicators. Both rfr to vidnc whr appropriat and hav followd th council's and/or national/eu rquirmnts for carrying out ths assssmnts. Both hav bn updatd as part of th adoption of th SPD alongsid th prparation of a sustainability statmnt. Thr is also furthr vidnc which undrpins th Cor Stratgy and savd Southwark Plan policis including th Stratgic Housing Markt

188 Rp Obj Rf Rf Nam Dtails of Rprsntation construction procss including issus such as traffic managmnt, nois and pollution, local mploymnt opportunitis and public ralm works. This mitigation masur is likly to hav an impact on all groups including a bnficial impact by ncouraging local mploymnt opportunitis which may bnfit th young. Officr Rspons to Rprsntation Assssmnt, th Housing Rquirmnts Study, th Employmnt Land Rviw and th Rtail Capacity Study as wll as th Banksid, Borough and London Bridg charactri study. In particular th Stratgic Housing Markt Assssmnt and th Housing Rquirmnts Study st out a lot of dtail about rsidnts within th whol of Southwark Maxin Walkr For thos of us who hav livd with continuous Savd Southwark Plan policy 3.2 Protction of amnity, sts out that 0 7 building work for ovr a dcad and will liv with it for planning prmission will not b grantd whr it would caus loss of dcads mor, this is hardly a mitigation of ndlss amnity, including disturbanc from nois, to prsnt and futur nois, dust and disturbanc. Nor is it th cas that occupirs in th surrounding ara or on th application sit. Furthr larg scal building works ar monitord by Southwark guidanc is also st out in th Rsidntial Dsign Standards SPD, in any srious sns. Th vry last that should Sustainabl Transport SPD and th Sustainabl Dsign and happn is that dvloprs should b forcd to pay for Construction SPD. Frquntly planning conditions or sction 106 mor building control inspctors so that whn (as w planning obligations ar rquird as part of a planning prmission to saw in Union Strt whn th Travlodg buildrs nsur minimal impact and whr appropriat to nsur construction bgan dismantling scaffolding ovr th hads of managmnt plans. Th Blackfriars Road SPD also rfrs dirctly to passrs by) thr is an immdiat and robust rquiring construction managmnt plans in sction 4.3. rspons. As it is, th dvloprs mak a vry hug amount of mony and th local rsidnts and workrs pay th pric in halth trms. Nor is thr vidnc brought forward that mploymnt opportunitis will incras Maxin Walkr Th EIA dos not appar to hav rsultd from any 1 7 factual bas nor from consultation with th affctd groups. For xampl, it has bn rportd by local charitis that local ldrly popl ar bcoming gratly mor isolatd as thir childrn hav to mov out of th ara having bn pricd out. A littl invstigation would hav turnd up this fact rathr than mrrily assrting that all groups will bnfit from dvlopmnt. I would strongly suggst rsarch is commissiond about this ara, its charactr, history, strngths and problms and that this is fd into an ovrall dvlopmnt plan. That vidnc is brought forward Th SPD is intndd to bnfit a wid rang of groups including xisting and nw rsidnts. Th qualitis analysis has bn undrtakn alongsid th sustainability appraisal to assss th likly impact of th SPD on th nin protctd charactristic groups and a rang of sustainability indicators. Both rfr to vidnc whr appropriat and hav followd th council's and/or national/eu rquirmnts for carrying out ths assssmnts. Both hav bn updatd as part of th adoption of th SPD alongsid th prparation of a sustainability statmnt. In particular th qualitis analysis has bn updatd to cross rfr to th vidnc that undrpins th Cor Stratgy and savd Southwark Plan as wll as th mor rcnt vidnc documnts informing th Blackfriars Road SPD including th

189 Rp Obj Rf Rf Nam 749 Eiln Goodwa y Dtails of Rprsntation that dvlopmnt will produc mploymnt for local communitis and for th othr assrtions in this documnt. Abov all dvlopmnt should not b an xcus for th wholsal driving out of working class communitis from this and othr aras (as w hav sn in th Elphant.) Officr Rspons to Rprsntation Blackfriars Road Urban Dsign Study and th Banksid, Borough and London Bridg charactri study. Whn will Southwark Council vr b proud of th Commnts notd. Th SPD sks to provid guidanc to implmnt borough it runs and whn will w b proud of it? th policis in th savd Southwark Plan, Cor Stratgy and London History is rpating itslf as th council gos hll for Plan. As st out within th SPD it dos not rpat borough wid lathr for anothr bout of manic and dismal building. I policis and th SPD must b rad alongsid othr planning should b a fin borough and a fantastic plac to liv. documnts. Togthr ths documnts provid a framwork to dlivr Post war, th push for L Corbusir styl blocks mant and manag chang including policis and guidanc on protcting th that th 60s and 70s wr a goldn ag for dvloprs historic nvironmnt and th typ of appropriat dvlopmnt. and much that w would now valu was dmolishd. Panickd by its foolishnss th council thn obstructd intllignt dvlopmnt for th nxt fw dcads and th borough got lft bhind. Now faring it has missd som unidntifid gravy train th Planning Dpartmnt has rushd through anothr SPD that for Blackfriars Road. Btwn th misrabl 70s block ar what managd to surviv th wrcking ball last tim around but now w ar supposd to thrill to th ida of swping away ths for yt mor spculativ and likly undrusd building. Hasn t th council larnt anything? Whn is tru inspiration, calm considration and an ability to tak a long viw and not follow th hrd going to b a prrquisit for running Southwark Planning Dpartmnt? As an architct said to m at a consultation Blackfriars Road This is first class ara with third class prics. How much clarr dos h hav to b? A dvlopr has got a bargain and th Planning Dpartmnt (somthing of a misnomr) hav, in th Blackfriars Road SPD, writtn a chartr for him. W ar not a walth borough so why ar som of our gratst assts bing discardd so briskly and so chaply?

190 Rp Obj Rf Rf Nam 749 Eiln Goodwa y 749 Eiln Goodwa y Dtails of Rprsntation Activ frontags. What is th point of a long strt of shops thr was almost no dmand for thos rcntly built in Southwark Bridg Road and borough Road? Across our grat city almost 10% of shops ar unoccupid and our Town Cntr at th Elphant and Castl is only part occupid. Nw rnts will b too high for all but th boring chain stors, th intrsting shops w nd hav no chang and our prsnt shops will hav bn drivn out of businss. A rvitalisd Marylbon High Strt was achivd by a policy of low rnts and choic of a mixtur of tnantsth Gingr Pig butchr s shop pays lss thr than it dos in Borough Markt. Th Planning Dpartmnt say w cannot hav any such policy so how will it achiv `world class shopping for th ar? Hritag and grand dsigns. Th borough could not b luckir in having a rmarkabl pric of town planning, yt th plannrs in thir SPD disrgard this. A `boulvard Blackfriars Road may b but it only on of a sris of grand roads radiating from St Gorg s Circus. What a fantastic rsourc on which to crat an ara unlik any th in London. Th SPD largly disrgards housing, yt that is what cntral London sorly nds. Whilst having no borough architct surly it is not byond th whit of thos mployd to considr how fin Blackfriars Road could b if thy found a 21st cntury Haussmann or somon of th calibr of th architcts of Vinna s Ringstrass? How xciting it would b to hav a sympathtic but nlivning SPD. It could so asily aton for th sins of our prdcssors who wilfully dmolishd th Gorgian trrac in th 1070s. That this shabby documnt was launchd outsid th borough, at th Building Cntr, Stor Strt, WC1, bggars blif. Bad nough that Southwark wrot it but to broadcast to th world that Southwark is a pushovr for wily Officr Rspons to Rprsntation Th businss and rtail background vidnc papr sts out furthr dtail to SPD2 and th futur rtail capacity for th Banksid and Borough district town cntr. This dtail has bn rfrncd from th Southwark Rtail Capacity Study. Th study valuats th vitality and viability of th town cntr, in trms of its rtail prformanc and idntifid that th focus should b on continuing to mt th nds of workrs, tourists and visitors. Nw schms will b supportd by an incras in population in th ara, through nw rsidnts, workrs and visitors and ths will com forward on an incrmntal basis. W hav amndd SPD2 bullt 1 to includ rfrnc to supporting a rang of unit sizs for nw town cntr uss, which will ncourag a widr divrsity of offr. SPD paragraph sts out that th SPD provids furthr guidanc to xisting planning policis in th Cor Stratgy and savd Southwark Plan. It dos not rpat borough wid policis and th SPD must b rad alongsid othr planning documnts. Housing is not givn its own sction within th SPD bcaus th borough-wid housing policis and guidanc alrady covr housing adquatly. This includs policis in th Cor Stratgy and savd Southwark Plan and SPDs on affordabl housing and rsidntial dsign standards. Th vision alrady rfrs to housing dvlopmnt. Housing will b ncouragd on appropriat sits. In ordr to mak this clarr, w hav updatd SPD 2: Mixd us town cntr to includ rsidntial dvlopmnt as on of th uss to b ncouragd alongsid th provision of a mixtur of nw town cntr uss. Th fact box on town cntr uss has also bn updatd in accordanc with th National Planning Policy Framwork dfinition to mak it clar that rsidntial dvlopmnt is not a main town cntr us but it can play an important rol in nsuring th vitality of town cntrs.

191 Rp Obj Rf Rf Nam 749 Eiln Goodwa y 749 Eiln Goodwa y Dtails of Rprsntation dvloprs to public mbarrassmnt that should not b tolratd. Tall building. Southwark Plannrs told UNESCO it would tak car with tall building. Blackfriars Road cuts right across th viws from Wstminstr to th City as th Thams mandrs. Our uniqu, cntral, situation could add crucially to th gratnss of London yt our plannrs car so littl for it. Modlling. A poor substitut for xprinc. An ldrly rsidnt nar th rivr has said sh dos not car if sh dis. A nw high ris building has takn all hr sun. Hr flat is now cold and sh cannot afford to har it. With proposd canyon w will all b blown away or burnt to a cindr (th Palstra glar has much in common with th still incomplt Solar Dath Ray in th City). Who has com off wors? Not th dvlopr nor plannrs but thos having to liv with th consquncs. Dos modlling includ th cost to Southwark s Social Srvics of dprssion? This is not mant factiously. It is a cost. Officr Rspons to Rprsntation A tall building up to 70m in hight providd that it complis with th dtaild guidanc outlind in SPD 5 and th xisting planning policy framwork of dsign, hritag and tall building policis (th rlvant savd Southwark Plan policis, Cor Stratgy Policy SP12 and th rlvant policis of th London Plan) could b appropriat at th southrn nd of Blackfriars Road and at Southwark tub station. Th Blackfriars Road SPD urban dsign study sts out th vidnc bas. Th potntial impact on World Hritag Sits has bn assssd and informs th guidanc. Dtaild dsign mattrs would b assssd at th planning application stag through th rlvant savd Southwark Plan policis, Cor Stratgy Policy SP12 and th rlvant policis of th London Plan and planning rgulations. Bullt point 14 of SPD 5 sts out furthr guidanc rgarding microclimat. In 2008 th Planning Dpartmnt producs th An xplanation of th boundary is st out within th SPD. It includs Elphant & Castl SPD and fiv yars latr w hav th whol of th Blackfriars Road and som of th surrounding ara. It th Blackfriars Road SPD. Th aras ovrlap and th includs th surrounding ara as th surrounding ara is also likly to lattr contradicts th formr. Blackfriars Road SPD s som dvlopmnt and improvmnts, particularly possibl blatantly and cynically undrmins th Localism Act. improvmnts to public ralm. Wording has bn addd to th SPD to South Bank & Watrloo and Banksid Forums, mak it clarr that th charactr and historic valu of much of th composd of both businssmn and rsidnt, ar far surrounding ara will continu to b protctd and nhancd. It is mor rprsntativ and mor likly to achiv a fully appropriat to ovrlap with part of th boundary of th Elphant and functioning mixd conomy for th ar. Furthrmor Castl SPD (2012) to nsur cohrnt guidanc and considration of th SPD undrmins various Consrvation Ara St Gorg's Circus including th consrvation ara. Th SPD has Plans. What a mss. This latst documnt mrly bn updatd to mak it clarr that th guidanc in th Blackfriars adds anothr layr of buraucracy, incrass th Road SPD will rplac that in th Elphant and Castl SPD/OAPF for workload for planning officrs, frustrats good planning th ovrlapping ara. and abuss th planning hirarchy Th Planning Dpartmnt in its SPD sms to display slf intrst Figur 3 of th SPD illustrats th rlationship btwn diffrnt

192 Rp Obj Rf Rf Nam Anonym 7 5 ous Anonym 8 5 ous Anonym 9 5 ous 1 Dtails of Rprsntation and ignoranc about th ara and in so doing lis to th Planning Committ. If th Committ vot to accpt this SPD thn thy will b cuckolds onc mor. How low do our Planning Dpartmnt hav to stoop bfor th Chif Excutiv and lctd Councillors call thm to account? I was dismayd at th non-accssibl languag in th documnt. What on ars ar `agglomration bnfits and `synrgis - accommodatd or not? With difficulty I translatd `vhicular mod shar in to `prcntag and fnstration in to windows? Has your dpartmnt not har of th campaign for Plain English? On pag 22 it stats that Blackfriars... important that it is asy to undrstand! I could only wish you d graspd that concpt for th SPD documnt. Also as was said at th consultation mting your documnt should b radily and wholly, rcycl-abl. On to spcifics. No objction to `activ frontags but you don t addrss th activ rtailing by individuals with considrabl front around th drug clinic. Thy ar a major dtrrnt to using this strtch of road and I doubt this is th `uniqu idntity you ar aiming for. Plans? Not vn a littl tiny aim or ambition hr? I wish LBS would prsrv and nhanc th historic nvironmnt. London Homs now hav prmission to knock down historic pub/ St Gorgs mansions dspit strong community objction. What ls will w loos to provid mor Sainsbury rtail opportunitis? (Isn t it tim LBS considrd a saturation policy for thm?) Officr Rspons to Rprsntation planning documnts including supplmntary planning documnts and nighbourhood plans. Th SPD has bn updatd to mak it clar th nighbourhood plans ar currntly bing prpard. Onc adoptd a nighbourhood plan will hav mor wight than a SPD in th planning procss as it will form part of th council's dvlopmnt plan. At prsnt thr is no adoptd nighbourhood plan for any of th ara covrd by th Blackfriars Road SPD. Th SPD may nd to b rviwd in th futur if a nighbourhood plan is adoptd for any of th SPD ara. Notd. Th SPD has bn updatd whr appropriat to mak th guidanc as clar as possibl. A trackd chang vrsion of th SPD is availabl on our wbsit. Th SPD provids adquat dtail with rgard to activ frontags and building form. Th supporting txt promots th dvlopmnt of a finr grain in th dsign of larg frontags, to hlp nsur a human scal to th buildings fronting th strts, and which will hlp to nhanc th charactr of th strtscap and activat th public ralm. Th assssmnt and dtail of th Lindn Homs planning application is availabl in th Planning Committ rport which is availabl in th link blow. WRAP&RIPNAME=Root.PgRsultDtail&ThSystmky= SPD2 rcogniss thr is an opportunity to promot a much widr mix of town cntr uss in th SPD ara. This should includ a rang of diffrnt typs and sizs of rtailrs. Th SPD cannot dsignat land

193 Rp Obj Rf Rf Nam Anonym 0 5 ous Anonym 1 5 ous Anonym 2 5 ous 1 Dtails of Rprsntation SPD3 I m glad you intnd to nsur Nlson Squar is maintaind and nhancd but as a gardn, plas, not a `grn infrastructur You aim to introduc a ntwork of public spacs providd by nw dvlopmnt again `Lindn Homs has got away with not doing this. Whr xactly will thr nw pockt parks/grn spacs b? Suggstion - thr s a fncd off bit of grnry by St Gorg s Circus that could b a nw pockt park, which would srv as a contmplativ s spac for honouring th Cnotaph, nhancing it s stting. Opposit Southwark Tub Station, LBS could usfully ngag thir housing/parks dpartmnts in wding th ntranc paths, improving th planting and gnrally maintaining Nlson Squar stat. Hroic fforts ar mad by voluntrs, but w pay for nonxistnt srvics, so th ara looks shabby. At 3.18 you hold up Isablla Strt and Th Cut as good xampls for your vision. Laving asid that thy ar largly in Lambth, Th two aras hav distinct and ntirly diffrnt qualitis. Th Cut hosts chain coff stors of th kind that pay no UK tax, altrnating with branchs of Sainsbury s. It also, of cours has th thatrs, and th fantastic gardn at Styls Hous (undr constant thrat of planning blight!) It s a busy strt, and a complt contrast to Isablla Strt, which is lafy, nclosd, and a havn for wildlif, particularly birds. Which, if ithr, is your modl for Blackfriars Road? You could usfully crat a mor wlcoming ntranc to Isablla Strt from th tub station with gnrous landscaping around th Officr Rspons to Rprsntation us on dvlopmnt sits, howvr w will considr th rang of uss that would b appropriat for allocatd dvlopmnt sits through th prparation of th Nw Southwark Plan and its accompanying proposal sits map. Th SPD dos not dsignat proposals sits or provid sit spcific guidanc, as this would byond th scop of th SPD. It dos idntify potntial dvlopmnt sits which ar illustrativ of th hug opportunity for chang within th ara and th nd for a cohrnt framwork. Th SPD has also bn updatd to clarify that th list of sits is not xhaustiv and othr sits may com forward for dvlopmnt. Som of th sits will b compltly rdvlopd, whilst othr sits may xprinc lss chang such as rfurbishmnt or improvmnts to th xisting buildings or surroundings. SPD 3 and th Sction 4 Implmntation sts out how th council will continu to work with stakholdrs within th ara. Thr ar opportunitis for a varity of public spacs along and off Blackfriars Road. Th guidanc in th SPD supports th cration of nw and nhancd public ralm. Southwark tub station and 1 Joan Strt ar idntifid as potntial dvlopmnt sits. Th SPD dos not dsignat proposals sits, mak sit allocations or provid sit spcific guidanc, as this would byond th scop of th SPD. It dos idntify potntial dvlopmnt sits which ar illustrativ of th hug opportunity for chang within th ara and th nd for a cohrnt framwork. Som of th sits will b compltly rdvlopd, whilst othr sits may xprinc lss chang such as rfurbishmnt or improvmnts to th xisting buildings or surroundings.

194 Rp Obj Rf Rf Nam Anonym 3 5 ous 1 Dtails of Rprsntation Boris biks compound. This would link to Nlson Squar, providing a grn corridor and provid a mor attractiv introduction to th ara, and a countr-point to th concrt/glass. SPD I am implacably opposd to any plans you 70m buildings at Southwark tub and St Gorgs Circus. Th road is alrady `bookd ndd by tall building. Any mor `books and you ll hav `book-cas ffct. NO! St Gorg s Circus alrady has a `focal point in th historic shap of th Cnotaph this should b nhancd? for ida of gardn), not dscratd for financial grdinss by dvloprs (and LBS). At th tub station thr is alrady a `focal point in th highly (56m) undsirabl shap of Palstra which dominats th `strtscap, du to its `iconic dsign it is clarly visibl th lngth of Blackfriars Road, satisfying any possibl nd to way find/idntify /gatway th station. And sinc whn did popl start navigating th strts from on tall building to th nxt, lik pigons? A 70m building ovr th tub station is going to b an normous, costly, and disruptiv plan. Do you think potntial businsss, rsidnts nw and old will wlcom this? Th tub is xtrmly busy, usd by many tourists as wll. OK, thr s narby Watrloo, but that is busy too. Isablla Strt would los it s ssnc of businss, Nlson Squar (particularly Rowland Hill Hous) will b cast into shadow W hav alrady sn th ngativ ffcts of shading and wind-tunnls Rsulting from Palstra on our day-light and gardns. No mor! Thn thr is th scurity issu Palstra is currntly ring-of-stling thir sit, such as th snsitivity of oprations thr. What ar th ky trrorists targts? Tall buildings (baltic x 2), transport (7/7), snsitiv Govrnmnt oprations Th ground floor is wll dfndd, whr do you aim? OK, I watch too many pisods of spooks, but you don t Officr Rspons to Rprsntation A tall building up to 70m in hight could b appropriat at th southrn nd of Blackfriars Road and Southwark tub station, providd that it complis with th dtaild guidanc outlind in SPD 5 and th currnt dvlopmnt plan that includs th rlvant policis of th savd Southwark Plan (2007), Cor Stratgy (2011), London Plan (2011) and othr planning documnts/guidanc, including th NPPF (2012). Th dvlopmnt plan sts out th policis for tall buildings. Th guidanc in th SPD provids dtail on how to implmnt ths dvlopmnt plan policis spcific to Blackfriars Road. Th approach is supportd by our vidnc bas including th Blackfriars Road Urban Dsign Study which has bn prpard in accordanc with CABE and English Hritag Guidanc on Tall Buildings, In light of consultation rsponss and to add clarity to th guidanc rlating to St Gorg s Circus in SPD 5, th SPD has bn updatd to clarify that a tall building could provid a focal point at th southrn nd of Blackfriars Road up to 70m. A tall building should also sustain, nhanc or bttr rval th local hritag assts. Dtaild dsign mattrs would b assssd at th planning application stag through th rlvant savd Southwark Plan policis, Cor Stratgy Policy SP12 and th rlvant policis of th London Plan and planning rgulations.

195 Rp Obj Rf Rf Nam Anonym 4 5 ous Anonym 5 5 ous 1 Dtails of Rprsntation nd much imagination to dtrmin ngativ possibilitis of an ovr-looking towr by Palstra SPD. Activ travl. How do you dfin in-activ travl? OK, walking is halthy, spcially if you don t risk trips/falls on currnt unvn pavmnt. Sgrgatd cycl routs- prfct. Why do popl not walk? Handy shops, bus stops, tub stations all clos by, so no nd. Howvr, local shops don t hav all you nd, and local Sainsbury/Tsco don t carry `valu lins, so chapr to go to largr stor. How ar you gtting thr, and mor importantly back hom with thos havy tins/bulky loo rolls if you don t driv/ no parking/car-fr dvlopmnt? Not cycling, rally so, bus! OK, fwr trips, monthly shop or, ordr it all ovr th intrnt and gt dlivrd. Circl living-room for an hour to mt /comply with LBS policy on activ travl. Thr is not on word on supporting thos with mobility problms to accss th nw and xciting activ Sainsbury frontags. Of cours whlchair usrs will bnfit from smoothr pavmnts tc. Howvr, thos of us not at th stag, but with dodgy kns bipdally activly transporting ourslvs forth and back, prmably, to th chapr stors at th Elphant and Castl would wlcom inactivity way stations (bnchs). Thr w can admir th finr grain buildings; contmplat th mystris of accommodating synrgis and Sainsbury s pricing policy in smallr stors; and pondr on th folly of tall buildings at St Gorgs Circus and Southwark tub station. So, to finalis. Thanks again for th ffort. If you can Commnts notd. contain th urg to dscrat hritag monumnts, flattn much-lovd buildings; truly nsur that nw builds rflct th historic /listd buildings, dtrmin no mor Valntin Plac horrors allowd; actually gt Officr Rspons to Rprsntation Th council activly supports provision of facilitis for th mobility impaird and as statd in sction 1 of th SPD, this SPD provids furthr guidanc to xisting policis in th Cor Stratgy, savd Southwark Plan and othr SPDs such as Sustainabl Transport but dos not rpat borough wid policis or objctivs includd in othr policy documnts. Th Sustainabl Transport SPD sts out spcific policis that rlat to thos with lss mobility including car parking provision. Appndix A also cross rfrs to ky xisting Southwark policis.

196 Rp Obj Rf Rf Nam Dtails of Rprsntation nw grn spacs, avoid pdstrians bing flattnd by cyclists, and stop frtting about us `undrstanding Blackfriars Road, you may yt succdd on providing a visionary and lasting lgacy Chris Jan I am writing to xprss my concrn du to som of th 6 8 faturs in th draft plans for Blackfriars Road and th surrounding ara. Ths includ; 1. Provision for a towr block 70 mtrs high at St Gorg s Circus This is xcdingly high, taking into account what is on and around this strt this would dwarf th structurs and b out of charactr. St Gorg s Circus is a fin xampl of Gorgian town planning with its focal point at its cntr, th Grad 2* listd oblisk. SPD 5 Building Hights proposs a tall building of hight up to 70 mtrs should provid a focal point at St Gorg s Circus. This statmnt displays a fundamntal ignoranc of this circus. A tall building will affct th stting of not only th oblisk, an important hritag asst, but also th listd Gorgian trracs in London Road. Plas dmonstrat undr London Plan CDR1 how tall building dvlopmnt, a fundamntal chang in architctur, will not advrsly affct th local charactr. Officr Rspons to Rprsntation Th policy approach within th SPD is considrd to b consistnt with th NPPF (2012), th London Plan (2011), th Cor Stratgy (2011) and th savd Southwark Plan (2007), taking into account changs in th surrounding contxt sinc dvloping th Cor Stratgy vision in 2009/2010. Th London Plan, Cor Stratgy and savd Southwark Plan form th dvlopmnt plan for Southwark, with th NPPF stting out national guidanc. Th dvlopmnt plan sts out th policis for tall buildings. Ky policis ar: London Plan policy 7.7 which idntifis that tall and largr buildings should gnrally b limitd to sits in th Cntral Activitis Zon, opportunity aras, aras of intnsification or town cntrs that hav good accss to public transport. Blackfriars Road lis within th Cntral Activitis Zon, is an opportunity ara and a town cntr with good accss to public transport. Cor Stratgy stratgic policy 12 rquirs tall buildings to hav an xmplary standard of dsign and idntifis locations whr tall buildings could go. Th Cor Stratgy vision for Banksid and Borough rfrs to th council stting out in dtail which sits ar appropriat, snsitiv and inappropriat for tall buildings through th supplmntary planning documnt/opportunity ara framwork. Savd Southwark Plan policy 3.20 sts out critria for considring applications for tall buildings and applis across th borough A tall building up to 70m in hight could b appropriat at th southrn nd of Blackfriars Road providd that it complis with th dtaild guidanc outlind in SPD 5 and th currnt dvlopmnt plan that includs th rlvant policis of th savd Southwark Plan (2007), Cor Stratgy (2011), London Plan (2011) and othr planning documnts/guidanc, including th NPPF (2012). Th approach is supportd by our vidnc bas including th Blackfriars Road Urban Dsign Study which has bn prpard in accordanc with CABE and English Hritag Guidanc on Tall Buildings, In light of consultation rsponss and to add clarity

197 Rp Obj Rf Rf Nam Dtails of Rprsntation Chris Jan Whr is th comprhnsiv urban dsign analysis of 7 8 th local charactr and historic contxt? (CABE and English Hritag Guidanc on Tall Buildings CDN25) Officr Rspons to Rprsntation to th guidanc rlating to St Gorg s Circus in SPD 5, th SPD has bn updatd to clarify that a tall building could provid a focal point at th southrn nd of Blackfriars Road up to 70m. A tall building should also sustain, nhanc or bttr rval th local hritag assts. Th approach is supportd by our vidnc bas including th Blackfriars Road Urban Dsign Study which has bn prpard in accordanc with CABE and English Hritag Guidanc on Tall Buildings, Chris Jan Dvlopmnt sits 39, 40, 41 and 43 dirctly affct th Th SPD dos not dsignat proposals sits or provid sit spcific 8 8 Circus and othr hritag assts. Council officrs hav guidanc, as this would byond th scop of th SPD. It dos idntify statd that tall buildings at St Gorg s Circus would potntial dvlopmnt sits which ar illustrativ of th hug not b a conflict with th adjoining hritag assts. opportunity for chang within th ara and th nd for a cohrnt Whr is th vidnc that this is not a conflict? framwork. Th SPD has also bn updatd to clarify that th list of sits is not xhaustiv and othr sits may com forward for dvlopmnt. Som of th sits will b compltly rdvlopd, whilst othr sits may xprinc lss chang such as rfurbishmnt or improvmnts to th xisting buildings or surroundings Chris Jan In dtrmining tall building hight limits within th SPD 9 8 of 70 mtrs, whr is th assssmnt of thr dimnsional modlling to dtrmin th potntial ffct on th local contxt? (CABE and English Hritag Guidanc on Tall Buildings CDN25) Chris Jan Why ar hotls bing promotd (SPD 3.10) as viabl us whn Southwark has alrady achivd or is clos to achiving th rquirmnts. Th figurs for hotl rooms in th SPD mak it clar that, of th 2500 bdrooms rquird by th GLA s Hotl Dmand Study 2006 by 2026, all but 75 hav ithr bn built or ar in th piplin. Th approach is supportd by our vidnc bas including th Blackfriars Road Urban Dsign Study which has bn prpard in accordanc with CABE and English Hritag Guidanc on Tall Buildings, 2007 Th London Plan sks to achiv 40,000 nt additional hotl bdrooms by 2031.Th stimat of th approximat nt and gross hotl rooms rquird ovr th priod for Southwark, as st out in th GLA s Hotl Dmand Study, is basd on assssmnt of factors including transport links to cntral London and connctions to airports, proximity of tourist attractions/businss locations, cafs and rstaurants in th ara, night tim conomy, cultural facilitis and attractions, and rgnration initiativs and sit availability. Th forcast for Southwark should b tratd as indicativ only, and local circumstancs should also b factord in. It is important to considr that th SPD ara is within th Cntral Activitis Zon, Banksid, Borough and London Bridg Opportunity Ara and part of th Elphant and Castl Opportunity Ara which ar aras promotd in

198 Rp Obj Rf Rf Nam Dtails of Rprsntation Chris Jan 2: Th dsignation of th Bakrloo sidings sit as a potntial dvlopmnt sit. In including larg aras of land that hav nothing to do with Blackfriars Road, Southwark Council will undrmin Nighbourhood Forums (South Bank and Watrloo Nighbourhood Forum and th Banksid Nighbourhood Forum) and th Localism Act Can th council dmonstrat that th SPD will giv a bttr outcom than thos nvisagd by Nighbourhood Forums? Dvlopmnt Sit 43 Th Bakrloo Sidings Any dvlopmnt on this sit will intrfr with long viws into th Wst Squar Consrvation Ara valud by Southwark Planning. What considration has bn givn to ths in th prparation of this SPD? What is th vidnc to support its suitability as a dvlopmnt sit as opposd to ducational, opn spac or othr us? Undr th Elphant & Castl Entrpris Quartr SPD Southwark should hav consultd TfL. Undr th Localism Act consults ar duty bound to co-oprat so whr may w s TfL s rspons? Any building on Officr Rspons to Rprsntation th London Plan to accommodat stratgically important hotl provision. Arts, cultural and tourism activitis hav flourishd in Southwark in th last dcad, particularly in th Stratgic Cultural Ara, which is within th CAZ. Banksid, Borough and London Bridg has consquntly xprincd a growth in th numbr of hotls to support this incrasing visitor conomy. SPD2 provids guidanc to support Cor Stratgy policy 10 Jobs and businss which sts out th council will allow th dvlopmnt of hotls within th town cntrs, th stratgic cultural aras, and placs with good accss to public transport srvics, providing that ths do not harm th local charactr. Policy 10 and SPD 2 ar also supplmntd by th savd policy 1.12 of th Southwark Plan which addrsss visitor accommodation. Nw hotl proposals in th ara will b assssd against ths rlvant planning policis and a considration of th impact upon local amnity and th balanc of land uss will also b takn into account. Th TfL Bakrloo sidings sit (Sit 43 in Figur 5/Tabl 1 in th draft SPD, but r-numbrd as Sit 47 in Figur 6/Tabl 1 in th updatd SPD) has bn includd as a potntial dvlopmnt sit, du to its rcognisabl dvlopmnt potntial. Any dvlopmnt at th sit would b assssd and dtrmind at th planning application stag, taking into account local contxt, which includs th local hritag assts. Th SPD dos not dsignat proposals sits or provid sit spcific guidanc, as this would byond th scop of th SPD. It dos idntify potntial dvlopmnt sits which ar illustrativ of th hug opportunity for chang within th ara and th nd for a cohrnt framwork. Th SPD has also bn updatd to clarify that th list of sits is not xhaustiv and othr sits may com forward for dvlopmnt. Som of th sits will b compltly rdvlopd, whilst othr sits may xprinc lss chang such as rfurbishmnt or improvmnts to th xisting buildings or surroundings. Th SPD is rsponding to dvlopmnt prssur and th potntial for picmal dvlopmnt. Th guidanc st out within th SPD is

199 Rp Obj Rf Rf Nam Dtails of Rprsntation this sit will advrsly affct th stting of hritag assts. Th Elphant & Castl Entrpris Ara SPD mntiond a landmark building. W find rfrnc to any such building on this sit dply concrning givn th proximity not only to our own listd houss but also th listd oblisk, St Gorg s RC Cathdral and Imprial War Musum, th lattr two bing th landmark buildings in this location. How ar ths proposals affctd by th Blackfriars Road SPD? Officr Rspons to Rprsntation consistnt with th xisting planning policy framwork of dsign, hritag and tall building policis, which includs th rlvant savd Southwark Plan policis, Cor Stratgy Policy SP12, th rlvant policis of th London Plan and th NPPF. Any forthcoming nighbourhood plans also has to b consistnt with th adoptd planning framwork. TfL, GLA and Ntwork Rail wr all consultd as part of th consultation procss. Th Blackfriars Road SPD consultation rport summariss all th rsponss rcivd and changs subsquntly mad to th SPD. Th full rprsntations rcivd from ths bodis and th council s rspons to thm is includd within Appndix J of th Blackfriars Road SPD consultation rport. Th Elphant and Castl SPD was adoptd on 20 March 2012 and rplacd th Elphant and Castl Entrpris Quartr SPD (2008) and th Walworth Road SPD (2008). Th Blackfriars Road SPD will rplac th Elphant and Castl SPD/OAPF guidanc for th ovrlapping aras. Th SPD has bn updatd to mak this clarr Chris Jan Th Council s Cor Stratgy 2010 dos not support tall Th policy approach within th SPD is considrd to b consistnt 2 8 buildings in Blackfriars Road South, as thy do not with th NPPF (2012), th London Plan (2011), th Cor Stratgy mt th critria for vision vibrancy and lif. Why (2011) and th savd Southwark Plan (2007), taking into account dos th Council s vision now diffr from th Cor changs in th surrounding contxt sinc dvloping th Cor Stratgy? Stratgy vision in 2009/2010. Th London Plan, Cor Stratgy and savd Southwark Plan form th dvlopmnt plan for Southwark, with th NPPF stting out national guidanc. Th dvlopmnt plan sts out th policis for tall buildings. Ky policis ar: London Plan policy 7.7 which idntifis that tall and largr buildings should gnrally b limitd to sits in th Cntral Activitis Zon, opportunity aras, aras of intnsification or town cntrs that hav good accss to public transport. Blackfriars Road lis within th Cntral Activitis Zon, is an opportunity ara and a town cntr with good accss to public transport. Cor Stratgy stratgic policy 12 rquirs tall buildings to hav an xmplary standard of dsign and idntifis locations whr tall buildings could go. Th Cor Stratgy vision for Banksid and Borough rfrs to th council stting out in dtail which sits ar

200 Rp Obj Rf Rf Nam Dtails of Rprsntation Chris Jan In 2012 UNESCO notd in its convntion brifing papr that in April 2011 Southwark s Cor Stratgy includs an mphasis on hritag assts and rviss thir approach to tall buildings on th ara. Why has th council rngd on this? UNESCO s World Hritag Committ Rport Jun 2012 nots th intntion of Southwark Council to dvlop a Supplmntary Planning documnt to clarify how and whr dvlopmnt can tak plac and to dfin building hight thrsholds so as to inform th appropriatnss of subsqunt dvlopmnt proposals. Is this th said SPD? Ptr Earnsha 4 9 w Th Council in promoting this SDP is sking to chang its policy on tall buildings from that containd within th Cor Stratgy, which stats that Blackfriars Road South is not a suitabl location for tall buildings. Any SPD currntly proposd must conform to xisting policis of th Cor Stratgy and savd policis of th Southwark Plan. It cannot claim to conform to a nw Southwark Plan, which dos not xist. If a nw Southwark Plan is to b producd it should follow Officr Rspons to Rprsntation appropriat, snsitiv and inappropriat for tall buildings through th supplmntary planning documnt/opportunity ara framwork. Savd Southwark Plan policy 3.20 sts out critria for considring applications for tall buildings and applis across th borough It should b notd that th GLA is supportiv of th approach to building hights. Th GLA s rprsntation confirms that th Mayor supports th council s approach on tall buildings, but suggsts that th SPD should b mor flxibl in rlation to building hights, and that buildings in th rgion of 70/30m would b appropriat. Th council disagrs with this proposd amndmnt as it could allow buildings that ar gratr than th 70m/30m thrshold, which would b considrd inappropriat basd on our vidnc bas. As such, th council considrs SPD5 to balanc local charactr and dvlopmnt potntial. Th UNESCO papr rlats to th ara around London Bridg and th potntial impact of tall buildings on th stting of th Towr of London World Hritag Sit. Th hights proposd in th Blackfriars Road SPD building hights stratgy ar consistnt with Southwark s dvlopmnt plan consisting of th savd Southwark Plan polics, Cor Stratgy and th London Plan. Our tsting shows that th proposd hights would not impact th stting of th Towr of London sit. Th proposd 70m thrshold guidanc for th southrn of Blackfriars Road rsponds to th snsitivity of th Palac of Wstminstr World Hritag sit. Th guidanc st out within th SPD is consistnt with th xisting planning policy framwork of dsign, hritag and tall building policis, which includs th rlvant savd Southwark Plan policis, Cor Stratgy Policy SP12, th rlvant policis of th London Plan and th NPPF. Th guidanc proposd falls within th rmit of an SPD. It is not an AAP and dos not propos nw policy for th ara. Th Blackfriars Road SPD urban dsign study sts out th vidnc bas. Th urban dsign study utiliss a robust mthodology that has prviously bn agrd with English Hritag, and 3D modlling

201 Rp Obj Rf Rf Nam Ptr Earnsha 5 9 w Dtails of Rprsntation corrct protocol and b accordanc with th London Plan and th NPPF and rciv approval of th Scrtary of Stat. It is from this documnt that any futur SPDs should flow. This appars to b an attmpt by th Council to circumvnt th stricturs of its own policy and also thos of national govrnmnt, prhaps in an ffort to support th application by Barratt for a 70 mtrs high towr at St Gorgs Circus, which fails to comply with currnt policy. Plas xplain why this invrtd approach is bing takn and how th NPPF justifis th chang in policy bing promotd by this SPD. Thr is no justification for tall buildings around St Gorgs Circus. St Gorgs Circus with its cntral fatur and wid radiating roads stands alon as a past xampl of Gorgian circus dsign in South London. With its cntral Grad II* listd oblisk it is itslf th focal point. To construct a 70 mtr high towr adjacnt to it as a focal point can only distract from th importanc of th historic circus and hav a dtrimntal ffct on its stting and th local consrvation aras. Whr has th imptus for this building com from and whr is th town planning vidnc bas to support such a contntion? Officr Rspons to Rprsntation tchniqus to assss th potntial impact on hritag assts. Th study updats th tsting from th prvious urban dsign studis in light of guidanc st out in th NPPF, th London Plan that was adoptd aftr th Cor Stratgy, schms that alrady hav bn consntd within th ara and xisting dvlopmnt prssur that could lad to picmal dvlopmnt within th ara. Th GLA s rprsntation confirms that th Mayor supports th council s approach on tall buildings, but suggsts that th SPD should b mor flxibl in rlation to building hights, and that buildings in th rgion of 70/30m would b appropriat. Th council disagrs with this proposd amndmnt as it could allow buildings that ar gratr than th 70m/30m thrshold, which would b considrd inappropriat basd on our vidnc bas. As such, th council considrs SPD5 to balanc local charactr and dvlopmnt potntial. Th policy approach within th SPD is considrd to b consistnt with th NPPF (2012), th London Plan (2011), th Cor Stratgy (2011) and th savd Southwark Plan (2007), taking into account changs in th surrounding contxt sinc dvloping th Cor Stratgy vision in 2009/2010. Th London Plan, Cor Stratgy and savd Southwark Plan form th dvlopmnt plan for Southwark, with th NPPF stting out national guidanc. Th dvlopmnt plan sts out th policis for tall buildings. Ky policis ar: London Plan policy 7.7 which idntifis that tall and largr buildings should gnrally b limitd to sits in th Cntral Activitis Zon, opportunity aras, aras of intnsification or town cntrs that hav good accss to public transport. Blackfriars Road lis within th Cntral Activitis Zon, is an opportunity ara and a town cntr with good accss to public transport. Cor Stratgy stratgic policy 12 rquirs tall buildings to hav an xmplary standard of dsign and idntifis locations whr tall buildings could go. Th Cor Stratgy vision for Banksid and Borough rfrs to th council stting out in dtail which sits ar appropriat, snsitiv and inappropriat for tall buildings through th supplmntary planning documnt/opportunity ara framwork. Savd Southwark Plan policy 3.20 sts out critria for considring applications for tall buildings and applis across th borough Th approach is supportd by our vidnc bas including th Blackfriars

202 Rp Obj Rf Rf Nam Ptr Earnsha 6 9 w Ptr Earnsha 7 9 w Ptr Earnsha 8 9 w Dtails of Rprsntation Th Draft SPD attmpts to justify a cas for tall buildings adjacnt to St Gorgs Circus by claiming it to b a transport nod. This is fals. Buss ar th only public transport availabl, yt bus stops ar rmot from th Circus and thr ar no intrchangs. A fin pic of Gorgian town planning, which would b a sourc of civic prid in most Europan capitals has bn rducd to a traffic roundabout. Why dos th Draft SPD not contain any substantiv ncouragmnt for th improvmnt of this hritag asst? Why dos th draft SPD not contain a schdul of historic buildings or buildings with potntial to b listd as would normally b producd to dmonstrat that th proposals ar sympathtic to ths? Th draft SPD claims that th local charactr will b nhancd. Bing physically a rsidntial and small businss ara it is difficult to conciv that th charactr of Blackfriars Road will b nhancd by buildings ranging in hight from mtrs. Whr is th vidnc to support this claim? Officr Rspons to Rprsntation Road Urban Dsign Study which has bn prpard in accordanc with CABE and English Hritag Guidanc on Tall Buildings, In light of consultation rsponss and to add clarity to th guidanc rlating to St Gorg s Circus in SPD 5, th SPD has bn updatd to clarify that a tall building could provid a focal point at th southrn nd of Blackfriars Road up to 70m. A tall building should also sustain, nhanc or bttr rval th local hritag assts. In light of consultation rsponss and to add clarity to th guidanc rlating to St Gorg s Circus in SPD 5, th SPD has bn updatd to clarify that a tall building could provid a focal point at th southrn nd of Blackfriars Road up to 70m. A tall building should also sustain, nhanc or bttr rval th local hritag assts. Th SPD also sts out clar guidanc for th nhancmnt of St Gorg s Circus in SPD 3, 4 and 6 Guidanc and th idntification of buildings will b addrssd in a nw Hritag SPD that will b prpard alongsid th Nw Southwark Plan. Th policy approach within th SPD is considrd to b consistnt with th NPPF (2012), th London Plan (2011), th Cor Stratgy (2011) and th savd Southwark Plan (2007), taking into account changs in th surrounding contxt sinc dvloping th Cor Stratgy vision in 2009/2010. Th London Plan, Cor Stratgy and savd Southwark Plan form th dvlopmnt plan for Southwark, with th NPPF stting out national guidanc. Th dvlopmnt plan sts out th policis for tall buildings. Ky policis ar: London Plan policy 7.7 which idntifis that tall and largr buildings should gnrally b limitd to sits in th Cntral Activitis Zon, opportunity aras, aras of intnsification or town cntrs that hav good accss to public transport. Blackfriars Road lis within th Cntral Activitis Zon, is an opportunity ara and a town cntr with good accss to public

203 Rp Obj Rf Rf Nam Ptr Earnsha 9 9 w Ptr Earnsha 0 9 w Charls Muriithi Enviro nmnt Agnc y Dtails of Rprsntation Thr is no schdul of buildings which ar ownd by Southwark Council. What assuranc can th Council giv that whr ths xist and ar to b considrd for disposal of that thy will first b considrd for th dirct bnfit of th community and if sold thy will b sold at markt valu? In summary th issuing of th draft SDP is procdurally flawd. Insofar as Blackfriars Road South is concrnd it displays a lack of undrstanding of th ara and its community. It offrs no vidnc basd proposals and should b withdrawn forthwith. Thank you for consulting th Environmnt Agncy on th abov which w rcivd on 12 August W wlcom this supplmntary planning documnt and hop it will mt its aim of providing a stratgic framwork and dtaild guidanc to coordinat futur growth along and around th Blackfriars Road. W hav bn closly involvd in supplying data and information to support th local plans vidnc bas including th Cor Stratgy, Banksid, Borough and London Bridg Opportunity Ara and Elphant and Castl SPD/Opportunity Ara Planning Framwork. Officr Rspons to Rprsntation transport. Cor Stratgy stratgic policy 12 rquirs tall buildings to hav an xmplary standard of dsign and idntifis locations whr tall buildings could go. Th Cor Stratgy vision for Banksid and Borough rfrs to th council stting out in dtail which sits ar appropriat, snsitiv and inappropriat for tall buildings through th supplmntary planning documnt/opportunity ara framwork. Savd Southwark Plan policy 3.20 sts out critria for considring applications for tall buildings and applis across th borough In light of consultation rsponss and to add clarity to th guidanc rlating to St Gorg s Circus in SPD 5, th SPD has bn updatd to clarify that a tall building could provid a focal point at th southrn nd of Blackfriars Road up to 70m. A tall building should also sustain, nhanc or bttr rval th local hritag assts. This lvl of dtail is outsid th scop of th SPD. Sction 1 of th SPD sts out why th council ar prparing th SPD. Evidnc whr appropriat is rfrrd to within th SPD and furthr information is also st out in th sustainability appraisal. Notd.

204 Rp Obj Rf Rf Nam 643 Charls Muriithi Enviro nmnt Agnc y 643 Charls Muriithi Enviro nmnt Agnc y 643 Charls Muriithi Enviro nmnt Agnc y Dtails of Rprsntation Officr Rspons to Rprsntation W support th mrging idas for a vision for Support notd. Savd Southwark Plan policis 3.29 and 3.30 st out Blackfriars Road as prsntd on paragraph For furthr dtail for dvlopmnt in th Thams Policy Ara. W will look dvlopmnts fronting th Rivr Thams, w would to updat ths policis through th prparation of th Nw Southwark wish to s th Blackfriars Road distinct idntity Plan. aligning with th Environmnt Agncy Thams Estuary 2100 (TE2100) Plan which was approvd by DEFRA in Novmbr W will support th London borough of Southwark with Our approach to managing surfac watr flood risk is borough wid. intrprtation of TE2100 data and information as Furthr information is st out in stratgic policy 13 of th Cor rquird to nsur th rvision of th borough Stratgy and in our adoptd Sustainabl dsign and Construction Stratgic Flood Risk Assssmnt (SFRA) and flood SPD. W will also look at updating this guidanc through th plans ar dvlopd with an undrstanding of TE2100 prparation of th Nw Southwark Plan. analysis and rcommndations. W hop th supplmntary planning documnt will support th flood risk managmnt masurs idntifid by th TE2100 Plan. For othr most up to dat and accurat nvironmntal vidnc w rcommnd using our Data Shar srvic whr you can accss our nvironmntal datasts and also datasts from Natural England, Forstry Commission and English Hritag. Our dtaild commnts ar attachd blow for your considration. TE2100 Policy Unit V Wandsworth to Dptford h Land rquirmnts for ach Policy Unit h Third party rivrsid dvlopmnts h TE2100 Improvmnts to th Flood Risk Managmnt h Thams Policy Ara (TPA) h Th Rivr Thams Th whol of th SPD ara is locatd within a high flood risk zon. It dos bnfit from a high lvl of flood protction by a combination of rivr walls and th Thams Barrir. Dspit this thr is a rsidual risk of flooding from ithr an ovrtopping of, or brach in th flood dfncs. Th TE2100 Plan is th rsult of a dtaild assssmnt of th options availabl to manag flood Our approach to managing flood risk from th Rivr Thams and surfac watr flood risk is borough wid. Furthr information is st out in stratgic policy 13 of th cor stratgy, savd Southwark Plan policis 3.29, 3.30 and 3.31 and our sustainabl dsign and construction SPD. W will b rviwing ths policis as part of th prparation of th Nw Southwark Plan.

205 Rp Obj Rf Rf Nam Dtails of Rprsntation risk and thir conomic costs, bnfits and nvironmntal impacts. It sts out th stratgic dirction for managing flood risk across th Estuary, and contains rcommndations on what actions w and othrs will nd to tak in th short trm (nxt 25 yars), mdium trm (th following 15 yars) and long trm (to th nd of th cntury). Th Plan is basd on currnt climat chang guidanc, but is adaptabl to changs in prdictions for sa lvl ris and climat chang ovr th cntury. TE2100 Policy Unit V Wandsworth to Dptford SPD ara falls within th Wandsworth to Dptford policy unit and has th largst dvlopd ara of any of th TE2100 policy units. Each policy unit has bn assignd a policy which dtrmins how flood risk will b managd in th futur. Th slctd policy for Wandsworth to Dptford is policy P5-t tak furthr action to rduc flood risk byond that rquird to kp pac with climat Chang. S th tabl blow for mor dtail. Thr ar 10 undrground stations and thr major railway trminals in th tidal flood risk ara. Thr ar also 32 car homs, 93 schools, thr hospitals and ovr 200 lctricity substations potntially at risk. This maks th Wandsworth to Dptford policy unit on of th most vulnrabl in th TE2100 ara to flood risk in th vnt of a failur or ovrtopping of th dfncs. Thr is nd to agr a programm of floodplain managmnt including local flood protction, rsilinc and mrgncy plans for vulnrabl ky sits in th ara. Thr may b opportunitis to st back dfncs and improv th rivrsid amnity and habitats. A combination of dfnc ralignmnt and floodplain managmnt could rduc th impacts of flooding to xisting proprtis and othr assts locatd in th floodabl aras on th rivr sid of ralignd dfncs. W nd to agr partnrship arrangmnts Officr Rspons to Rprsntation

206 Rp Obj Rf Rf Nam Dtails of Rprsntation and principls to nsur that nw dvlopmnt in tidal risk ara is saf, and flood risk managmnt is factord into th planning procss at all lvls for th first 25 yars from 2010 to Thr is nd for gratr clarity ovr mthods and procdurs for safty in nw dvlopmnt bhind dfncs. To viw th Thams Estuary 2100 (TE2100) Plan plas visit: Land rquirmnts for ach Policy Unit Th Thams Estuary 2100 Plan rquirs a wid rang of works to b implmntd on th stuary including: maintnanc and rpair of dfncs, rising of dfncs, nw fixd dfncs and intrtidal habitat cration. On of th actions idntifid in th plan is to dvlop a Land Stratgy for th Thams Estuary to idntify and safguard th land that will b or may b ndd for futur flood risk managmnt, so that it is availabl whn rquird. All Policy Units will rquir land for th following purposs: Along th xisting dfnc lins for inspction, maintnanc and rpair. Additional land along th xisting dfnc lin whr dfncs ar to b raisd. This includs all th xisting tidal flood dfncs that ar to b raisd xcpt whr dfncs ar ralignd. Additional rquirmnts for Wandsworth to Dptford Policy Unit ar listd blow. Th local choics includ som local dfnc ralignmnt including th lowr rach of th Rivr Wandl. If dfncs ar to b ralignd, spac will b ndd along th nw alignmnt for th dfnc and an accss rout. Land for scondary dfncs at vulnrabl locations including tub station ntrancs and critical infrastructur, for xampl pumping stations. Potntial futur high lvl accss routs into and out of th main flood risk aras. Third party rivrsid dvlopmnts Rivrsid dvlopmnts on th Officr Rspons to Rprsntation

207 Rp Obj Rf Rf Nam Dtails of Rprsntation Thams stuary should b compatibl with th TE2100 Plan. Spcific rquirmnts includ th following: h Prsnt day flood dfnc crst lvls should b consistnt with statutory rquirmnts and th TE2100 Plan. h Ability to rais flood dfncs to achiv futur dsign crst lvls. h Spac for accss to inspct, maintain and rpair dfncs. h Compatibility with th rquirmnts of rivrsid stratgis (or rlvant planning documnt whr rivrsid stratgis ar not availabl). This includs landscap and public accss rquirmnts. h Ensur that th dvlopmnt fulfils floodplain managmnt rquirmnts including public safty. h Sk opportunitis for nvironmntal and rcrational nhancmnts TE 2100 Improvmnts to th Flood Risk Managmnt W ar now looking at th most cost-ffctiv way to implmnt th rcommndations in th TE2100 Plan and starting with th first 10 yars. But w can't manag futur flood risk alon and will b working with partnrs and communitis to find th bst way to mt th futur dmands for flood risk managmnt on th Thams stuary. Th following will b rquird within th nxt 10 yars: h Safguarding land; h Dvloping rivrsid stratgis; h Floodplain managmnt (by partnrship working); h Managing flooding from othr sourcs (by partnrship working); h Agrd approachs to nw dvlopmnt (by partnrship working); h Providing information for SFRAs and othr purposs Thams Policy Ara (TPA) Dvlopmnt should also b in accordanc with Cor Stratgy Policy 3.29 dvlopmnt within th Thams Policy Ara as idntifid in th local dvlopmnt framwork. Spcial policy rquirmnts apply in this ara to mak sur nw dvlopmnt protcts and improvs th rivr and th charactr and quality of th public ralm along th Officr Rspons to Rprsntation

208 Rp Obj Rf Rf Nam Dtails of Rprsntation rivr. Dvlopmnt in this ara will b xpctd to b carfully dsignd to protct and nhanc th rivr nvironmnt and th important contribution it maks to both local popl and all of London. This includs its us for rcration and transport, protction and nhancmnt of th rivr walkway, and its importanc as a habitat and part of th city's natural cycls Th Rivr Thams W wlcom th rcognition of th Rivr Thams as a local and rgional asst. W not how th spac alongsid th Rivr Thams is now mor frquntly usd to clbrat public vnts that us th Rivr Thams as a London focus. This hightnd intrst rminds us of th nd to considr th highst of standards of rivrsid dsign for th public ralm. W bliv th London Borough of Southwark may wish to considr how it may rspond to th nd for opn watr spac in rlation to facilitis that may b rquird for rivr rlatd activity and if th local plan will play a constructiv rol for th bttrmnt of such intrsts. W support rivr transport as long as its implmntation will maintain th intgrity of th flood dfncs. It is qually important to prvnt dvlopmnt into th Rivr Thams that would damag th opnnss of th rivrscap which is th most valuabl landscap fatur in London. Ralignmnt of th flood dfncs, habitat cration and rmoval of obsolt structurs ar masurs which ar idntifid in th Thams Rivr Basin Managmnt Plan. Th Environmnt Agncy can provid cas study matrial and furthr information if ndd. For mor dtail s Estuary dgs guidanc at: Surfac Watr Managmnt h Lad Local Flood Authority h Surfac Watr Managmnt Plan h Drain London Lad Local Flood Authority Th London Officr Rspons to Rprsntation

209 Rp Obj Rf Rf Nam Dtails of Rprsntation Borough Councils ar dfind as th Lad Local Flood Authoritis undr th Act and hav th following rsponsibilitis: E Ensur that flooding is invstigatd E Maintain a rgistr of assts rlvant to flooding E Dsignat structurs that ar rlvant to flood risk E Ensur us of sustainabl drainag on nw dvlopmnts E Build partnrships and nsur ffctiv multi-agncy working Surfac watr Managmnt Plans Undr th Flood Risk Rgulations 2009 LLFAs ar also rsponsibl for assssing, mapping and planning for local flood risk, and any intraction ths hav with drainag systms and othr sourcs of flooding, including from swrs. London Borough of Southwark as th Lad Local Flood Authority (LLFA) has full rsponsibility for managing flood risk from surfac watr, groundwatr and ordinary watrcourss. Dvlopmnts should hav rgard to th following critria: h Dtrmination of potntial ovrland flow paths and proposals for appropriat solutions to minimis th impact of dvlopmnt on surfac watr flooding. Road and building configuration should b considrd to prsrv xisting flow paths and improv flood routing, whilst nsuring that flows ar not divrtd towards othr proprtis lswhr; h In th aras outlind in th Surfac Watr Managmnt Plan as aras with incrasd risk of surfac watr flooding, a FRA should mitigat off sit surfac watr flooding by aiming to achiv grnfild run off rats or bttr. SUDS tchniqus should b applid with rgard to th London Plan Sustainabl Drainag Hirarchy. h Incorporation of soft landscaping and prmabl surfacs into all nw rsidntial and non-rsidntial dvlopmnts. Rtntion of soft landscaping and prmabl surfacs in front gardns and othr mans of rducing, or at last not incrasing, th amount of Officr Rspons to Rprsntation

210 Rp Obj Rf Rf Nam 643 Charls Muriithi Enviro nmnt Agnc y 643 Charls Muriithi Enviro nmnt Agnc y 643 Charls Muriithi Enviro nmnt Agnc y Dtails of Rprsntation hard standing associatd with xisting homs is ncouragd. Nw drivways or parking aras associatd with non-rsidntial dvlopmnts and thos locatd in front gardns should b mad of prmabl matrial. h Application of a sit wid squntial approach to dvlopmnt by locating buildings within th aras of lowst flood risk on a sit in accordanc with th aras st out within th Surfac Watr Managmnt Plan as aras with incrasd risk of surfac watr flooding. Dsign of mixd us dvlopmnt As pointd out in th Sustainability Appraisal, th Environmnt Agncy nots that th high lvl of dvlopmnt proposd in th opportunity ara could lad to nvironmntal and cological impacts that rquir mitigation. W wlcom Southwark s considration of th dsign of mixd us dvlopmnt within th Blackfriars Road Supplmntary Planning Documnt ara. Th ara is within th dfndd tidal floodplain of th Thams and Southwark s Stratgic Flood Risk Assssmnt rcommnds that rsidntial living accommodation, in particular slping accommodation b locatd on th first floor and abov. This may also nd to b considrd in th us of studnt accommodation bnath railway archs and visitor accommodation on lowr and strt lvls as dscribd within th SPD. W rcognis th importanc of activ lowr floor building frontags but also th nd for ths spacs to hav accss to highr ground or lvls for mrgncy planning purposs in th vnt of inundation. Givn th larg numbrs of popl attractd to th ara as a rsult of nw tall buildings accss, grss and mrgncy planning should also b particularly considrd for th lowr and ground floor community spacs. Notd. Officr Rspons to Rprsntation Notd. This guidanc is st out in our sustainabl dsign and construction SPD. W also rquir a Flood Risk Assssmnt to b submittd alongsid planning applications dmonstrating how th proposal mts th squntial and xcptions tsts whr ncssary as st out in th NPPF. It is important to considr that th SPD provids furthr guidanc to xisting planning policis in our Cor Stratgy and savd Southwark Plan. It dos not rpat borough wid policis and so th SPD must b rad alongsid our othr planning documnts. This is mad clar within th SPD. W hav a Sustainabl Dsign and construction SPD which sts out minimum rquirmnts for flood prvntion masurs in nw buildings. W also rquir th submission of a Flood Risk Assssmnt alongsid planning proposals.

211 Rp Obj Rf Rf Nam 643 Charls Muriithi Enviro nmnt Agnc y 643 Charls Muriithi Enviro nmnt Agnc y Dtails of Rprsntation Sustainabl urban drainag should b considrd in th dsign of nw buildings and th us of opn spac to limit flood risk from surfac watr as st out within th Stratgic Flood Risk Assssmnt. Any dvlopmnt along th Thams frontag should b in kping with th Environmnt Agncy s Thams Estuary 2100 Plan and considr th futur improvmnts to dfncs that may b rquird within thir dsign. Officr Rspons to Rprsntation This is a borough wid issu. Furthr guidanc is st out in stratgic policy 13 of th cor stratgy and our Sustainabl Dsign and Construction SPD. W will b rviwing this guidanc as part of th prparation of th Nw Southwark Plan. Support notd. Savd Southwark Plan policis 3.29 and 3.30 st out furthr dtail for dvlopmnt in th Thams Policy Ara. W will look to updat ths policis if appropriat through th prparation of th Nw Southwark Plan Michal Doust Howvr, I fl th draft SPD lacks a clar and Commnts notd. Th mrging vision is st out in sction 2 of th 0 0 inspiring vision for th ara, which nds to b mor SPD, and as st out in th txt, will b dvlopd furthr through th carfully articulatd in ordr to ffctivly guid prparation of th Nw Southwark Plan. On of th indicativ dvlopmnt in this ara. In my opinion this should b diagrams on th front covr has bn updatd. to build on th ara s strngth as a cultural cntr, with Blackfriars Road and Union Strt bcoming ky cultural dstinations in thir own right as wll as cultural corridors to xisting attractions in th ara, supportd by high quality dining, ntrtainmnt and rtail facilitis. I think th council should tak a much mor activ rol in shaping th ara. Th drawing on th front covr of th SPD documnt (top right) is an attractiv and appaling vision for th ara (with widr and sgrgatd cycl lans). Howvr, currnt council policis and ladrship ar not alignd to dlivr this. W alrady hav an ovrabundanc of chain stor suprmarkts in th ara, which mak vry littl contribution to th public ralm, yt hav bn facilitatd by th council s planning policis. Lft to dvloprs Blackfriars Road will turn into a corridor of bland, high ris, low valu architctur with chain stor suprmarkts and coff shops on th ground floor. This is not my vision for th ara, nor th majority of rsidnts Michal Doust SPD 1 Businss spac W nd to attract businsss In prparing th Nw Southwark Plan, which will rplac th Cor 1 0 that will nhanc th look and fl of th ara. As such Stratgy (2011) and savd Southwark Plan policis (2007), th council

212 Rp Obj Rf Rf Nam Dtails of Rprsntation I would lik to suggst: - no furthr A5 uss allowd in th SPD ara, - nw businss spacs limitd in siz to attract local and SME rtailrs, - ddicatd spac is providd to attract art gallris into th ara, and - avoid rtail spac bing usd only Mon-Fri Michal Doust SPD 2 Mixd us town cntr Th SPD ara should support a mixd us town cntr, but also on with a uniqu charactr. This puts vn gratr mphasis on th council to clarly articulat thir vision for th ara basd on fdback from rsidnts and tak a vry activ rol in shaping th plac, to nsur th ara Officr Rspons to Rprsntation will b considring whthr w should prpar mor dtaild policis to manag th mix of rtail uss such as rstaurants, bars, cafs and hot food takaways. In lin with th Cor Stratgy, th SPD ncourags th provision of flxibly dsignd small businss spac. W hav insrtd additional txt to bullt 1 of SPD1 to add som furthr clarification. This includs ncouraging th provision of small and start-up businsss in th ara. Th supporting txt outlins borough wid policy on small businss spac, including mploymnt spac availabl within th railway archs. Ths spacs can b usd for a varity of mploymnt opportunitis. W hav also addd additional rfrnc into th supporting txt rgarding th savd Southwark Plan Policy 1.5 in ordr to highlight that this policy aims to protct small businss units in proposals for rdvlopmnt or chang of us of mploymnt sits, by rquiring th quivalnt provision for small units within th rplacmnt floorspac, subjct to xcption critria. SPD2 ncourags th dvlopmnt of nw arts, cultural, lisur and ntrtainmnt uss in mixd us dvlopmnt throughout th ara to hlp consolidat this clustr of arts and cultural facilitis. Through SPD1, w support th provision of small businss floorspac, such as small offic/studio workshop spac, to hlp to provid appropriatly sizd modrn nw spac for crativ and cultural businsss to mov in th ara. W hav also insrtd additional txt to bullt 1 of SPD2 to ncourag th flxibl dsign of nw unit sizs for nw town cntr us in nw mixd us dvlopmnt. Th Borough and Banksid licnsing saturation ara is a local licnsing policy that addrsss th cumulativ impact of licnsd prmiss. All applications for nw or varid prmiss licncs for night-clubs, public houss and bars, rstaurants and cafs, off-licncs, suprmarkts and grocrs nd to addrss th saturation concrns st out in th council s licnsing policy within th prmiss oprating schdul. Our mrging vision for Blackfriars Road has bn amndd sinc consultation, and includs th aspiration for Blackfriars Road to b transformd into a vibrant plac providing a rang of diffrnt activitis rgnrating th ara from th rivr along Blackfriars Road and stimulating chang at th Elphant and Castl. This vision is carrid forward into SPD4 which promots dvlopmnt to hlp crat a

213 Rp Obj Rf Rf Nam Dtails of Rprsntation dvlops as nvisiond and to mt th nds of th community rathr than thos of dvloprs and high strt stors which hav littl commitmnt or attachmnt to th ara. Officr Rspons to Rprsntation sns of plac and idntifiabl charactr Michal Doust SPD 3 Public ralm and opn spac Th ara lacks Th SPD is consistnt with our Opn Spac Stratgy (2013) which 3 0 significant grn and opn spac and th Council has idntifid a dficincy in opn spacs within thn ara; howvr should sk to incras this provision from nw givn th limitd opportunitis for th cration of opns, our priority is dvlopmnts howvr viwing platforms, shopping to focus on improving out xisting opn spacs. W will sk to plazas or nclosd grn spac rstrictd to rsidnts provid nw opn spac and grning as st in th stratgy. SPD 3 of a particular dvlopmnt do not mt this nd. ncourags nw strt trs. A nw paragraph has bn addd to What is ndd is gratr provision of accssibl SPD 3 "w ar doing this bcaus" to provid furthr background on grn and rcration spac. In addition I think th ara th Opn Spacs Stratgy rcommndations. nds mor grn roofs, grn walls and grn corridors for xampl, I would lik to s a tr-lind hard-shouldr running through th middl of Blackfriars road from St Gorg s Circus to th rivr, idally with path for pdstrians in th middl Michal Doust SPD 4 Built form and hritag Thr is a ral nd to Th SPD provids guidanc on hritag assts and would b rad in 4 0 protct th ara s hritag and nsur dvlopmnt is conjunction with th xisting hritag policy framwork and sympathtic to th ara s history and charactr. Old dsignations, including th savd Southwark Plan policis, Cor buildings vn if not listd should b protctd and Stratgy, London Plan and NPPF. Th potntial impact on any incorporatd into nw dvlopmnts rathr than hritag would b assssd at th planning application stag. dstroyd and rplacd. Nw dvlopmnts should b of th highst architctural standards, slndr and varid to nsur for an intrsting and dynamic cityscap. A lot of nw buildings that th council is giving planning prmission for ar bulky, unimaginativ and ubiquitous dvlopmnts that ar crowding th ara, undrmining th hritag and crating a lss plasant nvironmnt Michal Doust SPD 5 Building hights I agr with th hight proposals at th north nd of Blackfriars Road. Howvr, I do not think a 70m at Southwark tub station is appropriat or ndd to provid a focal point. Th Palstra building, whilst architcturally Notd. A tall building up to 70m in hight could b appropriat at th southrn nd of Blackfriars Road providd that it complis with th dtaild guidanc outlind in SPD 5 and th currnt dvlopmnt plan that includs th rlvant policis of th savd Southwark Plan (2007), Cor Stratgy (2011), London Plan (2011) and othr planning

214 Rp Obj Rf Rf Nam Dtails of Rprsntation appaling, is too tall, bulky and dominant for this ara and should not b usd as a rfrnc point. Building hight hr should b limitd to 30mtrs. Similarly for St Gorg s Circus. Btwn Southwark tub station and St Gorg s Circus building hight should b no highr than nighbouring buildings and sympathtic to listd buildings, and othr buildings or architctural valu, in th ara. This should also apply to nw dvlopmnts in aras covrd by th SPD but away from Blackfriars road. Dvlopmnts lik Mt Anvil on Union Strt, which is too tall and ntirly incongruous with othr buildings in th ara, should not b allowd to happn lswhr in th ara Michal Doust SPD 6 Activ Travl Surly th tim has com for a sgrgatd cycl lan along Blackfriars Road. In my opinion this should b in both dirctions, on both sids of th road, with bus stops and any parking bays on th road / traffic sid of th sgrgatd cycl lan. Elswhr in th SPD ara, cycl infrastructur should b upgradd: dlinating additional road spac for cyclists with hard and soft barrirs, improving signag for cyclists (.g. roads that ar a dad-nd for cars but not for cyclists should b indicatd as such rathr than just a dad-nd sign), ddicatd traffic lights for cyclists, updatd squncing of traffic lights to nsur cyclists hav sufficint tim to cross a junction safly (not th cas at th momnt) tc. Th council should play an activ rol in this and rally champion cycling in th ara to improv air quality, ncourag activ travl and gnrally crat a mor plasant, inclusiv and safr built nvironmnt. Popl will bgin to cycl, and switch from cars, buss and taxis if cycling is mad safr and mor njoyabl. Officr Rspons to Rprsntation documnts/guidanc, including th NPPF (2012). Th dvlopmnt plan sts out th policis for tall buildings. Th guidanc in th SPD provids dtail on how to implmnt ths dvlopmnt plan policis spcific to Blackfriars Road. Th approach is supportd by our vidnc bas including th Blackfriars Road Urban Dsign Study which has bn prpard in accordanc with CABE and English Hritag Guidanc on Tall Buildings, In light of consultation rsponss and to add clarity to th guidanc rlating to St Gorg s Circus in SPD 5, th SPD has bn updatd to clarify that a tall building could provid a focal point at th southrn nd of Blackfriars Road up to 70m. A tall building should also sustain, nhanc or bttr rval th local hritag assts. Th SPD sts out guidanc for building hights away from Blackfriars Road Sinc th publication of th draft SPD it has bn announcd that TfL ar proposing to introduc a Cycl Suprhighway on Blackfriars Road. Th council support TfL's proposals to introduc a sgrgatd cycl lan and th SPD has bn updatd to rfr to this. TfL hav advisd that a consultation will tak plac ovr summr 2014.

215 Rp Obj Rf Rf Nam Phob Grnw 7 1 ood Phob Grnw 8 1 ood Dtails of Rprsntation Friars Bridg Court Blackfriars Road W would lik to put forward Friars Bridg Court Blackfriars Road as a potntial sit for dvlopmnt and would lik to know why it has not bn includd? It is an unattractiv po-mo 80s building that has no appal and is rgularly lambastd as bing a horror by th architctur and building community. It's also a big sit, so thr's scop for significant nw dvlopmnt. On bhalf of Wbbr and Quntin TRA, 250 rsidntial flats that fall within th proposd Draft Blackfriars Road SPD ara, w would lik to mak th blow commnt. This lttr is to b rad in conjunction with that of Barbara Grhs, dputy chair of Wbbr & Quntin TRA. Sh has submittd a vry xtnsiv rport that w as a TRA support. This commnt is to furthr laborat on our srious concrn that th Blackfriars SPD is a documnt dvisd for th businss community and that it dos not put forward a stratgic framwork that taks into considration th nds of th xisting local community, nor dos it hav any dtail about how th nds will b mt of a massivly incrasd rsidntial population. Ovrall, w fl th draft Blackfriars Road SPD documnt rads lik a sals brochur to dvloprs and ral stat invstors - not a stratgy for sustainabl growth. This viw is confirmd by statmnts such as, "th markt is now ralising th potntial of this amazing location". It s our viw that thr is a contradiction in th stratgy that maks th draft SPD documnt flawd. Blackfriars Road and th ara around Blackfriars Road, as containd in th SPD boundary, ar two compltly distinct aras, which rquir diffrnt stratgic framworks. Th draft Blackfriars Road SPD, in it s currnt form, w would argu is only rlvant to th buildings actually on Blackfriars Road. W would ask that th SPD boundary b rdrawn or that a Officr Rspons to Rprsntation Figur 6 - and Tabl 1 has bn updatd with this potntial dvlopmnt sit. Th SPD is intndd to bnfit a wid rang of groups including xisting and nw rsidnts. Th SPD sks to mt th nds of rsidnts whilst also managing th prssur for nw dvlopmnt. Th SPD has bn updatd to mak it clarr that th mrging vision and th SPD sks to nsur that dvlopmnt mts th nds of xisting and nw rsidnts whilst also attracting nw dvlopmnt. Rsidnts will bnfit from th incras rang of uss including mor shops, srvics and businsss along th Blackfriars Road. An xplanation of th boundary is st out in th SPD. It includs th whol of th Blackfriars Road and som of th surrounding ara. It includs th surrounding ara as th surrounding ara is also likly to s som dvlopmnt and improvmnts, particularly possibl improvmnts to public ralm. Wording has bn addd to th SPD to mak it clarr that th charactr and historic valu of much of th surrounding ara will continu to b protctd and nhancd. Figur 3 of th SPD illustrats th rlationship btwn diffrnt planning documnts including supplmntary planning documnts and nighbourhood plans. Th SPD has bn updatd to mak it clar th nighbourhood plans ar currntly bing prpard. Onc adoptd a nighbourhood plan will hav mor wight than a SPD in th planning procss as it will form part of th council's dvlopmnt plan. At prsnt thr is no adoptd nighbourhood plan for any of th ara covrd by th Blackfriars Road SPD. Th SPD may nd to b rviwd in th futur if a nighbourhood plan is adoptd for any of th SPD ara.

216 Rp Obj Rf Rf Nam Phob Grnw 9 1 ood Dtails of Rprsntation scond SPD is producd that taks into account th blow points and rflcts th actual composition of th ara includd in th SPD. Th ara around Blackfriars Road is largly rsidntial, with pockts of smallbusinsss in low-ris industrial buildings, plus a high numbr of Consrvation aras and buildings of local hritag intrst. It is crtainly not a hintrland and w find it offnsiv and troubling that it should b rfrrd to as such in a planning documnt. Any stratgy that ncompasss this ara must includ xtnsiv dtails prtinnt to th actual mak-up of buildings and populations containd within it. W bliv that th SPD in its currnt form is not fit for purpos and that a nw stratgy documnt is rquird that taks in th blow concrns 1. Rsidnts p.6 To hlp crat a succssful plac whr popl want to work, liv and visit, w nd a vision which rflcts th nds and aspirations of th community, businsss, rsidnts, landownrs and local stakholdrs. Dspit th abov statmnt thr is in fact only 6 rfrncs to local rsidnts or rsidnts in th whol documnt. Thr ar larg numbrs of rsidnts in th proposd ara, living in a wid varity of privat proprtis and local authority housing, particularly south of Th Cut. Th draft SPD taks no account of ths xisting communitis and thir nds. W would xpct th BR SPD to includ up-to-dat data about th currnt rsidntial population in th SPD ara. What is th siz of th xisting rsidntial population and numbr of homs? W would thn xpct this figur to b quotd alongsid any projctions for th numbr of nw homs and any assssmnt of furthr social infrastructur that will b rquird. Officr Rspons to Rprsntation Th SPD is intndd to bnfit a wid rang of groups including xisting and nw rsidnts. Sction 4 of th SPD on implmntation highlights th importanc of working with all our partnrs including rsidnts and th local community. Sction 4.1 spcifically rfrs to continuing to ngag with th local community and rsidnts, and similarly sction 4.2 rfrs to continuing to ngag with many groups and ky stakholdrs as wll as look at opportunitis for ngagmnt with othr groups and rsidnts Phob Grnw p.9 Thr will b nw businsss, shops, housing... Th SPD and othr planning policy documnts provid th framwork

217 Rp Obj Rf Rf Nam Dtails of Rprsntation 0 1 ood this will includ nw improvd community and youth facilitis. p.11 Cultural, lisur, arts and ntrtainmnt uss will also b ncouragd. p Nw and improvd lisur, social infrastructur and community facilitis with accssibility for all will hlp to strngthn th rlationships btwn popl living and working in th ara, ncourag mor activity and also facilitat th xchang of idas and skills. Nw housing and businss floorspac will also incras th rsidnt and working population and it is important to nsur that infrastructur is in plac to support th community. W would xpct th BR SPD to includ a srious assssmnt of how all of th abov will b fundd, also whr ar th rcommndd sits for thir location - ar ths includd in th rcommndd dvlopmnt sits? If not, why ar rcommndd sits for local infrastructur not includd alongsid th potntial dvlopmnt sits? Officr Rspons to Rprsntation for th provision of infrastructur to support dvlopmnt. Updats hav bn mad to th SPD to rfr to ncouraging a rang of diffrnt uss/ SPD 2: Mixd us town cntr sts out that w will support th provision of nw social infrastructur and community facilitis as part of mixd us dvlopmnts. SPD 3: Public ralm and opn spac rfrs to th continud protction of th thr protctd opn spacs and ncouraging furthr linkags and nw spacs. Sction 4 of th SPD rfrs spcifically to infrastructur, crossing rfrring to th community infrastructur lvy (CIL) and sction 106 planning obligations to hlp nsur th dlivry of ky infrastructur to mitigat th impact of dvlopmnt. Infrastructur is covrd within borough-wid planning documnts with th ovrarching policy 14 of th Cor Stratgy rcognising that nw dvlopmnt in th borough nds to b supportd by adquat infrastructur, including social, nvironmntal and physical infrastructur. Th borough s Infrastructur Plan, idntifis stratgic infrastructur which is ndd to support growth and dvlopmnt in th borough ovr th liftim of th Cor Stratgy ( ). Whr possibl it idntifis th cost of infrastructur to providd, any committd sourcs of funding which will b usd to dlivr it and th organis rsponsibl. It also idntifis th funding gap i.. th gap btwn known commitmnts and th total cost of infrastructur rquird. Whn it is adoptd, Southwark s CIL will b usd to contribut towards bridging this funding gap. Funds armarkd for infrastructur in th Council s capital invstmnt programm also will hlp to improv infrastructur provision. Th council ar currntly prparing our draft community infrastructur charging schdul and an updatd sction 106 SPD. Adoption is plannd for It is appropriat to look at th provision of infrastructur at a borough-wid lvl through ths ddicatd documnts rathr than through th Blackfriars Road SPD Phob Grnw p.16 Supporting th provision of nw social Th SPD and othr planning policy documnts provid th framwork

218 Rp Obj Rf Rf Nam Dtails of Rprsntation Officr Rspons to Rprsntation 1 1 ood infrastructur and community facilitis as part of mixd for th provision of infrastructur to support dvlopmnt. SPD 2: us dvlopmnts. Opportunitis should b takn to Mixd us town cntr sts out that w will support th provision of nsur that nw community facilitis ar accssibl to nw social infrastructur and community facilitis as part of mixd us all mmbrs of th community. Th local population of dvlopmnts. SPD 3: Public ralm and opn spac rfrs to th workrs, rsidnts and tourists in this ara will xplod continud protction of th thr protctd opn spacs and with th proposd lvl of dvlopmnt in th draft SPD. W will nd schools, nursris, youth cntrs, local group cntrs, playgrounds, opn spacs, GP surgris, halth cntrs, fir srvics and polic srvics. W would lik to s includd xplanations ncouraging furthr linkags and nw spacs. Sction 4.4 of th SPD rfrs spcifically to infrastructur, crossing rfrring to th community infrastructur lvy (CIL) and sction 106 planning obligations to hlp nsur th dlivry of ky infrastructur to mitigat th impact of dvlopmnt. Th council ar currntly prparing our draft community of how this lvl of infrastructur will b providd. Also, infrastructur charging schdul and an updatd sction 106 SPD. w would lik to undrstand how it will b nforcd, Adoption is plannd for It is appropriat to look at th provision th rcnt Lindn Homs schm saw th dvlopr of infrastructur at a borough-wid lvl through ths ddicatd fail to provid any playground facilitis, instad only documnts rathr than through th Blackfriars Road SPD concding to a 15,000 sum to improv narby facilitis. Th Mayor of London has dvlopd Supplmntary Planning guidlins (Sptmbr 2012) for childrn s spac arising from nw dvlopmnts. It says that All dvlopmnts with an stimatd child occupancy of tn childrn or mor should sk to mak appropriat play provision to mt th nds arising from th dvlopmnt. W would xpct th BR SPD to includ a srious assssmnt of ovrall play nds in this rapidly dvloping ara Phob Grnw 2 1 ood p.18 Improvmnts to social infrastructur such as schools, halth facilitis, post offics and polic facilitis ar addrssd through xtrnal stakholdr s asst managmnt plans and through th council s Capital programm and infrastructur planning procss. Can you plas xplain in lay trms what this mans? Th SPD and othr planning policy documnts provid th framwork for th provision of infrastructur to support dvlopmnt. SPD 2: Mixd us town cntr sts out that w will support th provision of nw social infrastructur and community facilitis as part of mixd us dvlopmnts. SPD 3: Public ralm and opn spac rfrs to th continud protction of th thr protctd opn spacs and ncouraging furthr linkags and nw spacs. Sction 4.4 of th SPD rfrs spcifically to infrastructur, crossing

219 Rp Obj Rf Rf Nam Dtails of Rprsntation Officr Rspons to Rprsntation rfrring to th community infrastructur lvy (CIL) and sction 106 planning obligations to hlp nsur th dlivry of ky infrastructur to mitigat th impact of dvlopmnt Phob Grnw 3 1 ood Phob Grnw 4 1 ood Infrastructur is covrd within borough-wid planning documnts with th ovrarching policy 14 of th Cor Stratgy rcognising that nw dvlopmnt in th borough nds to b supportd by adquat infrastructur, including social, nvironmntal and physical infrastructur. Th borough s Infrastructur Plan, idntifis stratgic infrastructur which is ndd to support growth and dvlopmnt in th borough ovr th liftim of th Cor Stratgy ( ). Whr possibl it idntifis th cost of infrastructur to providd, any committd sourcs of funding which will b usd to dlivr it and th organis rsponsibl. It also idntifis th funding gap i.. th gap btwn known commitmnts and th total cost of infrastructur rquird. Whn it is adoptd, Southwark s CIL will b usd to contribut towards bridging this funding gap. Funds armarkd for infrastructur in th Council s capital invstmnt programm also will hlp to improv infrastructur provision. Th council ar currntly prparing our draft community infrastructur charging schdul and an updatd sction 106 SPD. Adoption is plannd for It is appropriat to look at th provision of infrastructur at a borough-wid lvl through ths ddicatd documnts rathr than through th Blackfriars Road SPD p. 11 Opportunitis to improv xisting opn spacs, SPD cannot st out spcific guidanc, howvr w will continu to spcifically Christ Church, Nlson Squar ad Paris work with BOST and othr community organis on a projct by Gardns will b maximisd through working with projct basis to dlivr public ralm and opn spac improvmnts groups such as BOST. Plas can you laborat on within th ara. what will this working arrangmnt b, will BOST rciv an incras in funds? Thy ar alrady vry activ in th community. W would xpct th BR SPD to xplain how this arrangmnt would b dlivrd. p. 16 W will ncourag th provision of a balancd Th idntification of baslin information and th rang of conomic, mix of town cntr uss to hlp nhanc th social and nvironmntal issus in th ara was undrtakn as part of commrcial attractivnss of th Blackfriars Road ara th Banksid, Borough and London Bridg Sustainability Appraisal

220 Rp Obj Rf Rf Nam Dtails of Rprsntation and th status and function of th widr CAZ. p.17 Th GLA s Hotl Dmand Study sts out th approx. amount of nw hotls rquird ovr th priod This amounts to 2,500 bd spacs for Southwark. Sinc 2007, approx hotl bd spacs hav bn compltd and approx. 850 ar in th piplin. p. 18 Th dvlopmnt of th vning and night-tim conomy will hlp kp th town cntr livly and saf at diffrnt tims of day and night As rsidnts, w hav alrady noticd qualitativ diffrncs in th quality of lif du to th influx of larg, budgt hotls; incrasd offic and businss spac and studnt accommodation. Du to th scal of proposd growth and dvlopmnt plannd, W would xpct th BR SPD to includ a srious assssmnt what th ffcts hav bn so far on th local nighbourhood of larg-scal commrcial dvlopmnt and of a nw, transint population. What nw local srvics hav arrivd in th ara, what ar th opning hours, hav thy bn succssful in crating local mploymnt, who frqunts thm, ar thy th typs of businsss that bst srv a local community, what hav bn th positiv and ngativ ffcts, do thy contribut to kping a town cntr livly or in fact do th opposit? With Southwark alrady clos to fulfilling it s hotl quota 13 yars ahad of schdul, w would xpct th BR SPD to includ a comprhnsiv rviw of what has bn th ffct of hotls on th ara, particularly on th local community. W do not think that a singl cas study, Citizn M Hotl, is sufficint. And with th hotl quota achivd, w would lik it assssd as to whthr an mphasis should b placd in th BR SPD on ncouraging rsidntial dvlopmnts Michal Doust p.9 Making sur that studnt accommodation is 5 0 includd without dominating is important for a Officr Rspons to Rprsntation Scoping Rport, which was publishd for consultation in Octobr This work has informd th prparation of th SPD guidanc. SPD2 provids guidanc to support stratgic policy 10 Jobs and businss of th Cor Stratgy (2011) which sts out th council will allow th dvlopmnt of hotls within th town cntrs, th stratgic cultural aras, and placs with good accss to public transport srvics, providing that ths do not harm th local charactr. This policy is also supplmntd by th savd policy 1.12 of th Southwark Plan which addrsss visitor accommodation. Nw hotl proposals will b assssd against ths rlvant planning policis and a considration of th impact upon local amnity and th balanc of land uss will also b takn into account. SPD2 ncourags any nw hotl proposal to includ ancillary facilitis. This will hlp to nsur that ths dvlopmnts ar mor intgratd into th strt scn and provid a widr bnfit. Th inclusion of th cas study on Citizn M hotl on Lavington Strt provids contxt by providing an xampl of how a hotl can succssfully offr a rang of uss and incorporat activ frontags. Th SPD provids furthr guidanc to xisting planning policis in th Cor Stratgy and savd Southwark Plan. It dos not rpat borough wid policis and th SPD must b rad alongsid othr planning documnts. Housing is not givn its own sction within th SPD bcaus th borough-wid housing policis and guidanc alrady covr housing adquatly. This includs policis in th Cor Stratgy and savd Southwark Plan and SPDs on affordabl housing and rsidntial dsign standards. Th SPD sts out that it provids furthr guidanc to xisting planning policis in th Cor Stratgy and savd Southwark Plan. It dos not

221 Rp Obj Rf Rf Nam Phob Grnw 6 1 ood Dtails of Rprsntation balancd mix of activitis. With th hug numbr of nw studnt accommodations, w find it vy concrning that thr is only on rfrnc to studnt accommodation in th ntir documnt. W think a stratgy for th ara must addrss how thy affct and intract with local infrastructur, what ar thir nds, do thy add a hug nw dmand on halth srvics for xampl? W would xpct th BR SPD to also includ dtails about long-trm concrns. A nw studnt dvlopmnt at Paris Gardns has gon on sal this wk with prics of 409 pr wk for a singl bd apartmnt and 215 pr room pr wk for a thr bd apartmnt. Ths ar vry xpnsiv rnts and with thr bing so much nw studnt accommodation in th ara, w would lik to s a rport on th long-trm viability of ths dvlopmnts. Who is this walthy studnt dmographic and for how long will thy continu to xist? What is considrd a sustainabl amount of placs and how clos is th currnt numbr of rooms to that rcommndd maximum limit? 3. Southwark s Rtail Capacity Study (2009), local nds and spcialist, indpndnt rtailing Pag 14 Supporting us of th railway archs for a rang of businss uss (B1) including small businss spac, crativ and cultural industris, light industrial uss and appropriat A or D class uss. Pag 17 Southwark s Rtail Capacity Study (2009) suggsts that th Banksid and Borough district town cntr should continu to b a cntr for local nds and spcialist, indpndnt rtailing and any nw rtail schms can b supportd by workrs, tourists and rsidnts, coming forward on an incrmntal basis. Thrfor, in ordr to continu to promot th ara as a commrcially attractiv location for businss, it will b important to maximis th divrsity of offr and Officr Rspons to Rprsntation rpat borough wid policis and th SPD must b rad alongsid othr planning documnts. Housing is not givn its own sction within th SPD bcaus th borough-wid housing policis and guidanc alrady covr housing adquatly. Spcific policis on studnt housing ar alrady st out in Cor Stratgy policy 8 and savd Southwark Plan policy 4.7. Furthr guidanc is also st out in th Affordabl Housing SPD and Rsidntial Dsign Standards SPD. W hav also insrtd a nw appndix (appndix A) listing th ky borough wid Southwark planning policis and supplmntary planning guidanc to mak it clarr that ths policis nd to b rad alongsid th Blackfriars Road SPD. Sction 1 of th SPD has bn updatd to rfr to this nw appndix. It is important to considr that th SPD provids furthr guidanc to xisting planning policis in our Cor Stratgy and savd Southwark Plan. It dos not rpat borough wid policis and so th SPD must b rad alongsid our othr planning documnts. This is mad clar within th SPD. Th SPD supports th provision of flxibl small businss spac and planning applications nd to addrss th rquirmnts in our adoptd policis and guidanc, and st out appropriat justification for a dvlopmnt schm.

222 Rp Obj Rf Rf Nam Phob Grnw 7 1 ood Dtails of Rprsntation facilitat a rang of town cntr uss as part of mixd us dvlopmnt in conjunction with a high quality public ralm. Rcntly, two high profil planning dcisions dmonstratd that Southwark Council is not committd to giving small businsss protction: Ntwork Rail victing small businsss in Union Strt Lindn Homs victing SE1 Dryclanrs; Imbib; Nwsagnt; Blackfriars Caf In light of th abov, w would lik to know how can th statd aims in th draft SPD (...focuss on ncouraging flxibl spac for a rang of diffrnt businsss, hlping both small and largr businsss bnfit from this cntral London location and its grat transport links and Encouraging flxibl businss us ) b considrd to b valid? Pag 14 Supporting th provision of nw businss floorspac (B1 us class). Spac should b dsignd flxibly to accommodat a rang of unit sizs hlping to contribut to a divrs stock of businss accommodation. Pag 16 Proposals should sk to maximis th opportunity to includ ancillary facilitis and activity along th lowr and strt lvl frontags. W would xpct th BR SPD to includ cas studis of strt lvl businsss with activ frontags that hav movd into nw larg-scal dvlopmnts in th SPD ara ovr th past 5 yars. Evidnc shows that th majority ar mini-suprmarkts, th rst largly rmain unoccupid or ar vntually takn up by charitis. W would xpct th BR SPD to dtail what is th stratgy to countract th abov trnd. W would also lik dtails in th BR SPD about th council s policy on mini-suprmarkts, is thr a saturation point as with licnsd srvics or btting shops? Thr ar now six in a 0.6 mil radius watrloo road, Blackfriars road, Union Strt, th Cut, two on Grat Suffolk Strt. It s widly documntd that thy hindr rathr than ncourag spcialist, Officr Rspons to Rprsntation SPD 2 promots nw dvlopmnt to maximis th divrsity of th rtail offr in th ara, to strngthn th appal of th ara and ncourag a widr rang of occupirs. In prparing th Nw Southwark Plan, which will rplac th Cor Stratgy (2011) and savd Southwark Plan policis (2007), th council will b considring whthr w should prpar mor dtaild policis to manag th mix of uss in th town cntr.

223 Rp Obj Rf Rf Nam Phob Grnw 8 1 ood Phob Grnw 9 1 ood indpndnt rtailing. Dtails of Rprsntation 4. Building hights p24 W will rinforc th civic scal along th main routs of Blackfriars Road, Stamford Strt and Southwark Strt, by: Dsign buildings of an appropriat massing to crat a human scal of dvlopmnt at strt lvl. W would lik it xplaind how buildings of 70m comply with th abov commitmnt to dsign buildings of a human scal at strt lvl? W do not undrstand or accpt th chang in guidanc on tall buildings sinc it dos not match th Cor Stratgy nor th council s Tall Building Study Dcmbr 2009 and want furthr justification for ncouraging buildings of up to 70m. It stats in th Cor Stratgy and was concludd in th 2009 rviw, that tall buildings ar suitabl in a clustr and should b sitd to th North of Blackfriars Road and that a building of th hight of Palstra and not tallr would b suitabl for abov Southwark Tub. Point 5.1 of Conclusions : Th Southwark tub station sit at th cornr of Blackfriars Road and Th Cut has th potntial for a nw landmark building which could mark th location of th train station and provid a countrpoint of similar hight to Palstra on th Officr Rspons to Rprsntation Th policy approach within th SPD is considrd to b consistnt with th NPPF (2012), th London Plan (2011), th Cor Stratgy (2011) and th savd Southwark Plan (2007), taking into account changs in th surrounding contxt sinc dvloping th Cor Stratgy vision in 2009/2010. Th London Plan, Cor Stratgy and savd Southwark Plan form th dvlopmnt plan for Southwark, with th NPPF stting out national guidanc. Th dvlopmnt plan sts out th policis for tall buildings. Ky policis ar: London Plan policy 7.7 which idntifis that tall and largr buildings should gnrally b limitd to sits in th Cntral Activitis Zon, opportunity aras, aras of intnsification or town cntrs that hav good accss to public transport. Blackfriars Road lis within th Cntral Activitis Zon, is an opportunity ara and a town cntr with good accss to public transport. Cor Stratgy stratgic policy 12 rquirs tall buildings to hav an xmplary standard of dsign and idntifis locations whr tall buildings could go. Th Cor Stratgy vision for Banksid and Borough rfrs to th council stting out in dtail which sits ar appropriat, snsitiv and inappropriat for tall buildings through th supplmntary planning documnt/opportunity ara framwork. Savd Southwark Plan policy 3.20 sts out critria for considring applications for tall buildings and applis across th borough Th approach is supportd by our vidnc bas including th Blackfriars Road Urban Dsign Study which has bn prpard in accordanc with CABE and English Hritag Guidanc on Tall Buildings, In light of consultation rsponss and to add clarity to th guidanc rlating to St Gorg s Circus in SPD 5, th SPD has bn updatd to clarify that a tall building could provid a focal point at th southrn nd of Blackfriars Road up to 70m. A tall building should also sustain, nhanc or bttr rval th local hritag assts. Ths mattrs would b assssd at th planning application stag through th rlvant savd Southwark Plan policis, Cor Stratgy Policy SP12 and th rlvant policis of th London Plan and planning rgulations. Bullt-point 14 of SPD 5 sts out furthr guidanc rgarding microclimat.

224 Rp Obj Rf Rf Nam Phob Grnw 0 1 ood Dtails of Rprsntation opposit sid of Blackfriars Road. p9 Banksid will b a location of larg offics and major arts and cultural facilitis, including an xpandd Tat Modrn. W think taking Banksid could b an intrsting cas study in th ffct of tall and larg-scal buildings on an ara. It has sn hug dvlopmnt, similar to that coming to Blackfriars Road. Its local rsidnts now suffr from: loss of light loss of viws wind tunnl ffct lack of human scal ovr-dominanc by tall buildings of xisting buildings (spcially rsidntial) loss of historic buildings (whr dmolition of historic buildings is carrid out in ordr to mak way for nw buildings) rosion of community fling loss of small businsss W would xpct th BR SPD to hav a srious assssmnt of th abov ngativ impacts and how thy would b mitigatd. In Banksid, th prdominanc of nw tall, mainly offic and hotl buildings on Southwark Strt, hav not contributd to a livly, mixd us town cntr, instad thy ovrshadow public spac and crat wind tunnls, making it unplasant to b in th public ralm. Th larg dvlopmnts hav faild to attract amnitis that srv local nds, so dspit th high volum of visitors to rivrsid attractions, and th xisting rsidntial community, th ara around Southwark Strt is dsolat aftr working hours and on wknds. 6. Built form and hritag p24 W will nsur that high quality dsign and architctur mak a positiv contribution to local charactr and distinctivnss, in particular rinforcing th civic charactr and scal of th historic boulvard of Blackfriars Road, th Thams rivrfront and th main ast wst routs of Stamford Strt and Southwark Strt, Union Strt and Th Cut. Dvlopmnt should: Hlp to crat a sns of plac and idntifiabl charactr, sustaining, nhancing Officr Rspons to Rprsntation Th SPD sts out built form guidanc in rlation to th ara s contxt, hritag and dvlopmnt potntial. Th guidanc st out within th SPD is consistnt and rad in conjunction with th xisting planning policy framwork of dsign, hritag and tall building policis, which includs th rlvant savd Southwark Plan policis, Cor Stratgy Policy SP12, th rlvant policis of th London Plan and th NPPF. Th guidanc is undrpinnd by th BBLB Charactri study (2013) which intrprts th ara s charactr and dvlopmnt.

225 Rp Obj Rf Rf Nam Phob Grnw 1 1 ood Dtails of Rprsntation or bttr rvaling lmnts of th xisting local and historic nvironmnt which hav good charactr. This includs consrving and nhancing hritag assts and thir sttings. Ensur that matrials and faturs rflct th idntity of th surroundings, taking th local historic nvironmnt into considration. Rinforc th civic scal along th main routs of Blackfriars Road, Stamford Strt and Southwark Strt Dsign buildings of an appropriat massing to crat a human scal of dvlopmnt at strt lvl. Th SPD has a prdominant mphasis on larg commrcial dvlopmnt, taking this into account alongsid Southwark council planning tam s willingnss to allow dvloprs to dmolish unlistd historic assts to mak room for tall buildings, thr is nothing in th SPD that maningfully sts out how policy rquirmnts on consrving and nhancing Southwark s built form and hritag will b mt or nforcd. W would xpct th BR SPD to includ a dtaild assssmnt of th historic charactr of th ara, it s bnfits to quality of lif, and to includ a mor forcful stratgy to consrv and nhanc that hritag. W would argu that th rcnt approval of th Lindn Homs schm, which fails to comply with any of th critria statd in th SPD, calls into qustion th point of th SPD. Th Lindn Homs dvpt is an avrag schm that has no rlation at all in scal or matrial to its surroundings. It also involvs th dmolition of two buildings of significant historical intrst. With policy on hritag not bing applid by th council s planning tam, why should any dvlopr fl thy nd to comply with SPD rcommndations? 10. Affordabl housing p.8 W ar working with th local community and landownrs to dlivr larg scal dvlopmnt and improvmnts, providing ovr 1,900 nw homs, 665 affordabl housing units and around Officr Rspons to Rprsntation Th SPD sts out that it provids furthr guidanc to xisting planning policis in th Cor Stratgy and savd Southwark Plan. It dos not rpat borough wid policis and th SPD must b rad alongsid othr planning documnts. Housing is not givn its own sction within

226 Rp Obj Rf Rf Nam Phob Grnw 2 1 ood Phob Grnw 3 1 ood Dtails of Rprsntation 25,000 nw jobs by Official policis which sit abov th draft SPD clarly acknowldg th nd for local councils to provid sufficint affordabl housing so that popl from all walks of lif can continu to liv in aras such as Blackfriars Road. Dspit this, th draft SPD contains an xtrmly worrying lack of dtail on th provision of such housing. With th xpctd incras in population numbrs in th SPD ara, will Southwark Council xplain why th draft SPD only maks on rfrnc to affordabl housing? 11. Community grn spac p.22 Urban grning and th provision of grn infrastructur is an important part of a high quality public ralm. Grn infrastructur can significantly contribut to a sns of plac and rsult in social and conomic bnfits, as wll as positiv nvironmntal ffcts. Th SPD ara alrady suffrs from a lack of gnuin public opn spac, by this w ar not rfrring to public ralm providd at th spac of larg dvlopmnts. Ths sits ar always shadd, gnrally windy and do not provid gnuin opn spac which by dfinition xists apart from buildings. Ar any of th 46 sits idntifid as potntial dvlopmnt sits bing considrd for us as grn opn spac? If not, why ar no sits idntifid for nw public or grn spac? Officr Rspons to Rprsntation th SPD bcaus th borough-wid housing policis and guidanc alrady covr housing adquatly. This includs policis in th Cor Stratgy and savd Southwark Plan and SPDs on affordabl housing and rsidntial dsign standards. Existing policis and guidanc provid clar policis for affordabl housing. W hav also insrtd a nw appndix (appndix A) listing th ky borough wid Southwark planning policis and supplmntary planning guidanc to mak it clarr that ths policis nd to b rad alongsid th Blackfriars Road SPD. Sction 1 of th SPD has bn updatd to rfr to this nw appndix. Th SPD is consistnt with our Opn Spac Stratgy (2013) which has idntifid a dficincy in opn spacs within thn ara; howvr givn th limitd opportunitis for th cration of opns, our priority is to focus on improving out xisting opn spacs. W will sk to provid nw opn spac and grning as st in th stratgy. SPD 3 ncourags nw strt trs. A nw paragraph has bn addd to SPD 3 "w ar doing this bcaus" to provid furthr background on th Opn Spacs Stratgy rcommndations. Th SPD dos not dsignat dvlopmnt sits, allocat proposals sits or provid sit spcific guidanc, as this would byond th scop of th SPD. It dos idntify potntial dvlopmnt sits which ar illustrativ of th hug opportunity for chang within th ara and th nd for a cohrnt framwork. Th SPD has also bn updatd to clarify that th list of sits is not xhaustiv and othr sits may com forward for dvlopmnt. Som of th sits will b compltly rdvlopd, whilst othr sits may xprinc lss chang such as rfurbishmnt or improvmnts to th xisting buildings or surroundings. 13. Potntial dvlopmnt sits In this w support th Th figur and tabl within th SPD shows potntial dvlopmnt commnts of Barbara Grhs: Th draft SPD contains a sits. Ths sits ar idntifid by officrs as sits with th potntial list of 46 potntial dvlopmnt sits with no for som chang to th building or its surroundings. Som of th sits accompanying dtail whatsovr on what ths ar, hav planning prmission, som ar undr construction, som ar why thy hav bn slctd and what th plans/idas going through th planning procss, and som hav no known plans ar. A closr look at ths sits rvals an xtrmly as yt. Th list and figur has bn updatd following consultation to worrying trnd of armarking buildings - both priod tak into account suggstions from land ownrs and rsidnts. Furthr

227 Rp Obj Rf Rf Nam Phob Grnw 4 1 ood Dtails of Rprsntation Officr Rspons to Rprsntation and modrn - which ar alrady fit for purpos in trms wording has also bn addd to th SPD to mak it clar that th list of srving th businss and rsidntial communitis of sits is not xhaustiv and that whilst som of th sits will b wll by mting ky policy issus such as th compltly rdvlopd othr sits might xprinc lss chang prsrvation of hritag assts, th provision of small such as rfurbishmnt or improvmnts to th xisting buildings or businss spac and th provision of rsidntial surroundings. Th SPD is not allocating sits as proposals sits and accommodation. Whn will Southwark Council b so dos not provid policis on th land uss within ach of th sits. issuing th following dtails to all partis in this Th allocation of proposals sits is don through a dvlopmnt plan consultation rgarding vry on of ths 46 sits in documnt. Currnt dsignations for Blackfriars Road ar in th savd th form of visuals (photographs), and dtails on Southwark Plan (2007) which is currntly bing rviwd through th currnt usag, why thy hav bn slctd for prparation of th Nw Southwark Plan. As part of this rviw w will dvlopmnt and what dvlopmnts ar bing b looking at whthr w should allocat mor and/or chang xisting considrd (visuals plus dscriptions)? In particular, proposals sits dsignations and updat th adoptd policis map. will Southwark Council plas commnt on th Full consultation will b carrid out on th Nw Southwark Plan in following sits markd as potntial dvlopmnt sits: accordanc with our SCI and th rlvant rgulations. Suggstion for o ID 11: This svn-story building at 209/215 Friars Bridg Court, Blackfriars Court notd. This sit has bn Blackfriars Road o ID 14: 200 Union Strt o ID 15: addd to th figur and tabl idntifying potntial dvlopmnt sits as Block T, Pabody Squar, Blackfriars Road o ID 17: thr may b potntial for improvmnts to this sit Union Strt o ID 20: Southwark Collg in Th Cut o ID 24: Markd on Tabl 1 as Fridn Hous, Blackfriars Road o ID 25: Also markd on Tabl 1 as Fridn Hous, Blackfriars Road, o ID 26: Blackfriars Road o ID 28: 57 Wbbr Strt o ID 29: 61 Wbbr Strt o ID 33 & ID 35: 63 Wbbr Strt / 94 Wbbr Strt o ID 34: 96 Wbbr Strt ID 30: Rushworth Strt o ID Lancastr Strt Friars Bridg Court Blackfriars Road W would lik to put forward Friars Bridg Court Blackfriars Road as a potntial sit for dvlopmnt and would lik to know why it has not bn includd? It is an unattractiv po-mo 80s building that has no appal and is rgularly lambastd as bing a horror by th architctur and building community. It's also a big sit, so thr's scop for significant nw dvlopmnt 14. Sits of hritag intrst Th blow following Buildings that contribut positivly to th charactr of consrvation buildings ar of intrst in th SPD ara and should b aras, buildings of townscap mrit or hritag valu outsid of

228 Rp Obj Rf Rf Nam Guid wll Ltd Guid wll Ltd Guid wll Ltd Guid wll Ltd Guid wll Dtails of Rprsntation Officr Rspons to Rprsntation highlightd as such Huntr Hous, St Jams Strt consrvation aras ar idntifid within figur 5 of th SPD. Guidanc Gardnr Hous, Lancastr Strt Th Bridg Hous, and th idntification of buildings will b addrssd in a nw Hritag Lancastr Strt Murphy Hous, Borough Road Albury SPD that will b prpard alongsid th Nw Southwark Plan. Buildings and Clandon Buildings, Boyfild Strt Parish of St Gorg th Martyr Public Libary, Borough Road Blackfriars Road Th Blackfriars Foundry, 156 Blackfriars Road Ths rprsntations ar submittd on bhalf of Support notd. Guidwll Ltd who own land known as Rnni Court, Rivr Court and th Doggtts Coat & Badg Public Hous, and follow communications with Tom Buttrick. Guidwll Ltd agr with th adoptd stratgic and local planning policy for th London Bridg, Borough and Banksid Opportunity Ara, as st out in th London Plan and Cor Stratgy, which nots considrabl potntial for intnsification and ndorss a clustr of tall buildings around th northrn nd of Blackfriars Road, providing high quality offics, housing, hotls and shops. Guidwll Ltd support th Council s mrging vision Support notd. for Blackfriars Road (para of th SPD) which ndorss maximising opportunitis to incras th amount and typ of dvlopmnt including housing and stats that thr will b a rang of building hights along Blackfriars Road, with th tallst buildings at th north nd of th road. Guidwll Ltd ar kn to work in partnrship with th Council and Stratgic/Local Stakholdrs in contributing to dvloping this vision. Rcommndation 1: Guidwll Ltd rcommnd that th land within its ownrship, as idntifid on th attachd plan rf: LOP001, should b includd on Figur 5/Tabl 1 as potntial dvlopmnt sits. Guidwll Ltd support SPD2 (Mixd Us Town Cntr) and SPD3 (Public Ralm and Opn spac) which Notd. Figur 6 - and tabl 1 hav bn updatd. Notd.

229 Rp Obj Rf Rf Nam Ltd Guid wll Ltd CBRE Lionbr ook & South wark Chariti s Dtails of Rprsntation ncourag a mixtur of nw town cntr uss and improvmnt to th public ralm including sustaining and nhancing xisting links to th Thams Path. Th land within Guidwll Ltd s ownrship provids opportunitis to contribut towards ths objctivs. Guidwll Ltd support th fact that SPD5 (Building Hights) dos not st out a spcific uppr limit on building hights at th north nd of Blackfriars Road and acknowldgs that dvlopmnt proposals should b guidd by sit spcifics and th urban contxt. Rcommndation 2: It would b hlpful if th SPD could b clar in stating that thr is no dfind uppr hight limit at th north nd of Blackfriars Road. Officr Rspons to Rprsntation No chang. This amndmnt is not rquird Blackfriars Road Th sit is situatd on th Figur 6 - and tabl 1 hav bn updatd. ast sid of Blackfriars Road btwn Burrll Strt and Nicholson Strt. It compriss 0.74 hctars and includs Conoco Hous and Quadrant Hous, Edward Edward s Hous and Suthring Hous, as idntifid on th attachd sit location plan. Thr is an xisting mix of uss as follows: Conoco Hous An offic block of 8 floors fronting Blackfriars Road dating from th 1970 s. It has a gross intrnal ara of approximatly 8,000 sqm and is fully lt, but only on short lass. Quadrant Hous A nin story rsidntial block fronting Burrll Strt comprising 36 socially rntd flats. It adjoins Conoco Hous and was built as part of th sam dvlopmnt Edward Edward s Hous A two story Alms hous dating from 1973 comprising 21x 1-bd flats, 5x bdsit/studios, 1x 2-bd flat and an stat offic and boardroom for th Charity. Th building is situatd on th cornr of Chancl Strt and Nicholson Strt and is built around a courtyard. Suthring Hous A thr story Public Hous with six flats abov Th xisting sit has a rlativly low dnsity with th buildings fronting Blackfriars Road st

230 Rp Obj Rf Rf Nam Dtails of Rprsntation back from th strt, and gnrous aras of surfac car parking and amnity spac within th sit. Non of th xisting buildings can b considrd to positivly contribut to th charactr and apparanc of th ara bcaus thy lack cohrnc and ar not of architctural mrit. Th sit thrfor prsnts a significant opportunity for rdvlopmnt. Quadrant Hous and Conoco Hous ar idntifid as a potntial dvlopmnt sit within Tabl 1 of th draft SPD (sit 9, amndd vrsion). Howvr, th rdvlopmnt of a largr sit than currntly proposd for sit 9 will offr mor options in trms of potntial dvlopmnt proposals and thrfor w rqust that th idntifid ara is xpandd to includ th ntir sit as shown within th rd lin on th plan attachd to ths rprsntations. Th ky stakholdrs ar in a position to bring forward th whol sit for rdvlopmnt nabling a comprhnsiv schm to b dvlopd It is nvisagd that th sit will b brought forward for an offic-ld mixd us dvlopmnt which will mak bst us of th opportunitis affordd by th sit and includ a gratr amount of floorspac. It is likly that th schm will includ rsidntial uss to rplac xisting units, and will includ a rplacmnt public hous. Thr could also b a suprmarkt to provid nhancd shopping facilitis in this part of th Borough. Th sit may also b brought forward for dvlopmnt with anothr sit(s) in Southwark to provid rplacmnt Alms hous. Th xisting Alms hous is no longr fit for purpos; th lift is inadquat and th building is not compliant with Disability Discrimination Act 1995 rquirmnts. Should two sits b brought forward togthr thy should b considrd togthr in trms of th proposd mix of affordabl and privat housing CBRE Blackfriars Road SPD In trms of th aims of th SPD, Notd. Officr Rspons to Rprsntation

231 Rp Obj Rf Rf Nam 2 0 Lionbr ook & South wark Chariti s CBRE Lionbr ook & South wark Chariti s CBRE Lionbr ook & South wark Chariti s CBRE Lionbr ook & South wark Chariti s Dtails of Rprsntation CBRE Lionbrook and Southwark Charitis support th Council s mrging vision for th ara. Th ara is suitd to a mix of uss including offics, srvics, shops and rsidntial uss. Th Council s aim to maximis opportunitis to incras th amount and typ of dvlopmnt is strongly supportd. Th vision for Blackfriars Road is indd on whr, incrasingly, popl will want to work, liv and visit, and th rdvlopmnt of th CBRE Lionbrook and Southwark Charitis sit can contribut to this. CBRE Lionbrook and Southwark Charitis support draft Policy SPD 1 which sks to hlp consolidat and xpand th xisting businss srvics clustr and rinforc th ara as a stratgic mploymnt location. Th rdvlopmnt of sit 9 can hlp to achiv th policy objctivs by providing a gratr amount of offic spac on th sit. Notd. CBRE Lionbrook and Southwark Charitis support Support notd draft Policy SPD 2, which ncourags th provision of a balancd mix of appropriat uss. Th rdvlopmnt of sit 9 can hlp to achiv th objctivs of this draft policy by providing an activ strt lvl frontag along Blackfriars Road to add visual intrst and contribut towards nhancing th commrcial attractivnss of th ara. Th provision of rtail uss will provid continuity with th rtail uss currntly bing constructd at 240 Blackfriars Road. CBRE Lionbrook and Southwark Charitis ar also supportiv of th principl of nhancing th public ralm and opn spacs as st out in SPD 3 if linkd to an incras in dnsity to support ths improvmnts. Th rdvlopmnt of th proposd sit will rinforc and nhanc th charactr of Blackfriars Road and can improv prmability with nw pdstrian linkag through th sit. Notd. Officr Rspons to Rprsntation

232 Rp Obj Rf Rf Nam CBRE Lionbr ook & South wark Chariti s CBRE Lionbr ook & South wark Chariti s CBRE Lionbr ook & South wark Chariti s Dtails of Rprsntation In rlation to draft Policy SPD 4, CBRE Lionbrook and Southwark Charitis acknowldg th nd for high quality dsign and architctur that maks a positiv contribution to local charactr and distinctivnss. Draft Policy SPD 5 concrns building hights. Th policy sts out that th tallst buildings should b towards th north nd of Blackfriars Road and spcifically stats that buildings btwn Southwark Tub Station and St. Gorgs Wharf should b up to 30 mtrs. Howvr, th proposd hight of th buildings btwn th idntifid Gatway Location and Southwark Tub is not clarly dfind. Givn that 240 Blackfriars Road will hav a hight of 89 mtrs, thr is potntial for dvlopmnt on th CBRE Lionbrook sit to b as tall as 240 Blackfriars Road, particularly at its northrn nd. Morovr, th incrasd siz of th sit will mak it suitabl for a comprhnsiv rdvlopmnt. It should thrfor b clar that th proposd sit is of a shap and siz suitabl for substantial dvlopmnt proposals, subjct to mting th rlvant planning policy rquirmnts for tall buildings. Policy SPD 6 concrns activ travl. Th sit is locatd in a highly accssibl location with a PTAL rating of 6b (xcllnt). It is within asy walking distanc of Southwark Undrground Station and bus stops along Blackfriars Road. It thrfor rprsnts a suitabl sit for high-dnsity dvlopmnt in lin with National and local planning policis which sk to locat dvlopmnt in accssibl locations and ncourag sustainabl mods of transport. Activ travl pattrns can b ncouragd as part of any Notd. Officr Rspons to Rprsntation Th SPD sts out th building hights guidanc for th ara. Dvlopmnt proposals would b assssd at th planning application stag. No chang. Dvlopmnt proposals would b assssd for fasibility at planning application stag.

233 Rp Obj Rf Rf Nam CBRE Lionbr ook & South wark Chariti s CBRE Lionbr ook & South wark Chariti s Dtails of Rprsntation rdvlopmnt schm including th provision of cycl parking and a travl plan. In rlation to Sction 4 Implmntation, th ky Notd. stakholdrs ar happy to work closly with Southwark to furthr dvlop th aspirations for th sit and public consultation will play an important rol whn working up dvlopmnt proposals. Conclusions Ovrall, CBRE Lionbrook and Southwark Charitis support th Council s vision for Blackfriars Road. Howvr, Sit 9 should b nlargd to includ th ara shown on th attachd sit location plan and th final vrsion of th documnt should b draftd to provid sufficint flxibility to ncourag an appropriat commrcial scal of dvlopmnt, including suitabl tall buildings, to support a mix of uss and to initiat arly rdvlopmnt W rqust that our commnts ar takn into account whn prparing th final SPD and would b happy to mt with you to discuss th potntial of th sit furthr. W would ask that you kp us informd about th progrss of this and any othr rlvant documnts. Notd. Officr Rspons to Rprsntation Jrmy Yap Ntwork Rail is gnrally supportiv of th documnt Notd. Officr commnts providd to ach of th dtaild commnts. 1 and in particular th rcognition of th potntial scal of growth that is xpctd to com forward in this ara. Having said that, dtaild blow ar additional commnts and obsrvations on th documnt that I would b gratful if you could considr prior to finalising th documnt Stv Austin Ntwor k Rail Paragraph 1.2 Ntwork Rail would b kn to undrstand furthr th rlationship btwn th various policy documnts that covr this part of Southwark. This ara is, in local and rgional planning policy trms, covrd by th London Plan and is Notd.

234 Rp Obj Rf Rf Nam 992 Stv Austin Ntwor k Rail 992 Stv Austin Ntwor k Rail 992 Stv Austin Ntwor k Rail Dtails of Rprsntation idntifid as an Opportunity Ara. This ara has prviously bn includd in th Draft Banksid, Borough and London Bridg SPD. Is work still continuing on this documnt? Th northrn sction of th Blackfriars Road SPD boundary is also proposd to form part of th Banksid Nighbourhood Plan boundary. I would wlcom a discussion to undrstand how th local planning policy will oprat btwn ths documnts if adoptd. Blackfriars Road Support is givn to th aspirations st Support notd. out in paragraph which xplains that: Blackfriars Road will hav its own distinct idntity as a livly and vibrant ara, bcoming an xciting plac whr popl want to work, liv and visit. It is vidnt that th ara offrs a rang of opportunitis to incras th amount of dvlopmnt and th ability for its potntial to b maximisd. Ntwork Rail blivs that much of its proprty portfolio can offr flxibl innovativ businss spac, as wll as rsidntial, cultural, lisur, arts and ntrtainmnt uss, as idntifid in th draft SPD. Within paragraph 2.2.4, it is rqustd that th rfrnc to Ntwork Rail s railway archs providing a rang of uss including small businsss, b amndd to mploymnt opportunitis. Ntwork Rail oprats a vry larg and divrs proprty portfolio, and it is not considrd to rflct our objctivs to rfrnc small businsss. W hav a vast array of tnants and w continu to striv to offr accommodation to all businsss, many of which ar not small in siz (in trms of th businss not th unit). Thrfor w do not wish to s rfrnc which may b intrprtd as suggsting Ntwork Rail is attractiv to small businsss only or principally. Dvlopmnt Sits Th land comprising th railway infrastructur, th archs and associatd land is oftn Officr Rspons to Rprsntation W hav amndd th mrging vision in th SPD and includd rfrnc to mploymnt opportunitis. Figur 5 (now Figur 6) and Tabl 1 has bn updatd with th Bar Lan and Dolbn/Gambia Strt sits. Th proposd Grat Suffolk

235 Rp Obj Rf Rf Nam 992 Stv Austin Ntwor k Rail Dtails of Rprsntation considrd a barrir, or gnrally dtachd from th local ara. As th upgrad of th xisting infrastructur continus, opportunitis hav arisn for som xciting rsidntial and commrcial dvlopmnt on railway land. Ntwork Rail wishs to promot th following major dvlopmnt sits which do not appar to hav bn includd on Figur 5: Potntial dvlopmnt sits and Tabl 1: Potntial dvlopmnt sits. Som of ths sits ar xpctd to b includd in th Banksid Nighbourhood Plan and thy hav also bn submittd as part of th Gratr London Authority s Stratgic Housing Land Availability Assssmnt (SHLAA). Th sit plans hav bn nclosd with this lttr and ar broadly known as: h Bar Lan Sit Dolbn/Gambia Strt Sit h Grat Suffolk Strt/Union Strt/Ewr Strt Sit Du to th natur of th oprational infrastructur, commrcial uss (associatd tnancis and lass) and availability, thr ar significant constraints and any dvlopmnt may b phasd. Th approach has to b flxibl in ordr to allow for th aspirations to b dlivrd. Th dtaild dsign of ths sits has yt to commnc, but it is considrd that thy could offr a wid rang of A, B, C and D uss and would support th low lin ast/wst pdstrian link adjacnt to th viaduct whr oprationally and commrcially fasibl. Givn th sit constraints, principally th oprational railway, dvlopmnt is likly rsult in tallr buildings. Ntwork Rail is proposing to mt with th London Borough of Southwark in th nar futur to introduc th dvlopmnt potntial of various sits idntifid. Following this it is anticipatd that dtaild prparation of th currnt aspirations is dvlopd and ngagmnt with stakholdrs will commnc. SPD1 Businss Spac In principal Ntwork Rail supports th proposals st out in SPD1 Businss Officr Rspons to Rprsntation Strt/Union Strt/Ewr Strt sit is outsid th SPD ara boundary. Th SPD stats that th list of potntial dvlopmnt sits is illustrativ of th hug opportunity for chang within th ara and th nd for a cohrnt framwork. It has also bn updatd to clarify that th list of sits is not xhaustiv and othr sits may com forward for dvlopmnt. Som of th sits will b compltly rdvlopd, whilst othr sits may xprinc lss chang such as rfurbishmnt or improvmnts to th xisting buildings or surroundings. Th formal idntification of proposals sits within th ara will b considrd as part of th prparation of th Nw Southwark Plan. Th SPD sts out a clar building hights stratgy for th ara in SPD 5, alongsid SPD 4. Tall buildings will b ncouragd in important locations, whr thy rinforc th charactr and function of Blackfriars Road as a main rout into cntral London. Ths landmarks will highlight th importanc of Blackfriars Road as a gatway to Southwark and crat nw focal points at main transport nods and th junction btwn Blackfriars Road and Elphant and Castl. W hav amndd th supporting txt and includd th rfrnc to mploymnt opportunitis in th archs.

236 Rp Obj Rf Rf Nam 992 Stv Austin Ntwor k Rail Dtails of Rprsntation Spac, particularly th promotion of a mix of uss within Opportunity Aras. It is apprciatd that th archs provid a significant opportunity to accommodat a mix of mploymnt uss, and th flxibility offrd spcially in th policy for railway archs B1, businss us, A and D uss is wlcomd. Th aims of th policy ar considrd largly in accordanc with guidanc st out in th National Planning Policy Framwork (NPPF) stats that: In drawing up Local Plans, local planning authoritis should: support xisting businss sctors, taking account of whthr thy ar xpanding or contracting and, whr possibl, idntify and plan for nw or mrging sctors likly to locat in thir ara. Policis should b flxibl nough to accommodat nds not anticipatd in th plan and to allow a rapid rspons to changs in conomic circumstancs; (paragraph 21) and Local Plans should mt objctivly assssd nds, with sufficint flxibility to adapt to rapid chang, unlss: any advrs impacts of doing so would significantly and dmonstrably outwigh th bnfits, whn assssd against th policis in this Framwork takn as a whol; or spcific policis in this Framwork indicat dvlopmnt should b rstrictd. (paragraph 14) Howvr, Ntwork Rail would not support th rfrnc in paragraph 3.6, which rfrs to spac for small businsss. It is rqustd that th rfrnc to Ntwork Rail s railway archs providing a rang of uss including small businsss, b amndd to mploymnt opportunitis. SPD 4 Built form and hritag Prsrving th local charactr is xtrmly important, and Ntwork Rail rcogniss that th railway archs hav an intgral part to play in th succss of many of th main principls idntifid in this documnt and this policy. Officr Rspons to Rprsntation No chang. Dvlopmnt proposals would b assssd for fasibility at planning application stag.

237 Rp Obj Rf Rf Nam 992 Stv Austin Ntwor k Rail 992 Stv Austin Ntwor k Rail Dtails of Rprsntation Howvr, Ntwork Rail would objct to th stringnt us of rsisting th us of solid xtrnal rollr shuttrs. It is considrd that thr should b a cavat or som lmnt of flxibility built into this statmnt that would allow for th us of an xtrnal rollr shuttr if it is not physically possibl to locat it intrnally. For xampl som railway arch units would not offr th opportunity for an intrnally locatd rollr shuttr du to thir physical shap or du angl at which thy fac onto th strt scn. A rcnt xampl of this is planning application 12/AP/3171, in which aftr som dtaild xplanation th us of an xtrnal rollr shuttr was prmittd du to th sit constraints. It should also considrd that whilst vry ffort will b mad to us matrials that ar considrd sympathtic to th hritag of an ara, thy may b circumstancs whr altrnativ matrials may b rquird to allow th sit to function safly and without th risk of damag. For xampl, a numbr of th railway archs and th viaducts provid uniqu sit conditions, particularly with rgards to drainag bcaus of th oprational railway abov and ag of th structur. Th railway viaduct includs a drainag systm that protcts th oprational railway and allows it to function. Unfortunatly, this dos rsult in som damp and laking (and th potntial for stalactits for xampl) in th arch units blow. Th intrnal lmnts of th units ar lind, but it is difficult to provid a solution to th xtrnal lvation. This damp and prsnc of watr would not support th us of matrials such as timbr, and oftn a mor robust matrial is rquird. Th significanc of ach sit in rlation to th consrvation aras and hritag principls should also Officr Rspons to Rprsntation W hav updatd SPD 4, so that matrials and faturs should considr th idntity of th surroundings, taking th local historic nvironmnt into considration. Notd.

238 Rp Obj Rf Rf Nam 992 Stv Austin Ntwor k Rail Dtails of Rprsntation b assssd, as not all of th railway proprty portfolio is of significanc; howvr Ntwork Rail is committd to improving th assts, as wll as prsrving and nhancing th hritag assts whr idntifid. Within PPS5 Practic Guid (still rlvant guidanc following th introduction of th NPPF) it stats that: 122. A propr assssmnt of th impact on stting will tak into account, and b proportionat to, th significanc of th asst and th dgr to which proposd changs nhanc or dtract from that significanc and th ability to apprciat it. This will b rflctd in any proposals that ar to b dvlopd. SPD 5 Building hights Ntwork Rail acknowldgs th currnt focus and guidanc for tall buildings as outlind in SPD 5. Howvr, it is considrd that this should b rviwd and amndd to rflct th changing natur of this part of London, south of th Rivr Thams. Th currnt policy wording rquirs that: Th tallst buildings should b at th north nd of Blackfriars Road. Th tallst hights must b st back from th rivr and focusd around th main junction of Blackfriars Road, Stamford Strt and Southwark Strt. It is rqustd that such a stringnt control ovr th location is rlaxd slightly. It is rqustd that this wording is amndd to rplac.around th main junction of Blackfriars Road, Stamford Strt and Southwark Strt, with.locatd north of th railway viaduct and Southwark tub. It is also rqustd that Figur 8: Blackfriars Road sction and Figur 9: Building hight stratgy b amndd to rflct th chang st out abov. Thr would appar to b a mor natural horizontal lin across Blackfriars Road and Banksid aras, linking Watrloo (th Shll Cntr and Elizabth Hous) to London Bridg (th Shard), which could b usd as a southrn boundary for which tall buildings, providing Officr Rspons to Rprsntation No chang. Th SPD sts out th building hight guidanc for th ara which sts out that th tallst buildings will b at th northrn nd of Blackfriars Road and will clustr around th main junction of Blackfriars Road, Stamford Strt and Southwark Strt. Th approach is supportd by our vidnc bas including th Blackfriars Road Urban Dsign Study which has bn prpard in accordanc with CABE and English Hritag Guidanc on Tall Buildings, In light of consultation rsponss and to add clarity to th guidanc rlating to St Gorg s Circus in SPD 5, th SPD has bn updatd to clarify that a tall building could provid a focal point at th southrn nd of Blackfriars Road up to 70m. A tall building should also sustain, nhanc or bttr rval th local hritag assts.

239 Rp Obj Rf Rf Nam 992 Stv Austin Ntwor k Rail Dtails of Rprsntation thy mt planning policy, could b locatd north of. This lin should follow th railway viaduct btwn Watrloo East and London Bridg, rathr than Stamford Strt and Southwark Strt as st out in SDP 5. This is clarly a mor distinctiv boundary, north of which tall buildings could b locatd. This would allow for th tallst buildings to b st back from th rivr as currntly dscribd, with a continuation of tall buildings in th ara south to th railway viaduct, with Southwark tub still providing a final focal point for a tall building. Th altrations proposd for accptabl locations abov, would not impact upon th Stratgic Viw Protctd Vistas or th London Viw Managmnt Framwork. Th ara is also dsignatd as part of th Cntral Activitis Zon and part of th Banksid, Borough and London Bridg Opportunity Ara, both of which support tall buildings as st out in th London Plan Policy 7.7 C, which stats that: Tall and larg buildings should: gnrally b limitd to sits in th, Cntral Activity Zon, opportunity aras. London Plan Policy 7.7, gos on to furthr say that any tall building could improv th improv th lgibility of an ara and prmability of th sit. Th dvlopmnt sits abov th viaducts and potntial tall buildings outlind prviously would support th lgibility of th ast/wst pdstrian link in trms of lgibility. In ordr to achiv th prmability and ast/wst link, any dvlopmnt potntial nds to b mt, particularly in ordr to sustain a mix of uss and vibrancy in th ara. It is considrd that th thrshold of tall buildings as dscribd in SPD 5 of up to 70 mtrs is too rstrictiv. It is rqustd that this is amndd to in th rgion of 70 mtrs or up to 70 mtrs, unlss it can b dmonstratd that a tallr building would not advrsly harm th surrounding ara. Thr may b Officr Rspons to Rprsntation No chang. Th hight thrshold guidanc st out in SPD is informd by th urban dsign study. It is considrd that hights abov th thrsholds would hav an advrs impact on amnity and hritag assts. As such th proposd thrsholds balanc dvlopmnt potntial with a contxtual rspons.

240 Rp Obj Rf Rf Nam 992 Stv Austin Ntwor k Rail 992 Stv Austin Ntwor k Rail Dtails of Rprsntation circumstancs, whr thr may b opportunitis to dvlop buildings that ar tallr thn 70 mtrs, particularly in an ara that is armarkd for intnsification such as Blackfriars Road. Providing th rlvant urban analysis supports th proposd hight of dvlopmnt and dmonstrats its accptability, furthr flxibility in th policy would allow dvlopmnt th potntial to mt furthr objctivs in th SPD. SPD 6: Activ travl Ntwork Rail wishs to support this policy. Th provision of an ast/wst pdstrian link, locatd adjacnt to th railway viaduct, whr both oprationally and commrcially fasibl, is considrd ncssary for this ara to provid furthr transport altrnativs and facilitat a mixd and activ conomy. This has bn promotd as th low-lin and considrabl work has takn plac to dat by th Banksid Nighbourhood Forum to try and bring this connction and significant improvmnt in prmability. Currnt invstigations ar also in plac for a north/south link which will connct th Rivr (th Tat) to aras south of th railway viaduct (vntually to Elphant & Castl). Ntwork Rail also wishs to support this aspiration and is looking to includ it into within its dvlopmnt proposals, whr both oprationally and commrcially fasibl. Summary Ntwork Rail wlcoms th aspirations of th Draft Blackfriars Road SPD and th vision that it is trying to achiv. To hlp scur th vision, Ntwork Rail bliv th fw objctions and its proposd solutions and changs ar ky. It is hopd that ths will b includd in ordr to ralis th full potntial of th ara and rflct nds of all popl who work, liv and visit th ara. As wll rsponding to this draft SPD, Ntwork Rail is a mmbr of th Banksid Nighbourhood Forum and is kn to continu to work Notd. Notd. Officr Rspons to Rprsntation

241 Rp Obj Rf Rf Nam 973 c/o agnt 973 c/o agnt Dtails of Rprsntation closly with th Forum and support th principls and objctivs bing producd in th Banksid Nighbourhood Plan. Significant work has bn undrtakn to dat and Ntwork Rail looks forward to this continuing, with th vntual adoption of an ffctiv Nighbourhood Plan. If you hav any qustions or wish to discussions any of th qustions, issus or gnral commnts raisd in this rspons, thn plas do not hsitat to contact m. Lindn On bhalf of our clint, Lindn Homs South East Homs Limitd (Lindn Homs), w writ to provid commnts on th draft Blackfriars Road Supplmntary Planning Documnt (SPD), which has bn publishd for consultation until 12 Sptmbr Introduction Lindn Homs is a national hous buildr that has dlivrd a numbr of housing dvlopmnts in Southwark, most rcntly gaining a rsolution to grant planning prmission for its dvlopmnt at Blackfriars Road. Th proposals ar for 87 nw dwllings and commrcial units in a building that is split into two lmnts, with a 10 story block fronting onto Blackfriars Road, with a linar 5 story proposition to th rar, fronting onto both Pocock Strt and Surry Row. Th building was dsignd in tandm with both pr and post application consultation with officrs, which rsultd in a scal, hight, bulk and mass that conforms to Southwark Council s dsign aspirations for Blackfriars Road and its surrounding ara. Th commnts blow rflct th viws of Lindn Homs in th contxt of Lindn Commnts on th Draft SPD Lindn Homs support Homs th principl of th production of an SPD for Blackfriars and undrstands th rational for adopting an holistic stratgy for th ara to assist in dlivring th rquird amount of homs and mploymnt in this Notd. Notd. Officr Rspons to Rprsntation

242 Rp Obj Rf Rf Nam 973 c/o agnt Dtails of Rprsntation ara of th Borough. Lindn Homs is in gnral agrmnt with th majority of th policis, with th xcption of building hights. As a rsult, th commnts blow ar mad only in rlation to th tall buildings policy containd within th SPD. Lindn It is notd that Southwark Council s mrging vision Homs for Blackfriars Road is for it to hav its own distinct idntity as a livly and vibrant ara and will continu to hav a mix of offics, srvics and shops, with nw homs on th uppr floors of commrcial dvlopmnts, offring a rang of housing typs and sizs. It stats at paragraph that opportunitis to incras th amount and typ of dvlopmnt will b maximisd, howvr, thr will b a rang of building hights along Blackfriars Road, with th tallst buildings at th north nd of th road thr will also b tallr buildings at th important locations of Southwark tub station and on th main junction of St. Gorg s Circus. Th abov rational is furthr quantifid in Policy SPD 5 Building Hights, which sts our furthr guidanc on what is prcivd to b th appropriat building hight for proposd nw buildings at diffrnt parts of Blackfriars Road. Th Policy stats that: Th tallst buildings should b at th north nd of Blackfriars Road. Th tallst hights must b st back from th rivr and focusd around th main junction of Blackfriars Road, Stamford Strt and Southwark Strt. A tall building, of a hight of up to 70 mtrs should provid a focal point at Southwark tub station. A tall building, of a hight of up to 70 mtrs should provid a focal point at St. Gorg s Circus. Tall buildings must b st back from th Circus. Buildings of up to 30 mtrs along Blackfriars Road btwn Southwark tub station and St Gorg s Circus. Th policy also sts out spcific Officr Rspons to Rprsntation No chang. Th hight thrshold guidanc st out in SPD is informd by th urban dsign study. It is considrd that hights abov th thrsholds would hav an advrs impact on amnity and hritag assts. As such th proposd thrsholds balanc dvlopmnt potntial with a contxtual rspons.

243 Rp Obj Rf Rf Nam Dtails of Rprsntation planning and dsign critria that a building ovr 25 mtrs should mt for it to b accptabl in planning trms. Lindn Homs quris th arbitrary building hight limits that ar proposd in th draft Policy. Whilst it is notd that Southwark Council has conductd an urban dsign study that has informd proposd building hights along th road, Lindn Homs has commissiond its own urban dsign work, which justifis buildings tallr than 30 mtrs at parts of Blackfriars Road othr than th northrn nd, St. Gorgs Circus or Southwark tub. Whilst Lindn Homs has obtaind a rsolution to grant planning prmission for its sit at Blackfriars Road, it maintains th viw that th sit could dlivr a tallr building that xcds th building hights prscribd in Policy SPD 5, whilst mting all of th planning and dsign critria that is rquird for a tall building. This is dmonstratd by th urban dsign work prpard by Nathanil Lichfild & Partnrs, which was commissiond by Lindn Homs. This work found that: Blackfriars Road (South of Southwark Station) has a varity of hights and diffrs in charactr btwn ast and wst. Buildings rang from 4 to 12 storys. Th xisting tall buildings along th astrn sid ar dfind by a numbr of buildings that contribut littl to th strt scn (Friar Hous, Hill Hous and Erlang Hous). Thr is a limitd variation in hight and som may b rdvlopd. To rinforc uniformity of hight along th astrn sid at blow 30m AOD would srv to dtract from th prsnt varity of hights which ar an mrging charactr of th boulvard aspiration for Blackfriars Road and accntuat th monolithic massing and scal of th larg buildings alrady at ths hights. Th mrging pattrn for Blackfriars Road and aras within th borough at ky nods has bn gratr divrsity in hight with clustrs of tall Officr Rspons to Rprsntation

244 Rp Obj Rf Rf Nam Dtails of Rprsntation buildings. Th sit lis clos to th Southwark Station nod on a sit at th intrsction of ky ast wst pdstrian routs through th ara. An incrasd hight and scal of a building on th sit would nhanc lgibility and provid a rfrnc point to ast wst links from th Shard - visibl at London Bridg to Blackfriars Road and thrin ncourag gratr prmability through th ara. Blackfriars Road is bing transformd by tall buildings. Thr is no ovrriding charactr or scal, but divrsity. This pattrn has alrady transcndd south towards th sit with th dvlopmnt of Palstra which is in stark contrast to th charactr of th Listd buildings opposit, or th adjacnt Nlson Squar stat. A maningful variation in hights (that would b apprciabl from walking along th road or from th conncting ast wst routs such as Pocock Strt and Surry Row) would nhanc and rinforc intrst and varity in th strt scn without dtracting from th rol of a much tallr focal building at Southwark Station. Th Banksid, Borough and London Bridg Stag 2 Tall Building Study Dcmbr 2009 found that: Within this appraisal, a visual impact assssmnt on th proposd tall buildings clustrd at Blackfriars Road north notd that St Gorgs Circus th Grad II* listd Oblisk should rmain th focus for viws along th road. Within this contxt, dvlopmnt of a tallr building upon th sit would not intrrupt th visual stting of th Oblisk and would not compt for dominanc with th northrn clustr - particularly if it is considrd that a building of up to 70m would b accptabl upon th station sit. Th London Plan stats that tall buildings ar appropriat in th Cntral Activitis Zons and in th opportunity aras. Givn that Blackfriars Road has xcllnt accssibility, with a PTAL rating of 6a-6b, high dnsity schms can b Officr Rspons to Rprsntation

245 Rp Obj Rf Rf Nam 973 c/o agnt Dtails of Rprsntation supportd. In addition, Lindn Homs has sought advic from lading counsl, Mark Low QC, who has supportd th urban dsign and tall buildings analysis commissiond by Lindn Homs. In Mr Low s opinion, datd 1 August 2013, which spcifically rfrncs th Blackfriars Road dvlopmnt sit, h concluds: As with any such policy thy should b applid flxibly in a mannr rsponsiv to sit spcific issus as wll as in accordanc with th proposd hirarchy. Th first building proposd hr was up to 15 storys and thus xcdd th 30 mtr cut off point. In my viw this was justifid by sit spcific considrations not takn account of in ths gnral policis. Such a building would not hav disturbd th proposd hirarchy in Blackfriars Road and it would hav rspondd positivly to th local contxt whr th cration of a focal point is a dsirabl objctiv for th rasons alrady discussd, whr it would stablish a local hirarchy in th contxt of th 12 story HGH st back on Surry Row away from th Blackfriars Road frontag and whr th Manna Ash building at th nd of Pocock Strt fronting Blackfriars Road to th south of th appal sit is 9 storys in hight. In light of th conclusions st out abov from both th urban dsign work and th lgal opinion sought from Mark Low QC, Lindn Homs maintain th viw that a building that xcds 30 mtrs in hight could b locatd in locations along Blackfriars Road, particularly in rlation to its sit at Blackfriars Road. Officr Rspons to Rprsntation Lindn It should also b notd, that thr is a mistak in th Th figur within th Urban Dsign Study has bn updatd to rmov Homs supporting information publishd with th draft SPD. th building in xcss of 56m from th southrn sction of Blackfriars Th urban dsign study Part 1 dscribs at pags 49 Road, which was includd in rror. Th conclusion of th urban dsign (paragraph ) and 50 (figur 4) th tsting of study rmains th sam for th southrn sction of Blackfriars Road. options for hights which hav informd th draft SPD. Thr is potntial for a sris of tallr buildings up to 30m along th Th tsting of Option 4 is considrd to b graphically southrn sction of Blackfriars Road, which tak into account th

246 Rp Obj Rf Rf Nam 362 Td Inman South Bank Emplo yrs Group Dtails of Rprsntation Officr Rspons to Rprsntation misrprsntd, illustrating a building in xcss of 56m xisting building hight contxt and boulvard charactr of th road. high upon th sit whras it should b illustrating a Buildings ovr 30m in hight along this sction ar likly to xcd th building of up to 56m as dscribd by th txt at transfr in hights rquird for th building hights stratgy in rlation paragraph Wr this graphic b corrctly to th 70m thrshold hights at Southwark tub station and St shown, a building at up to 56m high upon th sit (and Gorg s Circus, as wll as having a potntial advrs impact on th up to this hight along th rmaindr of south significanc of hritag assts and thir sttings within th local Blackfriars Road) would still allow for a transition in contxt and a potntial impact on amnity of lowr scal dvlopmnt hight btwn a building of up to 70m high at to th ast and wst of Blackfriars Road. Southwark Station and 100m at Erlang Hous that accntuats ths mor important nods. W would thrfor conclud that th paragraph should allow for buildings up to 56m high which would rtain th charactristics idntifid important to th boulvard (building lins)and allow for variation in hight (charactristic of Blackfriars) subjct to impact upon amnity and hritag assts as discussd lswhr. Th South Bank Employrs Group is an association of Notd. th major organis in th South Bank, Watrloo and Blackfriars ddicatd to achiving th bst possibl xprinc for mploys, rsidnts and visitors to its ara, which xtnds from Lambth Bridg to Blackfriars Bridg and south to St Gorg's Circus Th Group is a non-profit company limitd by guarant, govrnd by a Board appointd by its mmbrs, who currntly compris: Braburn Estats Kings Collg London British Film Institut London Duck Tours British Rail Board (Rsiduary) London South Bank Univrsity Coin Strt Community Buildrs National Thatr EDF Enrgy London Ey Ntwork Rail Elizabth Hous Partnrs Park Plaza Hotls EY Shll Guy s and St Thomas NHS Trust Southbank Cntr ITV W hav many yars xprinc in dvloping and dlivring mastrplans, urban dsign and planning policy including dvloping visions for Blackfriars Road in th

247 Rp Obj Rf Rf Nam 362 Td Inman South Bank Emplo yrs Group Dtails of Rprsntation past, notably proposals brought forward by Sainsbury s with Lifschutz Davidson Sandilands and Martha Schwarz in This was updatd with all stakholdrs with TfL support in , bringing togthr public highway and privat forcourt aras in a high quality holistic schm. W ar also rsponsibl for dvloping and dlivring th Spin Rout projct, a multi-agncy public-privat rfurbishmnt of Uppr Ground and Blvdr Road with Southwark and Lambth. W wr on th projct tam for Th Cut improvmnt schm and now sit on th Blackfriars Road String Group and lad with TfL on th IMAX Watrloo Road schm. Th Group wlcoms th opportunity to commnt on th draft SPD and th rfrncs in th draft documnt to furthr consultation and ngagmnt with SBEG as th SPD progrsss. Officr Rspons to Rprsntation BRB (Rsiduary) Ltd Braburn Estats British Film Figur 3 of th SPD illustrats th rlationship btwn diffrnt Institut Coin Strt Community Buildrs EDF planning documnts including supplmntary planning documnts and Enrgy London Ey Elizabth Hous Partnrs Ernst nighbourhood plans. Th SPD has bn updatd to mak it clar th & Young Guy s & St Thomas NHS Foundation Trust nighbourhood plans ar currntly bing prpard. Onc adoptd a ITV King s Collg London London Duck Tours nighbourhood plan will hav mor wight than a SPD in th planning London South Bank Univrsity National Thatr procss as it will form part of th council's dvlopmnt plan. At Ntwork Rail Park Plaza Hotls Shll UK prsnt thr is no adoptd nighbourhood plan for any of th ara Southbank Cntr A company limitd by guarant. covrd by th Blackfriars Road SPD. Th SPD may nd to b Rgistrd No Rgistrd Offic: Capital rviwd in th futur if a nighbourhood plan is adoptd for any of Towr, 91 Watrloo Road, London SE1 8RT 2. th SPD ara. Th SPD has bn updatd to rfr to nighbourhood Nighbourhood Planning and th Blackfriars Road forums throughout in appropriat placs and to rfr spcifically to SPD a) SBEG is also appointd as th administrator South Bank and Watrloo Nighbourhood Forum within sction 4 on for th South Bank and Watrloo Nighbourhood partnrship working, businss and community involvmnt. Forum, which has submittd applications to Southwark and Lambth for th ara boundd by th Thams, Blackfriars Road and Lambth Road to b dsignatd as part of th South Bank and Watrloo Nighbourhood Ara. This includs th wstrn sid of Blackfriars Road along its whol lngth and th ara btwn Blackfriars Road and th Borough boundary

248 Rp Obj Rf Rf Nam 362 Td Inman South Bank Emplo yrs Group Dtails of Rprsntation with Lambth, all of which falls in th SPD ara. Th mrging plan will also dvlop policy for Blackfriars Road. b) Th South Bank and Watrloo Nighbourhood Forum, constitutd in July 2013, has 180 mmbrs, many of thm from th ara covrd by th draft SPD. Th Forum will shortly lct a String Group and a Chair and will no doubt also wish to commnt on mattrs rlating to th SPD. Givn th timing of th consultation in rlation to th stablishmnt of th Nighbourhood Forum it is hopd that th Council will b flxibl about considring furthr commnts from th Forum in th nxt month. c) Givn that th community will soon fac furthr consultation on similar issus st out in th SPD, it is important that th council sts out th rasons for dvloping an SPD alongsid mrging nighbourhood plans and th formal rlationship in btwn thm in mor dtail than is illustratd in Figur 3. This applis also to th Nw Southwark Plan. Whr th community has gon to considrabl ffort to dvlop its vision for th ara, it is vital that th policis in th Southwark Plan accord with thos dvlopd in Nighbourhood Plans for th ara. W sk this assuranc from Southwark. d) In ths circumstancs th draft SPD should also rfrnc its commitmnt to working in partnrship with th proprly constitutd South Bank and Watrloo Nighbourhood Forum throughout. Officr Rspons to Rprsntation 3. Gnral Commnt s a) Importanc of Blackfriars An xplanation of th boundary is st out within th SPD. It includs Road As th Draft SPD rcogniss, Blackfriars Road is th whol of th Blackfriars Road and som of th surrounding ara. It a stratgic north-south link and many aspcts of th includs th surrounding ara as th surrounding ara is also likly to proposd policis addrss this. It also rcogniss that s som dvlopmnt and improvmnts, particularly possibl planning policy nds to addrss ast-wst linkags improvmnts to public ralm. Wording has bn addd to th SPD to across Blackfriars Road and links btwn th mak it clarr that th charactr and historic valu of much of th Borough and Banksid and th Watrloo opportunity surrounding ara will continu to b protctd and nhancd. aras. Th London Plan stats rightly that proposals

249 Rp Obj Rf Rf Nam 362 Td Inman South Bank Emplo yrs Group Dtails of Rprsntation Officr Rspons to Rprsntation for opn spac ntwork and transport and community Figur 3 of th SPD illustrats th rlationship btwn diffrnt infrastructur should b coordinatd with thos in th planning documnts including supplmntary planning documnts and Watrloo and Elphant and Castl Opportunity Aras nighbourhood plans. Th SPD has bn updatd to mak it clar th and across borough boundaris. Howvr, as is nighbourhood plans ar currntly bing prpard. Onc adoptd a vidnt from rfrncs such as that at para 3.41 W nighbourhood plan will hav mor wight than a SPD in th planning will also continu to work closly with Lambth Council procss as it will form part of th council's dvlopmnt plan. At to dlivr cross boundary improvmnts this lmnt prsnt thr is no adoptd nighbourhood plan for any of th ara of th draft SPD dos not rprsnt a plan, but simply covrd by th Blackfriars Road SPD. Th SPD may nd to b an intntion to plan. Th ky issu is that in its astwst significanc Blackfriars Road forms th natural th SPD ara. rviwd in th futur if a nighbourhood plan is adoptd for any of boundary btwn Banksid and th South Bank/Watrloo. Th chart of planning policis (Figur 3 p6) rightly idntifis nighbourhood plans as carrying mor wight than th SPD in th planning procss. Th two nighbourhood plans incorporating parts of th SPD ara ar capabl of adding much missing flsh to th bons of th draft SPD. Evn without th mrging nighbourhood plans th full assssmnt of th ast-wst cross- boundary issus (borough, opportunity aras, nighbourhoods) nds much gratr involvmnt of th two Nighbourhood Forums, th intrstd businss organis (SBEG, Watrloo Quartr, Bttr Banksid), GLA and TfL, Ward Councillors on both sids of th borough boundary tc. Idally, in our viw, th SPD should b dlayd to nabl this input to b providd in a coordinatd fashion and abov all to nabl th astwst cross boundary issus to b fully addrssd by all intrstd partis. b) Implmntation Th draft SPD also lacks any substantial contnt on implmntation and dlivry. It has littl rfrnc to how S106 and CIL will b applid to dal with th issus th draft policis idntify. It lacks a dlivry plan and any information about infrastructur costs and dlivry. Ths mattrs should b addrssd in dtail with th partis idntifid Th SPD and othr planning policy documnts provid th framwork for th provision of infrastructur to support dvlopmnt. SPD 2: Mixd us town cntr sts out that w will support th provision of nw social infrastructur and community facilitis as part of mixd us dvlopmnts.

250 Rp Obj Rf Rf Nam Dtails of Rprsntation Officr Rspons to Rprsntation abov, or, prfrably, should await furthr input from th two Nighbourhood Forums. SPD 3: Public ralm and opn spac rfrs to th continud protction of th thr protctd opn spacs and ncouraging furthr linkags and nw spacs. Sction 4.4 of th SPD rfrs spcifically to infrastructur, crossing rfrring to th community infrastructur lvy (CIL) and sction 106 planning obligations to hlp nsur th dlivry of ky infrastructur to mitigat th impact of dvlopmnt Td Inman South Bank Emplo yrs Carbon Rduction and Grn Infrastructur Th SPD is virtually silnt on th issu of carbon rduction. A South Bank Employrs Group/LSBU study idntifid th likly viability of a dcntralisd nrgy clustr at Infrastructur is covrd within borough-wid planning documnts with th ovrarching policy 14 of th Cor Stratgy rcognising that nw dvlopmnt in th borough nds to b supportd by adquat infrastructur, including social, nvironmntal and physical infrastructur. Th borough s Infrastructur Plan, idntifis stratgic infrastructur which is ndd to support growth and dvlopmnt in th borough ovr th liftim of th Cor Stratgy ( ). Whr possibl it idntifis th cost of infrastructur to providd, any committd sourcs of funding which will b usd to dlivr it and th organis rsponsibl. It also idntifis th funding gap i.. th gap btwn known commitmnts and th total cost of infrastructur rquird. Whn it is adoptd, Southwark s CIL will b usd to contribut towards bridging this funding gap. Funds armarkd for infrastructur in th Council s capital invstmnt programm also will hlp to improv infrastructur provision. Th council ar currntly prparing our draft community infrastructur charging schdul and an updatd sction 106 SPD. Adoption is plannd for 2014.It is appropriat to look at th provision of infrastructur at a borough-wid lvl through ths ddicatd documnts rathr than through th Blackfriars Road SPD. At prsnt thr is no adoptd nighbourhood plan for any of th ara covrd by th Blackfriars Road SPD. Th SPD may nd to b rviwd in th futur if a nighbourhood plan is adoptd for any of th SPD ara. Our approach to rducing nrgy consumption and carbon dioxid missions is borough wid. Furthr dtail is st out in stratgic policy 13 of th Cor Stratgy, savd Southwark Plan policy 3.4 and our sustainabl dsign and construction SPD. Cor Stratgy policy 13

251 Rp Obj Rf Rf Nam 362 Td Inman South Bank Emplo yrs Group 362 Td Inman South Bank Emplo yrs Group Dtails of Rprsntation Group th north nd of Blackfriars Road. Sinc thn proposals hav com forward furthr south which might also provid th basis for district hating and nighbourhood CHP. Opn spac rfrncs do not rflct cross-borough opportunitis and challngs. Similarly, grn infrastructur should b supportd at vry opportunity for th bnfits it brings th local community and London as a whol. Th South Bank Employrs Group and Watrloo Quartr hav publishd a grn audit which idntifis sits for grn covr such as rain gardns, opportunitis for surfac watr run-off, and principls for nw dvlopmnt. Ths opportunitis xtnd wll byond protcting xisting grn spacs rfrrd to in th rport. d) With a major studnt accommodation facility on Blackfriars Road, and a numbr of univrsity buildings vry clos by, th SPD should considr how it can support local univrsitis in thir studnt housing nds. Policis could go furthr to ncourag th animation of th public ralm and policis might b introducd that do - tabls and chairs licncs could b favourd whr away from rsidncs in ordr that th strt rmains animatd at diffrnt tims of day. Licnsd pitchs for slling appropriat goods might b ncouragd. Officr Rspons to Rprsntation stats that all major dvlopmnts should st up and/or connct to local nrgy ntworks whr possibl. This approach is in lin with London Plan policy 5.2. Our approach to opn spacs and grn infrastructur is also borough-wid. W hav st out in Cor Stratgy policis 11 and 13, savd Southwark Plan policis 3.25, 3.26, 3.27 and 3.28 and our sustainabl dsign and construction SPD how w will protct and improv opn spacs and ncourag nw dvlopmnt to includ masurs that hlp to promot grn infrastructur. A furthr paragraph has bn addd to th SPD to cross rfr to th council's Opn Spacs Stratgy (2013). As st out in th Blackfriars Road SPD, th SPD dos not rpat borough wid policis and so th SPD must b rad alongsid our othr planning documnts. An appndix has bn addd to cross rfr to ky othr Southwark planning documnts and policis including th Cor Stratgy, Savd Southwark Plan and Sustainabl Dsign and Construction SPD. Th SPD sts out that it provids furthr guidanc to xisting planning policis in th Cor Stratgy and savd Southwark Plan. It dos not rpat borough wid policis and th SPD must b rad alongsid othr planning documnts. Housing is not givn its own sction within th SPD bcaus th borough-wid housing policis and guidanc alrady covr housing adquatly. Spcific policis on studnt housing ar alrady st out in Cor Stratgy policy 8 and savd Southwark Plan policy 4.7. Furthr guidanc is also st out in th Affordabl Housing SPD and Rsidntial Dsign Standards SPD. Thr is no nd for furthr guidanc in th SPD. No chang. Th activation of th public ralm is covrd within th SPD Td Inman South Th Council proposs high quality public ralm Notd. Sction 106 and in futur th community infrastructur lvy

252 Rp Obj Rf Rf Nam 6 Bank Emplo yrs Group 362 Td Inman South Bank Emplo yrs Group 362 Td Inman South Bank Emplo yrs Group Dtails of Rprsntation Officr Rspons to Rprsntation throughout th ara of th draft SPD but th documnt would b dtrmind at th planning application stag. Sction 4 of dos not allud to th funding rquird to maintain th SPD rfrs spcifically to infrastructur, crossing rfrring to th such public ralm to a standard compatibl with th community infrastructur lvy (CIL) and sction 106 planning aspirations for a high quality approach. If th Council is obligations to hlp nsur th dlivry of ky infrastructur to mitigat to sk rvnu contributions from dvloprs for this th impact of dvlopmnt. Th council ar currntly prparing our purpos th SPD nds to includ this, or to rfr to draft community infrastructur charging schdul and an updatd an intntion to allocat a proportion of CIL for sction 106 SPD and will sk to adopt ths in It is appropriat managmnt and maintnanc purposs. to look at th provision of infrastructur at a borough-wid lvl through ths ddicatd documnts rathr than through th Blackfriars Road SPD. g) Bullt 4 of policy SPD 3 calls for a clar distinction btwn public and privat spac. This should b clarifid to nsur that it mans gnuinly privat spac, as opposd to privatly ownd public ralm for which it would b illogical to crat a distinction. Dvloprs should b ncouragd to provid public us of forcourts and othr spacs as part of th widr public ralm and thr should b as littl distinction as possibl in thos cass. h) A local mchanism for dfrayal of s106 and CIL, or at last th local idntification of prioritis should b ncouragd. Th SPD ncourags a ntwork of nw public spacs and improvd public ralm. Dtaild dsign would b assssd at th planning application stag. Th SPD and othr planning policy documnts provid th framwork for th provision of infrastructur to support dvlopmnt. SPD 2: Mixd us town cntr sts out that w will support th provision of nw social infrastructur and community facilitis as part of mixd us dvlopmnts. SPD 3: Public ralm and opn spac rfrs to th continud protction of th thr protctd opn spacs and ncouraging furthr linkags and nw spacs. Sction 4.4 of th SPD rfrs spcifically to infrastructur, crossing rfrring to th community infrastructur lvy (CIL) and sction 106 planning obligations to hlp nsur th dlivry of ky infrastructur to mitigat th impact of dvlopmnt.

253 Rp Obj Rf Rf Nam 362 Td Inman South Bank Emplo yrs Group 362 Td Inman South Bank Emplo yrs Group 362 Td Inman South Bank Dtails of Rprsntation Policy SPD2 and para 3.12 support arts and cultural provision. Thr should howvr b clos involvmnt of th South Bank and Banksid Cultural Quartr in providing advic on cultural dvlopmnts and in nsuring th right balanc btwn nw facilitis and nhancing xisting provision. 4. Spcific points P5. Southwark is splld incorrctly All figurs hav bn updatd. on th map at Southwark Station (and thraftr on all maps). It is also Blackfriars Station, rathr than Blackfriars Road Station. It may b worthwhil accuratly dpicting th opportunity ara boundaris at Elphant & Castl and Watrloo (and on th map on P4) P10 South Bank Univrsity should b London South Bank Univrsity. Officr Rspons to Rprsntation Infrastructur is covrd within borough-wid planning documnts with th ovrarching policy 14 of th Cor Stratgy rcognising that nw dvlopmnt in th borough nds to b supportd by adquat infrastructur, including social, nvironmntal and physical infrastructur. Th borough s Infrastructur Plan, idntifis stratgic infrastructur which is ndd to support growth and dvlopmnt in th borough ovr th liftim of th Cor Stratgy ( ). Whr possibl it idntifis th cost of infrastructur to providd, any committd sourcs of funding which will b usd to dlivr it and th organis rsponsibl. It also idntifis th funding gap i.. th gap btwn known commitmnts and th total cost of infrastructur rquird. Whn it is adoptd, Southwark s CIL will b usd to contribut towards bridging this funding gap. Funds armarkd for infrastructur in th Council s capital invstmnt programm also will hlp to improv infrastructur provision. Th council ar currntly prparing our draft community infrastructur charging schdul and an updatd sction 106 SPD. Adoption is plannd for It is appropriat to look at th provision of infrastructur at a borough-wid lvl through ths ddicatd documnts rathr than through th Blackfriars Road SPD. W hav amndd th supporting txt to mak rfrnc th South Bank and Banksid Cultural Quartr. Notd. Changd throughout th SPD.

254 Rp Obj Rf Rf Nam Emplo yrs Group Dtails of Rprsntation 961 Richard Parish English Thank you for consulting English Hritag on th Notd. Hritag London Borough of Southwark s Draft Blackfriars Road SPD and associatd Sustainability Appraisal (SA). As th Govrnmnt s statutory advisr on th historic nvironmnt, English Hritag is kn to nsur that hritag consrvation and nhancmnt is fully considrd in all aspcts of th local planning procss. Accordingly, w hav rviwd th dtails of th draft SPD and SA in light of th National Planning Policy Framwork (NPPF) which rquirs, as on of its cor principls, that hritag assts b consrvd in a mannr appropriat to thir significanc, so that thy can b njoyd for thir contribution to th quality of lif of this and futur gnrations (NPPF para. 126). In addition w hav also considrd th dtails of th draft SPD against th rcntly publishd National Planning Guidanc (NPG) (2013). Officr Rspons to Rprsntation 961 Richard Parish English In gnral, w support th aims of th SPD to provid Th guidanc st out within th SPD is consistnt with th xisting Hritag a framwork to guid futur dvlopmnt in a planning policy framwork of dsign, hritag and tall building policis, coordinatd mannr. W also wlcom th intntion of which includs th rlvant savd Southwark Plan policis, Cor th draft SPD to st out mrging idas for a Vision for Stratgy Policy SP12, th rlvant policis of th London Plan and th Blackfriars Road (para 2.2.4). Howvr thr a NPPF. Th approach is supportd by our vidnc bas including th numbr of hadlin concrns with rgards to th Blackfriars Road Urban Dsign Study which has bn prpard in mrging Vision and th travl of dirction it provids accordanc with CABE and English Hritag Guidanc on Tall for futur dvlopmnt in Blackfriars Road. It is notd Buildings, In light of consultation rsponss and to add clarity in paragraph that th mrging vision cannot b to th guidanc rlating to St Gorg s Circus in SPD 5, th SPD has formally adoptd through th SPD and that a rviw of bn updatd to clarify that a tall building could provid a focal point at th Southwark Plan will hlp formalis th vision for th southrn nd of Blackfriars Road up to 70m. A tall building should Blackfriars Road. This implis that contnt of th SPD also sustain, nhanc or bttr rval th local hritag assts. gos byond th xisting Southwark Plan, which suggst that th contnt of th draft SPD should b th subjct of thorough xamination, in th form of an

255 Rp Obj Rf Rf Nam Dtails of Rprsntation Ara Action Plan. Th basis for this opinion is that th scal of dvlopmnt now promotd through th draft SPD appars to b byond that nvisagd and articulatd in th Southwark Plan. For xampl th adoptd Cor Stratgy indicats tall buildings will b appropriat at th north nd of Blackfriars Road only. Th mrging Vision sks to dlivr a significant uplift in building hights along th lngth of Blackfriars Road. This is rflctd in th policy SPD 5 Building Hights, which ncourags nw build along Blackfriars Road to btwn 30m and 70m in hight at various points (.g. Southwark tub station and St Gorg s Circus). Th xcption to this approach appars to rlat to th north nd of th Road whr th tallst buildings ar promotd but without any indication of limit. This is an xtnsiv strtch of th Blackfriars Road which appars to b dvoid of any clarity in th managmnt of tall building hights. This is of particular concrn whn many of th tall buildings mrging in this spcific ara, ar impacting upon th widr historic nvironmnt, including many hritag assts in cntral London. This concrn raiss th issu that th mrging Vision promots an xtnsiv rang of tall buildings on th prmis that th dsign of dvlopmnts will b xcptional and will nhanc th local charactr, plus sustain and nhanc th historic nvironmnt. On considring th dtails of th draft SPD and th vry dtaild supporting vidnc (.g. Banksid, Borough and London Bridg Charactri Study July 2013; Draft Blackfriars SPD draft Urban Dsign Study August 2013) w would suggst that ths two drivrs of th mrging vision may not b dlivrabl in all cass. Thr ar concrns that th significanc of th historic nvironmnt as ncapsulatd by its hritag assts may b potntially harmd by th dgr of chang in Officr Rspons to Rprsntation

256 Rp Obj Rf Rf Nam Dtails of Rprsntation hights proposd on sits along Blackfriars Road. This includs potntial harm to hritag assts outsid of th draft SPD ara, north and south of th Rivr Thams. For xampl, hritag assts that ar potntially at risk includ th stting of St Gorg s Circus consrvation ara and th stting of Somrst Hous as xprincd from within its courtyard (not just from its rivr trrac). 961 Richard Parish English It is notd that th draft SPD promots th Hritag consrvation and nhancmnt of th historic nvironmnt, and th rinforcmnt of th aras distinctivnss. This approach is wlcomd. Howvr thr ar concrns that many of th opportunity sits idntifid could rsult in th loss of buildings of particular local intrst in trms of thir contribution to th distinctivnss of Blackfriars Road. Th potntial loss of buildings of local intrst combind with th proposd scal of dvlopmnt could rsult in a charactr that dos not rflct th currnt positiv aspcts of th Blackfriars ara. Th concrn is that th charactr of Blackfriars Road will not b nhancd but changd to on that is bland and disconnctd from th distinctivnss of its surroundings. 961 Richard Parish English Th post-war volution of Blackfriars Road has Hritag introducd substantial variations in parapt hights, and a gnral uncoordinatd, low quality, built form. W would support th intntion to control hights and not that th hights ar maximum with an xpctation of a rang of hights up to this ciling. Howvr w ar concrnd that this dos not provid sufficint assurancs of quality and dsign, and that th tndncy will b to build to th uppr limits. W would rcommnd that th Council considr th production of a dtaild mastrplan which sts out th appropriat rsponss to th diffrnt sits and givs gratr Officr Rspons to Rprsntation Th SPD dos not dsignat proposals sits or provid sit spcific guidanc, as this would byond th scop of th SPD. It dos idntify potntial dvlopmnt sits which ar illustrativ of th hug opportunity for chang within th ara and th nd for a cohrnt framwork. Th SPD has also bn updatd to clarify that th list of sits is not xhaustiv and othr sits may com forward for dvlopmnt. Som of th sits will b compltly rdvlopd, whilst othr sits may xprinc lss chang such as rfurbishmnt or improvmnts to th xisting buildings or surroundings. Th impact on dsignatd and non-dsignatd assts and thir sttings, as wll as dtaild dsign in rlation to contxt would b assssd at planning application stag. Th SPD sts out built form guidanc in rlation to th ara s contxt, hritag and dvlopmnt potntial. Th guidanc st out within th SPD is consistnt and rad in conjunction with th xisting planning policy framwork of dsign, hritag and tall building policis, which includs th rlvant savd Southwark Plan policis, Cor Stratgy Policy SP12, th rlvant policis of th London Plan and th NPPF. Th guidanc is undrpinnd by th BBLB Charactri study (2013) which intrprts th ara s charactr and history. A mastr plan is not considrd appropriat du to th xisting contxt of consntd schms, th immdiat dvlopmnt prssur, th multipl landownrs within th ara and that a mastr plan if

257 Rp Obj Rf Rf Nam 961 Richard Parish English Hritag 961 Richard Parish English Hritag Dtails of Rprsntation guidanc in rspct of th spatial considrations and built form xpctd. This would gratly assist in ralising th vision for Blackfriars Road (g. th Kings Cross Railway Lands Mastrplan ffctivly utiliss lmnts of local historic charactr to str th widr dvlopmnt in a cohrnt and qualitativ way). Mor dtaild commnts on th draft SPD includ: Tabl 1 Potntial dvlopmnt sits (pg13) As highlightd in th hadlin commnts w hav concrns to whthr th qualitis of xisting buildings markd for rdvlopmnt hav bn fully assssd for thir positiv contribution to th charactr of th ara. For xampl Tabl 1 idntifis Blackfriars Road as a potntial dvlopmnt sit. Whilst w rcognis this building is outsid of a consrvation ara and undsignatd, w would considr this to b a high quality commrcial building which rprsnts much of qualitis of charactr which th draft SPD hops to dlivr. In our viw, should b idntifid as an undsignatd hritag asst. Th loss of good quality undsignatd historic buildings and thir rplacmnt with buildings which fail to rspond to local charactr is a notd problm on Blackfriars Road and w would ncourag th council to tak this opportunity to addrss this SPD 1 Businss spac (pg14). It is notd that SPD1 supports th us of th railway archs for a rang of businss uss including crativ and cultural industris tc as contributor to conomic growth. English Hritag supports this approach as thr hav bn many studis rcntly such as th Hritag Lottry Fund Nw idas nd old buildings (2013) that dmonstrat th adaptability of xisting buildings to mting th nds of nw and altrnativ industris and activitis. W would suggst that th wording of Officr Rspons to Rprsntation succssfully tstd at appal, can bcom quickly outdatd. W hav workd with Allis and Morrison and continu to work with TfL and dvloprs to dvlop cohsiv public ralm principls for Blackfriars Road. Th SPD dos not dsignat proposals sits or provid sit spcific guidanc, as this would byond th scop of th SPD. It dos idntify potntial dvlopmnt sits which ar illustrativ of th hug opportunity for chang within th ara and th nd for a cohrnt framwork. Th SPD has also bn updatd to clarify that th list of sits is not xhaustiv and othr sits may com forward for dvlopmnt. Som of th sits will b compltly rdvlopd, whilst othr sits may xprinc lss chang such as rfurbishmnt or improvmnts to th xisting buildings or surroundings. Guidanc and th idntification of buildings will b addrssd in a nw Hritag SPD that will b prpard alongsid th Nw Southwark Plan. Support notd. Savd Southwark Plan policy 1.4 rquirs businss spac to b rtaind or rplacd unlss xcptional circumstancs can b dmonstratd. Southwark CAZ was also xmptd from th govrnmnt s rcnt chang to th Gnral Prmittd Dvlopmnt Ordr to allow offic buildings to convrt to rsidntial. Th CAZ has bn rcognisd by th govrnmnt as a nationally significant ara of conomic activity. Ths nw prmittd dvlopmnt rights do not apply in th CAZ. Thrfor xisting offic buildings will still nd to mt th xmption critria in policy 1.4.

258 Rp Obj Rf Rf Nam 961 Richard Parish English Hritag 961 Richard Parish English Hritag Dtails of Rprsntation SPD1 should promot this concpt byond th railway archs, to othr buildings (particular thos of local intrst) and aras within th Blackfriars ara. This would rflct th supporting commnts mad in th paragraph 3.3 of th draft SPD. SPD2 Mixd us town cntr (pg18) Paragraph 3.16 ncourags frontags and intrior activitis to animat th strt frontag. W would suggst that this approach should also b considrd in th contxt of th rar of nw buildings, whr thy ar visibl within th ntwork of sid strts. Th majority of th consrvation aras (with th xcption of St Gorgs Circus) visually intract with th rar of Blackfriars Road it is thrfor ssntial, in rspct of both prsrving and nhancing charactr and apparanc, and crating an attractiv nvironmnt for popl to work and liv, that th dsign principls of massing, fnstration and matrials should b considrd in ordr to nsur th rar of buildings contribut positivly to th charactr and apparanc of th surrounding ara. Although rlvant to all nw dvlopmnt this is particularly rlvant to dvlopmnts such as hotls (paragraph 3.10). SPD3 Public ralm and opn spac (pg19-20) Ovrall w support th gnral principls dfind in SPD3.Howvr rflcting our hadlin concrns, w would sk to nsur that th implmntation of SPD3 is undrtakn from a basis of idntifying and utilising xisting positiv aspcts of th public ralm that contribut to its charactr (.g. St Gorg s Circus). This includs nsuring nw public ralm works connct succssfully to its surroundings, provids a sns of varity and intrst, and dos not rsult in a bland dsign along th whol lngth of Blackfriars Road. Illustrations (pg21) It would b hlpful to add an Officr Rspons to Rprsntation W considr SPD 4 provids sufficint guidanc to link with SPD3 on activ frontags. SPD4 ncourags dvlopmnt to nsur that matrials and faturs rflct considr th idntity of th surroundings, taking th local historic nvironmnt into considration. In addition SPD4 ncourags dvlopmnt to rinforc th civic scal along th main routs of Blackfriars Road, Stamford Strt and Southwark Strt, by providing clar ntrancs that addrss th strt, gnrous window or aras of glazing. Notd. Th SPD sts out gnral principls for high quality public ralm improvmnts throughout th ara that rcognis th importanc of sustaining and nhancing local distinctivnss, taking th historic nvironmnt into considration, whil crating a sns of plac whr th public ralm provision is currntly poor. Spcific principls ar st out for placs that ar spcially important, such as St Gorg's Circus, th Thams Path and Blackfriars Road itslf. For xampl, SPD 3 sts out clar public ralm principls that sk to nhanc th stting of th Grad II* listd oblisk and th St Gorg s Circus consrvation ara. Th photographs illustrat part of th xisting public ralm contxt.

259 Rp Obj Rf Rf Nam Dtails of Rprsntation xplanation of th intndd principls illustratd by th photographs. 961 Richard Parish English SPD 4 Built form and hritag (pg24) In gnral w Hritag support SPD4 subjct to th following changs bing mad; Point 3 dash 2 - W would suggst changing Activating th bas of buildings by providing clar ntrancs that addrss th strt to Activating th bas by providing wll dfind ntrancs that addrss th strt to avoid confusion in th misintrprtation of th word clar. Point 4 - W would suggst that additional clarification is providd in rspct of th impact of th rar and sid lvations of nw dvlopmnts which front onto main routs, and a nd for ths to nhanc local charactr. This includs rsponding to local viws and th stting of hritag assts. 961 Richard Parish English Hritag SPD5 Building hights (pg27-28) Rflcting our hadlin concrns, w would advis that gratr justification nds to b providd on th hights dfind in SPD5. In particular at th north nd of Blackfriars Road, whr no hight limit is dfind. It is notd in th supporting vidnc that an xisting contxt of tall buildings is stablishd, with th highst approvd schm bing 165m. Howvr it is not clar whthr th rmaining tall buildings in this ara will xpct to b lowr than th 165m (thrfor rprsnting th pak of th clustr) or additional ons will b tallr? In addition it is not clar of th xtnt of th mrging clustr as SPD5 only starts to dfin a building hight maximum at Southwark tub station. Our concrns rlat to th proximity of a rang of high grad hritag assts narby (north and south of Rivr Thams) which could b significantly impactd upon without providing gratr clarity of hight paramtrs for tall buildings at this location. Elswhr, thr ar Officr Rspons to Rprsntation No chang. Th guidanc is clar. Th impact of th rar and sid lvations of nw dvlopmnts which front onto main routs, and a nd for ths to nhanc local charactr would b assssd at planning application stag. SPD 4 provids guidanc for aras off th main road. W hav updatd SPD 5 for gratr clarity in rlation to th guidanc for th northrn nd of Blackfriars Road and also at th southrn nd of Blackfriars Road. Th approach is supportd by our vidnc bas including th Blackfriars Road Urban Dsign Study which has bn prpard in accordanc with CABE and English Hritag Guidanc on Tall Buildings, Th impact on hritag assts outsid th SPD ara was also tstd and this is st out in th urban dsign study.

260 Rp Obj Rf Rf Nam Dtails of Rprsntation concrns that th hight of dvlopmnt at St Gorg s Circus at th southrn nd of Blackfriars Road, as promotd by SPD5, could dtract from th stting of th consrvation ara. W accpt that thr ar dvlopmnt opportunitis nar St Gorg s Circus, but du to th contxt of th hritag assts at this location, w do not s th justification for a tallr landmark lmnt, particularly in light of th grad II* oblisk providing an xisting and lgibl historic landmark. W would also considr that th proposd stting back of a tallr lmnt at this location would contradict its landmark justification. W would wlcom furthr discussion on this issu and modlling in rspct of how ths sits can b dvlopd so that thy consrv and nhanc nighbouring hritag assts. W support th principl that tall buildings must dmonstrat that thy contribut positivly to London s skylin. Howvr w would advis that this principl should b applid to all tall buildings and not just ons abov 50m in hight. W support th us of tsts that should b applid to all tall buildings ovr 25/30m and th inclusion of on rlating to th consrvation and nhancmnt of hritag assts and thir sttings. Howvr w would advis that this tst should b applicabl to hritag assts both within and outsid th draft SPD ara. Th xampls of assts idntifid do not includ any outsid of th draft SPD ara. This raiss concrns to th robustnss of th vidnc whn modlling th impact of th proposd tall buildings, and dfining appropriat hights within SPD5. Officr Rspons to Rprsntation 961 Richard Parish English Appndix 2 Rlvant plans and policis; National W hav amndd th final SA to rfr to ths documnts. Hritag Planning Policy (pg 68). Th rcntly publishd National Planning Practic Guidanc should b assssd with rgards to its impact upon sustainability of th draft SPD. It should also b notd that PPS5

261 Rp Obj Rf Rf Nam Dtails of Rprsntation Practic Guid has not bn rscindd, so should also b considrd as part of th SA procss. 961 Richard Parish English W would also suggst that undr th topic of rtail Hritag (pg92) rfrnc could b mad to English Hritag s guidanc: Rtail Dvlopmnt in Historic Aras Officr Rspons to Rprsntation W hav includd a rfrnc to this documnt in th tabl of national rlvant plans and policy documnts (appndix 2). 961 Richard Parish English Appndix 4 Sustainability matrics SPD5 Building W hav amndd th SA to show that building hights could Hritag Hights - in rspct of SDO11. It is notd that th potntially hav an uncrtain impact on SDO11. Tall buildings will commntary stats that idntifying potntial locations nd to tak into considration th significanc of hritag assts that for tall buildings will mphasis gatways and ky may alrady contribut to th xisting local contxt. Existing policy in locations. Howvr w would advis that tall buildings th London Plan, Cor Stratgy and savd Southwark Plan as wll as also nd to rspond to th xisting contxt which may guidanc in th Blackfriars Road SPD will nsur that applications for alrady includ sufficint lmnts that highlight tallr buildings considrs th significanc of hritag assts. gatways and/or ky locations. This includs considring th significanc of hritag assts that may contribut to an undrstanding of th xisting townscap, in trms of orintation, lgibility and sns of plac. Our concrn is that th matrics suggst that thr ar no conflicts yt th inappropriat dvlopmnt of tall buildings can caus significanc harm. As alrady dtaild abov in rlation to th draft SPD, in particular SPD5, w would suggst that th SA should not conclud at this stag complt complianc with th sustainability objctiv SDO Richard Parish English In th mantim, English Hritag would advis that Hritag th local authority s consrvation staff ar involvd throughout th prparation and implmntation of th draft SPD as thy ar oftn bst placd to advis on; local historic nvironmnt issus and prioritis; sourcs of data; and, considration of options rlating to th historic nvironmnt. 961 Richard Parish English It must b notd that this advic is basd on th Hritag information providd by you and for th avoidanc of doubt dos not affct our obligation to advis you on, and potntially objct to any spcific dvlopmnt proposal which may subsquntly aris from this or Notd. Th council's dsign and consrvation tam hav workd closly with th planning policy tam in prparing this SPD. Notd.

262 Rp Obj Rf Rf Nam Dtails of Rprsntation latr consultations. 961 Richard Parish English Finally, aftr considring our commnts w would Hritag wlcom th opportunity to discuss how furthr itrations of th SPD can b dvlopd. In th mantim I hop you find our commnts hlpful, and if you hav any quris in rspct of th abov plas do not hsitat to contact m. 769 Garth Parry Albrt Associ ation 769 Garth Parry Albrt Associ ation Notd. Officr Rspons to Rprsntation W writ this submission in rspons to th draft SPD Th guidanc st out within th SPD is consistnt with th xisting in th capacity of th Albrt Association rprsnting planning policy framwork of dsign, hritag and tall building policis, th rsidnts of Gladston Strt and Colnbrook which includs th rlvant savd Southwark Plan policis, Cor Strt within th Wst Squar Consrvation Ara. Our Stratgy Policy 12, th rlvant policis of th London Plan and th main concrns rlat to:- Th dficincis, NPPF. Th guidanc proposd falls within th rmit of an SPD. It is inconsistncis and contradictions of this SPD with not an AAP and dos not propos nw policy for th ara. Th adoptd National, Rgional, Local plans and policis approach is supportd by our vidnc bas including th Blackfriars Th us of this SPD as a wrappr to introduc by Road Urban Dsign Study which has bn prpard in accordanc stalth nw policy for tall buildings including a 70m with CABE and English Hritag Guidanc on Tall Buildings, hight critrion at St Gorgs Circus / Blackfriars Road In light of consultation rsponss and to add clarity to th guidanc South without following a formal adoption procss, rlating to St Gorg s Circus in SPD 5, th SPD has bn updatd to which includs clarify that a tall building could provid a focal point at th southrn nd of Blackfriars Road up to 70m. A tall building should also sustain, nhanc or bttr rval th local hritag assts. W contnd that th London Borough of Southwark (LBS) falls short of its obligation undr NPPF and its own adoptd policis in attmpting to lvat an SPD as a vhicl to introduc nw guidanc as if it was proposd policy, (namly for tall buildings 30-70M hight) and to promot Blackfriars South and St Gorgs Circus as suitabl dsignatd locations capabl of promoting tall building of 70m in hight, in contradiction of National, Rgional and Local adoptd policy, and in th absnc of an accptabl vidnc bas. An SPD is not a valid instrumnt for LBS to introduc nw policy in isolation. Thr is howvr an obligation for an SPD to b consistnt with, and subsrvint to, adoptd National, Rgional and Local Th guidanc st out within th SPD is consistnt with th xisting planning policy framwork of dsign, hritag and tall building policis, which includs th rlvant savd Southwark Plan policis, Cor Stratgy Policy SP12, th rlvant policis of th London Plan and th NPPF. Th guidanc falls within th rmit of an SPD. It is not an AAP and dos not propos nw policy for th ara. Th approach is supportd by our vidnc bas including th Blackfriars Road Urban Dsign Study which has bn prpard in accordanc with CABE and English Hritag Guidanc on Tall Buildings, In light of consultation rsponss and to add clarity to th guidanc rlating to St Gorg s Circus in SPD 5, th SPD has bn updatd to clarify that a tall building could provid a focal point at th southrn nd of Blackfriars Road up to 70m. A tall building should also sustain, nhanc or bttr rval th local hritag assts.

263 Rp Obj Rf Rf Nam 769 Garth Parry Albrt Associ ation Dtails of Rprsntation adoptd policis and in turn for ths documnts to support th vidnc bas for an SPD. Officr Rspons to Rprsntation Sction 38(6) of th Town and Country Planning Act is Th SPD accords with th rquirmnts of th Town and Country clar that dvlopmnt should b dtrmind against Planning (Local Planning) (England) Rgulations It is consistnt currnt adoptd dvlopmnt plans unlss matrial with and not in conflict with th adoptd dvlopmnt plan and th considration (appropriat tsts) suggsts othrwis. NPPF. Th SPD sts out that it provids furthr guidanc to xisting LBS is dficint in following a formal adoption procss planning policis in th dvlopmnt plan: th London Plan, Cor for this SPD; thr is no clar mthodology nor Stratgy and savd Southwark Plan. It dos not rpat borough wid vidnc bas to provid an appropriat tst of its policis and th SPD must b rad alongsid othr planning assumptions. Its poor cross rfrncing to adoptd documnts. policy is insufficint to dmonstrat how it would tst its approach. NPPF is clar in nsuring that Planning Authoritis gt th right dvlopmnts in th right placs and imposs an obligation on LBS to dmonstrat, through National, Rgional and Local policy, th likly impact on th immdiat surroundings and th widr nvironmnt. LBS hav bn inconsistnt and dficint in rspct of this SPD in th following adoptd policy and vidnc bas:- National Policy Town and Country Planning Act -38(6) NPPF 2012 Part 12: Consrving and Enhancing th Historic Environmnt Sctions: 126, , 137,141, and 169 Planning policy guidanc not 13 (PPG13) Rgional Policy London Plan 2011 Chaptr 7: London's Living Placs and Spacs Policis 7.4. A, 7.4.B (a, c, d, ), 7.6.A, B (b, d), 7.7. A, C (b, c, d), D (b), E, 7.8.D, 7.9.B Local Plan Southward s Cor Stratgy 2011 Policis 4.16, 5.114, Figur 12 Savd Southwark Plan Policis 2013 Policis 3.11(iii), 3.12(i,ii,iii), 3.15, 3.18(i,ii,iii,iv), 3.20(i,ii,iv,v), 3.22 CDD2 Banksid, Borough and London Bridg Stag 1 Tall Building Study 2010, Elphant and Castl SPD/OAPF 2012 St Gorg's Circus and Erlang Hous ar within this SPD/OAPF's Entrpris Quartr. Policis 2.3.6, 3.2.9, , 16, SPDs 16, 17 and 51 St Gorg's Circus CAA 2005 Draft Wst Squar

264 Rp Obj Rf Rf Nam 769 Garth Parry Albrt Associ ation Dtails of Rprsntation Consrvation Ara Appraisal Policy 9 Policy 12.4 (should th nw guidanc apply to th Consrvation Ara) Banksid, Borough and London Bridg Charactri Study 2013 Sctions 3.2.4, 6, 8, 9 and 10. Draft Banksid, Borough and London Bridg SPD/OAPF 2010 Policis 3.1, 3.2, , 12 Officr Rspons to Rprsntation Conflicts btwn adoptd Cor Stratgy CDD2 Th guidanc st out within th SPD is consistnt with th xisting Banksid Borough and London Bridg Opportunity planning policy framwork of dsign, hritag and tall building policis, Ara: Stag1 Tall Building Rsarch Papr March which includs th rlvant savd Southwark Plan policis, Cor 2010 and th Draft Blackfriars Road Supplmntary Stratgy Policy 12, th rlvant policis of th London Plan and th Planning Documnt. CDD2 adoptd only thr yars NPPF. Th guidanc proposd falls within th rmit of an SPD. It is ago (2010), sts out th approach and analysis to not an AAP and dos not propos nw policy for th ara. Th stablish suitabl locations for tall buildings in th approach is supportd by our vidnc bas including th Blackfriars Banksid, Borough and London Bridg (BBLB) Road Urban Dsign Study which has bn prpard in accordanc Opportunity Ara. It sts out how it supports th Cor with CABE and English Hritag Guidanc on Tall Buildings, Stratgy (CDCS1) and th mthodology for th study In light of consultation rsponss and to add clarity to th guidanc (in accordanc with CABE and English Hritag rlating to St Gorg s Circus in SPD 5, th SPD has bn updatd to guidanc [CDN25]) which sts out critria which it thn clarify that a tall building could provid a focal point at th southrn invstigats, namly :- Evaluation of Historic Contxt nd of Blackfriars Road up to 70m. A tall building should also sustain, Evaluation of th Local Charactr Evaluation of th nhanc or bttr rval th local hritag assts. Urban Dsign Opportunitis Indntify suitabl locations for tall buildings Draft Blackfriars Road Supplmntary Planning Documnt- SPD4 Built form and Hritag is in immdiat conflict with SPD5 Building Hights. It maks no rfrnc to how it rlats to adoptd policy, (including CDD 2); mthodology, vidnc bas and tst. It dos, howvr, introduc nw policy for a tall building of up to 70m in hight at St Gorgs Circus without making rfrnc to how this vision has volvd and what stps it has takn to dmonstrat how it has arrivd at this proposition. It is thrfor in dirct conflict with CDD2. LBS is dficint in by-passing a dvlopmnt plan-ld approach to tall buildings. LBS acknowldgs that this draft SPD should sit alongsid adoptd National Planning Policy Framwork NPPF, London

265 Rp Obj Rf Rf Nam 769 Garth Parry Albrt Associ ation Dtails of Rprsntation Plan, Cor Stratgy. Yt it is dficint and in dirct conflict with th Framwork through its attmpts to dmonstrat th suitability of spcific locations for Tall Buildings without any vidnc bas. It is also in conflict in proposing to rplac, at som point in th futur, th adoptd local plan and Cor Stratgy in ordr to facilitat this vision. In this SPD LBS hav not idntifid within th local dvlopmnt framwork, in advanc of spcific proposals, th spatial, scal and quality rquirmnts as st out in CDD2. Th intnt of a dvlopmnt plan-ld approach is to nabl propr public consultation at th plan-making stag on th fundamntal qustions of principl and dsign, including appropriat considration of th historic nvironmnt to rduc th scop for unncssary, spculativ applications in th wrong placs. A 70m in hight tall building at St Gorgs Circus would b a such a spculativ application in th wrong plac. LBS ar attmpting to circumnavigat this procss in an attmpt to rush through this dficint SPD to justify Barratt Homs spculativ application for a 70m tall building at St Gorgs Circus. Th rlationship to contxt, including natural topography, scal, hight, urban grain, strtscap and built form, opn spacs, rivrs and watrways, important viws, prospcts and panoramas, and th ffct on th skylin ar all missing from this SPD. Conflicts btwn NPPF 2012 Part 12: Consrving and Enhancing th Historic Environmnt, Sctions : 126, , 137,141, and 169 and th Draft Blackfriars Road Supplmntary Planning Documnt,SPD 4 and SPD5 In promoting St Gorgs Circus as a suitabl location for tall buildings LBS, in its drafting of this SPD, has falln short of its obligations undr NPPF sction 12. Consrving and nhancing th historic nvironmnt :- (126) Local planning Officr Rspons to Rprsntation Th guidanc st out within th SPD is consistnt and rad in conjunction with th xisting planning policy framwork of dsign, hritag and tall building policis, which includs th rlvant savd Southwark Plan policis, Cor Stratgy Policy 12, th rlvant policis of th London Plan and th NPPF. Th guidanc proposd falls within th rmit of an SPD. It is not an AAP and dos not propos nw policy for th ara. Th approach is supportd by our vidnc bas including th Blackfriars Road Urban Dsign Study which has bn prpard in accordanc with CABE and English Hritag Guidanc

266 Rp Obj Rf Rf Nam Dtails of Rprsntation Officr Rspons to Rprsntation authoritis hav an obligation to st out in thir Local on Tall Buildings, In light of consultation rsponss and to add Plan a positiv stratgy for th consrvation and clarity to th guidanc rlating to St Gorg s Circus in SPD 5, th njoymnt of th historic nvironmnt. This SPD SPD has bn updatd to clarify that a tall building could provid a attmpts to dnigrat this significanc through th focal point at th southrn nd of Blackfriars Road up to 70m. A tall convnint drawing of th boundaris to suit th building should also sustain, nhanc or bttr rval th local purpos of this SPD. Th Wst Squar Consrvation hritag assts. Ara is placd outsid (but in immdiat adjacncy), rathr that insid, th SPD boundary. No vidnc is supplid to dscrib th significanc of th many hritag assts affctd by th SPD. Thr is no vidnc dmonstrating that St Gorgs Circus is a suitabl location for tall buildings (or to st out what impact a tall building will hav on a prdominantly 3-5 story rsidntial community of a Consrvation Ara. Nor has it adquatly dmonstratd through its policis how th hritag assts hav bn assssd in support of SPD 5, using appropriat xprtis whr ncssary. (133) Whr a proposd dvlopmnt will lad to substantial harm to, or total loss of significanc of, a dsignatd hritag asst, local planning authoritis should rfus consnt, unlss it can b dmonstratd that th substantial harm or loss is ncssary to achiv substantial public bnfits that outwigh that harm or loss, or all of th following apply: th natur of th hritag asst prvnts all rasonabl uss of th sit; and no viabl us of th hritag asst itslf can b found in th mdium trm through appropriat markting that will nabl its consrvation; and consrvation by grant-funding or som form of charitabl or public ownrship is dmonstrably not possibl; and th harm or loss is outwighd by th bnfit of bringing th sit back into us. LBS has not mad any attmpt through this SPD to addrss how it will comply with and addrss ths critria st out in NPPF (134). Whr a dvlopmnt proposal will lad to lss than substantial harm to th

267 Rp Obj Rf Rf Nam Dtails of Rprsntation significanc of a dsignatd hritag asst, this harm should b wighd against th public bnfits of th proposal, including scuring its optimum viabl us. LBS hav bn dficint in dmonstrating through its mthodology and vidnc bas that it addrsss SPD4 in rlation to SPD5. (137) Local planning authoritis should look for opportunitis for nw dvlopmnt within Consrvation Aras and World Hritag Sits and within th stting of hritag assts to nhanc or bttr rval thir significanc. LBS hav bn dficint in dmonstrating nw policy for a 70m tall building undr SPD 5 in th location of St Gorgs Circus bing appropriat in, or prsrving, thos lmnts of th stting that mak a positiv contribution to, or bttr rval, th significanc of th asst. (141) to adquatly mak information about th significanc of th historic nvironmnt, gathrd as part of plan-making or dvlopmnt managmnt, publicly accssibl and undrstood. LBS hav mad no attmpt to comply with this and hav falln short of th standards and mthodology of CDD2 and ar in contradiction with findings of CDD2. (169) Historic Environmnt. In proposing th location of St Gorgs Circus for tall buildings LBS hav not fulfilld thir obligation to adquatly tak into account th vidnc about th historic nvironmnt in th location ara and to us it to assss th significanc of hritag assts and th contribution thy mak to thir nvironmnt. LBS hav spcifically bn dficint in following its obligation to follow its own mthodology st out in CDD2 to dmonstrat th :- Rlationship to th xisting local charactr th xisting and approvd scal of dvlopmnt Evaluation of urban dsign and ara basd studis Othr rsarch and vidnc prpard for policy documnts Charactr Ara appraisals Officr Rspons to Rprsntation

268 Rp Obj Rf Rf Nam 769 Garth Parry Albrt Associ ation Dtails of Rprsntation Officr Rspons to Rprsntation Evaluation of historic contxt and Stting and viws of Th guidanc st out within th SPD is consistnt and rad in Consrvation Aras - CDD Consrvation Aras conjunction with th xisting planning policy framwork of dsign, Th proposd SPD maks no rfrnc to Evaluation hritag and tall building policis, which includs th rlvant savd of Historic Contxt but is in conflict with CDD2:- Th Southwark Plan policis, Cor Stratgy Policy 12, th rlvant policis charactr of southrn Blackfriars Road as a mainly of th London Plan and th NPPF. Th guidanc proposd falls within low-ris ara with many historic listd and non-listd th rmit of an SPD. Th approach is supportd by our vidnc bas buildings including 34 listd 3-5 story buildings in th including th Blackfriars Road Urban Dsign Study which has bn St Gorgs Consrvation Ara, and svral rsidntial prpard in accordanc with CABE and English Hritag Guidanc communitis including th grad 2 listd Gladston on Tall Buildings, In light of consultation rsponss and to add strt and Colnbrook strt within th Wst Squar clarity to th guidanc rlating to St Gorg s Circus in SPD 5, th Consrvation Ara. It is compltly diffrnt from that SPD has bn updatd to clarify that a tall building could provid a north of Th Cut/Union Strt. In this SPD thr is a focal point at th southrn nd of Blackfriars Road up to 70m. A tall noticabl absnc of considration of th historic building should also sustain, nhanc or bttr rval th local contxt of th immdiat consrvation aras. NPPF hritag assts. Th impact on hritag assts would b assssd at (12) and Local Policy 3.16,3.17,3.18 is spcific in planning application stag. guidanc on considration of hritag assts and obligations. Th authoritis must idntify and considr local hritag assts and schduld monumnts whn considring th appropriatnss for dvlopmnt (in th cas of this draft SPD, th suitability of a 70m tall building at St Gorgs Circus). Thr is no mntion of ky historic listd buildings or monumnts, no assssmnt of spcific important local viws and stting and viws of schduld monumnts. It is xtraordinary that th significanc of th hritag asst of th major junction at St Gorgs Circus, namly th nationally important Grad II* Oblisk and th widr stting of th consrvation aras of St Gorgs Circus and Wst Squar and th 4-5 story Pabody and Wbr Row, ar not adquatly considrd or fatur in any vidnc bas ovr a priod of tim whn thr hav now bn svral succssiv documnts producd on tall buildings. LBS is dficint in automatically introducing nw policy through this SPD with an assumption that a tall building in th location of Blackfriars South St Gorgs Circus is suitabl without

269 Rp Obj Rf Rf Nam Dtails of Rprsntation having undrtakn th ncssary assssmnt to dmonstrat that this location, in its proximity to Wst Squar and St Gorg's Consrvation aras, would b snsitiv or appropriat. In dsignating this location as a potntial sit for tall buildings it has not adquatly considrd or dmonstratd th suitability. Whr is th vidnc bas to dmonstrat that a 70m tall building in th location of St Gorgs Circus is appropriat? LBS has not followd or adquatly considrd that a tall building should prsrv or nhanc th historic charactr stting and apparanc of buildings or aras of historical or architctural significanc if it is to b prmittd. Undr CDD LBS ar suggsting that th impact of buildings locatd outsid but clos to consrvation aras b considrd in rlation to any rlvant consrvation ara appraisal. Th SPD and CDD2 mak rfrnc to having compltd consrvation ara appraisals as rlvant documnts to rinforc th SPD. St Gorgs Circus 2005 pr dats cor stratgy, tall buildings studis, and maks no rfrnc to how to dal with tall buildings Th Wst Squar appraisal similarly dos not cross rfrnc any policy rlating to tall buildings or inform how it anticipats th critria to asss how it would dal with th suitability of proposd dsignd sits for dvlopmnt LBS in th drawing of boundaris of this SPD hav dlibratly xcludd Wst Squar Consrvation Ara and provid scant acknowldgmnt of St Gorg s consrvation ara in an attmpt to falsly validat th suitability of a 70m in hight tall building at St Gorg s circus. LBS is dficint in highlighting th suitability of this vry snsitiv location immdiatly within St Gorgs Circus consrvation ara and Wst Squar which is a contiguous arly Victorian rsidntial community of 3-4 storys. LBS has not followd National Rgional or its Officr Rspons to Rprsntation

270 Rp Obj Rf Rf Nam 769 Garth Parry Albrt Associ ation 769 Garth Parry Albrt Associ ation Dtails of Rprsntation own adoptd and Local policy mthodology to adquatly dmonstrat that a tall building in this immdiat vicinity will not hav a harmful and ngativ impact on th xisting rsidntial community, local charactr, scal and hight of dvlopmnt. Thr is an insufficint lvl of analysis, consultation and vidnc bas to dmonstrat that a 70m tall building in this location dos not hav a harmful ffct on th historic scal of largly 3-4 story arly Victorian houss of a rsidntial community, nor vidnc to dmonstrat that th xisting charactr and stting has adquatly bn takn into account. Th SPD nw guidanc fails to rcogniz th distinctiv charactr of southrn Blackfriars Road as a mainly low-ris ara with many historic listd and non listd buildings. Th Circus is dscribd only as a 'main junction', compltly ignoring its historical significanc as th most important surviving xampl of Gorgian town planning in South London, gracd by 34 listd buildings including th nationally important Grad II* Oblisk Officr Rspons to Rprsntation Charactr Aras Whilst th SPD maks rfrnc to Th approach is supportd by our vidnc bas including th CDD2 Cor Stratgy, (which in turn rfrncs CDD32 Blackfriars Road Urban Dsign Study which has bn prpard in Blackfriars Road Charactr Ara Appraisal, Wst accordanc with CABE and English Hritag Guidanc on Tall Squar Consrvation Ara Appraisal and St Gorgs Buildings, Circus Consrvation Ara appraisal as documnts that hav bn producd) thr is no adquat analysis or rsarch papr to dmonstrat what affct a tall building of 70Mm would hav on th charactr of a largly 3-4 story rsidntial community immdiatly adjacnt and within th consrvation aras. Urban Dsign and Ara basd studis Adoptd cor stratgy CDD2 4.2 summary of study of considrations that would support tall buildings dos not support th proposd location of a tall building Th guidanc st out within th SPD is consistnt and rad in conjunction with th xisting planning policy framwork of dsign, hritag and tall building policis, which includs th rlvant savd Southwark Plan policis, Cor Stratgy Policy 12, th rlvant policis

271 Rp Obj Rf Rf Nam Dtails of Rprsntation Blackfriars Road South / St Gorgs Circus. Th only critrion suggstd by LBS as bing satisfid by Blackfriars South as a suitabl location for a tall building was its proximity to a major junction (St Gorgs Circus). This is dscribd in th SPB, (rronously, as a transport nod. It is not, by any accptd dfinition of th word, a nod ). It has only priphral accss to Southwark station and Watrloo. It concluds that it is not a focus for major rdvlopmnt or activity. It is only srvd by busss, and bus stops ar rmot. LBS, in proposing Blackfriars Road south as a suitabl location for 70M tall building, is in dirct contradiction, and dficint in its findings in rspct of CDD2 and Planning Policy Guidanc not 13 (PPG13). Undr CDD Gatways, Junctions of major roads or points of civic or local significanc Blackfriars South (which St Gorgs Circus sits within) th only urban dsign considration that LBS suggstd would support tall building dvlopmnt was th critrion of th proximity of St Gorgs Circus as a major junction or point of local significanc. Only in th Charactr Ara of Blackfriars North did LBS suggst that th ara would b suitabl to mt th urban dsign critria to support tall building of:- Proximity to public transport Gatway junctions or local significanc Existing and approvd scal of dvlopmnt Vision vibrancy and lif Potntial public ralm and opn spac opportunitis Thr is dirct contradiction of th othr critria of CDD2 btwn CDD2, and th critria of CDD2, and thn CDD2 compard with th Draft Blackfriars Road Supplmntary Planning Documnt, SPD 4 and SPD5 that a tall building of 70M would not b ovrbaring and out of charactr in th location of St Gorgs Circus. It is LBS obligation to dmonstrat that a tall building in this location will Officr Rspons to Rprsntation of th London Plan and th NPPF. Th approach is supportd by our vidnc bas including th Blackfriars Road Urban Dsign Study which has bn prpard in accordanc with CABE and English Hritag Guidanc on Tall Buildings, 2007.

272 Rp Obj Rf Rf Nam 769 Garth Parry Albrt Associ ation Dtails of Rprsntation not dominat. It has not don so, nor has it offrd an vidnc bas. It rmains unprovn and it is an abdication of LBS s obligations not to dal with this suitability and tst at a cor stratgy lvl, but instad to rly on a dvlopr to dmonstrat it at a planning application stag of th procss. Whilst th draft documnt sts out th assssmnt critria that a tall building proposal would hav to satisfy in th vnt of a planning application, LBS ignors complianc with adoptd policy in favour of proposing nw policy for spcific hights 70M, stting spcific hights and locations. Whilst LBS will argu that th spcific location and hight of a tall building can only b idntifid at planning application stag, th failur to catgorically dmonstrat th adquacy of th dsignation of tall building undr urban dsign considrations suggsts that th dsignation of this location as suitabl for tall buildings (and indd this SPD) is prmatur and th critria not adquat without furthr tst and vidnc bas. For instanc:- sun path and shading analysis th absnc of massing scnarios local viws and contxt of hritag assts ovrlooking and massing studis Th original documnt publishd Dc 2009 Figur 11 and 12) indicats no consntd tall building schms around th Southrn nd of Blackfriars road. Within th tim of CDD2 bcoming an adoptd documnt and this draft SPD, th Strada building at Elphant and Castl was awardd th carbuncl award and Blackfriars has a furthr nomination pnding this yar. Officr Rspons to Rprsntation Othr issus, Dsignation of sit 43 Th Bakrloo Th approach is supportd by our vidnc bas including th Sidings for Dvlopmnt Us Any dvlopmnt on this Blackfriars Road Urban Dsign Study which has bn prpard in sit will intrfr with long viws into th Wst Squar accordanc with CABE and English Hritag Guidanc on Tall Consrvation Ara, valud by Southwark Planning. Buildings, Th study updats th tsting from th prvious What considration has bn givn to ths in th urban dsign background paprs in light of guidanc st out in th prparation of this SPD? What is th vidnc to NPPF, th London Plan that was adoptd aftr th Cor Stratgy,

273 Rp Obj Rf Rf Nam Dtails of Rprsntation support its suitability as a dvlopmnt sit as opposd to ducational, opn spac or othr us? Undr th Elphant & Castl Entrpris Quartr SPD 2012 LBS was obligd to hav consultd with TfL. Undr th Localism Act consults ar duty bound to co-oprat. LBS has an obligation to put in th public domain th outcom of thir rspons. This is also rlvant to this currnt draft SPD as vidnc bas to dmonstrat th suitability of this sit for dvlopmnt ovr an xisting and activ London Undrground siding. Whr may w s TfL s rspons? Any building on this sit will advrsly affct th stting of hritag assts. Th Elphant & Castl Entrpris Ara SPD mntiond a landmark building. W find rfrnc to any such building on this sit without vidnc bas or furthr mthodology through a dvlopmnt plan-ld approach dply concrning givn th proximity not only to our own listd houss but also th listd oblisk, St Gorg s RC Cathdral and Imprial War Musum, th lattr two bing th landmark buildings in this location. Officr Rspons to Rprsntation schms that alrady hav bn consntd within th ara and xisting dvlopmnt prssur that could lad to picmal dvlopmnt within th ara. Th TfL Bakrloo sidings sit (Sit 43 in Figur 5/Tabl 1 in th draft SPD, but r-numbrd as Sit 47 in Figur 6/Tabl1 in th updatd SPD) has bn includd as a potntial dvlopmnt sit, du to its rcognisabl dvlopmnt potntial. Any dvlopmnt at th sit would b assssd and dtrmind at th planning application stag, taking into account local contxt, which includs th local hritag assts. Th SPD dos not dsignat proposals sits or provid sit spcific guidanc, as this would byond th scop of th SPD. It dos idntify potntial dvlopmnt sits which ar illustrativ of th hug opportunity for chang within th ara and th nd for a cohrnt framwork. Th SPD has also bn updatd to clarify that th list of sits is not xhaustiv and othr sits may com forward for dvlopmnt. Som of th sits will b compltly rdvlopd, whilst othr sits may xprinc lss chang such as rfurbishmnt or improvmnts to th xisting buildings or surroundings. TfL, GLA and Ntwork Rail wr all consultd as part of th consultation procss. Th Blackfriars Road SPD consultation rport summariss all th rsponss rcivd and changs subsquntly mad to th SPD. Th full rprsntations rcivd from ths bodis and th council s rspons to thm is includd within Appndix J of th Blackfriars Road SPD consultation rport. Th Elphant and Castl SPD was adoptd on 20 March 2012 and rplacs th Elphant and Castl Entrpris Quartr SPD (2008) and th Walworth Road SPD (2008). Th Blackfriars Road SPD is consistnt with th adoptd Elphant and Castl SPD (2012) Garth Parry Albrt This SPD is dficint in following NPPF, rgional and Th SPD sts out that it provids furthr guidanc to xisting planning

274 Rp Obj Rf Rf Nam 7 Associ ation Dtails of Rprsntation local policy and dmonstrating a mthodology and vidnc bas to show how this proposd documnt has volvd or how it adquatly complis with its own adoptd policis. It attmpts to introduc nw policy for tall buildings hight critria which immdiatly contradicts adoptd policy including CDD2. LBS ar dficint in this SPD in putting forward inadquat documnt which:- no foundation against adoptd policis which contradicts adoptd cor stratgy fails to st out its proposals and mthodology for vidnc bas fails to st out how it complis and tsts adoptd policis through a dvlopmnt plan lad procss has not incorporatd maningful and structurd consultation with outputs that tst critria against adoptd policy is in contradiction to NPPF and adoptd policy It is quit clar that this SPD should not go forward for adoption until LBS has dmonstratd how it addrsss th conflicts of its proposals in this SPD with Town and Country Planning Act 38(6), NPPF, adoptd Rgional and Local plans, how th documnt has volvd and how consultation through a clar mthodology that follows a dvlopmnt lad plan lad procss has bn incorporatd and tstd. This is a dficint supplmntary planning documnt which is fundamntally at odds with NPPF guidlins which in turn is to nsur LBS avoid attmpts for spculativ dvlopmnt of tall buildings in th wrong placs. LBS ar hoping to hastily rush this SPD through to adoption, without adquat approach which should at last involv an Ara Action Plan, so as to provid th principal for such a spculativ dvlopmnt proposal namly Barratt Homs tall building at St Gorgs circus. Having rviwd prcdnt, if this SPD is takn forward and approvd by cabint, w will considr th option of a Judicial Rviw. Officr Rspons to Rprsntation policis in th Cor Stratgy and savd Southwark Plan. It dos not rpat borough wid policis and th SPD must b rad alongsid othr planning documnts. Th SPD guidanc is consistnt with that in th NPPF and th dvlopmnt plan. Policis in th dvlopmnt plan ar vidnc basd with many diffrnt vidnc documnts informing thir prparation. Furthr information is st out on th council's wbsit. Much of this sam vidnc has informd th prparation of th Blackfriars Road SPD. Furthr vidnc and information has bn prpard sinc th adoption of th most rcnt dvlopmnt plan documnt which dirctly rlat to Blackfriars Road. This includs th Banksid, Borough and London Bridg Charactri Study (2013), th Blackfriars Road Urban Dsign Study (2014) th Blackfriars Road SPD Businss and Rtail Background Papr (2014). Furthrmor, mor information on documnts which hav informd th prparation of th SPD is st out within th updatd Blackfriars Road SPD sustainability appraisal, spcifically undr th appndix 2 on rlvant plans and policis.

275 Rp Obj Rf Rf Nam Dtails of Rprsntation Cathrin Hop I objct strongly to th SPD in its prsnt form bing 8 1 put forward for formal adoption by th Southwark Cabint. It rprsnts a flawd unrprsntativ viw and contains contradictions and inconsistncis. Rathr than dtailing all th contntious issus lin by lin, I am rstricting my obsrvations hr to thos which ar of particular prsonal concrn. From my standpoint, having livd in Southwark vry yar of my marrid lif sinc Dcmbr 1972, and walkd to work up Blackfriars Road for many of thos yars, I find thr ar thr particularly objctionabl aspcts of th vision st out in th SPD. On is th assrtion that th framwork and dtaild guidanc containd in this documnt ar what will mak th road a dstination whr popl want to liv, work and visit (ignoring th fact that w alrady do). Plnty of fin sntimnts ar xprssd, but th dtaild contnts pay at bst lip srvic to considration of what popl living (and working around, and visiting), th south nd of th road actually might want. Officr Rspons to Rprsntation Th SPD is intndd to bnfit a wid rang of groups including xisting and nw rsidnts. Wording has bn addd to th vision to mak it clarr that th majority of chang will tak plac on Blackfriars Road. Th SPD sks to mt th nds of rsidnts whilst also managing th prssur for nw dvlopmnt. Th SPD has bn updatd to mak it clarr that th mrging vision and th SPD sks to nsur that dvlopmnt mts th nds of xisting and nw rsidnts whilst also attracting nw dvlopmnt. Rsidnts will bnfit from th incras rang of uss including mor shops, srvics and businsss along th Blackfriars Road Cathrin Hop Th Cor Stratgy focusd primarily on th potntial of Th whol of th Blackfriars Road SPD boundary lis within 9 1 th northrn nd and that town cntr opportunity opportunity ara boundaris: th majority within th Banksid, ara. By th tim th road rachs St Gorg's Circus, Borough and London Bridg Opportunity Ara, and a small part of th it is no longr running through an opportunity ara, but southrn part of Blackfriars Road and around St Gorg's Circus is th Oblisk (listd) marks its nd and th ntry to th within th Elphant and Castl Opportunity Ara. Th SPD cannot Elphant and Castl town cntr ara. Th vision allocat proposals sits. Th figur and tabl within th SPD shows taks insufficint account of th variations in potntial dvlopmnt sits and wording has bn addd to th SPD nighbourhoods along th lngth of th road, which to mak it clar that ths ar just potntial dvlopmnt sits and shap its charactr. Thr ar plans for shop that th list is not xhaustiv. Land uss on spcific sits will b frontags and offics. Whr though ar proposals for lookd at through th prparation of th Nw Southwark Plan and will dsignatd sits for th provision of affordabl vntually b adoptd on th Adoptd Policis Map and so th SPD housing? Instad of dtailing any such idas, w fac dos not dsignat spcific sits for a spcific typ of us such as Scoping Opinion applications from dvloprs clarly housing. Existing borough wid affordabl housing policis, as st out confidnt that high ris/high dnsity flats will b in th Cor Stratgy and savd Southwark Plan will continu to b wlcomd by th Borough plannrs. (Dja vu?). usd to dtrmin applications for rsidntial dvlopmnt.

276 Rp Obj Rf Rf Nam Dtails of Rprsntation Cathrin Hop This lads m to th scond wholly objctionabl 0 1 aspct is th proposal (which has matrialisd out of nowhr but unsurprisingly bn givn crdibility by commrcial dvloprs and ndorsd mdia covrag), namly that thr could/should b high ris buildings in th immdiat vicinity of St Gorg's Circus. (As you will know, in th contxt of th SPD, high ris has a vry spcific dfinition). Th notion that thr could b significant high ris dvlopmnt at th south nd of th road is dvastating. Again thr ar plnty of fin words, but th SPD chooss to ignor inconvnint consquncs of such a chang in policy and thrfor dos not addrss th advrs ffct on th stting of th hritag assts in th immdiat ara such dvlopmnt would caus. This is a hritag stting w hav workd hard to prsrv around th Circus, vn facd with th monstrosity which rplacd th old Ey Hospital. Th car and ffort put into gtting th LSBU's London Road Gorgian trrac back into us would b rducd to bing laughabl instad of laudabl if thr wr to b 70 mtr buildings within a ston's throw of th Oblisk, nxt to th consrvation aras and th listd Pabody Buildings. Th historic pattrn of th Circus itslf alrady constituts a focal point for th gatway to th Elphant and Castl if on is ndd, and a vision incorporating mor public opn spac thr, rathr than mor building, could nhanc this Cathrin Hop Th third objctionabl aspct of th contnts of th 1 1 SPD on which I wish to commnt hr is th proposd dsignation of th Bakrloo sidings as a dvlopmnt sit. It appars that this has bn includd without much thought, without any vidntial considration of contxt, and crtainly without any indication of futur prfrrd usag. Givn its proximity to consrvation aras and hritag sits/buildings, I would hav Officr Rspons to Rprsntation A tall building up to 70m in hight could b appropriat at th southrn nd of Blackfriars Road providd that it complis with th dtaild guidanc outlind in SPD 5 and th currnt dvlopmnt plan that includs th rlvant policis of th savd Southwark Plan (2007), Cor Stratgy (2011), London Plan (2011) and othr planning documnts/guidanc, including th NPPF (2012). Th dvlopmnt plan sts out th policis for tall buildings. Th guidanc in th SPD provids dtail on how to implmnt ths dvlopmnt plan policis spcific to Blackfriars Road. Th approach is supportd by our vidnc bas including th Blackfriars Road Urban Dsign Study which has bn prpard in accordanc with CABE and English Hritag Guidanc on Tall Buildings, In light of consultation rsponss and to add clarity to th guidanc rlating to St Gorg s Circus in SPD 5, th SPD has bn updatd to clarify that a tall building could provid a focal point at th southrn nd of Blackfriars Road up to 70m. A tall building should also sustain, nhanc or bttr rval th local hritag assts. Th TfL Bakrloo sidings sit (Sit 43 in Figur 5/Tabl 1 in th draft SPD, but r-numbrd as Sit 47 in Figur 6/Tabl1 in th updatd SPD) has bn includd as a potntial dvlopmnt sit, du to its rcognisabl dvlopmnt potntial. Any dvlopmnt at th sit would b assssd and dtrmind at th planning application stag, taking into account local contxt, which includs th local hritag assts. Th SPD dos not dsignat proposals sits or provid sit spcific guidanc, as this would byond th scop of th SPD. It dos

277 Rp Obj Rf Rf Nam Dtails of Rprsntation Officr Rspons to Rprsntation xpctd bttr. idntify potntial dvlopmnt sits which ar illustrativ of th hug opportunity for chang within th ara and th nd for a cohrnt framwork. Th SPD has also bn updatd to clarify that th list of sits is not xhaustiv and othr sits may com forward for dvlopmnt. Som of th sits will b compltly rdvlopd, whilst othr sits may xprinc lss chang such as rfurbishmnt or improvmnts to th xisting buildings or surroundings Cathrin Hop Th Cabint should b awar that local rsidnts and Th SPD is bing takn to Cabint for adoption on 10 Dcmbr 2 1 workrs in th Borough want to ngag and b 2013.Th consultation rport is on of th appndics to th Cabint involvd in our Council's plans sinc thy impact on Rport, summarising th consultation on th SPD, th consultation our livs and th quality of our community. This SPD is rsponss, and how ths hav influncd th final SPD. Similarly all on sidd, lacks supporting vidnc and is in th rprsntations rcivd and th officr commnts on ths contradiction to xisting statd policis. It should b rprsntations ar appndicd to th Cabint rport. withdrawn, rathr than continuing to s th light of day in this flawd form, and instad th documnts to which it is subordinat should b rvisd as appropriat aftr du procss Cathrin Hop Th tim and fforts of th Planning Tam would b 3 1 bttr dirctd to consulting on any changs to th Southwark Plan and Cor Stratgy aftr ngaging in a full dbat and discussion, instad of this attmpt to introduc, by a subsidiary documnt, vry matrial rvisions to xisting statd policis by drssing thm up in th guis of a vision. To procd to submit th currnt SPD for formal adoption by Cabint, likly without discussion, givs th imprssion of th Council pandring to commrcial dvloprs without rgard to nhancing Southwark's hritag or to th viws of local rsidnts Lnta Busin ss Cntr W writ on bhalf of Lnta Businss Cntrs to mak rprsntations to th Southwark s Draft Blackfriars Road Supplmntary Planning Documnts (SPD) (Jun 2013). Th aim of this lttr is to outlin our commnts on th issus, vision and objctivs notd within th Draft Blackfriars Road SPD. Our commnts A consultation rport has prpard alongsid th Blackfriars Road SPD. This sts out a summary of th rprsntations rcivd and how w hav takn ths into account in prparing th final vrsion of th SPD. Th appndics also st out all of th rprsntations rcivd and officr commnts on how this commnts hav bn takn into account, and whthr th SPD has bn updatd as a rsult. Th SPD was consultd on in accordanc with th council's Statmnt of Community Involvmnt (SCI) (2008) and xcdd th consultation rquirmnts of both th SCI and th rlvant rgulations. Th consultation rport summariss th consultation carrid out. Th consultation rport and all th rprsntations and officrs rport form appndics to th Cabint rport. Notd.

278 Rp Obj Rf Rf Nam Dtails of Rprsntation principally concrn th Council s approach to th provision of nw businss spac (particularly small and mdium accommodation) and th rgnration of th xisting mploymnt uss. In ordr to undrstand th contxt of our clint s commnts, w hav providd blow a dtaild dscription of th Lnta modl and how thy oprat thir businss. W also highlight blow thir spcific intrsts/aspirations in rlation to thir portfolio within th Blackfriars ara and th widr contxt of Southwark. Lnta Businss Holdings - History and Background Lnta Businss Holdings was first formd by Th London Entrpris Agncy in 1981 as a joint vntur originally st up by Midland Bank, Barclays Bank, BP and Shll to provid small businss units for start-up oprations. Th company was on of th first public/privat partnrships st up to assist start up businsss in London. Th company was purchasd by CP Holdings, a multinational holding company basd in Watford, mploying approximatly 7,000 popl. CP Holdings acquird th company in ordr to build on th xisting portfolio and dvlop th srvicd offic businss. Lnta is also a foundr mmbr of th BCA (Businss Cntrs Association) and mploys ovr 60 popl. In th last 33 yars Lnta has succssfully providd srvic offics for start-ups, individuals and for small and larg businsss. It is wll rgardd srvicd offic providr that gnrats loyalty from its clints and provids spac and th opportunity for local businss to thriv. Lnta currntly owns and manags 23 cntrs largly in London with a combind ara of approximatly 450,000sq ft. Occupirs ar a mixtur of traditional tnants on commrcial lass and licnss on flxibl agrmnts. Thr ar currntly 500 licnss in th buildings mploying 3,000 popl. Th company Officr Rspons to Rprsntation

279 Rp Obj Rf Rf Nam Dtails of Rprsntation provids a rang of srvics within th offic cntrs and Licncs can run for a minimum priod of on month and provids total flxibility. Th avrag stay is approximatly on yar although Lnta do hav a numbr of clints that hav bn with thm for mor thn 20 yars. Lnta has purchasd svn buildings in London in th Last two yars and plans to incras its portfolio significantly ovr th nxt fiv yars. It has adoptd a stratgy which targts mid-town London locations clos to transport hubs. Th company will sk to xpand by procuring and upgrading xisting mpty spac as wll as rgnrating xisting sits in thir ownrship to crat valu which will b pumpd back into th ara whr thy hav drivd th bnfit. Lnta in Southwark Proprtis Ownd In Southwark Lnta has providd srvicd offics and rsidntial accommodation in th Borough for mor than 24 yars. Lnta owns and manags 6 businss cntrs in Southwark providing businss units for 130 companis and ovr 1000 mploys. Blow w st out th proprtis ownd by Lnta within Southwark. Officially opnd in 1989 by Margart Thatchr th Blackfriars Foundry saw th transformation of a drlict building into 41 modrn units with a furthr 15 units at th Foundry Annx. Th buildings wr mad availabl to Lnta by th City of London Corporation as part of its 800th annivrsary clbrations Lnta convrtd th formr Archbishop Tmpl School, donatd by th Innr London Education Authority, into th Chandlry with 46 businss units. In 2005 Lnta undrtook rdvlopmnt of th Chandlry turning it into a mixd us dvlopmnt slling 13 flats (including liv/work) and som commrcial units. Also in 2005 Lnt bought Dlta Hous on Borough High Strt. This proprty is listd and has bn subdividd intrnally to provid Officr Rspons to Rprsntation

280 Rp Obj Rf Rf Nam Dtails of Rprsntation small offic units. In 2011 Lnta bought Tr Tuns Hous also on Borough High Strt. Lnta turnd this into its innovativ Co-Work concpt. In January 2012 Lnta compltd on th purchas of Watrloo Hous and has compltd th rfurbishmnt and ltting of this building. As you can s Lnts hav a long standing prsnc in th borough and has and continus to contribut to th local conomy though th provision of nw businss spacs. Lnta is sking to us thir skills and xprinc to incras th numbr of businss cntrs that thy own and manag in Southwark. By providing additional srvicd offics Lnta bliv that thr is scop to attract businss back into th ara by incrasing th supply of additional businss cntrs within th borough. Lnta rcognis that this approach will support th widr rgnration of Southwark by providing a sustainabl balanc btwn conomic and rsidntially ld rgnration. Lnta ar at prsnt invstigating opportunitis to improv th provision of businss accommodation within Southwark and ar currntly looking at th Southwark portfolio with a viw to rdvloping, xtnding and rfurbishing thir proprtis to provid additional offic spac in particular thir proprtis at Blackfriars Road and th Foundry Annx Building locatd at Glasshill Strt. At this stag no firm proposals hav bn dvlopd howvr Lnta is kn to progrss th improvmnt. Furthr dtail on ths sits will b providd as part of furthr discussions with th Council. Lnta Promoting and supporting nw small and mdium businsss. Lnta sks to provid wll managd, modrn, flxibl B1 spac, offrd with flxibl las arrangmnts. Lnta provid spac that is flxibl/adaptabl, incorporat communal aras (i.. café, brak-out spac tc), modrn communal mting Officr Rspons to Rprsntation

281 Rp Obj Rf Rf Nam Dtails of Rprsntation rooms, a high profil rcption ara, good IT links, data cabling, xcllnt sit scurity, modrn srvicing facilitis, 24 hour oprational accss tc. Lnta s businss modl is focusd on providing nw accommodation which is spcifically dsignd to promot, support and accommodat nw and xisting small/mdium businsss in London, and whr possibl thy incorporat th following: flxibl and adaptabl nw businss spac is typically dsignd on a flxibl grid arrangmnt to nabl a varity of unit sizs to b achivd. capabl of accommodating a rang of businsss and uss oftn businss cntrs will accommodat a divrs rang of businsss and activitis. providing a rang of srvics/tlcom intrnally within th spac including broadband, tlcommunications, data cabling and utility srvics. providing a high profil rcption ara a front door is important to all Workspac customrs. including communal facilitis for customr us in addition to th main rcption, nw businss cntrs will oftn provid modrn communal mting rooms, a café, toilt facilitis, showr room tc. incorporating nw wast disposal and rcycling facilitis nw tnants ar ncouragd to rcycl wast matrials and adopt a sustainabl working practic; providing comprhnsiv sit scurity. nsuring nw businss spac mts disabld accss rquirmnts. adopting a high quality and distinctiv architctural approach to all nw dvlopmnt. Formulating a positiv Planning Policy Approach In ordr to support th rgnration of xisting mploymnt sits and to promot th provision of additional businss spac. Lnta advocats th adoption of a flxibl policy. In particular, Lnta ar of th viw that nw policy must rcognis that th rnwal/rgnration/improvmnt of xisting Officr Rspons to Rprsntation

282 Rp Obj Rf Rf Nam Lnta Busin ss Cntr Lnta Busin ss Cntr Dtails of Rprsntation businss spac is only likly to b achivabl/viabl if th uplift in businss spac can b achivd via an intgratd mixd-us schm, which incorporats highr valu uss such as rsidntial or rtail tc which can thn act as an nabling dvlopmnt. In trms of rsponding to th Councils Draft Blackfriars Road SPD w mak th following rprsntations: Tabl 1 Potntial dvlopmnt sits should b amndd to includ th Foundry Annx locatd on Wbbr Strt and Glasshill Strt. SPD1 Businss Spac Policis for th safguarding of xisting businss spac ar insufficintly flxibl, potntially contributing to long-trm vacancis and drliction, as wll as limiting opportunitis for rlasing sits to provid for altrnativ uss for which thr ar known nds and dmands. Th policy wording also dos not offr ncouragmnt to mploymnt land to b dvlopd mor fficintly and mor intnsivly, which in crtain circumstancs can crat nw opportunitis for othr bnficial land uss. Policy should a sk to ncourag and support th rationali of xisting businss spac. In particular, thr ar a numbr of smallr sits which ar locatd within rsidntial aras and sparatd from othr commrcial/businss locations. Oftn ths smallr sits provid low quality, infficint spac; which, twinnd with thir location, hamprs thir ffctiv functioning/opration as businss/mploymnt locations. In ths circumstancs, significant bnfits/fficincis could b achivd by Officr Rspons to Rprsntation W hav updatd th figur and tabl. Th SPD dos not dsignat proposals sits or provid sit spcific guidanc, as this would byond th scop of th SPD. It dos idntify potntial dvlopmnt sits which ar illustrativ of th hug opportunity for chang within th ara and th nd for a cohrnt framwork. Th SPD has also bn updatd to clarify that th list of sits is not xhaustiv and othr sits may com forward for dvlopmnt. Som of th sits will b compltly rdvlopd, whilst othr sits may xprinc lss chang such as rfurbishmnt or improvmnts to th xisting buildings or surroundings. Th suggstd changs ar not considrd appropriat for th SPD guidanc. It is important for th SPD guidanc to b rad in conjunction with both adoptd planning policy Th rquirmnt to rtain or rplac xisting businss spac is consistnt with boroughwid policis. Th policy rquirmnt for th rplacmnt of businss floorspac is justifid by th council s vidnc bas which points to th nd to protct and intnsify mploymnt land and businss floorspac ovr th plan priod. Cor Stratgy policy 10 and savd Southwark Plan policy 1.4 rquir applicants to dmonstrat th loss of businss floorspac (B1, B2 and B8) against a rang of xcption critria whr th sit falls within a rang of locations, which includ (amongst othrs) th CAZ. Land outsid ths locations can b rlasd for othr uss. This stratgy nsurs th rtntion of xisting businss floorspac whr this is appropriat, to nsur thr continus to b spac availabl for stablishd businsss to mov into th ara and for start up businsss to stablish thmslvs. Th council considrs that it is rasonabl to xpct applicants to dmonstrat that in th aras whr businss floorspac is protctd that thr is a lack of dmand or viability, or physical and/or nvironmntal constraints which prclud r-provision or an uplift of

283 Rp Obj Rf Rf Nam Dtails of Rprsntation Officr Rspons to Rprsntation supporting/ncouraging th rlocation of xisting mploymnt spac (Southwark Plan Policy 1.4). It is considrd that businss spac onto an largr businss sits within this is consistnt with paragraph 21 and 22 of th NPPF and provids th Borough. This will not only rationalis mploymnt adquat flxibility. W will b considring dvlopmnt sit spac within th Borough, but also provid th allocations through th prparation of th Nw Southwark Plan. Th opportunity to crat businss clustrs which bnfit SPD idntifis possibl dvlopmnt opportunitis, som of which from shard/communal facilitis on a singl sit. This may b complt rdvlopmnt, and som may b mor minor approach would b particularly bnficial for th small changs or improvmnts. businsss - who thriv within largr sits which can succssfully provid a businss community aspct. This approach also allows smallr sits to b rlasd for altrnativ uss (including rsidntial), which can b far bttr rlatd to th nighbouring urban ara. W suggst amndmnts to th currntly draftd policy as follows: SPD 1 Businss Spac Add th following sntnc to bullt point 1 Whr additional offic floor spac has bn providd this can b st asid as a crdit which can b usd in th futur within an agrd tim fram to offst proposals whr thr is a loss of offic accommodation Add th following sntnc to bullt point 2 Whr xcptional circumstancs cannot b dmonstratd and in appropriat locations th rlocation of xisting businss spac onto anothr xisting businss sit (also locatd within th Borough) will b supportd. Futur policy must b sufficintly flxibl to rcognis that in crtain aras and circumstancs that th rduction in offic spac in on location and rdvlopmnt of sits will support th long trm dlivry of businss spac within th Borough. As notd abov, Lnta is invstigating opportunitis to improv th businss accommodation providd at 2 sits within th Borough Blackfriars Road and th Foundry Annx Building locatd at Glasshill Strt. At this stag, no firm proposals hav bn dvlopd. Howvr, Lnta is kn to progrss th improvmnt of ths proprtis through th SPD. It is

284 Rp Obj Rf Rf Nam Dtails of Rprsntation our intntion to provid you with mor dtail on our clint s proposals in rlation to ths two sits as and whn dtaild rgnration proposals com forward. Officr Rspons to Rprsntation Jnna Barry Gnral Th two aspcts of th SPD that w find most A tall building up to 70m in hight could b appropriat at th southrn 7 6 objctionabl ar: 1: Provision for a towr block 70 nd of Blackfriars Road providd that it complis with th dtaild mtrs high at St Gorg s Circus 2: Th dsignation guidanc outlind in SPD 5 and th currnt dvlopmnt plan that of th Bakrloo sidings sit (which is immdiatly includs th rlvant policis of th savd Southwark Plan (2007), bhind Gladston Strt) as a potntial dvlopmnt Cor Stratgy (2011), London Plan (2011) and othr planning sit. Th SPD proposs that Blackfriars Road b documnts/guidanc, including th NPPF (2012). Th dvlopmnt dvlopd solly as a sris of tall buildings with infill plan sts out th policis for tall buildings. Th guidanc in th SPD of significant hight. Whr is th vidnc to support provids dtail on how to implmnt ths dvlopmnt plan policis this vision for th ara rathr than som altrnativ spcific to Blackfriars Road. Th approach is supportd by our dvlopmnt plan? Which othr plans wr vidnc bas including th Blackfriars Road Urban Dsign Study considrd and rjctd? During consultation w hav which has bn prpard in accordanc with CABE and English bn informd that no particular nd us is nvisagd Hritag Guidanc on Tall Buildings, In light of consultation for any of th sits dsignatd for dvlopmnt. Whr rsponss and to add clarity to th guidanc rlating to St Gorg s is th justification for ignoring th suitability of Circus in SPD 5, th SPD has bn updatd to clarify that a tall particular sits of th dsignatd aras for any building could provid a focal point at th southrn nd of Blackfriars particular form of dvlopmnt, givn th snsitiv Road up to 70m. A tall building should also sustain, nhanc or bttr natur of th hritag contxt? It sms clar to us rval th local hritag assts. Th TfL Bakrloo sidings sit (Sit 43 that th rol of th Local Authority in connction with in Figur 5/Tabl 1 in th draft SPD, but r-numbrd as Sit 47 in th SPD is that of a dvlopmnt nablr rathr than a Figur 6/Tabl1 in th updatd SPD) has bn includd as a potntial rgulator. This throws onto th community th dvlopmnt sit, du to its rcognisabl dvlopmnt potntial. Any rsponsibility to act as a rgulator dvlopmnt at th sit would b assssd and dtrmind at th planning application stag, taking into account local contxt, which includs th local hritag assts. Th SPD dos not dsignat proposals sits or provid sit spcific guidanc, as this would byond th scop of th SPD. It dos idntify potntial dvlopmnt sits which ar illustrativ of th hug opportunity for chang within th ara and th nd for a cohrnt framwork. Th SPD has also bn updatd to clarify that th list of sits is not xhaustiv and othr sits may com forward for dvlopmnt. Som of th sits will b compltly rdvlopd, whilst othr sits may xprinc lss chang such as rfurbishmnt or improvmnts to th xisting buildings or surroundings.

285 Rp Obj Rf Rf Nam Dtails of Rprsntation Jnna Barry In including larg aras of land that hav nothing to do 8 6 with Blackfriars Road, Southwark Council will undrmin Nighbourhood Forums (South Bank and Watrloo Nighbourhood Forum and th Banksid Nighbourhood Forum) and th Localism Act Can th council dmonstrat that th SPD will giv a bttr outcom than thos nvisagd by Nighbourhood Forums? Jnna Barry Dvlopmnt Sit 43 Th Bakrloo Sidings Any dvlopmnt on this sit will intrfr with long viws into th Wst Squar Consrvation Ara valud by Southwark Planning. What considration has bn givn to ths in th prparation of this SPD? What is th vidnc to support its suitability as a dvlopmnt sit as opposd to ducational, opn spac or othr us? Undr th Elphant & Castl Entrpris Quartr SPD Southwark should hav consultd TfL. Undr th Localism Act consults ar duty bound to co-oprat so whr may w s TfL s rspons? Any building on this sit will advrsly affct th stting of hritag assts. Th Elphant & Castl Entrpris Ara SPD mntiond a landmark building. W find rfrnc to any such building on this sit dply concrning givn Officr Rspons to Rprsntation An xplanation of th boundary is st out within th SPD. It includs th whol of th Blackfriars Road and som of th surrounding ara. It includs th surrounding ara as th surrounding ara is also likly to s som dvlopmnt and improvmnts, particularly possibl improvmnts to public ralm. Wording has bn addd to th SPD to mak it clarr that th charactr and historic valu of much of th surrounding ara will continu to b protctd and nhancd. It has also bn mad clar that th aras which ar prdominantly housing will mostly continu to b so, with rsidnts bnfitting from th incrasd rang of activitis on th Blackfriars Road. Figur 3 of th SPD illustrats th rlationship btwn diffrnt planning documnts including supplmntary planning documnts and nighbourhood plans. Th SPD has bn updatd to mak it clar th nighbourhood plans ar currntly bing prpard. Onc adoptd a nighbourhood plan will hav mor wight than a SPD in th planning procss as it will form part of th council's dvlopmnt plan. At prsnt thr is no adoptd nighbourhood plan for any of th ara covrd by th Blackfriars Road SPD. Th SPD may nd to b rviwd in th futur if a nighbourhood plan is adoptd for any of th SPD ara. Th Wst Squar consrvation ara is situatd outsid th Blackfriars Road SPD ara. It would still b considrd as a hritag asst in rlation to th guidanc st out in SPD 3, 4 and 5. Any dvlopmnt proposal would b assssd at th planning application stag against th rlvant savd Southwark Plan policis, Cor Stratgy Policy SP12 and th rlvant policis of th London Plan and othr rlvant planning guidanc. Th TfL Bakrloo sidings sit (Sit 43 in Figur 5/Tabl 1 in th draft SPD, but r-numbrd as Sit 47 in Figur 6/Tabl1 in th updatd SPD) has bn includd as a potntial dvlopmnt sit, du to its rcognisabl dvlopmnt potntial. Any dvlopmnt at th sit would b assssd and dtrmind at th planning application stag, taking into account local contxt, which includs th local hritag assts.

286 Rp Obj Rf Rf Nam Dtails of Rprsntation th proximity not only to our own listd houss but also th listd oblisk, St Gorg s RC Cathdral and Imprial War Musum, th lattr two bing th landmark buildings in this location. How ar ths proposals affctd by th Blackfriars Road SPD? Officr Rspons to Rprsntation Th SPD dos not dsignat proposals sits or provid sit spcific guidanc, as this would byond th scop of th SPD. It dos idntify potntial dvlopmnt sits which ar illustrativ of th hug opportunity for chang within th ara and th nd for a cohrnt framwork. Th SPD has also bn updatd to clarify that th list of sits is not xhaustiv and othr sits may com forward for dvlopmnt. Som of th sits will b compltly rdvlopd, whilst othr sits may xprinc lss chang such as rfurbishmnt or improvmnts to th xisting buildings or surroundings. TfL, GLA and Ntwork Rail wr all consultd as part of th consultation procss. Th Blackfriars Road SPD consultation rport summariss all th rsponss rcivd and changs subsquntly mad to th SPD.T h full rprsntations rcivd from ths bodis and th council s rspons to thm is includd within Appndix J of th Blackfriars Road SPD consultation rport Jnna Barry Stratgic viws St Gorg s Circus and Tall Buildings St Gorg s Circus is a fin xampl of Gorgian town planning with its focal point at its cntr, th Grad 2* listd oblisk. SPD 5 Building Hights proposs a tall building of hight up to 70 mtrs should provid a focal point at St Gorg s Circus. This statmnt displays a fundamntal ignoranc of this circus. A tall building will affct th stting of not only th oblisk, an important hritag asst, but also th listd Gorgian trracs in London Road. Plas dmonstrat undr London Plan CDR1 how tall building dvlopmnt, a fundamntal chang in architctur, will not advrsly affct th local Th Elphant and Castl SPD was adoptd on 20 March 2012 and rplacd th Elphant and Castl Entrpris Quartr SPD (2008) and th Walworth Road SPD (2008). Th Blackfriars Road SPD will rplac th Elphant and Castl SPD/OAPF guidanc for th ovrlapping aras. Th SPD has bn updatd to mak this clarr. A tall building up to 70m in hight could b appropriat at th southrn nd of Blackfriars Road providd that it complis with th dtaild guidanc outlind in SPD 5 and th currnt dvlopmnt plan that includs th rlvant policis of th savd Southwark Plan (2007), Cor Stratgy (2011), London Plan (2011) and othr planning documnts/guidanc, including th NPPF (2012). Th dvlopmnt plan sts out th policis for tall buildings. Th guidanc in th SPD provids dtail on how to implmnt ths dvlopmnt plan policis spcific to Blackfriars Road. Th approach is supportd by our vidnc bas including th Blackfriars Road Urban Dsign Study which has bn prpard in accordanc with CABE and English Hritag Guidanc on Tall Buildings, In light of consultation rsponss and to add clarity to th guidanc rlating to St Gorg s

287 Rp Obj Rf Rf Nam Dtails of Rprsntation charactr. Whr is th comprhnsiv urban dsign analysis of th local charactr and historic contxt? (CABE and English Hritag Guidanc on Tall Buildings CDN25) St Gorg s Circus is statd on pag 29 of th SPD to b a transport nod. It cannot, by th accptd dfinition of a transport nod, b so dscribd. Dvlopmnt sits 39, 40, 41 and 43 dirctly affct th Circus and othr hritag assts. Council officrs hav statd that tall buildings at St Gorg s Circus would not b a conflict with th adjoining hritag assts. Whr is th vidnc that this is not a conflict? In dtrmining tall building hight limits within th SPD of 70 mtrs, whr is th assssmnt of thr dimnsional modlling to dtrmin th potntial ffct on th local contxt? (CABE and English Hritag Guidanc on Tall Buildings CDN25) Jnna Barry Why ar hotls bing promotd (SPD 3.10) as viabl us whn Southwark has alrady achivd or is clos to achiving th rquirmnts. Th figurs for hotl rooms in th SPD mak it clar that, of th 2500 bdrooms rquird by th GLA s Hotl Dmand Study 2006 by 2026, all but 75 hav ithr bn built or ar in th piplin. Officr Rspons to Rprsntation Circus in SPD 5, th SPD has bn updatd to clarify that a tall building could provid a focal point at th southrn nd of Blackfriars Road up to 70m. A tall building should also sustain, nhanc or bttr rval th local hritag assts. Th GLA s rprsntation confirms that th Mayor supports th council s approach on tall buildings, but suggsts that th SPD should b mor flxibl in rlation to building hights, and that buildings in th rgion of 70/30m would b appropriat. Th council disagrs with this proposd amndmnt as it could allow buildings that ar gratr than th 70m/30m thrshold, which would b considrd inappropriat basd on our vidnc bas. As such, th council considrs SPD5 to balanc local charactr and dvlopmnt potntial. Th SPD dos not dsignat proposals sits or provid sit spcific guidanc, as this would byond th scop of th SPD. It dos idntify potntial dvlopmnt sits which ar illustrativ of th hug opportunity for chang within th ara and th nd for a cohrnt framwork. Th SPD has also bn updatd to clarify that th list of sits is not xhaustiv and othr sits may com forward for dvlopmnt. Som of th sits will b compltly rdvlopd, whilst othr sits may xprinc lss chang such as rfurbishmnt or improvmnts to th xisting buildings or surroundings. Any dvlopmnt of th potntial dvlopmnt sits would b assssd and dtrmind at th planning application stag, taking into account local contxt, which includs th local hritag assts. Th London Plan sks to achiv 40,000 nt additional hotl bdrooms by 2031.Th stimat of th approximat nt and gross hotl rooms rquird ovr th priod for Southwark, as st out in th GLA s Hotl Dmand Study, is basd on assssmnt of factors including transport links to cntral London and connctions to airports, proximity of tourist attractions/businss locations, cafs and rstaurants in th ara, night tim conomy, cultural facilitis and attractions, and rgnration initiativs and sit availability. Th forcast for Southwark should b tratd as indicativ only, and local circumstancs should also b factord in. It is important to considr that th SPD ara is within th Cntral Activitis Zon, Banksid, Borough and London Bridg Opportunity Ara and part of th Elphant and Castl Opportunity Ara which ar aras promotd in

288 Rp Obj Rf Rf Nam Dtails of Rprsntation Jnna Barry Travl SPD6 givs no spcific information as Blackfriars Road falls undr th jurisdiction of TfL. Undr th Localism Act both TfL and Southwark Council ar duty bound to shar any consultation information rgarding activ travl. What plans hav bn proposd? Jnna Barry Gnral Th documnt rfrs to shops along th whol of Blackfriars Road but maks no rfrnc to a rtail impact study, indicating dmand for ths or th ffct on nighbouring shops. Officr Rspons to Rprsntation th London Plan to accommodat stratgically important hotl provision. Arts, cultural and tourism activitis hav flourishd in Southwark in th last dcad, particularly in th Stratgic Cultural Ara, which is within th CAZ. Banksid, Borough and London Bridg has consquntly xprincd a growth in th numbr of hotls to support this incrasing visitor conomy. SPD2 provids guidanc to support Cor Stratgy policy 10 Jobs and businss which sts out th council will allow th dvlopmnt of hotls within th town cntrs, th stratgic cultural aras, and placs with good accss to public transport srvics, providing that ths do not harm th local charactr. Policy 10 and SPD 2 ar also supplmntd by th savd policy 1.12 of th Southwark Plan which addrsss visitor accommodation. Nw hotl proposals in th ara will b assssd against ths rlvant planning policis and a considration of th impact upon local amnity and th balanc of land uss will also b takn into account. Th txt within SPD 6 has bn updatd to clarify that Blackfriars Road falls undr th jurisdiction of TfL. A consultation rport has bn prpard summarising rsponss to th consultation on th draft Blackfriars Road SPD. All rsponss to th SPD consultation will b publishd on th council's wbsit prior to th SPD bing takn to Cabint for adoption. TfL hav now announcd that TfL ar proposing to introduc a Cycl Suprhighway on Blackfriars Road, with consultation proposd for summr Rsults of this consultation would b shard on TfL's wbsit. Th businss and rtail background vidnc papr sts out furthr dtail to SPD2 and th futur rtail capacity for th Banksid and Borough district town cntr. This dtail has bn rfrncd from th Southwark Rtail Capacity Study. Th study valuats th vitality and viability of th town cntr, in trms of its rtail prformanc and idntifid that th focus should b on continuing to mt th nds of workrs, tourists and visitors. Nw schms will b supportd by an incras in population in th ara, through nw rsidnts, workrs and visitors and ths will com forward on an incrmntal basis Jnna Barry No mntion is mad of nvironmntal impact Ths mattrs would b assssd at th planning application stag

289 Rp Obj Rf Rf Nam Dtails of Rprsntation 4 6 assssmnts, wind and daylight modlling, which ar fundamntal rquirmnts in considring proposals of this natur, particularly considring th difficultis with th Palstra and Walki Talki buildings Jnna Barry Th documnt stats that crim will b rducd yt thr is no rfrnc to xisting or anticipatd crim statistics. Has th Mtropolitan Polic bn consultd? If ths studis hav bn obtaind and modlling carrid out thn ths should b in th public domain and not withhld. Plas advis whr ths may b sn Jnna Barry Why has Wst Squar Consrvation Ara not bn 6 6 mntiond in SPD4 and SPD5? Th tall buildings proposd affct th stting of this Consrvation Ara and its Listd Buildings. Officr Rspons to Rprsntation through th rlvant savd Southwark Plan policis, Cor Stratgy Policy SP12 and th rlvant policis of th London Plan and planning rgulations. Bullt-point 14 of SPD 5 sts out furthr guidanc rgarding microclimat. Th Mtropolitan Polic ar on th planning policy's mailing list and wr consultd as part of th consultation on th Blackfriars Road SPD. Th sustainability appraisal and th sustainability appraisal scoping rport which both informd th prparation of th SPD provid furthr information on th possibl impact of th SPD on crim. Th sustainability appraisal assssd th impact of th SPD guidanc on sustainability objctiv SDO4: To rduc th incidnc of crim and far of crim, and finds that th SPD is likly to ovrall hav a positiv impact. Th sustainability scoping rport also provids furthr information stting out information on th Indics of Multipl Dprivation which includs crim as on of its six indicators. Both documnts ar availabl to viw on th council's wb sit at: and Th Wst Squar consrvation ara is situatd outsid th Blackfriars Road SPD ara. It would still b considrd as a hritag asst in rlation to th guidanc st out in SPD 3, 4 and Jnna Barry This SPD has 1 Businss Spac, 2 Mixd Us Town Th SPD sts out that it provids furthr guidanc to xisting planning 7 6 Cntr, 3 Public Ralm and Opn Spac, 4 Built Form policis in th Cor Stratgy and savd Southwark Plan. It dos not and Hritag, 5 Building Hights and 6 Activ Travl. It rpat borough wid policis and th SPD must b rad alongsid dos not hav a Stratgy or Guidanc for Housing. othr planning documnts. Housing is not givn its own sction within Why not? th SPD bcaus th borough-wid housing policis and guidanc alrady covr housing adquatly. This includs policis in th Cor Stratgy and savd Southwark Plan and SPDs on affordabl housing and rsidntial dsign standards. Th vision alrady rfrs to housing dvlopmnt. Housing will b ncouragd on appropriat sits. In ordr to mak this clarr, w

290 Rp Obj Rf Rf Nam Dtails of Rprsntation Officr Rspons to Rprsntation hav updatd SPD 2: Mixd us town cntr to includ rsidntial dvlopmnt as on of th uss to b ncouragd alongsid th provision of a mixtur of nw town cntr uss. Th fact box on town cntr uss has also bn updatd in accordanc with th National Planning Policy Framwork dfinition to mak it clar that rsidntial dvlopmnt is not a main town cntr us but it can play an important rol in nsuring th vitality of town cntrs. W hav also insrtd a nw appndix (appndix A) listing th ky borough wid Southwark planning policis and supplmntary planning guidanc to mak it clarr that ths policis nd to b rad alongsid th Blackfriars Road SPD. Sction 1 of th SPD has bn updatd to rfr to this nw appndix Jnna Barry Th Council s Cor Stratgy 2010 dos not support tall Th policy approach within th SPD is considrd to b consistnt 8 6 buildings in Blackfriars Road South, as thy do not with th NPPF (2012), th London Plan (2011), th Cor Stratgy mt th critria for vision vibrancy and lif. Why (2011) and th savd Southwark Plan (2007), taking into account dos th Council s vision now diffr from th Cor changs in th surrounding contxt sinc dvloping th Cor Stratgy? Stratgy vision in 2009/2010. Th London Plan, Cor Stratgy and savd Southwark Plan form th dvlopmnt plan for Southwark, with th NPPF stting out national guidanc. Th dvlopmnt plan sts out th policis for tall buildings. Ky policis ar: London Plan policy 7.7 which idntifis that tall and largr buildings should gnrally b limitd to sits in th Cntral Activitis Zon, opportunity aras, aras of intnsification or town cntrs that hav good accss to public transport. Blackfriars Road lis within th Cntral Activitis Zon, is an opportunity ara and a town cntr with good accss to public transport. Cor Stratgy stratgic policy 12 rquirs tall buildings to hav an xmplary standard of dsign and idntifis locations whr tall buildings could go. Th Cor Stratgy vision for Banksid and Borough rfrs to th council stting out in dtail which sits ar appropriat, snsitiv and inappropriat for tall buildings through th supplmntary planning documnt/opportunity ara framwork. Savd Southwark Plan policy 3.20 sts out critria for considring applications for tall buildings and applis across th borough.th GLA s rprsntation confirms that th Mayor supports th council s approach on tall buildings, but suggsts that th SPD should b mor flxibl in rlation to building hights, and that buildings in th rgion

291 Rp Obj Rf Rf Nam Dtails of Rprsntation Jnna Barry In 2012 UNESCO notd in its convntion brifing papr that in April 2011 Southwark s Cor Stratgy includs an mphasis on hritag assts and rviss thir approach to tall buildings on th ara. Why has th council rngd on this? UNESCO s World Hritag Committ Rport Jun 2012 nots th intntion of Southwark Council to dvlop a Supplmntary Planning documnt to clarify how and whr dvlopmnt can tak plac and to dfin building hight thrsholds so as to inform th appropriatnss of subsqunt dvlopmnt proposals. Is this th said SPD? Officr Rspons to Rprsntation of 70/30m would b appropriat. Th council disagrs with this proposd amndmnt as it could allow buildings that ar gratr than th 70m/30m thrshold, which would b considrd inappropriat basd on our vidnc bas. As such, th council considrs SPD 5 to balanc local charactr and dvlopmnt potntial. Th potntial impact of tall buildings on th stting of th Towr of London World Hritag Sit. Th hights proposd in th Blackfriars Road SPD building hights stratgy ar consistnt with Southwark s dvlopmnt plan consisting of th savd Southwark Plan polics, Cor Stratgy and th London Plan. Our tsting shows that th proposd hights would not impact th stting of th Towr of London sit. Th proposd 70m thrshold guidanc for th southrn of Blackfriars Road rsponds to th snsitivity of th Palac of Wstminstr World Hritag sit Ann Critchly I hav livd clos to Blackfriars Road (BR) for ovr 30- Notd. Th BBLB Charactri Study (2013), a dtaild 0 5 yars. Most of this rspons thn is cntrd on BR as I assssmnt of th charactr of th ara undrpins th prparation of know it in dtail th rst of th ara lss so but th th SPD, alongsid othr planning documnts such as consrvation sam principls apply: viz-nd for divrsity of ara appraisals. buildings old and nw, nd for social housing including housing for oldr popl: strict controls on th hight of nw building: protction of xisting grn spacs and cration of nw ons; protction for th matur trs in BR; protction of historic buildings; rspct for th rich cultural hritag of th ara; strong cological/ nvironmntal policy for all nw buildings: protction for small businsss. Background to BR and its nvirons BR is a, broad historical road linking th City of London to South London. Wid strts with matur trs giv an attractiv potntial. At th North nd is th imposing Blackfriars Bridg with a statu of Qun Victoria and a marvllous vista of th rivr up to th National Thatr and byond. To th East is th

292 Rp Obj Rf Rf Nam Dtails of Rprsntation nw Blackfriars Station. A striking oblisk built in th 18th cntury marks th Southrn nd of BR and links BR to London Road. (St Gorgs Circus) Narby is St Gorgs Cathdral and th imprial War Musum worthy of mntion is Duk of Cumbrland pub and a row of rfurbishd Gorgian houss blonging to South Bank Univrsity in London Road just abov th Oblisk. BR has a smattring of historical buildings Pabody Estat (listd), Blackfriars Foundry and 176 BR th formr London HQ of th Tmpranc Frindly Socity. This is a much lovd local building and is awaiting a dcision on listing from English Hritag. A row of Gorgian houss (mostly listd) ar clos by. Significant contmporary buildings includ Palstria opposit Southwark Tub Station; th station itslf with its unusual `spac ship dsign which won an award whn first built. Worthy of mntion is th K2 building at South Bank Univrsity which is not only handsom but has many nvironmntal aspcts built in. Proof that `ancint and modrn can work togthr. Othr local historic buildings includ th Original Blackfriars Sttlmnt building in Nlson Squar, Rd Cross Cottags and Gardn (Octavia Hill), Draprs Cottags in Glasshill Strt, and St Gorg th Martyr in borough High Strt whr Hnry V is rputd to hav stoppd aftr th Battl of Agincourt! Charls Dickns livd in narby Lant Strt what an amazingly rich hritag w hav locally. This absolutly must not b ignord by th Council. Local popl lov th history and so do thousands of visitors to th ara. NOTE/176 Blackfriars Road is faturd on th Councils brochur on Blackfriars Road! You hav only to look at som nw buildings locally to undrstand rsidnts s concrns about ovrdvlopmnt. Whn you s th dnsity of offic bhind Tat Modrn witch virtually oblitrat Grat Guildford Strt at this point. Th Officr Rspons to Rprsntation

293 Rp Obj Rf Rf Nam Dtails of Rprsntation pattrn of formr small strt has also disappard. W nd a divrsity of buildings and a considrabl numbr of popl liv locally in th small stats off BR and in privat flats and houss. Thir nds to b listnd to as wll and don t gt much mntion your documnt Ann Critchly Nw buildings At th Northrn nd of BR No 1 will b 52 storys high! Opposit on h Old Daily Exprss sit will b anothr building 52 storys high. Th South Bank Towr, Stamford Strt will now b 42 storys and a building 45 storys high is plannd nxt to Christchurch Gardns. And yt Southwark Council is planning mor tall buildings at th Northrn nd of Blackfriars Road this tim without any control of hight. This is downright irrsponsibl and will dstroy th marvllous skylin at Blackfriars Bridg. Anything furthr from a boulvard cannot b imagind. Southwark Station is a dstination in its own right. thr is absolutly no nd for highr buildings at this point nor at St Gorgs Circus whr th oblisk stands out boldly. Any building hr should not b highr than th studnt building (12) storys othrwis th sns of balanc and spac will b lost. I prsonally would also lik to s a moratorium on any mor commrcial buildings in th small rsidntial strts off BR. Thr has alrady bn too many in roads. This is not to say th ara should b prsrvd in aspic but hr nds to b strict planning control on all nw builds, - not a ruthlss pursuit of s106 mony by th council as at prsnt. This is just giving cart blanch to dvloprs and will ultimatly dstroy th ara which provids mony th CII rlis on. Thn what? Ann Critchly Grn Spac & Matur Trs I would absolutly 2 5 support th ida of attractiv shard spacs in Officr Rspons to Rprsntation A tall building up to 70m in hight could b appropriat at th southrn nd of Blackfriars Road providd that it complis with th dtaild guidanc outlind in SPD 5 and th currnt dvlopmnt plan that includs th rlvant policis of th savd Southwark Plan (2007), Cor Stratgy (2011), London Plan (2011) and othr planning documnts/guidanc, including th NPPF (2012). Th dvlopmnt plan sts out th policis for tall buildings. Th guidanc in th SPD provids dtail on how to implmnt ths dvlopmnt plan policis spcific to Blackfriars Road. Th approach is supportd by our vidnc bas including th Blackfriars Road Urban Dsign Study which has bn prpard in accordanc with CABE and English Hritag Guidanc on Tall Buildings, In light of consultation rsponss and to add clarity to th guidanc rlating to St Gorg s Circus in SPD 5, th SPD has bn updatd to clarify that a tall building could provid a focal point at th southrn nd of Blackfriars Road up to 70m. A tall building should also sustain, nhanc or bttr rval th local hritag assts. Th SPD cannot provid this lvl of dtail or dsignat nw grn spacs. This can b undrtakn through th Nw Southwark Plan.

294 Rp Obj Rf Rf Nam Dtails of Rprsntation Blackfriars Road, but in ordr to crat attractiv spacs th currnt matur trs nd to b protctd and any planting nvisagd should b of noncorporat varity. W nd attractiv planting which givs us joy through all th sasons and hopfully hlps wildlif too (s th planting outsid Prontt Hous and in Isablla Strt/EV Rstaurant). Som public sating would also b vry wlcom and also som strts sculpturs. Th council could also ncourag vrtical planting and grt roofs and crat a whol strt of colourful bannrs illustrating local building and history (s South Bank Arts complx). A mor crativ approach would fr up th corporat imag which th council sms kn on promoting. It gos without saying that all xisting grt spacs should b protctd including th small community gardn nxt to 176 Blackfriars Road which is not mntiond in th council documnt Ann Critchly Environmntal Policy I would lik to s a strong ovr 3 5 arching nvironmntal policy for BR and its nvirons. Not just lip srvic, but a ral undrstanding of global warming and our diminishing nrgy rsourcs. This dfinitly mans control ovr th hight tall buildings which crat wind tunnls, ovr shadowing, and us massiv amounts of lctricity through air conditioning and th practic of laving all lighting on ovr night. Solar panls ar a mor practical mans of crating hating and hot watr and th rcycling of th gry watr. Grn roofs cool buildings in th summr and rtain hat in th wintr. A good provision of cycl racks and no car parking xcpt for th disabld is rquird Officr Rspons to Rprsntation SPD 3 ncourags improvd landscaping and grning and a nw paragraph has bn addd to th supporting txt of SP4 to cross rfr to th council's Opn Spacs Stratgy (2013). Our approach to rducing nrgy consumption and carbon dioxid missions is borough wid. Furthr dtail is st out in stratgic policy 13 of th Cor Stratgy, savd Southwark Plan policy 3.4 and our sustainabl dsign and construction SPD. Cor Stratgy policy 13 rquirs major dvlopmnt to achiv a rduction in carbon dioxid of 20% from using rnwabl tchnologis which may includ solar panls. Our car parking and cycl parking standards ar st out in appndix 15 of th Southwark Plan and our Sustainabl Transport SPD. As st out within th Blackfriars Road SPD, th SPD dos not rpat borough wid policis and must b rad alongsid our othr planning documnts. W hav also insrtd a nw appndix (appndix A) listing th ky borough wid Southwark planning policis and supplmntary planning guidanc to mak it clarr that ths policis nd to b rad alongsid th Blackfriars Road SPD. Sction 1 of th SPD has

295 Rp Obj Rf Rf Nam Dtails of Rprsntation Ann Critchly Social Housing Thr is a ral nd for social housing 4 5 locally. Unfortunatly Southwark s answr to this is to pursu s106 mony in ordr to provid housing lswhr in Southwark (so thy say). If w carry on with this dubious policy Blackfriars, Borough and Banksid will b popld only th rich. W nd a good social mix for a halthy socity. Why shouldn t ordinary popl njoy th cultural and historical dlights of th ara. Evn on story of small flats on commrcial buildings would turn th tid Ann Critchly Summary It is a human nd to connct with on anothr and sns of community is ssntial if w ar to surviv in a big city. A mixtur of housing and popl can hlp crat this. So can small businsss which ar disapparing at an alarming rat locally,. Th rmaining shops and cafs in Blackfriars Road and London road must b protctd somhow. Othrwis w could b facd with a sa of glass offics, chain shops, and branchs of Sainsbury s and Tsco s as for as th y can s. This is just too awful to contmplat. I m sur that if Charls Dickns and Octavia Hill wr aliv today thy would shar som of th concrns xprssd in ths commnts. Officr Rspons to Rprsntation bn updatd to rfr to this nw appndix. Th SPD sts out that it provids furthr guidanc to xisting planning policis in th Cor Stratgy and savd Southwark Plan. It dos not rpat borough wid policis and th SPD must b rad alongsid othr planning documnts. Housing is not givn its own sction within th SPD bcaus th borough-wid housing policis and guidanc alrady covr housing adquatly. This includs policis in th Cor Stratgy and savd Southwark Plan and SPDs on affordabl housing and rsidntial dsign standards. Existing policis and guidanc provid clar policis for affordabl housing. W hav also insrtd a nw appndix (appndix A) listing th ky borough wid Southwark planning policis and supplmntary planning guidanc to mak it clarr that ths policis nd to b rad alongsid th Blackfriars Road SPD. Sction 1 of th SPD has bn updatd to rfr to this nw appndix. SPD 2 rcogniss thr is an opportunity to promot a much widr mix of town cntr uss as part of th dvlopmnt of th potntial opportunity sits st out in th SPD. W hav amndd SPD2 to st out ncouragmnt for flxibly dsignd spac to accommodat a rang of unit sizs in nw dvlopmnt. Through our borough wid planning policis and SPD guidanc w will considr th impact of all nw proposals on th ovrall mix of uss in th ara and also on local amnity, and th charactr of th ara. Th SPD cannot dsignat land us on dvlopmnt sits, howvr w will considr th rang of uss that would b appropriat for allocatd dvlopmnt sits through th prparation of th Nw Southwark Plan and its accompanying proposal sits and adoptd policis map GJ Cobbtt I objct to th draft Blackfriars SPD bcaus it dos Furthr information on th potntial impact of th SPD guidanc on 6 4 not proprly xplain th conomic bnfits of social, nvironmntal and conomic sustainability is st out in our ncouraging popl to cycl nor dos it xplain what sustainability appraisal (SA). Th SA assssd th likly impact of th strt dsign is rquird to incras cycling. This SPD on 17 indicators including indicators spcific to sustainabl objction is basd on a wid rang of vidnc, mostly transport. Furthrmor, TfL has announcd proposals to introduc a collctd hr: I liv sgrgatd cycl lan on Blackfriars Road which will provid a saf

296 Rp Obj Rf Rf Nam Dtails of Rprsntation Officr Rspons to Rprsntation within on th bordr of Southwark. Blackfriars Road is facility for cyclists. Southwark supports this proposal and th SPD has on of my routs to work in London. If you mak bn updatd accordingly. Blackfriars Road saf to cycl in, thn I will cycl thr and spnd prhaps 2,000 a yar in local businsss. If you fail to grasp th nttl and mak it proprly saf to cycl, as th woolly wording in your SPD implis, thn I will continu to tak th bus all th way through Blackfriars Road and I will contribut xactly nothing to th local conomy. If thr ar just 25,000 popl lik m - a tiny proportion of th numbr of popl taking taxis and buss on Blackfriars Road vry day - thn you'r throwing away 50m vry singl yar. 1. Businss Bnfits of Sgrgatd Cycl Lans 9th Avnu, Nw York is a similar scal and typ of road to Blackfriars Road. Whn th local authority rplacd a gnral traffic lan with a sgrgatd cycl lan, local rtail trad ros 49% compard to narby strts with lss-good cycl facilitis (lik th poor-quality, narrow, unsgrgatd paintd lan you show in th main imag of your draft SPD). You will only gt this conomic bnfit if you put in proprly sgrgatd cycl lans which continu with priority across sid roads and to th lft of bus stops and loading bays. 2. Social bnfits of Sgrgatd Cycl Lans Aftr sgrgatd cycl lans wr installd on Grn Lan in Philadlphia, pavmnt cycling droppd by 75%. So pdstrians will fl safr walking among th shops and cafs and spnd mony thr. 3. Congstion Bnfits of Sgrgatd Cycl Lans TfL's Ntwork Assuranc modlling tam will try to scar you into bliving that taking away spac from motor vhicls and giving it to cycling will caus unaccptabl dlays. But thir modl is flawd bcaus it dos not proprly account for th rduction in motor traffic that happns whn you put in sgrgatd cycl lans and popl choos to cycl instad of driving or taking a taxi. 4.

297 Rp Obj Rf Rf Nam Dtails of Rprsntation How to Build Sgrgatd Cycl Lans W can do this in London. Camdn council has fully sparatd cycling from motor traffic, vn at bus stops and at junctions, in Royal Collg Strt. Motor traffic volums hav droppd 30% whr strts hav bn dsignd with proprly-sgrgatd cycl paths. This rport in th Tims c dscribs how local authoritis across th UK ar making conditions safr for cycling at littl cost, and this rport in cycling wkly shows how to do it without spnding lots of mony: grgatd-cycl-lans-using-plantrs-and-armadilloscould-sprad-across-britain.html Juha Rpo -I do not fl it is appropriat to hav th tallr "landmark" buildings furthr north Blackfriars Road than th railway bridg lading to Watrloo East. Thr ar svral consrvation aras which will b affctd by xcssiv dvlopmnt and hight Juha Rpo th north part of th road is also largly rsidntial and 8 5 th nd for furthr amnitis ar not proprly addrssd in th plans Officr Rspons to Rprsntation Th SPD 5 guidanc for th northrn nd of Blackfriars Road taks th xisting planning dsignations and consntd schms into account, with th tallst hights locatd around th junction of Stamford, Southwark and Blackfriars Road. Th SPD and othr planning policy documnts provid th framwork for th provision of infrastructur to support dvlopmnt. SPD 2: Mixd us town cntr sts out that w will support th provision of nw social infrastructur and community facilitis as part of mixd us dvlopmnts. SPD 3: Public ralm and opn spac rfrs to th continud protction of th thr protctd opn spacs and ncouraging furthr linkags and nw spacs. Sction 4 of th SPD rfrs spcifically to infrastructur, crossing rfrring to th community infrastructur lvy (CIL) and sction 106 planning obligations to hlp nsur th dlivry of ky infrastructur to mitigat th impact of dvlopmnt. Infrastructur is covrd within borough-wid planning documnts with th ovrarching policy 14 of th Cor Stratgy rcognising that nw dvlopmnt in th borough nds to b supportd by adquat infrastructur, including social, nvironmntal and physical infrastructur. Th borough s Infrastructur Plan,

298 Rp Obj Rf Rf Nam Dtails of Rprsntation Juha Rpo -th hritag of Blackfriars Road is not proprly lookd 9 5 aftr, and w run th risk of losing almost all of th pr-war building stock along th road, som of which is original sinc th road was laid out. A clarr ffort in protcting xisting landscap and building stock should hav bn includd as thr rally is not much lft now. Officr Rspons to Rprsntation idntifis stratgic infrastructur which is ndd to support growth and dvlopmnt in th borough ovr th liftim of th Cor Stratgy ( ). Whr possibl it idntifis th cost of infrastructur to providd, any committd sourcs of funding which will b usd to dlivr it and th organis rsponsibl. It also idntifis th funding gap i.. th gap btwn known commitmnts and th total cost of infrastructur rquird. Whn it is adoptd, Southwark s CIL will b usd to contribut towards bridging this funding gap. Funds armarkd for infrastructur in th Council s capital invstmnt programm also will hlp to improv infrastructur provision. Th council ar currntly prparing our draft community infrastructur charging schdul and an updatd sction 106 SPD. Adoption is plannd for It is appropriat to look at th provision of infrastructur at a borough-wid lvl through ths ddicatd documnts rathr than through th Blackfriars Road SPD. Th SPD sts out built form guidanc in rlation to th ara s contxt, hritag and dvlopmnt potntial. Th guidanc st out within th SPD is consistnt and rad in conjunction with th xisting planning policy framwork of dsign, hritag and tall building policis, which includs th rlvant savd Southwark Plan policis, Cor Stratgy Policy SP12, th rlvant policis of th London Plan and th NPPF. Th guidanc is undrpinnd by th BBLB Charactri study (2013) which intrprts th ara s charactr and history Juha Rpo -building a canyon lind by tall buildings along th road Ths mattrs would b assssd at th planning application stag 0 5 will not crat th nic atmosphr dscribd in th through th rlvant savd Southwark Plan policis, Cor Stratgy plans, but th proposd cafs and rstaurants along Policy SP12 and th rlvant policis of th London Plan and planning th road will not gt any natural light and suffr from a rgulations. Bullt-point 14 of SPD 5 sts out furthr guidanc wind tunnl ffct. rgarding microclimat, whil SPD3 sts out guidanc on landscaping and grning Juha Rpo -not nough mphasis has bn placd to improv 1 5 facilitis for th xisting rsidnts, and most of th plans will just b aimd for passing trad Th SPD and othr planning policy documnts provid th framwork for th provision of infrastructur to support dvlopmnt. SPD 2: Mixd us town cntr sts out that w will support th provision of nw social infrastructur and community facilitis as part of mixd us dvlopmnts. SPD 3: Public ralm and opn spac rfrs to th continud protction of th thr protctd opn spacs and

299 Rp Obj Rf Rf Nam 894 Valri Birn Banksi d Nighb ourhoo d Forum Dtails of Rprsntation W ar anxious to rgistr our intrst in th Blackfriars SPD and to acknowldg its importanc, and that of th ara it covrs, in th futur dvlopmnt of this nighbourhood. Banksid Nighbourhood Forum, and its constitunt parts who wr rsponsibl for submitting th application for th Banksid Nighbourhood Plan frontrunnr, hav bn clar from th outst that th cours of dvlopmnt on Blackfriars was ky to how th ara unfolds. You will b awar that following th submission of th application for th Banksid Nighbourhood Forum and Ara in Novmbr 2010, som tim lapsd Officr Rspons to Rprsntation ncouraging furthr linkags and nw spacs. Sction 4 of th SPD rfrs spcifically to infrastructur, crossing rfrring to th community infrastructur lvy (CIL) and sction 106 planning obligations to hlp nsur th dlivry of ky infrastructur to mitigat th impact of dvlopmnt. Infrastructur is covrd within borough-wid planning documnts with th ovrarching policy 14 of th Cor Stratgy rcognising that nw dvlopmnt in th borough nds to b supportd by adquat infrastructur, including social, nvironmntal and physical infrastructur. Th borough s Infrastructur Plan, idntifis stratgic infrastructur which is ndd to support growth and dvlopmnt in th borough ovr th liftim of th Cor Stratgy ( ). Whr possibl it idntifis th cost of infrastructur to providd, any committd sourcs of funding which will b usd to dlivr it and th organis rsponsibl. It also idntifis th funding gap i.. th gap btwn known commitmnts and th total cost of infrastructur rquird. Whn it is adoptd, Southwark s CIL will b usd to contribut towards bridging this funding gap. Funds armarkd for infrastructur in th Council s capital invstmnt programm also will hlp to improv infrastructur provision. Th council ar currntly prparing our draft community infrastructur charging schdul and an updatd sction 106 SPD. Adoption is plannd for It is appropriat to look at th provision of infrastructur at a borough-wid lvl through ths ddicatd documnts rathr than through th Blackfriars Road SPD. Notd. W wlcom furthr discussion. Within th SPD, figur 3 of th SPD illustrats th rlationship btwn diffrnt planning documnts including supplmntary planning documnts and nighbourhood plans. Th SPD has bn updatd to mak it clar th nighbourhood plans ar currntly bing prpard. Onc adoptd a nighbourhood plan will hav mor wight than a SPD in th planning procss as it will form part of th council's dvlopmnt plan. At prsnt thr is no adoptd nighbourhood plan for any of th ara covrd by th Blackfriars Road SPD. Th SPD may nd to b rviwd in th futur if a nighbourhood plan is adoptd for any of th SPD ara.

300 Rp Obj Rf Rf Nam 318 Hln Firming r Banksi d Opn Spac s Trust Dtails of Rprsntation bfor th ara was agrd. During this tim th complxity of th planning contxt for Blackfriars continud to dpn. Th Forum has attmptd to kp appraisd of th xtant planning applications, thos in th piplin and th mrging policy framwork. In addition to th Blackfriars SPD this has includd, th Banksid, Borough, London Bridg Charactri Study by URS and th Blackfriars Rd Public Ralm Study by A&M Urban Practitionrs. Rviwing this walth of information to th lvl which it dmands, raching a consnsus at th Forum, and tsting that with th rsidnt, businss and othr stakholdr communitis is not fasibl in th SPD consultation tim fram. It would, w fl, b prmatur for us to rspond without th bnfit of th Nighbourhood Plan consultation which is currntly undrway. To formulat a rspons without rflcting th output of th nighbourhood plan consultation would b to dvalu it and th importanc of th ara. It is apparnt from th many mtings of th Forum that th Nighbourhood Plan that mrgs will tak a position on th crucial issus along Blackfriars and it is imprativ that a dialogu with th council continus byond th consultation dadlin. Th timings ar unfortunat. W would wlcom your viws on how th adoption of th SPD and of th Nighbourhood Plan can b dovtaild. Banksid Opn Spacs Trust wlcoms this documnt and th stps it is taking to nshrin ky principls for this spcial ara. BOST particularly wlcom th gnral commitmnt towards opn spac, grning, and nhancing th public ralm. W do howvr hav on ky concrn rgarding th documnt s lgal status, at 1) blow for which rason w bliv th documnt should b withdrawn amndd and rissud. If this is dalt with, w bliv that th Notd. Officr Rspons to Rprsntation

301 Rp Obj Rf Rf Nam 318 Hln Firming r 318 Hln Firming r Banksi d Opn Spac s Trust Banksi d Opn Spac s Trust Dtails of Rprsntation documnt should go a grat dal furthr in trms of dfining this commitmnt, and hav th following commnts at 2) 5) to improv th documnt. W hav on additional ky concrn outlind at point 5) blow. Th boundary of th ara of th SPD is cohsiv in trms of Blackfriars Road, howvr it ovrlaps at St Gorg s Circus with that dtaild in th Elphant and Castl Supplmntary Planning Documnt and Opportunity Ara Framwork, rvisd in March W hav undrstood form Southwark Council, that thr could b no ovrlap of SPDs according to national planning policy, this was particularly mad clar to us at th tim of th consultation around th draft Borough and Banksid SPD, for which w sought a cohsiv boundary. W would agr that this maks sns as two ovrlapping aras of SPD with no clar guidanc would rsult in a lack of clarity on planning policy altogthr. For this rason w bliv that th Council should withdraw th SPD and rissu it with an appropriat boundary to intrlink with th E & C SPD. Furthrmor, during this procss w bliv that thr should b clar consultation ovr adjoining aras to nsur that th boundary dos not mak th sam mistaks as that of th E & C i by sking to giv itslf a cohsiv boundary, intruding into th cohsiv boundary of adjoining aras. 2) Vision on P10, 2.24 a) W wlcom th aspiration to giv th ara an idntifiabl charactr howvr w ar unclar what this idntifiabl charactr is. W suggst building on suggstions latr in th SPD for a cohrnt landscaping schm to crat a strong visionary idntity for Blackfriars Road, plas add th following dscription to th txt: A boulvard of grn, strtching from th City of London Gardn at th Officr Rspons to Rprsntation An xplanation of th boundary is st out within th SPD. It includs th whol of th Blackfriars Road and som of th surrounding ara. It includs th surrounding ara as th surrounding ara is also likly to s som dvlopmnt and improvmnts, particularly possibl improvmnts to public ralm. Wording has bn addd to th SPD to mak it clarr that th charactr and historic valu of much of th surrounding ara will continu to b protctd and nhancd. Figur 3 of th SPD illustrats th rlationship btwn diffrnt planning documnts including supplmntary planning documnts and nighbourhood plans. Th SPD has bn updatd to mak it clar th nighbourhood plans ar currntly bing prpard. Onc adoptd a nighbourhood plan will hav mor wight than a SPD in th planning procss as it will form part of th council's dvlopmnt plan. At prsnt thr is no adoptd nighbourhood plan for any of th ara covrd by th Blackfriars Road SPD. Th SPD may nd to b rviwd in th futur if a nighbourhood plan is adoptd for any of th SPD ara. a.) No chang. Th mrging vision and th guidanc in th SPD st out a strong and aspirational vision for Blackfriars Road that includs landscaping and grning. SPD 3 that sts out gnral principls for th public ralm and spcific principls for aras that ar spcially important. b.) No chang. Th mrging vision cannot st out sit spcific guidanc for dvlopmnt sits. Our Opn Spac Stratgy has idntifid a dficincy in opn spacs within thn ara; howvr givn th limitd opportunitis for th cration of opns, our priority is

302 Rp Obj Rf Rf Nam 318 Hln Firming r Banksi d Opn Spac s Trust Dtails of Rprsntation Bridg, to a grnr St Gorg s Circus to th south, achivd by widnd pavmnts with visionary planting crating a safr and mor njoyabl nvironmnt for pdstrians, a mor sustainabl climat, and an idntifiabl charactr for th road. b) Chang final lin as follows Opportunitis to crat nw opn spacs within dvlopmnt sits will b sought. Opportunitis to improv xisting parks including Christ Church Gardn, Nlson Squar, and Paris Gardns as wll as smallr community gardns will b maximisd through working with local groups such as th Banksid Opn Spacs Trust. c) Th vision nds to add two lins on climat in rspons to th nds of Blackfriars Road: Dvlopmnt, and grning projcts, will work to mitigat th difficult windy microclimats currntly occurring on Blackfriars Road and th wstrn nd of Union Strt. Any nw dvlopmnt will b rquird to dmonstrat how furthr xacrbation of wind is avoidd. Opportunitis for an xtnsiv Sustainabl Urban Drainag schm along th pavmnts of Blackfriars road will b ralisd. 3) SPD 3 Public Ralm and opn spac starting P19: a) In th introductory paragraph, plas add Banksid Opn Spacs Trust to th list of groups workd with. W would suggst also adding th local BIDs, as ths ar clarly important partnrs dividd by Blackfriars Road. b) Gnral principls quots Ensur that thr is a clar distinction btwn public and privat spac whil a usful aspiration this is a hard aim to nforc, considring for xampl th diffrnt aras of housing land that contribut to th strtscap (g Styls Hous Gardn, Brookwood Hous Gardn), th importanc of th plantd dining aras on Isablla Strt, and th contribution of Hln Gladston Hous Gardn to th strtscap. W ask Officr Rspons to Rprsntation to focus on improving out xisting opn spacs. W will sk to provid nw opn spac and grning as st in th stratgy. Nw opn spacs cannot b dsignatd through an SPD. This may addrssd through th nw Southwark Plan. C.) SPD 5 sts out guidanc on mitigating microclimat ffct, alongsid London Plan policy 7.7 and savd Southwark plan policy Th impact of dvlopmnt on microclimat would b assssd at th planning application stag. a) Agrd. W hav updatd SPD 3 to includ BOST. b) No chang. Th guidanc in SPD 3 ncourags public ralm and opn spac improvmnts within th SPD ara, including th cration of nw public spacs. Th rquirmnt for a clar distinction btwn public and privat spac sks to improv th lgibility of spac so that it ncourag popl to us public spac that is availabl to thm. Th guidanc in SPD 3 adquatly covrs this rquirmnt c) No chang. Play spac is alrady covrd in th adoptd Rsidntial Dsign Standards SPD, th London Plan and th Play and Informal Rcration SPG d) No chang. This lvl of dtail is byond th scop of th SPD. Our approach to improv th quality of th grn and amnity spac is borough-wid and st out in our Opn Spac Stratgy (2013). ) No chang. Th points raisd rgarding landscaping and nw public spacs ar alrady covrd within SPD 3.

303 Rp Obj Rf Rf Nam 318 Hln Firming r Banksi d Dtails of Rprsntation Officr Rspons to Rprsntation that this statmnt is qualifid to Ensur that privat f) No chang. This lvl of dtail is byond th scop of th SPD. spac is protctd, whil valuing and ralising th contribution it maks to public ralm and strtscap. c) Add gnral principl Plan for th nds of childrn living in th ara, including high quality wll maintaind play spac at Nlson Squar Gardn, Albury Grn, and in pockt play aras on nw dvlopmnts. Protct and nhanc th strtscap for pdstrians around Friars School. d) Amnd gnral principl Ensur that protctd opn spacs at Christ Church Gardn, Nlson Squar, and Paris Gardns ar maintaind and nhancd as part of a high quality infrastructur for rsidnts, businsss and visitors, build on this ntwork with improvmnts and maintnanc to furthr grn spacs, including th Hln Gladston Hous Gardn, Gambia Strt Gardn, th Divrsity Gardn, and Styls Hous Gardn. Whr possibl, sk opportunitis to xtnd ths parks and gardns. Protct and nhanc th calm and cohsiv sns of plac of ths parks and gardns, nsuring a clar boundary, no incras in shading, and no ncroachmnt. ) Additional Principls for Blackfriars Road, w wlcom th following paragraph and suggst it is amndd in lin with our commnt at 1a) Build a grn boulvard charactr for Blackfriars Road, introducing a ntwork of gnrous, maningful and prsonabl spacs that ar informd by th uss around thm and anticipatd lvls of activity. Nw public spacs should b providd by nw dvlopmnt, whil contributing to its unifid grn boulvard charactr. f) Principls for St Gorg s Circus add Furthr grning of St Gorg s Circus, building on xcllnt work of th Gurilla Gardnrs. P23 diagram, A numbr of opn spacs nd to b addd to this map that hav significanc to local No chang. Th SPD cannot provid this lvl of dtail as a SPD cannot allocat land for a spcific us on th adoptd policis map.

304 Rp Obj Rf Rf Nam 318 Hln Firming r 318 Hln Firming r Opn Spac s Trust Banksi d Opn Spac s Trust Banksi d Opn Spac s Trust Dtails of Rprsntation popl, ar wll usd, and contribut to strtscap, mntal halth, and microclimat, as wll as th sns of spcialnss in th ara. Thir function in this dnsly populatd ara is much gratr than that than pockts of opn spac that dg rsidntial blocks as thy ar dscribd in th URS charactr study. Plas s attachd map, which includs most of th following in roughly north to south ordr: Corporation of London Blackfriars Bridg Gardn (far north of map, not lablld). Christ Church Gardn Northrn xtnsion to Christ Church Gardn (agrd as part of approvd planning application) Paris Gardn Gambia Gardn and Play Ara Styls Hous Gardn, Th Cut, Hln Gladston Hous Gardn Applgarth Gardn Draprs Gardn Wbbr Row Algar Grn Brookwood Triangl Albury Grn and Play Ara Lingfild Gardn Markston Gardn Divrsity Gardn and Grn Stor St Gorg s Circus (off th map) Th proposd dvlopmnt ovr Southwark Tub Station would giv substantial shading to th café aras on Isablla Strt, faturd in th draft plan. It is possibl that this would mak th planting in containrs hr unviabl, which would b a grat loss of an important contribution to th viability of th ara. Any dvlopmnt at this location should clarly dmonstrat how it supports ths valuabl public ralm improvmnts, and how it dos not ovrshad thm. 6) W ar concrnd that nw dvlopmnts will b in xcss of dnsity standards, and will not achiv xtrnal amnity standards, particularly provision of childrn s play, this should b th first goal. As a scondary goal w nd to look to long trm improvmnts and rvnu funding. All maintnanc fund should b st up for th grn boulvard, and for Officr Rspons to Rprsntation Our protctd opn spacs ar allocatd on th adoptd policis map and listd within appndics to th savd Southwark Plan and within our ara action plans. A rviw of opn spac and borough wid rviw of th rcommndations of th Opn Spacs Stratgy (2013) will b undrtakn as part of th prparation of th Nw Southwark Plan. A nw paragraph has bn addd to SPD 3 "w ar doing this bcaus" to provid furthr background on th Opn Spacs Stratgy rcommndations. Impacts from tall buildings would b assssd at th planning application stag for consistncy with th xisting planning policy framwork of dsign, hritag and tall building policis, which includs th rlvant savd Southwark Plan policis, Cor Stratgy Policy SP12, th rlvant policis of th London Plan and th NPPF. Dvlopmnt proposals would b assssd at planning application stag for consistncy with th xisting planning policis and guidanc that covr this issu, which includs th Cor Stratgy policy 5, London Plan policy 3.6, th Rsidntial Dsign Standards SPD and th play rquirmnts in th Mayor's Play and Informal Rcration SPG. W hav addd an appndix to th SPD which signposts th xisting policy framwork. Public ralm maintnanc and projct

305 Rp Obj Rf Rf Nam 966 Hln Santr Watrl oo Quart r BID Dtails of Rprsntation localisd pockt parks dvlopd from th list abov. A local organi such as Banksid Opn Spacs Trust could thn us this fund to maintain th grn placs at no cost to th local authority or TFL. Watrloo Quartr is th Businss Improvmnt District (BID) for Watrloo. Rprsnting th intrsts of ovr 330 local businsss, w aim to improv th ara as a dstination, crat a safr and mor plasant trading nvironmnt and dvlop a crativ and connctd community in which to work. Watrloo Quartr BID oprats on a cross-borough basis, spanning parts of th boroughs of Southwark and Lambth. Th Southwark sction of Watrloo Quartr BID includs a significant portion of th SPD ara, including Blackfriars Road from Th Cut to St Gorg s Circus and th ara to th wst of this strtching as far as th borough boundary. 139 of our mmbr businsss ar basd within th SPD ara. Our particular commnts on th SPD focus on th nd for furthr clarity about accptabl us typs on th strt and th quantum of commrcial spac. This is promptd by significant concrn at th potntial for th continud loss of commrcial spac in th southrn sction of Blackfriars Road south of th Palstra, dspit th statd policy (SPD1 businss spac) to rquir xisting businss floorspac (B1) to b rtaind or rplacd unlss an xcption can b dmonstratd in accordanc with our borough wid mploymnt policis. Th rfrnc (p11) to flxibl innovativ businss spac is vry wlcom. W hav obsrvd a strong, largly untappd dmand for smallr commrcial spac in particular in th Watrloo/Blackfriars ara. Almost 100% of nquiris fildd by th Watrloo Quartr BID tam rgarding th availability of offic spac in th ara rlat to proprty in th 300-3,000sq ft brackt. Masurs to Officr Rspons to Rprsntation dlivry is outsid th scop of th SPD, howvr w will continu to work with BOST and othr groups on a projct by projct basis. It is important for th SPD guidanc to b rad in conjunction with both adoptd planning policy. Th rquirmnt in SPD1 to rtain or rplac xisting businss spac is consistnt with borough-wid policis. Cor Stratgy policy 10 and savd Southwark Plan policy 1.4 rquir applicants to dmonstrat th loss of businss floorspac (B1, B2 and B8) against a rang of xcption critria whr th sit falls within a rang of locations, which includ (amongst othrs) th CAZ. Land outsid ths locations can b rlasd for othr uss. This stratgy nsurs th rtntion of xisting businss floorspac whr this is appropriat, to nsur thr continus to b spac availabl for stablishd businsss to mov into th ara and for start up businsss to stablish thmslvs. Th council considrs that it is rasonabl to xpct applicants to dmonstrat that in th aras whr businss floorspac is protctd that thr is a lack of dmand or viability, or physical and/or nvironmntal constraints which prclud r-provision or an uplift of mploymnt spac (Southwark Plan Policy 1.4). It is considrd that this is consistnt with paragraph 21 and 22 of th NPPF and provids adquat flxibility. Support notd. SPD 2 rcogniss thr is an opportunity to promot a much widr mix of town cntr uss as part of th dvlopmnt of th opportunity sits idntifid in th SPD ara. This includs a rang of diffrnt typs and sizs of businsss to hlp boost th local conomy by gnrating additional spnding and inward invstmnt in othr businsss and providing an incrasd numbr of mploymnt opportunitis. Th SPD cannot dsignat land us on dvlopmnt sits, howvr w will considr th rang of uss that would b appropriat for allocatd dvlopmnt sits through th prparation of th Nw Southwark Plan and its accompanying proposal sits and adoptd policis map.

306 Rp Obj Rf Rf Nam 966 Hln Santr Watrl oo Quart r BID 966 Hln Santr Watrl oo Quart r BID 966 Hln Santr Watrl oo Quart r BID Dtails of Rprsntation incras th divrsity of businss spac in th ara ar thrfor wlcom and it may wll b that smallr units can b suitably locatd in th southrn part of th ara. Howvr, this should not b at th xpns of rducing th ovrall quantity of commrcial spac, particularly in th southrn sction of th road. Th provision of vry small numbrs of SME units on dvlopmnt sits should not, as has bn proposd in rcnt planning applications, b considrd suitabl rcompns for significant ovrall loss of B1 spac. W hav grav concrns that an mrging trnd towards loss of offic spac in th southrn sction of Blackfriars Road will continu to mphasis th lack of animation and activity in th road during th day, and that th lack of daytim customrs in an ara dominatd by a (working) rsidntial population will furthr impact on th viability of local shops and srvics. W wlcom th proposal to continu to convrt Support notd. railway archs into a varity of commrcial uss and considr ths sits idally suitd towards nurturing th crativ and oftn indpndnt businsss that charactris th ara. W also wlcom th promotion of activ frontags along Blackfriars Road and th animation that this will bring to th strt. W wlcom th aspiration to link both sids of Blackfriars Road and to intgrat it into th surrounding ara with nhancd ast/wst routs at ky junctions and xisting public spacs (additional principls for Blackfriars Road p20). W fl that th SPD dos not currntly st out a clar vision for th potntial for St Gorg s Circus to hlp dlivr on this objctiv. W fl that its potntial to b nhancd as a ky gatway into Blackfriars Road as an ara of public ralm nds to b considrd Support notd. Officr Rspons to Rprsntation Th public ralm principls for St Gorg s Circus st out in SPD 3 provid clar guidanc for th futur improvmnts at th Circus, alongsid guidanc in SPD 4 and 5.

307 Rp Obj Rf Rf Nam 966 Hln Santr Watrl oo Quart r BID 966 Hln Santr Watrl oo Quart r BID 166 Michal Ball Watrl oo Comm unity Dvlo pmnt Group Dtails of Rprsntation alongsid its rlation to nighbouring transport routs in particular Watrloo Road and Wstminstr Bridg Road. W bliv that th potntial rorgani of th traffic gyratory could hlp dlivr not only improvd public ralm for Blackfriars Road, but also nhancd traffic managmnt that could hav a vry positiv impact on th ntranc to Wstminstr Bridg Road and Watrloo Road (th lattr itslf also an important boulvard linking th rivr to St Gorg s Circus and byond to Elphant). As a gnral point and acknowldging th rstrictions of administrativ boundaris in planning trms w would wlcom significantly mor rfrnc in th documnt to th cross-borough implications of th dvlopmnt of Blackfriars Road, both in spatial and conomic trms. (a) Th ara was not a cohrnt plac which warrantd SPD of this sort, but that rathr any policy dtaild plan byond th xisting and mrging borough-wid plan should b focusd on th gnuinly cohrnt ara of Banksid or of Watrloo: th ara dfind as Blackfriars Rd by th draft SPD formd a part of both aras. Th ara is dfind and dominatd by a major through-road, which as such forms a barrir btwn Watrloo and Banksid. This barrir was sufficintly problmatic for rsidnts without that barrir bing rinforcd furthr by larg dvlopmnts along it, which was th main thrust of th SPD. Furthrmor th inclusion of th southrn sction around St Gorg s Circus and byond, which includs som of th ara of th Elphant SPD rcntly updatd, adds to th incohrnc of this proposd SPD s ovrall approach. Notd. Officr Rspons to Rprsntation Rfrnc is mad throughout th SPD at rlvant points to th nd to work with our nighbours. Furthr updats had bn mad. An xplanation of th boundary is st out within th SPD. It includs th whol of th Blackfriars Road and som of th surrounding ara. It includs th surrounding ara as th surrounding ara is also likly to s som dvlopmnt and improvmnts, particularly possibl improvmnts to public ralm. Wording has bn addd to th SPD to mak it clarr that th charactr and historic valu of much of th surrounding ara will continu to b protctd and nhancd. Figur 3 of th SPD illustrats th rlationship btwn diffrnt planning documnts including supplmntary planning documnts and nighbourhood plans. Th SPD has bn updatd to mak it clar th nighbourhood plans ar currntly bing prpard. Onc adoptd a nighbourhood plan will hav mor wight than a SPD in th planning procss as it will form part of th council's dvlopmnt plan. At prsnt thr is no adoptd nighbourhood plan for any of th ara covrd by th Blackfriars Road SPD. Th SPD may nd to b rviwd in th futur if a nighbourhood plan is adoptd for any of th SPD ara Michal Ball Watrl (b) Thr was strong disagrmnt with any Our mrging vision for Blackfriars Road has bn amndd sinc

308 Rp Obj Rf Rf Nam 7 oo Comm unity Dvlo pmnt Group 166 Michal Ball Watrl oo Comm unity Dvlo pmnt Group 166 Michal Ball Watrl oo Comm unity Dvlo pmnt Group Dtails of Rprsntation suggstion that th ara was a commrcial ara (which th SPD proposs at on point) and strong opposition to moving away from a mixd ara towards a mor commrcial ara. This is, of cours, ntirly in kping with th London Plan aspirations for Cntral London. Thr is a larg rsidntial population along both sids of th road which it is all too asy to ovrlook from an outsidrs prspctiv whn focusing on th movmnt and rhythm of th road from a north/ south prspctiv. Thr is also considrabl commrcial uss in th ara, with light industrial uss and small offics, particularly in th wstrn sid of th southrn sction of Blackfriars Rd. Thr wr also community uss, ducation, opn spacs, and th rtail cntr of Th Cut and Lowr Marsh, making th ara gnuinly mixd us. (c) Traditionally rsidnts hav lookd towards Watrloo for shopping, community facilitis and transport connctions, but with th rgnration of Banksid, London Bridg and th Elphant thy now tnd to look thr. Furthrmor, rsidnts to th south of th SPD ara focusd much mor radily on th Elphant & Castl. This rinforcs th point frquntly mad that th ara falls btwn 3 opportunity aras and town cntrs (Watrloo, Elphant, London Bridg/ Borough) and was not a plac in itslf which warrantd a SPD, unlss that wr bing usd to smuggl in spcific changs to planning policy. (d) Traffic spd, nois, pollution and traffic volums ar th most significant problm of th ara, and yt this is not addrssd anywhr in th SPD. Whil it is acknowldgd that th Road is a TfL road, this dos not prvnt LBS from dvloping a vision for th road which TfL should b prsuadd to adopt. A vision for Blackfriars without a vision for th road itslf would b Officr Rspons to Rprsntation consultation, and includs th aspiration for Blackfriars Road to b transformd into a vibrant plac providing a rang of diffrnt activitis rgnrating th ara from th rivr along Blackfriars Road and stimulating chang at th Elphant and Castl. W hav amndd th supporting txt to includ rfrnc to a mixd us ara, including rsidntial. Th supporting txt to SPD2, provids contxt to th rang of uss in th ara. It rcogniss th mix of community uss in th ara. Th SPD rcogniss that a numbr of nw larg dvlopmnts hav bn built, with mor undr construction or bing plannd. Du to th scal of growth nvisagd for th ara thr is a nd to nsur dvlopmnt taks plac in a coordinatd way and that Blackfriars Road rachs its potntial as a dstination with its own idntifiabl charactr and idntity. This purpos of th SPD is to provid dtaild guidanc to coordinat futur growth along and around th Blackfriars Road, stting out clar aspirations for growth, and b usd alongsid adoptd planning policis. TfL ar th Highway Authority for Blackfriars Road and as such st th spd limit. Southwark Council support th introduction of 20mph limits on our rsidntial strts. Th SPD dos not list spcific road safty intrvntions, howvr if a 20mph limit wr to b introducd by TfL this would b supportd by xisting policis (including th Cor Stratgy and th Transport Plan) and th guidanc within this SPD.

309 Rp Obj Rf Rf Nam 166 Michal Ball Watrl oo Comm unity Dvlo pmnt Group Dtails of Rprsntation compltly flawd. Addrssing th issus th road throws up should b th starting point for any invstigation of how to rpair and rgnrat th urban fabric of th ara. Blackfriars Rd is gnrally undrloadd, xcpt during rush-hour (and vn thn only half th road is fully loadd). Th rsult is that cars can too asily spd I frquntly manag mor than 40mph along th southrn strtch, and its width and straightnss positivly invit such a rspons from road-usrs. Th road could and should b narrowr at various points and mor crossabl, with lights and plican crossings rducing spds significantly, as wll as offring mor points for rsidnts and othr pdstrians to cross. This is particularly tru at th southrn nd of th Road. Thr should b widr pavmnts in gnral along th whol road, and thr is a vry clar opportunity to crat a sparatd cycl rout, which would b major boon to London, as wll hlp to try and brak th unplasant dominanc of vhicls. Such intrvntion could also hlp addrss th consistntly bad accidnts on BR and Th Cut, which is far largly unacknowldgd. A 20mph shard surfac was suggstd; givn th aspirations for th ara xprssd in th draft SPD, thr is no rason not to aim to achiv what has bn achivd at Exhibition Road. St Gorg s Circus is particularly difficult to cross, and is a particularly powrful barrir of movmnt to and from th Elphant. Public ralm: All th hotls and offics proposd will gnrat a lot of pdstrians, who will nd mor pdstrian spac. Thr is virtually no grn spac along this whol strtch a row of trs is not grn spac. Thr nds to b ral grn links to ral grn spacs just off Blackfriars. Thr is a rar opportunity at Christchurch Gardns for an xtraordinary burst of grn through th walls of dvlopmnt but this is Officr Rspons to Rprsntation Indicativ grn links hav bn idntifid throughout th borough through th Opn Spac Stratgy (2013). Th Stratgy sts out furthr dtail on th diffrnt typs and charactristics of grn links that may b ncouragd within th borough. This could includ saf grn routs btwn xisting opn spacs and ky dstinations. Christ Church Gardns is alrady a protctd opn spac, bing allocatd on our adoptd policis map. A nw paragraph has bn addd to SPD 3 "w ar doing this bcaus" to provid furthr

310 Rp Obj Rf Rf Nam 166 Michal Ball Watrl oo Comm unity Dvlo pmnt Group 166 Michal Ball Watrl oo Comm Dtails of Rprsntation thratnd by th misguidd focus on th pro-tall buildings agnda vidnt throughout th SPD. In trms of land uss, it is critical that th mix of uss is rtaind, including all of th small businsss in prmiss dottd around th ara as wll as focusd to th south of Th Cut, and in th archs. Thr is a nd to control th amount of studnt and othr tmporary accommodation coming forward in th ara. Th ara is in dangr of bcoming unbalancd and losing its mix, spcially smallr offics and workshops. Thr is insufficint analysis in th SPD of th impact of so many studnts and visitors on th ara, not just on public spac but local hospitals, GPs, fir srvic, polic, and othr srvics. W nd to somhow influnc th London plan policis that ar pushing for ths additional studnt schms and hotls, and w nd to call tim on dvloprs producing any nw proposals for thm in this ara. Should th small businsss in th archs b rplacd with offics? No, this is strongly opposd. Thr is a lin of thinking that th mor dirty industris such as Officr Rspons to Rprsntation background on th Opn Spacs Stratgy rcommndations. SPD2 rcogniss thr is an opportunity to promot a much widr mix of town cntr uss as part of th dvlopmnt of th potntial opportunity sits st out in th SPD. W hav amndd SPD2 to st out ncouragmnt for flxibly dsignd spac to accommodat a rang of unit sizs in nw dvlopmnt. Through our borough wid planning policis and SPD guidanc w will considr th impact of all nw proposals on th ovrall mix of uss in th ara and also on local amnity, and th charactr of th ara. Th SPD cannot dsignat land us on dvlopmnt sits, howvr w will considr th rang of uss that would b appropriat for allocatd dvlopmnt sits through th prparation of th Nw Southwark Plan and its accompanying proposal sits and adoptd policis map. Bullt 2 of SPD1 ritrats borough wid planning policy of rquiring th rtntion or rplacmnt of businss floorspac, and this will continu to b on of a numbr of prioritis for th council to nsur that th concntration of businss floorspac in th ara is maintaind. Th supporting txt outlins borough wid policy on small businss spac, including mploymnt spac availabl within th railway archs. Ths spacs can b usd for a varity of mploymnt opportunitis. W hav also addd additional rfrnc into th supporting txt rgarding th savd Southwark Plan Policy 1.5 in ordr to highlight that this policy aims to protct small businss units in proposals for rdvlopmnt or chang of us of mploymnt sits, by rquiring th quivalnt provision for small units within th rplacmnt floorspac, subjct to xcption critria. Policy 14 of th Cor Stratgy rcogniss that nw dvlopmnt in th borough nds to b supportd by adquat infrastructur, including social, nvironmntal and physical infrastructur. Th borough s Infrastructur Plan, idntifis stratgic infrastructur which is ndd to support growth and dvlopmnt in th borough ovr th liftim of th Cor Stratgy ( ). It is important for th SPD guidanc to b rad in conjunction with both adoptd planning policy. This is mad clar within th SPD. Th savd Southwark Plan policy 1.5 allows th chang of us of th railway

311 Rp Obj Rf Rf Nam unity Dvlo pmnt Group 166 Michal Ball Watrl oo Comm unity Dvlo pmnt Group 166 Michal Ball Watrl oo Comm unity Dvlo Dtails of Rprsntation taxi rpairs and garags shouldn t b in cntral London, but highr rnt offics, bars and rstaurants should b. This is short-sightd: th archs provid low rnt spacs for small businsss and crativ industris, and th ara is unusual in th scop of artistic/ crativ opportunitis, and this should b mbracd. Th crativ industris hav rmaind rlativly buoyant throughout th rcssion, and th ara along th rivr has th largst collction of arts buildings in Europ, so thr is a clar conomic bnfit from ncouraging ths industris and thir support srvics such as printrs to stay. Storag is not a good us. (h) In trms of rtail, th ara has a multitud of smallr suprmarkts and 24/7 shops, but still no propr suprmarkt to srv th local rsidntial community, many of whom do major houshold shopping at Vauxhall Nin Elms or th Old Knt Rd. A major outlt was approvd for 1 Blackfriars in 2003, but unimplmntd. This should b a ky aspiration: th most appropriat sit would b th Southwark Station sit, sinc it would complmnt th xisting rtail cntr in Th Cut & Lowr Marsh, and it would b dirctly on top of a transport nod. Protction of th shopping cntr is a priority for local rsidnts. Lisur uss for local rsidnts ar also insufficint, with th Colombo Cntr thratnd with closur should th Doon St lisur cntr finally b constructd (this is a condition of th las). A cinma or music hall would b good. Major dvlopmnts should b providing ral grn spac as wll as community srvics such as GP surgris. But thr s a ral shortag of grn spac and parks that you can sit in, and thr s a fundamntal diffrnc btwn this and th hard- Officr Rspons to Rprsntation archs for a varity of uss, including shops, cafs, rstaurants, light industry, businss, crativ uss and community uss, providd that th proposd us dos not hav an unaccptabl impact on th amnitis of nighbouring occupirs, or on car parking, traffic congstion and road safty. W hav mad additional rfrnc to this policy in th supporting txt. SPD2 rcogniss thr is an opportunity to promot a much widr mix of town cntr uss as part of th dvlopmnt of a rang of potntial sits idntifid in th SPD ara. This includs a rang of diffrnt typs and sizs of businss, to not only hlp to invst in th local conomy but provid srvics to rsidnts, visitors and workrs. Th SPD cannot dsignat land us on dvlopmnt sits, howvr w will considr th rang of uss that would b appropriat for dvlopmnt sits through th prparation of th Nw Southwark Plan and its accompanying proposal sits map. Th SPD is consistnt with th our Opn Spac Stratgy (2013) which has idntifid a dficincy in opn spacs within thn ara. Howvr givn th limitd opportunitis for th cration of nw opn spac, our priority is to focus on improving our xisting opn spacs.

312 Rp Obj Rf Rf Nam pmnt Group 166 Michal Ball Watrl oo Comm unity Dvlo pmnt Group Dtails of Rprsntation standing privat/ public ralm proposd by dvloprs and accptd by plannrs. Whil prmabl opn spacs at th bas of dvlopmnts ar usful and ncssary and wlcom, thy ar not sufficint. Thr nds to b attractiv pdstrian routs linking up xisting opn spacs. Thr ar many opportunitis for crating pdstrian priority strts and shard surfacs, rathr than th continud prim dfinition of strts as spacs for motor vhicls to mov through, particularly whn many of ths strts ar mpty of vhicls much of th tim. j) Th SPD is notably and rgrttably silnt on th social infrastructur alrady ndd, such as GP surgris, youth facilitis lt alon th amount of infrastructur which will b ndd if th scal of dvlopmnts proposd ar actually constructd. Th Bakrloo lin yard at Lambth Road is a hug sit which could b covrd ovr and dvlopd for all sorts of bnficial uss. Officr Rspons to Rprsntation Th SPD sks to improv walking and cycling opportunitis and links throughout th ara. This is st out in SPD 6, which has bn updatd rgarding TfL s proposals to crat a sgrgatd rout for cyclists whilst nsuring th nds of all usrs ar mt safly, managing th dmands of buss, fright, pdstrians and cyclists. A nw paragraph has bn addd to SPD 3 "w ar doing this bcaus" to provid furthr background on th Opn Spacs Stratgy rcommndations. Th SPD and othr planning policy documnts provid th framwork for th provision of infrastructur to support dvlopmnt. SPD 2: Mixd us town cntr sts out that w will support th provision of nw social infrastructur and community facilitis as part of mixd us dvlopmnts. SPD 3: Public ralm and opn spac rfrs to th continud protction of th thr protctd opn spacs and ncouraging furthr linkags and nw spacs. Sction 4 of th SPD rfrs spcifically to infrastructur, crossing rfrring to th community infrastructur lvy (CIL) and sction 106 planning obligations to hlp nsur th dlivry of ky infrastructur to mitigat th impact of dvlopmnt. Infrastructur is covrd within borough-wid planning documnts with th ovrarching policy 14 of th Cor Stratgy rcognising that nw dvlopmnt in th borough nds to b supportd by adquat infrastructur, including social, nvironmntal and physical infrastructur. Th borough s Infrastructur Plan, idntifis stratgic infrastructur which is ndd to support growth and dvlopmnt in th borough ovr th liftim of th Cor Stratgy ( ). Whr possibl it idntifis th cost of infrastructur to providd, any committd sourcs of funding which will b usd to dlivr it and th

313 Rp Obj Rf Rf Nam 166 Michal Ball Watrl oo Comm unity Dvlo pmnt Group Dtails of Rprsntation (k) A propr mix of additional housing is ssntial for maintaining th succssful social mix of th ara. Southwark s policy of accpting masss of markt housing but no affordabl, with hug quantitis of mony in liu to b spnt lswhr, thratns th ntir rlationship btwn th rsidntial community and th Council, whos vry lgitimacy is bing undrmind as a rsult. Popl ar moving out of th ara with right to buy maning social rntd stocks ar dwindling. W nd nw social rntd housing which is gnuinly affordabl for popl to liv in th ara. W also nd ky workr housing, to hous popl that ar ssntial for kping th infrastructur going. W also nd chap privat rntd, such as bdsits. Non of this is bing cratd in th proposals coming forward, which, at up to 2,000 psf, ar proving not to b usd as homs but as invstmnts and lft mpty. Officr Rspons to Rprsntation organis rsponsibl. It also idntifis th funding gap i.. th gap btwn known commitmnts and th total cost of infrastructur rquird. Whn it is adoptd, Southwark s CIL will b usd to contribut towards bridging this funding gap. Funds armarkd for infrastructur in th Council s capital invstmnt programm also will hlp to improv infrastructur provision. Th council ar currntly prparing our draft community infrastructur charging schdul and an updatd sction 106 SPD. Adoption is plannd for 2014.It is appropriat to look at th provision of infrastructur at a borough-wid lvl through ths ddicatd documnts rathr than through th Blackfriars Road SPD. Th SPD sts out that it provids furthr guidanc to xisting planning policis in th Cor Stratgy and savd Southwark Plan. It dos not rpat borough wid policis and th SPD must b rad alongsid othr planning documnts. Housing is not givn its own sction within th SPD bcaus th borough-wid housing policis and guidanc alrady covr housing adquatly. This includs policis in th Cor Stratgy and savd Southwark Plan and SPDs on affordabl housing and rsidntial dsign standards. Th vision alrady rfrs to housing dvlopmnt. Housing will b ncouragd on appropriat sits. In ordr to mak this clarr, w hav updatd SPD 2: Mixd us town cntr to includ rsidntial dvlopmnt as on of th uss to b ncouragd alongsid th provision of a mixtur of nw town cntr uss. Th fact box on town cntr uss has also bn updatd in accordanc with th National Planning Policy Framwork dfinition to mak it clar that rsidntial dvlopmnt is not a main town cntr us but it can play an important rol in nsuring th vitality of town cntrs. W hav also insrtd a nw appndix (appndix A) listing th ky borough wid Southwark planning policis and supplmntary planning guidanc to mak it clarr that ths policis nd to b rad alongsid th Blackfriars Road SPD. Sction 1 of th SPD has bn updatd to rfr to this nw appndix.

314 Rp Obj Rf Rf Nam 166 Michal Ball Watrl oo Comm unity Dvlo pmnt Group Dtails of Rprsntation (l) Thr is normous scpticism about th bnfits of tall buildings, or th argumnts rustld up in thir favour. No on at our consultations positivly sk tall buildings, and th vast majority activly oppos thm. Thr ar no vidnt bnfits to th local community, and normous impacts in trms of nvironmntal dgradation, microclimat, shadowing, th impact on viws, and th gnral dominanc thy xrt upon th ara. Whthr you liv in a hous or a high ris, th whol of th visibl sky is bing filld in, daylight and sunlight has rducd, local winds hav incrasd. Viws of historic buildings blockd and Consrvation Aras compromisd. Thy should proprly mt th planning rquirmnts of not damaging amnity or hritag, but plannrs and dcision-makrs sm consistntly blindd by th xtravagant claims and richs promisd by thir proponnts. Clarly th tall buildings approvd at th bridghad ar likly to b built and rsidnts rcognis that nothing can b don about this. But th proposals for tall buildings in th othr thr aras idntifid along Blackfriars Rd ar ntirly rjctd. Th sit abov Southwark Station is th only on which is a gnuin opportunity, but is sufficintly sizabl to accommodat a building of up to 50m without dscrating th various Consrvation Aras in Lambth which li clos by. This is not a sit appropriat for a tall building of 70m as suggstd Palstra is alrady vidnc of this! Proposing 100m buildings St Gorg s is wilfully inappropriat, it would b compltly out of contxt and scal, and would hav no rlation to th ara. This is not a transport nod, or a rtail nod, but simply a complx of roads mting. Th proposal for tall buildings btwn St Gorg s and Union St is vn mor prvrs and has no justification whatsovr. Officr Rspons to Rprsntation Th guidanc st out within th SPD is consistnt and rad in conjunction with th xisting planning policy framwork of dsign, hritag and tall building policis, which includs th rlvant savd Southwark Plan policis, Cor Stratgy Policy SP12, th rlvant policis of th London Plan and th NPPF. Th guidanc proposd falls within th rmit of an SPD. Th approach is supportd by our vidnc bas including th Blackfriars Road Urban Dsign Study which has bn prpard in accordanc with CABE and English Hritag Guidanc on Tall Buildings, Mattrs rgarding amnity and microclimat impacts would b assssd at th planning application stag through th rlvant savd Southwark Plan policis, Cor Stratgy Policy 12 and th rlvant policis of th London Plan and othr planning guidanc. Bullt point 14 of SPD 5 sts out furthr guidanc rgarding microclimat Michal Ball Watrl (m) Most of th sits proposd for rdvlopmnt ar Th SPD dos not dsignat proposals sits or provid sit spcific

315 Rp Obj Rf Rf Nam 8 oo Comm unity Dvlo pmnt Group 166 Michal Ball Watrl oo Dtails of Rprsntation simply not dvlopmnt opportunitis: ID NAME STATUS 1 Southbank Towr undr construction Not a Potntial dvlopmnt sit 2 1 Blackfriars Rd undr construction Not a Potntial Dvlopmnt sit 6 6 Paris Gardns undr construction Not a Potntial dvlopmnt sit Blackfriars rd undr construction Not a Potntial dvlopmnt sit Southwark Bridg Road Submittd Application 15 Block T Pabody Squar Listd Building Occupid Affordabl Housing Not a potntial Dvlopmnt sit 19 1 Joan Strt Submittd Application 20 Southwark Collg Submittd Application 22 St Gorgs Mansions Approvd Application 23 UDP sit 8P Garags Approvd Application 24 Fridn Hous Wrong addrss 25 Fridn Hous rpatd should b omittd Blackfriars Modrn block with shops and rsi abov Not a dvlopmnt sit 27 Friars Hous undr construction Not a Potntial dvlopmnt sit Wbbr Strt undr construction Not a Potntial dvlopmnt sit Rushworth Consrvation ara limitd dvlopmnt potntial Glasshill Strt Approvd Application Wbbr St Consrvation ara limitd dvlopmnt potntial Wbbr St Consrvation ara limitd dvlopmnt potntial Wbbr st Consrvation ara limitd dvlopmnt potntial Lancastr St Approvd Application Lancastr Strt Approvd Application 38 St Gorgs Halth Cntr Submittd Application 39 Erland Hill Hous Submittd Application 40 Erlang Car park Submittd Application 41 McClarn Hous 1 St Gorg Occuppid multi story studnt hostl Not a potntial dvlopmnt sit Wstminstr Bridg Rd Approvd Application Givn th work bing undrtakn to produc a Nighbourhood Plan w would arnstly urg you to Officr Rspons to Rprsntation guidanc, as this would byond th scop of th SPD. It dos idntify potntial dvlopmnt sits which ar illustrativ of th hug opportunity for chang within th ara and th nd for a cohrnt framwork. Th SPD has also bn updatd to clarify that th list of sits is not xhaustiv and othr sits may com forward for dvlopmnt. Som of th sits will b compltly rdvlopd, whilst othr sits may xprinc lss chang such as rfurbishmnt or improvmnts to th xisting buildings or surroundings. Figur 3 of th SPD illustrats th rlationship btwn diffrnt planning documnts including supplmntary planning documnts and

316 Rp Obj Rf Rf Nam Charlott 0 6 Glazir Comm unity Dvlo pmnt Group Dtails of Rprsntation chang tack on producing guidanc for th Blackfriars ara, and instad work with local stakholdrs on a mor appropriat plan for th ara which would b adoptd by th local community as wll as th Council Th ida that Blackfriars could b considrd as two sparat sctions of th SPD, du to thir diffrnt charactr is vry wlcom, as th South nd of Blackfriars Road avrag building hight is much lowr than th North and this charactr should b rtaind. Th trminology usd in th SPD nds to b considrd in mor dtail. Words such as idntity and charactr ar hollow as it is not prscriptiv as to what charactr and idntity Southwark would lik to promot and nhanc. I am also concrnd that th SPD would giv th grn light to planning application of th proposd 27 story towr at Eiln Hous, which at this prsnt tim is activly ncouragd within th SPD. This is rally concrning. Ths proposals ar out of touch with th ara. St Gorgs Circus is th landmark in th ara and should rmain so. Th only tim you nd a landmark of a 27 story towr, is whn viwd from out of spac. Having rad th SPD, thr ar assumptions that 'growth' quats 'improvmnt' which sms misguidd. Thr is also rfrnc to th SPD, which stats ' high quality nw dvlopmnt that maks a positiv contribution to th local charactr. I do not agr that a 28 story towr maks a positiv contribution to th local charactr. Th local charactr is rlativly low ris. I do not prsonally agr that th South of Blackfriars Road is a stratgic important location for a tall building - it is not th gatway to th South and is not a transport hub such as E&C. Plas Officr Rspons to Rprsntation nighbourhood plans. Th SPD has bn updatd to mak it clar th nighbourhood plans ar currntly bing prpard. Onc adoptd a nighbourhood plan will hav mor wight than a SPD in th planning procss as it will form part of th council's dvlopmnt plan. At prsnt thr is no adoptd nighbourhood plan for any of th ara covrd by th Blackfriars Road SPD. Th SPD may nd to b rviwd in th futur if a nighbourhood plan is adoptd for any of th SPD ara. A tall building up to 70m in hight could b appropriat at th southrn nd of Blackfriars Road providd that it complis with th dtaild guidanc outlind in SPD 5 and th currnt dvlopmnt plan that includs th rlvant policis of th savd Southwark Plan (2007), Cor Stratgy (2011), London Plan (2011) and othr planning documnts/guidanc, including th NPPF (2012). Th dvlopmnt plan sts out th policis for tall buildings. Th guidanc in th SPD provids dtail on how to implmnt ths dvlopmnt plan policis spcific to Blackfriars Road. Th approach is supportd by our vidnc bas including th Blackfriars Road Urban Dsign Study which has bn prpard in accordanc with CABE and English Hritag Guidanc on Tall Buildings, In light of consultation rsponss and to add clarity to th guidanc rlating to St Gorg s Circus in SPD 5, th SPD has bn updatd to clarify that a tall building could provid a focal point at th southrn nd of Blackfriars Road up to 70m. A tall building should also sustain, nhanc or bttr rval th local hritag assts.

317 Rp Obj Rf Rf Nam Charlott Charlott Charlott Charlott 4 6 Glazir Glazir Glazir Glazir Dtails of Rprsntation lts hav a paus and brathing spac rtaind btwn all ths othr high-ris proposals. W also want South of Blackfriars Road to continu to b a plac popl want to liv, yt my nighbours will hav no dirct sunlight, whn th SPD activly ncourags a 28 story towr on th door stp It would also b good to s mor vision and dtail on grning within th SPD, from balconis, grn roofs and walls as wll as strt grning. Rtain historic charactr and hritag, building hights and strt pattrns. Gt rid of crummy rdundant offics. Mak th strt bttr for pdstrians, a plac to stop and paus rathr than rush through I do not prsonally agr that th South of Blackfriars Road is a stratgic important location for a tall building - it is not th gatway to th South and is not a transport hub such as E&C. Plas lts hav a paus and brathing spac rtaind btwn all ths othr high-ris proposals. W also want South of Blackfriars Road to continu to b a plac popl want to liv, yt my nighbours will hav no dirct sunlight, whn th SPD activly ncourags a 28 story towr on th door stp. Officr Rspons to Rprsntation Th SPD sts out gnral guidanc for landscaping, grning and grn infrastructur. Furthr dtail is st out in th Sustainabl Dsign and Construction SPD and th Opn Spacs Stratgy, as wll as th London Plan. A nw paragraph has bn addd to SPD 3 "w ar doing this bcaus" to provid furthr background on th Opn Spacs Stratgy rcommndations. th xisting planning policy framwork of dsign, hritag and tall building policis (th rlvant savd Southwark Plan policis, Cor Stratgy Policy 12, th rlvant policis of th London Plan and th NPPF) and th guidanc in th SPD sks to prsrv and nhanc th ara's hritag assts and thir sttings. Th SPD also provids guidanc for th nw buildings, building hights and public ralm that is informd by our vidnc bas. An improvd pdstrian nvironmnt is ky aspiration of th guidanc in SPD, spcially through SPD 3 and SPD 6. A tall building up to 70m in hight could b appropriat at th southrn nd of Blackfriars Road providd that it complis with th dtaild guidanc outlind in SPD 5 and th currnt dvlopmnt plan that includs th rlvant policis of th savd Southwark Plan (2007), Cor Stratgy (2011), London Plan (2011) and othr planning documnts/guidanc, including th NPPF (2012). Th dvlopmnt plan sts out th policis for tall buildings. Th guidanc in th SPD provids dtail on how to implmnt ths dvlopmnt plan policis spcific to Blackfriars Road. Th approach is supportd by our vidnc bas including th Blackfriars Road Urban Dsign Study which has bn prpard in accordanc with CABE and English Hritag Guidanc on Tall Buildings, In light of consultation rsponss and to add clarity to th guidanc rlating to St Gorg s Circus in SPD 5, th SPD has bn updatd to clarify that a tall

318 Rp Obj Rf Rf Nam Adl Morris Libral 6 7 Dmoc rats Adl Morris Libral 7 7 Dmoc rats Dtails of Rprsntation Bfor w bgin w would lik to qustion why this SPD is bing rushd through now whn w hav two nighbourhood plans in th piplin covring larg parts of this ara. 1. Introduction - Para1.1.2 dos not rflct th fact that this is a historic strt whr many popl hav bn living for hundrds of yars. Officr Rspons to Rprsntation building could provid a focal point at th southrn nd of Blackfriars Road up to 70m. A tall building should also sustain, nhanc or bttr rval th local hritag assts. Figur 3 of th SPD illustrats th rlationship btwn diffrnt planning documnts including supplmntary planning documnts and nighbourhood plans. Th SPD has bn updatd to mak it clar th nighbourhood plans ar currntly bing prpard. Onc adoptd a nighbourhood plan will hav mor wight than a SPD in th planning procss as it will form part of th council's dvlopmnt plan. At prsnt thr is no adoptd nighbourhood plan for any of th ara covrd by th Blackfriars Road SPD. Th SPD may nd to b rviwd in th futur if a nighbourhood plan is adoptd for any of th SPD ara. Notd. Th SPD is intndd to bnfit a wid rang of groups including xisting and nw rsidnts. Th SPD sks to mt th nds of rsidnts whilst also managing th prssur for nw dvlopmnt. Th SPD has bn updatd to mak it clarr that th mrging vision and th SPD sks to nsur that dvlopmnt mts th nds of xisting and nw rsidnts whilst also attracting nw dvlopmnt. Rsidnts will bnfit from th incras rang of uss including mor shops, srvics and businsss along th Blackfriars Road Adl Morris Libral Figur 2: Boundaris of th SPD -W not th An xplanation of th boundary is st out within th SPD. It includs 8 7 Dmoc concrns and opposition of rsidnts about th currnt th whol of th Blackfriars Road and som of th surrounding ara. It rats proposd boundaris of th Blackfriars Road SPD, includs th surrounding ara as th surrounding ara is also likly to particularly th inclusion of th ara to th south of St s som dvlopmnt and improvmnts, particularly possibl Gorg s Circus (south of Borough Road and Lambth improvmnts to public ralm. Wording has bn addd to th SPD to Road). -W not th xtndd boundaris of th SPD mak it clarr that th charactr and historic valu of much of th to th ward boundaris on th wst of Blackfriars Road surrounding ara will continu to b protctd and nhancd. and to Hopton Strt/Grat Suffolk Strt on th ast. W qustion why ths boundaris xtnd so far whn th SPD is practically silnt on ths strts and aras - thir charactr, how thy should b dvlopd or how xisting hritag and buildings will b protctd Adl Morris Libral 2. Vision for Blackfriars Road (p.10-11) 2.2 Our Th idas for th mrging vision st out th council's aspirations for

319 Rp Obj Rf Rf Nam 9 7 Dmoc rats Dtails of Rprsntation mrging vision In rgards to th mrging vision w would mak th following points Blackfriars Road will hav its own distinct idntity as a livly and vibrant ara -It is not clar from th documnt what this distinct idntity will or should b in th viw of Southwark Council and th documnt fails in our viw to suggst a charactr for th Blackfriars Road, or to acknowldg in our viw that th road is not a singl ntity in rgards to its charactr. Th sction to th south of Union Strt and Th Cut is prdominatly rsidntial and low scal with buildings lss than 10 storys, whil th northrn sction prdominatly has businsss on ithr sid of th road, with th xcption of Christ Church. Thr ar of cours a numbr of rsidnts living bhind th businss proprtis on th northrn sction including th Rochstr Estat, Quadrant Hous, Rivr & Rnni Courts and Falcon Point. -It is not clar what th Council's dfinition of a "livly and vibrant ara" is. This nds to b clarifid and rfind - particularly in th contxt of th Council's licnsing saturation policy and th rcntly publishd crim and antisocial bhaviour statistics for th ward. "Cultural, lisur, arts and ntrtainmnt uss will also b ncouragd..." -It is not clar how ths uss ar bing ncouragd, othr than asking for D class uss in nw dvlopmnts. Opportunitis to incras th amount and typ of dvlopmnt will b maximisd -W do not agr that this is an appropriat aspiration without som qualification. As statd this appars to b a grn light for unrgulatd ovrdvlopmnt, which could hav a ngativ impact on th quality of lif for rsidnts and th charactr and hritag of th road. Social and community infrastructur will continu to b improvd -W think th statmnt is too vagu and unclar, and maks no rfrnc to how xisting Officr Rspons to Rprsntation th SPD ara. As st out within th SPD, ths idas will b furthr dvlopd through th prparation of th Nw Southwark Plan, which will vntually rplac th Cor Stratgy and th savd Southwark Plan. As st out within th SPD th Blackfriars Road is a ky rout running from th Rivr Thams to St Gorg's Circus and th SPD focuss mostly on th road itslf. It is appropriat to includ th whol of th road within th mrging vision as a ky rout and a historic boulvard. Information within th charactri studis, both for Banksid, Borough and London Bridg Opportunity Ara and Elphant and Castl Opportunity Ara idntify ky aspcts of charactr and managmnt principls, and hav informd th prparation of th SPD. With rfrnc to "a livly and vibrant ara" th SPD has bn updatd within th supporting txt to SPD 2 to rfr to th council's licnsing saturation ara. With rgards to how cultural tc uss will b ncourags th SPD ncourags this uss in accordanc with Cor Stratgy and savd Southwark Plan policis. Ths policis and also proposals sits allocations will b rviwd through th prparation of th Nw Southwark Plan.

320 Rp Obj Rf Rf Nam Dtails of Rprsntation rsidnts will b consultd as to what thir prioritis ar in rgards to nw or improvd infrastructur W will work with Ntwork Rail to rfurbish spac undr railway archs to provid a rang of uss including small businsss, shops, cafs and rstaurants. -A rcnt planning dcision in our ward in rgards to th Union Strt railway archs show that an unqualifid statmnt to support rfurbishing th railway archs dos not hav th dsird ffct of nsuring a rang of classs of us and typs of businsss. Th SPD should b clarr in supporting Policy 1.5 Small Businss Units in th Southwark Plan to nsur that th archs ar rfurbishd in a way that nsurs thy rmain affordabl and appropriat to a divrs rang of local SME businsss. -Thr ar many stablishd businsss in th railway archs and mor should b mad of how thy will b protctd. Thr will also b tallr buildings at th important locations of Southwark tub station and on th main junction of St Gorg s Circus -Whil th northrn sction of Blackfriars Road (north of Union Strt/Th Cut) has bn considrd suitabl for tallr buildings w would ask Southwark Council to not th strong opposition of xisting rsidnts to a tall building at Southwark tub and th ovrwhlming opposition to a tall building at St Gorg s Circus. W add our strong opposition to tall buildings on th southrn nd of Blackfriars Road Adl Morris Libral Figur 5: Potntial Dvlopmnt Sits and Tabl 1: 0 7 Dmoc Potntial dvlopmnt sits (p.12-13) rats Blackfriars Road -Th xisting building should not in our viw b considrd as a potntial dvlopmnt sit as it has architctural mrit. 15. Block T, Pabody Squar, Blackfriars Road -Th location and dscription do not match. This is not Block T, Pabody Squar, Blackfriars Road but rathr an addrss on ithr Union Strt or Grat Suffolk Strt 25. Fridn Officr Rspons to Rprsntation W hav updatd Figur 85- now Figur 6 - and Tabl 1 with an updatd list of potntial dvlopmnt sits. Th SPD dos not dsignat proposals sits or provid sit spcific guidanc, as this would byond th scop of th SPD. It dos idntify potntial dvlopmnt sits which ar illustrativ of th hug opportunity for chang within th ara and th nd for a cohrnt framwork. Th SPD has also bn updatd to clarify that th list of sits is not xhaustiv and othr sits may com forward for dvlopmnt. Som of th sits will b compltly rdvlopd, whilst othr sits may

321 Rp Obj Rf Rf Nam Adl Morris Libral 1 7 Dmoc rats Dtails of Rprsntation Hous, Blackfriars Road -W bliv this is mor likly to b Valntin Plac as th sam addrss is usd 24 and St Gorgs Halth Cntr, Blackfriars Road -This appars to includ Tadworth Hous, which is a council block with 27 proprtis. W would oppos th rdvlopmnt of this building without th consnt of tnants and rsidnts. 43. TfL Bakrloo Sidings and 7 St Gorg's Circus W cho th concrns of rsidnts in th Albrt Association about th snsitiv natur of this ara in rgards to th Wst Squar Consrvation ara and rqust that th suitability of th sit is rconsidrd or clarr guidlins givn as to how this sit could b appropriatly rdvlopd. 3. Stratgis and guidanc (p.14-15) SPD1 Businss Spac 3.5 Th protction of offic spac dos not sm to b bing applid to th dvlopmnt at Hill Hous/Erlang Hous. What judgmnt is usd to dcid whn it is appropriat to swap offic floorspac for rtail? Supporting us of th railway archs for a rang of businss uss (B1) including small businss spac, crativ and cultural industris, light industrial uss and appropriat A or D class uss -As statd abov in practic this policy aspiration will not b dlivrd du to a failur to nsur Policy 1.5 Small Businss Units is proprly intrprtd and nforcd to nsur that rfurbishmnt dos not rduc th varity of uss in railway archs and nsur that ths spacs rmain affordabl compard to mor traditional businss unit spacs. Officr Rspons to Rprsntation xprinc lss chang such as rfurbishmnt or improvmnts to th xisting buildings or surroundings. It is important for th SPD guidanc to b rad in conjunction with both adoptd planning policy. This is mad clar within th SPD. Th rquirmnt in SPD1 to rtain or rplac xisting businss spac is consistnt with borough-wid policis. Cor Stratgy policy 10 and savd Southwark Plan policy 1.4 rquir applicants to dmonstrat th loss of businss floorspac (B1, B2 and B8) against a rang of xcption critria whr th sit falls within a rang of locations, which includ (amongst othrs) th CAZ. Land outsid ths locations can b rlasd for othr uss. This stratgy nsurs th rtntion of xisting businss floorspac whr this is appropriat, to nsur thr continus to b spac availabl for stablishd businsss to mov into th ara and for start up businsss to stablish thmslvs. Th council considrs that it is rasonabl to xpct applicants to dmonstrat that in th aras whr businss floorspac is protctd that thr is a lack of dmand or viability, or physical and/or nvironmntal constraints which prclud r-provision or an uplift of mploymnt spac (Southwark Plan Policy 1.4). It is considrd that this is consistnt with paragraph 21 and 22 of th NPPF and provids adquat flxibility. Policy 1.4 allows th rplacmnt of businss floorspac with class A (rtail) or othr suitabl town cntr uss. Th SPD includs a fact box to xplain town cntr uss. W hav amndd th supporting txt to includ rfrnc to Policy 1.5 and th

322 Rp Obj Rf Rf Nam Dtails of Rprsntation Adl Morris Libral W ar doing this bcaus 3.6 Th railway is a 2 7 Dmoc dominant fatur of th ara and many of th archs rats hav alrady bn convrtd to provid a significant amount of spac for small businsss -As statd abov whil a numbr of railway archs in th Blackfriars Road SPD ara hav alrady bn convrtd, this has rsultd in a varity of uss bing rplacd by B1 us only, which has had th ffct of forcing out xisting businsss, providing srvics to local rsidnts. -W ar not awar of any community uss bing promotd in railway archs Adl Morris Libral SPD 2 Mixd us town cntr (p.16) Supporting 3 7 Dmoc proposals for nw hotls and othr forms of visitor rats accommodation (C1) to nsur thr is a good supply of accommodation for visitors and to contribut to a mix of uss and mploymnt opportunitis. -Whil w wlcom and acknowldg th nd for additional hotl rooms in London, w also bliv that th numbr of hotls in SE1 and in th proposd ara of th Blackfriars Road SPD should b rstrictd to nsur that othr important planning nds in th ara for xisting rsidnts such as affordabl (including social rnt) housing, family sizd units and additional public srvics ar prioritisd and dlivrd Adl Morris Libral 4 7 Dmoc rats Officr Rspons to Rprsntation rquirmnt to rplac small businss units within nw dvlopmnt. W hav amndd th supporting txt to SPD2 to includ rfrnc to Policy 1.5 and th rquirmnt to rplac small businss units within nw dvlopmnt. It is important for th SPD guidanc to b rad in conjunction with both adoptd planning policy. Th savd Southwark Plan policy 1.5 allows th chang of us of th railway archs for a varity of uss, including shops, cafs, rstaurants, light industry and othr typs of businss, crativ uss and community uss, providd that th proposd us dos not hav an unaccptabl impact on th amnitis of nighbouring occupirs, or on car parking, traffic congstion and road safty. Th SPD ncourags a mixtur of town cntr uss to b dvlopd alongsid businss uss and rsidntial. Nw hotl proposals will b assssd against ths rlvant planning policis and a considration of th impact upon local amnity and th balanc of land uss will also b takn into account. It is important for th SPD guidanc to b rad in conjunction with both adoptd planning policy. Th Cor Stratgy sts out th borough s stratgy for housing and th targts ovr th plan priod which includ th targt for th opportunity ara. SPD 2 provids sts out our support for th provision of nw social and community infrastructur. This is furthr xplaind in sction 4.4 on infrastructur provision. Considring th impact of all proposals for nw or W hav amndd th supporting txt to includ rfrnc to th xpandd food, drink, vning and night tim conomy Borough and Banksid licnsing saturation ara, which is a local uss, whthr cumulativly or individually, on th policy that addrsss th cumulativ impact of licnsd prmiss. All ovrall mix of uss in th ara and on local amnity. - applications for nw or varid prmiss licncs for night-clubs, public W wlcom this acknowldgmnt but would rqust houss and bars, rstaurants and cafs, off-licncs, suprmarkts that this point is strngthnd to tak into account th and grocrs nd to addrss th saturation concrns st out in th vry high lvls of ASB in Cathdrals Ward and th council s licnsing policy within th prmiss oprating schdul. W

323 Rp Obj Rf Rf Nam Dtails of Rprsntation Officr Rspons to Rprsntation ngativ impact on xisting rsidntial amnity. W rcognis that if prmiss ar not proprly managd and controlld, also bliv th SPD should acknowldg th fact that thy could bcom a srious sourc of crim and disordr or antisocial bhaviour problms. Th Council will xpct applicants for this is an ara covrd by an xisting saturation policy. prmiss licncs to dmonstrat in thir oprating schduls that suitabl and sufficint stps ar to b takn to prvnt crim and disordr in and around th vicinity of thir prmiss and vnts Adl Morris Libral Supporting th provision of nw social infrastructur 5 7 Dmoc and community facilitis as part of a mixd us rats dvlopmnts. -Whil this aspiration is wlcom thr is no dtail or acknowldgmnt of what ths nw social and community facilitis should b or what is rquird. This statmnt would b strongr if a study of xisting facilitis had bn carrid out or includd and xisting rsidnts had bn consultd about what thy bliv is ndd and should b a priority Th SPD and othr planning policy documnts provid th framwork for th provision of infrastructur to support dvlopmnt. SPD 2: Mixd us town cntr sts out that w will support th provision of nw social infrastructur and community facilitis as part of mixd us dvlopmnts. SPD 3: Public ralm and opn spac rfrs to th continud protction of th thr protctd opn spacs and ncouraging furthr linkags and nw spacs. Sction 4 of th SPD rfrs spcifically to infrastructur, crossing rfrring to th community infrastructur lvy (CIL) and sction 106 planning obligations to hlp nsur th dlivry of ky infrastructur to mitigat th impact of dvlopmnt. Infrastructur is covrd within borough-wid planning documnts with th ovrarching policy 14 of th Cor Stratgy rcognising that nw dvlopmnt in th borough nds to b supportd by adquat infrastructur, including social, nvironmntal and physical infrastructur. Th borough s Infrastructur Plan, idntifis stratgic infrastructur which is ndd to support growth and dvlopmnt in th borough ovr th liftim of th Cor Stratgy ( ). Whr possibl it idntifis th cost of infrastructur to providd, any committd sourcs of funding which will b usd to dlivr it and th organis rsponsibl. It also idntifis th funding gap i.. th gap btwn known commitmnts and th total cost of infrastructur rquird. Whn it is adoptd, Southwark s CIL will b usd to contribut towards bridging this funding gap. Funds armarkd for infrastructur in th Council s capital invstmnt programm also will

324 Rp Obj Rf Rf Nam Adl Morris Libral 6 7 Dmoc rats Adl Morris Libral 7 7 Dmoc rats Dtails of Rprsntation W ar doing this bcaus (p.17-18) 3.7 Land us, is prdominantly commrcial, with pockts of rsidntial in th south-ast, wst, and th north, clos to th rivr -W do not bliv this is an accurat dscription of th mak up of th road. As w hav indicatd arlir th southrn nd of Blackfriars Road (south of Union Strt/Th Cut) is prdominantly rsidntial and thrfor to dscrib it as pockts of rsidntial is mislading and fails to acknowldg th dnsity of th xisting rsidntial community. Whil th northrn nd is prdominantly frontd by businsss thr ar significant numbrs of rsidnts st bhind ths buildings on ithr sid of th road. 3.8 Southwark s Rtail Capacity Study (2009) suggst that th Banksid and Borough district town cntr should continu to b a cntr for local nds and spcialist, indpndnt rtailing and any nw rtail schms can b supportd by workrs, tourists and rsidnts, coming forward on an incrmntal basis. - Whil th aspiration for th district town cntr continuing to b a cntr for local nds and spcialist, indpndnt rtailing is wlcom in practic w hav sn a loss of indpndnt rtailrs in SE1, and a commitmnt to smallr affordabl units and mor spcific policis about th varity of rtail in a parad or block, is probably th only way to stop rtail chains pushing out indpndnt rtailrs and maintaining divrsity. Officr Rspons to Rprsntation hlp to improv infrastructur provision. Th council ar currntly prparing our draft community infrastructur charging schdul and an updatd sction 106 SPD. Adoption is plannd for It is appropriat to look at th provision of infrastructur at a borough-wid lvl through ths ddicatd documnts rathr than through th Blackfriars Road SPD. W hav amndd th supporting txt to clarify that th land us in th SPD ara is mixd with a larg numbr of commrcial buildings alongsid aras of rsidntial dvlopmnt. SPD2 rcogniss thr is an opportunity to promot a much widr mix of town cntr uss as part of th dvlopmnt of th potntial opportunity sits st out in th SPD. W hav amndd SPD2 bullt 1 to st out ncouragmnt for flxibly dsignd spac to accommodat a rang of unit sizs in nw dvlopmnt. Th SPD cannot dsignat land us on dvlopmnt sits, howvr w will considr th rang of uss that would b appropriat for allocatd dvlopmnt sits through th prparation of th Nw Southwark Plan and its accompanying proposal sits map Adl Morris Libral 3.10 Th London Plan aims to provid a nt incras Th hotl bd spacs forcast for Southwark should b tratd as

325 Rp Obj Rf Rf Nam 8 7 Dmoc rats Adl Morris Libral 9 7 Dmoc rats Dtails of Rprsntation of 40,000 hotl bdrooms. This amounts to 2,500 ovr this priod ( ) for Southwark. Sinc 2007, approximatly 1625 hotl bd spacs hav bn compltd and approximatly 850 bd spacs ar currntly in th piplin in th borough. Within th SPD ara thr ar svn hotls, with an additional thr hotls just byond th SPD boundary. -As statd arlir w bliv th amount of hotls should b limitd, so that mor important planning priority rquirmnts for th ara ar dlivrd. W can s from th figurs that Southwark has almost mt its targt of 2,500 spacs alrady, dspit th targt running until Th dvlopmnt of th vning and night-tim conomy will hlp kp th town cntr livly and saf at diffrnt tims of th day and provid mor lisur opportunitis for local rsidnts, visitors and workrs. Carful considration nds to b givn to masurs which mitigat any ngativ impacts of uss to protct th amnity of narby rsidnts. -Again as statd arlir th SPD should acknowldg th xistnc of a licnsing saturation policy, th high lvls of ASB and th larg numbr of xisting rsidntial proprtis within th SPD ara. This should rsult in strongr safguards and policis to avoid ngativ impacts on rsidntial amnity. Thr ar no dtails or suggstions of how th night tim conomy will b managd to protct th amnity of narby rsidnts. Officr Rspons to Rprsntation indicativ only, and local circumstancs nd also to b factord in. Th SPD ara is within th Cntral Activitis Zon and Banksid, Borough and London Bridg Opportunity Ara and part of th Elphant and Castl Opportunity Ara which ar aras promotd in th London Plan to accommodat stratgically important hotl provision. Arts, cultural and tourism activitis hav flourishd in Southwark in th last dcad, particularly in th Stratgic Cultural Ara in th north of th borough and th CAZ. Banksid, Borough and London Bridg has consquntly xprincd a growth in th numbr of hotls to support this incrasing visitor conomy. Th SPD2 provids guidanc to support stratgic policy 10 Jobs and businss of th Cor Stratgy (2011) which sts out th council will allow th dvlopmnt of hotls within th town cntrs, th stratgic cultural aras, and placs with good accss to public transport srvics, providing that ths do not harm th local charactr. Policy 10 and SPD 2 ar also supplmntd by th savd policy 1.12 of th Southwark Plan which addrsss visitor accommodation. Nw hotl proposals will b assssd against ths rlvant planning policis and a considration of th impact upon local amnity and th balanc of land uss will also b takn into account. W hav amndd th supporting txt to includ rfrnc to th Borough and Banksid licnsing saturation ara, which is a local policy that addrsss th cumulativ impact of licnsd prmiss. Savd Southwark Plan policis will b usd to assss th impact of dvlopmnt schms on local amnity.

326 Rp Obj Rf Rf Nam Dtails of Rprsntation Adl Morris Libral 3.15 Improvmnts to social infrastructur such as 0 7 Dmoc schools, halth facilitis, post offics and polic rats facilitis ar addrssd through xtrnal stakholdr s asst managmnt plans and through th council s Capital programm and infrastructur planning procss. Th nd for nw infrastructur will b kpt undr rviw as th ara changs. -Whil w wlcom th acknowldgmnt for improvmnts to social infrastructur w bliv this undrstats th xisting prssurs on th social infrastructur and would argu that a commitmnt to nw and incrasd capacity is rquird and this should b supportd by an vidnc basd projction of th numbrs xpctd to b living, working and visiting in th ara. In addition, it is insufficint to stat that xtrnal stakholdrs will manag th social infrastructur if thr ar no sits availabl for any nw schools, halth facilitis tc to b built. This cannot b lft to chanc whn th population is st to xpand at such a rat W wlcom activ frontags on th strt but thy nd to provid an appropriat mix of sizs and uss W wlcom th proposal for nw and maningful public spacs, and not vast amounts of "public opn spac" that hav no purpos or valu. Howvr, w would lik to s a clar dfinition of "maningful". Th illustration of th Isablla St archs givs a fals sns of what is thr - bhind th grnry ar livly prmiss that caus considrabl amnity issus for local rsidnts. Ths outdoor lisur spacs nd carful implmntation and managmnt Thr sms to b som mixd mssaging hr. Th road alrady has distinct charactr, yt th SPD is suggsting that it nds to b cratd. Is it suggsting that th old distinct charactr should b rplacd by a nw on? 3.29 Th rcntly approvd Lindn Homs dvlopmnt has Officr Rspons to Rprsntation Th SPD and othr planning policy documnts provid th framwork for th provision of infrastructur to support dvlopmnt. SPD 2: Mixd us town cntr sts out that w will support th provision of nw social infrastructur and community facilitis as part of mixd us dvlopmnts. SPD 3: Public ralm and opn spac rfrs to th continud protction of th thr protctd opn spacs and ncouraging furthr linkags and nw spacs. Sction 4 of th SPD rfrs spcifically to infrastructur, crossing rfrring to th community infrastructur lvy (CIL) and sction 106 planning obligations to hlp nsur th dlivry of ky infrastructur to mitigat th impact of dvlopmnt. Infrastructur is covrd within borough-wid planning documnts with th ovrarching policy 14 of th Cor Stratgy rcognising that nw dvlopmnt in th borough nds to b supportd by adquat infrastructur, including social, nvironmntal and physical infrastructur. Th borough s Infrastructur Plan, idntifis stratgic infrastructur which is ndd to support growth and dvlopmnt in th borough ovr th liftim of th Cor Stratgy ( ). Whr possibl it idntifis th cost of infrastructur to providd, any committd sourcs of funding which will b usd to dlivr it and th organis rsponsibl. It also idntifis th funding gap i.. th gap btwn known commitmnts and th total cost of infrastructur rquird. Whn it is adoptd, Southwark s CIL will b usd to contribut towards bridging this funding gap. Funds armarkd for infrastructur in th Council s capital invstmnt programm also will hlp to improv infrastructur provision. Th council ar currntly prparing our draft community infrastructur charging schdul and an updatd sction 106 SPD. Adoption is plannd for It is appropriat to look at th provision of infrastructur at a borough-wid lvl through ths ddicatd documnts rathr than through th Blackfriars Road SPD.

327 Rp Obj Rf Rf Nam Dtails of Rprsntation alrady gon against this by proposing to knock down th xisting charactr buildings and rplac thm with an ovr dns block. Officr Rspons to Rprsntation Adl Morris Libral SPD 3 Public ralm and opn spac (p.19) Ensur Notd. Th guidanc in SPD 3 ncourags public ralm and opn 1 7 Dmoc thr is a clar distinction btwn public and privat spac improvmnts within th ara, including th cration of nw rats spac -W would qustion what th intntion of this public spacs. Th rquirmnt for a clar distinction btwn public statmnt is in rgards to public ralm and opn and privat spac sks to improv th lgibility of spac so that it spac. Whil w acknowldg that thr will b som ncourag popl to us public spac that is availabl to thm. privat spac for businsss and rsidnts, w ar broadly in favour of public ralm and opn spac bing opn to all, whil acknowldging th importanc of crtain spacs to xisting communitis such as Nlson Squar and Christ Church Gardns Adl Morris Libral SPD 4 Built form and hritag (p.24) SPD 5 Building 2 7 Dmoc Hights (p.27) A tall building, of a hight of up 70 rats mtrs should provid a focal point at Southwark tub cntr -Although th northrn nd of Blackfriars Road is considrd suitabl for tall buildings w not th strong opposition from local rsidnts to a tall building in this location Adl Morris Libral 3 7 Dmoc rats A tall building, of a hight up to 70 mtrs should provid a focal point at St Gorg s Circus. Tall buildings must b st back from th Circus. -W strongly oppos th location of a tall building up to 70 mtrs at th southrn nd of Blackfriars Road. W do not bliv any cas has bn mad for a tall building in this location, whn thr ar no xisting buildings of this hight in this sction of th road. Furthrmor, w bliv a tall building in this location will hav a dtrimntal impact on xisting consrvation buildings A tall building up to 70m in hight could b appropriat at th southrn nd of Blackfriars Road providd that it complis with th dtaild guidanc outlind in SPD 5 and th currnt dvlopmnt plan that includs th rlvant policis of th savd Southwark Plan (2007), Cor Stratgy (2011), London Plan (2011) and othr planning documnts/guidanc, including th NPPF (2012). Th dvlopmnt plan sts out th policis for tall buildings. Th guidanc in th SPD provids dtail on how to implmnt ths dvlopmnt plan policis spcific to Blackfriars Road. Th approach is supportd by our vidnc bas including th Blackfriars Road Urban Dsign Study which has bn prpard in accordanc with CABE and English Hritag Guidanc on Tall Buildings, Basd on our vidnc bas and providd that dvlopmnt was consistnt with th guidanc outlind in SPD 5 and xisting planning policy framwork of dsign, hritag and tall building policis (th rlvant savd Southwark Plan policis, Cor Stratgy Policy SP12, th rlvant policis of th London Plan and th NPPF) a building up to 70m could b appropriat at th southrn nd of Blackfriars Road. Th approach is supportd by our vidnc bas including th Blackfriars Road Urban Dsign Study which has bn prpard in accordanc with CABE and English Hritag Guidanc on Tall Buildings, In light of consultation rsponss and to add clarity

328 Rp Obj Rf Rf Nam Adl Morris Libral 4 7 Dmoc rats Dtails of Rprsntation and aras in that sction of th road, particularly th Grad II Blackfriars Pabody stat and th St Gorg s Circus consrvation ara. A tall building would nd to b st back from th circus bcaus of th consrvation rstraints and thrfor thr is no justification for th argumnt that it would provid a focal point at th start of Blackfriars Rd. Buildings of up to 30m along Blackfriars Road btwn Southwark tub station and St Gorg s Circus -W do not bliv buildings of up to 30m should b ncouragd along th full lngth of this strtch of Blackfriars Road, but rathr that buildings of up to 30m will b considrd whr appropriat, and gnrally opposd whr thy will hav a dtrimntal impact on th St Gorg s Circus consrvation ara and th Grad II Blackfriars Pabody stat. Officr Rspons to Rprsntation to th guidanc rlating to St Gorg s Circus in SPD 5, th SPD has bn updatd to clarify that a tall building could provid a focal point at th southrn nd of Blackfriars Road up to 70m. A tall building should also sustain, nhanc or bttr rval th local hritag assts. Th guidanc outlind in SPD 5 for th spin of Blackfriars Road would b appropriat providd it complid with th guidanc in SPD5 and th xisting planning policy framwork of dsign, hritag and tall building policis (th rlvant savd Southwark Plan policis, Cor Stratgy Policy SP12, th rlvant policis of th London Plan and th NPPF). Th approach is supportd by our vidnc bas including th Blackfriars Road Urban Dsign Study which has bn prpard in accordanc with CABE and English Hritag Guidanc on Tall Buildings, Adl Morris Libral In addition to th abov critria, buildings which ar This rquirmnt is consistnt with London Plan 7.7. Th viability and 5 7 Dmoc significantly highr than 70 mtrs must Includ a fasibility of a publically accssibl spac would b assssd at rats publicly accssibl ara on uppr floors whr fasibl planning application stag. in th tallst buildings in th north of Blackfriars Road. -W do not support a blankt commitmnt to support a publicly accssibl ara on uppr floors of buildings highr than 70 mtrs, particularly if this is part of th sction 106 or futur CIL contributions. Any publicly accssibl ara should b providd by th dvlopr as part of th building dsign and costs, and should not b allowd to impact on th viability of th schm or its ability to mt th Council's policy Adl Morris Libral 6 7 Dmoc rats 3.31 At th cntr and south of Blackfriars Road tallr hights would provid focal points to mphasis th main transport nod of Southwark tub at th junction of Union Strt and Th Cut as wll as St Gorg s Circus a main nod and junction of London Road and Borough Road. -W do not support th suggstion that tallr buildings ar rquird to provid focal points Th building hights guidanc outlind in SPD 5 is considrd appropriat, providd that dvlopmnt complid with th guidanc outlind in SPD5 and th xisting planning policy framwork of dsign, hritag and tall building policis (th rlvant savd Southwark Plan policis, Cor Stratgy Policy 12, th rlvant policis of th London Plan and th NPPF). Th approach is supportd by our vidnc bas including th Blackfriars Road Urban Dsign Study which has bn

329 Rp Obj Rf Rf Nam Adl Morris Libral 7 7 Dmoc rats Adl Morris Libral Activ travl 8 7 Dmoc rats Alx Trouton NHS South wark 209 Alx Trouton NHS South wark Dtails of Rprsntation for Southwark tub and St Gorg s Circus. ly, w would point out that th Southwark tub junction alrady has a tall signatur building-th Palstra Building. Scondly, w do not accpt that th only way to provid a focal point is to hav a high building and thrfor 4. Implmntation (p.33) W will nsur that w continu to ngag with th many groups and individuals including ky stakholdrs such as local businsss, South Bank Employrs Group, Watrloo Quartr, Bttr Banksid, Banksid Opn Spacs Trust, Lambth Council, tnants and rsidnts associations, SE1 Safr Road Forum, South Bank Univrsity, Banksid Nighbourhood Forum, Blackfriars Landownrs Forum, Southwark Living Strts and Southwark Cyclists. W will also look at opportunitis for ngagmnt with othr groups and rsidnts. -W bliv that rsidnts living in th ara should hav a highr profil in th list of thos to b ngagd, followd by th nighbourhood forum(s), xisting businsss and othr stakholdrs in th Blackfriars Road SPD ara. W also think ward councillors should b includd in th list as th dmocratically lctd rprsntativs. A numbr of dirct positiv impacts on halth could b xpctd, for xampl th cration of nvironmnts conduciv to activ travl will hav bnficial ffcts particularly for obsity, diabts and cardiovascular disas (Hardman & Stnsal, 2009 Gratr us of th strt nvironmnt, for xampl for strt markts, could promot a sns of community which will fostr a sns of wllbing Officr Rspons to Rprsntation prpard in accordanc with CABE and English Hritag Guidanc on Tall Buildings, Sction 4 of th SPD on implmntation highlights th importanc of working with all our partnrs including rsidnts and th local community. Sction 4.1 spcifically rfrs to continuing to ngag with th local community and rsidnts, and similarly sction 4.2 rfrs to continuing to ngag with many groups and ky stakholdrs as wll as look at opportunitis for ngagmnt with othr groups and rsidnts. Rsidnts ar clarly within th list of popl th council ngagd with. W do not think it is appropriat to mntion ward mmbrs spcifically in th list of groups and individuals. Notd. Notd. Furthr information on th potntial impact of th SPD guidanc on social, nvironmntal and conomic sustainability is st out in our sustainability appraisal (SA). Th SA assssd th likly impact of th SPD on 17 indicators including indicators spcific to sustainabl transport. Notd.

330 Rp Obj Rf Rf Nam 209 Alx Trouton NHS South wark 209 Alx Trouton NHS South wark 209 Alx Trouton NHS South wark 209 Alx Trouton NHS South wark 209 Alx Trouton NHS South wark Dtails of Rprsntation (Calv Blanco, 2013). Incrasd mploymnt opportunitis, as wll as an improvd public ralm and provision of grn spacs/squars and strt trs ar likly to hav a bnficial impact on mntal halth (Ward-Thompson, 2011). An incras in th numbr of wll-dsignd opn spacs and squars could nhanc opportunitis for conviviality, xrcis and childrn s play. Notd. Officr Rspons to Rprsntation Play spac is covrd in th Rsidntial Dsign Standards SPD, th London Plan and Play and Informal Rcration SPG. Th stipulation that inclusiv dsign principls b Notd. Savd Southwark plan policy 1.7 sks to scur public applid to all buildings and spacs is wlcomd as this amnitis on larg dvlopmnt sits. is likly to provid gratr amnity and opportunitis for popl with disabilitis. This inclusivity will nd to considr not only mobility issus but popl with othr forms of disability (.g. snsory, larning.) Provision of accssibl public toilts will also nd to b considrd Howvr, thr ar som potntial dirct ngativ Th SPD sts out clar building hights guidanc. Th approach is impacts on halth also. Th proposd tall buildings supportd by our vidnc bas including th Blackfriars Road Urban hav a potntial for rducing possibilitis of social Dsign Study which has bn prpard in accordanc with CABE and cohsion as thr is alrady vidnc from English Hritag Guidanc on Tall Buildings, This vidnc consultation xrciss that thy ar not dsird by th bas rvals that hights abov thos outlind in th guidanc would xisting local rsidnts. Thr is also UK vidnc that hav an advrs impact on hritag assts, amnity or local tall housing dvlopmnts, unlss thy ar at th top charactr. nd of th markt, do not promot cohsiv communitis and can lad to ill halth amongst rsidnts (Boys Smith & Morton, 2013). This givs wight to th suggstion, chod by som rsidnts in consultations, that tall buildings, if at all, should b dvlopd only in th northrn part of Blackfriars Road and that th southrn ara should rtain its rsidntial strt charactr. Car will also nd to b takn to nsur that nw buildings, particularly thos that ar high-ris, incorporat opportunitis to maximis vry day Notd. This would b assssd at th planning application stag.

331 Rp Obj Rf Rf Nam 209 Alx Trouton NHS South wark 209 Alx Trouton NHS South wark 209 Alx Trouton NHS South wark Dtails of Rprsntation physical activity,.g. by positioning of stairwlls, provision of scur cycl parking for mploys and visitors, showr rooms, rooftop gardns tc Ys. A numbr of positiv impacts could b anticipatd, including: A positiv impact on transport as th proposals for th strtscap and plans for mixd us dvlopmnts with activ frontags would promot activ walking and th proposal highlights th importanc of making cycling in Blackfriars Road safr. Th impact on halth of incrasd activ travl has bn dscribd abov Incrasd mploymnt opportunitis (as abov) Officr Rspons to Rprsntation Notd. TfL has announcd proposals to introduc a sgrgatd cycl lan on Blackfriars Road which will provid a saf facility for cyclists. Southwark supports this proposal and th SPD has bn updatd accordingly. Th council s Economic Wll-bing Stratgy ( ) sts out th ambition for rgnration and dvlopmnt to provid lasting jobs for rsidnts in both th construction of dvlopmnt and also in th final dvlopmnt itslf through training and skills programms. Th council s adoptd Sction 106 Planning Obligations SPD sts out th dtail on scuring planning obligations from nw dvlopmnt for mploymnt and ntrpris masurs which includ initiativs to crat jobs and training in th final dvlopmnt, and also jobs and training during th construction priod of th dvlopmnt. Th dvlopmnt ara brings with it th potntial to Notd. Th SPD is consistnt with th our Opn Spac Stratgy incras th amount of vgtation-in form of strt (2013) which has idntifid a dficincy in opn spacs within thn trs, grn opn spacs as wll as grn roofs. As ara. Howvr givn th limitd opportunitis for th cration of opn notd in th 2012 Opn Spac Stratgy, th Banksid, spacs, our priority is to focus on improving out xisting opn spacs. Borough and London Bridg sub ara is on of ovrall W will sk to provid nw opn spac and grning as st in th opn spac dficincy and this is particularly th cas stratgy. This will b furthr rviwd through th prparation of th in th NW ara. (Th ara has a total of 0.25ha of park Nw Southwark Plan. provision /1000 population which is xpctd to fall to 0.20ha by 2026 as a rsult of population growth. Rcommndd standard is.77ha/1000). Givn this thr could b a gratr mphasis within th SPD on th significanc of improving th grn infrastructur, as th halth bnfits brought about by incrasing outdoor grn spac ar manifold (both dirct in trms of promoting xrcis and wllbing, but also indirctly

332 Rp Obj Rf Rf Nam 209 Alx Trouton NHS South wark 209 Alx Trouton NHS South wark 209 Alx Trouton NHS South wark 209 Alx Trouton NHS South Dtails of Rprsntation in trms of mitigating global warming and rducing hat rlatd xcss daths. Th possibility of crating additional public grn spacs and allocating dvlopmnt sits or strt spacs to ths could b considrd. Many rsidnts hav commntd on th paucity of grn spacs in th ara, and th dnsity of currnt grn spac provision dos not mt th targts in rcommndations mad by Natural England (Natural England, 2011). Eldrly popl would bnfit particularly from opportunitis to xrcis in outdoor grn spacs and whr walking is saf and njoyabl (Takano t al, 2002). Thr ar potntial ngativ impacts: Ngativ impact on climat chang du to incrasd population, larg dvlopmnts with larg carbon footprints during dvlopmnt and aftr compltion, urban hat island ffct, possibility of incrasd flood vnt risk. This has potntial impact on global halth (s blow) but also on xcss daths rlatd to hat (Mayor of London, 2006). Ngativ impact on air quality du to climat cratd by tall buildings whr pollution is trappd in canyons. Th potntial impact on halth is wll documntd (Dfra, 2013) Thr could b gratr mphasis on th rol of vgtation in mitigating against this and th intgral rol vgtation could hav in dsign proposals Othr ngativ nvironmntal impacts of tall buildings such as sun shading, wind tunnls and ovrhating on strt surfacs from glass-clad buildings Child dvlopmnt: thr should b an mphasis on nsuring that additional outdoor play facilitis for Notd. Officr Rspons to Rprsntation Notd. Th council s adoptd Sustainabl Dsign and Construction SPD provid furthr guidanc on this mattr. Th SPD supports urban grning that includs grn infrastructur that rcus th hight island ffct. Ths mattrs would b assssd at th planning application stag for consistncy with th xisting planning policy framwork of dsign, hritag and tall building policis that includs th rlvant savd Southwark Plan policis, Cor Stratgy Policy 12, th rlvant policis of th London Plan and th NPPF. Bullt-point 14 of SPD 5 sts out furthr guidanc rgarding microclimat. Play spac is covrd in th Rsidntial Dsign Standards SPD, th London Plan and Play and Informal Rcration SPG.

333 Rp Obj Rf Rf Nam wark 209 Alx Trouton NHS South wark 209 Alx Trouton NHS South wark 209 Alx Trouton NHS South wark 209 Alx Trouton NHS South wark 209 Alx Trouton NHS South Dtails of Rprsntation childrn ar cratd as play maks a vital contribution to child dvlopmnt An mphasis on activ travl should not xclud thoughtful provision for thos who ar car dpndnt.g. Blu Badg usrs, so that thy ar abl to bnfit fully from th nhancd cultural, lisur, rtail and mploymnt opportunitis in th ara. Ys Positiv impact likly on xrcis in trms of walking and cycling as dscribd abov As th SPD proposs incrasing amount of lisur facilitis accssibl to public within hotls and othr privat buildings thr is a potntial positiv impact on ability to b physically activ for rsidnts and workrs Availability of halthy food: thr could b a stipulation on limiting fast food outlts within nw prmiss Th suggstion that thr could b nw strt markt(s) has th potntial to promot provision of Officr Rspons to Rprsntation Whilst th mphasis in this SPD is on Activ Travl this dos not prclud ssntial car usrs. Th SPD rfrs to th council working with TfL to nsur th road balancs th nds of all usrs. Southwark has xisting policis in th savd Southwark Plan and Sustainabl Transport SPD to nsur adquat parking provision of disabld parking bays for rsidnts and visitors. Notd. Furthr information on th potntial impact of th SPD guidanc on social, nvironmntal and conomic sustainability is st out in our sustainability appraisal (SA). Th SA assssd th likly impact of th SPD on 17 indicators including indicators spcific to sustainabl transport. Commnt notd. At prsnt w do not considr thr should b spcific rfrnc to hot food takaways in th SPD. SPD2 rcogniss thr is an opportunity to promot a much widr mix of town cntr uss as part of th dvlopmnt of th potntial opportunity sits st out th SPD ara. This includs a rang of diffrnt typs and sizs of rtailrs, to hlp boost th local conomy by gnrating additional spnding and inward invstmnt in othr businsss and providing an incrasd numbr of mploymnt opportunitis. Th SPD cannot dsignat land us on dvlopmnt sits, howvr w will considr th rang of uss that would b appropriat for allocatd dvlopmnt sits through th prparation of th Nw Southwark Plan and its accompanying proposal sits map. In prparing th Nw Southwark Plan, which will rplac th Cor Stratgy (2011) and savd Southwark Plan policis (2007), th council will b considring whthr w should prpar mor dtaild policis to manag th mix of rstaurants, bars, cafs and hot food takaways. W do not considr th guidanc nds to includ spcific rfrnc to th provision of a markt. It is important for th SPD guidanc to b

334 Rp Obj Rf Rf Nam wark 209 Alx Trouton NHS South wark 209 Alx Trouton NHS South wark 209 Alx Trouton NHS South wark 209 Alx Trouton NHS South wark Dtails of Rprsntation halthy food, and th provision of variabl sizs of rtail unit might promot small indpndnt food rtailrs to bcom stablishd A limitation on th numbr of nw off-licnss and othr businsss slling alcohol could b considrd A significant population incras plannd so incrasd nd for all srvics anticipatd including additional primary/community halthcar capacity Th proposals hav a potntial positiv impact on incrasing amount of cultur and lisur srvics and this is has th potntial to incras wllbing and improv a fling of safty for road-usrs particularly at night whn th road would bcom busir (particularly th southrn half and th ara around St Gorg s Circus whr thr ar currntly concrns amongst rsidnts and workrs around safty) Officr Rspons to Rprsntation rad in conjunction with adoptd planning policy. Cor Stratgy Policy 3 promots nw markts in th borough. Th Southwark Markts and Strt Trading Stratgy sts out a numbr of actions and opportunitis to xplor with th opration and provision of markts in th borough. This includs using dmographic analysis to support th businss cas for chang or nw markts, including xploring aras whr nw strt trading sits could b locatd. W hav amndd th supporting txt to rfr to th Banksid and Borough licnsing saturation policy and th rquirmnt for nw licns applications to addrss th saturation concrns st out in th council licnsing policy. Sction 4.4 of th SPD sts out that w will continu to improv xisting infrastructur and provid nw infrastructur alongsid nw dvlopmnt. Th council s Infrastructur Plan idntifis that Southwark NHS will continu to sk invstmnt in thir stat whr ncssary to cop with th anticipatd riss in population and incrass in dmand on halthcar this will crat. Commnt notd. As dscribd abov, th dvlopmnts, particularly It is important for th SPD guidanc to b rad in conjunction with both largr ons, ar likly to mak a ngativ contribution adoptd planning policy and othr stratgis. Policy 13 of th Cor to global climat chang, and thrfor hav ngativ Stratgy sts out th rquirmnts for dvlopmnt to mt high implications for global halth. Thr should b a strong nvironmntal standards. Policy 11 provids th dtail on grn mphasis on mitigating against th climat chang infrastructur. In addition, th council has an Enrgy and Carbon ffcts and thr could b strongr mphasis within Rduction stratgy which is also takn into account whn prparing th SPD itslf on us of grn infrastructur, grn planning policy. and blu roofs and th intgral rol that ths could hav in th dsign proposals Alx Trouton NHS W wlcom this SPD and th opportunitis it offrs Major planning applications rquir th submission of an

335 Rp Obj Rf Rf Nam 3 South wark 209 Alx Trouton NHS South wark 209 Alx Trouton NHS South wark Dtails of Rprsntation for taking a cohrnt, considrat and imaginativ approach to rgnration and dvlopmnt in th Blackfriars ara. Whilst rcognising thr is an conomic cas for intnsification, w hop that this SPD can hlp rconcil th intrsts of ordinary popl, visitors and rsidnts with th markt cas for xpanding th rtail and offic sctor. This scrning against ky dtrminants of halth indicats whr car is rquird in dsign and implmntation to prvnt dvlopmnts that ar unfavourabl to halth and wll-bing. W hop that th ara can bcom a show cas for xmplary and sustainabl buildings and landscaping. Also that thr will b commnsurat improvmnts in th social infrastructur to accommodat th nds of an xpandd population. In this rspct it will b important to nsur that th NHS (Southwark Clinical Commissioning Group and GSTT Community Srvics) is informd, consultd and involvd as ncssary. It is ncouraging that th sction on implmntation highlights th nd to nsur ffctiv and coordinatd managmnt of dvlopmnt. Big construction projcts can bring disruption and inconvninc to popl living and working in an ara. This is particularly th cas thr ar a numbr of diffrnt dvlopmnts going on so it will b important to kp th cumulativ impact in mind. Th national Considrat Contractors Schm has th potntial to amliorat this and w rcommnd that a copy of th chcklist b mad availabl on th Planning wb pags so that popl ar abl to s th ovrall standards that ar xpctd from contractors working in thir ara and undrstand how to complain if Officr Rspons to Rprsntation accompanying sustainability assssmnt chcklist, which nds to st out how th schm has addrssd th ky sustainability rquirmnts/targts st out in policy and guidanc. Th SPD and othr planning policy documnts provid th framwork for th provision of infrastructur to support dvlopmnt. Th council ar currntly prparing our draft community infrastructur charging schdul and an updatd sction 106 SPD. This is bing takn to Cabint for agrmnt for consultation on 10 Dcmbr It is appropriat to look at th provision of infrastructur at a borough-wid lvl through ths ddicatd documnts rathr than through th Blackfriars Road SPD. W will continu to ngag with th NHS (Southwark Clinical Commissioning Group and GSTT Community Srvics) Notd. Th SPD rfrs spcifically to th Considrat Contractors Schm.

336 Rp Obj Rf Rf Nam 209 Alx Trouton NHS South wark 209 Alx Trouton NHS South wark Dtails of Rprsntation Officr Rspons to Rprsntation standards ar brachd. Halth Impact Assssmnt is rquird for larg Our approach to rquiring halth impact assssmnts is boroughwid. W hav st out in paragraph 5.52 of th Cor Stratgy that w dvlopmnts undr th London Plan but this may not apply to all th dvlopmnts which tak plac in th will continu to follow London Plan policy 3.2 Improving halth and Blackfriars ara. As th cumulativ impact of addrssing halth inqualitis and rquir halth impact assssmnts. dvlopmnt on th halth and wll-bing of th popl living in or using th ara is likly to b substantial, w would lik to s som rfrncs includd in th SPD to hlp guid dvloprs to achiv th maximum halth gain for th population in thir schms. E.g. th Halthy Urban Dvlopmnt chcklist: Watch Out for Halth or th Nw York Activ Dsign Guidlins. Linkd to th issu of halth impact is th xtnt to which inclusiv/univrsal dsign principls ar dployd across all th nw dvlopmnts and within th nw public ralm. It would b hlpful if th SPD rfrncd authoritativ sourcs such as UnivrsalDsign.com; th TCPA s worksht in applying inclusiv dsign principls or th NYC Guidbook to Accssibility and Univrsal Dsign Ths rcommndations may b mor widly applicabl and prhaps considration can b givn to th dvlopmnt of a Halthy Planning wbpag with usful rfrncs/signposting to good quality and vidnc basd rsourcs. 20 Gnrally BL ar vry ncouragd by th Council s Blackfri commitmnt in prparing a vision for Blackfriars Road ars which is in th procss of undrgoing significant Road rgnration and which BL bliv offrs significant furthr rgnration opportunitis. Th draft SPD is wlcomd as stablishing th Borough s vision which includs potntial for intnsification, high quality landmark buildings and th stratgic provision of offics and housing. Dtaild commnts ar providd blow which rlat to th nd for th Ara s W ar in th procss of prparing our Nw Southwark Plan, which onc adoptd will rplac th Cor Stratgy and savd Southwark Plan. As part of this work w ar also looking at updating our wbsit. W will look at providing appropriat links to usful documnts tc as part of this procss. Notd.

337 Rp Obj Rf Rf Nam Dtails of Rprsntation Opportunity Ara (OA) dsignation to b rcognisd and spcifically for rsidntial dvlopmnt to b acknowldgd as a valuabl contributor towards th cration of mixd and sustainabl communitis. 20 BL wlcom SPD2 Mixd us town cntr which Support notd Blackfri sks to ncourag th provision of a balancd mix of ars town cntr uss to hlp nhanc th commrcial Road attractivnss of th Blackfriars Road ara and th status and function of th widr Cntral Activitis Zon. SPD2 is also wlcomd for its support for proposals for nw hotls and othr forms of visitor accommodation (C1) to nsur thr is a good supply of accommodation for visitors and to contribut to a mix of uss and mploymnt opportunitis. Proposals should sk to maximis th opportunity to includ ancillary facilitis and activity along th lowr and strt lvl frontags. It is agrd that dmand for hotl rooms in Southwark, in particular th north of th Borough will continu to grow with th nhancmnt of Southwark s and indd th widr London cultural offr which will soon s th compltion of th xtnsion to th Tat Modrn gallry to crat mor prformanc and xhibition spac along with futur dvlopmnt of th South Bank Cntr. 20 BL wlcom that a ky drivr in th SPD is to Blackfri contribut to th cration of a sns of plac and ars ncourag a varity of activity by upgrading and Road nhancing th public ralm within th SPD ara which currntly is vry fragmntd. Although in principl nw public spacs should b providd by nw dvlopmnt, which would hlp maintain its prdominant boulvard charactr, thr should b a rcognition that many sits within th SPD ar constraind and may not b abl to offr substantial aras of public ralm. Officr Rspons to Rprsntation Notd. Th SPD sts out gnral principls to improv th quality of public ralm within th ara. Sit constraints and furthr lvls of dtail rgarding spcific sits would b assssd at th planning application stag.

338 Rp Obj Rf Rf Nam 209 Alx Trouton NHS South wark 379 c/o Agnt 379 c/o Agnt 379 c/o Agnt Dtails of Rprsntation Officr Rspons to Rprsntation BL not th point about public accss to tall buildings This rquirmnt is consistnt with London Plan 7.7. Th viability and howvr, thy considr this rquirmnt to b ovrly fasibility of a publically accssibl spac would b assssd at prscriptiv, in particular, considration nds to b planning application stag. Th SPD has bn updatd to chang th mad to points such as scurity issus associatd with word "must" to "should". allowing accss to uppr floors which rquir considrabl managmnt. This would also impact significantly on th amount of usabl floorspac as a rsult of th nd to provid a ddicatd cor which would unduly constrain th final dsign Gnrally, th draft SPD is wlcomd as stablishing Notd. 150 th Borough s vision for th Ara, namly potntial for Blackfri intnsification, high quality landmark buildings and th ars stratgic provision of offics and housing. Dtaild Road commnts ar providd blow which rlat to th nd for th Ara s Opportunity Ara (OA) dsignation to b rcognisd and spcifically for rsidntial dvlopmnt to b acknowldgd as a valuabl contributor towards th cration of mixd and sustainabl communitis Blackfri ars Road Boundaris of th SPD ara (pag 5) Figur 2 nots th Watrloo and Elphant and Castl OAs but not th Banksid, Borough and London Bridg OA. Th plan should b updatd to rflct this in ordr to avoid any confusion Banksid and Borough (pag 9) Blackfriars Road will 150 continu to hav a mix of shops, srvics and offics Blackfri srvicing both a local widr nd. Thr is no ars rfrnc to housing bing providd within th SPD Road Ara hr although it is listd as on of th Aras potntial strngths on pag 7 ( Thr is scop to Figur 1 shows th location of Blackfriars Road, and illustrats th surrounding opportunity aras at Watrloo and Elphant and Castl. It also shows th Banksid, Borough and London Bridg Opportunity Ara. Th Blackfriars Road SPD ara falls mostly within th Banksid, Borough and London Bridg Opportunity Ara with a small part lying within th Elphant and Castl Opportunity Ara. This is mad clar in th SPD - in figur 1 and in th txt. Figur 1 has bn updatd to show th ovrlapping boundaris mor clarly. Figur 2 simply shows th boundaris of th SPD ara. Th figur has bn updatd to rmov rfrnc to th opportunity aras to incras th focus on th actual boundary and to avoid any confusion. Th SPD sts out that it provids furthr guidanc to xisting planning policis in th Cor Stratgy and savd Southwark Plan. It dos not rpat borough wid policis and th SPD must b rad alongsid othr planning documnts. Housing is not givn its own sction within th SPD bcaus th borough-wid housing policis and guidanc alrady covr housing adquatly. This includs policis in th Cor

339 Rp Obj Rf Rf Nam Dtails of Rprsntation Officr Rspons to Rprsntation dvlop th strngths of th Ara for stratgic offic Stratgy and savd Southwark Plan and SPDs on affordabl housing provision as wll as housing ). It is suggstd that and rsidntial dsign standards. Thr is nothing additional that this sntnc is amndd to includ rsidntial uss nds furthr spcific guidanc for Blackfriars Road. Th vision within th mix of Blackfriars Road as many alrady rfrs to housing dvlopmnt. Housing will b ncouragd on applications coming forward within th past numbr of appropriat sits. In ordr to mak this clarr, w hav updatd SPD yars for rdvlopmnt on Blackfriars Road also 2: Mixd us town cntr to includ rsidntial dvlopmnt as on of includ rsidntial accommodation. Ths includ for th uss to b ncouragd alongsid th provision of a mixtur of nw xampl, 1 Blackfriars and 20 Blackfriars Road and town cntr uss. Th fact box on town cntr uss has also bn Kings Rach Towr. This commnt is also mad in updatd in accordanc with th National Planning Policy Framwork rspct of pag 11 whr th sntnc is rpatd. dfinition to mak it clar that rsidntial dvlopmnt is not a main Thr will b a rang of building hights along town cntr us but it can play an important rol in nsuring th vitality Blackfriars Road, with th tallst buildings at th north of town cntrs. W hav also insrtd a nw appndix (appndix A) nd of th road, signifying th gatway to Cntral listing th ky borough wid Southwark planning policis and London and th gatway to Southwark. Thr will also supplmntary planning guidanc to mak it clarr that ths policis b tallr buildings at th important locations of nd to b rad alongsid th Blackfriars Road SPD. Sction 1 of th Southwark Tub Station and on th main junction of St SPD has bn updatd to rfr to this nw appndix. Gorg s Circus This aim is supportd and th opportunity for tall buildings in ths locations will provid a uniqu opportunity providing stimulus for rgnration and boosting th local conomy. Thr is an opportunity hr to xpand on why a tall building is appropriat at St Gorg s Circus as th Sit is locatd at th conflunc of major routs at St Gorgs Circus, which links Blackfriars Bridg, Wstminstr Bridg, Lambth Bridg, London Bridg and Elphant and Castl. Th location of a tall building would mark th southrn nd of Blackfriars Road and th Sit is at a hing point midway along th spin of rgnration btwn th northrn nd of Blackfriars Road and Elphant and Castl. It could also b ritratd that a tall building would nd to comply with Policy 3.20 of th Southwark Plan which sts out critria which nd to b mt to justify a tall building: i. Maks a positiv contribution to th landscap; and ii. Is locatd at a point of landmark significanc; and iii. Is of th highst architctural standard; and iv. Rlats

340 Rp Obj Rf Rf Nam 379 c/o Agnt Blackfri ars Road Dtails of Rprsntation wll to its surroundings, particularly at strt lvl; and v. Contributs positivly to th London skylin as a whol, consolidating a clustr within that skylin or providing ky focus within viws. SPD 1 Businss spac (pag 14) W will ncourag th gnration of nw jobs and businsss in th Blackfriars Road ara to hlp consolidat and xpand th xisting businss srvic clustr and rinforc th ara as a stratgic offic mploymnt location Rquiring xisting businss floorspac (B1) to b rtaind or rplacd, unlss an xcption can b dmonstratd in accordanc with our borough wid mploymnt policis. Although stratgic offic uss in Blackfriars Road ar supportd BL objct to this policy as it ffctivly rducs support for othr typs of dvlopmnt, namly rsidntial. Th SPD ara is within th Cntral Activitis Zon (CAZ) as shown on Figur 1 on pag 4. Th associatd London Plan CAZ policis do not protct or prioritis offic floorspac, thy simply idntify it as an appropriat land us (policis 2.10, 2.11 and 2.12). Th policy fails to rcognis rsidntial dvlopmnt as promotd through th OA and th CAZ in th London Plan (policis 2.10, 2.11, 2.12 and 2.13) and particularly larg rsidntial dvlopmnts which ar promotd in aras of high public transport accssibility (Policy 3.7). Th Banksid, Borough and London Bridg Opportunity Ara has a targt of 1,900 nw homs whil th Elphant and Castl Opportunity Ara has a targt of 4,000 nt nw homs and this is furthr dvlopd by th London Plan which considrs OA targts to b a minimum which should b xcdd. Th Blackfriars Road SPD should mak rfrnc to ths targts. Th London Plan contains housing targts for all boroughs and supports incrasd housing dvlopmnt across London. Southwark s Officr Rspons to Rprsntation It is important for th SPD guidanc to b rad in conjunction with adoptd planning policy. This is mad clar in th SPD. Th Cor Stratgy sts out th borough s stratgy for housing and th targts ovr th plan priod, which includ th targt for th opportunity ara. W hav amndd SPD 2 to mak it clar that spac for town cntr uss should b dvlopd alongsid both rsidntial dvlopmnt and also businss uss. Th guidanc st out in th SPD supports borough wid policis. Th rquirmnt to rtain or rplac xisting businss spac is consistnt with borough-wid policis. Th policy rquirmnt for th rplacmnt of businss floorspac is justifid by th council s vidnc bas which points to th nd to protct and intnsify mploymnt land and businss floorspac ovr th plan priod. Cor Stratgy policy 10 and savd Southwark Plan policy 1.4 rquir applicants to dmonstrat th loss of businss floorspac (B1, B2 and B8) against a rang of xcption critria whr th sit falls within a rang of locations, which includ (amongst othrs) th CAZ. Land outsid ths locations can b rlasd for othr uss. This stratgy nsurs th rtntion of xisting businss floorspac whr this is appropriat, to nsur thr continus to b spac availabl for stablishd businsss to mov into th ara and for start up businsss to stablish thmslvs. Th council considrs that it is rasonabl to xpct applicants to dmonstrat that in th aras whr businss floorspac is protctd that thr is a lack of dmand or viability, or physical and/or nvironmntal constraints which prclud r-provision or an uplift of mploymnt spac (Southwark Plan Policy 1.4). It is considrd that this is consistnt with paragraph 21 and 22 of th NPPF. Southwark CAZ was also xmptd from th govrnmnt s rcnt chang to th Gnral Prmittd Dvlopmnt Ordr to allow offic buildings to convrt to rsidntial. Th CAZ has bn rcognisd by th govrnmnt as a nationally significant ara of conomic activity. Ths nw prmittd dvlopmnt rights do not apply in th CAZ. W also ncourag th dvlopmnt of othr

341 Rp Obj Rf Rf Nam 379 c/o Agnt Dtails of Rprsntation Officr Rspons to Rprsntation housing targt sks to provid 20,050 nw dwllings mploymnt gnrating town cntr uss such as cultural/community, ovr th priod 2011 to 2021 (Tabl 3.1). Th prssing rtail and lisur to b providd alongsid B1 uss. W will b nd for additional housing in London is thrfor not considring dvlopmnt sit allocations through th prparation of acknowldgd nor is th gnral, widr nd to crat th Nw Southwark Plan. Th SPD idntifis possibl dvlopmnt mixd and sustainabl communitis as pr th opportunitis, som of which may b complt rdvlopmnt, and National Planning Policy Framwork (NPPF), 2012 som may b mor minor changs or improvmnts. which promots th dlivry of a wid rang of high quality homs. BL considr that rfrnc should b mad within th SPD to th fact that both Hill Hous and Erlang Hous ar larg floor plat offic buildings which do not mt markt rquirmnts without major invstmnt which is not viabl in this location. It is rcognisd that whil som aras of th Southbank including th north nd of Blackfriars Road ar viabl Grad A offic locations othr aras ar not. Thr ar thr distinct bands along Blackfriars Road from St Gorgs Circus up to th Rivr. Th southrn most band raching down to Elphant and Castl dos not fall within a location whr thr would b a dmand for Grad A accommodation or indd largr floor plat offics. Whil offics this far south might hav succdd historically, it is considrd that thy would not succd now. A rviw of mploymnt uss has bn undrtakn by EA Shaw for BL in rlation to Blackfriars Road. Thy idntifid th optimum approach to mploymnt provision on th sit was to provid a mix of rtail and flxibl Class B1 offic spac targtd at SME s. Rtail us placd at ground floor would crat footfall and activat frontags. SME offic spac could mt a local markt dmand which is also idntifid with th draft BBLB SPD Fact box: Town cntr uss (pag 16) Rsidntial us W hav amndd th fact box to st out furthr clarification. Th 150 is appropriat in town cntrs but is not a town cntr dfinition of town cntr uss now rflcts th NPPF dfinition of main Blackfri us for th purpos of Southwark s Local Plan. This is town cntr uss. W hav also mad clarr that whilst rsidntial ars not consistnt with th NPPF which stats that LPA s dvlopmnt can play an important rol in nsuring th vitality of town Road should rcognis that rsidntial dvlopmnt can cntrs, is not a main town cntr us whn planning for comptitiv

342 Rp Obj Rf Rf Nam 379 c/o Agnt 379 c/o Agnt Dtails of Rprsntation play an important rol in nsuring th vitality of cntrs and st out policis to ncourag rsidntial dvlopmnt on appropriat sits (paragraph 23) SPD 3 Public ralm and opn spac (pag 20) 150 Additional principls for St Gorg s Circus To Blackfri nhanc St Gorg s Circus, public ralm schms ars should: Focus on rinforcing th charactr and Road gomtry of th Circus. Incras th ara of usabl pdstrian spac around th primtr and at th cntr of th Circus. Enhanc th stting of th consrvation ara, listd buildings and th listd oblisk. Contribut to th importanc of th Circus as a stratgic gatway south to Elphant and Castl, and north to Blackfriars Road and onwards to th City. Th SPD rcogniss that St Gorg s Circus maks an important contribution to Blackfriars Road. Th currnt application for Blackfriars Road rcogniss th importanc of th Circus and sks to improv it by undrtaking physical works on and around th sit and by contributing towards physical improvmnts to th Circus in th form of S.106 planning obligations SPD 5 Building hights (pag 27) BL nots and 150 wlcoms th Council s accptanc that Blackfri Blackfriars Road is an appropriat sit for a tall ars building A tall building, of a hight of up to 70 mtrs Road should provid a focal point at St. Gorg s Circus. Tall buildings must b st back from th Circus. BL howvr considr it to b ntirly inappropriat to prscrib a hight of up to 70m for th sit. No vidnc bas to substantiat this assumption has bn undrtakn in th form of dtaild urban analysis, hritag tsting or assssmnt of viws. Instad, it would b appropriat to not th potntial for a tall building at Blackfriars Road / St Officr Rspons to Rprsntation town cntrs which nd to provid customr choic and a divrs rtail offr and xprinc in th contxt of Southwark s Local Plan. Notd. Th SPD sts out clar building hights guidanc. Th policy approach within th SPD is considrd to b consistnt with th NPPF (2012), th London Plan (2011), th Cor Stratgy (2011) and th savd Southwark Plan (2007), taking into account changs in th surrounding contxt sinc dvloping th Cor Stratgy vision in 2009/2010. Th London Plan, Cor Stratgy and savd Southwark Plan form th dvlopmnt plan for Southwark, with th NPPF stting out national guidanc. Th dvlopmnt plan sts out th policis for tall buildings. Ky policis ar: London Plan policy 7.7 which idntifis that tall and largr buildings should gnrally b limitd to sits in th Cntral Activitis Zon, opportunity aras, aras of intnsification or town cntrs that hav good accss to public transport. Blackfriars Road lis within th Cntral Activitis Zon, is an opportunity ara and

343 Rp Obj Rf Rf Nam 379 c/o Agnt Dtails of Rprsntation Officr Rspons to Rprsntation Gorg s Circus which rprsnts a stp down in a town cntr with good accss to public transport. Cor Stratgy hight from th vry tall buildings at th north nd of stratgic policy 12 rquirs tall buildings to hav an xmplary Blackfriars Road and at Elphant and Castl which ar standard of dsign and idntifis locations whr tall buildings could up to mid 40 storys in hight. Th appropriat hight go. Th Cor Stratgy vision for Banksid and Borough rfrs to th should thn b dtrmind through a planning council stting out in dtail which sits ar appropriat, snsitiv and application procss which would fully considr th inappropriat for tall buildings through th supplmntary planning quality of dsign and associatd impacts in lin with documnt/opportunity ara framwork. Savd Southwark Plan policy th critria st out within Policy 3.20 of th Southwark 3.20 sts out critria for considring applications for tall buildings and Plan. Buildings which ar significantly highr than 50 applis across th borough. Th approach is supportd by our mtrs must dmonstrat that thy contribut vidnc bas including th Blackfriars Road Urban Dsign Study positivly to London s skylin, whn viwd locally and which has bn prpard in accordanc with CABE and English in mor distant viws, particularly on th rivr front and Hritag Guidanc on Tall Buildings, This vidnc bas that thy mak xcptional contribution to th rvals that hights abov thos outlind in th guidanc would hav rgnration of th ara. All tall buildings ovr 25 an advrs impact on hritag assts, amnity or local charactr. Th mtrs / 30 mtrs must: Dmonstrat an xmplary Rsidntial Dsign Standards SPD sts out minimum spac standard of dsign, provid high quality rquirmnts for th borough. Th SPD provids furthr guidanc to accommodation which significantly xcds minimum xisting planning policis in th London Plan, our Cor Stratgy and spac standards and promot housing choic by savd Southwark Plan. It dos not rpat borough wid policis and providing a mix of unit typs. Achiving high quality so th SPD must b rad alongsid our othr planning documnts urban dsign is a ky planning objctiv throughout all lvls of policy and a ky drivr for th Blackfriars Road sit which is partly within a Consrvation Ara and thrfor subjct to mor rigorous standards of dsign. This objctiv is thrfor supportd and th potntial for tall building and high quality architctur to act as a catalyst for widr rgnration is rcognisd. With th abov txt, it is considrd that rfrnc should b includd to xcding th minimum dwlling siz standards as st out within th London Plan SPD 5 Building hights (pag 28) In addition to th 150 abov critria, buildings which ar significantly highr Blackfri than 70 mtrs must: Includ a publicly accssibl ars ara on uppr floors whr fasibl in th tallst Road buildings in th north of Blackfriars Road. This rquirmnt is considrd to b ovrly prscriptiv, in This rquirmnt is consistnt with London Plan 7.7. Th viability and fasibility of a publically accssibl spac would b assssd at planning application stag. Th SPD has bn updatd to chang th word "must" to "should".

344 Rp Obj Rf Rf Nam 379 c/o Agnt 907 c/o Agnt 907 c/o Agnt Dtails of Rprsntation Officr Rspons to Rprsntation particular, considration nds to b mad to points such as scurity issus associatd with allowing accss to uppr floors which rquir considrabl managmnt. This would also impact significantly on th amount of usabl floorspac as a rsult of th nd to provid a ddicatd cor which would unduly constrain th final dsign. W thrfor objct to th proposd rquird provision of public aras at uppr lvls. Notwithstanding this, BL do support communal accss for rsidnts within tall buildings of abov 70m, as providd at Canada Watr and proposd at Blackfriars Road 128- Building hights (pag 29, paragraph 3.33) Th Dvlopmnt proposals would b assssd at planning application 150 amount of public spac at th bas of th building stag. Blackfri should rlat to its hight Although thr is a ars rlationship btwn hight and th amount of public Road spac at th bas of a building this statmnt is qurid bcaus it is also affctd by othr factors such as th constraints of th sit and th contxt of surrounding buildings and public ralm. It is not always possibl to provid a significant amount of public spac at th bas of vry tall building, howvr, this may b consistnt with th charactr of an ara or complmntd by opn spacs availabl narby. Dvlo pmnt Scurit is Plc Dvlo pmnt Gnrally, th draft SPD is wlcomd as stablishing Th SPD ara s dsignation within th Banksid, Borough and London th Borough s vision for th Ara, namly potntial for Bridg opportunity ara is rcognisd throughout th SPD. intnsification, high quality landmark buildings and th stratgic provision of offics and housing. Dtaild commnts ar providd blow which rlat to th nd for th Ara s Opportunity Ara (OA) dsignation to b rcognisd and spcifically for rsidntial dvlopmnt to b acknowldgd as a valuabl contributor towards th cration of mixd and sustainabl communitis. Boundaris of th SPD ara (pag 5) Figur 2 nots th Watrloo and Elphant and Castl OAs but not th Figur 1 shows th location of Blackfriars Road, and illustrats th surrounding opportunity aras at Watrloo and Elphant and Castl. It

345 Rp Obj Rf Rf Nam 907 c/o Agnt Scurit is Plc Dvlo pmnt Scurit is Plc Dtails of Rprsntation Banksid, Borough and London Bridg OA. Th plan should b updatd to rflct this in ordr to avoid any confusion. Banksid and Borough (pag 9) Blackfriars Road will continu to hav a mix of shops, srvics and offics srvicing both a local widr nd. Thr is no rfrnc to housing bing providd within th SPD Ara hr although it is listd as on of th Aras potntial strngths on pag 7 ( Thr is scop to dvlop th strngths of th Ara for stratgic offic provision as wll as housing ). It is suggstd that this sntnc is amndd to includ rsidntial uss within th mix of Blackfriars Road as many applications coming forward within th past numbr of yars for rdvlopmnt on Blackfriars Road also includ rsidntial accommodation. Ths includ for xampl 1 Blackfriars Road and Kings Rach This commnt is also mad in rspct of pag 11 whr th sntnc is rpatd. Thr will b a rang of building hights along Blackfriars Road, with th tallst buildings at th north nd of th road, signifying th gatway to Cntral London and th gatway to Southwark. Thr will also b tallr buildings at th important locations of Southwark Tub Station and on th main junction of St Gorg s Circus This aim is supportd and th opportunity for tall buildings in ths locations will provid a uniqu opportunity providing stimulus for rgnration and boosting th local conomy. Thr is an opportunity hr to xpand on why a tall building is appropriat at th Southwark Officr Rspons to Rprsntation also shows th Banksid, Borough and London Bridg Opportunity Ara. Th Blackfriars Road SPD ara falls mostly within th Banksid, Borough and London Bridg Opportunity Ara with a small part lying within th Elphant and Castl Opportunity Ara. This is mad clar in th SPD - in figur 1 and in th txt. Figur 1 has bn updatd to show th ovrlapping boundaris mor clarly. Figur 2 simply shows th boundaris of th SPD ara. Th figur has bn updatd to rmov rfrnc to th opportunity aras to incras th focus on th actual boundary and to avoid any confusion. With rgards to th point on housing, th SPD sts out that th SPD provids furthr guidanc to xisting planning policis in th Cor Stratgy and savd Southwark Plan. It dos not rpat borough wid policis and th SPD must b rad alongsid othr planning documnts. Housing is not givn its own sction within th SPD bcaus th borough-wid housing policis and guidanc alrady covr housing adquatly. This includs policis in th Cor Stratgy and savd Southwark Plan and SPDs on affordabl housing and rsidntial dsign standards. Thr is nothing additional that nds furthr spcific guidanc for Blackfriars Road. Th vision alrady rfrs to housing dvlopmnt. Housing will b ncouragd on appropriat sits. In ordr to mak this clarr, w hav updatd SPD 2: Mixd us town cntr to includ rsidntial dvlopmnt as on of th uss to b ncouragd alongsid th provision of a mixtur of nw town cntr uss. Th fact box on town cntr uss has also bn updatd in accordanc with th National Planning Policy Framwork dfinition to mak it clar that rsidntial dvlopmnt is not a main town cntr us but it can play an important rol in nsuring th vitality of town cntrs. Support notd with rgards to th building stratgy. Howvr, it is not appropriat to includ mor dtail within th vision on th suitability of why Southwark Tub Station nod is suitabl for a tall building. This dtail is providd as part of SPD 5: Building hights and within th urban dsign study.

346 Rp Obj Rf Rf Nam 907 c/o Agnt Dvlo pmnt Scurit is Plc Dtails of Rprsntation Tub Sit as this rprsnts a ky transport nod in th London Borough of Southwark and as th sit marks an important landmark location at th cornr on Th Cut and Blackfriars Road. Th location of a tall building would also mark a mid sction along Blackfriars Road, btwn th proposd tall buildings that mark th north nd of Blackfriars Road and th gatway to th City of London and th south nd of Blackfriars Road at St Gorg s Circus which is also idntifid as a location for a tall building. SPD 1 Businss spac (pag 14) W will ncourag th gnration of nw jobs and businsss in th Blackfriars Road ara to hlp consolidat and xpand th xisting businss srvic clustr and rinforc th ara as a stratgic offic mploymnt location Rquiring xisting businss floorspac (B1) to b rtaind or rplacd, unlss an xcption can b dmonstratd in accordanc with our borough wid mploymnt policis. Although stratgic offic uss in Blackfriars Road ar supportd w objct to this policy as it ffctivly rducs support for othr typs of dvlopmnt, namly rsidntial. Th SPD ara is within th Cntral Activitis Zon (CAZ) as shown on Figur 1 on pag 4. Th associatd London Plan CAZ policis do not protct or prioritis offic floorspac, thy simply idntify it as an appropriat land us (policis 2.10, 2.11 and 2.12). Th policy fails to rcognis rsidntial dvlopmnt as promotd through th OA and th CAZ in th London Plan (policis 2.10, 2.11, 2.12 and 2.13) and particularly larg rsidntial dvlopmnts which ar promotd in aras of high public transport accssibility (Policy 3.7). Th Banksid, Borough and London Bridg Opportunity Ara has a targt of 1,900 nw homs whil th Elphant and Castl Opportunity Ara has a targt of 4,000 nt nw homs and this is furthr Officr Rspons to Rprsntation It is important for th SPD guidanc to b rad in conjunction with both adoptd planning policy. Th Cor Stratgy sts out th borough s stratgy for housing and th targts ovr th plan priod, which includ th targt for th opportunity ara. Th guidanc st out in th SPD supports borough wid policis. Th rquirmnt to rtain or rplac xisting businss spac is consistnt with borough-wid policis. Th policy rquirmnt for th rplacmnt of businss floorspac is justifid by th council s vidnc bas which points to th nd to protct and intnsify mploymnt land and businss floorspac ovr th plan priod. Cor Stratgy policy 10 and savd Southwark Plan policy 1.4 rquir applicants to dmonstrat th loss of businss floorspac (B1, B2 and B8) against a rang of xcption critria whr th sit falls within a rang of locations, which includ (amongst othrs) th CAZ. Land outsid ths locations can b rlasd for othr uss. This stratgy nsurs th rtntion of xisting businss floorspac whr this is appropriat, to nsur thr continus to b spac availabl for stablishd businsss to mov into th ara and for start up businsss to stablish thmslvs. Th council considrs that it is rasonabl to xpct applicants to dmonstrat that in th aras whr businss floorspac is protctd that thr is a lack of dmand or viability, or physical and/or nvironmntal constraints which prclud r-provision or an uplift of mploymnt spac (Southwark Plan Policy 1.4). It is considrd that this is consistnt with paragraph 21 of th NPPF. Southwark CAZ was also xmptd from th govrnmnt s rcnt chang to th Gnral Prmittd Dvlopmnt Ordr to allow offic buildings to convrt to

347 Rp Obj Rf Rf Nam 907 c/o Agnt Dvlo pmnt Dtails of Rprsntation Officr Rspons to Rprsntation dvlopd by th London Plan which considrs OA rsidntial. Th CAZ has bn rcognisd by th govrnmnt as a targts to b a minimum which should b xcdd. nationally significant ara of conomic activity. Ths nw prmittd Th Blackfriars Road SPD should mak rfrnc to dvlopmnt rights do not apply in th CAZ. Th supporting txt ths targts. Th London Plan contains housing ncourags small offic/studio/workshops spac in th southrn part targts for all boroughs and supports incrasd of th SPD ara, to hlp consolidat th xisting clustr of crativ housing dvlopmnt across London. Southwark s sctor businsss which hav chosn to locat in th ara. W hav housing targt sks to provid 20,050 nw dwllings also mad an amndmnt W also ncourag th dvlopmnt of ovr th priod 2011 to 2021 (Tabl 3.1). Th prssing othr mploymnt gnrating town cntr uss such as nd for additional housing in London is thrfor not cultural/community, rtail and lisur to b providd alongsid B1 acknowldgd nor is th gnral, widr nd to crat uss. W will b considring dvlopmnt sit allocations through th mixd and sustainabl communitis as pr th prparation of th Nw Southwark Plan. Th SPD idntifis possibl National Planning Policy Framwork (NPPF), 2012 dvlopmnt opportunitis, som of which may b complt which promots th dlivry of a wid rang of high rdvlopmnt, and som may b mor minor changs or quality homs. Dvlopmnt Scuritis considr that improvmnts. rfrnc should b mad within th SPD that whil som aras of th Southbank including th north nd of Blackfriars Road ar viabl Grad A offic locations, thr ar potntially thr distinct bands, from St Gorgs Circus up to th rivr. Th southrn most band raching down to Elphant and Castl dos not fall within th location whr thr would b a dmand for Grad A accommodation or indd largr floor plat offics and it is considrd that smallr start up businss units may b appropriat with a mix of othr uss such as rsidntial and rtail. Th ara to th south of th railway lin (mid way point along Blackfriars Road) offrs th potntial for offic provision but, also togthr with othr town cntr uss and rsidntial us whras th ara to th north of Blackfriars Road has provn to b an attractiv location for offic dvlopmnt and this can b sn through th rdvlopmnt of Sa Containrs Hous and 240 Blackfriars Road whr work is currntly taking plac on sit. Fact box: Town cntr uss (pag 16) Rsidntial us is appropriat in town cntrs but is not a town cntr W hav amndd th fact box to st out furthr clarification. Th dfinition of town cntr uss now rflcts th NPPF dfinition of main

348 Rp Obj Rf Rf Nam 907 c/o Agnt 907 c/o Agnt Scurit is Plc Dvlo pmnt Scurit is Plc Dvlo pmnt Scurit is Plc Dtails of Rprsntation us for th purpos of Southwark s Local Plan. This is not consistnt with th NPPF which stats that LPA s should rcognis that rsidntial dvlopmnt can play an important rol in nsuring th vitality of cntrs and st out policis to ncourag rsidntial dvlopmnt on appropriat sits (paragraph 23). SPD 3 Public ralm and opn spac (pag 19-20) Th gnral principls as st out undr SPD 3 ar gnrally wlcomd and indd nw dvlopmnts should indd try to promot activ ground floor us howvr, it should b rcognisd that not all sits will b abl to dlivr a ntwork of gnrous, maningful and prsonabl public spacs du to th constraind natur of many of th sits within th SPD ara. Officr Rspons to Rprsntation town cntr uss. W hav also mad clarr that whilst rsidntial dvlopmnt can play an important rol in nsuring th vitality of town cntrs, is not a main town cntr us whn planning for comptitiv town cntrs which nd to provid customr choic and a divrs rtail offr and xprinc in th contxt of Southwark s Local Plan Rlvant dvlopmnt proposals would b assssd at planning application stag. SPD 5 Building hights (pag 27) Dvlopmnt Th SPD sts out clar building hights guidanc. Th policy Scuritis nots and wlcoms th Council s approach within th SPD is considrd to b consistnt with th NPPF accptanc that Southwark Tub is an appropriat sit (2012), th London Plan (2011), th Cor Stratgy (2011) and th for a tall building A tall building, of a hight of up to 70 savd Southwark Plan (2007), taking into account changs in th mtrs should provid a focal point at Southwark tub surrounding contxt sinc dvloping th Cor Stratgy vision in station. Dvlopmnt Scuritis howvr qustion th 2009/2010. Th London Plan, Cor Stratgy and savd Southwark appropriatnss of including a prscriptiv hight of up Plan form th dvlopmnt plan for Southwark, with th NPPF stting to 70m as bing appropriat for th sit. It is not out national guidanc. Th dvlopmnt plan sts out th policis for considrd appropriat to cap th hight of a tall tall buildings. Ky policis ar: London Plan policy 7.7 which idntifis building but instad not that Southwark Tub that tall and largr buildings should gnrally b limitd to sits in th rprsnts a stp down in hight from th vry tall Cntral Activitis Zon, opportunity aras, aras of intnsification or buildings at th north nd of Blackfriars Road and at town cntrs that hav good accss to public transport. Blackfriars Elphant and Castl which ar up to mid 40 storys in Road lis within th Cntral Activitis Zon, is an opportunity ara and hight. Th appropriatnss of th hight would thn a town cntr with good accss to public transport. Cor Stratgy b tstd as part of pr-application discussions with stratgic policy 12 rquirs tall buildings to hav an xmplary th Council and a planning application which would standard of dsign and idntifis locations whr tall buildings could includ a dtaild analysis of townscap and dsign. go. Th Cor Stratgy vision for Banksid and Borough rfrs to th Buildings which ar significantly highr than 50 council stting out in dtail which sits ar appropriat, snsitiv and mtrs must dmonstrat that thy contribut inappropriat for tall buildings through th supplmntary planning positivly to London s skylin, whn viwd locally and documnt/opportunity ara framwork. Savd Southwark Plan policy in mor distant viws, particularly on th rivr front and 3.20 sts out critria for considring applications for tall buildings and

349 Rp Obj Rf Rf Nam 907 c/o Agnt 907 c/o Agnt Dvlo pmnt Scurit is Plc Dvlo pmnt Scurit is Plc Dtails of Rprsntation that thy mak xcptional contribution to th rgnration of th ara. All tall buildings ovr 25 mtrs / 30 mtrs must: Dmonstrat an xmplary standard of dsign, provid high quality accommodation which significantly xcds minimum spac standards and promot housing choic by providing a mix of unit typs. Achiving high quality urban dsign is a ky planning objctiv throughout all lvls of policy and a ky drivr for dlivring hight along Blackfriars Road. This objctiv is thrfor supportd and th potntial for tall building and high quality architctur to act as a catalyst for widr rgnration is rcognisd. SPD 5 Building hights (pag 28) In addition to th abov critria, buildings which ar significantly highr than 70 mtrs must: Includ a publicly accssibl ara on uppr floors whr fasibl in th tallst buildings in th north of Blackfriars Road. This rquirmnt is considrd to b ovrly prscriptiv, in particular, considration nds to b mad to points such as scurity issus associatd with allowing accss to uppr floors which rquir considrabl managmnt. This would also impact significantly on th amount of usabl floorspac as a rsult of th nd to provid a ddicatd cor which would unduly constrain th final dsign. W thrfor objct to th proposd rquird provision of public aras at uppr lvls. Building hights (pag 29, paragraph 3.33) Th amount of public spac at th bas of th building should rlat to its hight Although thr is a rlationship btwn hight and th amount of public spac at th bas of a building this statmnt is qurid bcaus it is also affctd by othr factors such as th constraints of th sit and th contxt of Officr Rspons to Rprsntation applis across th borough. Th approach is supportd by our vidnc bas including th Blackfriars Road Urban Dsign Study which has bn prpard in accordanc with CABE and English Hritag Guidanc on Tall Buildings, This vidnc bas rvals that hights abov thos outlind in th guidanc would hav an advrs impact on hritag assts, amnity or local charactr. Th Rsidntial Dsign Standards SPD sts out minimum spac rquirmnts for th borough. Th SPD provids furthr guidanc to xisting planning policis in th London Plan, our Cor Stratgy and savd Southwark Plan. It dos not rpat borough wid policis and so th SPD must b rad alongsid our othr planning documnts This rquirmnt is consistnt with London Plan 7.7. Th viability and fasibility of a publically accssibl spac would b assssd at planning application stag. Th SPD has bn updatd to chang th word "must" to "should". Notd. This mattr would b assssd at th planning application stag.

350 Rp Obj Rf Rf Nam Dtails of Rprsntation surrounding buildings and public ralm. It is not always possibl to provid a significant amount of public spac at th bas of vry tall building, howvr, this may b consistnt with th charactr of an ara or complmntd by opn spacs availabl narby. Officr Rspons to Rprsntation