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