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Russell Gray russell@bvag.net

5 May 2016 17:55
Bevan, Simon Simon.Bevan@SOUTHWARK.GOV.UK
Info info@oldbermondseyforum.org, Amy Carruthers ameliebc@yahoo.com, ravi Bhaskaran

OBNVNF revision of designated area

As you will recall, when the Old Bermondsey Forum was in its very protracted application phase the Council made a decision to designate
a particular geographical area for which any neighbourhood forum application had to be made. This decision did not accord with the
wishes of our members and did not represent what we considered to be a well selected area from the perspective either of its size or its
coherence in character.
The Forum decided to accept the Council-imposed area because we had confronted so many obstacles from the Council in the process
of securing recognition that our supporters were beginning to believe that the Council would never agree to recognition of a NF at all.
This was demoralising and it was undermining local participation and support. Accordingly we did not consider we had any real choice
but to accept the dictates of the Council.
The Forum has of course now been recognised by the Council for some nine months and various working groups are preparing draft
policies for inclusion in a plan that we hope will be brought together later this year. As this process has advanced it has become even
more apparent that the area for which we originally applied would have been better suited for the application of the kinds of policy
initiatives that were always central to our ethos. We therefore now propose that we extend our designated area to include those areas
from which we consider the Council unreasonably excluded us in the first place.
For clarity I attach a colour-coded map showing the various relevant boundaries together with a key. At our meeting of wednesday 20
April the Group unanimously agreed to extend our designated area to include the areas coloured red and purple on the map. Essentially
this means the areas between Druid St, Crucifix Lane, Snowsfields and Newcomen St to the south and Tooley St to the north. Our
position is that in character these streets belong with the area designated 'Area A' by the Council that we accepted under some duress. It
is also evident that without them being brought under the umbrella of the OBVNF there would be very little prospect of them having any
NF representation.
The last legal advice we received with regard to the exclusion of these areas was to the effect that although local authorities have what
the Court of Appeal acknowledged to be a wide discretion in designation of areas for inclusion in a neighbourhood plan that did not
extend to arbitrary exclusions. We certainly recognise that the principle of 'strategic sites' has some legal precedent where a local
authority wishes to deny a NF to any particular area. We therefore acknowledge that if the Council is determined to exclude London
Bridge Station and Guy's and St Thomas' hospital from any Neighbourhood forum it may have an arguable lawful basis to do so. Our
advice is that the same is not true of the other areas excluded from our original application area, where no comparable argument can be
We therefore now propose that OBVNF be permitted to extend its area to include the areas from which we were excluded (station and
hospital marked red and remainder marked purple on the map). If the Council is ready to cooperate with such an extension of the
designated Forum area - with the exclusion of the station and the hospital - there is no reason why we should have to pursue the issue as
a matter of law. If however the Council resolves to maintain its position that the area we now propose for inclusion must remain outside of
any NF we will take the matter to the courts for resolution.
Of course, we acknowledge that there must be a formal process for the amendment of a designated area and we are ready to comply
with any reasonable requirements the Council may have in this regard.
Please will you let us know as soon as possible the Council's position on us making the proposed change to our area and whether you
will oppose it regardless of its compelling logic from a neighbourhood planning perspective.
Russell Gray