From:

Subject:
Date:
To:

Russell Gray <Russell@bvag.net>

Fwd: STP(D)
5 February 2015 17:24:06 GMT
Admin BVAG <admin@bvag.net>

From: "Seymour, Juliet" <juliet.seymour@southwark.gov.uk>

Date: 29 January 2015 15:58:20 GMT
To: 'Russell Gray' <Russell@bvag.net>
Cc: "Bevan, Simon" <Simon.Bevan@SOUTHWARK.GOV.UK>, Ravi Bhaskaran <ravibhaskaran.archi@googlemail.com>, Amy BlierCarruthers <ameliebc@yahoo.com>, "Pettit, Susannah" <Susannah.Pettit@southwark.gov.uk>, "Williams, Mark"
<Mark.Williams@southwark.gov.uk>
Subject: RE: STP(D)

DearRussell

Weareonlyconsidering1applicationatthemomentforaneighbourhoodforumfromyourselvesaboutAreaA.We
havenotreceivedanyotherapplicationsatpresent.WearecontactingothergroupsassuggestedbyOSC,andaspart
oftheconsultationonyourapplicationtoinformthemoftheapplicationandoftheapplicationtoworkwith
yourselves.Wewillalsobeaskingiftheywillbesubmittingtheirownapplication.

WehavealsoinvitedthesegroupstothemeetingwithCllrWilliamsandyourselfon11thFeb.

Kindregards

Juliet

From: Russell Gray [mailto:Russell@bvag.net]

Sent: Thursday, January 29, 2015 10:25 AM
To: Williams, Mark
Cc: John, Peter; Bevan, Simon; Ravi Bhaskaran; Amy Blier-Carruthers; Pettit, Susannah; Seymour, Juliet
Subject: Re: STP(D)

Mr Williams
Please confirm that you have read my email of yesterday and have nevertheless instructed Juliet Seymour to
write the email below. You are aware that past conduct has left Juliet Seymour with an unbridgeable credibility
gap in her communications with us.
I fail to see how you can be unclear as to what questions you have been asked since (1) you have been sent
them several times over and (2) as a result they appear not once but twice in the email thread below.
Nevertheless I repeat them yet again here:

(a)
As you appear to deny that the founders of the group,
the community at large, or the former BNF's own 'steering
group' are at liberty to wind it up, who do you say is so
entitled?
(b)
What steps have you taken to determine whether BNF
was ever either a representative or properly constituted body,
capable of being recognised as a NF?
(c)
What steps have you taken to verify that John Corey,
who you appear to regard as a one-man NF, represents

anybody whatsoever?
(d)
Has John Corey made an application to become the NF
for your officially designated area? If so, what steps have you
taken to verify whether he has done so pursuant to a
constitutional mandate from an eligible group? If not, on
what basis do you maintain there is any obstacle to the
immediate approval of our application?
You were also asked (again below)

Please take legal advice

on the status of your
decision to designate a
NA for which there is
no applicant. You
should refer your
lawyers in particular to
the requirement upon a
local authority to
designate 'some or all'
(but not more) of a NA
for which a there is an
application from a
qualifying group.
Hence you had to rely
on the BNF application
to bring your decision
into conformity with the
Act. BNF was not, as
you know, a fit body to
be recognised as a NF
when you made the
decision - which is why
you had to stop short of
approving it. Now it
does not exist at all I
think you must concede
that your feigned

recognition of BNF is a
charade too far, even for
this Council.
As I expect to be discussing this matter with our lawyers tomorrow please now confirm that these issues are
clearly understood by you and, if you cannot provide a response today, when you will be able to do so.
As regards a meeting, i have now attended a dozen or so, all of which were without practical objective but
purely tactical moves by the Council to obscure its fundamental policy of obstruction of our application. It was
for that reason that you have been invited to produce a focused agenda:
My email of 16 January:
You appear to be proposing nothing more than yet further tactical delay. Please call me as requested
below and, independently, immediately forward the invitation list and agenda for your proposed meeting
as well as a copy of what you claim is a direction from the 'Scrutiny Committee'.
Regards
Russell Gray
On 29 Jan 2015, at 08:43, Seymour, Juliet wrote:
DearRussell,

ThanksforyouremailtoCllrWilliams.
Iamunclearontheinformationthatyoustillrequire.Theletter:

Acknowledgesyourapplication
Asksforfurtherdetailthatweneedtoprocesstheapplication
SetsatimelineforanIDMtoconsultonyourapplication
OfferstomeetyouandtheBNFon11Febtodeterminewhetherthereisawayforwardforthegroupsto
worktogether

ThereforeasweprogressyourapplicationIamunclearonyouroutstandingpoints.Pleasecouldyouclarifyforme.

Kindregards

<image002.jpg>
Juliet Seymour
Planning Policy Manager
Southwark Council
Juliet.Seymour@Southwark.gov.uk
02075250508
07506911851

From: Russell Gray [mailto:Russell@bvag.net]

Sent: Wednesday, January 28, 2015 3:53 PM
To: Williams, Mark
Cc: John, Peter; Bevan, Simon; Ravi Bhaskaran; Amy Carruthers
Subject: Fwd: STP(D)

Mr Williams
Thank you for your letter of yesterday - attached to the email below from Susannah Pettit. I shall respond on
various points shortly but, as you know, we have been forced to engage legal Counsel because of what we
consider to be your consistent failure to respect your obligations under the Localism Act. Your letter does not
indicate any serious reconsideration of your position in this regard and in order to avoid duplication of work for
myself and our Counsel when responding to you please now answer the questions posed in the email thread
below, which you have ignored hitherto.
Regards
Russell Gray
____________________________________________________________________________________
From: Susannah Pettit <Susannah.Pettit@southwark.gov.uk>
Subject: Neighbourhood Planning in Bermondsey
Date: 27 January 2015 15:38:12 GMT
To: Russell Gray <Russell@bvag.net>

DearRussell

PleasefindattachedaletterfromCouncillorWilliams.

Regards
Susannah

The email you received and any files transmitted with it are confidential, may be covered by legal and/or
professional privilege and are intended solely for the use of the individual or entity to whom they are addressed.
If you have received this in error please notify us immediately.
If you are not the intended recipient of the email or the person responsible for delivering it to them you may not
copy it, forward it or otherwise use it for any purpose or disclose its contents to any other person. To do so may
be unlawful.
Where opinions are expressed in the email they are not necessarily those of Southwark Council and Southwark
Council is not responsible for any changes made to the message after it has been sent.
_________________________________________________________________________________________
Begin forwarded message:

From: Russell Gray <Russell@bvag.net>

Date: 29 December 2014 12:01:18 GMT
To: Mark Williams <Mark.Williams@southwark.gov.uk>
Cc: Peter John <Peter.John@SOUTHWARK.GOV.UK>, Simon Bevan
<Simon.Bevan@SOUTHWARK.GOV.UK>, "damian.obrien68@gmail.com O'Brien"
<damian.obrien68@gmail.com>, Amy Carruthers <ameliebc@yahoo.com>, Admin BVAG
<admin@bvag.net>, Ravi Bhaskaran <ravibhaskaran.archi@googlemail.com>
Bcc: Paul Stinchcombe QC <paul.stinchcombe@39essex.com>, Russell Gray
<russell@bvag.net>
Subject: Re: STP(D)
Mr Williams
You did not respond to the email below. As you have been informed on several occasions, we do not believe
Southwark Council is complying with either the spirit or the letter of the Localism Act. Our legal advice is
corroborative of this view.
Since (a) we have now reluctantly accepted the NA imposed on the local community by the Council, (b) you
have already acknowledged that our Group is eligible for recognition as a NF and (c) you have not cited any
rival application, there can be no good reason for further delay in recognition of the STP(D) group as a NF.
Unless we now have your proposals for a speedy determination of our application within seven days we will
have no alternative but to instruct Counsel with a view to bringing a Judicial review claim against the Council.
Regards
Russell Gray

On 16 Dec 2014, at 10:23, Russell Gray wrote:

Mr Williams
There was no such agreement. Certainly none to which our Group was party.
I you want to rely upon something you say was said at the Scrutiny Committee meeting perhaps you can be
more specific in your interpretation and direct me to the relevant part of the minutes of the meeting. Since you
have not even identified any other applicant for the NA you have already designated it is not open to you to
stall on determining our application. Particularly as you have also already confirmed our eligibility on the
criteria stipulated in the Localism Act there can be no reason for not approving our application.
As I said, if you will not attend our meeting tomorrow you can send a representative. If you are not prepared to
do either please provide answers to our questions in writing so that they can be communicated to those at the
meeting.
(a)
As you appear to deny that the founders of the group, the community at large, or the former
BNF's own 'steering group' are at liberty to wind it up, who do you say is so entitled?

(b)
What steps have you taken to determine whether BNF was ever either a representative or
properly constituted body, capable of being recognised as a NF?
(c)
What steps have you taken to verify that John Corey, who you appear to regard as a one-man NF,
represents anybody whatsoever?
(d)
Has John Corey made an application to become the NF for your officially designated area? If so,
what steps have you taken to verify whether he has done so pursuant to a constitutional mandate from an
eligible group? If not, on what basis do you maintain there is any obstacle to the immediate approval of
our application?
Regards
Russell Gray

On 15 Dec 2014, at 17:02, Williams, Mark wrote:

DearMrGray,

Aspermyemailbelow,andasagreedattheOverviewandScrutinyCommitteemeeting,wewillarrangeameeting
forallinterestedparties,officersarecurrentlyarrangingadate.ForthisWednesdayIamnotavailableasIhavea
priorcommitment.

Bestwishes,

Mark

CouncillorMarkWilliams
LabourMemberforBrunswickParkWard
CabinetMemberforRegeneration,Planning&Transport
LondonBoroughofSouthwark
160TooleyStreet
London,SE12TZ
02075257730/07985629095/@markwilliams84

From: Russell Gray [mailto:Russell@bvag.net]

Sent: Monday, December 15, 2014 4:47 PM
To: Williams, Mark
Cc: John, Peter; Bevan, Simon; damian.obrien68@gmail.com O'Brien; Amy Carruthers; Admin BVAG; Ravi Bhaskaran
Subject: Re: STP(D)

Mr Williams
Please respond to the email below. Our meeting is on Wednesday and our members will obviously want to
hear from you, and at least to know whether you are coming or not.
Regards
Russell Gray
On 11 Dec 2014, at 18:52, Russell Gray wrote:

Mr Williams
Again you have not responded to the email below.
As you are fully aware, we have long contended that the Council is dragging its heels and creating obstacles in
response to our application for recognition as a neighbourhood forum ('NF'). We have similarly long contended
that the reasons are obvious: You do not want local people having an influence over planning decisions,
particularly in the area around St Thomas St that the Council has identified as a cash cow to be milked at the
expense of the character and identity of the neighbourhood, contrary to local feelings. Your aspirations for
profitable but anti-social developments stand to be impeded by a community plan and you are therefore pushing
to the legal limits (and beyond) your powers to thwart our application.
You have chosen to dictate a neighbourhood area ('NA'). As you know, we do not accept that you are legally
entitled to designate an area for which there is no application. However, to strip you of any excuse for further
delay our meeting of 12 November agreed that we will amend our application to accept your designated area.
You received notice to that effect on 28 november.
In your officer's report, dated 20 August this year, that purported to justify your decision to designate the NA,
and that you signed on 28 August, you acknowledged that the BVAG/STP group met the criteria for
recognition as a NF.
In the circumstances there can be no justification for your failure to respond to my email below by giving an
early target decision date.
The STP(D) group will be holding a further meeting from 17.30 to 18.30 on Wednesday of next week (17
December), immediately prior to the BVAG Christmas party, for an update on the progress made by the
Council in determining our application. As you have declined all invitations to attend or host a meeting
yourself to explain your reasons for the continuing delay your attendance is requested. As a minimum you
should send a representative who is in a position to answer for you. The meeting will be held in Globe House,
at the corner of Bermondsey St and Crucifix Lane
Our followers will be wanting to ask you (or your delegate) the questions that you seem unwilling or unable to
address. Among others:
(a)
As you appear to deny that the founders of the group, the community at large, or the former BNF's own
'steering group' are at liberty to wind it up, who do you say is so entitled?
(b)
What steps have you taken to determine whether BNF was ever either a representative or properly
constituted body, capable of being recognised as a NF?
(c)
What steps have you taken to verify that John Corey, who you appear to regard as a one-man NF,
represents anybody whatsoever?
(d)
Has John Corey made an application to become the NF for your officially designated area? If so, what
steps have you taken to verify whether he has done so pursuant to a constitutional mandate from an
eligible group? If not, on what basis do you maintain there is any obstacle to the immediate approval of our
application?
Pleaser confirm by return whether you will be attending or sending a representative.
Regards
Russell Gray

On 4 Dec 2014, at 14:49, Russell Gray wrote:

Mr Williams
At the joint meeting on 12 November BNF was would up by the very people who established it. Please tell us
what causes you to think that exclusive control has shifted to John Corey. If you are in no position to do so
please confirm that our new application will be processed within the prescribed time, giving a target decision
date.
Regards
Russell Gray
On 4 Dec 2014, at 14:12, Williams, Mark wrote:
DearMrGray,

Thankyouforyouremail.Iacknowledgeyourrequesttoberecognisedastheneighbourhoodforumforthe
neighbourhoodareathathasbeendesignated.

FollowingthemeetingoftheOverviewandScrutinyCommitteeIagreedtoholdameetingwiththedifferentgroups
todiscusswhetheragreementcouldbereachedonaneighbourhoodforumforthearea.Asyouknow,thismeeting
hasnotyetbeenarranged.

InoteyourclaimthattheBermondseyNeighbourhoodForummetatyourpremiseson12Novemberandagreedto
disband.However,IshouldadviseyouthatIreceivedconfirmationfromJohnCoreyinadvanceofthatmeetingthat
themeetingtakingplaceon12NovemberwasnotameetingoftheBermondseyNeighbourhoodForum.Ihavenot
receivedconfirmationfromtheBermondseyNeighbourhoodForumthattheyhavedisbandedandwishtowithdraw
theirapplicationtoberecognisedasaneighbourhoodforum.Iwould,therefore,liketocontinuewithmyintention
asagreedatthescrutinymeetingtoarrangeajointmeetingwithyourgroupandtheBermondseyNeighbourhood
Forumtoagreeawayforward.

IhopethatsuchameetingcanbearrangedinJanuary.Dependingontheoutcomeofthismeetingandwhether
furtherpublicconsultationisnecessary,Ishouldthenbeinapositiontomakeadecisiononthedesignationofa
neighbourhoodforum.

Yours,

Mark

CouncillorMarkWilliams
LabourMemberforBrunswickParkWard
CabinetMemberforRegeneration,Planning&Transport
LondonBoroughofSouthwark
160TooleyStreet
London,SE12TZ
02075257730/07985629095/@markwilliams84

From: Russell Gray [mailto:russell@bvag.net]

Sent: Friday, November 28, 2014 12:34 PM

To: Williams, Mark

Cc: Bevan, Simon; John, Peter; damian.obrien68@gmail.com; Amy Carruthers; admin; Ravi Bhaskaran
Subject: Fwd: STP

Mr Williams
You have not responded to the email below. Our 12 November meeting did consider the possibility that the
Council would now revert to what we refer to as your plan A, which was simple delay in responding to us and
processing our application for recognition as a NF. The meeting's unanimous decision in that event was to reapply in exactly the same terms as for the original St Thomas St Plan but accepting the NA designated by the
Council. This is without prejudice to our contention that you had no power to designate such an area and that
the community will be at liberty to amend it if such a decision is subsequently made by the Group.
Please therefore take this email as a formal application for recognition of our group as the NF for the NA you
designated. You will of course have all the original application material and it now simply needs to be taken as
an application for the much larger area selected by you. The only change is that The St Thomas St Plan, 'STP'
will be known under the working title of The St Thomas St Plan (Displaced) 'STP(D)' until the Group
reconvenes to agree a new name.
Please confirm by return your target date for processing this application.
Regards
Russell Gray

From: Russell Gray <russell@lordshiva.net>

Date: 13 November 2014 14:32:33 GMT
To: Mark Williams <mark.williams@southwark.gov.uk>
Cc: peter.john@southwark.gov.uk, Simon Bevan <Simon.Bevan@southwark.gov.uk>, Damian O'Brien
<damian.obrien68@gmail.com>, Amy Carruthers <ameliebc@yahoo.com>, Admin BVAG
<admin@bvag.net>, Ravi Bhaskaran <ravibhaskaran.archi@googlemail.com>, John Corey
<john.corey@chelseaprivateequity.com>
Subject: STP

Mr Williams
It is unfortunate that you did not attend yesterday's joint BVAG/BNF and open
community meeting. You had been given some weeks notice, you gave no specific
explanation of why you did not attend and you did not even send a representative. As
you have been told before, we do not think it is open to the Council to take a
totalitarian approach to neighbourhood planning on one level and then completely
absent yourself when the community assembles to respond to your diktats.
The meeting was well attended by the community at large, by a high proportion of
those who met originally to create BNF some years ago and the only known remaining
active members of the BNF committee. John Corey, the self appointed chairman,
made his excuses at the last minute and did not turn up. Also present was Grange
ward councillor, Damian O'Brien who, for independence, was jointly nominated by
BNF and BVAG to chair the meeting but in the circumstances of such unanimity was
not required to do so.
As it turned out, the Meeting and BNF itself (so far as it exists) resolved that BNF
should be formally wound up. Of course, we have maintained for years now that BNF
was just a straw man serving as a convenient decoy for a Council policy of obstructing

was just a straw man serving as a convenient decoy for a Council policy of obstructing
a genuine community group with policies at odds with its own. I do not think it is now
open to you either legally or politically to continue that ruse.
Please take legal advice on the status of your decision to designate a NA for which
there is no applicant. You should refer your lawyers in particular to the requirement
upon a local authority to designate 'some or all' (but not more) of a NA for which a
there is an application from a qualifying group. Hence you had to rely on the BNF
application to bring your decision into conformity with the Act. BNF was not, as you
know, a fit body to be recognised as a NF when you made the decision - which is why
you had to stop short of approving it. Now it does not exist at all I think you must
concede that your feigned recognition of BNF is a charade too far, even for this
Council.
Other decisions made by the meeting will be communicated to you when minutes have
been transcribed and when you have responded to the request above to stand by or
abandon your attempt to impose a NA on a community that considers itself lawfully
entitled to select its own.
Regards
Russell Gray

The email you received and any files transmitted with it are confidential, may be covered
by legal and/or professional privilege and are intended solely for the use of the individual
or entity to whom they are addressed. If you have received this in error please notify us
immediately. If you are not the intended recipient of the email or the person responsible
for delivering it to them you may not copy it, forward it or otherwise use it for any purpose
or disclose its contents to any other person. To do so may be unlawful. Where opinions
are expressed in the email they are not necessarily those of Southwark Council and
Southwark Council is not responsible for any changes made to the message after it has
been sent.

The email you received and any files transmitted with it are confidential, may be covered by legal and/or
professional privilege and are intended solely for the use of the individual or entity to whom they are addressed.
If you have received this in error please notify us immediately. If you are not the intended recipient of the email
or the person responsible for delivering it to them you may not copy it, forward it or otherwise use it for any
purpose or disclose its contents to any other person. To do so may be unlawful. Where opinions are expressed
in the email they are not necessarily those of Southwark Council and Southwark Council is not responsible for
any changes made to the message after it has been sent.

The email you received and any files transmitted with it are confidential, may be covered
by legal and/or professional privilege and are intended solely for the use of the individual

or entity to whom they are addressed.

If you have received this in error please notify us immediately.
If you are not the intended recipient of the email or the person responsible for delivering it
to them you may not copy it, forward it or otherwise use it for any purpose or disclose its
contents to any other person. To do so may be unlawful.
Where opinions are expressed in the email they are not necessarily those of Southwark
Council and Southwark Council is not responsible for any changes made to the message
after it has been sent.
<Bermondsey NP 27 Jan.pdf>
The email you received and any files transmitted with it are confidential, may be covered by legal and/or professional privilege and are
intended solely for the use of the individual or entity to whom they are addressed.
If you have received this in error please notify us immediately.
If you are not the intended recipient of the email or the person responsible for delivering it to them you may not copy it, forward it or
otherwise use it for any purpose or disclose its contents to any other person. To do so may be unlawful.
Where opinions are expressed in the email they are not necessarily those of Southwark Council and Southwark Council is not
responsible for any changes made to the message after it has been sent.