Select Committee on Transport, Local Government and the Regions Memoranda

Memorandum by Commission for Architecture and the Built Environment (CABE) (TAB 10)


  1.1  CABE is the government's champion for architecture and urban design in England. Its function is to promote high standards in the design of buildings and the spaces between them. It offers advice to all those who create, manage and use the built environment.

  1.2  CABE is jointly sponsored by the Department for Culture Media and Sport (DCMS) and the Department for Transport, Local Government and the Regions (DTLR).

  1.3  CABE's involvement in the subject of tall buildings is dealt with below under two headings: casework and policy. They are dealt with in that order because CABE's casework, offering advice to local authorities and the promoters of projects, has informed the development of policy.


  2.2  CABE is a non-statutory consultee within the planning process. A letter from (the then) DETR to local planning authorities of 15 May 2001 (Annex A) sets out the circumstances in which CABE should be consulted about planning applications. The criteria for consultation are as follows (a fuller description of each category is contained in the letter):

1.  Proposals which are significant because of their size or the uses they contain

  This category includes large buildings or groups of buildings such as courts, large religious buildings, museums or art galleries, hospitals, shopping and leisure complexes, and office or commercial buildings, infrastructure projects and major changes in the public realm.

2.  Proposals which are significant because of their site

  In this category are proposals which affect important views—into or from a World Heritage Site, for example—or are sited in such a way that they give rise to exceptional effects on their locality.

3.  Proposals with an importance greater than their size, use or site would suggest

  This includes proposals which are likely to establish the planning, form or architectural quality for future large scale development or re-development, and proposals which are out of the ordinary in their context or setting because of their scale, form or materials.

  2.3  It can be seen that proposals for tall buildings are likely to fall into at least one of the above categories, and quite often into all three.

  2.4  Major projects are reviewed by CABE's design review committee, which meets every four weeks. Since the design review committee began its work in 1999 it has reviewed about 25 proposals for tall buildings across England, including the following:

    —  City of London: Heron Bishopsgate Tower. CABE supported this proposal, which was the subject of a recent public inquiry.

    —  Southwark: London Bridge Tower. This project, the subject of a current planning application, for what would be the tallest building in London, was considered by CABE's design review committee and the Commission itself. The letter setting out the Commission's views is at Annex A. The applicants have done further work to address CABE's concerns about the setting of the project, and this will be seen again by the committee early in 2002.

    —  Westminster: Paddington Station development and Grand Union building, Paddington basin. These two projects each proposed forty-storey towers overlooking Paddington basin. CABE's design review committee was unconvinced by the former but supported the latter. Westminster City Council's planning committee, however, decided that buildings of this height would not be acceptable, and both projects have been redesigned at a lower height.

    —  Bristol: Broad Quay development. This project in the centre of Bristol proposes the replacement of a 1960s office tower (the former HQ of the Bristol and West Building Society) by a mixed use development which includes a residential tower of a similar height. The committee supported this project, admiring particularly the way in which it offered a genuine and attractive mix of uses on the site.

    —  Leeds: Bridgwater House. This project for a "gateway" site at the entrance to the city centre from the south proposed a mixed use scheme which included hotel, office and residential uses. The committee thought that the architecture was not good enough for such a prominent location; it did not live up the "landmark" aspiration.

  2.5  The committee has reviewed other projects which propose tall buildings in the following local authority areas:

    —  In London: Camden, Croydon, Hammersmith and Fulham, Hounslow, Islington, Lewisham, Southwark.

    —  Elsewhere: Gravesham, Manchester, Reading.

  2.6  We are aware from our casework that many more proposals for tall buildings are being worked up at the moment in a number of other cities including Birmingham, Liverpool, Manchester and Newcastle.


  3.1  Through consideration of individual projects by the committee, a number of common themes emerged. CABE and English Heritage agreed that it would be useful to publish a document which sets out how the two bodies evaluate proposals for tall buildings. This document, "Guidance on tall buildings", was issued for public consultation in June 2001. It is attached at Annex B. The key points of the document follow.



  4.1  As the national bodies charged, respectively, with promoting high standards in architecture and urban design and with the conservation and enhancement of the historic environment in England, both CABE and English Heritage have an important role to play in evaluating proposals for tall buildings, which, by definition, are usually of more than local significance.

  4.2  In assessing major proposals for tall buildings, CABE and English Heritage will liase and take into account each other's views when arriving at their own conclusions. Because of the differences in remit given to them by government, however, there may be occasions on which the two bodies arrive at different conclusions about particular proposals. This could arise, for example, as a result of giving differing weight to various pros and cons of proposals.

  4.3  For the purposes of this document, which is based on locational and qualitative considerations, we do not think it useful or necessary to define rigorously what is and what is not a tall building.

Presentation of projects

  4.4  Because of the intensity of land use which they represent, and because of the degree of change to the environment which their construction will bring about, all major tall buildings proposals should be presented in the context of an urban design study/masterplan of their immediate and wider areas, based on a characterisation of the area.

  4.5  Proposals for tall buildings should be accompanied by accurate and realistic representations of the appearance of the building in all significant views affected, both near, middle and distant. CABE and English Heritage will not lend their support to proposals which have not been illustrated in accordance with current best practice.

  4.6  Proposals for tall buildings are likely to require a full Environmental Impact Assessment.

Evaluating tall building proposals

  4.7  Cities and their skylines evolve. In the right place, tall buildings can make positive contributions to city life. They can be first-rate works of architecture in their own right; some of the best post-war examples are now listed buildings. Individually, or in groups, they affect the image and identity of a city as a whole. In the right place they can serve as beacons of regeneration, and stimulate further investment. The design and construction of innovative tall buildings can also serve to push out the frontiers of building and environmental technology.

  4.8  However, by virtue of their size and prominence, such buildings can also harm the qualities that people value about a place. Where tall buildings have proved unpopular, this has generally been for specific rather than abstract or general reasons. In many cases one of the principal failings is that many were designed with a lack of appreciation or understanding of the context in which they were to sit. There have been too many examples which have been unsuitably sited, poorly designed and detailed, badly built or incompetently managed (although this has been equally true of many buildings which are not tall).

  4.9  Proposals will be assessed in terms both of the potential contribution, and any potentially adverse impacts, which they may bring. They will be considered as pieces of architecture in their own right, and as pieces of urban design sitting within a wider context.

  4.10  The trend of recent and emerging policy, based on sustainability and demographic considerations, has been to support increased density. In some cases the desire for high-density development has been used to support proposals for tall buildings. However, it is clear that tall buildings are only one possible model for high-density development. While tall buildings with a large total floor area have a correspondingly large impact on their location in term of activity and use, this can be equally true of large and dense developments, which are not so tall. In both cases there are likely to be positive and negative effects. Projects need to be considered in the round.

Criteria for evaluation

  4.11  Proposals for tall buildings will be considered in accordance with of the following criteria. These are not listed in order of importance; the relative importance will depend on the circumstances of the site and the project. In the case of exceptionally tall buildings, some of the criteria will apply over a wide geographical area, and it will be necessary for the urban design study, referred to above, to address this.

    (i)  The relationship to context, including both topography and built form, and the effect on the skyline. Tall buildings should have a positive relationship with relevant topographical features and other tall buildings; the virtue of clusters when perceived from all directions should be considered in this light.

    (ii)  The effect on the whole existing environment, including the need to ensure that the proposal will conserve, or not damage or detract from:

      —  World Heritage sites and their buffer zones

      —  Scheduled Ancient Monuments and their settings

      —  Listed buildings and their settings, including the backdrops to landmark buildings

      —  Conservation areas and their settings

      —  Archaeology

      —  Historic parks and gardens, landscapes and their settings

      —  Other open spaces, including rivers, their settings and views from them

      —  Other important views, prospects and panoramas

    (iii)  The relationship to transport infrastructure, and particularly public transport provision. This includes the existing capacity available, the quality of links between transport and site, and the feasibility of making improvements.

    (iv)  The architectural quality of the building including its scale, form, massing, silhouette, facing materials and relationship to other structures. The design of the top of a tall building will be of particular importance when considering the effect on the skyline.

    (v)  The contribution that the development will make to external and internal public spaces and facilities in the area: the provision of a mix of uses, especially on the ground floor of towers, and the inclusion of these areas as part of the public realm. The development should interact with and contribute positively to its surroundings at street level; it should contribute to diversity, vitality, social engagement and place making.

    (vi)  The effect on the local environment: including microclimate, overshadowing, night-time appearance, vehicle movements and the environment for those in the vicinity of the building.

    (vii)  The contribution made to the permeability of a site and the wider area: opportunities to offer improved linkages on foot; and, where appropriate, the opening up, or effective closure, of views to improve the legibility of the city and the wider townscape.

    (viii)  Function and fitness for purpose: the provision of a high quality environment for those who use the buildings.

    (ix)  The sustainability of the proposal: sustainability is a central plank of planning policy; it needs to be demonstrated that any tall building proposal is sustainable in the broadest sense, taking into account its social and economic impact, based on whole life costs and benefits.

  4.12  For CABE, the overarching principle will be that any new tall building should be of first class design quality in its own right and should enhance the quality of its immediate location and wider setting; it should produce more benefits than costs to those lives which are affected by it. For English Heritage, the overriding consideration will be whether the location is suitable for a tall building in terms of its effect on the historic environment at a city-wide as well as a local level.

  4.13  CABE and English Heritage attach great importance to the opportunities for all major building projects to enrich the public realm in terms of external and internal space. In many cases it will be desirable to dedicate substantial parts of the lower levels of tall buildings to public uses. Where appropriate, it should also be possible for members of the public to enjoy the views afforded from tall buildings. However, it may not be possible to achieve all of the desired benefits within the confines of the planning application site—for example, when the proposed building fills the site. In many cases, planning agreements (Section 106 agreements) will be an important mechanism for delivering the public benefits of tall buildings proposals. Such agreements will often be the only way of ensuring that a tall building is integrated with its immediate surroundings in a satisfactory way at the lower levels.

Protection of design quality

  4.14  CABE and English Heritage will not support proposals for tall buildings unless they are satisfied through the submission of fully worked up proposals that they are of the highest architectural quality. For this reason, outline-planning applications will not be appropriate.

  4.15  Where planning permission is granted, it is essential that there should be guarantees that architectural quality is maintained throughout the implementation of the entire project and, in particular, that inferior detailing or materials are not substituted at a later date.


  5.1  The consultation period for the document has now closed, but the results have not yet been processed. It is clear from looking at the responses received, however, that tall buildings arouse strong feelings, in professional and in lay circles; and that there is no consensus on the subject in the planning and development community, or amongst members of the public. Responses to the document itself range from "why are you promoting the development of tall buildings?" to "why are you obstructing the development of tall buildings?"; this suggests the document may have got the balance about right.

  5.2  CABE and English Heritage will issue a report on the result of the consultation early in 2002, and will then issue a final version of the guidelines which takes into account comments made.

  5.3  At the same time, a number of local authorities are considering the development of planning guidance on the subject of tall buildings. Some have stated in response to the CABE/EH paper that they will use that as the basis for their own policies.

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