Select Committee on Transport, Local Government and the Regions Memoranda

Annex B


  Thank you for presenting this project to CABE's Commission meeting on 14 March. We acknowledge that the further development of this design has taken into account comments made by CABE after earlier presentations. Our comments below follow the headings set out in our earlier comments on the project, and absorb and expand on those comments as appropriate.


  The first question to consider is one of principle. Irrespective of architectural quality, is a building of this height acceptable on this site? It would be visible from near and far, from many different places, dominating many views. It would become a picture postcard image representing London (as has happened in Paris with the Eiffel Tower—a structure of much the same height). It could be argued that both practical and symbolic regeneration benefits will flow to a relatively neglected part of London from what might turn out to be one of the finest buildings south of the river. We think that the fact that its appearance will imply a nexus of activity at London Bridge is in the project's favour. A location at a major transport interchange is a strong argument for a tall building; but we should point out that that interchange does not in its present state measure up to the building proposed. While the presence of a tower on this site will inevitably impact on certain strategic views, the building need not crowd out other landmark buildings. In summary, we consider that London Bridge could be a suitable location for a tower of exceptional design quality.

  In our view, the further work which has been done on the design of the building since CABE first reviewed it has brought about significant improvements. We think that this design could become a remarkable building which would be worthy of its prominence in views of London—and it would clearly move forward the architecture of London's tall buildings into the twenty-first century. We are far less convinced, however, about the way the building relates to its immediate surroundings at the lower levels, on which it will have a huge impact. We think that considerably more work needs to be done on this before planning permission should be granted.

Wider context : the need for a masterplan

  The London Bridge Tower proposal, and the redevelopment of London Bridge station presently being planned by Railtrack and their architects, are both very large projects, and the sites are contiguous. In our view, the reordering of London Bridge station and the transport interchange is the most important aspect of the redevelopment of this area. The potential benefits to millions of people who live or work in London are enormous. It would not be acceptable for the London Bridge Tower proposal to jeopardise this; in fact, for the proposal to be convincing in terms of its location, it needs to show how it can contribute to securing these benefits.

  Although we acknowledge that efforts have been made to make the projects compatible, we believe that much remains to be done in this area. We believe that further attention should be paid to the urban design and masterplanning implications of developing the site in this way. This applies both to the relationship with the station and to the wider context. Although more work has been done on the coordination of the two projects (tower and railway station) since December, which is welcome in itself, there remains an unrealised potential for each project to benefit the other in a way that improves the quality of this part of London for those who use it and pass through it. We hope that the developer of this project and Railtrack will continue to work together closely on this.

  We observed before that, as a consequence of being an extremely tall building which fills the site owned by the developer, it may not be possible for this project to deliver, within the confines of a limited site, public realm benefits commensurate with the scale and ambition of the scheme.

  All of the above leads us to recommend that work should be carried out on how the two projects—the tower and the station—could work successfully with each other (as well as each having to work independently in case the other does not proceed). We believe that because of the great impact of this project, a masterplan should be prepared which deals with the tower project, the station project and the wider area, including the various aspects of the historic context. The planning application, in our view, should not be considered in the absence of such a masterplan. Clearly such an exercise will not be successful without the cooperation of adjoining owners; we believe that there must be a role for the local authority and the Greater London Authority to facilitate this.

  The tower has not yet been provided with an adequate setting. The masterplan exercise needs to examine ways of achieving this: to provide some public open space of high quality, and to achieve a sense of arrival at the complex as a whole. This needs to be considered in conjunction with the arrangements for buses—a bus station is unlikely to form an adequate forecourt for a transport interchange or for a 1 million sq ft commercial building. In our view, it would not be acceptable for the two projects to proceed without providing a first-class long-term solution for buses at London Bridge which does not compromise the settings of or the approaches to the buildings. There should be a wide-ranging examination of the possibilities, including the possibility of dispersing bus stops more widely to reduce their impact - some transport interchanges work successfully without large bus stations.

  The masterplan ought to reveal a number of ways in which the tower project can deliver public benefits outside the red line of its own planning application site boundary—these should be delivered in due course by means of a Section 106 agreement.

Scheme design

  We believe that the revised massing of the lower parts of the project is an improvement on the previous version, and that relating the massing to the proposed station redevelopment rather than to existing larger buildings nearby is a good move. This strategy further reinforces the need for coordination between the tower development and the station development.

  In our view, the work which has been done on refining the articulation and the detail of the spire has been a success. Clearly, the result will be heavily dependent on continuing refinement of the details, and on the quality of materials—both would need to be closely controlled by any planning consent.

  We draw attention to the extent to which the building will in fact be reflective rather than transparent, whatever the quality of the white glass to be used. It seems to us that there is an opportunity to achieve a visual lightness which would be a welcome contrast with the gloomy heaviness of so many other towers in central London, and we hope that the detailing as a whole will take this into account.

  We strongly support the ambition to make this a low-energy tower, and we think that the symbolic potential of the "radiator spire" is attractive. So many towers have been profligate with energy that it will be important to seize the opportunity for this project to begin to redeem this building type in London. The top of the spire, as a built representation of this, therefore needs to be completely convincing in energy terms rather than just an attractive symbol.

  The architecture of the lower parts of the building seems to us to remain a weakness in the design, and this is connected with the more general failure of the planning of this part of the scheme in its wider setting. We sense that less work has been done on the design of these parts than on the upper parts. We have seen little yet to convince us about the quality of the lower parts when seen from its immediate environs. People will travel to see this building, and what they see when they get there needs to be as impressive as what they see from a distance. This, of course, is connected with the earlier point about the project's setting. We continue to believe that more needs to be done to illustrate these aspects adequately; a detailed model would be very useful.

Protection of design quality

  Planning consent is only likely to be granted for this building if, among many other considerations, there is consensus that the design is one of the very highest quality. This can be assumed to have been recognised by a developer who has engaged one of the world's leading architects. It is essential, therefore, that a consent, if granted, should guarantee this quality, in detail as well as in general terms, with sufficient robustness to resist "dumbing down". This is not to doubt the good faith of the developer, but simply to recognise the legal realities of the planning system. Legal advice needs to be taken by the local planning authority to achieve this robustness: to ensure, for example, that the type of glass proposed by the architect cannot be replaced by a less acceptable alternative. We recommend strongly that, if a planning consent is to be granted for this project, a way should be found of guaranteeing (a) the continuing involvement of the Renzo Piano Building Workshop as principal architect for the project through to completion, and (b) the integrity not merely of the overall design but of the details and materials.

  We are pleased to learn of the developer's commitment to providing such a guarantee, and we would like to offer our help to the developer and local authority in finding a legally robust way of achieving this.

Illustration of views

  The work which has been done to illustrate the longer views of the building is welcome, but we are not yet convinced that it is comprehensive. The local authority and other interested parties need to scrutinise the proposals carefully and ensure that all relevant views of the tower have been dealt with; that they are illustrated from appropriate observer positions; and that the results are verifiably accurate.


  The great fear of the Commission is that a planning consent may be granted for something which it does not make economic sense to build, and that an inferior design will be substituted. We urge the planning authority to be alert to this danger, to insist on robust economic data and to employ the expertise required to evaluate this data fully. The planning authority will need reassurance that there has been sufficient development of the design, and sufficiently close collaboration between the design team and the cost consultants, to ensure that the building costs which are being relied on do in fact reflect accurately all aspects of the design for which planning consent is being sought.

Strategic implications

  We would like to draw attention to the strategic implications of this planning application. We think that it would be unwise for it to be determined in isolation from the wider issues concerning London's future skyline. What would London be like with five towers of comparable, or greater, height; or twenty-five? What is the attitude of the public to this prospect? It would be strange if the face of the city were to be transformed without a public debate. In the light of the number of tall building projects which are continuing to come forward, we think that these questions should be considered by the relevant interested parties—including the London local authorities, the GLA, English Heritage and CABE—as a matter of urgency.


  In conclusion, we believe that a tower of this height on this site could be successful; and that the design as it now stands holds out the promise of a world-class building. It will not be possible to fulfil this potential, however, without resolving the following problems—and in our view this needs to done before the planning application can be determined.

    —  The impact of the project is such that it needs to be placed in the context of a masterplan, which deals with the immediate surroundings in all directions and with the wider setting.

    —  The building fills the site which the applicant owns and does not yet have an adequate setting. This is one of the principal failings of the existing tall buildings at London Bridge. There is a need for some high quality public space, which will benefit both the new tower and the station.

    —  Arrangements for buses at London Bridge need to be reconsidered in the light of the tower project.

    —  In conjunction with the work on the building's setting, more work needs to be done on the design of the lower parts of the tower, which we think is the least convincing part of the architecture.

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