Memorandum by Sellar Property Group (TAB
1. The Sellar Property Group are pleased
to have the opportunity to submit evidence to this Inquiry and
trust that their submissions will be of assistance to the Sub-Committee.
2. The Sellar Property Group is the developer
of the proposed 67-storey London Bridge Tower, which adjoins the
London Bridge Station in the London Borough of Southwark. The
architect is Renzo Piano and the application for planning permission
is due to be considered by the London Borough of Southwark early
3. The evidence presented represents the
legitimate interests of a commercial developer who is a key stakeholder
in development of such buildings as are currently being studied
by the Sub-Committee.
4. The evidence given, however, is against
the background of the considerable comment on and public interest
in these issues in recent months.
5. The current promotion of tall buildings
is simply a part of an overall drive towards achieving higher
urban densities. Without the freedom to develop particularly tall
buildings in areas of greater density, there will be inevitable
recourse to a uniform, flat skyline with a consequent diminution
of public open space.
6. Tall buildings need to be understood
in the context of Central Government Policy on four key issues;
maximising the use of available brownfield
land in urban areas;
enabling increased density of development
within central urban areas without recourse to green belt development
and urban sprawl;
maximising the potential of transport
interchanges to allow dense development without significant adverse
impact on existing transport infrastructure; and
encouraging the greatest possible
use of public transport, as opposed to the private car.
7. In relation to development in primarily
residential areas, the achievement of high densities does not
necessarily require tall buildings, although in some cases tall
buildings may be appropriate. The acceptability of such a solution
will very much depend on local context.
8. For office development, different considerations
apply. In major cities, there is a real and identifiable need
to meet market demand for large areas of uniform floorspace in
single buildings, usually in prestige locations. This is particularly
important to the City of London, which has a vital role to play
in the national economy. A typical requirement would lie between
400,000sf and 750,000sf.
9. Such requirements can be met either by
building tall buildings or lower "groundscrapers" with
significantly larger floorplates. The excessive floor areas of
many ground scrapers result either in a slab block arrangement
such as seen at Croydon, or in a deep plan arrangement depriving
most occupants of any contact with the outside world. Groundscrapers
tend to have an adverse impact on adjacent public open space and
it is clear from occupier surveys that workspaces in airy tall
buildings are actually preferred to similar, dense, low-rise establishments.
10. Canary Wharf is currently the only location
in London that offers tall buildings to the market. Currently
demand clearly exceeds supply and developer will seek to supply
into this market.
11. The issue of location is a highly subjective
one. While some seek to show that the provision of tall buildings
would adversely effect existing cityscapes, others believe that
visual qualities of our major cities could be enhanced by exciting
new architecture in the form of tall buildings.
12. SPG feels strongly that decisions as
to the acceptability or otherwise of tall building proposals should
be based upon accurate visualizations of specific proposals in
their actual context. Such visualizations are undoubtedly possible
using modern technology.
13. To attempt to proscribe conditions for
the acceptability or otherwise of tall buildings in the abstract
will restrict the authorities ability to make judgements on proposals
within specific contexts.
14. Further, in reaching a judgement on
such specific proposals, the effects of tall buildings on views
should be only one of the many material considerations. Others
should include the need for the development, regenerative effects,
benefits to local communities and further opportunities created
in the local area.
15. Clearly mistakes were made in earlier
decades which colour our view of tall buildings today. The question
is whether these mistakes would be repeated in the generation
of tall buildings proposed today.
16. Many factors have changed since the
1960's. Architects, developers and planners have shown themselves
more than capable of learning the lessons and contemporary developments
benefit greatly from past experiences.
17. It is clearly not appropriate to create
policy against tall buildings based solely on poor experiences
in the past. It is interesting to note that some of the previous
generations of tall buildings, such as Centrepoint and the BT
Tower areor are proposedto become Listed.
18. A key consequence of the lack of appropriate
planning policy in earlier decades is the unacceptable "peppering"
of individual tall buildings on most city skylines. This demonstrates
the obvious necessity to protect the cohesion of the overall skyline
of our cities. This will be an issue that prevails over several
adjacent planning authorities.
19. In some parts of cities it may be appropriate
to seek to cluster tall buildings so as to draw attention to a
particular part of the City such as the Central Business District.
In other situations a high quality mixed-use tall building may
be acceptable on its own and indeed may even be less effective
in terms of cohesive massing if other tall buildings are allowed
20. Clear guidance will be necessary and
this should come from the authority with responsibility for the
overall cohesion of planning policy in the city concerned. However,
this guidance should not be exclusive to further proposals for
centres of density and the relevant city authority should be required
to review policy as major proposals that show other significant
benefits are brought forward.
21. Another deficit of past decades was
poor quality design and detailing. This became particularly apparent
in tall buildings.
22. It is clear that tall buildings will
have a greater than average impact on the built environment and
as such, design quality is of paramount importance.
23. We welcome current initiatives from
government, which have resulted in the establishment of the Commission
for Architecture and the Built Environment. (CABE) Our view is
that the achievement of higher standards of design should be promoted
by early referral to CABE and the appropriate use of reserved
matters in planning approvals.
24. Quality should not be used as a reason
for reservations in principle to tall buildings in London and
other major cities.
25. Finally, the current requirement for
full environmental impact assessments for all major developments
does ensure that all the impacts of tall building proposals will
be adequately considered at the planning stage. This was simply
not the case in the 1960's and marks a complete change in a local
authority's ability to determine an application.
26. In the Sellar Property Group's view,
decisions regarding tall buildings should be taken at local level
by those who represent the people most directly affected by a
27. In large cities, tall buildings will
have an impact beyond the immediate vicinity and a more strategic
view needs to be taken by the city authority. But once these strategic
factors have been taken into account, the final decision should
be returned toand remain withthe local council for
28. Whilst the views of interested parties
and consultees must always be taken into account, the weight to
be given to each should be for determination by local councils
in the light of guidance by central government relating to the
mandate of such interest groups, and the full range of factors
relevant to the proposal.
29. Such decisions should be taken in the
context of up to date and properly researched planning policies.
Unfortunately, the present system results in lengthy delays in
the updating of policy, such that decisions often need to be taken
against the background of emerging policy, or, worse, policy which
has become out of date. The Government's green paper includes
measures to speed up the plan making system and reduce the difficulties
that are occasioned by out of date policies. This is to be welcomed
as is the strong recommendation for thorough local consultation
to be carried out by a developer prior to the submission of any
30. The Sellar Property Group does not believe
that it is necessary for the Government to have a more explicit
policy relating specifically to tall buildings. The context for
tall buildings is very largely set by existing Government Policy
Objectives relating to major projects, sustainability, heritage,
31. Where an application has been the subject
of extensive public consultation, and the local authority in question
has properly discharged its responsibilities, there seems no reason
for Central Government to exercise its call-in powers in relation
to tall buildings per se. Such action simply results in lengthy
planning inquiries which are excessively costly to public agencies,
lead to considerable delays, and rarely contribute significantly
to the quality of the decision taken.
32. Furthermore, successive or excessive
call-in will deter developers from proposing any substantial schemes
that would provide significant benefit to the communityespecially
those that impinge on existing transport infrastructure.
33. Sellar Property Group trust that the
above submissions are of value to the sub-committee in their consideration
of this important topic, and would be happy to give oral evidence
in front of the committee if asked to do so.