Select Committee on Transport, Local Government and the Regions Memoranda

Memorandum by The Chelsea Society (TAB 15)


    —  Tall buildings have great impact when built in and near streets of 18th and 19th century terrace houses. They overlook nearby residents, block the sky as seen from adjacent windows and streets and, when built next to the Thames, help transform the river's generous, natural openness into a corridor of buildings.

    —  Built form studies published by the Urban Task Force and the evidence of Kensington and Chelsea itself (a high density district containing few tall buildings) demonstrate that terrace houses and six-storey mansion blocks with communal gardens can provide high densities.

    —  Without the presence of policy, the location of high-rise buildings is random and can be very disruptive. It is determined by the chance availability of large sites (especially along the Thames), the desire of developers to impress and sell opportunities for some residents to indulge in the selfish desire of overlooking their neighbours.

    —  The Chelsea Society is not opposed to high buildings in all locations, but is strongly opposed to further tall residential buildings both in Chelsea and visible within Chelsea, particularly from Thames-side.

    —  The Society urges the House of Commons Urban Affairs Committee to press the Government to ensure that Greater London is covered by a rational and sensitive policy for controlling the height of buildings. Consideration should be given to creating a system of control similar to that operated within the former Greater London Development Plan.

    —  The Commission for Architecture and the Built Environment (CABE) rightly represents architectural thinking. As such there is a risk that it will follow prevailing architectural fashion. In the present intellectual climate, it therefore seems likely to support tall residential buildings at the expense of residents and the environment. In the absence of any policy for high buildings this is, to say the least, unfortunate.

    —  The Society urges the Committee to consider how the promote the idea of "listing" ill-located and ugly tall buildings so that, when redeveloped they are reduced in height. Examples of possible candidates in Chelsea include the Holiday Inn Hotel (formerly Penta) in Cromwell Road, the World's End Estate in Chelsea and the Empress State Building in Fulham.


A.  Background

  1.  This submission considers tall buildings in the context of high-density, residential Inner London. It addresses the following issues:

    —  the role of tall buildings in achieving high densities in residential areas;

    —  where tall buildings should be located, including what restrictions should be put on their location;

    —  whether, in the present movement to erect tall buildings, we are in danger of repeating the mistakes of the 1960s;

    —  whether those making decisions are sufficiently accountable to the public; and

    —  whether the Government should have a more explicit policy on tall buildings.

  2.  Notes on existing tall buildings in and adjacent to Chelsea are covered in Appendix 1. The full background to current policy on tall buildings in central and inner London is set out in Appendix 2.

B.  Policy on high buildings in Central and Inner London

  3.  The County of London Plan 1943 set out three "height zones", based on concern about fire hazards and the London Buildings Act.

  4.  In 1954 these limits were removed and led to a spate of tall buildings.

  5.  When the Greater London Council was established in 1965 it was required by the Development Plans Regulation to have a policy on high buildings. London was classified into:

    —  areas in which high buildings are inappropriate;

    —  areas which are particularly sensitive to the impact of high buildings; and

    —  areas in which a more flexible or positive approach is possible.

  6.  The three categories were based on London-wide visibility studies and created a system for evaluating tall building proposals that was not based on arbitrary limits or ad hoc decisions. Cases could be assessed on their wider impact. All applications for high buildings were, in addition, referred to the GLC before determination by the relevant London Borough.

  7.  Most of Chelsea, because of its proximity to the Thames (an Area of Special Character) was designated as an "area in which high buildings are inappropriate", as was the Battersea riverside.

  8.  The abolition of the GLC in 1986 led to tall building applications being decided by London Boroughs unless called in by the Secretary of State. A weakening over the control of tall, Thames-side buildings followed. Fulham gave permission to Belvedere Tower at Chelsea Harbour and, following call-in, the Secretary of State to Montevetro, designed by Richard Rogers, in Wandsworth.

  9.  Supplementary guidance on Strategic Views and on the Thames was issued by the Secretary of State in 1990 but provides less control over tall buildings than the GLDP. Treatment of the Thames is particular disappointing and gives no guidance on appropriate heights for buildings. New guidelines, such as those for the river from Kew to Chelsea Bridge, may be superior, but this is by no mean certain.

  10.  The current situation in Chelsea is:

    —  The Council's Unitary Development Plan seeks "to resist a new high building which would significantly exceed the height of neighbouring buildings and which would harm the skyline."

    —  The Mayor of London's "Interim Policy for Tall Buildings" which, not having undergone public consultation or testing at examination in public, has limited status. However all riverside buildings over 25 metres high have to be referred to the Mayor who has power to direct their refusal.

    —  The Secretary of State for Transport, Local Government and the Regions has issued weak guidelines but has power to call in all applications.

  11.  London has been through several periods of "deregulation" of high buildings and inappropriate developments have always resulted. The current policy framework and the Mayor for London's "Interim Policy for Tall Buildings" give little protection. Chelsea and other riverside Boroughs need well-founded technical guidelines for the Thames Policy Area that protect 18th and 19th century districts from inappropriate tall buildings.

C.  Proposed tall buildings in Chelsea

  12.  Chelsea is today faced by an application for twin residential towers—one 130m/39 storeys and the other 91m/25 storeys—beside the Thames next to Lots Road Power Station. Sir Terry Farrell's design for Circadian, shows towers with seductively slim profiles when seen from east and west along the river and slab facades when seen from nearby streets. The Society, in making representations to the Council, has objected to these towers on grounds that they would:

    —  contribute to over-development at a location poorly served by public transport at the same time as other traffic-generating developments are being built nearby at Imperial Wharf in Fulham and the College of St Mark & St John in Chelsea;

    —  dominate the outlook of existing residents in the Victorian streets to the north of Lots Road;

    —  deflect blasts of wind onto the stretch of Thames-side walk to be created with the development; and

    —  contribute to the "Manhattanisation" of the hitherto open, tree-lined and river based character of Chelsea Reach.


D.  The role of tall buildings in achieving high densities in residential areas

  13.  Research in the 1960s by Professor Sir Leslie Martin and Dr Lionel March at the Cambridge University School of Architecture clarified the relationship between density and building form. This research showed that rows of terrace houses with gardens (as in much of 18th and 19th century Chelsea), seven storey mansion blocks, or apartments built around garden squares (as at Elm Park Gardens in Chelsea), can, just as much as towers, achieve high densities. Indeed, the Royal Borough of Kensington and Chelsea has the highest population density in the United Kingdom, yet it contains very few tall buildings.

  14.  Figure 2.6 in "Towards an Urban Renaissance", the final report of the Urban Task Force, shows the high density of 75 dwellings per hectare deployed in a tower, in terraces and in garden apartments.

  15.  In the view of the Chelsea Society, built form research has demonstrated that residential towers are not necessary to achieving high densities. Towers are the result of architectural fashion.

E.  Where tall buildings should be located, including what restrictions should be put on their location

  16.  Tall residential buildings may well have a role in large areas of new development such as London's Docklands. There they can be sited to provide valuable focal points and to create landmarks that distinguish one place from another. (It follows that, like church towers, they should be varied rather than repetitions of the same design.)

  17.  The Chelsea Society believes that there is no case for building them in districts where the nearby street scale is that of the 18th and 19th centuries.

  18.  Chelsea Reach is an open stretch of river crossed by Albert and Battersea Bridges. At high tide it is a huge river, smelling of the sea and bringing openness and a sense of the natural into the heart of London. The Council's World's End Estate, then Chelsea Harbour and, most recently, Montevetro in Battersea began the indiscriminate diminution of this openness. Sir Terry Farrell's proposed towers would take it further.

  19.  The Chelsea Society believes that in a huge city such as London the feeling of openness provided by the river should maintained and not diminished by enclosing it with tall buildings.

F.  Whether, in the present movement to erect tall buildings, we are in danger of repeating the mistakes of the 1960s

  20.  The mistakes of the 1960s were of four kinds:

    —  Some tall blocks of flats were built with untested and unreliable materials and in some cases with inadequate thermal and sound insulation.

    —  Flats in towers were rented to households some of whom would have been bad neighbours in houses but whom, in the confined landings, corridors and lifts of tower blocks, made life impossible for others. This was not an architectural problem. It was about bad housing management and irresponsible behaviour.

    —  The tall buildings of the 1960s were utilitarian in appearance and often located with little thought about their effect on their surroundings.

    —  Insufficient recognition was given to the way in which tall buildings deflect and funnel unpleasant winds and dust into the spaces around them.

  21.  It is unlikely that, in current conditions, the first two problems will be repeated but, given the current enthusiasm for tall buildings and the lack of a clear policy along the Thames, the Chelsea Society fears a repeat of the insensitive location of tall buildings. Wind effects are also a continuing problem for all towers, notwithstanding mitigation following wind tunnel tests of models.

G.  Whether those making decisions are sufficiently accountable to the public

  22.  The Society has doubts about the accountability of the Commission for Architecture and the Built Environment (CABE). The Commission expressed its support of Sir Terry Farrell's design for the Lots Road Power Station site within weeks of the application being lodged, and, in particular, supported the proposed towers.

  23.  CABE's "Guidance on Tall Buildings—Consultation Paper June 2001" sets out criteria for evaluating tall buildings. Criterion (vi) is about: "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." (Chelsea Society emphasis.)

  24.  The Society notes that existing residents of, for instance, Stadium Street, Ashburnham Road, Burnaby Street, Tadema and Uverdale Roads would have their southern outlook dominated by the slab sides of Sir Terry's towers. They would also be looked down upon by tower residents. This is not a matter of daylighting or overshadowing, both of which are considered in Circadian's Environmental Impact Statement. It is to do with the effect of the towers on the psychology and comfort of those who are overlooked.

  25.  The Chelsea Society does not believe that CABE, notwithstanding a site visit, has put sufficient weight on the overpowering scale of the proposed towers for nearby residents.

  26.  The Society also believes that whereas the south facing Thames path could have been designed as a riverside delight without equal in Inner London, the towers will deflect onto it unwelcome blasts of wind.

  27.  The Chelsea Society considers that CABE, which rightly represents architectural interests, is bound to be influenced by architectural fashion and to give architectural values higher priority than the amenity of those living and walking in the vicinity of proposed towers.

H.  Whether the Government should have a more explicit policy on tall buildings

  28.  The Greater London Development Plan contained criteria used to evaluate proposed buildings. These ruled out high buildings in sensitive places such as the edges the Royal Parks, Battersea Park, the Thames and Areas of Metropolitan Importance. It was held that such places are intrinsically unsuited to the location of towers.

  29.  Manhattan's Central Park with its fence of skyscrapers is, without doubt, an important feature of New York. But London is not New York. It is famous for being a huge city blessed with a sense of the country. Hyde Park, before the building of the Hilton Hotel in Park Lane and Knightsbridge Barracks was an astonishing example of rus in urbis. Insensitive siting of tall buildings destroyed that unique feature. Such buildings should be "listed" to ensure than, when rebuilt, their height it greatly reduced.

  30.  The Chelsea Society therefore urges the House of Commons Urban Affairs Committee to recommend a review, such as the one that informed the GLDP policy on high buildings, leading to a London-wide policy on the appropriate height of new buildings. This would involve:

    —  A study to assess the suitability of areas of London to accept high buildings.

    —  Guidance for development along the Thames, including clear guidelines for the height of buildings in a "blue belt"—the Thames Policy Area.

    —  A statement from the Secretary of State about the status of the Mayor's Interim Policy on Tall Buildings.

    —  Consideration of how existing tall buildings, which are inappropriately located or overweening, could be "listed" to ensure that, when redeveloped, they are reduced in height.

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