Select Committee on Transport, Local Government and the Regions Memoranda

Memorandum by English Heritage (TAB 18)

  English Heritage was established by Parliament under Section 32 of the National Heritage Act 1983. It is the lead body for the entire heritage sector and the government's principal adviser on the historic environment in England.


  In 1998 an exhaustive study of tall buildings for the London Planning Advisory Committee (LPAC) concluded that "there is no overwhelming evidence to suggest that there is a need for a radical change in London's skyline through the addition of high buildings in order to secure, sustain or enhance London's importance as a World City, or to create a new image of London for Londoners or the world". It stressed that "economic analysis confirms that very high office buildings are not required for London to maintain and enhance its World City role. There is no evidence to support arguments that London will lose jobs to other World Cities if high buildings are not developed". Since 1998, no further evidence or analysis has emerged to challenge LPAC's conclusions. These underpinned subsequent LPAC Advice, which was endorsed by the government in November 1999.

  There appears to be no economic imperative for tall buildings in London or indeed elsewhere. Clearly it is more a question of whether we want or desire them.

  In June 2001 English Heritage joined with the Commission for Architecture and the Built Environment (CABE) to produce a consultation paper Guidance on Tall Buildings which gives advice on the way both English Heritage and CABE evaluate proposals for tall buildings. It sets out how both organisations will deal with proposals in the light of existing planning policies, the information required, and the criteria which both will adopt when evaluating schemes.

  Paragraph 5.8 summarises English Heritage's position, "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 local level. If not, then no tall building will be acceptable, however good the design. Only if it can be demonstrated that the location and context are appropriate will other factors, including design quality, be addressed".

  The results of this consultation are now being assessed and will be published in due course.

  English Heritage also commissioned a MORI poll to find out what the public think. Between 1 and 3 June 2001 MORI questioned a statistically-robust sample of 1,302 residents nationwide, including 477 in London, by telephone. Key findings revealed that:

    —  67 per cent thought it was very important that a building should fit in with its surrounding area;

    —  57 per cent strongly agreed that tall buildings should be restricted to certain parts of cities so that other parts can retain their character;

    —  67 per cent did not want to see new tower blocks erected for living accommodation;

    —  most people, 62 per cent, did not want any more very tall buildings in London over the next few years;

    —  91 per cent approved of the protection of views of St Paul's and the Palace of Westminster; 74 per cent wanted views of more landmark buildings protected; and

    —  only 5 per cent thought that more tall buildings close to London's public parks would enhance the experience of being in them.

  The MORI poll is important because it provides a snapshot of public opinion on tall buildings prior to 11 September. Most people do not want them.

  In the light of public opinion and current economic evidence, in August 2001 English Heritage resolved to set up a cross-sectoral steering group to oversee and validate further research into the economic, environmental and social issues relating to both commercial and residential tall buildings. Following the tragic events of 11 September, we deferred the work until the repercussions on investors' and occupiers' perceptions, market needs and future working patterns become clearer. It will be revived shortly. Detailed research should be complete by the autumn. In the absence of any reliable evidence to the contrary, English Heritage is not convinced that there is any overriding economic or social imperative for a new generation of tall buildings.


  Higher densities may well be needed to maximise development potential in urban areas and to reduce pressures on greenfield sites, but as Lord Rogers pointed out in Towards an Urban Renaissance, this does not necessarily imply high rise. Different forms of architecture—a single point block, a traditional street layout and medium-rise urban blocks enclosing an open space can all be built to the same density. Some of the highest residential densities can be found in low-rise areas of elegant terrace housing like Islington, Kensington, Harrogate, Brighton or Bath, which have become celebrated centres of high density living without sacrificing environmental quality. It is also questionable whether it is prudent at the moment to increase densities within the central area of London, or at major transport nodes, when in many areas the public transport infrastructure is already operating above capacity and unable to cope with existing demand.


  There is no evidence to suggest that certain types of global companies must have tall buildings or they will relocate outside the UK. Height is much less of a factor than location. The City of London, for instance, has flourished in the past 20 years by building low-rise, large floorplate groundscrapers of 8-12 storeys in developments such as Broadgate and elsewhere. Some fine new low rise buildings have been erected for major international companies such as Merrill Lynch and Deutschebank in a form which reinforces rather than erodes the City's distinctive urban grain and character. In any event the City of London now forms part of a much wider international central business district embracing Canary Wharf and beyond, and also parts of the West End. Should a future need for tall buildings be proven, they can be directed to areas such as Canary Wharf, Croydon, Stratford and the Thames Gateway, which are in need of regeneration, where the historic environment is less sensitive, and where local employment needs are greater.


  Historically policies to protect the skyline and the settings of landmark buildings, such as St Paul's or the Palace of Westminster, have arisen in response to specific threats and only after the damage has been done. The St Paul's Heights policies were drawn up in response to the building of Unilever House and Faraday House in the 1930s, whilst the protection of strategic views of St Paul's and the Palace of Westminster were put in place in response to the Nat West Tower. (Tower 42).

  Until 1956 the London skyline was controlled by the London Building Acts of 1888 and 1894 which restricted building heights to the width of the street or to the height of a fireman's ladder (80') plus a two-storey roof with some concession for "architectural features". Many other cities adopted a similar regime, conferring a consistent scale, height and built form on most urban areas. In 1956 the former LCC announced that it would consider each case on its merits. Subsequently this led to the Shell Centre, the Hilton Hotel and a rash of other tall buildings culminating in 1978 with the Nat West Tower, which set a precedent in London for very tall buildings.

  Only 10 of the 34 strategic views of the London skyline recommended to LPAC by consultants were protected by the government in 1991, whilst responsibility for protecting nationally important medium range views across more than one Borough has been passed repeatedly between regional and local government. Today even world-renowned cross-Borough panoramas, such as those from Waterloo Bridge, or of Greenwich from the Isle of Dogs, for example, have no strategic protection. It is not just a question of ensuring that views are not blocked, but of considering a whole range of potential impacts, both far and near. The backgrounds to views of landmark buildings and their wider settings are just as important as the foregrounds.

  Outside London few local authorities have designated views of landmark buildings or city skylines for protection in their UDPs. Bristol and Newcastle have UDP policies to ensure that development does not harm various views, whilst Oxford, for instance, has a rigorous skyline policy with specific height constraints within a 1,200m radius of Carfax. Leeds has policies recognising the importance of relating tall buildings to local topographical features. Birmingham has no specific city-wide policies for tall buildings.


  It is highly debatable whether tall buildings enhance the beauty of our cities, which have developed is a multi-layered organic way in the European rather than North American tradition. One of the principal failings of high-rise buildings of the 1960s and 1970s was that so many were designed with a lack of appreciation or understanding of the townscape context in which they were to sit. At the time modernist architectural orthodoxy regarded context as transient and likely to be replaced. All too often it was disregarded. As a result dreadful damage was done to many towns and cities nationwide at great economic and social cost generating widespread public concern. Although a small handful of tall buildings of this period are listed for their special architectural or historic interest, many of these, such as Centre Point, for instance, exhibit the common failing of disregard for context. Unless we learn from the lessons of the past, there is real danger of repeating the mistakes of the 1960s.

  For these reasons English Heritage strongly believes that if there is to be a new generation of high-rise buildings, locational considerations are paramount if the beauty of our cities is to be enhanced. We believe that they should be countenanced only in the following circumstances:

    —  where it can be demonstrated that they will not harm the historic environment including important views, prospects and panoramas;

    —  where they form part of a clear, agreed urban design framework for the wider development of an area; and

    —  as part of an approved masterplan for the wider local context which has evaluated the potential impacts on the existing environment, including the transport infrastructure at a city-wide as well as local level.

  For every town and city strategic clarity and vision are essential. Dublin has rejected new tall buildings to protect the medium and low rise built form of the city. Paris has grouped its very tall buildings at La Défense. London has an opportunity to do the same at Canary Wharf and perhaps one or two other centres, such as the Thames Gateway and Croydon. Clearer national guidance is required for Manchester, Birmingham, Bristol, Leeds, Liverpool, Newcastle and other large cities.


  Only when a detailed environmental analysis has been carried out, can an informed decision be taken as to whether a site can best accommodate an individual tall landmark building or a cluster. An ad hoc unplanned group of indifferent buildings erected over time without reference to each other, or to the whole, does not necessarily constitute a cluster. It may often be preferable to remove such buildings where their impact is damaging and to encourage low or medium-rise alternatives to stitch back together the urban fabric, although in restricted city centre locations the scope to do so may be limited. If clusters are to be developed, they should be modelled and planned in advance and form part of a wider masterplan underpinned by clear strategic vision.


  Much of the recent debate about tall buildings has been about skyline, but the impact at ground level is just as important at a time when the liveability of cities is under close scrutiny. There is a danger of ignoring the lessons we have learned in the past 30 years in striking a balance between continuity and change. Some of our most successful and vibrant older neighbourhoods have been regenerated through a subtle mixture of refurbishment and contextual infill, disciplined by those qualities that make the area special and which confer local distinctiveness, including scale, height, bulk, massing and materials. Tall buildings do not usually sit comfortably in areas with a fine urban grain or texture. They can create dark, windy canyons and cut out the sky, although in more open-textured, less sensitive areas they can sometimes provide a focus for regeneration and placemaking when they form part of a coherent overall vision for an area of civic significance.


  Power of Place: The Future of the Historic Environment (2000) highlighted that most people regard the historic environment as a totality and place a high value upon it. They value the whole of their environment and entire places rather than just a series of individual sites and buildings. This has profound implications for how we identify and evaluate significance. Many tall buildings by their very nature will have an effect upon the wider historic environment as well as on local contexts. An 8 or 10 storey building, for instance, in a mainly 3-storey neighbourhood will be regarded as tall by those affected by it and could dominate the entire area. An early understanding of the local context and the value of places through character analysis and appraisal is an essential pre-requisite for all major development proposals including tall buildings.

  The historic environment is the context within which development happens. It is an irreplaceable asset representing the investment of centuries of skills and resources. It gives places a unique competitive advantage. It generates jobs. It attracts people to live in an area, businesses to invest and tourists to visit. It is a crucial economic and social asset which we squander or degrade at our peril.


  The careful stewardship of this limited resource is a key component of a sustainable planning framework. Whereas conservation can be seen as the protection of a fixed or limited resource from the pressures of short-term demand, sustainability has been defined as "development that meets the needs of the present without compromising the ability of future generations to meet their own needs" (World Conservation on Environment and Development 1987). Conservation and sustainability are therefore two sides of the same coin. The government has a clear commitment to the principles of sustainable development (Sustainable Development: The UK Strategy 1994), which embraces the objectives of "conserving both the cultural heritage and national resources taking particular care to safeguard designations of national and international importance". Whether or not tall buildings are sustainable is not just a matter of their "green" credentials or energy efficiency, but how compatible they are with the historic environment and wider local context.


  Responsibility for decisions on tall buildings resides principally with local planning authorities. We are concerned that some are not giving sufficient weight to the impact which tall buildings will have on the wider environment beyond their own individual boundaries.

  Nationally proposals for tall buildings are the subject of very close scrutiny by English Heritage. Normally the views of the relevant Advisory Committee are sought. Controversial proposals are reported to Commissioners, who are the decision-making body accountable to the Secretary of State for Culture, Media and Sport.

  In London the Mayor has a strategic role and may direct the refusal, but not approval, of referable applications. Surprisingly, elected members of the Greater London Assembly are not consulted by the Mayor on tall buildings or other major development proposals before decisions are taken on individual applications. This is particularly worrying in the absence of an agreed London Plan which has been the subject of public consultation and scrutiny.


  English Heritage strongly urges the government to issue a Planning Policy Guidance Note on Tall Buildings to provide a clearer planning framework to aid the decision-making process and to reduce the risk of conflict. Such guidance should encourage local planning authorities:

    —  to carry out detailed character appraisals of the historic environment to identify significant strategic views of skylines, landmark buildings and areas and their settings, and important local views, prospects and panoramas; and to include policies for their protection in their UDPs;

    —  having carried out such an analysis, to identify areas appropriate, sensitive and inappropriate for tall buildings in their UDPs;

    —  in areas deemed appropriate, or sensitive, to tall buildings, to commission detailed urban design frameworks as part of wider area-based masterplans to ensure that tall buildings are designed as part of a coherent whole informed by a clear vision, rather than in an ad hoc, piecemeal, reactive manner;

    —  to ensure that proposals for tall buildings are normally accompanied by Environmental Impact Assessments;

    —  to consult with adjacent planning authorities in the preparation of such policies and also on individual proposals which will have an impact upon them, including applications for high level communications masts, illumination or signs; and

    —  to stitch back the damaged urban fabric by encouraging the removal of tall buildings which detract from views, skylines and townscapes and their replacement by lower rise, contextual development compatible with the wider area.

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Prepared 22 January 2002