Memorandum by British Property Federation
The British Property Federation (BPF) is the
trade association of the property industry in the UK. As such
it speaks for a broad membership of companies and individuals
who own, develop, manage and invest in property. The BPF promotes
the views of the whole industry, both commercial and residential.
Its membership comprises the majority of property companies, and
property owning financial institutions, together with the professions
serving the property industry. The property assets held by BPF's
members were collectively valued in 2000 in excess of £100
The vast majority, if not all, tall buildings
are owned by BPF members. Our members will develop the UK's future
tall buildings. The BPF would be delighted to expand on the points
in this memorandum to the Sub-Committee, if that would be helpful.
1. Headline points
2. Tall buildings in the context of existing
3. A response to each of the issues identified
for Sub-Committee examination
1. HEADLINE POINTS
Properly designed and located tall
buildings can significantly benefit society.
Their role and value extend beyond
economic considerations, to include social and environmental factors.
Tall buildings are now frequently
considered landmarks of regeneration.
They can create a sense of civic
We would urge the Government to develop
and publish an explicit policy on tall buildings, not least to
ensure their benefits are not confined to London.
The preservation of strategic views
should be considered as one element within an overall policy governing
Allied to this, a true tall building
policy will acknowledge the importance of balancing and reconciling
the preservation of strategic views with economic and environmental
It is not for the planning system
to judge whether a tall building is commercially viable or not.
2. TALL BUILDINGS
In considering the Government's future stance
on tall buildings, it is worth reflecting on the fact that tall
building development proposals have to take into account many
key components of national and regional planning policy guidance,
including PPG1, 3, 13, 15 and 16. The development of high-density
development (with tall buildings having an important role in this
regard) around transport nodes can, we believe, support the Government's
Integrated Transport Policy. Tall buildings, and the high densities
easily afforded from them, can inject viability into public transport
In terms of our impact on the environment, and
specifically global warming, it is also worth considering that
most of us use more energy travelling to and from work, than in
work, and public transport schemes are therefore fundamental to
reducing energy consumption and its consequences. Typically a
significantly greater proportion of workers housed in tall buildings
travel to work by public transport due to the greater availability
of it, and corresponding restraints in the provision of parking.
With ever-increasing pressure for space within
town centres, tall buildings provide an excellent means of accommodating
necessary commercial and residential development without encroaching
into the greenbelt. In the right circumstances, tall buildings
positively support current national imperatives on issues from
sustainable development to integrated transport.
3. A RESPONSE
3.1 The role of tall Buildings in achieving
high densities in residential areas
Apart from the need to provide housing without
uncontrolled urban sprawl, well-designed and appropriately tenanted
tall buildings can meet a need in providing affordable accommodation
for the workforce upon which an economic cluster depends.
Whilst tall buildings are an excellent means
of achieving high density, the extent to which their development
will be appropriate in what has traditionally been considered
as "residential areas" will depend on commercial viability,
site availability and contextual acceptability.
However the Urban White Paper advocates the
importance of moving away from the practice of allocating large
swathes of land purely for single tenure, or building type, and
away from the notion of purely "residential", or "commercial"
designation. Instead it emphasises the importance of diversity
in creating vibrant communities through mixed-use development.
Within such a properly planned framework, and reflecting the Government's
proposals within the Green Paper on Planning Reform, (published
12 December 2001), tall buildings will have a role to play in
delivery high density in many areas. Including those that can
presently reasonably be described as "residential".
3.2 The provision of offices for certain types
of global companies
To some extent global companies are considering
their location decisions against the availability of well designed
and appropriately located tall buildings from which to operate.
The result is that against these criteria, global companies are
currently considering the UK as one possible location for their
European headquarters. Testament to this is the success of the
Canary Wharf Group in attracting such major investment and employment
A greater factor in determining the importance
of providing tall buildings is the current manifest demand for
big buildings, with some users looking for as much as one million
square foot. If such a building were to be accommodated in the
traditional seven/eight storey City building, (and sites actually
existed in the area to accommodate a building of such a floor
plate), it would cover an area of around 150,000 square foot,
creating enormous travel distances on each floor and reducing
flexibility in arranging adjacencies between departments that
work in network.
Beyond the issue of attracting global companies
to locate their international or European headquarters in the
UK, rather than overseas, many of the UK's largest companies seek
to house as many of their employees as possible, (certainly those
in specific and related departments), in one large building, or
fewer large buildings, rather than numerous smaller buildings.
Increasing restraints on space in urban areas means that tall
buildings are the most effective and cost efficient means of achieving
this. For many of these companies the issue is less one of image,
as perhaps is the case with blue-chip companies, as one of practicality
and simple commercial advantage.
Tall buildings are also being demanded as a
direct result of the increased instance of company mergers, (a
trend that looks set to continue in the foreseeable future), and
the consequential increased demand for single buildings of between
half and three quarters of a million square feet to accommodate
these merged workforces.
3.3 As a means of enhancing the beauty of
As clusters, or isolated towers, there are already
numerous examples of appropriately located and designed tall buildings
that enhance the beauty of our cities. We note that English Heritage
has in fact listed many of them including Centre Point, Millbank
Tower, New Zealand House and the Barbican Towers.
For the following reasons the BPF is confident
that the vast majority, if not all, future tall buildings will
enhance the beauty of our cities. Firstly, all tiers of Government
from the Cabinet to local planning authority now promote high
design standards. Secondly, it is well understood by the property
industry that only well designed, carefully planned proposals
for tall building development that on balance impact positively
on the surrounding area will be approved. Thirdly, we are further
reassured by the existence of the Commission for Architecture
and the Built Environment, (considered an effective body), and
others, all of which can and do provide advice on maximising good
3.4 Where tall buildings should be located
Tall buildings should be located wherever they
are appropriate in terms of need, architectural and environmental
context, and within close proximity to public transport nodes,
or in urban areas where the potential exists for enhanced public
transport links. The latter point is key because the high density
afforded from tall buildings can help deliver the volume of passengers
necessary to entertain investment in public transport services,
the future running of which would be commercially viable, such
as mainline trains and, in London, extensions to the underground.
3.5 What restrictions, if any, should be placed
on the location of tall buildings?
The BPF has already referred to the relationship
between tall buildings, density and transport infrastructure.
Tall buildings may not be appropriate in areas where planning,
financial, or other constraints prevent necessary improvements
to transport infrastructure to meet the needs of the occupants
and visitors to the site.
Notwithstanding the above, regional and local
planning guidance should indicate the areas where proposals for
the development of tall buildings would be considered favourably.
The act of positively indicating preferred locations for tall
building development would greatly reduce both the prospect of
the property industry submitting applications for development
in other areas and, if it were to do so, the prospect of those
proposals being approved. The Government expects local planning
authorities to identify areas appropriate, (and inappropriate),
for tall buildings, and we are concerned that this has not been
properly carried by many local authorities.
Before permitting the development of a tall
building in a specific location, its impact on surrounding microclimatic
conditions, such as wind speed, should be considered. The capacity
of surrounding infrastructure, (including parking and waste removal),
to cope with the pressures placed upon it by a tall building should
also be considered.
3.6 How far they should be allowed to block
As the built landscape evolves, as clearly it
must to permit the realisation of many of the UK's economic, social
and environmental objectives, and to permit this generation to
leave our own legacy to future generations, so must, to a degree,
those views currently designated as important also evolve. It
would be extremely helpful if the Government were to conduct an
impartial assessment of the value of existing views, and crucially
against this value the opportunity cost of maintaining them in
their current form. There are now many areas in London, and other
cities, which are restricted from taking advantage of tall building
development within their strategic position and location due to
rigid adherence to the preservation of views.
One should continually bear in mind that the
preservation of strategic views should be considered as one element
within an overall policy governing tall buildings rather than
its central concern. A true tall building policy will acknowledge
the importance of balancing and reconciling the preservation of
strategic views with economic and environmental considerations.
Having said this, certain existing views should
be preserved, and in preserving them take priority over other
considerations in order to protect the unique character of each
area in which tall buildings might be developed. The fact is that
there is only so much demand for big buildings, and tall buildings
will satisfy only part of that demand, (the skyline of London
will never resemble Manhattan), and therefore we believe that
is possible to provide properly for tall buildings and strategic
3.7 Whether they should be clustered or dotted
As the Government is aware, there are often
real competitive advantages to be gained from the congregation
of commercially compatible companies in one area. The clustering
of tall buildings can achieve this by concentrating sufficient
activity to support ancillary services. Canary Wharf is a case
in point, with major law firms seeking to occupy tall buildings
neighbouring other tall buildings occupied by their investment
bank clients. Others decide that it is advantageous to move to
the same building, as was the case with Citibank and City Corp.
Clustering often enhances the visual impact
of stand-alone tall buildings. In addition, if we are to permit
proper provision of tall buildings to meet future needs without
radically transforming existing views, most future tall buildings
will need to be clustered.
However there are also many examples of "dotted"
or stand-alone tall buildings that successfully meld with the
location and community to which they are a part. The Telecom Tower
is a case in point.
3.8 Whether in the present movement to erect
new tall buildings we are in danger of repeating the mistakes
of the 1960s
What were the mistakes? Is the Sub-Committee
referring to certain residential towers constructed in the 1960s?
The BPF has already referred to a number of safeguards now in
place to protect design quality and local amenity. These include:
Good design, rather than lowest cost
approach, is now a central plank of Government policy.
The property industry's recognition
that only well designed proposals will be entertained by local
The existence of organisations assisting
in the delivery of good design.
Partnerships such as the Design Alliance
to which BPF is a part.
The Green Paper on Planning Reform
published on 12 December 2001 and described by the Chairman of
CABE, Sir Stuart Lipton, as: "a series of proposals from
Government that will allow developers and designers more creative
time and space to generate high-quality developments which are
responsive to community needs and aspirations".
3.9 Whether those making decisions are sufficiently
accountable to the public
National and local politicians exerting an influence
on planning decisions are elected via a democratic process which
we consider provides as great a degree of public accountability
as is reasonably practicable.
3.10 Whether the Government should have a
more explicit policy on the subject
The BPF considers that it is essential for local
planning authorities to be supported by national policy direction
in determining proposals for the development of tall buildings
in order that they can reasonably attempt to determine whether
any impact on local amenity is offset against the benefits to
be derived nationally from their development.
The BPF also considers that it is important
for the Government to develop a more explicit policy on tall buildings
as the economic, environmental and social benefits of their development
should extend to the Regions and not be confined to London, where
the Mayor's broad support for the circumstances of tall building
development will be fully set out in the Spatial Development Strategy