Select Committee on Transport, Local Government and the Regions Memoranda

Memorandum by Westminster City Council (TAB 39)


  1.1  Westminster City Council have been at the forefront in the debate on tall buildings in London commissioning independent consultants, EDAW, to provide a comprehensive study on the place for tall buildings in Westminster—"City of Westminster High Building Study". This work was completed in September 2000. See appendix "A" for background to this report.[20]19

  1.2  In order to clarify terms it should be noted that Westminster City Council uses the terms "Tall Buildings" and "High Buildings" interchangeably. The Unitary Development Plan (UDP) definition describes them as "Buildings or structures that are significantly higher than their context. In Westminster, the urban context is generally low to mid-rise, characterised by buildings of up to 6-8 storeys in height.

  1.3  The High Buildings Policy in the replacement Unitary Development Plan Policy (DES 3) was formulated with reference to the EDAW report-the full policy DES 3 can be found at the end of Appendix "B".[21]20 The report recommended that Westminster City Council's Policy should not be amended to positively identify areas for high buildings and that the generally restrictive approach to high buildings should remain.

  1.4  The EDAW report concludes that Westminster is, on the whole, to be considered an unacceptable location for high buildings because of the particular sensitivity of the City in terms of its architectural and historic nature. Some 76 per cent of the Borough is designated conservation area and there are over 11,000 listed buildings. In addition, there are important Strategic Views that have statutory protection, as well as the need to protect the Palace of Westminster and Westminster Abbey World Heritage site. There are also important metropolitan and local views and panoramas that need protecting including views from London Squares, the Royal Parks, the Grand Union and Regents Canal and the River Thames (further advice on the River Thames is given in Thames Policy Area Supplementary Planning Guidance prepared in accordance with RPG 3B/9B).


(a)  Role

Densities in Residential Areas

  2.1  While tall buildings could provide some high density housing solutions on appropriate sites, such sites in Westminster are likely to be extremely limited given the constraints identified in the EDAW report and the Unitary Development Plan Policies, 2nd deposit January 2001.

  2.2  The design of successful high rise residential blocks raises numerous issue at ground floor level including the provision of active frontages, the creation of interest and vitality in the public realm, the provision of car parking and issues relating to servicing such as refuse collection and disposal. These design considerations are more easily addressed in medium rise/high density schemes which provide similar densities of housing.

  2.3  High rise housing still has a stigma attached to it and is unlikely to be considered suitable to accommodate families. Council policies focus on building balanced communities through improvements to the physical fabric and services. These objectives are best met through the provision of a mix of housing types within a well-designed and managed public realm.

  2.4  The planning system now deals with design issues relating to crime, and tower blocks and high rise buildings are associated with antisocial behaviour. More traditional schemes will provide a higher level of public surveillance and policing through its inherent design qualities rather than the more inward looking arrangement and internalised entrances required in high building design.

  2.5  Notwithstanding the lack of new high buildings, Westminster achieves high density housing provision. Through appropriate urban design policies there has been a significant residential population increase. The population has risen from 175,000 in 1976 to 244,000 in 2001, a rise of 69,000 in 25 years.

Global Office Provision

  2.6  The Council recognises the City's unique role and character and the twin role it plays in being both the heart of a World Class and Capital City. Westminster contains prestige locations for headquarters and for professional and other firms. The City of Westminster has over 40,000 VAT registered businesses ranging from the very small to the biggest corporate and public offices with no visible demand for high buildings in themselves. Appendix "C"[22]21 describes Westminster's Planning Strategy as contained in Part 1 of the UDP and includes the strategic policies relating to its capital and world class City status.

  2.7  The intrinsic value of Westminster's historic townscape and the resulting high quality environment is a major factor in Westminster's continuing economic success. The prestige attached to a West End address is among the City's greatest assets and is largely dependent on the high quality environment. The City attracts many sectors of the business community who function effectively in the types of accommodation available.

  2.8  The Council places great emphasis on conserving and protecting the unique environments of Westminster and its remarkable historic heritage. In framing our planning policies and in their application, we have taken a firm stand on protecting those things that are of lasting value and shape the quality and nature of the city. In providing exceptional design and planning advice the Council shapes change effectively within the existing fabric allowing for the creation of flexible office accommodation without harming those qualities which people value most about the city.

  2.9  Policies in Part 2 of the UDP seeks to accommodate the changing requirements of the economy. These will be met through the refurbishment and renewal of business premises as stated above and also through a limited number of new, large "state of the art" business premises such as those permitted in the Paddington Special Policy Area. This approach is consistent with "Towards the London Plan—the Initial proposals for the Mayor's Spatial Development Strategy", which envisages parts of the City of London and Canary Wharf, and some main rail termini, as the areas where the additional capacity for London's global economy sectors will be provided. (Paragraph 2.19)


  2.10  While tall buildings of high architectural quality can provide visual highpoints and prominent objects of beauty, it is wrong to assume that they are in some way inherently more beautiful or iconic than low or medium rise buildings. The City is full of beautiful low-rise buildings from all ages including modern. While there are some high rise buildings that may be considered beautiful and iconic (Telecom Tower and Centre Point) they are generally few and far between and intrinsic architectural merit alone is not enough to justify a tall building. For example, Millbank Tower (listed at Grade II) is widely acknowledged as successful as a landmark in views along the Thames. However, its impact on the skyline in views from St James's Street is seriously harmful to the setting of St James's Palace. Further, the great majority of high rise buildings in London are of mediocre or poor design and due to their prominence (by virtue of their height) the damage they do is far greater than many of the lower buildings of poor design eg The impact of Knightsbridge Barracks, the Hilton Hotel and the Shell Centre in views from the Royal Parks.

  2.11  The need for architectural excellence for high rise buildings is such as to make their design problematic for all but the most prestigious clients—the risk factor in getting it wrong is formidable. Even where there is a consensus that good designs have been achieved there is often poor design and interface at ground floor level with the public realm. Generally slender towers are going to be more elegant and better in silhouette than bulky, wider and more solid structures. There is a case to be made that the silhouette and profile of a high-rise building is more (and certainly as) important as the architectural detailing—certainly both must be to an exceptional standard to be considered acceptable.

(b)  Sustainability

  2.12  The sustainable development of the City will be achieved by meeting economic, social and environmental needs in a balanced and integrated way. Environmental considerations form only one part of sustainable development, other elements such as social, economic, cultural and equity are equally important.

  2.13  Sustainable residential communities will be achieved by building more homes but also by safeguarding residents' amenities, protecting residential uses from commercial activities and maintaining and encouraging a full range of accessible local services and shopping facilities.

  2.14  The quality and character of Westminster's built, landscaped and natural environment will be at the forefront in all decision making. This will be preserved and enhanced; particularly the historic fabric, which is one of London's major assets as a World City, and an irreplaceable resource.

  2.15  The City Council will promote the highest standards of sustainable design principles in new developments and in alterations and additions to existing buildings. It will ensure that all developments, particularly with regard to bulk and height, make a positive contribution to the environment, retaining the distinctiveness of different areas and relating well to their surroundings. In order to encourage this process, the City Council has recently published an SPG entitled "Design Matters in Westminster".

(c)  Siting

  2.16  The location of towers is of critical importance and locational criteria should be the primary consideration before any other factors are considered. If the location is inappropriate then the quality of the design will be a secondary consideration.

  2.17  Location criteria should include views (strategic, metropolitan and local), the effect on the setting of conservation areas and listed buildings and access to adequate public transport facilities. Overshadowing, and the impact on microclimates and neighbours, particularly residential uses, also need to be considered. The UDP policy clearly sates the location criteria which all need to be met and no high building should be allowed unless it meets these tests.

Impact on views

  2.18  High buildings should not be permitted if they appear intrusive in either strategies or important local views or if they compromise the scale or setting of important landmark buildings, whether in the foreground, middle distance or background of those views. Of the ten Strategic Views, four of them cross Westminster and of these, two focus on the city at the Palace of Westminster. A fifth view, that to St Paul's Cathedral, has its station point within the city at Westminster pier. In addition to these strategic views there are many important local views into, across and out of the city. Of these local views, a number are of metropolitan importance, either because they form part of the wider identity of London as a whole, eg the view of Horse Guards from the footbridge in St James's Park and that of Buckingham Palace along the Mall from Admiralty Arch; or because they affect more than one borough, eg the view of St Paul's Cathedral from Waterloo Bridge and of the World Heritage Site from the South Bank and the view of St Paul's Cathedral from the river terrace of Somerset House.

  2.19  Policy STRA 28: Views and High Buildings states it is the City Council's aim, "To protect and enhance important views across and within Westminster and to resist inappropriately designed and located high buildings and structures."

  2.20  The strategic views of the Palace of Westminster and St Paul's Cathedral are protected in the UDP. In addition, examples of Local Views, particularly those that cross the city boundary, are identified in the Plan in draft Supplementary Planning Guidance on the Thames Policy Area. These are recognised as making a valuable contribution to the City scene, particularly along the River Thames and canals. Further work to identify and record Local Views will be carried out as an integral part of the City Council's ongoing programme of preparing Conservation Area Audits for all of its Conservation Areas.


  2.21  A Tall building should only be considered where character analysis has demonstrated it to be suitable for the proposed location. It is considered that the sieve analysis approach followed in Westminster's EDAW study might be adopted to cover London as a whole. It would be particularly relevant for the river corridor.


  2.22  Each proposal should be judged on its own merits and it is unlikely that planning policy could effectively shape and control a designated cluster to a prior agreed townscape form.

  2.23  The potential impact of clusters is greater than that of individual buildings and these should be seen as exceptional occurrences relating to existing concentrations of tall buildings and only where the further addition of a tall building would meet the criteria as defined in Westminster's policy DES3. It is difficult to see where a cluster would be acceptable in Westminster.

  2.24  This also applies to stand alone or "dotted" tall buildings whose impact will also be significant as they will be exposed to views from all sides and silhouetted. By definition they will be out of context and significantly higher than the prevailing development and sites for these will be rare due to their potential citywide impact.

(d)  Repeating mistakes of the past

  2.25  The mistakes made in the 1960's where the result of applications characterised by national interest and ministerial intervention. These have heightened the profile of the current debate on the role of high buildings in the future development of London.

  2.26  There is a danger of repeating the mistakes of the 1960's. There is no agreed strategic framework for considering proposals for tall buildings. They are being driven by commercial pressure and there is no demand from the public in general for high buildings and no consensus on their acceptability. They are being considered in a policy vacuum, a scenario which is redolent of the situation in the 1960's, where planning failed to give consideration to architectural and urban design issues, with the result that much development was not sustainable or sympathetic to its context. The current proposal for the 222 metre high Heron Tower in the City of London has demonstrated the importance of a thorough and scholarly character analysis of the wider scene in order to ensure that the visual impact of the building on the setting of existing important landmark buildings and on the wider London skyline can be accurately assessed and an informed judgement made. Never before has such an extensive analysis of this type been carried out. It should, however, be the norm for all tall building proposals in the future.

(e)  Public accountability of decision making process

  2.27  Local Planning authorities are sufficiently accountable. Providing that the consultation process is effectively undertaken there is already the opportunity for Call-In of decisions in the public interest.

(f)  Government policy

  2.28  It is considered that an explicit Government policy expressed through either a Circular or Planning Policy Guidance would be inappropriate. Local planning authorities can determine that an Environmental Impact assessment will be required in appropriate cases and can, either as part of such studies or separately, require a design statement to accompany tall building proposals. It is considered, however, that the joint English Heritage/Cabe consultation paper on Tall Buildings, in a refined form, has the potential to be an extremely useful tool in the development control process for the country as a whole. Most importantly, it lays down criteria for the presentation of the proposals and for their assessment. It is suggested, therefore, that following refinement in the light of public consultation (including Westminster City Council's observations), endorsement of the final document by the Government, in the same way as it endorsed the LPAC advice on High Buildings and Strategic Views in London in November 1999, would give the advice appropriate weight.

20   Available from Westminster City Council. Back

21   Ibid. Back

22   Available from Westminster City Council. Back

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Prepared 22 January 2002