Select Committee on Transport, Local Government and the Regions Memoranda

Memorandum by The Royal Town Planning Institute (TAB 45)


  1.  The Urban Affairs Sub-Committee of the House of Commons Select Committee on Transport, Local Government and the Regions has resolved to undertake an inquiry into Tall Buildings. The Sub-Committee will wish to consider the following:

    —  the role of tall buildings in achieving high densities in residential areas; the provision of offices for certain types of global companies; and as a means of enhancing the beauty of our cities;

    —  where tall buildings should be located, including what restrictions, if any, should be placed on the location of tall buildings, and how far they should be allowed to block existing views; and whether they should be clustered or dotted;

    —  whether in the present movement to erect new 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 the subject.


  2.  The inquiry is very timely coming in the wake of the consultation by English Heritage and the Commission for Architecture and the Built Environment (CABE) on draft guidance on tall buildings and recent controversial planning applications. The planning and design issues have become matters of even greater interest since the 11 September terrorist attack on the World Trade Centre in New York. That has raised very real additional issues of building standards and evacuation procedures, in addition to whether landmark buildings are by their very nature at greater risk of terrorist attack. It remains to be seen whether 11 September will have a long term impact on the potential occupancy of tall buildings and hence on the economics of their development, particularly as many such proposals seem highly speculative in their funding and occupancy arrangements.

  3.  A first issue to be clarified by the inquiry is what the Sub-Committee means by "tall buildings". Any definition would include very tall buildings—perhaps in excess of thirty or forty storeys—of which there are relatively few in the UK, and those are mostly in central London and adjoining financial districts. There are many parts of urban Britain, however, let alone the rural areas, where the majority of buildings may be no more than two or three storeys, and where four storeys and over would be considered "tall"—ie taller than the average height of buildings in the vicinity. Thus if a building, or group of buildings, is required to make some sort of local "statement" it simply needs to be taller than the general height of buildings in the locality. Relative height might be more significant than absolute height.

  4.  A second issue is that the "statement" made by a tall building, or a group of tall buildings, may be an economic one as well as, or rather than, a design one. Tall buildings generally result from the interaction between land values and urban design. This is perhaps a very simplistic statement, but the Institute would hope that tall buildings are not purely the result of the designer's whim, the developer's ego or the lure of large financial rewards for them. The commercial centres of our towns and cities, transport nodes, and other areas of high accessibility tend to create the highest land values. Similarly, smaller centres in the suburbs will generally support higher values than the surrounding residential areas.

  5.  There are pressures, therefore, for a higher density of development on the higher value land. One way of achieving the higher density is to build upwards—and use tall buildings. At the same time, it is argued that this leaves more space at ground level for access, movement, circulation and other functions that realistically can only take place on the ground. The Institute does not accept however that pressures for higher density must result in very tall buildings and it would point to, for example, the award winning and much acclaimed Broadgate development in the City of London as evidence that high density can be achieved on a human scale with quality public spaces, without resorting to towers.

  6.  This leads the Institute to the conclusion that where a local planning authority has something to say about the location and design of tall buildings, or about the principles of urban design generally, it should say it in its development plan. It may be, in a historic city, for example, that centrally located tall buildings would detract from the townscape of the historic core, or be uncomfortably juxtaposed with the castle or cathedral, while more peripheral locations would damage the overall setting of the city. In such cases, it would be perfectly reasonable for the development plan, and supplementary planning guidance (SPG), to fix rigid limits to the height of any new development in different parts of the city. Conversely, where regeneration of a former industrial city was a priority, it would be equally reasonable for the development plan to encourage the development of tall buildings, perhaps providing development guidance in SPG, to mark the phoenix rising from the ashes of dereliction.

  7.  The principal points here are that:

    —  policies on tall buildings are largely a local concern (accepting the national interest in central London); and

    —  their inclusion in the development plan provides transparency and allows the community to have its say before policies are adopted and implemented.

  This approach also signals a local planning authority's intentions and allows bodies such as English Heritage and CABE to make an early input on proposals that have the potential to impact significantly on the townscape.

  8.  The proposals of this past week in the Planning Green Paper Planning: Delivering a Fundamental Change for replacing the current development plan system with Local Development Frameworks need to be fully considered to assess their implications for tall buildings. However, the proposed area approach seems as if it would be a good mechanism for dealing with the site specific criteria of tall buildings policy.


The Role of Tall Buildings

Achieving high densities in residential areas

  9.  The theory may sound attractive, but it is perilously close to the experiments of the 1960s (see below) that led to "gap-toothed" planning—tall blocks in a sea of meaningless open spaces. Where tall buildings are used exclusively for housing, one of the difficulties is always going to be creating any sense of ownership, on the part of residents, of the space between the blocks at ground level. If people do not feel they own this space, there is no common interest in its management leading progressively to alienation and dereliction.

  10.  This was clearly demonstrated by the 1960s experience. Achieving high residential densities in tall buildings was not a solution for social housing, or for housing families. More recently, there have been indications that it may work better for young professionals, or single people. Where incomes are relatively higher, management and maintenance costs can be more readily taken on board, and a sense of ownership fostered. Better still is the mixed use of tall buildings, where commercial or retail occupiers can meet much of the management and maintenance cost and a residential element contributes to the vitality of the centre after office hours.

Offices for global companies

  11.  This is probably where the developer interest in tall buildings lies. Global headquarters, located on the right site, can become impressive landmarks, foster inward investment, and are seen by some contribute to the recognition of "world class" cities. Nevertheless, it is important to keep this in perspective. Occupation by a multinational or global company is only the use of the tall building. It is not a reason for departing from a strategy for the location/development of tall buildings.

Enhancing the beauty of cities

  12.  It is easy to get carried away here—beauty, it is claimed, is in the eye of the beholder. Cities can be considered attractive when they accommodate many and various tall buildings in clusters—as evidenced in Manhattan and the centres of many stylish Far Eastern cities. In other locations, tall buildings might be regarded variously as incongruous, compromising local character and distinctiveness, or injurious to amenity, to vistas, or to skylines. "Beauty" and "enhancement" rely very much on the quality of the buildings and their relationship on the ground. The acceptability of a tall building will always depend on the character of its surroundings, and whether this can be altered without sacrificing valued attributes or local distinctiveness. The answer depends as much on location as on the skill and innovation of the urban designer and architect—or on the eye of the beholder!

  13.  The Institute has observed that much design interest in tall buildings has focussed on either their effect on historic views (see paragraph 6) or on their impact on the panorama. It would urge however that no less important is the visual impact of tall buildings on their immediate environment, at street level. There is a real challenge to address in the way these buildings are designed to meet the street and to create successful public spaces in and around such buildings. This challenge is often not taken on by the developer and their designer who are focussed on what towers above to the detriment of creating places for people. Additionally, the impact of a proposed tall building on the local microclimates needs to be satisfactorily addressed during the design and planning application processes.


  14.  Dotting tall buildings around cities completely loses the impact and sense of their importance. It also has the disadvantage of dwarfing attractive smaller buildings, without any commensurate benefit, and the potential to destroy protected and cherished views. In considering how far tall buildings should be allowed to block existing views, it needs to be borne in mind that, in the UK, there is no right to a private view. However, some views and vistas in the public realm may be the key to the character of a place, or the setting of an important building. In these terms, the effect of tall buildings can only be assessed locally.

  15.  The Institute has little enthusiasm for mechanistic approaches such as concentric rings on maps, with maximum building heights decreasing outwards, away from the city centre. The impact of tall buildings in other parts of the world is usually their location in close proximity to one another in clusters that are recognised as being the commercial hub of the city. This may originally have been a historical accident, but the cluster has subsequently taken shape as a result of intervention by planners and urban designers.

  16.  Despite this concentration in commercial areas, tall buildings need not be single use buildings. Office, residential and retail uses are an attractive combination for those who work in pressurised jobs and wish to live close to their workplace.


  17.  The "mistakes of the 1960s" almost all related to tall buildings used for social rather than market housing and, to a lesser extent, for speculative office development. The problems have been well documented, and the lessons learned.

  18.  The governments of the day used generous subsidy regimes to encourage local housing authorities to build "high rise flats"—often 20-30 storeys high—or deck access housing complexes. Such development was a panic "solution" to meeting the demand for social housing arising from the widespread clearance of high density Victorian terraces and tenements, and the perceived shortage of land for the replacement housing.

  19.  The tall housing blocks were built to rigid cost regimes, mainly by systems building techniques that had been developed inadequately, and generally were not the most attractive of buildings. Of those that have survived, despite several external "makeovers" in the intervening years, few would qualify for awards for their contribution to the urban environment. Schemes were generally built to a masterplan, but this often related inadequately to the local urban form and topography. As a consequence, many of the high rise blocks appeared as misfits, rising from unattractive hard areas of car parking and servicing, or neglected landscaping, and with no apparent pattern or reason in their location.

  20.  The social problems that subsequently emerged on such estates have been well documented. Many of the problems appear to have arisen from shared lifts, stairways, access corridors, etc—a lack of private defensible space in general—rather than from any inherent problems in living many storeys above the ground. The final irony is that it has also been amply demonstrated that good design can achieve greater overall densities in traditional low rise housing than ever was achieved by the high rise "mistakes".


  21.  The Institute does not see this as an exceptional issue. Provided that policies and proposals for tall buildings are fully set out in the development plan, with additional detail or design briefs added through supplementary planning guidance, there is no need to treat tall buildings any differently from any other development proposals as far as public accountability is concerned. Not only will proposals have been subject to public consultation, but there will also have been the opportunity to include any special management and infrastructure requirements of tall buildings in the policy and to test such policy across planning authority boundaries.


  22.  As indicated in paragraph 7 (above), the Institute is not convinced that there is the need for any additional planning policy guidance at national level. There cannot be a role for anything other than the most general statement from Government that:

    —  the general design guidance that might appear in the proposed revision of PPG 1;

    —  a clear steer towards the inclusion of policies on tall buildings in development plans to introduce certainty and ensure transparency; and

    —  perhaps, encouragement to local planning authorities at least to examine the potential of tall buildings in view of their possibility of maximising the use of land.

  23.  All other work to determine appropriateness, distribution, size, form, design, etc can only properly be undertaken at the local level. It is consideration of local circumstances, local topography, local townscape and local development economics that will determine whether tall buildings are appropriate in a particular location.

  24.  The Institute is concerned however by press reports that the Building Regulations do not include particular standards for evacuation form tall buildings. It is appalled that the construction industry can even consider developing proposals for such structures unless and until this matter is satisfactorily addressed. It would also urge the Committee to seek evidence from the emergency services on the issues.


  25.  The Committee's inquiry provides a key forum in which to test many of the myths of the cases for and against tall buildings. Much of the evidence will undoubtedly come from those with strongly held views. It is essential to draw out the genuine public interest concerns. The Institute would welcome the opportunity to expand on this submission in oral evidence.

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Prepared 22 January 2002