Select Committee on Transport, Local Government and the Regions Memoranda

Memorandum by Office of the Mayor of London, Greater London Authority (TAB 55)

  The Mayor is responsible for the production of a Spacial Development Strategy for London, known as the London Plan. Government Office for London Circular 1/2000, Strategic Planning in London, states that the Mayor has specific responsibility for existing policies to protect strategic views and that the London Plan should reflect such policies and any others he may adopt on views and the general location of tall buildings. As such the Mayor has a clear remit to develop strategic tall buildings and view policies for London. In October 2001 the Mayor published Interim Strategic Planning Guidance on Tall Buildings, Strategic Views and the Skyline in London attached as Appendix 1 of this submission. The interim guidance bridged the gap between existing policy and LPAC advice and forthcoming policy in the Mayor's Strategic Development Strategy (The London Plan). As such this submission should be read as part of the on-going development of the Mayor's policies. Further information on the history of tall building and view policy in London is contained within section 2 of the interim guidance.

  The development of policies for the London Plan is being based on the Mayor's overall priorities and objectives together with emerging advice from his consultants DEGW, who have been investigating the requirements of tall building and view policies for London. Both this research and the development of policy are on-going and the Mayor cannot present finite draft policies to this Sub-committee.

  In response to specific issues raised by the Committee the Mayor wishes to make the following points.


"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 not." (From Sub-committee press release)

  The Mayor believes that the benefits tall buildings can bring should be the starting point for identifying places where they should be built and for assessing development proposals. They can represent an efficient use of London's land, transport and economic resources by:

    —  Providing a competitive advantage for economic clusters of related activities and so contribute to London's world city role.

    —  Representing intensive and resource efficient development places that can support high intensity trip generation.

    —  Providing a visual signal enhancing the image and function of a locality.

  Appropriate locations for tall buildings will be places where they can meet the above objectives. However, tall buildings can also cause significant change to existing local character, can damage unacceptably the settings of historic assets and create poor microclimatic conditions. So local qualities, including the appreciation of designated views and historic places and distinctive local qualities, should be preserved or enhanced. Difficulties arise where there is conflict between these two issues. In these cases it is important to balance the benefits the proposal would bring against any adverse impact it will have on existing character.


  The Mayor believes that London incorporates viewing opportunities that are of benefit to the quality of the capital and its appreciation by Londoners and visitors alike. To be of real value views must be appropriately identified and managed in a manner sensitive to their specific characteristics and the benefits they can bring. This means views are about much more than blocking or not blocking sight lines to existing landmarks, the consolidation of clusters or the creation of new landmarks. The GLA is in the process of reviewing the protection and management of views in the capital including the need to preserve existing views, clusters or scattered tall buildings.


"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." (From Sub-committee press release)

  One of the cornerstones of the Mayor's strategy for London is to accommodate future growth in population and jobs in a sustainable way. Key to achieving this is maximising development opportunity and available land resources in locations that are, or will be, well served by public transport. Such development in essence needs to be densely built and well used. Tall buildings provide one way, but not the only, way of achieving this if they are designed well and sited in the right place. National[24]23 and strategic[25]24 policy supports the importance of sustaining clusters of economically related activities to gain competitive advantage. This is particularly important in central London where the cluster of highly specialist business and financial services is competing in the most advanced of all global markets. In particular tall commercial buildings in central London represent a way of fitting space onto land that is in short supply. (Further information on tall office buildings is included in section 3.2 of the interim guidance). In the case of tall residential development the relationship between height and density is not so clear. Theoretically tall residential buildings should allow for the optimum use of accessible land. However, the requirements of residents, in terms of their individual amenity, social wellbeing and the need for ancillary facilities such as schools, open space, health services etc. mean high buildings may not be the most appropriate or resource efficient way of providing homes in every case.

  However, tall residential buildings do have a role in providing for a specific part of the residential market—in particular for high cost, non-family homes where there is significant locational demand in terms of accessibility, prestige or access to specific facilities and services. Such developments can provide successful residential environments for those who want them while helping to support vibrant mixed uses within and around them. The premium paid for such accommodation means it can be economically viable to build tall, and more dwellings can be accommodated in a sustainable manner. However, these conditions present significant restrictions for providing mixed tenure schemes with affordable housing on site, particularly in terms of housing maintenance and service charges. Tall residential buildings also pose concerns about accessible housing excluding disabled people. In planning new tall residential buildings careful consideration must be given to these issues.

  The Mayor does not therefore believe tall residential buildings are necessarily the most appropriate way of providing homes in existing residential areas. However, some types of tall residential buildings in particular locations may be a way of promoting an urban renaissance, strengthening residential uses in highly accessible areas and helping to sustain different services and businesses whilst minimising the need to travel. (Further information on residential tall buildings can be found in section 3.3 of the interim guidance.)


  The Mayor believes that tall buildings can also help to make London attractive. They can be eye-catching from outside their immediate surroundings providing new landmarks that enhance local image and help to stimulate regeneration around them. They offer unique opportunities to stimulate regeneration and improvements to character and image, both at the local level and for London as a whole.

  In order to achieve this, tall buildings should be of exceptional design quality and carefully planed to make sure they have the right impact. For example, individual buildings within established areas might play a role in enhancing the image or function of the locality. In such cases their siting and design should capitalise on their landmark and regenerative capabilities providing a recognisable and attractive new local element that is sensitive to local surroundings. The high profile and economic value of tall buildings within the London context also mean they provide a realistic opportunity to attract very high calibre architects and the best possible designs both in terms of innovation and quality of materials and detailing. Ensuring such potential is met is a vital role for the control and planning of tall buildings.


Whether in the present movement to erect tall buildings we are in danger of repeating the mistakes of the 1960s (From Sub-committee press release)

  There are many differences between tall buildings of the 1960s and those proposed today. For example, the rationale for building tall is very different now. In the 1960s tall buildings were seen as part of the creation of utopia, a new way of living. Very often they were residential buildings, driven by the need to replace a large number of old or damaged stock and predicated on indistrialised building techniques. Many have subsequently been demolished. Today tall buildings are seen as a way of making the best use of land and transport resources and integrating functions. This means we are not in danger of making the most obvious mistake of creating accommodation that isolates, both in terms of physical connections and in the mixing of people and functions.

  Another fundamental difference is the funding of tall buildings. It is acknowledged that tall buildings are expensive and that they will only be appropriate where the location makes them viable. 1960s tall buildings were generally publicly funded, with pressure on budgets resulting in poor quality buildings with sub standard maintenance programmes.

  Lastly, the importance of urban design was not valued in the 1960s. It can be argued that the failing of past eras has fed into the current growing acceptance that the way we deal with the relationship between buildings and the spaces between them is vital. Understanding of issues such as designs to reduce crime, taking forward sustainable construction and design techniques, making sure space is used and is "owned", the importance of connectivity and making vibrant public places and spaces continues to grow.

  On a different scale the ability to look strategically at the structure and functioning of cities in light of urban design priorities means the ad-hoc building of stumps unrelated to the function and character of their surroundings will not be seen as acceptable. The Mayor believes that such understanding must be a vital part of the regulation of tall building development in London helping to create successful tall buildings, both internally and externally. This means even listed tall buildings like Centre Point would not have a poor external environment if they were built today.


Whether those making decisions are sufficiently accountable to the public. Whether the Government should have a more explicit policy on the subject. (From Sub-committee press release)

  In London proposals for buildings over threshold heights (as set out in section 3.1 of the Interim Planning Guidance attached as Appendix 1) are determined by the local planning authority, and are referred to the Mayor who can direct their refusal. In addition policies for tall buildings will be developed within Borough UDPs in the context of the Mayor's emerging London Plan. The Secretary of State has the opportunity to call in applications and comment on UDP policy. All levels of control, from borough to central Government are therefore by elected representatives.

  The Mayor, who made his position on tall buildings clear before he was elected, is democratically elected with a clear mandate for the development of strategic policy in London and a clear statutory framework for doing so. Other organisations such as the Commission for Architecture and the Built Environment or English Heritage also have a role in commenting on policy and proposals that affect their particular remit. Such advice should be taken into account by the publicly accountable decision-makers within their decision making process.


  There has been a policy vacuum in London in terms of a strategic overview or strategy for the city. However London has been fortunate in having policy advice on tall buildings developed by the London Planning Advisory Committee and endorsed by central Government (LPAC Advice 1999). The Mayor's interim guidance and emerging London Plan policies are in line with Government advice and priorities as set down in national Planning Policy Guidance Notes. Emerging Borough UDPs will have to be in general conformity to the Mayor's policies. There does not seem a need for specific national policy on tall buildings. However there is a lack of up to date national guidance on urban design issues which reflects the design-led approach that is central to the success of tall buildings. In addition Government may wish to review the Building Regulations to ensure all large buildings are constructed and managed to appropriate safety standards.

24   Business Clusters ion the UK 2001, DTI. Back

25   Regional Planning Guidance for the South East (RPG9) GOSE, GOEE, GOL. Back

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Prepared 22 January 2002