Memorandum by Commission for Architecture
and the Built Environment (CABE) (TAB 10)
1.1 CABE is the government's champion for
architecture and urban design in England. Its function is to promote
high standards in the design of buildings and the spaces between
them. It offers advice to all those who create, manage and use
the built environment.
1.2 CABE is jointly sponsored by the Department
for Culture Media and Sport (DCMS) and the Department for Transport,
Local Government and the Regions (DTLR).
1.3 CABE's involvement in the subject of
tall buildings is dealt with below under two headings: casework
and policy. They are dealt with in that order because CABE's casework,
offering advice to local authorities and the promoters of projects,
has informed the development of policy.
2. TALL BUILDINGS
2.2 CABE is a non-statutory consultee within
the planning process. A letter from (the then) DETR to local planning
authorities of 15 May 2001 (Annex A) sets out the circumstances
in which CABE should be consulted about planning applications.
The criteria for consultation are as follows (a fuller description
of each category is contained in the letter):
1. Proposals which are significant because
of their size or the uses they contain
This category includes large buildings or groups
of buildings such as courts, large religious buildings, museums
or art galleries, hospitals, shopping and leisure complexes, and
office or commercial buildings, infrastructure projects and major
changes in the public realm.
2. Proposals which are significant because
of their site
In this category are proposals which affect
important viewsinto or from a World Heritage Site, for
exampleor are sited in such a way that they give rise to
exceptional effects on their locality.
3. Proposals with an importance greater than
their size, use or site would suggest
This includes proposals which are likely to
establish the planning, form or architectural quality for future
large scale development or re-development, and proposals which
are out of the ordinary in their context or setting because of
their scale, form or materials.
2.3 It can be seen that proposals for tall
buildings are likely to fall into at least one of the above categories,
and quite often into all three.
2.4 Major projects are reviewed by CABE's
design review committee, which meets every four weeks. Since the
design review committee began its work in 1999 it has reviewed
about 25 proposals for tall buildings across England, including
City of London: Heron Bishopsgate
Tower. CABE supported this proposal, which was the subject of
a recent public inquiry.
Southwark: London Bridge Tower. This
project, the subject of a current planning application, for what
would be the tallest building in London, was considered by CABE's
design review committee and the Commission itself. The letter
setting out the Commission's views is at Annex A. The applicants
have done further work to address CABE's concerns about the setting
of the project, and this will be seen again by the committee early
Westminster: Paddington Station development
and Grand Union building, Paddington basin. These two projects
each proposed forty-storey towers overlooking Paddington basin.
CABE's design review committee was unconvinced by the former but
supported the latter. Westminster City Council's planning committee,
however, decided that buildings of this height would not be acceptable,
and both projects have been redesigned at a lower height.
Bristol: Broad Quay development.
This project in the centre of Bristol proposes the replacement
of a 1960s office tower (the former HQ of the Bristol and West
Building Society) by a mixed use development which includes a
residential tower of a similar height. The committee supported
this project, admiring particularly the way in which it offered
a genuine and attractive mix of uses on the site.
Leeds: Bridgwater House. This project
for a "gateway" site at the entrance to the city centre
from the south proposed a mixed use scheme which included hotel,
office and residential uses. The committee thought that the architecture
was not good enough for such a prominent location; it did not
live up the "landmark" aspiration.
2.5 The committee has reviewed other projects
which propose tall buildings in the following local authority
In London: Camden, Croydon, Hammersmith
and Fulham, Hounslow, Islington, Lewisham, Southwark.
Elsewhere: Gravesham, Manchester,
2.6 We are aware from our casework that
many more proposals for tall buildings are being worked up at
the moment in a number of other cities including Birmingham, Liverpool,
Manchester and Newcastle.
3. TALL BUILDINGS
3.1 Through consideration of individual
projects by the committee, a number of common themes emerged.
CABE and English Heritage agreed that it would be useful to publish
a document which sets out how the two bodies evaluate proposals
for tall buildings. This document, "Guidance on tall buildings",
was issued for public consultation in June 2001. It is attached
at Annex B. The key points of the document follow.
4. CABE/EH "GUIDANCE
4.1 As the national bodies charged, respectively,
with promoting high standards in architecture and urban design
and with the conservation and enhancement of the historic environment
in England, both CABE and English Heritage have an important role
to play in evaluating proposals for tall buildings, which, by
definition, are usually of more than local significance.
4.2 In assessing major proposals for tall
buildings, CABE and English Heritage will liase and take into
account each other's views when arriving at their own conclusions.
Because of the differences in remit given to them by government,
however, there may be occasions on which the two bodies arrive
at different conclusions about particular proposals. This could
arise, for example, as a result of giving differing weight to
various pros and cons of proposals.
4.3 For the purposes of this document, which
is based on locational and qualitative considerations, we do not
think it useful or necessary to define rigorously what is and
what is not a tall building.
Presentation of projects
4.4 Because of the intensity of land use
which they represent, and because of the degree of change to the
environment which their construction will bring about, all major
tall buildings proposals should be presented in the context of
an urban design study/masterplan of their immediate and wider
areas, based on a characterisation of the area.
4.5 Proposals for tall buildings should
be accompanied by accurate and realistic representations of the
appearance of the building in all significant views affected,
both near, middle and distant. CABE and English Heritage will
not lend their support to proposals which have not been illustrated
in accordance with current best practice.
4.6 Proposals for tall buildings are likely
to require a full Environmental Impact Assessment.
Evaluating tall building proposals
4.7 Cities and their skylines evolve. In
the right place, tall buildings can make positive contributions
to city life. They can be first-rate works of architecture in
their own right; some of the best post-war examples are now listed
buildings. Individually, or in groups, they affect the image and
identity of a city as a whole. In the right place they can serve
as beacons of regeneration, and stimulate further investment.
The design and construction of innovative tall buildings can also
serve to push out the frontiers of building and environmental
4.8 However, by virtue of their size and
prominence, such buildings can also harm the qualities that people
value about a place. Where tall buildings have proved unpopular,
this has generally been for specific rather than abstract or general
reasons. In many cases one of the principal failings is that many
were designed with a lack of appreciation or understanding of
the context in which they were to sit. There have been too many
examples which have been unsuitably sited, poorly designed and
detailed, badly built or incompetently managed (although this
has been equally true of many buildings which are not tall).
4.9 Proposals will be assessed in terms
both of the potential contribution, and any potentially adverse
impacts, which they may bring. They will be considered as pieces
of architecture in their own right, and as pieces of urban design
sitting within a wider context.
4.10 The trend of recent and emerging policy,
based on sustainability and demographic considerations, has been
to support increased density. In some cases the desire for high-density
development has been used to support proposals for tall buildings.
However, it is clear that tall buildings are only one possible
model for high-density development. While tall buildings with
a large total floor area have a correspondingly large impact on
their location in term of activity and use, this can be equally
true of large and dense developments, which are not so tall. In
both cases there are likely to be positive and negative effects.
Projects need to be considered in the round.
Criteria for evaluation
4.11 Proposals for tall buildings will be
considered in accordance with of the following criteria. These
are not listed in order of importance; the relative importance
will depend on the circumstances of the site and the project.
In the case of exceptionally tall buildings, some of the criteria
will apply over a wide geographical area, and it will be necessary
for the urban design study, referred to above, to address this.
(i) The relationship to context, including
both topography and built form, and the effect on the skyline.
Tall buildings should have a positive relationship with relevant
topographical features and other tall buildings; the virtue of
clusters when perceived from all directions should be considered
in this light.
(ii) The effect on the whole existing environment,
including the need to ensure that the proposal will conserve,
or not damage or detract from:
World Heritage sites and their
Scheduled Ancient Monuments and
Listed buildings and their settings,
including the backdrops to landmark buildings
Conservation areas and their
Historic parks and gardens, landscapes
and their settings
Other open spaces, including
rivers, their settings and views from them
Other important views, prospects
(iii) The relationship to transport infrastructure,
and particularly public transport provision. This includes the
existing capacity available, the quality of links between transport
and site, and the feasibility of making improvements.
(iv) The architectural quality of the building
including its scale, form, massing, silhouette, facing materials
and relationship to other structures. The design of the top of
a tall building will be of particular importance when considering
the effect on the skyline.
(v) The contribution that the development
will make to external and internal public spaces and facilities
in the area: the provision of a mix of uses, especially on the
ground floor of towers, and the inclusion of these areas as part
of the public realm. The development should interact with and
contribute positively to its surroundings at street level; it
should contribute to diversity, vitality, social engagement and
(vi) The effect on the local environment:
including microclimate, overshadowing, night-time appearance,
vehicle movements and the environment for those in the vicinity
of the building.
(vii) The contribution made to the permeability
of a site and the wider area: opportunities to offer improved
linkages on foot; and, where appropriate, the opening up, or effective
closure, of views to improve the legibility of the city and the
(viii) Function and fitness for purpose:
the provision of a high quality environment for those who use
(ix) The sustainability of the proposal:
sustainability is a central plank of planning policy; it needs
to be demonstrated that any tall building proposal is sustainable
in the broadest sense, taking into account its social and economic
impact, based on whole life costs and benefits.
4.12 For CABE, the overarching principle
will be that any new tall building should be of first class design
quality in its own right and should enhance the quality of its
immediate location and wider setting; it should produce more benefits
than costs to those lives which are affected by it. 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 a local level.
4.13 CABE and English Heritage attach great
importance to the opportunities for all major building projects
to enrich the public realm in terms of external and internal space.
In many cases it will be desirable to dedicate substantial parts
of the lower levels of tall buildings to public uses. Where appropriate,
it should also be possible for members of the public to enjoy
the views afforded from tall buildings. However, it may not be
possible to achieve all of the desired benefits within the confines
of the planning application sitefor example, when the proposed
building fills the site. In many cases, planning agreements (Section
106 agreements) will be an important mechanism for delivering
the public benefits of tall buildings proposals. Such agreements
will often be the only way of ensuring that a tall building is
integrated with its immediate surroundings in a satisfactory way
at the lower levels.
Protection of design quality
4.14 CABE and English Heritage will not
support proposals for tall buildings unless they are satisfied
through the submission of fully worked up proposals that they
are of the highest architectural quality. For this reason, outline-planning
applications will not be appropriate.
4.15 Where planning permission is granted,
it is essential that there should be guarantees that architectural
quality is maintained throughout the implementation of the entire
project and, in particular, that inferior detailing or materials
are not substituted at a later date.
5. CABE/EH "GUIDANCE
5.1 The consultation period for the document
has now closed, but the results have not yet been processed. It
is clear from looking at the responses received, however, that
tall buildings arouse strong feelings, in professional and in
lay circles; and that there is no consensus on the subject in
the planning and development community, or amongst members of
the public. Responses to the document itself range from "why
are you promoting the development of tall buildings?" to
"why are you obstructing the development of tall buildings?";
this suggests the document may have got the balance about right.
5.2 CABE and English Heritage will issue
a report on the result of the consultation early in 2002, and
will then issue a final version of the guidelines which takes
into account comments made.
5.3 At the same time, a number of local
authorities are considering the development of planning guidance
on the subject of tall buildings. Some have stated in response
to the CABE/EH paper that they will use that as the basis for
their own policies.