Thank you for presenting this project to CABE's
Commission meeting on 14 March. We acknowledge that the further
development of this design has taken into account comments made
by CABE after earlier presentations. Our comments below follow
the headings set out in our earlier comments on the project, and
absorb and expand on those comments as appropriate.
The first question to consider is one of principle.
Irrespective of architectural quality, is a building of this height
acceptable on this site? It would be visible from near and far,
from many different places, dominating many views. It would become
a picture postcard image representing London (as has happened
in Paris with the Eiffel Towera structure of much the same
height). It could be argued that both practical and symbolic regeneration
benefits will flow to a relatively neglected part of London from
what might turn out to be one of the finest buildings south of
the river. We think that the fact that its appearance will imply
a nexus of activity at London Bridge is in the project's favour.
A location at a major transport interchange is a strong argument
for a tall building; but we should point out that that interchange
does not in its present state measure up to the building proposed.
While the presence of a tower on this site will inevitably impact
on certain strategic views, the building need not crowd out other
landmark buildings. In summary, we consider that London Bridge
could be a suitable location for a tower of exceptional design
In our view, the further work which has been
done on the design of the building since CABE first reviewed it
has brought about significant improvements. We think that this
design could become a remarkable building which would be worthy
of its prominence in views of Londonand it would clearly
move forward the architecture of London's tall buildings into
the twenty-first century. We are far less convinced, however,
about the way the building relates to its immediate surroundings
at the lower levels, on which it will have a huge impact. We think
that considerably more work needs to be done on this before planning
permission should be granted.
Wider context : the need for a masterplan
The London Bridge Tower proposal, and the redevelopment
of London Bridge station presently being planned by Railtrack
and their architects, are both very large projects, and the sites
are contiguous. In our view, the reordering of London Bridge station
and the transport interchange is the most important aspect of
the redevelopment of this area. The potential benefits to millions
of people who live or work in London are enormous. It would not
be acceptable for the London Bridge Tower proposal to jeopardise
this; in fact, for the proposal to be convincing in terms of its
location, it needs to show how it can contribute to securing these
Although we acknowledge that efforts have been
made to make the projects compatible, we believe that much remains
to be done in this area. We believe that further attention should
be paid to the urban design and masterplanning implications of
developing the site in this way. This applies both to the relationship
with the station and to the wider context. Although more work
has been done on the coordination of the two projects (tower and
railway station) since December, which is welcome in itself, there
remains an unrealised potential for each project to benefit the
other in a way that improves the quality of this part of London
for those who use it and pass through it. We hope that the developer
of this project and Railtrack will continue to work together closely
We observed before that, as a consequence of
being an extremely tall building which fills the site owned by
the developer, it may not be possible for this project to deliver,
within the confines of a limited site, public realm benefits commensurate
with the scale and ambition of the scheme.
All of the above leads us to recommend that
work should be carried out on how the two projectsthe tower
and the stationcould work successfully with each other
(as well as each having to work independently in case the other
does not proceed). We believe that because of the great impact
of this project, a masterplan should be prepared which deals with
the tower project, the station project and the wider area, including
the various aspects of the historic context. The planning application,
in our view, should not be considered in the absence of such a
masterplan. Clearly such an exercise will not be successful without
the cooperation of adjoining owners; we believe that there must
be a role for the local authority and the Greater London Authority
to facilitate this.
The tower has not yet been provided with an
adequate setting. The masterplan exercise needs to examine ways
of achieving this: to provide some public open space of high quality,
and to achieve a sense of arrival at the complex as a whole. This
needs to be considered in conjunction with the arrangements for
busesa bus station is unlikely to form an adequate forecourt
for a transport interchange or for a 1 million sq ft commercial
building. In our view, it would not be acceptable for the two
projects to proceed without providing a first-class long-term
solution for buses at London Bridge which does not compromise
the settings of or the approaches to the buildings. There should
be a wide-ranging examination of the possibilities, including
the possibility of dispersing bus stops more widely to reduce
their impact - some transport interchanges work successfully without
large bus stations.
The masterplan ought to reveal a number of ways
in which the tower project can deliver public benefits outside
the red line of its own planning application site boundarythese
should be delivered in due course by means of a Section 106 agreement.
We believe that the revised massing of the lower
parts of the project is an improvement on the previous version,
and that relating the massing to the proposed station redevelopment
rather than to existing larger buildings nearby is a good move.
This strategy further reinforces the need for coordination between
the tower development and the station development.
In our view, the work which has been done on
refining the articulation and the detail of the spire has been
a success. Clearly, the result will be heavily dependent on continuing
refinement of the details, and on the quality of materialsboth
would need to be closely controlled by any planning consent.
We draw attention to the extent to which the
building will in fact be reflective rather than transparent, whatever
the quality of the white glass to be used. It seems to us that
there is an opportunity to achieve a visual lightness which would
be a welcome contrast with the gloomy heaviness of so many other
towers in central London, and we hope that the detailing as a
whole will take this into account.
We strongly support the ambition to make this
a low-energy tower, and we think that the symbolic potential of
the "radiator spire" is attractive. So many towers have
been profligate with energy that it will be important to seize
the opportunity for this project to begin to redeem this building
type in London. The top of the spire, as a built representation
of this, therefore needs to be completely convincing in energy
terms rather than just an attractive symbol.
The architecture of the lower parts of the building
seems to us to remain a weakness in the design, and this is connected
with the more general failure of the planning of this part of
the scheme in its wider setting. We sense that less work has been
done on the design of these parts than on the upper parts. We
have seen little yet to convince us about the quality of the lower
parts when seen from its immediate environs. People will travel
to see this building, and what they see when they get there needs
to be as impressive as what they see from a distance. This, of
course, is connected with the earlier point about the project's
setting. We continue to believe that more needs to be done to
illustrate these aspects adequately; a detailed model would be
Protection of design quality
Planning consent is only likely to be granted
for this building if, among many other considerations, there is
consensus that the design is one of the very highest quality.
This can be assumed to have been recognised by a developer who
has engaged one of the world's leading architects. It is essential,
therefore, that a consent, if granted, should guarantee this quality,
in detail as well as in general terms, with sufficient robustness
to resist "dumbing down". This is not to doubt the good
faith of the developer, but simply to recognise the legal realities
of the planning system. Legal advice needs to be taken by the
local planning authority to achieve this robustness: to ensure,
for example, that the type of glass proposed by the architect
cannot be replaced by a less acceptable alternative. We recommend
strongly that, if a planning consent is to be granted for this
project, a way should be found of guaranteeing (a) the continuing
involvement of the Renzo Piano Building Workshop as principal
architect for the project through to completion, and (b) the integrity
not merely of the overall design but of the details and materials.
We are pleased to learn of the developer's commitment
to providing such a guarantee, and we would like to offer our
help to the developer and local authority in finding a legally
robust way of achieving this.
Illustration of views
The work which has been done to illustrate the
longer views of the building is welcome, but we are not yet convinced
that it is comprehensive. The local authority and other interested
parties need to scrutinise the proposals carefully and ensure
that all relevant views of the tower have been dealt with; that
they are illustrated from appropriate observer positions; and
that the results are verifiably accurate.
The great fear of the Commission is that a planning
consent may be granted for something which it does not make economic
sense to build, and that an inferior design will be substituted.
We urge the planning authority to be alert to this danger, to
insist on robust economic data and to employ the expertise required
to evaluate this data fully. The planning authority will need
reassurance that there has been sufficient development of the
design, and sufficiently close collaboration between the design
team and the cost consultants, to ensure that the building costs
which are being relied on do in fact reflect accurately all aspects
of the design for which planning consent is being sought.
We would like to draw attention to the strategic
implications of this planning application. We think that it would
be unwise for it to be determined in isolation from the wider
issues concerning London's future skyline. What would London be
like with five towers of comparable, or greater, height; or twenty-five?
What is the attitude of the public to this prospect? It would
be strange if the face of the city were to be transformed without
a public debate. In the light of the number of tall building projects
which are continuing to come forward, we think that these questions
should be considered by the relevant interested partiesincluding
the London local authorities, the GLA, English Heritage and CABEas
a matter of urgency.
In conclusion, we believe that a tower of this
height on this site could be successful; and that the design as
it now stands holds out the promise of a world-class building.
It will not be possible to fulfil this potential, however, without
resolving the following problemsand in our view this needs
to done before the planning application can be determined.
The impact of the project is such
that it needs to be placed in the context of a masterplan, which
deals with the immediate surroundings in all directions and with
the wider setting.
The building fills the site which
the applicant owns and does not yet have an adequate setting.
This is one of the principal failings of the existing tall buildings
at London Bridge. There is a need for some high quality public
space, which will benefit both the new tower and the station.
Arrangements for buses at London
Bridge need to be reconsidered in the light of the tower project.
In conjunction with the work on the
building's setting, more work needs to be done on the design of
the lower parts of the tower, which we think is the least convincing
part of the architecture.