Memorandum by The Chelsea Society (TAB
Tall buildings have great impact
when built in and near streets of 18th and 19th century terrace
houses. They overlook nearby residents, block the sky as seen
from adjacent windows and streets and, when built next to the
Thames, help transform the river's generous, natural openness
into a corridor of buildings.
Built form studies published by the
Urban Task Force and the evidence of Kensington and Chelsea itself
(a high density district containing few tall buildings) demonstrate
that terrace houses and six-storey mansion blocks with communal
gardens can provide high densities.
Without the presence of policy, the
location of high-rise buildings is random and can be very disruptive.
It is determined by the chance availability of large sites (especially
along the Thames), the desire of developers to impress and sell
opportunities for some residents to indulge in the selfish desire
of overlooking their neighbours.
The Chelsea Society is not opposed
to high buildings in all locations, but is strongly opposed to
further tall residential buildings both in Chelsea and visible
within Chelsea, particularly from Thames-side.
The Society urges the House of Commons
Urban Affairs Committee to press the Government to ensure that
Greater London is covered by a rational and sensitive policy for
controlling the height of buildings. Consideration should be given
to creating a system of control similar to that operated within
the former Greater London Development Plan.
The Commission for Architecture and
the Built Environment (CABE) rightly represents architectural
thinking. As such there is a risk that it will follow prevailing
architectural fashion. In the present intellectual climate, it
therefore seems likely to support tall residential buildings at
the expense of residents and the environment. In the absence of
any policy for high buildings this is, to say the least, unfortunate.
The Society urges the Committee to
consider how the promote the idea of "listing" ill-located
and ugly tall buildings so that, when redeveloped they are reduced
in height. Examples of possible candidates in Chelsea include
the Holiday Inn Hotel (formerly Penta) in Cromwell Road, the World's
End Estate in Chelsea and the Empress State Building in Fulham.
1. This submission considers tall buildings
in the context of high-density, residential Inner London. It addresses
the following issues:
the role of tall buildings in achieving
high densities in residential areas;
where tall buildings should be located,
including what restrictions should be put on their location;
whether, in the present movement
to erect 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 tall buildings.
2. Notes on existing tall buildings in and
adjacent to Chelsea are covered in Appendix 1. The full background
to current policy on tall buildings in central and inner London
is set out in Appendix 2.
B. Policy on high buildings in Central and
3. The County of London Plan 1943 set out
three "height zones", based on concern about fire hazards
and the London Buildings Act.
4. In 1954 these limits were removed and
led to a spate of tall buildings.
5. When the Greater London Council was established
in 1965 it was required by the Development Plans Regulation to
have a policy on high buildings. London was classified into:
areas in which high buildings are
areas which are particularly sensitive
to the impact of high buildings; and
areas in which a more flexible or
positive approach is possible.
6. The three categories were based on London-wide
visibility studies and created a system for evaluating tall building
proposals that was not based on arbitrary limits or ad hoc decisions.
Cases could be assessed on their wider impact. All applications
for high buildings were, in addition, referred to the GLC before
determination by the relevant London Borough.
7. Most of Chelsea, because of its proximity
to the Thames (an Area of Special Character) was designated as
an "area in which high buildings are inappropriate",
as was the Battersea riverside.
8. The abolition of the GLC in 1986 led
to tall building applications being decided by London Boroughs
unless called in by the Secretary of State. A weakening over the
control of tall, Thames-side buildings followed. Fulham gave permission
to Belvedere Tower at Chelsea Harbour and, following call-in,
the Secretary of State to Montevetro, designed by Richard Rogers,
9. Supplementary guidance on Strategic Views
and on the Thames was issued by the Secretary of State in 1990
but provides less control over tall buildings than the GLDP. Treatment
of the Thames is particular disappointing and gives no guidance
on appropriate heights for buildings. New guidelines, such as
those for the river from Kew to Chelsea Bridge, may be superior,
but this is by no mean certain.
10. The current situation in Chelsea is:
The Council's Unitary Development
Plan seeks "to resist a new high building which would significantly
exceed the height of neighbouring buildings and which would harm
The Mayor of London's "Interim
Policy for Tall Buildings" which, not having undergone public
consultation or testing at examination in public, has limited
status. However all riverside buildings over 25 metres high have
to be referred to the Mayor who has power to direct their refusal.
The Secretary of State for Transport,
Local Government and the Regions has issued weak guidelines but
has power to call in all applications.
11. London has been through several periods
of "deregulation" of high buildings and inappropriate
developments have always resulted. The current policy framework
and the Mayor for London's "Interim Policy for Tall Buildings"
give little protection. Chelsea and other riverside Boroughs need
well-founded technical guidelines for the Thames Policy Area that
protect 18th and 19th century districts from inappropriate tall
C. Proposed tall buildings in Chelsea
12. Chelsea is today faced by an application
for twin residential towersone 130m/39 storeys and the
other 91m/25 storeysbeside the Thames next to Lots Road
Power Station. Sir Terry Farrell's design for Circadian, shows
towers with seductively slim profiles when seen from east and
west along the river and slab facades when seen from nearby streets.
The Society, in making representations to the Council, has objected
to these towers on grounds that they would:
contribute to over-development at
a location poorly served by public transport at the same time
as other traffic-generating developments are being built nearby
at Imperial Wharf in Fulham and the College of St Mark & St
John in Chelsea;
dominate the outlook of existing
residents in the Victorian streets to the north of Lots Road;
deflect blasts of wind onto the stretch
of Thames-side walk to be created with the development; and
contribute to the "Manhattanisation"
of the hitherto open, tree-lined and river based character of
D. The role of tall buildings in achieving
high densities in residential areas
13. Research in the 1960s by Professor Sir
Leslie Martin and Dr Lionel March at the Cambridge University
School of Architecture clarified the relationship between density
and building form. This research showed that rows of terrace houses
with gardens (as in much of 18th and 19th century Chelsea), seven
storey mansion blocks, or apartments built around garden squares
(as at Elm Park Gardens in Chelsea), can, just as much as towers,
achieve high densities. Indeed, the Royal Borough of Kensington
and Chelsea has the highest population density in the United Kingdom,
yet it contains very few tall buildings.
14. Figure 2.6 in "Towards an Urban
Renaissance", the final report of the Urban Task Force, shows
the high density of 75 dwellings per hectare deployed in a tower,
in terraces and in garden apartments.
15. In the view of the Chelsea Society,
built form research has demonstrated that residential towers are
not necessary to achieving high densities. Towers are the result
of architectural fashion.
E. Where tall buildings should be located,
including what restrictions should be put on their location
16. Tall residential buildings may well
have a role in large areas of new development such as London's
Docklands. There they can be sited to provide valuable focal points
and to create landmarks that distinguish one place from another.
(It follows that, like church towers, they should be varied rather
than repetitions of the same design.)
17. The Chelsea Society believes that there
is no case for building them in districts where the nearby street
scale is that of the 18th and 19th centuries.
18. Chelsea Reach is an open stretch of
river crossed by Albert and Battersea Bridges. At high tide it
is a huge river, smelling of the sea and bringing openness and
a sense of the natural into the heart of London. The Council's
World's End Estate, then Chelsea Harbour and, most recently, Montevetro
in Battersea began the indiscriminate diminution of this openness.
Sir Terry Farrell's proposed towers would take it further.
19. The Chelsea Society believes that in
a huge city such as London the feeling of openness provided by
the river should maintained and not diminished by enclosing it
with tall buildings.
F. Whether, in the present movement to erect
tall buildings, we are in danger of repeating the mistakes of
20. The mistakes of the 1960s were of four
Some tall blocks of flats were built
with untested and unreliable materials and in some cases with
inadequate thermal and sound insulation.
Flats in towers were rented to households
some of whom would have been bad neighbours in houses but whom,
in the confined landings, corridors and lifts of tower blocks,
made life impossible for others. This was not an architectural
problem. It was about bad housing management and irresponsible
The tall buildings of the 1960s were
utilitarian in appearance and often located with little thought
about their effect on their surroundings.
Insufficient recognition was given
to the way in which tall buildings deflect and funnel unpleasant
winds and dust into the spaces around them.
21. It is unlikely that, in current conditions,
the first two problems will be repeated but, given the current
enthusiasm for tall buildings and the lack of a clear policy along
the Thames, the Chelsea Society fears a repeat of the insensitive
location of tall buildings. Wind effects are also a continuing
problem for all towers, notwithstanding mitigation following wind
tunnel tests of models.
G. Whether those making decisions are sufficiently
accountable to the public
22. The Society has doubts about the accountability
of the Commission for Architecture and the Built Environment (CABE).
The Commission expressed its support of Sir Terry Farrell's design
for the Lots Road Power Station site within weeks of the application
being lodged, and, in particular, supported the proposed towers.
23. CABE's "Guidance on Tall BuildingsConsultation
Paper June 2001" sets out criteria for evaluating tall buildings.
Criterion (vi) is about: "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." (Chelsea Society emphasis.)
24. The Society notes that existing residents
of, for instance, Stadium Street, Ashburnham Road, Burnaby Street,
Tadema and Uverdale Roads would have their southern outlook dominated
by the slab sides of Sir Terry's towers. They would also be looked
down upon by tower residents. This is not a matter of daylighting
or overshadowing, both of which are considered in Circadian's
Environmental Impact Statement. It is to do with the effect of
the towers on the psychology and comfort of those who are overlooked.
25. The Chelsea Society does not believe
that CABE, notwithstanding a site visit, has put sufficient weight
on the overpowering scale of the proposed towers for nearby residents.
26. The Society also believes that whereas
the south facing Thames path could have been designed as a riverside
delight without equal in Inner London, the towers will deflect
onto it unwelcome blasts of wind.
27. The Chelsea Society considers that CABE,
which rightly represents architectural interests, is bound to
be influenced by architectural fashion and to give architectural
values higher priority than the amenity of those living and walking
in the vicinity of proposed towers.
H. Whether the Government should have a more
explicit policy on tall buildings
28. The Greater London Development Plan
contained criteria used to evaluate proposed buildings. These
ruled out high buildings in sensitive places such as the edges
the Royal Parks, Battersea Park, the Thames and Areas of Metropolitan
Importance. It was held that such places are intrinsically unsuited
to the location of towers.
29. Manhattan's Central Park with its fence
of skyscrapers is, without doubt, an important feature of New
York. But London is not New York. It is famous for being a huge
city blessed with a sense of the country. Hyde Park, before the
building of the Hilton Hotel in Park Lane and Knightsbridge Barracks
was an astonishing example of rus in urbis. Insensitive siting
of tall buildings destroyed that unique feature. Such buildings
should be "listed" to ensure than, when rebuilt, their
height it greatly reduced.
30. The Chelsea Society therefore urges
the House of Commons Urban Affairs Committee to recommend a review,
such as the one that informed the GLDP policy on high buildings,
leading to a London-wide policy on the appropriate height of new
buildings. This would involve:
A study to assess the suitability
of areas of London to accept high buildings.
Guidance for development along the
Thames, including clear guidelines for the height of buildings
in a "blue belt"the Thames Policy Area.
A statement from the Secretary of
State about the status of the Mayor's Interim Policy on Tall Buildings.
Consideration of how existing tall
buildings, which are inappropriately located or overweening, could
be "listed" to ensure that, when redeveloped, they are
reduced in height.