Memorandum by Department for Transport,
Local Government and the Regions (TAB 16)|
2Why build high?
3Planning tall buildings
4The safety of tall buildings
Annex ASub-Committee: issues for investigation
Annex BTall buildings in England
Annex CTall buildings: a checklist of
Annex DGovernment statement on tall buildings
Annex EPotential consultees
Annex FConsultation on strategic views
1.1 Tall buildings provoke highly polarised
opinion. Proponents see them as valued and vital additions to
cities, others as unnecessary threats to historic skylines. The
recent resurgence in proposals for tall buildings, mostly but
not exclusively in London, has created substantial public interest.
This has been given an extra dimension by the unprecedented terrorist
attack on the twin towers of the World Trade Center. The Committee's
inquiry is therefore timely and to be welcomed.
1.2 This memorandum describes the national
and regional planning policy framework within which proposals
for tall buildings are brought forward, together with contextual
background. It sets out, in broad terms, Government policy relevant
to tall buildings, including on matters of safety. The memorandum
addresses the Committee's highlighted areas of investigation (at
Annex A) to the extent consistent with the Secretary of State's
quasi-judicial role in the planning system. Most particularly,
the views in the memorandum should not be taken as implied comment
on any live planning application.
2. WHY BUILD
The English tradition
2.1 Tall buildings are a relatively recent
addition to urban skylines. The pre-war trend towards tall buildings
seen in major cities in the United States did not take root in
England until the 1960s. With the exception of industrial structures,
the tallest building in most English cities had been its cathedral.
Taste, locally applied height restrictions and lack of demand
had all contributed to a stable skyline.
2.2 Change was prompted by the radical approaches
to urban living and the modern lifestyles offered by "cities
in the sky". High-rise was seen as the answer to chronic
housing shortages and the unhealthy living environments of condemned
terraced housing. Sites shortages and difficulties in assembling
large sites for big, low-rise developments prompted tall buildings
in central areas, mostly for offices.
2.3 The current stock of tall buildings
reflects these influences. Most cities have office blocks dating
from the 1960s and high-rise social housing. There are also notable
examples of tall buildings accommodating hotels, hospitals and
civic uses. Interestingly, some of the cause celebres of their
day are now listed buildings, because of their special architectural
or historic interest. Annex B picks out some notable examples
of tall buildings (with their height, use and date of construction)
and proposals in the pipeline. The list is not exhaustive.
A global marketplace
2.4 Recent proposals for tall buildings
have involved a step-change in height from most established high-rise.
Demand appears to be fuelled by a strong economy and pressure
for office space from national and international firms.
2.5 Much of this demand may to a degree
be driven by a sense of "prestige". Companies with a
major international profile typically invest heavily in their
corporate image to keep themselves in the public eye and to impress
customers. International and national head offices are frequently
prestigious buildings. They tend to be either bespoke designs,
or tenanted buildings of the highest quality with well-known addresses
(eg "One Canada Square" at Canary Wharf). The advantages
of a tall building that is a landmark are evident.
2.6 Global companies are in the market for
prestige buildings. Tall buildings have a strong presence and
for that reason may be particularly favoured over low-rise developments.
They can also be a matter of choice in terms of work environment
and floorplate functionality. But other good quality buildings
can also attract international interest, as with the medium-rise
developments at Broadgate in the City of London and Embankment
Place at Charing Cross. Although tall buildings can be attractive
to developers, they cost more per square foot to build than low
rise. This margin is likely to increase as construction costs
and safety arrangements rise along with insurance costs, as a
result of 11 September.
2.7 Tall buildings can also appeal to local
authorities. Image, demand for space and competition to accommodate
global companies can all be relevant. The Corporation of London
is a notable advocate, and has highlighted that individual company
requirements for premises in the Square Mile are now up to one
million square feet or more. The Corporation reports that some
fourteen major international companies are said to be looking
for large units within its financial and business services "cluster".
2.8 An economic need for tall buildings
may have wider implications for the London and national economy.
Proponents say there is a risk that major companies unable to
establish or expand in the City, and unable or unwilling to find
alternative premises in Canary Wharf or the West End, may go to
Frankfurt or Paris instead.
2.9 High-rise residential development is
making a comeback after rejection of this model of living for
a number of years. Much of the renaissance is due to expensive
private developments with integrated facilities, security and
high levels of maintenance. Such schemes are proving highly popular,
particularly with young affluent professionals attracted to metropolitan
2.10 The trend has been encouraged by planning
policies for housing which encourage more effective use of land
through a move to higher densities. However, higher densities
can equally be secured through low-rise developments.
2.11 In encouraging higher densities, the
Government is not advocating a "back to a 1960s future"
of high-rise developments. The aim is places designed around the
needs of people. One of the most interesting observations about
well-designed higher density developments is how varied they are.
They do not have to be tall buildings. For example, Poundbury
in Dorset seeks to recreate a traditional village layout; Chatham
Maritime in the Thames Gateway provides a range of modern variations
on the traditional town house; whilst the Millennium Village in
London involves flats and apartments in an uncompromisingly modern
style. All are attractive and proving popular. All are at densities
more that double the norm of many places.
2.12 Very little new social housing has
been provided recently in tall buildings, although the Peabody
Trust is interested in their potential. Peabody is presently undertaking
research amongst current tenants to gauge interest in high-rise
2.13 Existing tower blocks have been refurbished
successfully for identified groups of tenants. For example, some
authorities have designated "elderly only" porter-controlled
blocks or blocks for singles or childless young couples. It is
commonly accepted that high-rise living is normally unsuitable
3. PLANNING TALL
3.1 Within the plan-led system of development
control, local development plans form the framework within which
decisions on proposals for tall buildings are taken. A key influence
on proposals for tall buildings will be the work carried out by
local authorities at the beginning of the planning process to
identify suitable locations. A number of local authorities have,
or are developing, policies on tall buildings, sometimes amplified
in supplementary planning guidance. Examples include Birmingham,
Leeds, Nottingham, Leicester and most London boroughs.
3.2 Local planning authorities in preparing
their development plans should take into account Government policy.
For the most part, this is set out in Planning Policy Guidance
notes (PPGs) and Regional Planning Guidance (RPG). Both PPGs and
RPGs can be material to decisions on individual planning applications
3.3 Within the context of their development
plans, and Government guidance, planning authorities will weigh
a complex array of social, economic and environmental factors
when considering proposals for tall buildings. There are also
a number of operational impacts that have to be addressed. The
checklist at Annex C, taken from the London Planning Advisory
Committee's Strategic Planning Advice on High Buildings and Strategic
Views in London
illustrates the task.
3.4 PPG1 General Policy and Principles describes
the planning system's role in securing well-designed, sustainable
development. The recent Green Paper on reforming the planning
sets out how Government will tackle the inefficiencies that stand
in the way of good planning delivering a better quality environment,
economic prosperity and social inclusion.
3.5 PPG1 underlines that "good design
should be the aim of all those involved in the development process
and should be encouraged everywhere". Securing good design
is central to good planning. The appearance of a proposed development,
its relationship to its surroundings and likely impact on the
character of a skyline are all relevant to the consideration of
a planning application. PPG1 makes it clear that local planning
authorities should reject poor designs. The policy is supported
by good practice guidance, By Design,
published with the Commission for Architecture and the Built Environment
3.6 By Design encourages thought and attention
to the design and layout of the built environment. It sets out
a number of objectives of good urban design. Planners, architects
and developers are encouraged to aspire to these objectives to
create attractive and sustainable places. By Design explores the
translation of design objectives into buildings by considering
the main aspects of development form. The scale of a building,
both in its height and massing, are highlighted as critical.
3.7 As a matter of good practice, By Design
advises that the scale, massing and height of a proposed development
should be considered in relation to that of adjoining buildings,
the topography, the general pattern of heights in the area, and
views, vistas and landmarks. It highlights that the character
of a skyline is composed of the massing of blocks and the shape
of roofs, as well as by the height of buildings, and that the
massing of a development contributes to creating distinctive skylines,
or to respecting skylines. The good practice advice is that a
building should only stand out from the background of buildings
if it contributes positively to views and vistas as a landmark.
3.8 The Government has also produced good
practice guidance, Better Places to Live,
to help deliver the commitment in PPG3 to better quality housing
developments. The guide looks at the principles of good design
as they apply to residential development and the attributes of
successful housing environments. It considers a number of forms
of residential development, including taller buildings. The conclusion
is that both low-rise and taller buildings can be good to look
at, and good to live in, if well-designed.
3.9 Good design, in the sense of good urban
design, is about more than aesthetics. It is about how a place
works, not least in terms of transport. The Government's planning
policies for transport are set out in PPG13. The PPG helps to
deliver the vision in the Transport White Paper of an integrated
transport system by looking at how new development is best located
in terms of its demands on transport. The aim is to get the right
development in the right place. Developments that attract large
numbers of people should be accessible by a choice of means of
transport, including bus, rail, walking and cycling, as well as
3.10 Tall buildings that accommodate offices,
as with other forms of intensive development, have particular
demands on transport capacity in terms of passenger flows and
concentrations in peak periods. Residential blocks may involve
less pronounced peaks. There are, therefore, advantages in mixed-use
developments, that include commercial and residential floorspace
as well as services such as shopping.
Quality public realm
3.11 The public realm can be enriched by
developments designed to welcome a broad range of people, and
by creative management. Conversely, it can be impoverished by
buildings and spaces designed to discourage all but a narrow range
of users. The ground floors of tall buildings, and their interaction
with the public realm, can be a critical planning consideration.
A mix of uses rather than a single-use has the greatest potential
for interacting successfully with the surroundings of smaller
buildings and of creating a place, not just a location. Tall buildings
will also affect the public realm through their influence on the
local microclimate, daylight and sunlight.
Preserving and enhancing historic environments
3.12 Government advice on planning and the
historic environment (PPG15) can be particularly pertinent to
proposals for tall buildings depending on the context. The PPG
sets out the importance of considering a development's likely
impact on listed buildings and conservation areas, irrespective
of the location of the proposal. Local authorities are encouraged
to formulate specific planning policies for protecting World Heritage
Sites to reflect their outstanding universal value. Significant
development proposals affecting these sites will generally require
formal environmental assessment, to ensure that their immediate
impact and their implications for the longer term are fully evaluated.
3.13 Tall buildings can also affect telecommunications.
They may be useful for the siting of new telecoms apparatus, yet
in other instances can create blind spots. The same principle
applies to radio links. Advice on these issues is provided in
London: strategic guidance
3.14 London has a history of building height
regulation. For example, up to the mid-1950s there was a height
restriction in central London of 100 foot. Current Government
guidance for tall buildings is set out in Strategic Guidance for
London Planning Authorities.
Boroughs are required to:
include appropriate policies in their
Unitary Development Plans (UDPs to protect and enhance existing
protect important local views;
identify areas considered particularly
appropriate or inappropriate for high buildings; and
include safeguarding areas near airports
and in telecommunication corridors.
3.15 There is specific guidance in Supplementary
Guidance for London on the Protection of Strategic Views
on protecting the ten strategic views of St Paul's Cathedral and
the Palace of Westminster. Statutory directions have been issued
to help protect each view from inappropriate development (revised
directions came into force in July 2000see Annex F). Separate
guidance has been prepared in respect of the built environment
adjoining the River Thames (Strategic Planning Guidance for the
3.16 In responding to a Parliamentary Question
in 1999 from Gareth Thomas on tall buildings in London, the Government
agreed to take into account the advice on high buildings and strategic
views in London issued by the London Planning Advisory Committee
This advice noted that there was some demand for high buildings
(both residential and commercial) but no economic imperative in
terms of unmet demand or evidence of the threat to the competitive
position of London. The advice noted there was no need, or desire,
for radical change in London's skyline to sustain or enhance London's
image and status as a world city.
3.17 The Government also asked London Boroughs
to ensure that proposals for high-rise development were subject
to full consultation with interested parties and took account
of the criteria for assessing site suitability and development
quality set out in the LPAC advice. The Parliamentary Question
and answer is at Annex D.
London: Spatial Development Strategy
3.18 Strategic policy on tall buildings
in London is now the responsibility of the Mayor. In formulating
strategic policy he has to take account of national policy guidance
and the Government Office for London Circular Strategic Planning
which transfers responsibility for policies to protect strategic
views in London from the Secretary of State to the Mayor. Policy
for tall buildings is being developed in the context of preparing
the Spatial Development Strategy (SDS). The SDS will eventually
supersede the 1996 guidance and is required to set out policies
in respect of strategic views and the general location of tall
buildings. London Borough UDPs are expected to contain detailed
policy in terms of design and precise location of tall buildings
within the framework of the SDS.
3.19 The Mayor has produced Interim Strategic
Planning Guidance on Tall Buildings, Strategic Views and the Skyline
This document builds on the LPAC advice of 1999 and sets out the
Mayor's views on the question of tall buildings, and how he intends
to assess proposals referred to him, before the SDS is published.
Consultation: public attitudes
3.20 There is a range of requirements on
local planning authorities to consult the public, both in the
preparation of development plans and on planning applications.
It is widely accepted these arrangements have not always worked
well. Proposals to ensure the planning system fully engages with
local people in shaping the future of their communities are set
out in the Planning Green Paper.
3.21 There are few examples of direct attempts
to gauge public opinion on tall buildings. The research project,
which supported LPAC's 1999 advice did not explicitly consider
Londoners' views on the shape and size of their city in the future.
Whilst the report did not reveal widespread general opposition
to new tall buildings it did note a dislike of grand designs,
and the design of some existing tall buildings. Clusters were
felt to be better than random development.
3.22 More recently English Heritage undertook
opinion polling that suggested a general dislike of tall buildings.
The findings were not universally accepted.
Consultation: expert bodies
3.23 A number of expert bodies are likely
to be consulted on proposals for tall buildings. Potential statutory
and non-statutory consultees are listed at Annex E. Annex F sets
out the specific consultation arrangements for tall buildings
affecting strategic views in London.
3.24 Consultees are likely to include English
Heritage and the Commission of Architecture and the Built Environment
(CABE). English Heritage will advise whether the location is suitable
in terms of the proposal's impact on the historic environment
at a city-wide, as well as local level. CABE's remit is to promote
high standards in the design of buildings and the spaces between
them. Together, they have produced a consultation paper, Guidance
on Tall Buildings, setting out how each organisation intends to
assess proposals. This provides the potential for a framework
for a consistent evaluation by the Government's main advisors
on the built environment.
3.25 The Civil Aviation Authority are also
a significant consultee. The location of tall buildings can affect
aircraft operation and can restrict the use of airports. They
will be consulted to determine the safety implications for a development
within the approach, take-off or circuit areas of certain aerodromes
(determined on the basis of their importance to the national air
transport system). These aerodromes are safeguarded in order to
ensure their operation and development are not inhibited. A similar
safeguarding system applies to certain military aerodromes, selected
on the basis of their strategic importance.
4. THE SAFETY
4.1 The extent to which, and whether, safety
and the threat of terrorist attack is relevant (a material consideration)
to the decision on a planning application will depend on the circumstances
of the case. It will be for the decision taker and, if necessary,
the courts to decide if such an issue is a material consideration
in an individual case.
4.2 The Secretary of State has the power
to make Building Regulations in order to secure the health and
safety of people in and around buildings. Since 1985 these Regulations
have been expressed in goal-based terms, and are backed by "Approved
Documents" which provide guidance on how the requirements
of the Regulations can be met. The current set of Regulations
is the Building Regulations 2000 (SI 2000 No. 2531).
4.3 Schedule 1 to these Regulations sets
out the requirements under different headings. The two most relevant
Parts of this Schedule for tall buildings are Part A (Structure)
and Part B (Fire safety). Part A sets out requirements relating
to loading, ground movement, and disproportionate collapse. This
last requirement is that "the building shall be constructed
so that in the event of an accident the building will not collapse
to an extent disproportionate to the cause". Part B sets
out requirements relating to means of warning and escape, internal
and external fire spread, and access and facilities for the fire
service. The first of these includes the requirement that "the
building shall be designed and constructed so that there are "appropriate
means of escape in case of fire from the building to a place of
safety outside the building capable of being safely and effectively
used at all material times".
4.4 The Department issued a consultation
paper proposing changes to Part A of the Schedule on 31 August
2001. Responses were requested by 30 November 2001. These are
currently being analysed. The Department also issued on 16 November
a consultation paper proposing changes to the guidance in association
with Part B of the Schedule to facilitate European harmonisation.
Responses have been requested by 15 February 2002.
4.5 Schedule 1 to the Regulations also contains
a requirement (Part F) that there shall be adequate means of ventilation
provided for people in the building. Consideration is being given
as to whether any additional guidance needs to be provided in
support of this requirement to deal with potential attacks from
substances such as anthrax.
4.6 Following the events in the US on 11
September 2001, we are considering whether any additional changes
are necessary to the Building Regulations to improve further the
safety of people in and around tall buildings. The results of
the investigations being carried out by the authorities in the
US will be carefully considered when these are available.
4.7 We have also encouraged the professional
institutions to come together to consider the events of 11 September
and to propose any changes they consider necessary to Building
Regulations and design codes. A working party has been set up
under the Chairmanship of the Institution of Structural Engineers
to progress this. It met for the first time on 29 October and
will meet again on 24 January 2002. We will give careful consideration
to any recommendations coming from this group.
4.8 The Department has also established
a Building Disaster Assessment Group under the Chairmanship of
H M Chief Inspector of Fire Services. This is looking at the relationship
between operational fire fighting procedures and practices and
building design to establish the issues raised by the World Trade
Center incident, and any changes which need to be made. This Group
met for the first time on 23 November 2001.
8 Published in November 1999 Back
Planning: delivering a fundamental change, published in December
By Design: Urban design in the planning system: towards better
practice. Published in May 2000 Back
Better Places to live: By design. Published in September 2001 Back
PRG3, published in May 1996. Back
PRG3A, published in November 1991. Back
RPG3B/9B published in February 1997. Back
See footnote 1. Back
Government Office for London Circular 1/2000 Strategic Planning
in London June 2000. Back
16 October 2001 Back
High Buildings and Strategic Views in London 1998. Back