Select Committee on Transport, Local Government and the Regions Memoranda

Memorandum by Department for Transport, Local Government and the Regions (TAB 16)


  Section 1—Introduction

  2—Why build high?

  3—Planning tall buildings

  4—The safety of tall buildings

  Annex A—Sub-Committee: issues for investigation

  Annex B—Tall buildings in England

  Annex C—Tall buildings: a checklist of impacts

  Annex D—Government statement on tall buildings in London

  Annex E—Potential consultees

  Annex F—Consultation on strategic views in London


  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.


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.

High-rise living

  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 lifestyles.

  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 living.

  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 for families.


  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 and appeals.

  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[8] illustrates the task.

National policy

  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 system[9] 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.

Good design

  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[10], published with the Commission for Architecture and the Built Environment (CABE).

  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[11], 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.

Sustainable transport

  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 by car.

  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 PPG8.

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[12]. Boroughs are required to:

    —  include appropriate policies in their Unitary Development Plans (UDPs to protect and enhance existing strategic views;

    —  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[13] 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 2000—see Annex F). Separate guidance has been prepared in respect of the built environment adjoining the River Thames (Strategic Planning Guidance for the River Thames[14]).

  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 (LPAC)[15]. 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 in London[16], 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 in London[17]. 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[18], 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.


Planning application

  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.

Building Regulations

  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

9   Planning: delivering a fundamental change, published in December 2001 Back

10   By Design: Urban design in the planning system: towards better practice. Published in May 2000 Back

11   Better Places to live: By design. Published in September 2001 Back

12   PRG3, published in May 1996. Back

13   PRG3A, published in November 1991. Back

14   RPG3B/9B published in February 1997. Back

15   See footnote 1. Back

16   Government Office for London Circular 1/2000 Strategic Planning in London June 2000. Back

17   16 October 2001 Back

18   High Buildings and Strategic Views in London 1998. Back

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