Memorandum by Minerva plc (TAB 40)
These representations are prepared on behalf
of Minerva Plc. Minerva is a FTSE 250 property investment company
with landholdings and development interests valued at circa £989
million. The company owns significant areas of real estate in
Central London including sites in the City of London (the City)
including a 0.5 hectare site at St Botolph's House, Houndsditch,
EC3 and a 0.15 hectare site at the Walbrook, EC4, together with
2.8 hectares at Sampson House and Ludgate House, Bankside SE1.
Minerva has put together an experienced team
of professional advisers to actively promote opportunities for
a tall office based building. The company is well placed, therefore,
to comment on tall buildings from a developer's perspective.
Whilst it is acknowledged that the scope of
this Inquiry is not geographically focussed, the following representations
reflect Minerva's experience in promoting a tall building in the
City together with wider comments.
We trust that the following comments assist
the Sub-Committee's consideration of the tall building issues
at the Inquiry. If appropriate, we would be willing to amplify
We would comment on specific aspects of the
sub-Committee's remit as outlined in the press release as follows:
Tall buildings play an important role in meeting
occupier demand for large prestigious headquarters.
The City is the leading international financial
and business centre and contributes significantly to London's
status as a "world class" city.
The City needs to respond to occupier requirements
to maintain and enhance its competitiveness.
There is increasing demand from City occupiers
requiring up to one million sq.ft. buildings with large floorplates.
Physical and economic constraints in the City
restrict opportunities to develop buildings with large footprints
leading to demand for tall buildings.
Tall buildings can contribute to an evolving
and dynamic skyline.
Tall buildings can be equally appropriate grouped
in clusters or as stand alone structures.
Technological advancements increase opportunities
to develop flexible and imaginatively designed tall buildings
that are environmentally sound and can stand the test of time.
An extensive policy and consultation framework
exists to assess all aspects of a tall building proposal and its
acceptability in planning and environmental terms.
The City is recognised as the leading international
financial and business centre and makes a vital contribution to
London's position as a world city. It contributes directly to
the London economy and benefits from access to a large and highly
skilled workforce which enhances its international competitiveness.
The strength of London's economic base together with its international
communications, range of cultural, educational and social facilities
act as a magnet for inward investment. It is essential that London
is able to evolve and respond swiftly to changing market circumstances
to retain its "world class" status in competition with
New York and Tokyo.
Tall buildings play an important role in meeting
the demand from commercial organisations for large prestigious
headquarter buildings. Demand is responding to wider economic,
technological and corporate influences and the use and occupation
of offices are subject to new pressures affecting the type, layout
and quantum of floorspace sought by tenants.
The City office market is at the forefront of
global competitiveness. It is experiencing significant restructuring
through, amongst other changes, expansion of its occupier base.
This is particularly evident in the financial services sector
where a smaller number of very large global organisations are
emerging as the key players. As a consequence, businesses are
seeking larger premises to accommodate expansion and merger and
to benefit from the economic and communications efficiencies of
consolidating operations. This has been a major driver of demand
in the City market over the last decade.
Demand for large buildings is now becoming more
common. Businesses require high quality flexible floorspace often
with large floorplates.
Many organisations wish to remain in the City
to benefit from its connections, linkages, infrastructure, support
services and status. Site assembly/land ownership constraints,
planning, environmental and economic considerations limit opportunities
to provide buildings with large footprints. This contributes towards
the demand for tall buildings.
Land is a scarce resource and particularly restricted
in central city areas. This necessitates greater density of development
often leading to demand for tall buildings. These locations have
the benefit of existing transport and communications infrastructure
and can be achieved without jeopardising green field sites.
Office occupiers attach significant weight to
location and flexibility in prioritising their accommodation preferences.
It is essential that the City is able to respond to this market
so as to retain existing key players and attract new businesses
to maintain the City's international pre-eminence and in turn,
London's position as a "world class" city.
In order to maintain London's competitive edge
it is imperative that a broad range of accommodation in terms
of quality and size is both readily available and deliverable
in the future. This should include the provision of tall buildings.
High building proposals provide an opportunity
to achieve significant townscape benefits. They need not adversely
impact on the local environment and streetscape. By virtue of
their size, they will be prominent landmarks. A well-designed
and appropriately located tall building does contribute to the
beauty of our cities.
Well designed tall buildings can act as a magnet
for further regeneration of the surrounding area and often promote
public realm improvements in the surrounding area.
The City embraces a diverse architectural palette
reflecting its historical growth and current status. The relationship
between buildings of different ages, scales and materials contributes
to a varied and vibrant townscape. The juxtaposition of contrasting
architectural styles can provide exciting and dynamic views. Tall
buildings form part of an evolving City skyline and can make a
positive contribution in townscape terms.
The impact on local and long distance views
is an important consideration in assessing the suitability of
a site for a tall building and the acceptability of a particular
development scheme. An extensive planning and environmental policy
framework is in place to ensure that the visual impact of a tall
building is thoroughly assessed as part of the planning decision
Tall buildings can be equally appropriate grouped
in clusters or located alone. The suitability of a particular
site for a tall building development will, however, depend on
site specific circumstances and the proposal in question.
There are recognised economic benefits for those
businesses who operate within clusters. In particular, the interaction
of professional services and depth of human resources.
There may also be benefits in townscape terms
in grouping tall buildings together. The appearance of a cluster
and the prominence of individual buildings within it will vary
from different viewpoints and will depend on the cluster's composition
and the design of its component buildings. It is considered inappropriate,
therefore, to seek to define a cluster by lines on a map.
A well designed isolated tall building can be
equally appropriate in townscape terms. Arguably English Heritage's
decisions to list the Millbank Tower and Centrepoint demonstrate
the potential contribution that such buildings can make to our
Tall buildings in locations well served by public
transport is an efficient use of resources and obviates the need
for major new infrastructure links therefore making development
in these areas more sustainable. Planning, environmental, legal
and economic constraints will inevitably limit the number of City
sites that come forward for tall buildings. It is important, therefore,
that development opportunities on potentially suitable sites are
Technical advancements in design and engineering,
construction techniques and building regulation controls since
the 1960s have extended the economic life of tall buildings and
offer greater scope for imaginative development solutions.
A well conceived building offering flexible
accommodation and employing high quality materials can withstand
the test of time. Long term maintenance of a tall building and
scope to adapt its structure to embrace changing occupier requirements
in terms of floorspace planning, energy consumption etc are important
considerations which if taken into account at the initial design
stage can influence a building's economic life.
The environmental impact of a tall building
is currently assessed as part of the planning process. The assessment
is undertaken in consultation with a wide range of interested
parties and covers all aspects of the development proposal from
conception, through construction and occupation to final demolition
at the end of the building's economic life.
This is not an issue on which Minerva has any
Extensive policy currently exists with respect
to the development of tall buildings and their associated impact
through the Town and Country Planning Acts, the Planning (Listed
Building and Conservation Areas) Act 1990, the Environmental Impact
Assessment Regulations 1999, Planning and Regional Policy Guidance
notes and the development plan framework.
Section 54A of the 1990 Planning Act requires
planning applications to be determined in accordance with the
development plan unless material considerations indicate otherwise.
In the case of development in the City, the development plan comprises
the 1994 adopted City of London Unitary Development Plan (UDP)
and the UDP Review 2000 which is due to be adopted early 2002.
Other material considerations include national and regional policy
guidance and advice issued by the London Advisory Planning Committee
(LPAC), English Heritage and the Commission for Architecture and
the Built Environment (CABE).
Regional guidance relevant to the consideration
of tall buildings in the City is contained in:
RPG9 (1989) Regional Guidance for
the South East.
RPG3 (1996) Strategic Guidance for
Local Planning Authorities.
RPG3A (1991) Supplementary Guidance
for London on Strategic Views.
RPG3B (1997) Strategic Planning Guidance
for the River Thames.
Also relevant to the consideration of tall buildings
is the research undertaken by LPAC and published in:
High Buildings and Strategic Views
in London, 1988.
Strategic Planning Advice on High
Buildings and Strategic Views in London, 1999.
At a London wide level, the forthcoming Spatial
Development Strategy (SDS) being prepared by the Mayor of London
(to be called the London Plan), will provide strategic guidance
for assessing tall building proposals.
The Mayor's consultation document "Towards
the London Plan", May 2001 sets out proposals to direct future
development in London and is supplemented by Interim Guidance
on tall buildings, strategic views and the London skyline, October
2001. These documents form the basis of the policy to be set out
in the draft London Plan due for publication early 2002.
Further guidance on tall buildings is set out
in the joint English Heritage and CABE document "Guidance
on Tall BuildingsConsultation Paper" June 2001. The
document identifies criteria for evaluating tall building proposals.
The above guidance provides an extensive policy
framework for assessing the appropriateness of a site as a location
for a tall building and the acceptability of a specific development
proposal. For example, it affords protection to Strategic Views
of St Paul's Cathedral and the St Paul's Heights Grid which effectively
restrict building heights across substantial parts of the City.
In addition, other important local views, panoramas and prospects
are identified in the City UDP and LPAC guidance.
It is anticipated that the forthcoming SDS will
evaluate existing tall building policies and produce strategic
guidance on the issue which local authorities will be required
to adhere to in preparing their UDPs.
The plan led system together with the consultations
undertaken in determining planning applications and Environmental
Impact Assessments, involve a very rigorous scrutiny of all material
considerations of the implications of tall building proposals
in an extremely detailed fashion, before planning permission may
be granted. Additional planning policy is not, therefore, required.