Select Committee on Transport, Local Government and the Regions Memoranda

Memorandum by Manchester City Council (TAB 41)


  In our response we will endeavour to address the points that the Sub-committee wishes to examine. Before doing so, however, we feel that the starting point should be the important issue of 'need' for tall buildings—who wants them and why?

  If it is understood that the development market requires tall buildings, as opposed to asserting they are important, then a number of issues flow from this. With need demonstrated, Manchester would want to consider attracting such investment as part of broadening the range and sustainability of its facilities and activities. This then makes it possible to give weight in decision-making considerations. If need is not demonstrated, just a preference or desire, then the possibility of alternative development forms and locations is important, balanced against what this means for investment prospects. The developer or applicant should therefore take on the role of providing explicit information on need, and this may cover areas such as investor, developer and tenant requirements; availability of sites; affordability of sites; affordability in relation to anticipated financial returns; prevailing market conditions; and the certainty associated with them.

  Following on from this, commenting on the Sub-committee's points is always going to be difficult as the answer to whether a tall building is necessary or appropriate will change with circumstances. This leads us to a more pragmatic view that the process of considering a scheme is probably more important than any policy that starts with a particular presumption. We have previously commented on the CABE / English Heritage view of policy, which was more to do with protecting a particular standpoint than developing understanding of the overall circumstances within which proposals are developed and the end result.

The role of tall buildings in achieving high densities in residential areas; the provision of offices for certain types of global companies; and as a means of enhancing the beauty of our cities.

  Generally speaking, our recent experience of tall buildings is confined to the City Centre and mostly for residential development. Their role is much more one of regeneration benefit, with positive connections to the social, economic, environmental, functional and investment circumstances that provide the context. This is more than a narrow focus, important though it is on, for example, building appearance, and should also generate a product that has purpose for a diverse group of people, from the Manchester resident to the Manchester investor.

  Any proposal should be useful and deliverable. The balance to be drawn between these attributes will only be tested by a thorough consideration of a wide range of regeneration parameters. In doing this, Manchester's experience is that tall buildings are a positive and important component of delivering regeneration that is of benefit to a broad spectrum of people. For these reasons, and within Manchester, there are aspirations to see more tall buildings in the City Centre as a demonstration of its vitality that is so important for continued investment and the wide regeneration benefits that this can derive, including for surrounding areas. The City Centre is the Regional Centre for the North West, and its competitiveness is essential for social progress over a wide area. The Urban White Paper underlines this approach—achieving an urban renaissance does mean concentrating development in accessible locations and achieving regeneration objectives where benefits can be maximised.

  Tall buildings undoubtedly have an impact on the appearance of an area and on the impression that people have of such visual impacts. It is unfair to pre-judge such impacts as a tall structure in an area of close knit or fine-grained streets may have a limited impact in the immediate area, whilst one on the edge of a public space will clearly be more obvious. The important issue here is about the tall structure's quality of design and how this relates to its setting. Urban design is about the relationship between various buildings (group value) and the spaces between them (streets, public squares and open spaces). Where these relationships are positive and the building is well designed and interesting, it is then that it will contribute to diversity, social engagement and a "sense of place". Furthermore, and most importantly, the building will contribute to peoples' perceptions of quality and visual interest in urban areas.

The sustainability of tall buildings, in particular in terms of construction, transport and long term flexibility of use.

  Although most buildings generally reflect the technology of their time some are clearly more innovative than others. The prestige of a tall building and its associated cost may suggest that innovation and future flexibility assumes a higher role here. Any building can use renewable or recycled materials of course but investment in taller buildings suggests some longevity of structures, perhaps because of high initial costs extending debt payments allied to higher cost of removing structures, and the opportunity costs of not continuing the use of such buildings.

  Recent experience in Manchester suggests that upgrading existing structures will prolong their useable life at a particular level in the market. Tall buildings also seem versatile in use terms, with hotel, residential, commercial and educational being potentially interchangeable.

Where tall buildings should be located, including: what restrictions if any, should be placed on the location of tall buildings, and how far they should be allowed to block existing views; and whether they should be clustered or dotted.

  The response to such points will very often be couched in negative terms of where not to locate them. If we were to try and identify areas positively, there would be an assumption that these should be limited and policies stemming from this should be restrictive rather than promotional. Again, we would say that the process of consideration is important, and that any policy should be an exposition of the criteria against which proposals can be assessed. This list should include broad based issues of need and regenerative benefit. This is where Government guidance might be helpful in establishing the basis of any planning consideration especially since in city centres there will often be a policy bias towards conservation and presumptions about restrictions. Urban design is obviously important but has to be balanced against other planning matters although the acceptability of a tall building is often influenced by the characteristics of the proposed location in terms of built form and topography and there will obviously be different judgements within the same city and between cities. The points about "views" and "clustering" or "dotting" are bound to vary between cities, and since most city centres outside London are so much smaller, they are probably of less significance but are capable of being considered locally.

  The real difficulty would be if it were ever thought that a policy should spell out where the location or character of tall buildings should not be acceptable. In truth there probably are some such locations, perhaps within a conservation area that has an obviously uniform character, but how far this restriction should hold is very debatable and certainly should not be pursued dogmatically. To counter such claims we should be able to identify what unique characteristics a tall building brings, and this is to do with:

    —  the need for a particular built form;

    —  the concentration of activity;

    —  the proximity to important facilities for large numbers of people, including sustainable transport;

    —  a quality image that can mark a location or area;

    —  an efficient way of meeting local and national policy objectives;

    —  how they assist in maintaining perceptions of integrated and rational development over time (which is more than "image"); and

    —  being a more sustainable form of development.

Whether in the present movement to erect tall new buildings we are in danger of repeating the mistakes of the 1960's.

  There are two groups of "mistakes": residential—where building high was effectively the result of Government policy which, combined with "systems building", brought multi-storey municipal housing into disrepute; and commercial—where much post war redevelopment, in looking forward to the modern age, did not take enough account of its context. Manifest in these mistakes were social issues; and construction techniques, control of quality, and site management that were of their time and unlikely to repeated.

Whether those making decisions are sufficiently accountable to the public.

  The statutory planning process is geared to being accountable to the public. With both residential and commercial schemes the process of approving such schemes involve many groups and individuals. Whether consultees such as English Heritage and CABE have such a public mandate or transparency in their processes is another matter and should be carefully considered. How to draw the balance of points of view against each other is fundamental. This is essentially about everyone demonstrating that their view is a reasonable one and that there is support for it, and that such support can be set against other viewpoints.

Whether the Government should have a more explicit policy on the subject.

  Whether having a more explicit Government policy is good or not depends on its intentions and what it achieves and for whom. "Guidance" rather than 'policy' may be more appropriate in that it has the potential to put everyone into the same debate, knowing their view is valid, understandable and capable of being weighed in the balance of any judgements made.

  The position of English Heritage on tall buildings is geared towards a restrictive policy approach which is narrow in focus. This could stifle schemes coming forward that would otherwise replicate the benefits of earlier schemes within conservation areas before their designation and which were considerably taller than surrounding buildings at the time. There are numerous examples of this within Manchester City Centre and this is where the approach of CABE is more relevant since they are looking towards quality of design. The approach of English Heritage, had it existed at the beginning of the last century, could potentially have stifled creativity and innovation in new buildings which were taller than their counterparts at the time. That would have been a real impediment for the development of cities and it is of some concern that the stance of English Heritage appears to be more one of preservation and resistance to change over time than of conservation. The position of CABE is also in need of development as the lives and livelihoods of the people of Manchester rely on more than the design of buildings.


  The City Council has adopted a holistic approach for considering proposals for tall buildings and it would request Government not to embark on a policy that is more prescriptive and restrictive in operation. It would be much more appropriate, if deemed necessary, to endorse guidelines such as those set out in the recent English Heritage / CABE consultation document but recognise that these are only part of the overall consideration which local planning authorities need to take into account in reaching decisions.

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