Memorandum by London Borough of Tower
Hamlets (TAB 44)
The London Borough of Tower Hamlets is currently
reviewing its Unitary Development Plan. As part of this review
the issue of high buildings is being reconsidered. The Borough's
planners are therefore following the London-wide debate about
high buildings with considerable interest.
The Planning Policy Team are also concurrently
preparing a Supplementary Planning Guidance Note (SPG) on High
Buildings to articulate the Council's position on high buildings.
This SPG has yet to be adopted, but the following comments indicate
the likely position of the Council on a number of matters relating
to high buildings.
The Mayor of London's Spatial Development Strategy
proposes much of the future growth of London toward the east.
The London Borough of Tower Hamlets finds itself very much at
the heart of this potential growth, being located at the hub of
both the Thames Gateway and Lea Valley growth corridors. In response
to this, we are currently considering how this proposed growth
could be accommodated, and whether tall buildings have a role
We anticipate being faced with increasing demand
for non-residential uses as well as for residential development.
We have, in recent years, considered many proposals for residential
use that fit our definition of "high" buildings, and
in principle are not opposed to their development in the future.
We consider that tall buildings play a role
where land is at a premium. They can achieve high density and
deliver vitality on small sites, both for residential and commercial
uses. However, for tall buildings to be successful we believe
that they have to be appropriately located and contribute to the
One of the main issues relating to tall buildings
we currently face in Tower Hamlets is that any significant development,
tall or not, places additional demand on infrastructure resources.
Transport links in particular are currently stretched to capacity,
and without additional investment the network will be unable to
adequately service new large-scale developments. We feel that
the developers of high-density projects should not rely on the
unlimited supply of infrastructure as a right. Projects should
either be accommodated within the carrying capacity of an area
or provision should be made as part of development to improve
networks before placing additional pressure on them.
Tall buildings can contribute significantly
to sustainability objectives. New designs should always take into
account environmental efficiency in design, layout, construction
techniques materials, and to ensure future adaptability of buildings.
The contribution to reducing vehicle movements, increasing use
of public transport and facilitating other pollution-reducing
forms of transport should also be considered.
Many global companies desire an "address"a
prestigious and recognisable location, and tall or architecturally
distinctive buildings can provide this identity locally, and more
often globally. There are certainly economic advantages for a
company to have all its employees on one site. However, in the
majority of cases, companies seeking premises take into account
other functional requirements such as location, access, servicing,
infrastructure and floorplate size as priorities. We understand
that the desire to occupy a landmark building exists for many
companies, but do not believe that this factor alone should be
used as justification for allowing more new high buildings.
High buildings can also contribute to the beautification
of the city, particularly if they are strikingly designed and
replace something of lesser architectural merit. The critical
factor in the design success of tall buildings is the manner in
which they "hit the ground" and contribute to the public
realm. Many examples of poorly executed developments have given
us sterile plazas and ground-floor uses which lack of interaction
with the public realm just outside the front door. As for any
new development, the potential of a building to enhance and enliven
street life should be of paramount importance.
The top of a building should also be given special
attention. Many cities, London included, are known for their distinctive
skylines, but we do not believe that a skyline has to remain static
or feature only historic buildings for it to contribute positively
to a city's image. Indeed, when considering various distinctive
buildings that global cities are known for, many of the buildings
and structures featured have been built in "recent"
timessome even since the 1970's. However, emphasis should
still always be focused on the contribution of the building to
street life and its ability to support economic activity.
The Tower Hamlets Unitary Development Plan currently
defines a "high building" as one that "exceeds
20 metres in height". The UDP review will look at the wider
policy issues of tall buildings, including the current definition
Obviously the current debate is centred on buildings
that far exceed this limit, and we have many buildings in the
Borough that are much taller than 20 metres. As part of the development
of the upcoming SPG, we have considered where buildings which
are significantly taller than 20 metres could potentially be located.
A number of criteria were used to determine locations that might
be suitable for very tall buildings, based on their likely impact
on local and regional infrastructure, and environmental conditions.
Proposals would also have to satisfy the requirements of the planning
process. This sort of analysis proved very useful in determining
areas where high buildings could potentially be located.
We do not think that the Government should prescribe
locations for tall buildings, but a direction that local planning
authorities carry out a similar study (particularly Inner London
Boroughs and those in proposed Spatial Development Strategy development
corridors) would be welcomed and supported.
The argument for protecting specific views of
buildings is difficult to make due to the subjective nature of
views themselves. At what point is a view most "valuable",
and when is it "lost" or "unimportant"?
Tower Hamlets is affected by three strategic
views as outlined in RPG3 Annex A: Supplementary Planning Guidance
for London on the Protection of Strategic Views. Within these
areas, inappropriately high development is resisted. In addition
to the Strategic Views, there are other views within the Borough
which are considered worthy of protection, as they provide vistas
which are unique to Tower Hamlets and serve to strengthen the
identity of these places. There are nine such local views that
the Council strives to protect, and four views from within the
Borough to landmarks in other boroughs. We therefore consider
that protection of views is important, as they strengthen the
identity of the Borough and of London as a whole.
In a predominantly flat city such as London,
views provide interest and strengthen a sense of identity. However,
we feel that the current strategic views are limited in that significant
changes in the skyline have occurred since they were proposed.
A graphic example of this is the views from Greenwich Observatory
towards St Paul's Cathedral. The viewshaft was outlined before
development at Canary Wharf took place, and it is these large
new buildings which now dominate the views from Greenwich. We
would like the Government to re-examine this aspect of the tall
buildings debate, and update strategic guidance on viewshafts.
It is possible to argue that if buildings are
clustered the identity of individual buildings is lost, which
defeats the purpose of such a striking form of architecture.
However, the impact of a group of buildings
can also be significant. Consider Canary Wharfon its own,
One Canada Square was a landmark building. However, now with its
two companions of similar height and bulk, they form a group that
more fully identifies the place as "Canary Wharf".
There are arguments both ways, and proposals
for high buildings should always be assessed on their merits.
What we would caution against is architectural "trophy-ism"
whereby a building is intended to glorify an architect or company
simply by its design. There is a place for spectacular architecture
in London. However, it must not be at the expense of the amenities
of occupiers or those in the area, nor be at odds with the surroundings.
The poor reputation of high buildings in this
Borough is predominantly associated with residential blocks. Many
of these admittedly are of poor design and quality. While the
current debate about "tall" buildings predominantly
centres on a small number of landmark buildings, we are also faced
with considering the possibility of high residential buildings,
and must be aware of the "mistakes" of the past. Faced
with a proposed expansion of the City eastwards, an increase in
the population and a change in household composition over the
next 15 years, we cannot ignore the potential of high buildings
as a solution for residences.
Similarly, many tall office buildings have shown
architects how not to design plazas.
Much has been learned from the developments
of the 1960s. Architects and developers are now much more aware
of the undesirable effects of high buildings, and there are many
design solutions and new technologies that should be able to reduce
the adverse effects of tall buildings.
We consider that in order to achieve a quality result,
it is crucial for developers to engage an architect who has experience
of making tall buildings work. We will press for the highest standards
of urban design in order to make high buildings, whatever their
proposed use, pleasant to occupy and be near.
In addition, it is crucial that high buildings
do not contribute to social exclusion. Every effort should be
made to ensure that developments contain a mix of uses.
London is a place of diverse environments, and
Boroughs have different skills and capacity to assess proposals
for tall buildings. On the matter of tall buildings in general,
we feel that some sort of strategic guidance would be helpful.
In areas such as the inner Boroughs and East of London, the pressure
for tall buildings is likely to remain or intensify.
We do not propose that the Government direct
local authorities in the matter of location of tall buildings,
as every site and every building proposal presents different opportunities
and constraints. Consistent and refined design assessment skills
in local planning authorities are therefore critical, but for
those Boroughs which lack resources, Government guidance would
at least ensure that all local authorities are assessing the same
types of things at the same level of detail when considering proposals
for tall buildings.
As already mentioned, we feel that the current
guidance on Strategic Views needs reviewing.