1.  INTRODUCTION

  In response to the Urban Affairs Sub-Committee call for memoranda, the Conservative Group of the Greater London Authority would like to submit its perspective on the terms of reference of the inquiry.

  This memorandum considers these questions in the light of the Interim Strategic Planning Guidance on tall buildings[2] published in October by the Mayor. It covers only the situation in London.

2.  BACKGROUND

  Up to 20 skyscrapers are proposed for the capital by the Mayor's Interim Guidance[3] in the next 10 years, both as clusters (as in the City, Canary Wharf and Croydon) and as stand-alone buildings (such as the Post Office Tower and Millbank Tower). Some of the proposed locations are within what we consider very "critical", areas that is urban contexts which have landmarks of cultural and architectural value and importance, such as to be recognised as relevant to the maintenance of the city's historical and environmental heritage and impose conservation constraints.

3.  THE ROLE OF TALL BUILDINGS

3.1  The economic need for tall buildings

  It is claimed that the rationale behind the construction of tall buildings in London is an economic need for them to sustain the capital's role as a world city. In presence of a growing shortage of land, the demands for buildings of more than 100,000 square metres, have seen a substantial increase. There is a need to create more office space and to answer the demand for higher densities in the capital. The construction of tall buildings is primarily a response to these demands.

  However, as it has been recognised by all the witnesses and by the Mayor of London himself[4] that high rise buildings are not always economically justified as they do not necessarily provide a greater density of office space than other buildings.

3.2  The environmental motive

  It is also argued by supporters of the "vertical development" that tall buildings play a relevant role in allowing the reduction of the consumption of land, greater energy efficiency and the reduction of the pollution deriving from travelling, by creating mixed-use towers that include office space, residential occupancy, hotel and commercial facilities.

3.3  Tall buildings and "the image of the city"

  But tall buildings do not only contribute to reach objectives of higher urban density. They also have a significant role in determining the identity of the cities, shaping the urban environment, the overall panorama and the city's urban skyline.

  Like the Royal Institute of British Architects and English Heritage we believe that tall buildings are a cultural issue[5] and their role is first and foremost of image and aesthetics rather than economic. Consequently the design quality is a key point to be considered as skyscrapers can change the traditional distinct character of many parts of London, determining the shape of London's urban skyline forever. Our concerns are to do with the impact they have on the urban environment and the skyline and, consequently on the quality of life of the city's residential communities and the overall image of London as a world city.

4.  THE LOCATION OF TALL BUILDINGS

  The issue of location is the most controversial in the debate about tall buildings in London.

  The urban design criterion of whether a site is suitable for tall buildings is that the site should be appropriate to its context and in harmony with existing architectural and urban settings. This includes taking into consideration primarily the issues of context and conservation constraints; such as the shape and the physical characteristics of the architectural and urban settings, including transport infrastructure and the processes that linked the forms of the urban spaces to the social behaviours of the communities who lived and live there.

4.1  Where tall buildings should be located

  A primary consideration is the whether the location is suitable for a tall building in terms of its effect on the historic environment at the city-wide as well as local level. There is scope for tall buildings in the city in some locations such as Croydon and the East, particularly Docklands and Canary Wharf. In these areas they would be appropriate to the historic environment and not compromise the existing strategic views across the Thames as well as important local views, panoramas and prospects, which must be protected.

4.2  Where tall buildings should not be located

  We object to the current proposals for location in West London and the City of London, where we consider tall buildings, as those proposed for these areas, could gravely damage and compromise London's environment from the point of view of the historic heritage, the quality of street environment and the overall urban skyline. This is the case for the proposed 600ft tower on Bishopsgate, the Heron Tower, whose erection, as claimed by English Heritage, "would inevitably lead to the erosion and eventual extinction of the visual prominence of the St Paul's cathedral, which has soared majestically over London for nearly 300 years[6].

  Our objections to the location of high rise buildings in these areas are primarily based on arguments of cultural nature, rather than technical and economical. More particularly a conception based on the idea of conferring a value judgement—which is primarily an historic and cultural value—to the existing urban and architectural settings. We believe such values determine constraints of conservation and the potential for intervention and modification of the built form. In particular we believe, high rise buildings should not be accepted in important conservation areas, however good the quality of the design.

5.  THE IMPORTANCE OF A COHERENT POLICY

  The setting of an overall policy and design strategy on tall buildings for London is considered essential. Whilst every project should singularly be the subject of accurate analysis and evaluation, the establishment of an overall policy does assist in keeping the issue of tall buildings high on the technical and political agenda. Whereas the critical issue of location needs to be addressed by the London Plan, which should clearly identify a limited number of suitable locations and the appropriate evaluation and judgement criteria for tall buildings in consultation with the boroughs.

  A tall buildings policy should require the highest design quality at street level and for surrounding spaces, specify locations for clusters of tall buildings and address the impact of tall buildings on views and settings.

  We also believe that following the events in New York on 11 September 2001, tall buildings policies in the London Plan should address construction methods, safety and security, as well as sustainability, impact on the public realm and accessibility issues.

6.  THE NEED FOR GREATER ACCOUNTABILITY

  A further issue, which the Conservative group would bring to the Sub-Committee's attention, is the lack of the accountability of the Mayor in his role as planning authority for London. We are concerned that the GLA Act 1999 failed to give a role to the Greater London Assembly as a consultative body which should guide the Mayor in making strategic decisions with regard to both the Spatial Development Strategy and the applications which are referred to him. Furthermore we believe scrutiny is inadequate when it concerns decisions that have already been made.

  We would recommend that when the Act is reviewed these matters should be taken into consideration.

7.  CONCLUSIONS

  We have no objection in principle to high buildings, as we recognise that London as a world city and the City of London as its financial centre must respond and adapt to changing requirements. Our concerns about tall buildings are to do with the quality of the urban and street environment they create, as well as with issues of skyline and strategic views.

  The Mayor's Interim Report on Tall Buildings does emphasise the need to address the issue of providing a supply for affordable office space of all types, in order to maintain London's role as a capital and global financial district[7].

  It primarily takes into account the economic concerns and the viability of meeting the needs of the city as a global financial district, without giving the due attention to the other sectors of the London's economy as well as to the environmental, cultural and historical concerns.

  In particular, it remains elusive on the issues of impact, context and design and on how tall buildings relate to the existing environment and urban settings. Issues that we believe are as important as the economic reasons.

8.  KEY RECOMMENDATIONS

  The report recommends that the Committee should further investigate whether there is a role for tall buildings in contributing to the provision of higher urban density in London.

  The Committee should also give the due importance and attention to the issues of impact, context and design.

3   Interim strategic planning guidance on tall buildings, strategic views and the skyline in London, pvii. Back

4   Mayor of London, Evidentiary Hearing 31 May 2001, Spatial Development Strategy Investigative Committee. Back

5   RIBA, Evidentiary hearing 27 June 2001, Spatial Development Strategy Investigative Committee. Back

6   English Heritage and RIBA, Evidentiary Hearing 27 June and RTPI & RICS, Evidentiary Hearing 28 June 2001. Back

7   Interim strategic planning guidance on tall buildings, strategic views and the skyline in London, pvii. Back