1.  The Sellar Property Group are pleased to have the opportunity to submit evidence to this Inquiry and trust that their submissions will be of assistance to the Sub-Committee.

  2.  The Sellar Property Group is the developer of the proposed 67-storey London Bridge Tower, which adjoins the London Bridge Station in the London Borough of Southwark. The architect is Renzo Piano and the application for planning permission is due to be considered by the London Borough of Southwark early in 2002.

  3.  The evidence presented represents the legitimate interests of a commercial developer who is a key stakeholder in development of such buildings as are currently being studied by the Sub-Committee.

  4.  The evidence given, however, is against the background of the considerable comment on and public interest in these issues in recent months.

ISSUE 1—THE ROLE OF TALL BUILDINGS

  5.  The current promotion of tall buildings is simply a part of an overall drive towards achieving higher urban densities. Without the freedom to develop particularly tall buildings in areas of greater density, there will be inevitable recourse to a uniform, flat skyline with a consequent diminution of public open space.

  6.  Tall buildings need to be understood in the context of Central Government Policy on four key issues;

—  maximising the use of available brownfield land in urban areas;

—  enabling increased density of development within central urban areas without recourse to green belt development and urban sprawl;

—  maximising the potential of transport interchanges to allow dense development without significant adverse impact on existing transport infrastructure; and

—  encouraging the greatest possible use of public transport, as opposed to the private car.

  7.  In relation to development in primarily residential areas, the achievement of high densities does not necessarily require tall buildings, although in some cases tall buildings may be appropriate. The acceptability of such a solution will very much depend on local context.

  8.  For office development, different considerations apply. In major cities, there is a real and identifiable need to meet market demand for large areas of uniform floorspace in single buildings, usually in prestige locations. This is particularly important to the City of London, which has a vital role to play in the national economy. A typical requirement would lie between 400,000sf and 750,000sf.

  9.  Such requirements can be met either by building tall buildings or lower "groundscrapers" with significantly larger floorplates. The excessive floor areas of many ground scrapers result either in a slab block arrangement such as seen at Croydon, or in a deep plan arrangement depriving most occupants of any contact with the outside world. Groundscrapers tend to have an adverse impact on adjacent public open space and it is clear from occupier surveys that workspaces in airy tall buildings are actually preferred to similar, dense, low-rise establishments.

  10.  Canary Wharf is currently the only location in London that offers tall buildings to the market. Currently demand clearly exceeds supply and developer will seek to supply into this market.

ISSUE 2—LOCATION OF TALL BUILDINGS

  11.  The issue of location is a highly subjective one. While some seek to show that the provision of tall buildings would adversely effect existing cityscapes, others believe that visual qualities of our major cities could be enhanced by exciting new architecture in the form of tall buildings.

  12.  SPG feels strongly that decisions as to the acceptability or otherwise of tall building proposals should be based upon accurate visualizations of specific proposals in their actual context. Such visualizations are undoubtedly possible using modern technology.

  13.  To attempt to proscribe conditions for the acceptability or otherwise of tall buildings in the abstract will restrict the authorities ability to make judgements on proposals within specific contexts.

  14.  Further, in reaching a judgement on such specific proposals, the effects of tall buildings on views should be only one of the many material considerations. Others should include the need for the development, regenerative effects, benefits to local communities and further opportunities created in the local area.

ISSUE 3—REPEATING THE MISTAKES OF THE 1960S

  15.  Clearly mistakes were made in earlier decades which colour our view of tall buildings today. The question is whether these mistakes would be repeated in the generation of tall buildings proposed today.

  16.  Many factors have changed since the 1960's. Architects, developers and planners have shown themselves more than capable of learning the lessons and contemporary developments benefit greatly from past experiences.

  17.  It is clearly not appropriate to create policy against tall buildings based solely on poor experiences in the past. It is interesting to note that some of the previous generations of tall buildings, such as Centrepoint and the BT Tower are—or are proposed—to become Listed.

  18.  A key consequence of the lack of appropriate planning policy in earlier decades is the unacceptable "peppering" of individual tall buildings on most city skylines. This demonstrates the obvious necessity to protect the cohesion of the overall skyline of our cities. This will be an issue that prevails over several adjacent planning authorities.

  19.  In some parts of cities it may be appropriate to seek to cluster tall buildings so as to draw attention to a particular part of the City such as the Central Business District. In other situations a high quality mixed-use tall building may be acceptable on its own and indeed may even be less effective in terms of cohesive massing if other tall buildings are allowed nearby.

  20.  Clear guidance will be necessary and this should come from the authority with responsibility for the overall cohesion of planning policy in the city concerned. However, this guidance should not be exclusive to further proposals for centres of density and the relevant city authority should be required to review policy as major proposals that show other significant benefits are brought forward.

  21.  Another deficit of past decades was poor quality design and detailing. This became particularly apparent in tall buildings.

  22.  It is clear that tall buildings will have a greater than average impact on the built environment and as such, design quality is of paramount importance.

  23.  We welcome current initiatives from government, which have resulted in the establishment of the Commission for Architecture and the Built Environment. (CABE) Our view is that the achievement of higher standards of design should be promoted by early referral to CABE and the appropriate use of reserved matters in planning approvals.

  24.  Quality should not be used as a reason for reservations in principle to tall buildings in London and other major cities.

  25.  Finally, the current requirement for full environmental impact assessments for all major developments does ensure that all the impacts of tall building proposals will be adequately considered at the planning stage. This was simply not the case in the 1960's and marks a complete change in a local authority's ability to determine an application.

ISSUE 4—ACCOUNTABILITY

  26.  In the Sellar Property Group's view, decisions regarding tall buildings should be taken at local level by those who represent the people most directly affected by a proposal.

  27.  In large cities, tall buildings will have an impact beyond the immediate vicinity and a more strategic view needs to be taken by the city authority. But once these strategic factors have been taken into account, the final decision should be returned to—and remain with—the local council for the area.

  28.  Whilst the views of interested parties and consultees must always be taken into account, the weight to be given to each should be for determination by local councils in the light of guidance by central government relating to the mandate of such interest groups, and the full range of factors relevant to the proposal.

  29.  Such decisions should be taken in the context of up to date and properly researched planning policies. Unfortunately, the present system results in lengthy delays in the updating of policy, such that decisions often need to be taken against the background of emerging policy, or, worse, policy which has become out of date. The Government's green paper includes measures to speed up the plan making system and reduce the difficulties that are occasioned by out of date policies. This is to be welcomed as is the strong recommendation for thorough local consultation to be carried out by a developer prior to the submission of any application.

ISSUE 5—NEED FOR GOVERNMENT POLICY ON TALL BUILDINGS

  30.  The Sellar Property Group does not believe that it is necessary for the Government to have a more explicit policy relating specifically to tall buildings. The context for tall buildings is very largely set by existing Government Policy Objectives relating to major projects, sustainability, heritage, etc.

  31.  Where an application has been the subject of extensive public consultation, and the local authority in question has properly discharged its responsibilities, there seems no reason for Central Government to exercise its call-in powers in relation to tall buildings per se. Such action simply results in lengthy planning inquiries which are excessively costly to public agencies, lead to considerable delays, and rarely contribute significantly to the quality of the decision taken.

  32.  Furthermore, successive or excessive call-in will deter developers from proposing any substantial schemes that would provide significant benefit to the community—especially those that impinge on existing transport infrastructure.

CONCLUSION

  33.  Sellar Property Group trust that the above submissions are of value to the sub-committee in their consideration of this important topic, and would be happy to give oral evidence in front of the committee if asked to do so.