Thankyou for your letter of 30 November about the forthcoming inquiry and the invitation to this Council to comment. I have read the outline of the inquiry set out in the press release, and noted that the committee has asked this Council to comment with particular reference to the status of Bath as an historic city. I have the following comments to make on behalf of the Council.

  The city of Bath is an historic settlement located on a wide bend in the river Avon and its steep wooded hillsides. It is famous for its Roman Baths, Hot Springs and Georgian architecture. The whole city is designated as a world heritage site, and a large part is also within the Bath conservation area. Its landscape setting is designated as an area of outstanding natural beauty and green belt.

  Bath is a major tourist attraction. Tourism and related activities are its most important economic activity. It also has the highest residential land values outside London, reflecting its popularity as a place to live, largely due to its outstanding attractiveness and good geographical location.

  The Council is mindful that stewardship of this special environmental quality is vital to the economic well being of the area, but it is also mindful of the need to provide as sustainable and balanced local community. Opportunities for expansion are limited.

  The city has one high-rise building, a block of flats built in the 1960's. It is the most disliked building in the city and has had an adverse effect on a wide part of the conservation area. Today it is doubtful whether any public housing provider could justify building high rise flats. For many reasons they are not regarded as a suitable means of increasing residential density in this district.

  Global companies have relocated to Bath, using a range of historic and low-rise buildings very satisfactorily. They come to Bath for the quality of the environment for their staff and customers, and use electronic communications to contact the rest of the world. Smaller commercial units are in short supply in Bath and these generally fit well with the characteristics of the historic buildings and streetscape. High rise office blocks would be very damaging to the special quality of this historic city and there would be no economic justification for them in the current climate.

  In the well-defined landscape setting of the city of Bath it is improbable that a very tall structure could enhance a vista or "beautify" the city. On the contrary it would distract from the symbolic vistas of church spires, towers and civic buildings which accentuate this city and from the wooded hillsides which frame it.

  Many historic cities do have tall structures that play an important role in the townscape and civic identity of their area, but these are on the whole public structures, such as town halls, cathedrals and churches, not commercial office blocks. The cultural significance of this should not be overlooked.

  In the context of Bath all new development is assessed for its impact on the townscape, which is generally low and homogenous. Views and vistas are very important to the character and historic layout of Bath. Buildings which are significantly taller than their neighbours will have an impact on these special characteristics; they will also have an impact on the wider setting of the city. Full townscape and context studies would be necessary to ensure that the location, height and massing of a building is acceptable within the generally highly sensitive settings containing many listed buildings in Bath. Tall buildings should have to satisfy these stringent tests just like other proposals—they should not be seen as special cases.

  The committee is asked not to make generalisations about whether tall buildings should be clustered or dotted, but to consider that all tall buildings should be judged rigorously in their context and in the light of any urban design strategy for the area. The protection of views, skylines etc as part of a democratically developed urban design strategy for an area should be seen as the determining factor.

  There is certainly the fear that the same mistakes of the 1960's could be made again, if the developers do not involve their design teams in the context of the area. What works in one city will not always work in another. The fact that a place has no special environmental designation should not be a justification for a lower quality of environmental design, especially if the block is to be residential. Where new development is considered possible the public should be involved from the outset in an urban design strategy for the area. Design teams should study the context and consult widely before preparing designs. The designers of very tall buildings are often perceived by the public to be high-flying technologists revelling in structural excellence rather than in the design of the important public and semi-public spaces around the building. The design team should be set up on a multi-disciplinary basis from the outset to avoid this.

  At present the Local Planning Authority can take into account the impact of a development in terms of traffic and travel, but the Planning Acts do not allow the sustainability of the structure to be a material factor in the granting of planning permission. The Council would welcome moves to include this in the environmental factors to be considered. Along with CO2 emissions in making and transporting the new materials (usually very high for multi-storey buildings) and thermal performance, the embodied energy and potential for re-cycling of any existing structures should also be counted. This would give a truer picture of the environmental impact, which is likely to be very adverse for tall buildings, even if their cladding and structure was carefully designed to reduce energy consumption. Other more flexible building types, constructed from materials from renewable sources, are likely to be better in the long term, as they can adapt to change without major demolition. Many of Bath's important historic buildings for example have contributed to the sustainability by being in continuous economic use over the centuries.

  It is difficult to see how a specific policy for tall buildings could be developed by the Government. This Council would not support a policy giving them special status and it urges the government to strengthen the case for all buildings to be carefully considered in their context (both immediate and wide). It also urges the Government to recognise that many cities such as Bath have a unique and historic character and that this character is an economic asset, not a liability. Bath's limited capacity for expansion should not be seen as a justification for introducing structures which damage this special character. Bath does not see itself as a museum piece but rather as a very sustainable city which has adapted to change over the centuries without compromise to its beauty or vitality. It has after all been an "attraction" to visitors and a source of employment for over 300 years and will continue to do so in the future.