THE BRITISH PROPERTY FEDERATION

  The British Property Federation (BPF) is the trade association of the property industry in the UK. As such it speaks for a broad membership of companies and individuals who own, develop, manage and invest in property. The BPF promotes the views of the whole industry, both commercial and residential. Its membership comprises the majority of property companies, and property owning financial institutions, together with the professions serving the property industry. The property assets held by BPF's members were collectively valued in 2000 in excess of £100 billion.

  The vast majority, if not all, tall buildings are owned by BPF members. Our members will develop the UK's future tall buildings. The BPF would be delighted to expand on the points in this memorandum to the Sub-Committee, if that would be helpful.

THE BPF'S MEMORANDUM—CONTENTS

  1.  Headline points

  2.  Tall buildings in the context of existing planning policy

  3.  A response to each of the issues identified for Sub-Committee examination

1.  HEADLINE POINTS

—  Properly designed and located tall buildings can significantly benefit society.

—  Their role and value extend beyond economic considerations, to include social and environmental factors.

—  Tall buildings are now frequently considered landmarks of regeneration.

—  They can create a sense of civic pride.

—  We would urge the Government to develop and publish an explicit policy on tall buildings, not least to ensure their benefits are not confined to London.

—  The preservation of strategic views should be considered as one element within an overall policy governing tall buildings.

—  Allied to this, a true tall building policy will acknowledge the importance of balancing and reconciling the preservation of strategic views with economic and environmental considerations.

—  It is not for the planning system to judge whether a tall building is commercially viable or not.

2.  TALL BUILDINGS IN THE CONTEXT OF EXISTING PLANNING POLICY

  In considering the Government's future stance on tall buildings, it is worth reflecting on the fact that tall building development proposals have to take into account many key components of national and regional planning policy guidance, including PPG1, 3, 13, 15 and 16. The development of high-density development (with tall buildings having an important role in this regard) around transport nodes can, we believe, support the Government's Integrated Transport Policy. Tall buildings, and the high densities easily afforded from them, can inject viability into public transport solutions.

  In terms of our impact on the environment, and specifically global warming, it is also worth considering that most of us use more energy travelling to and from work, than in work, and public transport schemes are therefore fundamental to reducing energy consumption and its consequences. Typically a significantly greater proportion of workers housed in tall buildings travel to work by public transport due to the greater availability of it, and corresponding restraints in the provision of parking.

  With ever-increasing pressure for space within town centres, tall buildings provide an excellent means of accommodating necessary commercial and residential development without encroaching into the greenbelt. In the right circumstances, tall buildings positively support current national imperatives on issues from sustainable development to integrated transport.

3.  A RESPONSE TO EACH OF THE ISSUES IDENTIFIED FOR SUB-COMMITTEE EXAMINATION

3.1  The role of tall Buildings in achieving high densities in residential areas

  Apart from the need to provide housing without uncontrolled urban sprawl, well-designed and appropriately tenanted tall buildings can meet a need in providing affordable accommodation for the workforce upon which an economic cluster depends.

  Whilst tall buildings are an excellent means of achieving high density, the extent to which their development will be appropriate in what has traditionally been considered as "residential areas" will depend on commercial viability, site availability and contextual acceptability.

  However the Urban White Paper advocates the importance of moving away from the practice of allocating large swathes of land purely for single tenure, or building type, and away from the notion of purely "residential", or "commercial" designation. Instead it emphasises the importance of diversity in creating vibrant communities through mixed-use development. Within such a properly planned framework, and reflecting the Government's proposals within the Green Paper on Planning Reform, (published 12 December 2001), tall buildings will have a role to play in delivery high density in many areas. Including those that can presently reasonably be described as "residential".

3.2  The provision of offices for certain types of global companies

  To some extent global companies are considering their location decisions against the availability of well designed and appropriately located tall buildings from which to operate. The result is that against these criteria, global companies are currently considering the UK as one possible location for their European headquarters. Testament to this is the success of the Canary Wharf Group in attracting such major investment and employment opportunity.

  A greater factor in determining the importance of providing tall buildings is the current manifest demand for big buildings, with some users looking for as much as one million square foot. If such a building were to be accommodated in the traditional seven/eight storey City building, (and sites actually existed in the area to accommodate a building of such a floor plate), it would cover an area of around 150,000 square foot, creating enormous travel distances on each floor and reducing flexibility in arranging adjacencies between departments that work in network.

  Beyond the issue of attracting global companies to locate their international or European headquarters in the UK, rather than overseas, many of the UK's largest companies seek to house as many of their employees as possible, (certainly those in specific and related departments), in one large building, or fewer large buildings, rather than numerous smaller buildings. Increasing restraints on space in urban areas means that tall buildings are the most effective and cost efficient means of achieving this. For many of these companies the issue is less one of image, as perhaps is the case with blue-chip companies, as one of practicality and simple commercial advantage.

  Tall buildings are also being demanded as a direct result of the increased instance of company mergers, (a trend that looks set to continue in the foreseeable future), and the consequential increased demand for single buildings of between half and three quarters of a million square feet to accommodate these merged workforces.

3.3  As a means of enhancing the beauty of our cities

  As clusters, or isolated towers, there are already numerous examples of appropriately located and designed tall buildings that enhance the beauty of our cities. We note that English Heritage has in fact listed many of them including Centre Point, Millbank Tower, New Zealand House and the Barbican Towers.

  For the following reasons the BPF is confident that the vast majority, if not all, future tall buildings will enhance the beauty of our cities. Firstly, all tiers of Government from the Cabinet to local planning authority now promote high design standards. Secondly, it is well understood by the property industry that only well designed, carefully planned proposals for tall building development that on balance impact positively on the surrounding area will be approved. Thirdly, we are further reassured by the existence of the Commission for Architecture and the Built Environment, (considered an effective body), and others, all of which can and do provide advice on maximising good design.

3.4  Where tall buildings should be located

  Tall buildings should be located wherever they are appropriate in terms of need, architectural and environmental context, and within close proximity to public transport nodes, or in urban areas where the potential exists for enhanced public transport links. The latter point is key because the high density afforded from tall buildings can help deliver the volume of passengers necessary to entertain investment in public transport services, the future running of which would be commercially viable, such as mainline trains and, in London, extensions to the underground.

3.5  What restrictions, if any, should be placed on the location of tall buildings?

  The BPF has already referred to the relationship between tall buildings, density and transport infrastructure. Tall buildings may not be appropriate in areas where planning, financial, or other constraints prevent necessary improvements to transport infrastructure to meet the needs of the occupants and visitors to the site.

  Notwithstanding the above, regional and local planning guidance should indicate the areas where proposals for the development of tall buildings would be considered favourably. The act of positively indicating preferred locations for tall building development would greatly reduce both the prospect of the property industry submitting applications for development in other areas and, if it were to do so, the prospect of those proposals being approved. The Government expects local planning authorities to identify areas appropriate, (and inappropriate), for tall buildings, and we are concerned that this has not been properly carried by many local authorities.

  Before permitting the development of a tall building in a specific location, its impact on surrounding microclimatic conditions, such as wind speed, should be considered. The capacity of surrounding infrastructure, (including parking and waste removal), to cope with the pressures placed upon it by a tall building should also be considered.

3.6  How far they should be allowed to block existing views

  As the built landscape evolves, as clearly it must to permit the realisation of many of the UK's economic, social and environmental objectives, and to permit this generation to leave our own legacy to future generations, so must, to a degree, those views currently designated as important also evolve. It would be extremely helpful if the Government were to conduct an impartial assessment of the value of existing views, and crucially against this value the opportunity cost of maintaining them in their current form. There are now many areas in London, and other cities, which are restricted from taking advantage of tall building development within their strategic position and location due to rigid adherence to the preservation of views.

  One should continually bear in mind that the preservation of strategic views should be considered as one element within an overall policy governing tall buildings rather than its central concern. A true tall building policy will acknowledge the importance of balancing and reconciling the preservation of strategic views with economic and environmental considerations.

  Having said this, certain existing views should be preserved, and in preserving them take priority over other considerations in order to protect the unique character of each area in which tall buildings might be developed. The fact is that there is only so much demand for big buildings, and tall buildings will satisfy only part of that demand, (the skyline of London will never resemble Manhattan), and therefore we believe that is possible to provide properly for tall buildings and strategic views.

3.7  Whether they should be clustered or dotted

  As the Government is aware, there are often real competitive advantages to be gained from the congregation of commercially compatible companies in one area. The clustering of tall buildings can achieve this by concentrating sufficient activity to support ancillary services. Canary Wharf is a case in point, with major law firms seeking to occupy tall buildings neighbouring other tall buildings occupied by their investment bank clients. Others decide that it is advantageous to move to the same building, as was the case with Citibank and City Corp.

  Clustering often enhances the visual impact of stand-alone tall buildings. In addition, if we are to permit proper provision of tall buildings to meet future needs without radically transforming existing views, most future tall buildings will need to be clustered.

  However there are also many examples of "dotted" or stand-alone tall buildings that successfully meld with the location and community to which they are a part. The Telecom Tower is a case in point.

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

  What were the mistakes? Is the Sub-Committee referring to certain residential towers constructed in the 1960s? The BPF has already referred to a number of safeguards now in place to protect design quality and local amenity. These include:

—  Good design, rather than lowest cost approach, is now a central plank of Government policy.

—  The property industry's recognition that only well designed proposals will be entertained by local planning authorities.

—  The existence of organisations assisting in the delivery of good design.

—  Partnerships such as the Design Alliance to which BPF is a part.

—  The Green Paper on Planning Reform published on 12 December 2001 and described by the Chairman of CABE, Sir Stuart Lipton, as: "a series of proposals from Government that will allow developers and designers more creative time and space to generate high-quality developments which are responsive to community needs and aspirations".

3.9  Whether those making decisions are sufficiently accountable to the public

  National and local politicians exerting an influence on planning decisions are elected via a democratic process which we consider provides as great a degree of public accountability as is reasonably practicable.

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

  The BPF considers that it is essential for local planning authorities to be supported by national policy direction in determining proposals for the development of tall buildings in order that they can reasonably attempt to determine whether any impact on local amenity is offset against the benefits to be derived nationally from their development.

  The BPF also considers that it is important for the Government to develop a more explicit policy on tall buildings as the economic, environmental and social benefits of their development should extend to the Regions and not be confined to London, where the Mayor's broad support for the circumstances of tall building development will be fully set out in the Spatial Development Strategy from 2003.