These representations are prepared on behalf of Minerva Plc. Minerva is a FTSE 250 property investment company with landholdings and development interests valued at circa £989 million. The company owns significant areas of real estate in Central London including sites in the City of London (the City) including a 0.5 hectare site at St Botolph's House, Houndsditch, EC3 and a 0.15 hectare site at the Walbrook, EC4, together with 2.8 hectares at Sampson House and Ludgate House, Bankside SE1.

  Minerva has put together an experienced team of professional advisers to actively promote opportunities for a tall office based building. The company is well placed, therefore, to comment on tall buildings from a developer's perspective.

  Whilst it is acknowledged that the scope of this Inquiry is not geographically focussed, the following representations reflect Minerva's experience in promoting a tall building in the City together with wider comments.

  We trust that the following comments assist the Sub-Committee's consideration of the tall building issues at the Inquiry. If appropriate, we would be willing to amplify the representations.

  We would comment on specific aspects of the sub-Committee's remit as outlined in the press release as follows:

SUMMARY

  Tall buildings play an important role in meeting occupier demand for large prestigious headquarters.

  The City is the leading international financial and business centre and contributes significantly to London's status as a "world class" city.

  The City needs to respond to occupier requirements to maintain and enhance its competitiveness.

  There is increasing demand from City occupiers requiring up to one million sq.ft. buildings with large floorplates.

  Physical and economic constraints in the City restrict opportunities to develop buildings with large footprints leading to demand for tall buildings.

  Tall buildings can contribute to an evolving and dynamic skyline.

  Tall buildings can be equally appropriate grouped in clusters or as stand alone structures.

  Technological advancements increase opportunities to develop flexible and imaginatively designed tall buildings that are environmentally sound and can stand the test of time.

  An extensive policy and consultation framework exists to assess all aspects of a tall building proposal and its acceptability in planning and environmental terms.

THE ROLE OF TALL BUILDINGS IN PROVIDING OFFICES FOR CERTAIN TYPES OF GLOBAL COMPANIES AND AS A MEANS OF ENHANCING THE BEAUTY OF OUR CITIES

  The City is recognised as the leading international financial and business centre and makes a vital contribution to London's position as a world city. It contributes directly to the London economy and benefits from access to a large and highly skilled workforce which enhances its international competitiveness. The strength of London's economic base together with its international communications, range of cultural, educational and social facilities act as a magnet for inward investment. It is essential that London is able to evolve and respond swiftly to changing market circumstances to retain its "world class" status in competition with New York and Tokyo.

  Tall buildings play an important role in meeting the demand from commercial organisations for large prestigious headquarter buildings. Demand is responding to wider economic, technological and corporate influences and the use and occupation of offices are subject to new pressures affecting the type, layout and quantum of floorspace sought by tenants.

  The City office market is at the forefront of global competitiveness. It is experiencing significant restructuring through, amongst other changes, expansion of its occupier base. This is particularly evident in the financial services sector where a smaller number of very large global organisations are emerging as the key players. As a consequence, businesses are seeking larger premises to accommodate expansion and merger and to benefit from the economic and communications efficiencies of consolidating operations. This has been a major driver of demand in the City market over the last decade.

  Demand for large buildings is now becoming more common. Businesses require high quality flexible floorspace often with large floorplates.

  Many organisations wish to remain in the City to benefit from its connections, linkages, infrastructure, support services and status. Site assembly/land ownership constraints, planning, environmental and economic considerations limit opportunities to provide buildings with large footprints. This contributes towards the demand for tall buildings.

  Land is a scarce resource and particularly restricted in central city areas. This necessitates greater density of development often leading to demand for tall buildings. These locations have the benefit of existing transport and communications infrastructure and can be achieved without jeopardising green field sites.

  Office occupiers attach significant weight to location and flexibility in prioritising their accommodation preferences. It is essential that the City is able to respond to this market so as to retain existing key players and attract new businesses to maintain the City's international pre-eminence and in turn, London's position as a "world class" city.

  In order to maintain London's competitive edge it is imperative that a broad range of accommodation in terms of quality and size is both readily available and deliverable in the future. This should include the provision of tall buildings.

  High building proposals provide an opportunity to achieve significant townscape benefits. They need not adversely impact on the local environment and streetscape. By virtue of their size, they will be prominent landmarks. A well-designed and appropriately located tall building does contribute to the beauty of our cities.

  Well designed tall buildings can act as a magnet for further regeneration of the surrounding area and often promote public realm improvements in the surrounding area.

  The City embraces a diverse architectural palette reflecting its historical growth and current status. The relationship between buildings of different ages, scales and materials contributes to a varied and vibrant townscape. The juxtaposition of contrasting architectural styles can provide exciting and dynamic views. Tall buildings form part of an evolving City skyline and can make a positive contribution in townscape terms.

WHERE SHOULD TALL BUILDINGS BE LOCATED?

  The impact on local and long distance views is an important consideration in assessing the suitability of a site for a tall building and the acceptability of a particular development scheme. An extensive planning and environmental policy framework is in place to ensure that the visual impact of a tall building is thoroughly assessed as part of the planning decision making process.

  Tall buildings can be equally appropriate grouped in clusters or located alone. The suitability of a particular site for a tall building development will, however, depend on site specific circumstances and the proposal in question.

  There are recognised economic benefits for those businesses who operate within clusters. In particular, the interaction of professional services and depth of human resources.

  There may also be benefits in townscape terms in grouping tall buildings together. The appearance of a cluster and the prominence of individual buildings within it will vary from different viewpoints and will depend on the cluster's composition and the design of its component buildings. It is considered inappropriate, therefore, to seek to define a cluster by lines on a map.

  A well designed isolated tall building can be equally appropriate in townscape terms. Arguably English Heritage's decisions to list the Millbank Tower and Centrepoint demonstrate the potential contribution that such buildings can make to our heritage.

  Tall buildings in locations well served by public transport is an efficient use of resources and obviates the need for major new infrastructure links therefore making development in these areas more sustainable. Planning, environmental, legal and economic constraints will inevitably limit the number of City sites that come forward for tall buildings. It is important, therefore, that development opportunities on potentially suitable sites are optimised.

ARE WE IN DANGER OF REPEATING THE MISTAKES OF THE 1960S?

  Technical advancements in design and engineering, construction techniques and building regulation controls since the 1960s have extended the economic life of tall buildings and offer greater scope for imaginative development solutions.

  A well conceived building offering flexible accommodation and employing high quality materials can withstand the test of time. Long term maintenance of a tall building and scope to adapt its structure to embrace changing occupier requirements in terms of floorspace planning, energy consumption etc are important considerations which if taken into account at the initial design stage can influence a building's economic life.

  The environmental impact of a tall building is currently assessed as part of the planning process. The assessment is undertaken in consultation with a wide range of interested parties and covers all aspects of the development proposal from conception, through construction and occupation to final demolition at the end of the building's economic life.

ARE THE DECISION MAKERS SUFFICIENTLY ACCOUNTABLE TO THE PUBLIC?

  This is not an issue on which Minerva has any particular views.

SHOULD THE GOVERNMENT HAVE A MORE EXPLICIT POLICY ON THE SUBJECT?

  Extensive policy currently exists with respect to the development of tall buildings and their associated impact through the Town and Country Planning Acts, the Planning (Listed Building and Conservation Areas) Act 1990, the Environmental Impact Assessment Regulations 1999, Planning and Regional Policy Guidance notes and the development plan framework.

  Section 54A of the 1990 Planning Act requires planning applications to be determined in accordance with the development plan unless material considerations indicate otherwise. In the case of development in the City, the development plan comprises the 1994 adopted City of London Unitary Development Plan (UDP) and the UDP Review 2000 which is due to be adopted early 2002. Other material considerations include national and regional policy guidance and advice issued by the London Advisory Planning Committee (LPAC), English Heritage and the Commission for Architecture and the Built Environment (CABE).

  Regional guidance relevant to the consideration of tall buildings in the City is contained in:

—  RPG9 (1989) Regional Guidance for the South East.

—  RPG3 (1996) Strategic Guidance for Local Planning Authorities.

—  RPG3A (1991) Supplementary Guidance for London on Strategic Views.

—  RPG3B (1997) Strategic Planning Guidance for the River Thames.

  Also relevant to the consideration of tall buildings is the research undertaken by LPAC and published in:

—  High Buildings and Strategic Views in London, 1988.

—  Strategic Planning Advice on High Buildings and Strategic Views in London, 1999.

  At a London wide level, the forthcoming Spatial Development Strategy (SDS) being prepared by the Mayor of London (to be called the London Plan), will provide strategic guidance for assessing tall building proposals.

  The Mayor's consultation document "Towards the London Plan", May 2001 sets out proposals to direct future development in London and is supplemented by Interim Guidance on tall buildings, strategic views and the London skyline, October 2001. These documents form the basis of the policy to be set out in the draft London Plan due for publication early 2002.

  Further guidance on tall buildings is set out in the joint English Heritage and CABE document "Guidance on Tall Buildings—Consultation Paper" June 2001. The document identifies criteria for evaluating tall building proposals.

  The above guidance provides an extensive policy framework for assessing the appropriateness of a site as a location for a tall building and the acceptability of a specific development proposal. For example, it affords protection to Strategic Views of St Paul's Cathedral and the St Paul's Heights Grid which effectively restrict building heights across substantial parts of the City. In addition, other important local views, panoramas and prospects are identified in the City UDP and LPAC guidance.

  It is anticipated that the forthcoming SDS will evaluate existing tall building policies and produce strategic guidance on the issue which local authorities will be required to adhere to in preparing their UDPs.

  The plan led system together with the consultations undertaken in determining planning applications and Environmental Impact Assessments, involve a very rigorous scrutiny of all material considerations of the implications of tall building proposals in an extremely detailed fashion, before planning permission may be granted. Additional planning policy is not, therefore, required.