The City Corporation has had considerable experience of high rise buildings since their development in this country for commercial and residential purposes and has considered a large number of proposals for tall buildings through the planning process. The City Corporation considers that, in certain parts of the City, they are an appropriate form of development which could enhance London's skyline and enable the provision of high density, high quality floorspace to meet the needs of international businesses, thus developing the financial services cluster. The commentary which follows seeks to address the specific points which the Inquiry wishes to consider.

  1.  The role of tall buildings in achieving high densities in residential areas

  Tall buildings can be effective in achieving high densities in residential areas provided that they are well managed, well maintained, supported by the right facilities and provide accommodation for residents where high rise living is compatible with their life style and life stage. The City estates of Golden Lane, Petticoat Tower and the Barbican have all proved effective in providing high rise/high density urban accommodation, with a need for outdoor play-space typically having proved to be the greatest area of difficulty for children of differing ages.

  2.  The Provision of Offices for Certain Types of Global Companies

  London currently has a status as one of only two "world cities" founded on its concentration of international service activities, notably clusters of firms, both large and small, in financial and business services, in corporate headquarters and in news and information industries.

  Evidence from a variety of sources shows that successful clusters lead to significant economic benefits in terms of enhanced competitiveness and higher growth. These benefits arise in three main ways:

—  clusters raise average productivity by allowing firms within them access to specialised inputs and specialist skills, by enhancing access to information and institutions and by facilitating complementarities: for example, firms in the City of London have access to a large pool of people with the full range of skills and experience they most need (in the Square Mile more than 320,000 people work for over 12,000 firms;

—  competitive pressure between individual firms within clusters increases the incentive to innovate to ensure continued competitiveness: for many, this means diffusing technological knowledge and innovating more rapidly, with the result that firms in the cluster benefit from higher rates of technological and organisational innovation and are able to retain their adaptability to unexpected external changes; and

—  clusters stimulate higher rates of new business formation, for example as employees in established firms within the cluster become entrepreneurs in spin-off ventures often meeting the emerging needs of other firms within the cluster, or as other new businesses are established to meet the sometimes specialised needs of the leading firms in the cluster. Merger and acquisition activity leads to fewer larger firms and more smaller ones.

  London faces competition to retain its status as a "world city" whilst the City of London faces competition to remain a global financial centre. Many of the key global businesses located in the City have offices in other centres around the world, many of which provide a diverse range of accommodation, including significant amounts of space in tall buildings.

  The amount, quality and range of office accommodation available in the City is important to the efficiency of the City cluster and, hence, to its future growth prospects.

  Historically, analysis of the City's growth needs to be set in the context of the development of the City's office stock, which increased by 17 per cent between 1984 and 2000.

  In the past, the pressure from rising demand for office space in the City has resulted in:

—  firms which benefit least from, and are thus least essential to, the cluster such as the newspaper industry, the post office and British Telecom, relocating elsewhere so that approaching 90 per cent of employment in the City is now in "City-type" activities: the scope for further movement of this sort is thus extremely limited; and

—  some larger users being forced to move most, if not all, of their operations to other locations; there would be significant risks to the cluster if this trend were to continue too far.

  Looking ahead, the City of London has the potential to attract more employment in financial and business services given the underlying forces affecting these sectors, provided that its infrastructure does not impose a constraint. Demand for office space in the City is expected to increase as employment in City financial and business services (F&BS) grows at between 1 and 2½ per cent per annum over the next 10 years representing between a 16 per cent to 22 per cent increase on the 1999 figure of 259,000 F&BS jobs in the Square Mile. There will also be an increasing emphasis on higher quality space, which is required by both large and small occupiers.

  Inevitably, there are physical and policy constraints on the opportunities available in the City to meet rising demand. It is, therefore, extremely important that the best possible use be made of such opportunities as there are to increase the quantity, quality and range of office space in the City.

  Tower developments represent an opportunity to secure an increase in the quantum of high quality space in Central London and specifically in the City or Canary Wharf, in established locations where tall buildings are appropriate.

  Tall buildings can be designed to provide office space that is not only high quality and centrally located, but also can be available for either large predominately single occupiers or for multiple lets in relatively small units in buildings such as Tower 42, City Point and City Tower. Such space is much sought after in both categories, particularly in the City where demand for a range of quality accommodation is at its highest

  Tall multi-let or single occupier pre-let buildings have the potential in the City to provide the following benefits:

—  They promote the efficient use of space in the City, well served by public transport, by adding to the range of types and quality of space available within the City and thereby, encourage and enable more firms to occupy space better suited to their needs.

—  Multi-let towers help meet the needs of the City's growing financial and businesses services cluster by providing space for new and established firms within the cluster which are seeking high quality office space in small units but which are unable or unwilling to commit to long term pre-lets. Multi-let towers can often accommodate the expansion needs of existing tenants in newly recycled space that becomes available when existing tenants come to the end of their lease and have a changing property requirement, or as a result of merger and acquisition activity making the need for space redundant.

—  Pre-let towers are often developed for a single occupier thereby helping to meet the need of established large City businesses within the cluster by providing the appropriate image and quantum of floorspace. The space provided by a tower often initially exceeds the amount required by the business as is, for example, the case with one new headquarters in the City and for several others in Canary Wharf. Excess floorspace is normally sub-let on short term leases to enable the business to take more floorspace, as and when they expand in the future.

—  Tall buildings, by allowing the development of higher density commercial floorspace, contribute to the efficient use of land and a more sustainable pattern of development. Well over 90 per cent of City workers travel to work by public transport, which illustrates the desirability of locating tall building developments where the public transport infrastructure can support the transport demands they create. Economic forecasts indicate that employment in the financial services and related sectors will grow substantially in the long term. If this growth cannot be accommodated in the City and surrounding areas there is a real possibility that development will instead take place in locations, such as the M25 corridor, where a high proportion of employees arrive by private car.

—  It encourages intensive and sustainable development within the City of London. The Corporation has recently commissioned consultants to assess the sustainability credentials of tall buildings. The initial findings of the study suggest that in many ways tall buildings have greater potential than other structural forms for incorporating sustainable features into their design, construction and operation.

—  Allowing the concentration of development in central areas accords with the Government's urban regeneration objectives. The City adjoins some of the most deprived urban areas in Britain. Development in the City has the potential to spread benefits to surrounding areas and provide employment opportunities for local residents.

  Failure to provide more floorspace in tall buildings would make the City less attractive to mobile international businesses (internationally, office rentals in the City of London already mean that London is still one of the most expensive locations in the world for business). This would be to the detriment of the City cluster and could potentially threaten the City's and London's competitiveness.

  3.  Tall Buildings as a means of enhancing the beauty of our Cities

  Tall buildings can and do attract the attention of internationally renowned architects and can positively enhance the skyline provided that they are suitably located and designed which is attractive to international businesses. The biggest challenge is how these buildings meet the ground and how they provide an attractive environment at pedestrian level. This is a matter which has been developed since skyscrapers of the 1960s and 1970s. The nature of City development enables the creation of high quality schemes.

  The Inspector's report into the City's recent Unitary Development Plan Review encouraged the Corporation to set out formally the contribution tall buildings might play in consolidating the two main clusters of high buildings in the City.

  4.  The location of Tall Buildings

  As has been set out in all relevant advice on tall buildings by CABE, English Heritage and LPAC, the location of tall buildings is critical to their success, not only locally but also in the wider skyline.

  The City of London is a highly built up but attractive area with a long history of development. It contains areas and buildings of high quality and character many of which are designated as conservation areas (covering over 1/3 of the City's area) and listed buildings. The protection of the City's significant historic, cultural and environmental qualities, whilst also encouraging and accommodating economic growth, is a major element of planning control in the City of London.

  The City recognises the importance of its townscape and its role as the historic core of London with its rich heritage of historic buildings and areas. This has to be balanced, however, with its role as the heart of the world's international financial centre and the need to provide the accommodation and infrastructure necessary to sustain it. These needs not only result from growth, but changing needs arising from rapid global and technological challenges. However, the size of the City, with its 26 conservation areas and numerous listed buildings means that new development is inevitably in close proximity to its historic fabric. In reality, this means that substantial proposals can rarely be advanced without impacting in some way on the setting of conservation areas and historic buildings. However, many see the contrasts created as part of the drama of the City with its juxtaposition of different scales and ages of buildings which adds to the quality of the townscape and the importance of the historic elements.

  The policies of successive governments and the policies adopted by the Corporation of London to protect the historic environment restrict the locations in which high buildings can be located without causing significant detriment to the environment and cherished views.

  In large parts of the City high buildings are not appropriate at all. The remainder of the City is sensitive to the development of high buildings. In each case proposals are carefully assessed to take full account of relationships to the surroundings, strategic and local views and the City skyline, the quality of the design and the capacity of the existing infrastructure. This has been assisted by the detailed analysis required as part of the Environmental Impact Assessments which are sought in respect of such schemes.

  It is of vital importance to the City's role as the world's international financial centre to be able to provide not only sufficient floorspace, but also a range of accommodation, sizes and types, matched to the needs and aspirations of international City occupiers. For the reasons that have been outlined there is limited scope within the City to provide high buildings.

  The limitations such conservation constraints create makes it necessary that suitable opportunities for sustainable large-scale development should be grasped when they arise. If they are not, it restricts the opportunity to meet the accommodation needs of the World Financial Centre. Proposals for suitably located towers should be supported since, if they are not, this could lead to a reduction in proposals for towers and in the diversity of new accommodation being provided within the City which, in turn, could affect the public perception of and confidence in the City's ability to provide the space requirements of City occupiers.

  In summary, the City is of the view that high buildings should be clustered in order to maximise their visual, economic and sustainable advantages centred on the greatest concentration of public transport nodes. They should not be allowed to block or intrude unacceptably into views of national importance.

  5.  The Mistakes of the 1960s

  The mistakes of the 1960s should not be repeated in the future provided the lessons of the past have been learnt in respect of the pedestrian level environment, the impact on the skyline, the residential content, the impact on local climatic conditions and the necessary interface with sustainable transport modes.

  The requirement for Environmental Impact Assessments enables Local Authorities to seek the information necessary to determine these impacts.

  The nature of City development ensures these issues are fully assessed and addressed. Tall buildings can also, through conditions and Section 106 Agreements, provide benefits to the wider hinterland and pump prime regeneration in certain locations.

  Policy on high buildings should normally be set out in local authorities' development plans. The process by statute requires a considerable degree of public consultation, including a public inquiry or examination in public. The Unitary Development Plan Review recently undertaken involved a consultation process which included publication of discussion papers and 2 versions of the Unitary Development Plan. At each stage 10,000 individuals and organisations were consulted. A wide range of views were expressed on the policy for tall buildings and these were considered by an independent inspector. While supportive of the policy, he made recommendations for modifications to it, which the Corporation has accepted. The Corporation therefore believes that its policy for tall buildings has been arrived at in the full light of public consultation.

  6.  Whether those making decisions are sufficiently accountable to the Public

  Local Authorities make decisions in respect of high buildings as they do in respect of all other development. This should continue to be the case. They make their decision following consultation with affected bodies and as required by the Environmental Impact Assessment Regulations. They are often the subject of wide publicity and interested members of the public become aware of them. It is essential that publicity is wide because of the nature of the impact of high buildings.

  Local Authorities in making their decisions are advised by a large number of statutory and non-statutory consultees and, in the case of London, the Mayor of London has powers of direction to refuse.

  It is important that those providing advice are aware of all the relevant information before giving their advice.

  It is also essential that negotiations in respect of planning obligations are kept separate from an appraisal of the planning merits of the case and that these are negotiated in a transparent manner. Various suggestions in the DTLR consultation document on Planning should assist this process by encouraging early public consultation and transparency in "planning gain" negotiations.

  7.  Whether the Government should have a more explicit policy on the subject

  It is not considered that it would be valuable to have more Government guidance on tall buildings for the following reasons:

(i)  It would of necessity be too general to assist Local Authorities in the consideration of such cases, where very particular and different issues may impact on closely adjoining sites;

(ii)  There is already advice from CABE, English Heritage, LPAC and the Mayor's interim policy, which provides a sufficient strategic framework within London;

(iii)  Policy is more appropriately set out in Local Plans. In the case of the City there is a very recent Unitary Development Policy Review where the Planning Inspector endorsed the approach of the City and which provides an up-to-date and relevant policy framework;

(iv)  High buildings should not be singled out for special treatment. The definition of a high building and its impact would be wholly different in one context than another; and

(v)  The Government's endorsement of the LPAC study as interim guidance might usefully be reviewed prior to the Mayor of London's Spatial Development Strategy being approved recognising the Government's endorsement of clusters and emerging policies.

  These points are not affected by any proposals in the Green Paper on Planning.

CONCLUSION

  Whilst the consideration of Tall Buildings raises complex and important issues it is considered that the planning system and framework, particularly if a number of measures in the Green Paper are endorsed, enable them to be properly considered and that further central guidance is unlikely to assist Local Authorities in that process.