1.  This brief Memorandum has been prepared on behalf of the Dean and Chapter of St Pauls Cathedral in their capacity as custodians for the present time of a building of national importance, views of which have for many decades been the subject of protection under the St Pauls Heights Code.

  2.  For three centuries the present building has dominated the skyline of London. The profile of the dome of the Cathedral has international significance as a symbol of the City of London; and certain views of the City, in which the Cathedral plays a pre-eminent role, are recognised the world over.

  3.  In the 1930s, commercial pressures led to a situation where, within a very few years, the Cathedral could have been lost to view behind tall buildings. It was the construction of Faraday House, which to this day masks much of the Cathedral from historic views from the Thames Bridges, which galvanised Godfrey Allen, the then Surveyor to the Fabric of St Pauls, to initiate action to protect these views from damaging development. His efforts resulted in the St Pauls Heights Code, introduced in 1937 and still enforced by the City authorities today.

  4.  The St Pauls Heights Code is based on a series of planes applied over a grid covering the areas around the Cathedral, limiting the height of developments so as to achieve the retention of views from certain selected viewpoints of the dome, the western towers and the main cornice line connecting them. All this was carefully calculated in 1935-36 by the use of the Parallacter system of working on photographs. The result has certainly achieved its purpose in allowing the whole upper part of the Cathedral to remain visible from these key views, in particular from the Thames bridges and embankments. From those same viewpoints it is also possible to sense the pressure constantly being placed on those limits, made evident by the tight lines of the roofs between the Cathedral and the river. Faraday House still stands as a memorial to what might so easily have occurred to block all views of the cathedral had the custodians of St Pauls not been so vigilant, and as a reminder of how difficult it is, once a building has been constructed, to remove it.

  5.  What is significant is that the buildings such as Faraday House did not need to be significantly tall—in contemporary terms—but simply tall enough to block those particular views. What is of importance is that the views themselves needed to be carefully and accurately defined in order to be effectively protected.

  6.  The generally successful enforcement of the St Pauls Heights Code has played an essential role in ensuring that these views of the Cathedral from certain key viewpoints, and in particular those from the Thames embankments and bridges, have not been blocked. But as the scale of buildings has increased over the last half century, so the necessity to protect views of the Cathedral from further away has come to be recognised. This has resulted in the introduction of the Strategic Views Protection Policy. This protection extends to Viewing Corridors from certain selected viewpoints, Wider Setting Consultation Areas and Background Consultation Areas, acknowledging the significance both of the desirability to preserve the direct sight lines to the Cathedral from these selected viewpoints, and of ensuring that the effect of the wider setting and background of these strategic views are also taken into account.

  7.  However, in recent years the arrival on the scene of significantly taller buildings introduces a new component to the debate about the skyline of London which requires a further degree of evaluation, beyond that already introduced under the Strategic Views policy.

  8.  When it was constructed, the Cathedral was conceived and executed on a huge scale. Whatever the significance of that scale for religious reasons, simply as a building it was designed to impress by sheer size; the dome was carefully devised by Wren so that it can be appreciated from far and near, and the upper part of the Cathedral stood a whole order above the roof levels of the seventeenth century city. That sense of dominance had already been partially eroded by the 1930s; but the significance of the levels set by the St Pauls Heights Code is to ensure that the main upper cornice of the whole cathedral continues to remain visible, so that the dome and the two western towers are able to be seen as belonging to the same building. Without this, the sense of enormous scale which we consider to be such a significant aspect of this historic building would already be lost.

  9.  But during the past 50 years, and in particular the last two decades, that sense of scale has been further diminished by the construction of larger and taller buildings within the City. Larger buildings even when further away continue to have an effect on the setting of the Cathedral. The construction of the building now known as Tower 42 set a new standard for its time; but within the last decade substantially taller buildings have been proposed, and others are clearly under consideration. We consider that these introduce a new factor, which should now properly be taken into consideration in evaluating the effect of new development on the historic skyline of London, and in particular on St Paul's contribution to it: the effect of the scale of these significantly tall buildings. We consider that the potential effect of significantly tall buildings on historic buildings of national significance such as St Pauls Cathedral should be subject to policies, formulated at a national level, which will require the evaluation of the significance of historic views and of historic skylines to be taken into account in determining planning applications.

  10.  We are aware that we should not be the policy makers. But we hope that our experience as recipients of the benefits of protection over a period of more than 60 years may be of some value in the debate about the issues relating to tall buildings in our cities.