Category: Opinions | October 04, 2023
There are many challenges being faced by tall building planning applications in London. One major challenge is the issues surrounding heritage harm, as evidenced by the recent refusal on 22 September 2023 by the Secretary of State for a scheme proposed by the Great Portland Estates to demolish an existing 1980’s 4-5 storey office building and construct one of two alternative tall buildings, rising to 37 and 26 floors respectively, near The Shard, on the corner of Borough High Street and St Thomas Street. The schemes were opposed at the Inquiry by the Southwark Council and by Historic England stating the scheme would cause “serious harm” to historic parts of Southwark.
The schemes were refused on design and heritage grounds. The Secretary of State stated that the extent of the harm caused to a number of designated heritage assets was significant. There would also be harm related to a number of aspects of the design and because of this, the schemes cannot be said to be exceptional, or exemplary. The heritage harm was given considerable weight; the harm related to a wide number of assets within Southwark and across London, including those of the highest significance. As such, the heritage harm and harm to townscape character and design were “not outweighed by the public benefits, including heritage benefits” and that both schemes were in conflict with the development plan.
Aside from the townscape and heritage impacts on listed buildings and conservation areas, where the case-law seems to be growing due to challenges coming forward and it is proving harder to outweigh harm via public/heritage benefits, one other challenge faced by tall building proposals is planning policy. First there is the protection afforded of ‘Strategically Important Landmarks’ from views identified in the London View Management Framework (LVMF). This was last published/updated in 2012, and as much as our historic environment is important, some people argue for its refresh to ensure it is fit-for-purpose as our Capital’s housing needs continue to go unmet. Tall buildings may deliver more floorspace with less footprint – particularly relevant in areas where there is pressure for growth coupled with a lack of available land. Tall buildings are seen by some to be part of the response to England’s housing crisis. Secondly, the London Plan policy on tall buildings also provides more control to local authorities over the definition, location and height of tall buildings based on the authority’s own policies. Within London, it is likely to become more difficult to promote a taller building without a specific site allocation and it is critical for developers, landowners and investors to engage with the local plan process and provide justification for their preferred building typology in a location. For instance, proposals to rework the City of London’s planning policies in relation to tall buildings will see specific sites in the Square Mile identified as likely to be suitable for new structures above 75m in height, in a change from current rules.
We all know that all building developments are not straightforward, but tall building proposals also face a further myriad of planning and non-planning matters to consider - such as viability, financing, the ‘Gateway 2 Levy’ proposals, good design, infrastructure provisions due to the local population spikes of thousands of new residents and workers overburdening current infrastructure (such a transport, health, education or open space) fire safety (second staircase requirements), aviation, wind microclimate, daylight/sunlight and overshadowing, as well as environmental performances and the whole life carbon assessments to combat the climate emergency and the whole retrofit vs demolition debate.
However, to meet the predicted increase in population and the need for housing, densifying London is unlikely to be achieved by low and mid-rise buildings alone, especially considering the growing competition that now exists on a finite supply of sites from other land uses, most notably urban logistics and distribution. We have to remember that tall buildings, provided they are well-located and well-designed, offer the opportunity to create a vibrant, polycentric city which supports walkability and public transport connectivity, help us reduce pressure on green belt and providing liveable new communities in close proximity to the services that people need. The balancing exercise of heritage harm vs benefits as well as overcoming all the challenges mentioned above is not going to be easy, but we need to make sure that the default position should not be that tall buildings are a bad thing.
