CITY OF LONDON TALL BUILDINGS EVIDENCE PAPER

September 2010 CONTENTS

1. Introduction 6 1.1 The City of London 6 1.2 Definition of Tall Buildings in a City Context 6 1.3 Methodology 7 1.4 Structure of the paper 9

2. Policy Context 10 2.1 National Guidance 10 2.1.1 PPS 1 10 2.1.2 PPS 5 10 2.1.3 CABE / English Heritage Guidance on Tall Buildings (2007) 10 2.2 Regional Guidance 11 2.2.1 London Plan 11 2.2.2 City Fringe 12 2.3 Economic Growth in the City 12

3. Policy History and Evolution 14 3.1 Development of Tall Buildings Related Policy in the City of London 14 3.1.1 London Building Acts 14 3.1.2 St. Paul’s Heights (1938) 14 3.1.3 Reconstruction in the City of London (1947) 14 3.1.4 County of London Plan (1951 & 1962) 15 3.1.5 Greater London Development Plan (1976) 15 3.1.6 Smithfield District Plan (1981) 16 3.1.7 City of London Local Plan (1989) 16 3.1.8 City of London Unitary Development Plan (UDP) (1994) 17 3.1.9 City of London Unitary Development Plan (UDP) (2002) 17 3.1.10 London Plan (2004–2008) 18 3.1.11 Conclusions 18 3.2 Tall Buildings Policy Timeline 19

4. Urban Characterisation 21 4.1 The Urban Character of the City 21 4.1.1 Historical development 21 4.2 General urban design considerations for tall buildings 24 4.3 The Distribution of Tall Buildings 24 4.4 Approved tall building proposals 26 4.5 Skyline and Topography of the City 28 4.5.1 The Thames and Riverside 28 4.5.2 Environs of the City 30 4.5.3 More distant hills and ridges 30

5. Heritage Assets 32 5.1 Conservation Areas 32 5.1.1 Settings of Conservation Areas 35 5.1.2 Conservation Area Character Summaries / Management Plans 36 5.1.3 Conservation Areas: Conclusions 36 5.2 Listed Buildings 37 5.3 Historic City Landmarks 37 5.4 Archaeology and Scheduled Ancient Monuments 40 5.5 Historic Parks and Gardens 40

6. Protected Views and Settings 43 6.1 Views and Setting of the World Heritage Site 43 6.2 London View Management Framework 45

2 6.2.1 Policy Development 45 6.2.2 River Prospects and St. James’ Park View 52 6.3 St. Paul’s Cathedral: Local Views and Setting 54 6.3.1 Infringements of the heights 57 6.3.2 Backdrop to the views 59 6.3.3 St. Paul’s Heights: Conclusions 61 6.4 Monument Views 61 6.5 Tall Buildings that have been demolished 64

7. Other Planning Considerations 65 7.1 Thames Policy Area 65 7.2 Tall Buildings and Transport 67 7.3 London’s Airports 68 7.4 Environmental effects 71 7.5 Mixed use 71 7.6 Other Relevant Plans and Strategies in the City 72 7.6.1 Enhancing the Public Realm in the Eastern Cluster (2005) 72 7.6.2 St. Helens Square and Vicinity – Enhancing the Public Realm (2007) 72 7.6.3 Barbican Listed Building Management Guidelines SPD (Volume I & II) (2005) 73 7.6.4 Golden Lane Listed Building Management Guidelines SPD (2007) 73 7.6.5 Tall Buildings and Sustainability (2002) 73

8. Conclusion 74 8.1 Regional planning context 74 8.2 Local policies 74 8.3 Areas inappropriate for tall buildings 76 8.4 Areas sensitive to tall buildings 78 8.5 Tall Building Clusters 78 8.6 The Eastern Cluster 79 8.7 Other considerations 83 8.8 Summary 83 8.9 Policy 84

9. References 86

Appendices 88

Appendix A. Tall Buildings over 75m AOD in the City of London (Existing and Permitted). 88 Appendix B. Conservation Area Character Summaries. 92 Appendix C. Conservation Area Management Strategies. 93 Appendix D. Comparison of Strategic Views and Protected Vistas 1991 / 2007 / 2010. 94

3 LIST OF FIGURES

Figure 1. City of London employment projections. 13

Figure 2. Development and height control limitations timeline. 20

Figure 3. Tall Building distribution in the City. 27

Figure 4. Viewing locations in the City. 31

Figure 5. Heritage Assets in the City. 33

Figure 6. Conservation Areas in the City. 34

Figure 7. Historic City Landmarks. 39

Figure 8. Scheduled Ancient Monuments in the City. 41

Figure 9. Historic Parks and Gardens in the City. 42

Figure 10. Tower of London Local Setting Area. 44

Figure 11. Components of a Protected Vista. 46

Figure 12. Strategic Views 1991 – coverage in the City of London. 48

Figure 13. London View Management Framework Protected Vistas (2007). 49

Figure 14. London View Management Framework Protected Vistas (2010). 50

Figure 15. Comparison of changes from Strategic Views to Protected Vistas 51 1991 – 2010.

Figure 16. LVMF River Prospects and Townscape Views affecting City of London tall buildings. 53

Figure 17. St. Paul’s Heights Policy Area. 56

Figure 18. Buildings that infringe St. Paul’s Heights. 58

Figure 19. Monument Views Policy Area. 63

Figure 20. Thames Policy Area. 66

Figure 21. Public transport in the City of London. 69

Figure 22. London City Airport Safeguarding Area. 70

Figure 23. Tall Buildings in the City by Height. 75

Figure 24. Summary of Tall Building Constraints. 77

Figure 25. Anticipated Distribution of Development (% of floorspace and % of residential 80 units).

Figure 26. Eastern Cluster (LDF Core Strategy). 81

Figure 27. Major Schemes in the Eastern Cluster. 82

Figure 28. Tall Buildings in the City of London. 85

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5 1. Introduction

1.1 The City of London

The City of London is internationally recognised as the world’s leading financial and business centre. The firms and institutions located here require a growing supply of high-quality, modern office accommodation, and the ‘Square Mile’s’ dynamic economy generates a high level of development activity.

The City’s economy and employment levels are predicted to grow substantially in the longer term, notwithstanding current short to medium term economic conditions. This will create demand for a significant increase in office and other commercial floorspace. While the City’s residential population is small, the number of dwellings is also expected to rise. As all land in the City is already developed, this increase in both commercial and residential accommodation will be achieved through the redevelopment of existing buildings at higher density. Taller buildings will be one means by which this intensification can be achieved.

Since the 1960s considerable numbers of tall buildings have been constructed in the City, and form a distinctive and characteristic element of parts of its townscape and skyline. The expected growth in the economy will mean that further proposals for tall buildings will be brought forward in future.

The City of London is preparing a Core Strategy as part of its Local Development Framework. The Core Strategy should contain a clear and robust policy to guide tall development.

The City has long been densely developed, and tall buildings are a modern expression of this. Tall buildings have very considerable impact on both their local surroundings and the London skyline. The City has a high quality of environment and is the most historically important area of London, so increased density will not be appropriate on all sites. Tall buildings provide a means of bringing about an increase in the total floorspace in the City by accommodating development on suitable sites and relieving pressure on those where intensification would be harmful. The Core Strategy’s policy therefore needs to be based on a thorough process of identifying those locations where tall buildings would be regarded as either appropriate or unacceptable.

1.2 Definition of Tall Buildings in a City Context

“Guidance on tall buildings”, issued by English Heritage and the Commission for Architecture and the Built Environment, states that “it is not considered useful or necessary to define rigorously what is and what is not a tall building. The simplest definition would be to take a height threshold. However, a judgement as to whether a building can be considered tall is strongly influenced by its surroundings. The general height, scale and density of the townscape varies greatly from place to place. The EH/CABE guidance notes that “it is clearly the case that a ten storey building in a mainly two-storey neighbourhood will be thought of as a tall building by those affected, whereas in the centre of a large city it may not. The assessment is therefore a relative one.

The London Plan (paragraph 4.119) defines tall buildings as those “that are significantly taller than their surroundings and/or have a significant impact on the skyline and are larger than the threshold sizes set for the referral of planning applications to the Mayor.” The height threshold for planning applications that need to be referred to the Mayor is 150m in most of the City, which is considerably higher than anywhere else in London. This threshold height

6 would exclude many buildings that would otherwise be considered tall, and so this definition is not appropriate for the City’s Core Strategy or this report.

The City of London Unitary Development Plan (UDP) 2002 defined tall buildings as those which “significantly exceed the height of their surroundings.” This definition has been contained in the City’s development plans since the 1989 Local Plan. The definition allows a qualitative decision to be made as to whether a building is regarded as tall according to its context and so is used in this report.

This definition would include a number of listed historic buildings, such as churches, some of which are significantly taller than their surroundings. However, the policies of the London Plan, the current UDP and Core Strategy are concerned with proposals for tall office, residential and other commercial accommodation. Therefore, the term “tall building” when used in this report does not apply to pre-war listed buildings.

For consistency, a height threshold of 75m AOD for the purposes of the maps and tabulated information has been used in this report, unless otherwise stated.

1.3 Methodology

The following table summarises the approach the City is taking to identifying suitable locations for tall buildings.

7 • 1 Heritage assets including: Views and setting of World Heritage Sites Scheduled Ancient Monuments and archaeological remains 1. EVALUATION OF Conservation Areas and their settings HISTORIC CONTEXT Listed Buildings Historic Parks and Gardens • 2 St. Paul’s Heights • 3 Monument Views • 4 Strategic Views • 5 River Prospects • 6 Historic City Landmarks

• Skyline / Topography • Proximity to major transport interchanges • Potential for open space / urban grain / public realm improvements / pedestrian NATIONAL / 2. URBAN capacity REGIONAL CHARACTERISATION • Mixed use GUIDANCE • Tall buildings that have been demolished and replaced • Urban design considerations

• Existing scale of development and approved tall building proposals • Thames Policy Area • Rights of Way, permeability 3. EVALUATION OF • Relevant plans and strategies THE CITY’S LOCAL • Economic benefits of tall buildings in the City CHARACTER • Relationship to tall buildings within and outside the City • Potential impact on London’s Airports

OUTCOMES: Appreciation of City context of development Overview of constraints to tall building development Overview of sensitivities to tall building development 8 Overview of appropriate locations for tall buildings

1.4 Structure of the paper

This paper sets out the approach to establish locations that are inappropriate for, sensitive to and appropriate for tall buildings in the City of London to inform the City’s Local Development Framework (LDF) Core Strategy. This paper supports Policy CS14: Tall Buildings.

The following themes will be addressed:

• Section 1 has defined the need for a policy evidence base on tall buildings in the City of London and provided a methodology for the evidence paper. • Section 2 describes the relevant national, regional and local guidance. • Section 3 describes the evolution of policy relating to tall buildings in the City from the early 20th century to the present day. • Section 4 provides an urban characterisation of the City, describing the historical development of tall buildings in the City, the existing scale of development, the skyline and topography of the City and urban design considerations relevant to tall buildings. • Section 5 details and explains heritage assets in the City and their relation to tall building development in the City. • Section 6 explains how protected views and World Heritage Site policies reflect tall building development. • Section 7 details other planning considerations that are relevant to tall buildings policy in the City of London. • Section 8 concludes by identifying the areas of the City of London that are inappropriate or sensitive to tall buildings and criteria for assessing proposals. This informs the LDF Core Strategy policy.

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2. Policy Context

The City of London’s Local Development Framework is required to take account of polices operating at national and regional level. National guidance is issued by the Secretary of State for Communities and Local Government, other branches of government and its agencies. In London, regional policies are prepared by the Mayor.

2.1 National Guidance

2.1.1 PPS 1

National planning guidance is set out in Planning Policy Statements (PPS) issued by the Secretary of State. PPS1: ‘Delivering sustainable development’ contains guidance on development and design that applies generally to all forms of development, including tall buildings. It states that local planning authorities should concentrate on guiding the overall scale, density, massing, height, landscape, layout and access of new development. However, policies for tall buildings are considered to be a local matter and are not explicitly addressed by PPS1.

2.1.2 PPS 5

The general guidance contained in other PPSs also needs to be taken into account, although none refers specifically to tall buildings. For example, PPS 5: ‘Planning for the historic environment’ contains guidance on the conservation of the historic environment including heritage assets such as listed buildings, scheduled ancient monuments and conservation areas.

2.1.3 CABE / English Heritage Guidance on Tall Buildings (2007)

The CABE and English Heritage Guidance on Tall Buildings (2007) advises local planning authorities to consider the scope for tall buildings, where they are a possibility, as part of strategic planning. This may include how they contribute to areas of change. In identifying locations where tall buildings would and would not be appropriate, local planning authorities should, as a matter of good practice, carry out a detailed urban design study. This will support the policy approach the City is taking regarding tall buildings. This report has been prepared in conformity with this guidance.

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2.2 Regional Guidance

2.2.1 London Plan

The London Plan sets out strategic planning policy for the whole of Greater London and the City’s Core Strategy is required to be in general conformity with it. The London Plan was first published in 2004, has been altered on several occasions, and was published in consolidated form in February 2008. A replacement London Plan is in preparation, but is not expected to come into force until late 2011. The London Plan contains a number of objectives and policies relevant to tall buildings.

The London Plan identifies the capital is a ‘world city’ and predicts substantial growth in its economy, employment and population in the period up to 2026. This growth is driven particularly by the financial services sector, concentrated in central London and especially the City. The Plan aims to accommodate this growth within London and without encroaching on the green belt or open space. It seeks to achieve this by an overall increase in the density of building on previously developed land, making London a more compact city, while enhancing the quality of the environment.

Chapter 4B of the London Plan sets out design principles for a compact city. While all of these policies are of some relevance to tall buildings, the following are of particular importance:

4B.9 Tall buildings – location 4B.10 Large-scale buildings – design and impact 4B.16 London View Management Framework 4B.17 View management plans 4B.18 Assessing development impact on designated views

Policies 4B.9 and 4B.10 state that the development of tall buildings should be promoted in suitable locations and that Development Plan Documents may identify areas that could be sensitive to tall buildings. The policies set out detailed criteria to be taken into account in assessing proposals for tall buildings.

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Policies 4B.16, 4B.17 and 4B.18 deal with the London View Management Framework (LVMF), which protects and manages defined views, identified as ‘London Panoramas,’ ‘Linear Views,’ ‘River Prospects’ and ‘Townscape Views.’ A detailed account of the operation of the policies is set out in supplementary planning guidance (SPG) first published in July 2007, and reviewed and replaced in July 2010. The LVMF is accompanied by a statutory direction setting out requirements for its operation. The LVMF in relation to the City is described in more detail in section 6.2 of this paper.

The London Plan identifies ‘Opportunity Areas’ defined as locations for accommodating large- scale development. These areas include the ‘City Fringe (Bishopsgate/South Shoreditch)’. Policy 4B.16 states that some Opportunity Areas may be suitable locations for tall buildings. An Opportunity Area Planning Framework for the City Fringe is currently being prepared by the Mayor in consultation with the City and its neighbouring boroughs (see section 2.2.2).

The replacement London Plan contains similar policies to the current Plan, while allowing boroughs greater flexibility in determining locations where tall development is considered suitable or inappropriate.

The City’s policy must take account of the Mayor’s policies in defining locations suitable for and sensitive to tall development. The London Plan and the LVMF SPG set out criteria for assessing tall building proposals in considerable detail, and it is not necessary to repeat these in the Core Strategy.

2.2.2 City Fringe

The City Fringe Opportunity Area is identified in Table 5C.1 of the London Plan. It forms an arc of land from around the eastern edge of the City from Shoreditch to Wapping and contains a number of accessible, relatively central sites with significant development capacity. The area faces issues related to the expansion of the City’s activities eastwards and the intensification of residential uses and covers parts of the City of London and the London Boroughs of Islington, Tower Hamlets and Hackney.

The draft City Fringe Opportunity Area Planning Framework (CFOAPF) identifies the City Fringe as one of the locations where the Mayor will promote tall buildings. The area has potential to provide an eastward extension to the City’s office core. The development of good quality and sustainable tall buildings properly related to their surroundings and contributing to mixed use can provide a catalyst for regeneration in deprived areas in the City Fringe. The CFOAPF is currently subject to consultation and review with the relevant Boroughs and Strategic Partnerships.

2.3 Economic Growth in the City

The City of London has a key role in achieving the London Plan’s targets for economic and employment growth. As the world’s leading international financial and business centre, it is supported by a unique combination of economic activities, technology, business skills and a high quality environment concentrated in a highly accessible location. The beneficial existing concentration of economic activities gives the City a “critical mass” which makes it the preferred location for many institutions, markets and major employers who specialise in “City- type” international financial and business services.

The City’s office floorspace projections are based on the London Office Policy Review (LOPR) 2009 and the Greater London Authority Working Paper 39: Borough Employment Projections

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to 2031 (November 2009). These are explained in more detail in the City’s Office Evidence Paper.

The City’s employment projections are set out below:

Figure 1. City of London employment projections.

Actual Projection 2005 2006 2007 2011 2016 2021 2026 2031 337,000 332,000 339,000 373,000 401,000 423,000 428,000 435,000

Source: GLA Economics Working Paper 39 (November 2009)

These are the most up-to-date employment projections. The figures show that between 2006– 2026 there is an expected employment increase of 96,000 workers in the City. This is nearly 15% of London’s total expected employment increase in all sectors over the same period.

The London Plan (2008) states in paragraph 3.144:

“A number of office employment density scenarios have been considered. As a single, average net measure 16 square metres per worker is now considered to mark the top of the density range and a figure of 13.9 sq m is a more robust central assumption. Office-based employment is projected to increase by 535,000 between 2006 and 2026. Taking into account uncertainties over future trends in occupancy ratios and vacancy rates it is prudent to plan for 7.0 million to 9.4 million square metres more office floorspace by 2026. These figures set the broad parameters for monitoring, managing and planning for substantial growth in the office based economy.”

The City is using the revised density figure of 16 sq m per person (gross) for the purpose of office floorspace calculations. Further justification for this can be found in the Office Evidence Paper.

The City of London Local Development Framework Core Strategy has set a target for office development in the City, informed by the GLA employment projections (Working Paper 39, November 2009) and on office-based employment projections provided by the LOPR 2009. The target for the increase in office floorspace from 2006 – 2026 is 1,500,000 sq m. This is equivalent to an annual average of 75,000 sq m per year, but is expected to be phased as follows:

2006 – 2011: 750,000 sq m (a large proportion of which has been delivered 2006 – 2010) 2011 – 2016: 250,000 sq m 2016 – 2021: 250,000 sq m 2021 – 2026: 250,000 sq m

This is explained in further detail within the Office Evidence Paper.

This growth in floorspace will be met through the construction of larger buildings on appropriate sites. Tall buildings are one means of achieving higher densities.

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3. Policy History and Evolution

3.1 Development of Tall Buildings Related Policy in the City of London

Tall buildings policy has long-term effects on the townscape and skyline for years or even centuries to come. It is important therefore to be aware of previous policies to ensure that these are taken into account.

3.1.1 London Building Acts

Prior to the 1948 planning system the height of buildings were for several centuries controlled by the Building Acts. Their main aims were fire prevention and structural stability, and height was largely restricted to the length of the Fire Brigade’s ladders. This ensured relatively low rise development until the early 20th century, with only St Paul’s Cathedral, the numerous church towers and spires and a few civic buildings rising above the roof-line. A new Act in 1930 raised the maximum height of building to 100 feet from 80 feet. The London County Council, which administered the Acts increasingly granted waivers permitting some structures higher than this limit. From 1933 controls under the Building Acts were supplemented by the City’s Town Planning Schemes, which included controls on building heights to similar limits.

3.1.2 St. Paul’s Heights (1938)

Following the 1930 London Building Act, several tall buildings were constructed, notably Unilever House, the Faraday Building and Vintry House. These blocked cherished views of St Paul’s and gave rise to public concern. The City Corporation and the Dean and Chapter asked W. Godfrey Allen, Surveyor to the Fabric of St Paul’s Cathedral, to put forward measures to preserve important views of the Cathedral. The Surveyor proposed building height limits to maintain views of St Paul’s from the south bank of the Thames, the Thames Bridges from London Bridge to Hungerford Bridge, as well as views along streets, including Fleet Street and Farringdon Road. The system was expressed as a grid, showing a maximum building height in each 50’ square.

The height limitations were endorsed by the City Corporation in 1938 and became known as “St Paul’s Heights”. They carried no statutory force and for several decades were applied through informal agreement with developers. Since 1981 and 1984 they were incorporated into successive statutory development plans for the City and remain in operation today.

Section 6.3 contains further information relating to St. Paul’s Heights.

3.1.3 Reconstruction in the City of London (1947)

The City Corporation appointed Dr C. H. Holden and Prof. (later Lord) W. G. Holford to prepare a plan for the post-war reconstruction of the City completed in 1947. The plan contained policies that directly and indirectly affected building height, including ‘height and cover’ clauses, which limited the height of buildings according to the width of adjoining streets, plot ratio controls and daylighting standards. Generally, the plan envisaged that the future height of development in the City would continue the existing pattern. The Plan was approved by the City Corporation, although when the Town & Country Planning Act came into force in 1948 responsibility for preparing the development plan transferred to the London County Council.

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3.1.4 County of London Plan (1951 & 1962)

The London County Council (LCC) prepared a development plan for its area, which included the City of London. The plan was adopted in 1951 and reviewed in 1962.

The County of London Plan contained a number of policies that influenced the location of tall buildings, the most significant being plot ratio. The main aims of plot ratio control were limiting the physical bulk of buildings and constraining the density of employment with the intention of preventing congestion in the immediate surroundings of the building and the wider transport system. Varying plot ratios were set out in supplementary guidance, notably “A Plan to Combat Congestion in Central London” 1957. In the City the zones ranged from 2:1 to 5½:1, although most of the area was zoned at 3:1 and 5:1. Plot ratio controls limited the total floorspace on a site but did not constrain the form of development and so did not restrict the height of buildings.

The County of London Plan designated Comprehensive Development Areas where there had been extensive war damage and streets and buildings were radically replanned. The plan contained many proposals for road construction and widening. New roads were proposed in the north of the City and near the Thames to carry east-west traffic through the City. Street width standards were applied and many City streets were proposed for widening. Much of this widening was achieved when buildings were redeveloped, with frontages being set back from previous building lines. These measures had significant effects on the appearance and character of many streets and on building heights, as accommodating floorspace on residual sites after road widening led to taller buildings.

The plan did not contain explicit policies for tall buildings. Nevertheless, many such buildings were proposed and constructed during the life of the plan, and the locations of these were considered according to informal guidelines. Within the City tall buildings were not permitted in sensitive areas such as the setting of St Paul’s Cathedral or near the River Thames, with the result that they were mainly confined to the north and east of the City.

The County of London Plan remained in force in the City until superseded by the London boroughs’ local plans. In the City these were the Smithfield District Plan, adopted in 1981, and the City of London Local Plan 1989.

3.1.5 Greater London Development Plan (1976)

The Greater London Council (GLC), established in 1963, superseded the London County Council. It had a duty to prepare a Greater London Development Plan (GLDP) to provide a strategic framework for the London boroughs’ plans. The GLDP was approved in 1976.

The GLDP was the first plan to include a policy for tall building proposals. It divided London into three categories: "areas in which high buildings are inappropriate”; “areas which are particularly sensitive to the impact of high buildings”; and “areas where a more flexible or positive approach is possible”. The GLDP included an ‘urban landscape diagram’ that showed the City falling within the first two categories, but not the last. The plan set out criteria for the consideration of proposals for tall buildings in each of the categories of area. The GLDP was required by legislation to define ‘areas of special character’: several of these areas were in the City, including ‘Thames and Thames-side’, ‘the City’, ‘Tower of London area’, and ‘Royal Courts of Justice, Inns of Court, etc’. The plan referred to important long-distance views, which included those of St Paul’s Cathedral from Greenwich, Primrose Hill and Hampstead. The areas of special character and long-distance views were shown on the urban landscape

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diagram and were important determinants of the location of the tall building categories. The GLDP continued plot ratio controls, although referring to the need eventually to replace these.

The GLDP did not replace the LCC’s County of London Plan, and the two plans were in force concurrently. The GLC was abolished in 1986 and GLDP remained in force until the issue of the Secretary of State for the Environment’s Strategic Planning Guidance for London 1989.

3.1.6 Smithfield District Plan (1981)

The Smithfield District Plan (SDP) was a local plan prepared by the City of London Corporation for the Smithfield area and adopted in 1981. The SDP incorporated the St Paul’s Heights policy, adding two additional protected views from Myddleton Square/Amwell Street and St John Street in Islington, and continued the plot ratio standard. It did not envisage tall buildings in the Smithfield area, but contained a proposal for the construction of a new road north of Little Britain, the achievement of which resulted in the construction of an associated tall building at the western end of London Wall.

The SDP was superseded by the adoption of the City’s Unitary Development Plan in 1994.

3.1.7 City of London Local Plan (1989)

The City of London Local Plan covered the entire City except the area covered by the Smithfield District Plan and was adopted in 1989. The plan included a policy for tall buildings and several other policies indirectly affecting tall development.

The policy for tall buildings conformed with the GLDP, interpreting its requirements for the City’s local context. It defined protected views and conservation areas as inappropriate for tall buildings. The remainder of the City was considered sensitive to the impact of tall buildings and the plan set out criteria for consideration of proposals in these areas.

The Local Plan included a policy for St. Paul’s Heights giving it formal status. It introduced a policy for the protection of views of and from the Monument, defining a local setting where the height of surrounding buildings should not compromise the dominance of the Monument, and a number of view corridors seen from its gallery. The plan included a policy for the protection of the setting of St Paul’s on the skyline, which in addition referred to the backdrop to the St Paul’s Heights views and the strategic views included in the GLDP as well as the view from Richmond Park, which was protected by statutory direction. It continued the plot ratio standard, replacing the varying zones with a 5:1 ratio applying across the whole of the City.

The Local Plan contained policies to guide development in conservation areas, which were first designated in 1971.

The plan’s policies for transport identified a number of main through-traffic routes. These were two east-west routes to the north and south of the City largely carried forward from the LCC’s plans, and two north-south routes from Blackfriars Bridge to Farringdon Street and London Bridge to Bishopsgate. These had since the 1940s been subject to road construction and widening schemes and the Local Plan sought the completion of the last remaining widening proposals. Outside these defined locations all previous widening proposals were abandoned.

The Local Plan remained in force until the adoption of the Unitary Development Plan in 1994.

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3.1.8 City of London Unitary Development Plan (UDP) (1994)

The City became a unitary authority with a duty to prepare a UDP on the abolition of the GLC in 1986. The Secretary of State for the Environment issued ‘Strategic Planning Guidance for London Planning Authorities’ in 1989 to provide a framework for the London boroughs’ UDPs.

In 1991 “supplementary guidance for London on the protection of strategic views” (RPG3a) was issued by the Secretary of State. This required the protection of long-distance views that crossed boroughs’ boundaries and included eight views of St Paul’s Cathedral from Richmond Park, Primrose Hill, Parliament Hill, Kenwood, Alexandra Palace, Westminster Pier, Greenwich Park and Blackheath Point. These views were protected by defined view corridors and wider settings and backdrops to the views.

The City of London’s UDP policy for tall buildings largely continued that of the Local Plan, identifying conservation areas and protected views as inappropriate locations for tall buildings and the rest of the City as being sensitive to their impact. It also included more detailed criteria for considering proposals within the sensitive areas.

The UDP continued the Local Plan’s policies for St Paul’s Heights and Monument views and included a policy for the protection of strategic views of St Paul’s in accordance with Strategic Guidance. A further policy sought the protection of views of buildings, townscape and skylines, and an appendix listed historic skyline landmarks within and near the City. A significant change was the exclusion of a policy for plot ratio, control of the bulk and volume of buildings instead being achieved through the general policies for building design.

The 1994 UDP was replaced by the UDP 2002.

3.1.9 City of London Unitary Development Plan (2002)

The Secretary of State for the Environment issued revised Strategic Guidance for London in 1996 (RPG 3). In 1997 “strategic planning guidance for the River Thames” was published; among its policies was a requirement for all riparian local authorities to define a ‘Thames Policy Area’. The City Corporation commenced a review of the 1994 UDP, and the new UDP was adopted in 2002.

The policy for tall buildings in the 2002 UDP continued to recognise protected views and conservation areas as being inappropriate for tall buildings and the remainder of the City as sensitive to such development.

The policy recognised that the areas not covered by protected views and conservation areas had potential for the construction of new tall buildings, and that these areas compromised in an “eastern cluster” and a “north central area”. It set out criteria for assessing proposals in these areas.

The 2002 UDP included policies for St Paul’s Heights, strategic views, Monument views and townscape views, as well as the listed historic skyline landmarks, carried forward from the 1994 UDP. In accordance with the requirement of strategic guidance the UDP designated a ‘Thames Policy Area’, and set out policies for this area, including one requiring a high standard of design appropriate to riverside locations.

The UDP 2002 was accompanied by supplementary planning guidance (SPG), including “St Paul’s and Monument views” and “Riverside appraisal of the Thames policy area”. These gave detailed guidance on the operation of the relevant policies in the UDP.

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The 2002 UDP remains in force. In 2007 several policies lapsed, including that for strategic views which was not saved because the strategic guidance on which it was based was repealed on the adoption of the London Plan. The SPG remains in force except for the section on strategic views.

3.1.10 London Plan (2004–2008)

The Greater London Authority was established in 2001 and the Mayor of London has a duty to prepare a Spatial Development Strategy, known as the London Plan. The first London Plan was published and took effect in 2004. It was altered on several occasions until 2008, when it was published in consolidated form. Its relationship to City policies is set out in section 2 where the London Plan’s policies for tall and large buildings are described in more detail in paragraph 2.2.1. The London Plan provides a strategic framework with which the boroughs’ LDFs must be in general conformity. It is part of the statutory development plan, and so must be taken into account in determining planning applications.

From 2001 the City Corporation was required to refer to the Mayor all planning applications for tall buildings over 25 metres in the Thames policy area and 75 metres elsewhere in the City. In 2008 the latter limit was increased to 150 metres.

The London Plan 2008 remains in force. The Mayor consulted the public on a replacement of the London Plan in 2009/2010 and the revised London Plan is expected to come into force in late 2011.

3.1.11 Conclusions

The City Corporation may review existing local policies for tall buildings in considering options for the Core Strategy. When carrying out this review it is important to be aware of previous policy frameworks to understand the present situation and to ensure consistency of approach in view of the long-term implications of such policies. It is useful to draw conclusions from past policies and their implementation.

Previous and current plans and policies have ensured that tall building development has mainly taken place in the east and north of the City, and has mainly avoided from the west and the riverside. This has resulted in a distinctive cluster of tall buildings in the east. This cluster is relatively concentrated, contains many of the tallest buildings and forms a prominent element on the skyline. Elsewhere in the north and east of the City tall buildings have a more scattered distribution. The west and south of the City generally have a noticeably lower skyline.

This policy approach has been in response to the varied local character of different areas of the City. The eastern area of the City has long contained the highest densities of development, and taller buildings have been allowed there since the 1930s Town Planning Schemes. Some areas of the City were heavily damaged by bombing in the Second World War and so offered opportunities for replanning, while in others the existing character of development was a consideration.

Views of St Paul’s have been protected over a considerable period of time, and methods of protection have become more systematised. St Paul’s Heights have been continuously applied since the 1930s, while longer-distance views have developed from an initial informal consideration to a comprehensive system of protection.

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While the policies of successive development plans have varied in their detail, they have all treated some areas of the City as being inappropriate for tall development, and others as being more suitable, but still sensitive to their impact and demanding a selective approach to site assessment. These considerations have resulted in the present distribution of tall buildings.

Until 1994 controls on the overall bulk and mass of development operated in the form of a plot ratio standard. This standard imposed a uniform maximum density of development on each site. This meant that tall buildings did not necessarily achieve any greater floorspace on a given site than other configurations of development. Although this limited the commercial incentive to build tall, many tall buildings were constructed while these controls were in force. The limits on floorspace mean the tall elements of these developments are often associated with low-rise elements or open space. The profile of the tall buildings is often relatively slender, as they were not seeking to achieve more space.

When plot ratio controls were removed development proposals were considered according to townscape and design policies. Where tall development was judged acceptable in relation to these considerations, a greater bulk and floorspace could result. This led to a greater variation in density between individual sites. While an increase of density has not been acceptable on some sites due to design considerations, the effect has been to increase the total amount of floorspace and density of development in the City as a whole. The prospect of achieving significant increases in floorspace on sites where high-rise development is acceptable in design terms has created a greater commercial incentive to construct tall buildings.

3.2 Tall Buildings Policy Timeline

Figure 2 shows how policy relating to tall building development has emerged since the 1930s.

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Figure 2. Development and height control limitations timeline.

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4. Urban Characterisation

4.1 The Urban Character of the City

It is essential that the Core Strategy’s policy for tall buildings should take account of the City of London’s distinctive character in identifying those areas and locations where tall development would or would not be acceptable and set out relevant criteria for assessing proposals. The City’s character derives from its long history and its 800-year role as a major international financial centre. These factors have resulted in a townscape of great complexity and diversity. It is important to identify the elements of this townscape that need to be considered in the development of a policy for tall buildings. This section considers the historical development of the City, its present townscape character, the distribution of existing and proposed tall buildings, and the City’s topography and skyline.

4.1.1 Historical development

One of the most distinctive features of the City’s townscape is its pattern of streets and spaces. The City was first settled following the Roman occupation in 43AD and during the Roman period the City wall and gates were established; these were an important influence on the City’s later development. While the original alignment of London Bridge and several of the City’s streets can be traced back to the Roman period, most of the City’s street pattern originates from the reoccupation of the City in Saxon times and its subsequent medieval development. This resulted in a dense and intricate network of streets, lanes and alleys which form the basis of much of the street pattern that survives today and is a significant component of the City’s characteristic urban grain. The Saxon and medieval periods saw the establishment of the City’s many parishes, each with its church and churchyard. Many of these churchyards exist today, providing valuable open spaces, while several medieval church towers are features in the skyline.

Much of the medieval City was destroyed in the Great Fire of 1666. The reconstruction of the City was carried out on the original plots and the medieval pattern of streets and spaces was very largely maintained. While some widening of existing streets was carried out, only a few new roads were built, such as King Street and Queen Street linking the Guildhall to the river. A succession of Building Acts sought to prevent further fires through prescriptive controls on design which imposed limits on the height of buildings.

The most significant building rebuilt after the fire is St Paul’s Cathedral. With a height of 111.6m (above ground level) it remained the tallest building in the City of London until 1970. Of the 87 pre-fire churches, 51 were rebuilt. The churches had spires and towers which rose above the general rooftops and created a skyline unique in Europe and greatly admired. The church steeples continue to provide characteristic features in local views and the wider skyline. The Monument, built to commemorate the origin of the Great Fire, with a height of 202 ft (67m) also rose above the roofline.

Westminster had, since the eleventh century, become the main centre of the state, while from the seventeenth century the West End developed as London’s principal residential area. The City, by contrast, while retaining a large residential population, remained primarily a centre of commerce, with a variety of trades, industries, warehousing and exchange, much of it related to river-borne trade. This mixture of activities was reflected in the form of development, with a great variety of building types and sizes of plots. The density of development intensified as gardens and other open land were increasingly used for building, giving the City’s townscape an increasingly close-grained texture.

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The overall form of building and townscape set by the post-fire reconstruction was maintained throughout the eighteenth century, but during the nineteenth century radical changes to the City’s urban fabric were made. These included the construction of new roads, including Moorgate, Princes Street and King William Street, built in the 1830s to connect the newly reconstructed London Bridge; Queen Victoria Street, built in the 1870s to link to the new Victoria Embankment; and Holborn Viaduct, which carried the road from Newgate Street to Holborn over the valley of the River Fleet. Elsewhere, many existing streets were widened and realigned. The first railway was built at Fenchurch Street in 1840-42, and many lines and stations followed until the construction of Liverpool Street Station in 1874. The first underground line from Paddington to Farringdon opened in 1863 and was extended to Moorgate in 1865. More “cut and cover” lines followed, while the first deep “tube” line opened in 1890.

These transport improvements led to a growth in commuting to the City to work, and the City became an increasingly specialised commercial enclave. The residential population fell from 128,000 in 1801 to 30,000 in 1891, while most of the City was redeveloped for commercial buildings, mainly offices and banks. There was also a significant amount of warehousing and some industry, although the Port of London had expanded to the docklands in the east. There was a high rate of redevelopment driven by the City’s primacy as a world centre of commerce. The wealth of the City’s institutions was expressed through the style and materials of the buildings commissioned. The scale and height of buildings generally increased throughout the period, a trend encouraged by the increasing use of lifts, although the building acts continued to ensure height controls. Secular buildings included elements that were designed to rise above the roof-line, creating new features on the skyline, such as the towers of Cannon Street Station and the dome of the Central Criminal Courts, the Old Bailey.

This general pattern of activity and development continued into the twentieth century, and the density of development and size of buildings continued to increase. By the 1930s the City’s working population had grown to almost 500,000, but the resident population had fallen to only a few thousand.

The City was heavily bombed in the Second World War, with one third of its area destroyed. After the war reforms were introduced that would radically influence the reconstruction, including the Town and Country Planning Act in 1948 and revisions to the building acts that promoted greater flexibility in design and removed limits on the height of buildings.

The built form of the City was perceived as suffering from high density, lack of space, congestion and poor daylighting, and rebuilding and replanning was thought necessary. Although reconstruction was initially delayed by shortages of building materials, many war- damaged locations were declared comprehensive development areas, and compulsory purchase powers were used to assemble sites for redevelopment. The district including the Golden Lane and Barbican Estates and London Wall was one of the largest and most radical areas of comprehensive replanning, while others can be seen between Fetter Lane and Farringdon Street, around St Paul’s Cathedral, along the riverside and east of Minories.

Motor traffic was to be accommodated by road building. Options were put forward for the provision of new routes to accommodate through traffic: these were the “northern route” from Holborn to Aldgate, including a new dual-carriageway road at London Wall; the “southern route”, achieved by widening Lower and Upper Thames Street and constructing Blackfriars underpass to link it to the Victoria Embankment; and road widening from Bishopsgate to London Bridge, including the rebuilding of the bridge. Elsewhere, there was further extensive road widening, achieved by the setting back of building frontages on redevelopment. Pedestrians were segregated from vehicles by the creation of a network of upper-level

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walkways. It was envisaged that this would be made possible through the redevelopment of almost all buildings in the City.

New buildings were designed to avoid the perceived problems of the pre-war City. Larger sites enabled buildings to be designed with regular floor plans, maximising daylight both within the building and to its surroundings, and often incorporating open space. During the 1950s Bucklersbury House (Queen Victoria Street), Fountain House (Fenchurch Street) and the towers lining London Wall became the City’s first tall buildings. They were followed by many more during the 1960s and 70s, culminating in the completion of the NatWest Tower (now Tower 42) in 1981.

Offices became more specialised, concentrating on higher-level and headquarters functions, while clerical work was increasingly decentralised, with the result that, while the City’s economy continued to thrive, the numbers working in the City never regained the levels seen in the 1930s. In many cases the total amount of floorspace was not substantially increased on redevelopment, so the overall density of development in the City did not rise markedly. The decline in the City’s residential population was reversed by the construction of the Golden Lane and Barbican estates, and the Middlesex Street housing estate was rebuilt. All these residential schemes incorporated tall buildings.

During the 1960s this radical approach to planning began to be questioned. In the 1970s the policy of accommodating road traffic was replaced by one of traffic restraint. The City’s first conservation areas were designated in 1971 and an increasing number of buildings were protected by listing for their special architectural and historic interest. While the creation of an upper-level walkway network was achieved in the Barbican and London Wall area, elsewhere only disconnected sections were realised, and the concept was abandoned in the 1970s.

In 1986 the deregulation of the financial markets stimulated new forms of working and trading which required large trading floors with greater floor-to-ceiling heights to accommodate office technology. These changed needs made many buildings of the 1960s and 70s redundant, leading to their redevelopment. The abolition of plot ratio controls in 1994 removed a quantitative limit on density of development, leading to greater variations in the amount of floorspace on individual sites. These trends in development have continued to the present.

The evolution of the City has resulted in a townscape whose dominant characteristic is its great diversity. There is great variety in building type, age, materials, scale, bulk, height and architectural style which often results in the juxtaposition of widely differing buildings. The rich variety of built form means that urban character can contrast greatly within very local areas.

The City’s antiquity also results in a very fragmented and complex pattern of land ownership. Many street blocks are in a large number of separate ownerships. These interests can often be difficult to establish as records go back many centuries. Within individual buildings there are also often many different leasehold and tenancy interests.

The street pattern and land ownership pattern in the City result in site assembly often being extremely complex. A developer wishing to acquire a site with the potential to accommodate a large development, such as a tall building, must often investigate and acquire a very considerable number of interests in the land. This can be a time-consuming process, sometimes taking years, but is of critical importance to realising development potential.

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The pattern of streets and spaces is important to the character and functioning of the City. The street pattern is of historic value and is an essential component of the City’s townscape. The dense network of streets and alleys provides convenient walking routes and a high degree of pedestrian permeability, which is of particular importance as most movement in the City is on foot. In the densely developed City the numerous churchyards, open spaces and gardens provide a valuable resource.

4.2 General urban design considerations for tall buildings

One of the characteristics of areas of the City which distinguishes them from many other parts of central London is the dynamic relationship between buildings of different design, age and scale. Whilst such relationships may appear incongruous and harmful in some locations, in others it may create contrast in scale that is characteristic and dynamic.

Tall buildings can have a profound impact on urban character by introducing a stridently larger scale of development in parts of the City which are defined by a dense urban grain and narrow plot widths. Within this context the podiums of tall buildings (especially the earlier generation of 1950s and 60s podium blocks) can appear incongruous. However, in other locations, the larger scale and urban grain of some areas means that tall buildings may be acceptable within such settings.

Tall buildings in the City have an impact on the public realm. Such buildings can limit sunlight and result in unwelcome wind effects which significantly diminish the quality of the public realm. An older generation of tall buildings of the 1950s to 1970s paid little attention to the desirability of providing permeable routes for pedestrians through the site or retaining historic lanes and alleys. However, recently permitted and constructed schemes such as the Pinnacle, 100 Bishopsgate, 125 Old Broad Street and 51 Lime Street have sought to retain and integrate pedestrian routes through the sites which reflect the distinctive pattern of alleyways that characterise the City.

The relationship of tall buildings to one another on the skyline, and to existing clusters as well as the townscape impacts of isolated tall structures are important considerations. Tall buildings may contribute to the uniqueness and distinctiveness of the City. However, the height and urban form of tall buildings can result in inappropriately designed and sized spaces around them which are uncharacteristic for the area, and can create a canyon effect if located opposite each other in streets.

The design and materials used should reflect the activities within the building and the orientation of the facades, and should be innovative, high quality and contemporary. The profile and upper areas of tall buildings are important design considerations and the building should be well designed in its own right. There is an opportunity to incorporate innovative façade designs and environmental solutions at higher levels which may be inappropriate at lower levels where seen in a street context.

4.3 The Distribution of Tall Buildings

The location of existing and proposed tall buildings in the City is shown in Figure 3. Appendix A details all tall buildings over 75 metres in height above Ordnance Datum in the City. There are 8 buildings over 150m AOD of which 3 exist. There are 14 buildings over 100m AOD. Therefore there are 18 buildings in total over 100m AOD.

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Planning and other considerations have led to tall buildings being mainly located in the north and east of the City. Across much of this area tall buildings have a relatively scattered distribution and do not form groupings that have a strong visual coherence, but in an area around Bishopsgate and St Mary Axe in the east of the City the closer proximity and generally greater height of tall buildings creates a visually distinctive cluster.

The eastern cluster is an area that has long been characterised by the highest building densities in the City. This was recognised by the early town planning schemes of the 1930s, which allowed greater building height here, and the plot ratio zones introduced in the 1950s, which designated this area for the highest plot ratios in London. As tall buildings were constructed from the 1950s onwards their locations were relatively scattered and a cluster was not initially apparent. In the 1973 edition of the Buildings of England Sir Nikolaus Pevsner opined “I had written in 1962 that the next few years were to change drastically the skyline of London. They have done it, and it is wholly to the detriment of London. Go to Waterloo Bridge or stand in Fleet Street, and look towards St Paul’s. The dome now has to compete with more upstarts than one can count or easily recognise. These skyscrapers are not as high as those of America and they rarely come in clusters. So the result is not dramatic; it does not remind one of New York or Chicago, but of some medium-sized city of the Middle West. That, in my opinion, is the greatest and saddest change.” However, a recognisable cluster later began to emerge as a distinctive feature of the City’s skyline. In the 1997 edition of the Buildings of England Simon Bradley, while still regretting “the loss of coherence caused by the failure to group tall buildings properly” in some areas, felt able to write “From the old financial heart, east of the Bank, they surge up in a mass that communicates a sense of excitement worthy of the area.”

The greater coherence of the cluster was in part due to the construction of Tower 42 (formerly the Nat West Tower), completed in 1981, which was significantly taller than other buildings in the area and gave the cluster a distinct visual focus. The more recent construction of 30 St Mary Axe and the Heron Tower at a similar height to Tower 42 has compromised the focal effect of the latter. However, the Pinnacle development in Bishopsgate, currently under construction, will be substantially taller than other buildings in the cluster and will again provide it with a visual focus. The buildings of the cluster are relatively closely spaced and in many views the lower members of the cluster appear round its periphery and the taller buildings to the centre, so that the buildings step up towards the centre, which makes the cluster a distinct and striking feature of the City’s skyline.

Which buildings constitute the eastern cluster depends in part on the location of view points. For instance, Angel Court and 125 Old Broad Street (the former Stock Exchange) are visually part of the cluster in some important views from the west, although they are some way removed from it in other views. The potential for constructing new tall buildings to add to the cluster in future also has to be taken into account. For example, conservation areas lie to the west of the cluster, and so it is unlikely that further tall buildings would be considered acceptable there.

Elsewhere in the City there are isolated tall buildings and loose groupings have been built on sites considered appropriate with regard to their local surroundings and their setting on the wider skyline. Most are located in the north and east of the City, although New Street Square is a notable recent addition to the skyline in the west.

The City’s tall buildings need to be considered in relation to tall developments nearby in neighbouring boroughs. The grouping of tall buildings around London Bridge Station in Southwark is currently being reinforced by the Shard, which will be taller than any other building in London. The City’s tall buildings have a visual relationship to those at London

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Bridge when seen on either side of the Thames in views along the River. There are also some tall buildings to the north and east of the City in Islington, Hackney and Tower Hamlets, and more may be constructed. These buildings loosely relate to City tall buildings, but do not generally form any distinctive grouping.

4.4 Approved tall building proposals

Approved tall building proposals (above 75m AOD) in the City of London are shown below.

Address Height (m Status Floors Main Use Permitted Architect AOD) The Pinnacle, 22-38 Under Bishopsgate 304.25 Construction 62 Office 30/11/2007 KPF Heron Tower, 110 Under Bishopsgate 257.60 Construction 46 Office 22/07/2002 KPF 122 Leadenhall Street Richard Rogers 239.40 Site cleared 52 Office 29/04/2005 Partnership GPE Tower, 100 Bishopsgate / Permitted Camomile Street not Allies & Corner 180.68 commenced 40 Office 28/05/2008 Morrison 20 Fenchurch Street Rafael 177.00 Site cleared 36 Office 2007 Vinoly The Heron, Milton Court David 127.00 Site cleared 36 Residential 31/01/2008 Walker Land Bounded By Cannon Street, Queen Foster & Street, Queen Victoria Permitted Partners Street, Bucklersbury & not and Jean Walbrook 120.00 commenced 21 Office 20/12/2007 Nouvel 60 - 70 St Mary Axe Permitted not Office with 105.00 commenced 22 retail 09/12/2008 Foggo International House, 1 Permitted Mitre Square not Sheppard 80.00 commenced 20 Office 2005 Robson

For further information on tall buildings in the City, please refer to Appendix A.

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Figure 3. Tall Building distribution in the City.

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4.5 Skyline and Topography of the City

The topography of the City and its surroundings is a major determinant of the visibility of its skyline. The City’s skyline is made up of a number of elements, comprising buildings that rise above the general roofline. From some viewpoints the entire City skyline can be seen, but from most places only certain elements are visible.

The skyline of the City can be seen from locations both near the Square Mile’s boundaries and from more distant vantage points around London. Tall buildings are prominent in views of the City and their effect on the skyline is an important consideration that needs to be taken into account in the Core Strategy’s policies. The main elements within the skyline can be described as:

• The Eastern Cluster of tall buildings. These are all office buildings and form a distinct grouping. • Isolated tall buildings and loose groupings elsewhere in the City, mainly in the north and east. • St Paul’s Cathedral. Policies to protect views of the Cathedral have ensured that it has remained a dominant element in the skyline of the western part of the City. • Historic skyline landmarks, such as church towers and spires, the Monument and other secular buildings. They are mostly of lower height than the preceding elements.

The physical relief of London is a series of terraces stepping up from the River Thames. The City is situated on high ground above the River Thames. Most of the City is 15 to 17 metres above Ordnance Datum, other than beside the Thames and in the valley of the former River Fleet. The visibility of the City’s skyline and the elements within it depends on the height of the vantage points relative to the City. Views can be seen from the following categories of vantage points, which as described in detail below:

• The Thames and riverside • Environs of the City • More distant hills and ridges

4.5.1 The Thames and Riverside

The ground in the City rises up relatively steeply from the river and the skyline is prominent in views from the riverside walk along south bank and Thames bridges stretching from Rotherhithe in the east to Hungerford Bridge in the west. The riverside walk is nearly continuous and each stretch of the south bank shows different aspects of the City skyline. The following is a description of the views from each stretch of the south bank, moving from east to west. Figure 4 shows the location of the viewing areas described.

Rotherhithe to Shad Thames The most easterly point on the south bank from which the City’s skyline forms an eye-catching element in views is King’s Stairs Gardens in Rotherhithe. The City’s eastern cluster of tall buildings forms a striking feature of the skyline. From the eastern part of this stretch of riverside walk the cluster is seen behind the river-front buildings on the north bank of the river in Wapping, but further west towards Bermondsey the cluster is seen with the Thames and Tower Bridge in the foreground. The angle of view ensures that the tall buildings of the eastern cluster appear significantly higher than the general roof-line and so form a distinctive and highly noticeable skyline feature. Tall buildings in the north of the City, however, are not visible. From westerly parts of this stretch, the City’s riverside can be seen. The dome of St Paul’s can be seen against clear sky, and the Monument and the towers of

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Cannon Street Station are noticeable. Tower Bridge forms a notable foreground feature of all the views, and from some points frames views of the skyline.

Tower Bridge The bridge affords striking views of the eastern cluster with the Tower of London in the foreground. Tall buildings appear behind the White Tower, so that it is not seen in front of clear sky. This viewpoint is close enough to the City for the tall buildings to form a dominant and imposing element of the view.

Tower Bridge to London Bridge The view from the eastern part of the riverside walk near City Hall is similar to that from Tower Bridge, with the eastern cluster prominent on the skyline and the Tower of London in the foreground. Further west the angle of view is such that the City’s river-front buildings obscure many of the tall buildings, with only the upper parts of the tallest buildings in the eastern cluster are visible. However, tall buildings that are under construction and proposed will make the eastern cluster more visible in future.

London Bridge to Southwark Bridge From these bridges and the riverside walk St Paul’s Cathedral is a prominent feature and is seen against clear sky. Looking east from London Bridge good views of the Tower of London are seen, although buildings at St Katherine’s Dock appear on the skyline behind it. As in the views from the preceding stretch, only the upper parts of the tallest buildings in the eastern cluster are visible, so are of limited impact.

Southwark Bridge to Blackfriars Bridge At the eastern parts of this stretch the eastern cluster is still partly hidden by river-front buildings, but moving further west the shallower angle of view and the lower height of buildings on the north bank means that the eastern cluster becomes prominent again. This stretch gives wide views, and almost all the City’s tall buildings can be seen, including those in the north and west. St Paul’s is highly visible. From Southwark Bridge and adjoining parts of the riverside walk the dome and western towers are seen against clear sky, but further west the tall buildings of the Barbican and London Wall appear behind the Cathedral, compromising its dominance of the skyline. The lower general height of building in the west of the City allows church steeples and other historic skyline features to be seen rising above the roof line.

Blackfriars Bridge to Waterloo Bridge This stretch affords impressive views of the whole of the City skyline, with nearly all tall buildings and many historic skyline landmarks visible. The greater distance of these viewpoints means that there is a shallow angle of view, so that tall buildings and landmarks are not hidden by river-front buildings and are seen to rise well above the general roof line. The eastern cluster forms a prominent feature. With the completion of the Pinnacle development in Bishopsgate and 122 Lime Street, the cluster will be given a clear focus to which other buildings will appear to step up. St Paul’s is a striking element in the views, although its skyline setting is compromised by tall buildings in the north of the City which appear behind it. However, the eastern cluster appears well to the right of the Cathedral.

Waterloo Bridge The bridge affords some of the best views of the City skyline in central London. The views are similar to those from the south bank, but are better seen due to the higher vantage point. The eastern cluster forms a distinctive element in the views, and it will become more coherent and focused when the Pinnacle is completed to provide an apex to the cluster. St Paul’s is prominent in the views and appears separate from the eastern cluster, although from the southern section of the bridge the Broadgate Tower appears behind the dome.

Hungerford Bridge The City skyline is seen over Waterloo Bridge and so the views seen are very similar. However, as Hungerford Bridge is further away, the viewing angle is shallower

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and so the tall buildings are more prominent and less of the Cathedral is obscured by Unilever House.

Because the City skyline is seen as a whole from the riverside, its overall composition from these viewpoints is important. Visual effects deserving careful consideration include: the benefits of achieving a distinctive cluster of tall buildings in the east; the impact of isolated tall buildings not related to any cluster; the relationship of modern tall buildings to the views and settings of historic skyline landmarks.

4.5.2 Environs of the City

Because the land surface in the boroughs surrounding the City is at a similar elevation to the Square Mile, there are relatively few views of the City’s skyline from these areas. Such views as there are mainly take the form of glimpses: individual tall buildings or small numbers of buildings are seen, but not the whole skyline. Some of the most noteworthy of these local views are from the east, such as from Whitechapel, where views of the eastern cluster can be seen. However, from the south, west and north views are limited.

Because most of these views are of only a few elements of the City’s skyline, they are of lesser importance than the riverside views. In most cases, it is unlikely that proposals for new tall buildings would raise issues relating to the composition of the skyline. The views from Whitechapel and other locations to the east allow an appreciation of the eastern cluster, and so the composition of these views is of some significance.

4.5.3 More distant hills and ridges

In outer London there are high ridges that afford impressive views of the central London skyline. These include Hampstead Heath, Highgate, Archway, Alexandra Palace and Primrose Hill in north London, Greenwich and Blackheath to the east, Sydenham and Crystal Palace to the south, and Richmond Park to the west. Within these views, the City’s tall buildings form just one element among large numbers of tall structures in central and inner London. Because the viewpoints are at high elevations, the views are mostly downwards, so that the City’s tall buildings are mainly seen against a background of buildings, hills and other features, rather than against the sky.

Specific views of St Paul’s from defined viewpoints at Primrose Hill, Parliament Hill, Kenwood, Alexandra Palace, Greenwich Park, Blackheath Point and Richmond Park (King Henry’s Mound) are protected by the LVMF.

As most or all of the City’s tall buildings can be seen from these viewpoints, the overall skyline can be appreciated. The eastern cluster appears as a relatively coherent element in these distant views, and so the relation of proposed tall buildings to the cluster may be a significant consideration.

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Figure 4. Viewing Locations in the City.

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5. Heritage Assets

The City is the original core from which London developed and consequently is of great historic interest. It has many historic buildings and areas, and considerable archaeological value. Its heritage assets are protected by a variety of policies and controls. These influence the potential location of tall buildings and so need to be examined.

PPS 5 sets out planning policies on the conservation of the historic environment. Those parts of the historic environment which have significance because of their archaeological, architectural or historic interest are called heritage assets. Designated heritage assets include World Heritage Sites, Scheduled Ancient Monuments, Listed Buildings, Registered Parks and Gardens, and Conservation Areas.

PPS 5 advises that local planning authorities should seek to identify and assess the particular significance of any element of the historic environment that may be affected by a development proposal, including the setting of a heritage asset (Policy HE 7.1). It states that significance can be harmed or lost through alteration or destruction of the heritage asset or development within its setting (Policy HE 9.1).

The heritage assets in the City, that is, conservation areas, listed buildings, ancient monuments and archaeology and historic parks and gardens, are described below.

5.1 Conservation Areas

The City of London Corporation, under the Planning (Listed Buildings and Conservation Areas) Act 1990, has a duty consider whether it should designate conservation areas, which are defined as “areas of special architectural or historic interest, the character of which it is designed to preserve or enhance”. The City also has a duty to review the boundaries of its conservation areas from time to time.

There are 26 conservation areas in the City, which vary considerably in size, scale and character and which currently cover approximately one-third of the City’s total area. These are detailed in Figure 6. The City of London designated its first conservation areas in 1971 and has carried out three comprehensive assessments of these designations in 1981, 1991 and 2007.

Conservation areas are designated to protect the special character of entire areas rather than individual buildings, and therefore not all buildings within their boundaries will necessarily contribute to their significance or conform to their predominant character.

With reference to new development in conservation areas, including tall buildings, PPS5 states: “Local Planning Authorities should take into account the desirability of new development making a positive contribution to the character and local distinctiveness of the historic environment. The consideration of design should include scale, height, massing, alignment, materials and use.” (policy HE7.5). This also relates to PPS1: Delivering Sustainable Development, paragraphs 17-19, 33-39).

According to the principles set out in PPS5 the erection of a tall building within a conservation area could be considered as substantial harm to a Designated Heritage Asset. The PPS states that “there should be a presumption in favour of the conservation of designated heritage assets” (HE9.1), and where substantial harm or loss of significance is proposed to a heritage asset or its setting a number of tests need to be applied (HE9.2).

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Figure 5. Heritage Assets in the City.

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Figure 6. Conservation Areas in the City.

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There are three tall buildings within the Bank conservation area. Two of these were in existence when the conservation area was designated and the third was permitted after designation of the area.

125 Old Broad Street (formerly the London Stock Exchange) and Angel Court were completed in 1969 and 1979 respectively. The area in which they stand has a strong historic character and many listed buildings within a dense network of streets and alleys. In view of this, it was considered appropriate to designate the conservation area notwithstanding the existence of these two individual buildings.

New Court also stands in the Bank conservation area. It was granted planning permission in 2007 and is currently nearing completion. When permitted, it was felt to be an exceptional piece of architecture, but that it would be detrimental to the character of the conservation area and the setting of a number of listed buildings. The building was designed to accommodate all Rothschild’s staff in one building which was only achievable in a building significantly larger than other buildings in this part of the conservation area. The application was treated as a departure from the development plan and it is therefore not considered as a precedent for tall development in conservation areas.

5.1.1 Settings of Conservation Areas

PPS5 Policy HE10 relates to development which would affect the setting of a designated heritage asset, and advises that when considering applications the local authority should consider how proposals would affect the significance of the asset. The policy further advises that applications for development which would make a positive contribution to the significance of a heritage asset should be treated favourably, whereas those which would have a negative impact should be weighed proportionately against the public benefit they would bring (HE10.1).

A proposal for a tall building affecting the setting of conservation area would have to be carefully considered on its own merits against this and other relevant national, regional and local policies.

PPS5 also recommends that local planning authorities should identify opportunities for changes in the setting to enhance or better reveal the setting of a heritage asset. (HE10.2). It is intended that potential enhancement opportunities will be identified in forthcoming Conservation Area Character Summaries, and these may make reference to tall buildings in or adjacent to conservation areas.

Guidance in the PPS5 Practice Guide (EH, DCMS, DCLG), which is a material consideration, states: “The contribution of setting to the historic significance of an asset can be sustained or enhanced if new buildings are carefully designed to respect their setting by virtue of their scale, proportion, height, massing, alignment and use of materials.” (paragraph 121).

Development which has a negative impact on the setting of a conservation area could be considered to inflict substantial harm to a designated heritage asset (see PPS1 HE9.2).

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5.1.2 Conservation Area Character Summaries and Management Strategies

The City of London has an ongoing programme for the preparation and review of Conservation Area Character Summaries and Management Strategies.

Section 71 of the Planning (Listed Buildings and Conservation Areas) Act 1990 requires the local planning authority to "formulate and publish proposals for the preservation and enhancement of any parts of their area which are Conservation Areas." They are intended as a development management tool, and to provide a sound basis for each area’s designation. Forthcoming Character Summaries will also form part of the evidence base for the LDF.

Conservation Area Character Summaries seek to identify the special character of a conservation area from a range of factors, including historical development, spatial analysis, and architectural character. Management Strategies summarise local policies and strategies relevant to the preservation and enhancement of the City’s conservation areas.

The local criteria for conservation area character are set out in the document Conservation Areas in the City of London: A General Introduction to Their Character, produced by the City of London in 1994.

Character Summaries have been prepared for 18 of the City’s 26 conservation areas. In addition to Character Summaries, Conservation Area Management Strategies set out the position regarding the wider policies concerning the conservation and enhancement of the City. They refer to projects which have been recently undertaken and those proposed in the near future.

5.1.3 Conservation Areas: Conclusions

Designation of a conservation area carries a statutory duty to preserve or enhance its special character and interest. The City’s conservation areas have strong and distinctive characters. Tall buildings are not considered to be compatible with this character. There are, however, three tall buildings within conservation areas, one of which was permitted after designation of the area. The policy for tall buildings in the City of London UDP 2002 states that tall buildings are not considered appropriate in conservation areas, and this policy has been in force since the Local Plan 1989. The tall building permitted since designation was treated as a departure from the development plan, and are therefore not considered a precedent.

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5.2 Listed Buildings

There are approximately 590 buildings in the City which are listed for their special architectural and historic interest. A wide variety of buildings and structures are listed, ranging in scale from statues and telephone kiosks to St Paul’s Cathedral and the Barbican Estate. The City is notable for containing many well known buildings of the highest historic and architectural significance.

The City’s listed buildings show great variety of age, type, use, scale and style. Some listed buildings are unique because of their location, style and perhaps the purpose for which they were built. Many listed buildings are referred to on the statutory list as having group value. When considering the setting of listed buildings, and the potential impact of development, each development proposal must be considered on its own merits. A proposal’s main requirement is to have regard to the development plan, with careful reference to the designated asset that will be affected by the proposal(s).

A class of listed building that is a particular consideration in relation to tall building proposals are those that are themselves tall and whose design incorporates features intended to be seen on the skyline. These are considered in more detail in paragraph 5.3.

5.3 Historic City Landmarks

The Unitary Development Plan (Appendix 5) identifies a number of historic landmarks within and around the City which are features in the City’s skyline. Policy ENV 2 of the UDP states that the effect of development proposals on the setting of these landmarks will be assessed.

The following are the historic landmarks and prominent skyline features identified in Appendix 5 of the UDP. With the exception of HMS Belfast they are all listed. • Cannon Street Station (Towers) • Central Criminal Court (Dome) • Spire of Christchurch, Spitalfields • City Temple (Tower) • Guildhall (Roof and flêche) • HMS Belfast • Former Port of London Authority Building (Tower) • Royal Exchange (Tower) • Southwark Cathedral (Northern transept and tower) • Tower Bridge • The towers and spires of: o All Hallows Barking; o St Augustine, Watling Street; o St Benet’s Welsh; St Bride, Fleet Street; o St Dunstan-in-the-east; o St Dunstan-in-the-west; o St James, Garlickhythe; o St Magnus, London Bridge; o St Margaret, Lothbury; o St Margaret Pattens; o St Martin, Ludgate; o St Mary Aldermary; o St Mary-le-Bow;

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o St Mary Somerset; o St Michael, Cornhill; o St Michael Paternoster Royal; o St Nicholas Cole Abbey; o St Sepulchre; o St Vedast, Foster Lane.

The UDP notes that, in addition to skyline features set out above, local townscape considerations will also be relevant in accordance with the policies of the Plan in relation to St Paul’s Cathedral, the Tower of London and Monument views.

The UDP states that, in the course of time, views of other significant historic landmarks may be revealed or identified; therefore the list is not exhaustive. Since the adoption of the UDP a number of post-war tall buildings have been included in the listing of the Golden Lane and Barbican Estates: • Great Arthur House • Cromwell Tower • Shakespeare Tower • Lauderdale Tower • Barbican YMCA

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Figure 7. Historic City Landmarks.

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5.4 Archaeology and Scheduled Ancient Monuments

There are 48 designated assets in the City which are scheduled ancient monuments and they include stretches of the Roman and medieval City wall and Roman fort, buried remains such as the Roman governor’s palace, the Roman amphitheatre, and livery company halls. The setting of these will be important in considering tall building proposals. See Figure 8.

The almost continuous occupation of the City (as mentioned in section 4.1.1) has led to the build up and development of a very complex survival of archaeological remains, which in some cases are of regional and national importance. There are many heritage assets with archaeological interest which are not designated but which are demonstrably of equal significance.

Development proposals, particularly for tall buildings, may involve excavation, for example for basements and foundations’ that affect scheduled ancient monuments and other archaeological remains. These are assessed on a site by site basis.

5.5 Historic Parks and Gardens

There are four gardens in the City which are on the Register of Historic Parks and Gardens. These are Finsbury Circus, Inner Temple Gardens, Middle Temple Garden and the Barbican. See Figure 9. The impact of tall buildings on the setting of these historic gardens will be an important consideration.

The Inner and Middle Temples are designated a conservation area. They are adjoined by other conservation areas in both the City of London and the City of Westminster. In addition, they are in an area where the height of development is largely restricted by protected views.

Finsbury Circus garden is located in a conservation area, which is adjoined by other conservation areas. The Drapers’ Gardens tall building was formerly prominent in views out of the garden to the south, but this has now been demolished.

The Barbican landscaping is an integral part of the master plan for the area and is important in the relationship of towers, lower buildings and spaces, and are now part of the listed fabric the estate.

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Figure 8. Scheduled Ancient Monuments in the City.

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Figure 9. Historic Parks and Gardens in the City.

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6. Protected Views and Settings

There are a number of policies for the protection and management of views that affect the City and these are a significant consideration in the location of tall buildings. These policies relate to the views and settings of St Paul’s Cathedral, the Monument and the Tower of London, and views of the townscape and skyline seen from the Thames bridges, riverside and other locations. They are set out in various policy documents, including the Mayor’s London View Management Framework, the City’s Unitary Development Plan and accompanying supplementary planning guidance. The Tower of London, located outside but adjoining the City’s boundary, is a World Heritage Site subject to international as well as national, regional and local protection. These policies must be examined in detail so that their relevance to the Core Strategy policies for tall buildings can be assessed.

6.1 Views and Setting of the World Heritage Site

The Tower of London was inscribed by UNESCO as a World Heritage Site in 1988 for its “outstanding universal value”. The City Corporation must take the setting of the Tower of London into account when considering development proposals, as the City forms the backdrop to many views to the Tower from the south, from the river and from the east.

The Tower of London World Heritage Site Management Plan (2007) was prepared by Historic Royal Palaces to ensure the effective management of the World Heritage Site for present and future generations. It provides an agreed framework for long-term decision- making on the conservation and improvement of the Tower, protecting and enhancing the visual and environmental character of its local setting, providing consideration of its wider setting and improving the understanding and enjoyment of the Tower as a cultural resource.

Tall buildings in the City need to respect the setting of the World Heritage Site. The setting of the Tower includes its relationship to historic features visible in the urban landscape, and its evolving visual relationships to that landscape, insofar as they contribute to perceptions of its significance, and particularly, its outstanding universal value. The importance of setting is enhanced by public accessibility and visibility.

There are three types of “setting” relevant to the Tower (as defined in the Tower of London World Heritage Site Management Plan):

• Local Setting • Immediate Setting • Wider Setting

The local setting comprises the spaces from which the Tower can be seen from street and river level, and the buildings that provide definition to those spaces. This forms an “arena” (see Figure 10). The boundary is heavily influenced by views from across the Thames and its bridges. The immediate setting relates to the part of the local setting on the north bank of the Thames, as defined in the London View Management Framework. The wider setting includes buildings and areas beyond the local setting that are inter-visible with the Tower.

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Figure 10. Tower of London Local Setting Area.

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Further information can be found in the Tower of London World Heritage Site Management Plan (2007), the Tower of London Local Setting Study (2010) and the Mayor’s London View Management Framework SPG.

The view from Assessment Point 25A.1 of the LVMF aims to evaluate the impact of new development on the Tower of London. Specific guidance has been included in the LVMF regarding World Heritage Sites. Proposals must be assessed for any potential adverse effect on the ability of the viewer to recognise and appreciate the site. Development proposals that exceed the threshold plane of the Background Assessment Area (which begins at the White Tower at 25.7m AOD and rises in a constant plane to 164.2m AOD) are subject to consultation. Where such consultation is undertaken, applicants are required to prepare Accurate Visual Representations (AVRs) to allow the degree of impact to be assessed.

6.2 London View Management Framework

6.2.1 Policy Development

Protection of long-distance views of key London landmarks was first included in the Greater London Development Plan, approved in 1976. Several of these views were of St Paul’s Cathedral and the views were incorporated into the City of London Local Plan, adopted in 1989. After the abolition of the Greater London Council in 1986 the Secretary of State asked the London boroughs to recommend long-distance views that should be included in strategic planning guidance.

In 1991, Regional Planning Guidance 3a identified strategic views of St. Paul’s Cathedral and the Palace of Westminster from viewpoints across London. There were eight protected strategic views designated of St. Paul’s Cathedral from viewpoints at Alexandra Palace, Parliament Hill, Primrose Hill, Kenwood, Blackheath Point, Greenwich Park, Westminster Pier and King Henry’s Mound, Richmond. Further background detail is explained in paragraphs 2.2.1 and 3.1.8. The views were included in the policies of the City of London’s Unitary Development Plans, adopted in 1994 and 2002.

The views were made up of a number of elements. The main view corridor sought to protect the view of the Cathedral and height limits within it were firmly applied. There was also a defined wider setting and background area, within which a more flexible approach could be taken, while ensuring that regard was given to the setting of the Cathedral.

The most significant infringement of the strategic views in the City was the former headquarters of the Mirror Group Newspapers at Holborn Circus, a tall building completed in 1960. This adversely affected the view from Primrose Hill. The building was demolished in 1998 and replaced by a building of lower height, restoring the view.

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Figure 11. Components of a Protected Vista.

Source: Mayor of London. London View Management Framework (2010)

With the establishment of the GLA in 2001, the government’s strategic views protection was devolved to the Mayor of London. When the first London Plan was adopted in 2004, policy 4B.15 referred to a new London View Protection Framework. The “London View Management Framework” SPG was adopted in 2007 and revised in July 2010. The main changes to earlier policies included:

• An increase in the number of “strategically important views”, each with their own management plan. • An additional protected view from Queen’s Walk, City Hall to the Tower of London. Now 9 views are relevant to the City. • Change in terminology from “strategic views” to “protected vistas”. • Previous strategic viewing corridors were narrowed in width by about a half. • Other views introduced are reliant on “Qualitative Visual Assessment” – these include River Prospects (views of the Thames, associated landmarks and skyline) which are all measured by Qualitative Visual Assessment (QVA).

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The views are managed in accordance with a set of principles. There are three categories of “Protected Vistas”: • London Panoramas – views affecting the City are those of St. Paul’s Cathedral from Alexandra Palace, Parliament Hill, Kenwood, Primrose Hill, Greenwich Park and Blackheath Point. • Townscape Views – including views of the Tower of London (White Tower) from the Queen’s Walk at City Hall. • Linear Views – including views of St. Paul’s Cathedral from Westminster Pier and King Henry’s Mound, Richmond.

The other type of view is a series of “River Prospects”. These are views from Thames bridges and the riverside walk, detailed in section 6.2.2.

Management plans for different types of view are to be based on the following principles: • River prospects. The management of these prospects should ensure that the juxtaposition between elements, including the river frontages and major landmarks, can be appreciated within their wider London context. • Townscape and linear views. These views should be managed so that the ability to see specific buildings, or groups of buildings, in conjunction with the surrounding environment, including distant buildings within views, is preserved or enhanced. • London Panoramas. Within these views, proposed development in the foreground, middle ground or background of a London Panorama should provide an appropriate setting for Strategically Important Landmarks by not crowding in too close to them and by not contributing to a canyon effect either side of the Protected Vista.

Further information can be found in the Mayor’s London View Management Framework SPG.

The key changes in the widths of the strategic views and protected vistas are shown in Figures 12–15. Where protection under RPG3a in 1991 comprised a much wider “strategic view”, these were significantly narrowed in 2007. The “protected vistas” in the 2010 London View Management Framework SPG are a compromise between the 1991 strategic views and the much narrower protection in the 2007 LVMF SPG. A tabular summary of the changes of the widths of the protected vistas is provided in Appendix D.

Within the “landmark viewing corridor” building heights are relatively strictly applied to maintain the view of the Cathedral. In the lateral and background assessment areas a more flexible approach can be taken, consistent with maintaining the quality of the view.

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Figure 12. Strategic Views 1991 – coverage in the City of London.

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Figure 13. London View Management Framework Protected Vistas (2007).

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Figure 14. London View Management Framework Protected Vistas (2010).

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Figure 15. Comparison of changes from Strategic Views to Protected Vistas 1991 – 2010.

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6.2.2 River Prospects and St. James’ Park View

Within the LVMF a number of designated River Prospects (views from the River Thames) have an impact on tall building proposals in the City of London. They are not subject to the definition of geometric criteria.

The management of River Prospects should ensure that the juxtaposition between elements, including the river frontage and landmarks, is appreciated within a wider London context. Development must ensure that key features of the view can continue to be enjoyed in the context of their surrounding environment, including distant buildings.

Development in the foreground and middle ground of the River Prospects should enhance the juxtaposition of townscape elements with the riverbanks and the depth and variety of the surrounding London townscape. Interventions into the built fabric should preserve or, where possible, enhance this relationship. Development in the foreground or middle ground that is overly intrusive, unsightly or prominent to the detriment of the view as a whole should normally be refused.

New development in the background of a River Prospect should, where relevant, preserve or enhance a viewer’s ability to appreciate the outstanding universal value of a World Heritage Site and should be consistent with the objectives of the World Heritage Site Management Plans.

The LVMF river prospects relevant to the consideration of tall buildings in a City of London are listed and mapped in Figure 16.

10A.1 Tower Bridge looking towards the Tower of London 11A.1 London Bridge looking towards Tower of London 11B.1 London Bridge looking towards Tower Bridge 11B.2 London Bridge looking towards St Paul’s Cathedral 12A.1 Southwark Bridge looking towards St Paul’s Cathedral 12B.1 Southwark Bridge looking towards Southwark Cathedral 13A.1 Millennium Bridge looking towards St Paul’s Cathedral 13B.1 Millennium Bridge looking towards St Paul’s Cathedral 14A.1 Blackfriars Bridge looking towards St Paul’s Cathedral 14B.1 Blackfriars Bridge looking north towards Victoria Embankment 15B.1 Waterloo Bridge looking towards St Paul’s Cathedral 15B.2 Waterloo Bridge looking towards St Paul’s Cathedral 16B.1 South Bank looking towards St Paul’s Cathedral 16B.2 South Bank looking towards St Paul’s Cathedral 17B.1 Hungerford footbridges looking towards St Paul’s Cathedral 17B.2 Hungerford footbridges looking towards St Paul’s Cathedral 18B.1 Westminster Bridge, looking at the London Eye 19A.1 Lambeth Bridge looking north 19A.2 Lambeth Bridge looking north 25A.1 City Hall looking towards the Tower of London 25A.2 City Hall looking towards the Tower of London 25A.3 City Hall looking towards the Tower of London 26A.1 St James’s Park looking at Horse Guards (this is a townscape view of the City skyline)

Further information can be found in the Mayor’s London View Management Framework SPG.

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Figure 16. LVMF River Prospects and Townscape Views affecting City of London tall buildings.

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6.3 St Paul’s Cathedral: Local Views and Setting

St Paul’s Heights” have been operated since 1938 to protect local views of the Cathedral. The current policy for St Paul’s Heights is included in the City of London UDP 2002. The operation of the policy is explained in more detail in supplementary planning guidance “St Paul’s and Monument Views” 2002.

St Paul’s Heights take the form of a map overlain with squares, each showing a maximum building height. The squares are on a 50 feet grid and the building heights are given above Ordnance Datum (AOD). The height in each square is a spot height at the centre of the square, rather than a value applying to the whole square. Taken together, the heights describe a series of planes sloping up from view points to the Cathedral.

In the following paragraphs reference is made to the main elements of the Cathedral. The main body of the Cathedral comprises the nave and choir, and the outer walls of this are surmounted by an entablature and balustrade, the top of latter being at a height of 50m AOD. At the western end of the Cathedral are two towers. At the crossing of the Cathedral is a central dome made up of (from base to top) a lower drum, peristyle, upper drum, the dome itself, and a lantern, reaching a total height of 127.7m AOD.

The extent of the “Heights” is shown on the UDP Proposals Map. The views protected are those from the following locations (shown on Figure 17):

• The Thames bridges and south bank between London Bridge and Waterloo Bridge. (The views from Hungerford Bridge are also indirectly protected as they are on the same alignment as the Waterloo Bridge view) • Fleet Street • Watling Street • Cannon Street • King Edward Street/Little Britain • St Martin’s le Grand • Farringdon Road • Amwell Street/Myddleton Square • St John Street

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Most of the view planes protect a view of the Cathedral down to the level of the main entablature. The views from the north, however, protect sight-lines of the Cathedral at a somewhat higher level. The width of the view planes extends beyond the extremities of the Cathedral so that its setting on the skyline is also protected. The effect of the geometry of the planes is to protect views not only of the dome and the western towers, but also to allow an appreciation of the entire length of the Cathedral.

Several of the views are from points in the London Borough of Islington. The City and Islington co-operate in the protection of these views; their protection is incorporated in Islington’s UDP and is expected to be carried forward into its LDF.

The St Paul’s Heights impose a limit on development varying between approximately 20 and 52 metres AOD, while ground level slopes up from the river to a maximum of about 17m. The views are sensitive to any infringements and so the height limitations are strictly and precisely applied. Tall development is not permitted anywhere in the area covered by the Heights.

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Figure 17. St. Paul’s Heights Policy Area.

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6.3.1 Infringements of the heights

Several buildings have infringed the heights, rising significantly above the view planes. The policy towards infringing buildings has been to ensure that, when they are redeveloped, the replacement building complies with St Paul’s Heights and the views are restored. Several infringing buildings have been redeveloped, leading to a considerable improvement in the views.

The buildings constructed during the 1930s that prompted the formulation of the St Paul’s Heights were Unilever House, the Faraday Building and Vintry House. Since the introduction of the Heights two buildings were constructed which significantly infringed: Sudbury House in the City, and Cardinal House in Islington. These infringing buildings are shown in Figure 18 and described in more detail:

Buildings that currently infringe the views

• Unilever House. Constructed in 1930, this office building exceeds the Heights by approximately 17m. It intrudes on views from the southern half of Waterloo Bridge. Unilever House is listed Grade II and so is protected in its own right. In 2007 it was extensively refurbished. The rear was rebuilt to a lower height which improved the protected views. • Faraday Building. Built in 1930 as a telephone exchange, this building exceeds the Heights by 15m and obstructs views of the Cathedral from Blackfriars Bridge and nearby areas of the South Bank. The building was in two parts: the northern part has now been redeveloped in conformity with the Heights; planning permission for the redevelopment of the taller, southern part in conformity with the Heights was granted, but the scheme was not implemented and the planning permission has now lapsed.

Buildings that have been redeveloped in conformity with the policy

• Vintry House. Constructed in 1930, this office building exceeded the Heights by 30m and obstructed views of the Cathedral from the area of St Mary Overie’s Dock on the south bank. It was demolished in the 1980s and replaced by a new building that conforms to the Heights, restoring the views. • Sudbury House. Built in 1964 as part of the Paternoster Square development, this office block exceeded the Heights by over 30m. It was granted permission by the then Minister for Housing & Local Government following a public inquiry. The building blocked much of the Cathedral’s dome and peristyle in the view from Farringdon Road. Its close proximity to St Paul’s made it prominent in the Cathedral’s backdrop and skyline setting in many views from the Thames bridges and south bank. It was demolished and replaced by buildings that conform to the Heights, restoring the views. • Cardinal House. This office building in Islington was constructed in the 1960s. It intruded into the Farringdon Road view corridor. Cardinal House was demolished in 2010. No planning application has yet been submitted for a new building on the site, but any scheme will be expected to conform to the Heights.

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Figure 18. Buildings that infringe St. Paul’s Heights.

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There are a number of other buildings that infringe the Heights to a lesser degree; however, these are not considered here as they do not fall within the definition of tall building and the infringements are less significant in scale.

The policy for St Paul’s Heights states that buildings in the view “shadows” of infringements should not be allowed to exceed the Heights, on the grounds that the infringing buildings will eventually be replaced by structures that conform to the limitations when they are redeveloped. This has successfully ensured that the lost views have been restored.

6.3.2 Backdrop to the views

The St Paul’s Heights were originally devised during the 1930s to prevent buildings in the foreground of views obstructing sight of the Cathedral. At that time the Building Acts allowed structures up to 100 feet, and these would not have been tall enough to appear on the skyline behind the Cathedral. As the backdrop was not under threat, measures to secure its protection were not considered.

Until the early 1950s the Cathedral’s dominance of the overall City skyline remained uncompromised by buildings in its background. From the late 1950s onwards, however, buildings very much taller than the general roof line began to appear. Some of these figured directly behind the dome and western towers in certain views, so that the profile of the Cathedral was not seen against clear sky; from other vantage points tall buildings did not appear directly behind the Cathedral, but sufficiently close to it to affect its setting on the skyline.

To address this issue, the City of London Local Plan 1989 and subsequent development plans for the City have included a policy stating that the effect of development on the skyline setting and backdrop of the Cathedral would be a consideration in determining applications for tall buildings. These policies have been expressed in qualitative terms, but no geometrical system of view protection was proposed.

It is important to consider the backdrop of the St Paul’s Heights views and how this might affect the location of tall buildings. This can be done by considering groups of views with similar characteristics:

Islington views. The dome, peristyle and western towers of the Cathedral are seen against clear sky in the three views from Islington (Farringdon Road, Amwell Street and St John Street). The backdrop falls across areas of the City covered by the St Paul’s Heights and vistas defined by the LVMF. The backdrop is effectively protected by these. The Shard development at London Bridge Station in Southwark, currently under construction, is visible to the left of the dome in the view from Farringdon Road, but it will not appear behind the Cathedral.

Northern views. The backdrop to the views from King Edward Street, Little Britain and St Martin le Grand similarly falls across areas south of the Cathedral covered by the St Paul’s Heights and protected vistas and so is effectively protected.

Fleet Street. In the views from Fleet Street the Cathedral’s dome, peristyle and western towers are seen against clear sky. Although some tall buildings are seen from the extreme west of Fleet Street, for an observer walking eastwards, by the time the Cathedral has moved fully into view these have disappeared from sight. The backdrop to the view is not protected by other view controls and falls across the southern part of the Eastern Cluster as defined by the UDP and Core Strategy. There are, however, two developments that have been permitted

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but not yet constructed that potentially affect the view. When first proposed, the tall building at 20 Fenchurch Street would have intruded into the skyline between the dome and the south- west tower seen from Fleet Street. The permitted scheme was reduced in height so that it would no longer be visible. The development at 122 Leadenhall Street would appear on the skyline to the left of the dome, becoming the only tall building visible in the Fleet Street view. The building has been designed with its south elevation, which faces towards the dome in the view, strongly raked in order to reduce its impact on and to respect the Cathedral.

Watling Street. The dome and peristyle are seen against clear sky. The northern part of the backdrop falls across areas covered by the LVMF protected vistas. As the view point is close to the Cathedral, the view plane slopes relatively steeply and so it is unlikely that any building in the west of the City or Westminster could be tall enough to be visible in the view.

Cannon Street. From the junction with New Change the whole of the Cathedral is seen, but from the rest of Cannon Street the view is of the south-west tower only. The view is seen against clear sky. The backdrop falls across areas which have recently been redeveloped or are protected by LVMF views and conservation areas and so development should not intrude into this view.

River views. The views from the Thames bridges and south bank form a near-continuous sequence. They can best be considered in three sections:

Views from London Bridge, Cannon Street Railway Bridge and Southwark Bridge, and from the south bank between London Bridge and New Globe Walk. The Cathedral is seen against clear sky, with no tall buildings within its wider setting. The backdrop to these views falls across areas in the north-west of the City protected by St Paul’s Heights and LVMF views and so tall buildings should not intrude on these views.

Views from the Millennium Bridge and Blackfriars Bridge, and from the south bank between New Globe Walk and Gabriel’s Wharf. The tall buildings in and around the Barbican, London Wall and west of Moorgate are seen in the backdrop to the views of the Cathedral. The tall buildings variously appear on the skyline behind and on either side of the dome and western towers, and above the nave and choir roofs. The tall buildings appear at various heights relative to the Cathedral. The tops of the tallest buildings appear level with the lower drum or the peristyle; however, none appears as high as the upper drum or the dome. Thus, while they compromise the Cathedral’s setting on the skyline, they do not intrude on the outline of the dome itself. Several of the tall buildings are of recent construction and have replaced former tall buildings constructed in the 1960s; some of the new buildings are taller and broader than the buildings they replaced, and so have worsened the impact on the Cathedral’s skyline setting.

Views from Waterloo Bridge and Hungerford Bridge, and from the south bank between Gabriel’s Wharf and Waterloo Bridge. St Paul’s is seen with the Broadgate Tower in the backdrop and in relation to the Eastern Cluster to its right. The Broadgate Tower variously appears behind and to either side of the dome, according to the vantage point. It is the only tall building in any of the views that is high enough to appear behind the dome itself, and it therefore has a significant impact on the skyline profile of the Cathedral. The Eastern Cluster is seen to the right of the Cathedral, close enough to have a visual relationship, but not appearing in its backdrop. The tall building that is seen closest to the right of the Cathedral is Angel Court. The height of buildings in the Cluster generally steps upwards to the right of Angel Court. There is a gap on the skyline between the Cathedral and Angel Court, introducing a “breathing space” between St Paul’s and the Cluster that is visually important to the relationship between them. This space did not previously exist and was deliberately created.

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The gap was formerly filled by two tall office buildings constructed during the 1960s: Winchester House and Drapers Gardens. Because of the effect of these on the skyline setting of the Cathedral, when they were redeveloped, they were replaced by buildings whose height ensured that they would not intrude into the gap. The space is somewhat compromised by high-rise student accommodation in Tower Hamlets (100 Middlesex Street or “Nido”), although the top of this appears no higher than the lower part of the Cathedral’s peristyle.

6.3.3 St Paul’s Heights: Conclusions

The restrictions on the height of development imposed by the St Paul’s Heights limitations mean that tall buildings would not be acceptable anywhere in the area of control. A number of relatively tall buildings infringed the height limitations; however, all but two of these have been demolished.

The backdrop to the St Paul’s Heights views is an issue deserving consideration. While areas in the backdrop of many views is effectively protected from the intrusion of any tall buildings because they coincide with LVMF views or the foreground of different St Paul’s Heights views, there are other views where the backdrop is not protected in this way. Significant numbers of tall buildings already appear in the backdrop to these views or have been permitted. Proposals need to be assessed on their merits having regard to their potential effect on the skyline setting of the Cathedral and their relationship to other tall buildings affecting that setting.

6.4 Monument Views

The Monument, built between 1671 and 1677 to commemorate the Great Fire of London, is both a listed building and a scheduled ancient monument. It is an important vantage point with extensive views over London and these attract up to 100,000 visitors per year to its gallery. Many more, however, visit the Monument without ascending it and enjoy it as a City landmark of distinctive height and architectural form.

The City of London UDP (2002) contains policies (ENV 25 & 26) regarding the Monument’s setting and views from its gallery. Policy for the Monument’s setting require the height, massing and design of development within the setting of the Monument to maintain the Monument’s

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visual impact in the local street scene, and to preserve existing views of the Monument. The setting is defined on the proposals map as the four street blocks surrounding the Monument.

The policy also resists development which interferes with specific views seen from the gallery of the Monument. The prospect seen from the Monument comprises views of particular landmarks, the River Thames and the surrounding townscape. Nearby familiar skyline landmarks are also described as they are important features in the general panorama to be seen from the public viewing gallery. The policy is explained further in Supplementary Planning Guidance, which is expected to be replaced by a Supplementary Planning Document.

The five Monument views (as detailed in Figure 19 and on the UDP Proposals Map) are: • View One: South East to the Tower of London, Tower Bridge, the River Thames and HMS Belfast • View Two: South to the River Thames • View Three: South West to London Bridge and Cannon Street Railway Bridge • View Four: West to Waterloo Bridge and Victoria Embankment • View Five: North West to St Paul’s Cathedral

Further information can be found in the Unitary Development Plan Supplementary Planning Guidance “St. Paul’s and Monument Views”. The SPG will eventually be replaced by a supplementary planning document (SPD) on protected views in the City.

The Tower Place development, 1962–65, included a tall building, Vincula House, which blocked the view of the White Tower seen from the gallery of the Monument. Tower Place was demolished in 1998 and replaced by a building of lower height, restoring the view.

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Figure 19. Monument Views Policy Area.

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6.5 Tall Buildings that have been demolished

The exceptionally high rate of development in the City has led to the demolition and replacement of buildings that were constructed relatively recently. This has included a number of tall buildings. In some cases they were replaced with new tall buildings, but in other instances the new building on the site was low-rise. The redevelopment of tall buildings gives the opportunity to consider whether the site is suitable for a tall building and, if not, whether it should be replaced with a building of lower height.

In some cases where tall buildings have been demolished they have been replaced by a new building of similar or greater height. In these instances it was considered that the sites were appropriate for tall development.

Most of the tall buildings demolished and replaced have been in London Wall. This was an area of extensive bomb damage that was declared a comprehensive development area and the subject of a redevelopment plan announced in 1955. It consisted of a dual carriageway lined by slab blocks placed en echelon either side of the road. The blocks were mostly built around 1957. Several of the 1950s tall buildings have been demolished since the 1980s and replaced by office buildings of similar or greater height. These are Lee House (125 London Wall), Royex House, Gillett House and the Plaisterers’ Hall.

Elsewhere in the City, the Kleinwort Benson Building in Fenchurch Street was 20 storeys high and was built in 1968. It was demolished in 2008 and planning permission was granted, following a public inquiry, for its replacement by a building of greater height, but construction has not yet commenced. The Lime Bank building in Gracechurch Street, built in 1971 by Barclays Bank, was demolished in the 1980s and replaced by a lower-rise building on the same site, although a tall building was constructed by Barclays on another site nearby.

This report has referred to a number of tall buildings that have been demolished and replaced by lower-rise development because the site was not considered appropriate for a high-rise building. In all cases the main reason that the site was not judged suitable was the effect on protected views. These developments can be summarised here:

Built Demolished Rebuilt

Building Comments

Vintry House 1930 1980s 1990s All these buildings infringed the St Paul’s Heights limits Faraday House 1930 2006 2009 and have been replaced with buildings that conform (north) to the Heights. (Cardinal House has been demolished Sudbury House 1964 1990s 2003 although no planning application for its replacement Cardinal House 1960s 2010 has yet been submitted) See paragraph 6.3.1 for (LB Islington) more information Winchester House 1968 1997 2000 Considered detrimental to the backdrop of views of Drapers’ Gardens 1967 2007 2009 St Paul’s Cathedral seen from Waterloo Bridge. (See paragraph 6.3.2 for more information) Vincula House, 1966 1998 2002 The former tall building obstructed the protected view Tower Place of the White Tower from the gallery of the Monument and was considered too tall within the setting of the Tower. Mirror Building, 1960 1998 2002 The tall building adversely affected the strategic view Holborn Circus of St Paul’s from Primrose Hill.

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7. Other Planning Considerations

7.1 Thames Policy Area

The Secretary of State’s “Strategic planning guidance for the River Thames”, published in 1997, required riparian local authorities to designate a “Thames policy area” and carry out an appraisal of its character. The City’s UDP 2002 contains a chapter on the River Thames setting out policies that had regard to this guidance. The UDP’s proposals map identified the Thames policy area in the City. In accordance with the requirements of the strategic guidance the City Corporation published supplementary planning guidance (SPG) “Riverside appraisal of the Thames policy area” in 2002, and this remains in force. The policies of the UDP and SPG follow strategic guidance in promoting a high quality of design and environment in the Thames policy area. The London Plan also refers to the Thames policy area and continues to promote its enhancement. The SPG will eventually be replaced by a supplementary planning document (SPD) on the Thames policy area.

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Figure 20. Thames Policy Area.

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7.2 Tall Buildings and Transport

Tall buildings often contain large amounts of floorspace on a relatively small site, accommodating a significantly greater number of workers than lower-rise development. Consequently, individual tall buildings or clusters of tall buildings may put particular pressure on the transport system and local thoroughfares, especially during the morning and evening peak periods. It is therefore necessary to consider whether the number and location of tall buildings in the City needs to be managed to take account of the capacity of transport infrastructure.

In many areas of Greater London transport capacity is an important consideration in relation to tall and other large employment-generating developments. Planning policies seek to locate tall buildings and large developments close to transport nodes, such as railway stations. The existence of stations may be used to justify tall development above the stations or in their immediate vicinity. Many planning authorities, especially in London, use the Public Transport Accessibility Levels (PTAL) methodology to assess the suitability of locations for high-density development. The relevance of these considerations in the City needs to be appraised.

The City has a very high working population within its small area. While employment levels fluctuate with the economic cycle, the long-term trends are for growth in future. Current employment in the Square Mile is estimated to stand at over 300,000 and this is projected to rise to 428,000 by 2026. The effect of the distribution of additional development and floorspace is therefore an important consideration.

The City has the highest density of public transport provision in Britain (see Figure 21). There are 9 mainline rail stations and 16 underground stations within or close to the City’s boundaries, and 53 bus routes pass through the Square Mile. This gives the City an employment catchment area that covers much of the south-east of England. Many workers travel considerable distances, and public transport usage is exceptionally high, with over 90% of commuters arriving by train or bus. The majority of these commuters complete their journey to work on foot, and most movement within the City is also on foot, giving rise to very high levels of pedestrian traffic throughout the working day.

By contrast, less than 5% of the workforce commutes by car and planning policy since the 1960s has sought to restrain car use for commuting. The City’s streets are important for servicing buildings, and tall buildings may generate more servicing traffic than development with less floorspace.

The London Plan’s policies aim to accommodate the projected growth in employment within London, while recognising that the public transport system is suffering serious strains on its capacity. It does not seek to restrain employment growth, but seeks to cater for it by improvements to public transport provision, particularly through the construction of Crossrail as well as the Thameslink and Tube upgrades.

The exceptionally high provision of public transport in the Square Mile means stations are in close proximity and no part of the City is more than a very short walk from a station or bus stop. It is therefore not possible to calculate PTALs for the City or to regard any location as having a significantly higher level of accessibility than any other. Therefore it is not practical to use public transport accessibility calculations to distinguish between potential tall building sites.

Accessibility could potentially become a significant consideration in relation to street access for pedestrians and service vehicles where there are high concentrations of tall buildings and

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other high-density development. This may raise issues in the eastern cluster, where already high densities of development are expected to be intensified by further tall buildings. Many streets in the area are narrow and it will be a challenge to accommodate the growing numbers of workers moving around on foot while at the same time meeting the requirements of vehicles needed to service buildings. The City Corporation has commissioned a study of this area and individual development proposals are being assessed for their effects on pedestrian and vehicular traffic and the quality of the pedestrian environment. Transport studies indicate that further tall buildings can be accommodated in the cluster as a whole, but careful consideration needs to be given to the suitability of individual sites and the detailed configuration of their servicing facilities.

7.3 London’s Airports

London airport safeguarding requirements need to be adhered to on all tall building proposals in the City. When considering planning applications for tall buildings the City of London is required to consult airport operators within a defined safeguarding area. The purpose of the safeguarding is to allow airport operators to consider the potential effect of proposals on their flight paths and navigational systems. Under the Town & Country Planning (Safeguarded Aerodromes, Technical Sites and Military Explosives Storage Areas) Direction 2002, the City of London is required to consult London City Airport on all planning applications for buildings, structures, erections or works over 90 metres in height (above ground level) within the Airport's safeguarded area. The safeguarded area covers the City east of Ordnance Survey grid line easting 532000, as shown on the Figure 22. Although the 'Square Mile' lies outside the safeguarding area for Heathrow Airport, the Civil Aviation Authority has asked the City of London to consult both the operator, BAA Airports Ltd and London City Airport on all planning applications for buildings over 150m in height above ground level throughout the City. The City of London will take account of any views expressed by London City Airport and BAA in considering planning applications. In the event that the City of London intends to grant planning permission contrary to the advice of the consultees, it is required to notify the Civil Aviation Authority of its intention.

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Figure 21. Public transport in the City of London.

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Figure 22. London City Airport Safeguarded Area.

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7.4 Environmental effects

Tall buildings can affect daylighting, sunlighting and wind turbulence in their surroundings.

Daylighting and sunlighting is principally an issue in relation to residential buildings and open spaces. It is of more limited concern for commercial accommodation. It will need to be considered on a site by site basis.

The impact of wind on surrounding streets and open spaces will need to be assessed.

Another environmental effect that tall building development needs to consider is that of radio interference.

7.5 Mixed use

Tall buildings are sometimes seen as providing an opportunity to provide a mixture of uses to increase the vitality and interest of their surroundings and it is necessary to consider the relevance of this concept in the City. The mixture of uses may be confined to the lower floors of the building, or the building as a whole may contain several different uses.

Existing tall buildings in the City are predominantly in a single use on their upper floors. The tall blocks in the Golden Lane, Barbican and Middlesex Street estates and Gloucester House nurses’ home are in residential use, while all other tall buildings in the City are primarily in office use. Some tall buildings have retail uses on their lower floors. A few tall buildings accommodate other uses on their lower floors, such as Bastion House, which contains the Museum of London. and the Heron, currently under construction at Milton Court, which will provide accommodation for the Guildhall School of Music & Drama on its lower floors with housing above. Other tall buildings are exclusively offices.

The great majority of the land and buildings in the City are in office use. Other land uses include housing, retailing, and cultural and leisure facilities, but none of these individually occupies more than about 5% of the City’s total floorspace. The saved policies of the UDP and the emerging policies of the Core Strategy generally seek to protect existing mixed uses and ensure that they are replaced on redevelopment. Policies aim to ensure that new uses are appropriately located; for example, new retail space should be in locations that complement existing shopping centres and new housing should be sites in or near existing residential areas. These considerations apply throughout the City to all forms of development.

Tall development is one of the means of meeting the City’s requirements for increased office space and, to a lesser extent, housing. It is considered that other uses within tall buildings do not normally raise special issues and can be considered according to general policies relating to land use.

Tall buildings in certain locations afford opportunities for spectacular views from their upper storeys, and it would be a benefit if the public could share the enjoyment of these. Viewing galleries, or public uses such as restaurants, would allow visitors to appreciate the views. Tower 42 has a bar and restaurant on its upper floors, but this is the only instance in the City. The proposed development at 20 Fenchurch Street includes a “sky garden” which will be fully accessible to the public. While attempts have been made to provide public access to upper floors of other tall buildings, concerns over security and the need for separate access and lifts have made this difficult to achieve.

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7.6 Other Relevant Plans and Strategies in the City

7.6.1 Enhancing the Public Realm in the Eastern Cluster (2005)

This strategy for enhancing the public realm and streetscape in the eastern part of the City, particularly with regard to the integration of tall buildings into the fabric and grain of the City’s spaces and streets, is intended to achieve the following:

• To offer a framework for joined up thinking, supported by all departments and disciplines within the City of London, to work with developers and others to identify opportunities for public realm enhancement. • To outline the City’s public realm vision and provide a clear strategy and guiding principles, without being prescriptive, for developers and designers when putting forward proposals for public realm improvements as part of their development schemes.

This study has identified certain issues that have emerged as critical to achieving the looked for success in public realm enhancement in the eastern part of the City and these provide a basic briefing framework:

• Servicing • Street management • Wind pollution • Security • Open space • Implications of Section 106 agreements.

7.6.2 St. Helens Square and Vicinity – Enhancing the Public Realm (2007)

Building on the wider strategy ‘Enhancing the Public Realm in the Eastern Cluster’ (2005), St Helen’s Square and Vicinity Public Realm Strategy (2007) provides a detailed strategy to support public realm enhancement projects for the St Helens study area. Defined by Bishopsgate to the west, Camomile Street to the north, St Mary Axe to the east and Leadenhall Street to the south, the study area includes a number of existing and approved tall building schemes. 122 Leadenhall Street, Bishopsgate Tower, (The Pinnacle), 100 Bishopsgate and 30 St Mary Axe lie within the study area, with Heron Tower, Stone House/Staple Hall and 51 Lime Street close by.

Initiated in response to the Section 106 agreement for 122 Leadenhall Street the intention is that the strategy document should contribute to enabling public realm enhancement projects within the study area that achieve integrated and seamless results. The strategy brings together information and evidence on a range of issues including: security; servicing, vehicle & pedestrian movement; surveillance; access & inclusive design; open space/public realm enhancement; micro climate; environmental sustainability and management & maintenance, to inform proposals for future public realm enhancement projects in the area. The strategy outlines guiding principles agreed by the City of London St Helen’s Square working party, which fit in with the City’s planning policies, but are not overly prescriptive. These principles are intended to enable constructive dialogue between the City of London, developers and designers preparing proposals for projects within the study area.

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7.6.3 Barbican Listed Building Management Guidelines SPG (Volume I & II) (2005)

The Barbican Listed Building Management Guidance, adopted as a Supplementary Planning Guidance in 2005, sets out guidelines for positive and proactive management of the grade II listed Barbican Estate. The document sets out the nature and extent of the special architectural and historic interest of the Barbican Estate. Offering guidance to the Corporation as freeholder and landlord, and to leaseholders and rental tenants it describes the formal procedures that should be followed in connection with planning or Listed Building Consent applications. A ‘traffic light’ system is used to help residents, leaseholders and the freeholder to determine the level of permission required for proposed work. The estate includes several listed tall buildings.

7.6.4 Golden Lane Listed Building Management Guidelines SPD (2007)

Listed Building Management Guidelines for the Golden Lane Estate, adopted as Supplementary Planning Document in 2007 provides detailed guidance for the physical management of the grade II/II* listed estate including the residential blocks, leisure centre and nursery, community centre, commercial premises and external landscape and includes advice on best practice and a management strategy. The estate includes Great Arthur House as a tall building.

The document defines in detail how building type, urban space, urban form, structure, materials and components, contribute to the special interest of the Golden Lane Estate. While the retention of original features and like-for-like replacement is encouraged, the management guidelines use a ‘traffic light’ system to help residents, leaseholders and the freeholder to determine the level of permission required for proposed work. This depends on the impact of the work on the special architectural interest of the building.

7.6.5 Tall Buildings and Sustainability (2002)

Intended as a discussion paper, Tall Buildings and Sustainability (Faber Maunsell, 2002) commissioned by the City of London Corporation examines the options for tall buildings in the City of London in the context of sustainable development. Recognising tall office buildings are seen as increasingly necessary to meet office demand in the City the report considers the effects of tall buildings on their local environment and on their occupants. Analysis of the sustainability of new developments in the design, construction and operation of tall buildings is followed by a discussion of best practice examples of new design ideas from around the world.

In line with the London Plan, new buildings are expected to maximise their energy efficiency and carbon emissions reduction. Tall buildings can provide opportunities to do this with measures that would not be available to low rise buildings due to their close proximity of the facades to other buildings and smaller façade surfaces. Tall buildings are therefore expected to contribute significantly and innovatively to sustainable City development.

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8. Conclusion

8.1 Regional planning context

The London Plan predicts significant future growth in the economy and workforce of the capital, particularly in central London. Much of this growth is expected to come from the financial services sector, which is concentrated in the City. It states that this growth should be accommodated by an overall increase in the amount of office floorspace, and this will be achieved by making London a more “compact city”, with a general increase in the density of development. In the City of London it is expected that, during the period 2006 to 2026, an additional 1.5 million square metres of office stock is required to accommodate this predicted economic growth. This can be achieved by the redevelopment of buildings on suitable sites at increased density. Tall buildings will be one means by which the overall uplift in floorspace and density can be realised.

The London Plan also states that Development Plan Documents should promote tall buildings in suitable locations and identify areas that could be sensitive to tall development. The City’s Core Strategy must be in general conformity with these requirements of the London Plan. The policies of the London Plan also include detailed criteria for the assessment of proposals. As the London Plan forms part of the development plan for the consideration of planning applications, it will not be necessary to repeat these in the Core Strategy.

8.2 Local policies

The location of tall buildings in the City has been influenced by a succession of development plans and other policies that have operated over a considerable period of time. The City of London Unitary Development Plan 2002, currently in force, contains a policy for tall buildings setting out criteria for the assessment of planning proposals for such development. It states that tall development is inappropriate within conservation areas and certain view protection areas. The rest of the City is considered sensitive to tall buildings. It also identifies an “eastern cluster” and a “north central area” as locations with particular potential for accommodating further tall development.

The identification of areas of the City that are either inappropriate for or sensitive to tall development has been an approach that has been consistently applied since the inclusion of the first policy explicitly to address tall buildings in the Greater London Development Plan, approved in 1976. The City of London Local Plan, adopted in 1989, interpreted the areas inappropriate for tall buildings as conservation areas and certain view protection areas, and this approach has been carried forward into the subsequent Unitary Development Plans, adopted in 1994 and 2002.

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Figure 23. Existing and proposed Tall Buildings by height.

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8.3 Areas inappropriate for tall buildings

The UDP identifies protected view corridors and conservation areas as inappropriate locations for tall buildings and it needs to be considered if this approach should be continued in the LDF Core Strategy.

Protected views are an important consideration in the City, where a number of policies operate. At the regional level, the London Plan’s London View Management Framework (LVMF) defines eight long-distance “Protected Vistas” which comprise “London Panoramas” and “Linear Views” of St Paul’s Cathedral, and a “Townscape View” of the Tower of London World Heritage Site. At the local level policies of the City of London UDP 2002, operated in co-operation with neighbouring boroughs, protect defined views of the Cathedral through the St Paul’s Heights policy. The UDP also operates a policy to protect views of and from the Monument. Protection of these views is to be carried forward into the Local Development Framework. The views protected by all these policies are defined geographically on the UDP’s proposals map.

In accordance with these policies, it would not be acceptable to allow any tall buildings within the defined St Paul’s Heights or Monument views. Similarly, tall buildings could not be permitted within the “landmark viewing corridors” of the LVMF’s protected vistas. However, in the lateral and background assessment areas of the LVMF’s views a more flexible approach is possible, consistent with the maintenance of the views.

The City’s conservation areas have strong and distinctive historic character. It is considered that tall buildings would generally be inappropriate to the character of these areas. There are, however, three tall buildings within conservation areas, and the relevance of these to policy needs to be considered. Two of these were already in existence when the conservation areas in which they stand were designated. It is recognised that the character of these buildings is not sympathetic to their locations, but, as they are both surrounded by areas of strong historic character, it was considered that their presence should not preclude designation. The other tall building was permitted after designation of the conservation area and is considered to be a very exceptional case. Therefore, the three tall buildings, are not considered to set a precedent for further tall development and it is desirable to continue to regard conservation as generally inappropriate for tall development.

Figure 24 is a composite map showing protected view corridors and conservation areas, making up the areas inappropriate for tall buildings.

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Figure 24. Areas Inappropriate for Tall Buildings.

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8.4 Areas sensitive to tall buildings

Outside the areas inappropriate for tall buildings there are many considerations that must be taken into account in determining whether a site is suitable for tall development. These considerations include the effect of potential tall buildings on their local setting and townscape, views, the amenities of neighbouring buildings and spaces, the wider skyline, and the settings of listed buildings and conservation areas. Notwithstanding that there are already many existing and proposed tall buildings, the historic character of the City, its density of development and occupation, and the quality of its environment mean that all areas not identified as inappropriate for tall buildings should continue to be regarded as sensitive to their impact.

The question arises as to whether, in view of the City’s sensitivity to tall buildings, the Core Strategy should identify any other areas as inappropriate for tall development. It is concluded that this is not the case. This is because many of the issues relevant to tall building proposals cannot practicably be defined on the LDF’s proposals map, as they mainly relate to individual sites. For example, the City’s townscape in many locations is characterised by the close proximity of buildings of widely contrasting scales and styles. In some instances the juxtaposition of buildings of differing height creates an interesting and exciting townscape; in others it would be harmful. These decisions must be made on the basis of individual sites or very localised areas; it would not be realistic to attempt to define them on the LDF’s proposals map. Similarly, the effect of a proposed tall building on the settings of listed buildings and conservation areas depends on very local considerations that it would not be feasible to portray geographically.

A further consideration is the effect of tall buildings on views that are not geometrically defined. These are the LVMF’s ‘River Prospects’ and the wider setting of the Tower of London, the backdrop to the St Paul’s Heights views, and views of historic skyline landmarks. The appraisal of the effects of tall building proposals on these is largely according to qualitative criteria. It would not be practicable or desirable to attempt to define these view considerations geometrically or geographically.

In conclusion, treating all of the City outside those areas defined as inappropriate for tall buildings as sensitive to tall development allows a range of considerations to applied in assessing whether proposals are acceptable.

8.5 Tall Building Clusters

The City of London UDP 2002 identified a “north City area” and an “eastern cluster” as the main concentrations of tall buildings. It needs to be considered if these areas should be carried forward into the Core Strategy.

The north City area was mainly identified on the basis that it was a large area that was not designated as inappropriate for tall buildings because it was outside conservation areas and certain protected views. The buildings within it include the tall office buildings along London Wall and, more widely, City Tower and the tall residential buildings of the Barbican and Golden Lane Estates. In visual terms, these buildings can only be considered to make up a loose grouping of tall buildings rather than a distinctive cluster. Since the preparation of the UDP several tall buildings have been built elsewhere in the City. The former strategic views have also been replaced by the narrower corridors of the LVMF. The north City area is therefore no longer so recognisably different from other areas of the City in terms of its concentration of tall buildings. It is concluded that considerations applying to areas of the City

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defined as sensitive to tall buildings apply equally to the north City area, and so it is no longer justifiable to specially distinguish this area in the Core Strategy.

The eastern cluster is the most distinctive concentration of tall buildings in the City. At the time of the preparation of the UDP 2002 the tallest building in the cluster was Tower 42, which was significantly higher than any others and formed a visual focus for the grouping. Since that time two other buildings of similar height have been constructed, so that its role as a focus has been reduced. However, the Pinnacle development in Bishopsgate, currently under construction, will be significantly taller and will provide a new focus for the cluster when it is completed. Existing and proposed tall buildings in the eastern cluster over 100 metres in height are shown in Figures 26 and 27.

Grouping tall buildings into a visually coherent cluster is of benefit to the appearance of the City’s skyline and should be encouraged. The eastern cluster is the only area of the City where such a distinctive concentration has formed. Since the preparation of the UDP several tall buildings have been added to the cluster and further tall buildings have been permitted (see Appendix A). Although the cluster temporarily does not have a single building to act as a clear focus, a new building is expected to assume this role in the foreseeable future. It thus continues to be beneficial to identify an eastern cluster and this should be carried forward into the Core Strategy. Within the cluster, however, not all sites will be appropriate for tall development, and so the cluster should continue to be regarded as an area sensitive to tall development, as in other parts of the City.

8.6 The Eastern Cluster

The Eastern Cluster contains the greatest density of businesses and jobs in the Square Mile, principally offices for banking and insurance, but there are also other land uses, including open spaces and retailing at Leadenhall Market. The Eastern Cluster has potential to accommodate more development and jobs and has fewer constraints on the development of tall buildings than many other areas of the City. In the future the Eastern Cluster will contain more tall and large buildings and an even larger workforce.

In order to cope with the continued increase shown in employment and population projections, the delivery of floorspace in the City of London is essential to achieve greater employment densities. This can be achieved in those areas of the City with fewer land use and height constraints affecting tall buildings.

In view of the degree of change which is expected to take place here, it is appropriate to include the Eastern Cluster, among the Core Strategy’s policies for ‘Key City Places’.

Figure 25 illustrates the broad distribution of development anticipated in each of the five Key City Places identified in the Core Strategy and the rest of the City over the period to 2026. The figures are presented as percentage ranges for key land uses rather than precise floorspace estimates or numbers of residential units, and allow some flexibility to respond to changing circumstances. The percentages are based upon City Corporation monitoring of the development pipeline at March 2010 (sites under construction or with the benefit of planning permission) but also take account of policy aspirations within the Core Strategy. The overall distribution across the City reflects the City’s primary business role.

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Figure 25. Anticipated Distribution of Development (% of floorspace and % of residential units).

Offices Retailing Hotels Housing (units) North of the City 10-20 20-30 0-10 70-80 Cheapside 0-10 50-60 10-20 0 Eastern Cluster 60-70 10-20 0-10 0 Aldgate 0-10 0-10 0-10 0-10 Thames & 0-10 0-10 60-70 0-10 Riverside Rest of the City 10-20 0-10 0-10 0-10 City of London 100 100 100 100

Offices are the predominant land use in the City, providing approximately 70% of all floorspace and 80% of total employment, although there are areas where other uses such as retailing and housing are locally dominant. Figure 25 shows the anticipated distribution of office development highlighting that the Eastern Cluster will be the main focus for offices, with 60-70% of growth expected to take place in the area.

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Figure 26. Eastern Cluster (LDF Core Strategy).

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Figure 27. Major Schemes in the Eastern Cluster.

Source: City of London (2010) and Land Use Survey (2001)

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8.7 Other considerations

The Core Strategy’s policy for tall buildings needs to take account of a range of other considerations which will be relevant to decisions on appropriate locations for tall development. These include the impact of large developments on the local and wider transport system, including the pedestrian environment and vehicular servicing.

The London Plan contains detailed criteria against which tall building proposals should be considered. In view of this, it is considered that the London Plan and the Core Strategy will together provide sufficient policy guidance for the consideration of planning applications for tall buildings. It is therefore not necessary for further guidance on tall buildings to be included in other Local Development Documents.

An issue needing consideration is whether the LDF should identify specific sites where tall development would be encouraged. Land ownership, site assembly and the economics of development are particularly complex matters. Developers are encouraged to propose sites within the cluster for detailed consideration against the development plan policy context. In view of this, it is considered that any attempts to designate specific sites would be unrealistic and could be harmful to the development process.

8.8 Summary

The main conclusions as to the content of the Core Strategy’s policy for tall buildings can be summarised as follows:

• Conservation areas and certain view protection areas, shown on the LDF proposals map, are inappropriate for tall buildings. • The remainder of the City is sensitive to tall buildings. • The eastern cluster is identified as an area where further tall buildings may be encouraged on suitable sites, but the cluster is nevertheless an area sensitive to tall development. • It is not desirable for the LDF to identify specific sites where the development of tall buildings should be encouraged. • Within areas sensitive to tall buildings, proposals for tall development will need to be carefully considered in relation to a range of criteria to determine whether sites are suitable for such development. • The policies of the London Plan and the City’s Core Strategy provide sufficient guidance in relation to tall buildings and it is not necessary to include further policies in other Local Development Documents. • The Eastern Cluster should be the subject of a policy among the Core Strategy’s ‘Key City Places’.

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8.9 Policy

In view of these conclusions, the following policy is included in the Core Strategy:

Policy CS14: Tall Buildings

To allow tall buildings of world class, sustainable design in suitable locations and to ensure that they take full account of the character of their surroundings, enhance the skyline and provide a high quality public realm at ground level, by:

1. Permitting tall buildings of the highest architectural excellence on suitable sites within the City’s Eastern Cluster.

2. Refusing planning permission for tall buildings within conservation areas, where they would adversely affect protected views of St Paul’s Cathedral, the Monument and the Tower of London as defined on the Proposals Map.

3. Elsewhere in the City, permitting proposals for tall buildings only on those sites which are considered suitable having regard to the potential effect on the City skyline, the character and amenity of their surroundings including the relationship with existing tall buildings, the settings of listed buildings and conservation areas, and the effect on historic skyline features.

4. Ensuring that tall building proposals do not adversely affect the operation of London’s airports.

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Figure 28. Tall Buildings in the City of London.

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9. References

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City of London. DEVELOPMENT SCHEDULES (RECORDS GO BACK TO JANUARY 2000).

City of London. CONSERVATION AREA CHARACTER SUMMARIES AND MANAGEMENT PLANS (SEE APPENDIX B AND C FOR FURTHER DETAILS).

City of London. (1947) HOLDEN-HOLFORD PLAN.

City of London. (1981) SMITHFIELD DISTRICT PLAN.

City of London. (1989) LOCAL PLAN.

City of London. (1994) UNITARY DEVELOPMENT PLAN.

City of London. (1994) CONSERVATION AREAS IN THE CITY OF LONDON: A GENERAL INTRODUCTION TO THEIR CHARACTER.

City of London. (2002) UNITARY DEVELOPMENT PLAN.

City of London. (2002) ST. PAUL’S AND MONUMENT VIEWS SUPPLEMENTARY PLANNING GUIDANCE.

City of London. (2002) RIVERSIDE APPRAISAL OF THE THAMES POLICY AREA IN THE CITY OF LONDON SUPPLEMENTARY PLANNING GUIDANCE.

City of London. (2002) PLANNING ADVICE NOTE 3: ARCHAEOLOGYIN THE CITY OF LONDON.

City of London. (2002) TALL BUILDINGS AND SUSTAINABILITY. (Faber Maunsell)

City of London. (2005) BARBICAN LISTED BUILDING MANAGEMENT GUIDELINES SUPPLEMENTARY PLANNING GUIDANCE. (VOLUME I & II) (English Heritage)

City of London. (2007) GOLDEN LANE LISTED BUILDING MANAGEMENT GUIDELINES SUPPLEMENTARY PLANNING DOCUMENT. (English Heritage)

City of London. (2010) DEVELOPMENT INFO (PERIOD 1ST OCTOBER 2009 TO 31ST MARCH 2010: RECORDS GO BACK TO JANUARY 1999).

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Department for Transport. (2002) TOWN AND COUNTRY PLANNING (SAFEGUARDED AERODROMES, TECHNICAL SITES AND MILITARY EXPLOSIVES STORAGE AREAS) DIRECTION 2002.

Department for Culture, Media and Sport / English Heritage / Communities and Local Government. (2010) PPS5 PLANNING FOR THE HISTORIC ENVIRONMENT: PLANNING PRACTICE GUIDE.

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GLA Economics. (2009) WORKING PAPER 39: BOROUGH EMPLOYMENT PROJECTIONS TO 2031.

Greater London Council. (1976) GREATER LONDON DEVELOPMENT PLAN.

Historic Royal Palaces. (2007) TOWER OF LONDON WORLD HERITAGE SITE MANAGEMENT PLAN.

Land Use Consultants for Historic Royal Palaces. (2010) TOWER OF LONDON: ASSESSMENT OF THE LOCAL SETTING.

London County Council. (1951) COUNTY OF LONDON PLAN.

London County Council. (1962) COUNTY OF LONDON PLAN.

Lovejoy for City of London. (2005) ENHANCING THE PUBLIC REALM IN THE EASTERN CLUSTER.

Lovejoy for City of London. (2007) ST. HELENS SQUARE AND VICINITY – ENHANCING THE PUBLIC REALM.

Mayor of London. (2004) THE LONDON PLAN. SPATIAL DEVELOPMENT STRATEGY FOR GREATER LONDON.

Mayor of London. (2007) LONDON VIEW MANAGEMENT FRAMEWORK SUPPLEMENTARY PLANNING GUIDANCE.

Mayor of London. (2008) THE LONDON PLAN. SPATIAL DEVELOPMENT STRATEGY FOR GREATER LONDON. (CONSOLIDATED WITH ALTERATIONS SINCE 2004)

Mayor of London. (2009) THE LONDON PLAN. SPATIAL DEVELOPMENT STRATEGY FOR GREATER LONDON. (CONSULTATION DRAFT REPLACEMENT PLAN)

Mayor of London. (2009) LONDON OFFICE POLICY REVIEW. (PREPARED BY RAMIDUS CONSULTING LIMITED WITH ROGER TYM & PARTNERS)

Mayor of London. (2010) LONDON VIEW MANAGEMENT FRAMEWORK: REVISED SUPPLEMENTARY PLANNING GUIDANCE.

ODPM. (2005) PLANNING POLICY STATEMENT 1: DELIVERING SUSTAINABLE DEVELOPMENT.

Secretary of State. (1991) REGIONAL PLANNING GUIDANCE 3A.

Secretary of State. (1996) REGIONAL PLANNING GUIDANCE.

UK Government Parliament Act. (1948) TOWN AND COUNTRY PLANNING ACT 1948.

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Appendices

Appendix A. Tall Buildings over 75m AOD in the City of London (Existing and Permitted).

*Highlighted buildings are listed buildings.

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Height (Above Height Ground (m Floorspace Address Level) AOD) Status Floors Main Use (sq m) Permitted Commenced Completed Architect 22-38 Bishopsgate 288.00 304.25 Under Construction 62 Office 148,000 30/11/2007 2007 KPF 106-126 Bishopsgate and 35- 37 Camomile Street 242.00 257.60 Under Construction 46 Office 68,000 22/07/2002 2007 KPF 122 Leadenhall Street 224.50 239.40 Demolished 52 Office 95,979 29/04/2005 Richard Rogers Partnership Tower 42, 25 Old Broad Street 185.40 199.60 Completed 44 Office 05/11/1964 1977 1980 R. Seifert & Partners Swiss Re, 30 St Mary Axe 180.00 195.00 Completed 2001 2004 Foster & Partners 100 Bishopsgate / Camomile Permitted not Street Corner 167.08 180.68 commenced 40 Office 45,900 Allies & Morrison 201 Bishopsgate 164.00 178.00 Completed 35 Office 110,042 23/11/2005 2006 2009 Skidmore, Owings & Merrill 20 Fenchurch Street 177.00 Demolished Office 2007 Rafael Vinoly 51 Lime Street London 125.60 141.40 Completed Office 70,803 21/03/2005 2005 2008 Foster & Partners Cromwell Tower, Barbican 123.10 139.90 Completed 39 Residential 11/11/1965 1968 1972 Chamberlain, Powell & Bon Shakespeare Tower, Barbican 123.10 139.90 Completed 41 Residential 11/11/1965 1969 1976 Chamberlain, Powell & Bon Lauderdale Tower, Barbican 123.10 139.90 Completed 41 Residential 11/11/1965 1968 1975 Chamberlain, Powell & Bon City Point (formerly Britannic Tower), Moor Lane 125.00 139.00 Completed 35 Office 12/12/1957 1962 2004 J.F. Milton Cashmore & Partners Commercial Union, I Undershaft 114.90 129.80 Completed 28 Office 189,889 07/03/1963 1968 1970 Gollins, Melvin, Ward & Partners St Paul's Cathedral, St Paul's Churchyard 111.40 127.60 Completed 4 Public N/A 1680 1711 Sir Christopher Wren Milton Court, London, EC2Y 9BJ 112.00 127.00 Demolished Residential 27,574 31/01/2008 2010 David Walker Land Bounded By Cannon Street, Queen Street, Queen Victoria Street, Bucklersbury & Permitted not Foster & Partners and Jean Walbrook, London, EC4N 8EL 107.00 120.00 commenced 21 Office 131,003 20/12/2007 Nouvell 125 Old Broad Street 104.50 118.40 Completed Office 73,041 15/09/2005 2006 2009 Nicholas Grimshaw & GMW Little Britain, 200 Aldersgate Street 91.00 106.90 Completed 21 Office 14/07/1987 1988 1992 Fitzroy Robinson Partnership Morgan House, 1 Angel Court 93.10 106.80 Completed 25 Office 23/07/1964 1978 1980 Fitzroy, Robinson & Partners 6-8 Bishopsgate 89.00 106.00 Completed 23 Office 23/11/1976 1979 1982 Norman Shaw 99 Bishopsgate 90.20 105.80 Completed 29 Office 23/07/1970 1973 1976 R. Seifert & Partners 60 - 70 St Mary Axe, London, Permitted not EC3A 8JQ 90.60 105.00 commenced 22 Office with retail 39,166 09/12/2008 Foggo 54 Lombard Street 87.00 103.60 Completed 17 Office 372,000 27/06/1991 1992 1994 G.M.W Architects Lloyds Building, 1 Lime Street 84.00 101.00 Completed 12 Office 20/09/1979 1983 1986 Richard Rogers & Partners 125 London Wall 86.20 100.00 Completed 19 Office 12/03/1987 1988 1992 Terry Farrell Partnership Moor House, 120 London Wall 81.40 94.80 Completed Office 37,212 27/04/1999 2003 2005 Foster & Partners Land Bounded By New Fetter Lane, Bartlett Court, New Street 76.11 92.45 Completed 19 Office plus retail 102,446 12/04/2006 2006 2008 Bennetts Associates

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Square, Printer Street, East Harding Street, Pemberton Row and West Harding Street, London, EC4

1 Minster Court 77.00 92.00 Completed 12 Office 13/10/1987 1988 1991 G.M.W Architects Daiwa Building, 84-89 Wood Street 75.00 91.50 Completed 18 Office 13/10/1995 1995 1999 Richard Rogers Partnership 5 Aldermanbury Square 75.50 91.40 Completed Office with retail 38,480 26/06/2003 2005 2007 Eric Parry Architects Plantation Place, Fenchurch Street 73.20 88.00 Completed See plans Office with retail 105,000 15/06/1994 1999 2004 Foster & Partners 23/10/2002 Drapers Gardens, 12 and Throgmorton Avenue, London, subsequent EC2N 2DL 73.40 86.00 Completed See plans Office 37,325 amendments 2008 2010 Foggo Associates

Bastion House, 140 London Wall 69.20 85.30 Completed 21 Office 25/04/1968 1973 1976 Powell & Moya New Court, 1-10 St Swithin's Lane, London, EC4P 4DU 70.00 85.00 Under construction 16 Office 20,992 26/07/2007 2008 OMA & Allies & Morrison St Mary-le-Bow Church, Cheapside 68.00 84.30 Completed 4 Public N/A 1670 1683 Sir Christopher Wren St Alphage House, 2 Fore Street 68.90 83.20 Completed 22 Office 26/05/1960 1960 1962 Maurice Saunders Associates Central Criminal Court, 13 Old Bailey 66.60 83.00 Completed 5 Public N/A 1907 E W Mountford Petticoat Tower, Petticoat Square 68.30 82.30 Completed 24 Residential 16/02/1965 1974 1977 B.J. Brown City Tower, 40 Basinghall Street 69.20 82.30 Completed 20 Office 08/02/1962 1963 1965 Swanke Hayden Connell 2 Minster Court 66.00 81.00 Completed 10 Office 13/10/1987 1988 1991 G.M.W Architects Permitted not 64-71 Mark Lane 66.00 81.00 commenced 16 Office 24,735 04/08/2008 Bennetts Associates Shire Milton House, Milton Street 66.35 80.70 Completed 15 Office 01/01/1975 1977 1981 Sheppard Robson Barbican YMCA, Fann Street 60.90 80.20 Completed 17 Hostel 05/05/1966 1971 Chamberlain Powell & Bon International House, 1 Mitre Permitted not Square 65.00 80.00 commenced 20 2005 Sheppard Robson 135 Bishopsgate 64.80 79.30 Completed 12 Office 352,000 11/09/1986 1987 1990 Skidmore, Owings & Merrill 155 Bishopsgate 64.80 78.30 Completed 12 Office/Transport 28/07/1987 1988 1990 Skidmore, Owings & Merrill Peterborough Court, 131-141 Fleet Street 64.20 78.30 Completed 13 Office 02/05/1988 1988 1991 KPF

175 Bishopsgate 64.80 78.30 Completed 13 Office 394,000 28/07/1986 1987 1990 Skidmore, Owings & Merrill

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St Botolph's House, 138-139 Houndsditch & 2 White Kennet Street 61.80 77.80 Completed 8 Office 71,404 30/11/1999 2007 2010 Nicholas Grimshaw 1 America Square 63.70 77.60 Completed 13 Office 387,650 02/06/1988 1988 1991 R.H.W.L Architects Beaufort House, 15 St Botolph Street 63.00 77.40 Completed 14 Office 22/07/1986 1986 1989 R.H.W.L Architects 12-14 New Fetter Lane, 43 Permitted not Fetter Lane 77.35 commenced 14 Office and retail 19,944 13/01/2009 BFLS St Bride's Church, Bride Lane 69.00 77.00 Completed 2 Public N/A 1670 1684 Sir Christopher Wren St Margaret Pattens Church, Rood Lane 61.00 76.20 Completed 2 Public N/A 1687 Sir Christopher Wren Dashwood House, 69 Old Broad Street 61.60 75.50 Completed 16 Office 130,243 29/01/1971 1973 1976 Yorke, Rosenberg, Mardell 58 Fenchurch Street 65.00 75.00 Completed See plans Office 16,500 21/10/1998 2001 2003 Agent - DP Gaunt Selected Others

Great Arthur House, Golden Lane Estate 53.37 72.37 Completed 16 Residential 26/05/1960 1965 Chamberlain Powell & Bon The Monument, Monument Street 61.60 72.00 Completed 1 Leisure N/A 1667 1677 Sir Christopher Wren Cannon Street Station Towers, Cousin & Allhallows Lanes 51.10 54.80 Completed 1 Transport N/A 1866 J Hawkshaw & J W Barry

Source: City of London (2010)

*Please note that this information is compiled using information from a range of sources including development proposals, committee reports and planning statements. The data is as accurate and up to date as possible.

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Appendix B. Conservation Area Character Summaries.

The following Conservation Area Character summaries have been completed:

• Brewery • Chancery Lane • Dyer’s Buildings (now part of Chancery Lane Conservation Area) • Finsbury Circus • Fleet Street • Guildhall • Laurence Pountney Hill • Leadenhall Market • Lovat Lane (now part of Eastcheap Conservation Area) • Ludgate Hill (now part of St. Paul’s Cathedral Conservation Area) • Middlesex Street (now part of Bishopsgate Conservation Area) • New Broad Street • Newgate Street • Postman’s Park • St Helen’s Place • Smithfield • Temples • Whitefriars

These are available on the City of London website. This includes the most current and up to date information on Conservation Area Character Summaries.

The remaining eight are yet to be completed. These are for:

• Bishopsgate • Bow Lane • Crescent • Eastcheap • Fenchurch Street Station • Lloyd’s Avenue • Queen Street • Trinity Square

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Appendix C. Conservation Area Management Strategies.

Five Conservation Area Management Strategies have been prepared for the following Conservation Areas:

• Finsbury Circus • Guildhall • Laurence Pountney Hill • New Broad Street • Temples

These are available on the City of London website. This includes the most current and up to date information on Conservation Area Management Strategies.

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Appendix D. Comparison of Strategic Views and Protected Vistas 1991 / 2007 / 2010.

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Protected Vista 1991 Strategic 2007 2007 LVMF Total 2010 2010 LVMF Landmark Total Change in Width of Views (RPG3a) LVMF Landmark Lateral (2007) LVMF Lateral Assessment (2010) Protection Total Viewing Assessment Areas Viewing Areas (Viewing Corridor Corridor Corridor a) 1991-2010 & Wider Setting) b) 2007-2010 1A.2 440m 70m 140m 210m 140m 160m 300m a) 1991-2010: Alexandra (300m VC; 140m (70m LLAA; 70m RLAA) (110m LLAA; 50m RLAA) Total: -140m -32% Palace to St. Wider Setting) VC: -160m -53% Paul’s b) 2007-2010: (London Total: +90m +43% Panorama) VC: +70m +100%

2A.1 440m 140m 70m 210m 140m 160m 300m a) 1991-2010: Parliament Hill (300m VC; 140m (all LLAA) (110m LLAA; 50m RLAA) Total: -140m -32% to St. Paul’s Wider Setting) VC: -160m -53% (London b) 2007-2010: Panorama) Total: +90m +43% VC: No change. 2A.2 None. None. None. None. 155m None. 155m a) 1991-2010: Parliament Hill Total: +155m New. (the summit) to VC: +155m New. Palace of b) 2007-2010: Westminster Total: +155m New. (London VC: +155m New. Panorama)

2B.1 300m 210m None. 210m 220m None. 220m a) 1991-2010: Parliament Hill Total: -80m -27% (east of the VC: -80m -27% summit) to b) 2007-2010: Palace of Total: +10m +5% Westminster VC: +10m +5% (London Panorama)

3A.1 Kenwood 440m 140m 70m 210m 140m 160m 300m a) 1991-2010: to St. Paul’s (300m VC; 140m (all LLAA) (110m LLAA; 50m RLAA) Total: -140m -32% (London Wider Setting) VC: -160m -53% Panorama) b) 2007-2010:

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Protected Vista 1991 Strategic 2007 2007 LVMF Total 2010 2010 LVMF Landmark Total Change in Width of Views (RPG3a) LVMF Landmark Lateral (2007) LVMF Lateral Assessment (2010) Protection Total Viewing Assessment Areas Viewing Areas (Viewing Corridor Corridor Corridor a) 1991-2010 & Wider Setting) b) 2007-2010 Total: +90m +43% VC: No change. 4A.1 Primrose 440m 120m 90m 210m 130m 170m 300m a) 1991-2010: Hill to St. (300m VC; 140m (70m LLAA; 20m RLAA) (110m LLAA; 60m RLAA) Total: -140m -32% Paul’s Wider Setting) VC: -170m -57% (London b) 2007-2010: Panorama) Total: +90m +43% VC: +10m +5%

5A.2 440m 115m 95m 210m 170m* 130m 300m* a) 1991-2010: Greenwich (300m VC; 140m (25m LLAA; 70m RLAA) (65m LLAA; 65m RLAA) Total: -140m -32% Park to St. Wider Setting) VC: -130m -43% Paul’s b) 2007-2010: (London Total: +90m +43% Panorama)* VC: +55m +48%

6A.1 440m 120m 90m 210m 125m 175m 300m a) 1991-2010: Blackheath (300m VC; 140m (20m LLAA; 70m RLAA) (65m LLAA; 110m RLAA) Total: -140m -32% Point to St. Wider Setting) VC: -175m -58% Paul’s b) 2007-2010: (London Total: +90m +43% Panorama) VC: +5m +4%

8A.1 103m 70m None. 70m 80m None. 80m a) 1991-2010: Westminster (VC only) Total: -23m -22% Pier to St. VC: -23m -22% Paul’s b) 2007-2010: (Linear View) Total: +10m +14% VC: +10m +14%

9A.1 King 148.9m 70m None. 70m 80m 70m 150m a) 1991-2010: Henry’s (VC only) (35m LLAA; 35m RLAA) Total: +1.1m +1% Mound, VC: -68.9m -46%

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Protected Vista 1991 Strategic 2007 2007 LVMF Total 2010 2010 LVMF Landmark Total Change in Width of Views (RPG3a) LVMF Landmark Lateral (2007) LVMF Lateral Assessment (2010) Protection Total Viewing Assessment Areas Viewing Areas (Viewing Corridor Corridor Corridor a) 1991-2010 & Wider Setting) b) 2007-2010 Richmond Park b) 2007-2010: to St. Paul’s Total: +80m +114% (Linear View) VC: +10m +14%

25A.1 City Hall None. 90m None. 90m 90m None. 90m a) 1991-2010: to Tower of Total: +90m New. London VC: +90m New. (Townscape b) 2007-2010: View) Total: No change. VC: No change.

Strategic Views: VC – Viewing Corridor WS – Wider Setting Protected Vistas: LLAA – Left Lateral Assessment Area RLAA – Right Lateral Assessment Area BAA – Background Assessment Area

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