12 March 2020
Historic England has issued a draft updated advice note on tall buildings. Interestingly, this guidance highlights that the evolution of skylines is inherent to all towns and cities, and that some of the most important historic buildings were once the tallest within their built environment.
Consequently, it is stated that in the right place, well-designed tall buildings can make a positive contribution to urban life. However, it is also noted in the advice note that there will be locations where, regardless of the perceived quality of design, tall buildings will cause harm through disruption to a distinctive or sensitive quality of place.
The draft note reiterates accepted guidelines for the assessment of heritage assets and outlines the following additional guidance regarding tall buildings, as well as highlighting existing national policy and guidance of particular relevance.
The draft note emphasises the need for early engagement with consultees given the potential greater impacts of tall buildings, due to their inherent height, bulk and often widespread visibility. The note reiterates that while good design on its own does not justify a tall building in the wrong location, tall buildings need to set the highest standards in design because of their wide impact and likely longevity. It is noted that consultation, including at design review panel, is helpful in determining an Area of Visual Influence as well as identifying the appropriate level of detail required.
The National Design Guide
This guide is noted as particularly relevant to tall buildings, specifically the ‘10 characteristics of good design’. Paragraphs 69 and 70 deal specifically with tall buildings, stating that:
‘Well-designed tall buildings play a positive urban design role in the built form. They act as landmarks, emphasising important places and making a positive contribution to views and the skyline’ (paragraph 69) and ‘Proposals for tall buildings (and other buildings with a significantly larger scale or bulk than their surroundings) require special consideration. This includes their location and siting; relationship to context; impact on local character, views and sight lines; composition - how they meet the ground and the sky; and environmental impacts, such as sunlight, daylight, overshadowing and wind. These need to be resolved satisfactorily in relation to the context and local character’ (paragraph 70).
National Model Design Code
A code is being drafted that will set a baseline standard of quality and practice across England which local planning authorities will be expected to consider when developing their own local design codes and guides, and controlling planning applications dealing with tall buildings.
The note emphasises the importance of including specific tall building policies within development plans and promotes the need for a strong evidence base to support these policies. It is suggested that this evidence base includes the provision of:
- Statements of Heritage Significance
- Conservation Area Appraisals
- Characterisation Studies
- Inter-visibility Studies
- Urban design and townscape analysis
- Three-dimensional (3D) modelling
- Views studies
Criteria for Townscape Assessment
The advice note identifies several criteria and approaches to defining existing local character, prior to determining the impact of a tall buildings. Considerations when assessing existing context include the following:
- Natural topography
- Urban grain
- Significant views of skylines
- Scale and height
- Streetscape and historic character
- Landmark and historic buildings, including their settings any views
High Quality Design
The guidance includes a checklist for preparing an application to ensure an appropriate level of design consideration is evidenced. This includes:
- Design and Access Statement
- Statement of Heritage Significance
- Assessment of context (local and town/city-wide)
- Assessment of cumulative impacts
- Environmental Impact Assessment (when required by the local planning authority)
- World Heritage Site Heritage Impact Assessment (where proposals might affect the Outstanding Universal Value of a World Heritage Site)
- Satisfaction of the following design criteria:
- Architectural quality
- Sustainable design and construction
- Credibility of the design
- Contribution to public space and facilities
- Consideration of the impact on the local environment (and particularly at ground level)
- Provision of a well-designed inclusive environment
- A 3D digital model that can be shared with stakeholders
The guidance notes that assessments of impact should include an assessment of cumulative impact, including the impact upon any existing clusters of tall buildings. Assessments should also take advantage of new technology such as VR headsets to demonstrate impact.
In weighing any public benefits offered by a tall building proposal, the note directs specific attention to paragraphs 8 and 9 of the NPPF in that these benefits should be ‘mutually supportive’ and contribute to protecting and enhancing the built, natural and historic environments. It is suggested that this assessment may involve the examination of alternative designs or schemes that might be more sustainable in that they deliver public benefits while avoiding harm to the built environment.
Bidwells’ Townscape Services
Bidwells is well placed to respond to this updated advice. We possess the expertise to provide robust evidence both in terms of supporting emerging policy and assessment to accompany applications. Engagement on behalf of clients with consultees, initial strategic advice and providing evidence in the form of Heritage, Townscape and Visual Impact Assessments form a core part of our work. Successful townscape projects include the redevelopment of Purley Town Centre and Hurlingham Road in Fulham. Fundamentally, the advice note emphasises the importance of detailed expert engagement with specialists, and Bidwells can provide the confidence for clients that these requirements are being met.
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