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RIBA London Submission, March 2003
Introduction
RIBA London is the Royal Institute of British Architects' region covering the capital and represents nearly 7000 architects in 1,200 registered architectural practices plus over 2000 architecture students. RIBA London provides services to members in the areas of education and practice, as well as public and promotional services.
In June 2001, RIBA London with 14 other environment-based organisations published "Design for a Greater London" containing proposals for London's public realm. This was followed by the publication of "Delivering the Vision", RIBA London's response to the draft London Plan in September 2002. Both documents are available from the web site http://www.designforlondon.com.
RIBA London supports a strategic Plan for London that allows for sustainable growth and compact development but requires a high quality of design input to ensure that this achieves a better quality of life for both Londoners and visitors to the city. The draft London Plan is applauded for its recognition of the need to promote "the world class architecture that London needs." RIBA London will continue to work with all agencies and organisations in London to support this ambition.
Issue 2.7
Does the Plan provide adequately for the protection of historic buildings and their environs from development/growth pressures?
1. The RIBA is committed to "an appropriate balancing of conservation and innovation"
2. RIBA London wishes to see an approach to the extensive historic environment of London that not only enhances the buildings, spaces and landscapes of the city but also maintains these parts of London in active use and allows for the continued historical evolution of the city's environment. London must maintain its diverse and distinct character/s while allowing for development and cultural change.
3. There is relatively little consideration given to the built heritage of London in the draft plan. Although RIBA London agrees with the thrust of policy 4B.10 it feels that wider and more extensive policies should be developed to deal with issues of World Heritage sites, listed buildings and landscapes and conservation areas.
4. The draft plan should recognise the three existing World Heritage sites in London (Maritime Greenwich, The Tower of London and Westminster) together with the possible addition of a fourth (Kew Gardens). These sites should be afforded particular consideration to maintain and improve them and their settings and the plan should recognise and work with the management plans for these sites.
5. Although listed buildings have their own separate system of recommendation and protection administered by English Heritage and the boroughs the large numbers of listed buildings in London and particularly the central area should be recognised in the Plan as they pose important issues of development in their environs.
6. Where listed buildings or landscapes are involved in schemes for area regeneration, whether conservation-led as recommended in policy 4B.11, or otherwise, the highest quality of new design should be required, as it is with tall buildings, to complement and enhance the existing historic structures and environments. RIBA London fully supports policy 4B.11.
7. London now has an extensive patchwork of conservation areas, as illustrated on page 252, ranging from those protecting London's glorious set piece urban developments to others simply giving extended planning protection to a group of streets and buildings. They lack consistency of purpose and are frequently used to prevent development that would create higher densities in areas where the city and city life could usefully benefit.
8. The London Plan should contain strategic guidelines for the implementation and maintenance of conservation areas while ensuring boroughs maintain the freedom to develop policies in conjunction with local communities and deal with the medium to fine grain of the townscape.
9. London has the opportunity to increase its density and capacity partly by infilling many of the available sites within the existing texture of the streets and buildings. Small scale and appropriate infill, that maintain London's heterogeneous character as described in clause 4B.29, should be facilitated including in many conservation areas.
Issue 2.8:
Are the policies on high buildings appropriate and consistent with other policies?
1. RIBA London recognises that while tall buildings are not necessary to achieve high density they have other significant benefits and can make worthwhile contributions to the quality of cityscape both on the street and at a distance, including:
- Acting as landmark structures and providing a distinctive identity to parts of the city
- Providing animation and interest to the skyline
- Providing a well populated public realm at ground level supporting shops, restaurants and other facilities in the immediate vicinity
- Allowing large communities of businesses and workers to operate within easily walkable distances of transport facilities and each other whilst not excluding other uses.
2. Tall buildings also have the great capacity to be detrimental to the skyline and to sterilise areas of the city. For this reason RIBA London supports the requirement in the draft Plan that any large scale building should be of the highest quality design [Policy 4B.9]. However the policy should be expanded to include the contribution that the design must make to local environment and setting of the building/s over and above the requirement to provide high quality spaces and uses with public access.
3. RIBA London supports the joint paper published by English Heritage and CABE "Guidance on Tall Buildings" and recommends that reference to it should be made in the London Plan.
4. The principle of locating tall buildings in clusters is supported although with important reservations:
- Buildings need to work as individual, identifiable structures with distinctive characters (in particular their tops) and be of differing heights
- There should be adequate space around buildings and consideration given to their setting so that they maintain their separateness from a distance and do not merge into a solid wall (as at Paddington Basin)
- The views between buildings should be considered so that they reveal sky or frame particular views from identified vantage points
- Advertising or corporate emblems on the tops of buildings should not be allowed (see Canary Wharf)
- The spaces and areas at street level should be designed, presented and agreed in detail before consent is given to each development
- Transport infrastructure must be appropriate and of sufficient capacity to support the proposed population of the buildings
5. Proposals for stand alone tall buildings should be particularly convincing. Opportunities should be taken to demolish some existing isolated tall buildings or to facilitate clusters around them as appropriate.
6. Policies 4B.8 and 4B.9 are supported by RIBA London as being generally appropriate for London's needs.
Issue 2.9:
Are the proposals to update London's view protection framework effective and are they appropriate for inclusion in the draft Plan? Should any views be added or removed from the framework?
1. RIBA London recognises that the skyline is one of London's glories and considers that the continued existence of key views and panorama_s in and of the capital has been a significant achievement for planning in London. The current views give huge pleasure to both Londoners and visitors alike. The skyline has both been successfully augmented and damaged in recent decades and we and future generations need to continue maintain and improve the views while being able to contribute to greater possible changes to its appearance.
2. Clarity as to the exact scope of the views is of great importance to ensure that matters concerning views are not subjective. The current RPG3A view protection framework offers such clarity. Any replacement structure needs to operate in similar fashion. Any alterations to the framework should take the form of modifications to the existing requirements rather than new wordings.
3. The narrowing of some existing viewing corridors is generally supported subject to other considerations on the nature of the skyline. This should continue to be formed from individually articulated buildings with space around them rather than slab-like forms or closely packed, uniform tall buildings.
4. The maintenance of background assessment areas, clear from major intrusions, is regarded as being of great importance. There is recognition that individual small or slender buildings in the assessment areas may be allowable within these. Policies VA1-4 are accepted.
5. However RIBA London and in particular our branches representing members from Richmond & Kingston feel strongly that the view from King Henry's Mound in Richmond Park should be maintained. This is a popular and significant view, successfully recreated after a period of loss. RIBA London concurs with many of the other submissions to the EIP supporting the retention of this view.
6. The new River Prospects and Townscape Views are also welcomed and supported.
7. RIBA London supports the proposals of ICOMOS UK and others that policy 4B.12 should be extended to include the obligation to sustain significant views of, and from, World Heritage Sites.