Summary introduction

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    1. I am an Assistant Regional Director with the London Region of English Heritage, with responsibility for the London Borough of Southwark. English Heritage is the Government’s adviser on matters concerning the built heritage and a statutory consultee on planning applications affecting the historic environment.

The Scope of my evidence

1.2 My evidence concerns the impact of the proposed development upon the Tower of London World Heritage Site, the protected Strategic view of St Paul’s Cathedral from Blackheath Point and upon the setting of key listed buildings in the vicinity of the site, notably Tower Bridge and Lambeth College. Section 54A of the Town & Country Planning Act requires that planning applications and appeals be determined in accordance with the development plan unless material considerations justify a departure. Sections 66(1) and 72(1) of the Planning (Listed Buildings & Conservation Areas) Act 1990 require that special attention be given to preserving the setting of listed buildings and of conservation areas when determining relevant planning applications.

    1. PPG1 (CD7/1) stresses the plan-led system, the importance of good design, the importance of sustainability and protection of the historic environment. Part of good design is the relationship of a proposed building to its context and the relationship of a proposed development to its surroundings is a material consideration. PPG 1 is about getting the right development in the right location. PPG 15 (CD7/6) sets out detailed policy on conservation areas, listed buildings and other heritage designations. New developments must be considered against existing context.


    1. English Heritage has been involved and supported the More London development and two previous proposals for the Potter’s Field site, including Ian Ritchie Architects’ proposed opera house. Both of the earlier schemes supported by English Heritage were of contemporary design and both acknowledged the importance of modest height in order to protect strategic views and the setting of Tower Bridge and the Tower of London.

English Heritage’s consideration of the scheme the subject of this inquiry

    1. English Heritage staff attended four pre-application meetings with the architects’ team and the scheme was put before the London Advisory Committee on 11 January 2002. This was preceded by a site visit and presentation from the architects. An update of the proposal was given to LAC on 22 November 2002. The architects’ made a presentation to Casework Review on 26 February 2003, following submission of the planning application. Our position, as set out in our letter of 21 January 2002, was that the site is highly sensitive in heritage terms, that we support a contemporary design approach, that the starting point should be a character analysis of the environs but that nevertheless we were ‘intrigued’ by the conceptual approach and considered that the concept might be developed. However, we expressed clear concern regarding both the number and height of the towers.

Impact on the setting of the Tower of London World Heritage Site

    1. World Heritage Sites are sites of ‘outstanding universal value’ the responsibility of the international community as a whole to protect. The Tower of London WHS was inscribed in 1988. There is not yet an agreed management plan. A Management Plan would set out a statement of significance, identifying vulnerabilities and how to protect the site, including “the protection of the wider setting from intrusive development”. Given that the Tower of London is a low-lying medieval fortress it is not surprising that protection of its setting, in the heart of a world city, is exercising minds and has not yet been finalised. There is already intrusion into the setting of the Tower, both from within its precincts and in views of the monument, and concerns were raised at the time of inscription. Until there is an agreed Management Plan, from which policy can be drawn, each potentially harmful proposal requires careful consideration so as not to significantly worsen the existing situation.

    1. The Tower of London is also a grade I listed building, a scheduled ancient monument and stands within a conservation area. PPG15 sets out policy advice on the protection of listed buildings and their settings, of conservation areas and of “the outstanding international importance” of World Heritage Sites. Consideration of setting must include analysis of views from and to the monument, the relationship of the Tower to its environs and to the key components of the river and Tower Bridge. The proposed Potter’s Field development will be perceived from many points within and in juxtaposition with the Tower of London.

    1. Section 5.2 (viii) (page 22) of the applicant’s Urban Design, Conservation & Visual Assessment acknowledges that “the effect of the development [on the Tower of London] will be profound from a certain standpoint since the development site is directly opposite the Tower”. In my view the view of the Tower of London from the Tower Hill viewing platform will be harmed; a view that is the “more critical,…because it would be a first impression of the scene.” (CD14/2 para. 16.81). The proposed Potter’s Field development is only c340m from the Tower of London and will be clearly visible in views from Mansell Street, from Trinity Square and from within the Inner Ward, effectively from many points within the Tower precincts and from the immediate environs to the north, north east and north west – an unwelcome intrusion. Whilst the experience of visiting the Tower of London cannot be separated from the modern city all around, there is still a feeling of apartness, that requires a careful balance to maintain it. In considering the impact of new development on the experience of the Tower both height and distance are important. The height and proximity of the proposed Potter’s Field development will have a much greater impact than existing development south of the river.

Impact on the protected strategic view of St Paul’s Cathedral from Blackheath Point

    1. St Paul’s Cathedral is of international significance and one of only two buildings in England that enjoy view protection. Designated Strategic Views are of national importance. Views should be “enhanced where possible” and regional and local plan policy is that development which “encroaches above the development plane” should normally be refused. The view of the dome and western towers of the cathedral from Blackheath Point is unobstructed and is not hemmed in by tall buildings. Development around the base of the cathedral combines to form a neutral dark grey plinth, contrasting with the whiteness of the Portland stone of the cathedral itself. Whilst the proposed towers do not obscure any part of the cathedral, they do harm its context by introducing a group of eye-catching structures immediately below the cathedral in the view.

    1. The width of the Viewing Corridor and the prescribed AOD height are not arbitrary measurements but are the result of considerable thought and study to provide a clear framework for managing development that may harm the view of the symbolic heart of London. All of the proposed development is within the viewing corridor and four of the towers rise above 50 AOD. The policy position is clear; such development should normally be refused.

Impact on the setting of Tower Bridge

    1. Tower Bridge is a Grade I building of international renown, which truly deserves the epithet ‘iconic’. It is one of London’s best known landmarks and it dominates all around because of its form and height; a height which is not challenged close by. It has become an accepted neighbour to the Tower of London and, owing to its medievalising style, it is perhaps considered by many to be integral and perhaps contemporary with the Tower of London. The proposed development at Potter’s Field challenges this supremacy, owing to its height, the mass of the combined eight towers, the striking nature of the design and the highly reflective materials of stainless steel and glass. The Inspector at the Royal Opera House inquiry (CD14/4 para. 20.21) concluded that that proposal “in terms of its height, well related to Tower Bridge”, whilst the designer of that scheme “felt that the height of the crenellations of the south entrance portal [of Tower Bridge] represented a target height which we should seek not to exceed” (Ian Ritchie Proof of Evidence para. 3.11) (appendix 13).

    1. View 5 (montage 2) of the Urban Design, Conservation & Visual Assessment show how the proposed new development will compete for attention with Tower Bridge and view 21 shows how the south portal of Tower Bridge will be lost against the backdrop of the proposed development. A more appropriate form of contextual development on the site should make the transition from the c50m maximum height of More London and City Hall to the c30m maximum height of the warehouses east of Tower Bridge and in so doing would form a more fitting neighbour to Tower Bridge. This scheme is not a good neighbour, and the policy framework for safeguarding the setting of listed buildings, here a Grade I building (the top 3% of listed buildings), in my opinion suggests that permission should be refused.

Impact on the setting of Lambeth College, Tooley Street and other listed buildings

    1. PPG 15 and local plan policies seek to protect the setting of listed buildings from unsuitable development. Lambeth College is a handsome Grade II listed building of strong character and presence, relating well to the buildings to the south that enclose this city space. However, it cannot hold its own against a development set immediately behind it which rising to more than three times its height. The juxtaposition of the scale of the listed building and the scale of the proposed development is extreme. From being a bold marker on Tooley Street it would become a diminutive incident, eclipsed by the great scale and presence of the development behind. Foster & Partners 1998 Masterplan for More London acknowledged the transition in scale from the lower buildings on Tooley Street to the higher buildings fronting the expanse of the river. The proposed development presents a cliff face to Tooley Street and steps down towards the river, reflecting the obvious need to maximise residential views of the river at the expense of good townscape context.

    1. Lambeth College relates to the city space that includes other listed buildings, the National Westminster Bank and the statue of Samuel Bevington, as well as unlisted buildings that contribute positively to the Tower Bridge Conservation Area. Their setting too would be harmed by the sheer scale of the proposed development of the Potter’s Field site. The Bridgemaster’s House is also listed grade II. In his proof of evidence for the Royal Opera House inquiry Ian Ritchie wrote “I considered it important to maintain space about this building by not coming up too close to it”. The current proposal comes up to less than 12m from Bridgemaster’s House and will be about two and a half times the height of the then proposed theatre.


    1. The Potters Field site sits in a highly sensitive location, with the fortress of the Tower of London World Heritage Site across the River Thames and the grade I listed Tower Bridge close by. Fortress, bridge and river together form a cultural site that more than any other says ‘this is London’. Just to the north east of the development and to the east of the site is one of the most evocative remnants of narrow streets and warehouses redolent of London’s great docks, Shad Thames. In my view the Potters Field site requires a development that will “successfully reconcile the complexities of the site, including its relationship with the Thames, adjacent listed buildings and conservation areas, and the context generally” (Potters Field Planning Brief paragraph 7.1 CD5/19).

    1. The proposed development before this inquiry introduces a form of development alien to the existing context, eight separate towers, in a landscape setting, rising above all other development in the area. Four of these towers break through the development plane of the protected strategic viewing corridor of St Paul’s Cathedral from Blackheath Point. The eight towers will undermine “the unique status and dignity” of The Tower of London World Heritage Site and harm the setting of this Grade 1 listed building. The combined effect of the eight towers will undermine the iconic status of Tower Bridge, also a grade I listed building and the second most visited tourist attraction in the capital. The development has a devastating impact on Tooley Street and the setting, in particular, of the grade II listed former Lambeth College.

    1. The Potter’s Field site is of the utmost importance to London, in heritage terms and as the last link in the chain of regeneration of the former docklands on the south side of the river in central London. It demands a development of quality to stitch in a seamless link between the diverse character of its neighbours. In the words of the Inspector for the Royal Opera House inquiry, it demands a design “of strong and restrained character” (para. 20.21, CD14/4). The Inspector also wrote that “a markedly flamboyant design on the application site might be ‘overegging the pudding’.” (para. 20.20). What is proposed here is too big and too striking to be an appropriate infil of this, last and most sensitive of riverside sites and to make the transition between the scale and character of the carefully considered More London Development and the scale and character of the archetypal ‘historic docklands’ environment of Shad Thames. I would ask the Inspector to recommend to the First Secretary of State that these appeals be dismissed.

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