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Consultation on Historic England’s updated tall buildings advice
Tall buildings have become an increasingly common and sometimes contentious feature of the planning system. They can successfully fulfil a number of roles such as contributing to housing provision, improving townscape and acting as landmarks. Their contentiousness can arise from their effect on heritage assets and this is a common consideration in planning applications. Since Historic England’s advice on tall buildings was last updated more than four years ago in 2015, it is not surprising that the opportunity is being taken to review this as there have been changes to policy and the nature, location and number of applications for tall buildings. As noted in the draft advice, tall buildings are not a new feature and the definition of tall is relative; St Paul’s Cathedral was the tallest building in London for hundreds of years and the Eiffel Tower and Empire State Building were both at one time the tallest buildings in the world. St Paul’s Cathedral is now a key consideration of views management guidance and protection in London and so tall buildings, old and new, form part of our historic and built environment legacy. This is reflected in the statutory protection of key tall buildings through listing; examples include the Grade II* listed Trellick Tower and Grade II listed BT Tower in London and Grade II listed Rotunda in Birmingham. Historic England’s website states the updated advice will be issued in the summer and so it will shortly become a material consideration in many applications for tall buildings and Historic England (HE) officers will inevitably use it as a guide when giving pre-application advice or responding to planning applications and local plan submissions as part of HE’s role. The consultation therefore gives an insight to HE’s approach in assessing tall building proposals and policies, subject to finalisation, and the advice will guide heritage professionals and decision makers throughout England. The following are some key points to be aware of in the draft updated advice and our commentary on where it could go further. 1. Case studies of historic cities Probably one of the most noticeable developments in tall building proposals in recent years is that they are no longer the preserve of London. Rightly so, the draft advice recognises this and makes reference to examples outside of the capital. However, the key case studies in addition to London are Oxford, Cambridge and York. Although these are key historic cities, they are not representative of the variety of historic areas and buildings across the country. Practical case studies of successful examples of tall buildings would have been helpful. 2. Expansion of the scope of what constitutes a tall building? The reinforced assertion in the draft advice that whether or not a building is considered tall and the threshold for this depends on the local context, is welcome and allows for clarification and definition in local plans and policies. However, the same section of the consultation refers to “a building in a hill-top location, or on the crest of a ridge of higher ground, may gain prominence and an appearance of height.” This suggests the advice relates not only to tall buildings but those in high or prominent locations. This particular advice note does not seem the appropriate place for such buildings; Historic England already has guidance on the effects of development on the setting of heritage assets and such buildings would be appropriately considered through the methodology this promotes. There are unique considerations and effects that tall buildings bring, that those in prominent or high locations do not; the two should be distinguished. 3. Increased emphasis on the importance of design, context and of a plan-led approach This reflects the increased focus on these areas in national guidance. A plan-led approach and definition of tall building zones, which consider the effects on heritage assets, provide greater clarity to decision-makers, developers and residents and can help ensure sensitive development in the historic environment. However, as these issues, such as the components of good design, are dealt with at length in other guidance, they could be cross-referred in the advice rather than considered in detail. HE’s recommendation that there should be criteria to assess speculative proposals in places where tall building development is likely, but there is a lack of allocations or areas identified for tall buildings, seems pragmatic. 4. The role of technology The draft advice refers to the increasing range of technical tools that can assist all stakeholders in assessing tall building proposals, such as 3D models. Until fairly recently this type of analysis was mainly requested by councils in central London but now is an increasingly common request elsewhere. Advice on when such tools are likely to be required would be helpful, to be proportionate to the scheme and potential effects. The draft currently makes a blanket suggestion for the use of 3D models, virtual reality headsets and Accurate Visual Representations, but these will not be necessary in all tall building cases; a ‘tall’ building in some contexts will be relatively low and can be understood from application drawings, photographs and technical analysis. This could be better framed in the guidance as ‘where available/ appropriate’. Which leads on to… 5. A missed opportunity to emphasise proportionality in assessment and approach The consultation makes reference to proportionality but this could be emphasised further. HE’s advice on assessing effects on the setting of heritage assets has a helpful reference to the importance of scoping to minimise the need to assess very large numbers of heritage assets, including for tall building proposals; reinforcement of this approach would be particularly helpful in this advice note. Tall building assessments clearly have the potential to cover a wide area and repetitive and unnecessary assessment is not in anyone’s interest. A well-considered scoping exercise with the local authority can ensure that assessments are targeted and focused on where the important effects are likely to take place, aiding informed decision-making.  This also relates to the level and amount of supporting information which is required to accompany applications, particularly when the number of technical tools is increasing. Summary Overall, the draft advice should be seen as an evolution of Historic England’s position. There are still opportunities for the advice note to provide more specific and practical advice, particularly in the section on assessing proposals, to ensure the sector has a proportionate and comparable approach. The space dedicated to checklists for applications and design considerations, which are covered in numerous other places such as policy and validation requirements, would be better spent on targeted historic environment advice that can be used as a practical guide by all those involved in the design and assessment of tall buildings. The increased focus on the role of development plans in relation to tall buildings – notably with regard to a strong evidence base - indicates that Historic England recognises that tall buildings are here to stay, and that the response needs to be led at a local level to ensure tall buildings can make a positive contribution to the built and historic environment. The combination of a plan-led approach, focus on design and proportionate and informed assessment supported by the most recent technology where necessary, should result in just this.

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Power to the (West Yorkshire) People!

Power to the (West Yorkshire) People!

Tabitha Howson & Adam Jackson 03 Apr 2020
After more than five years of debate, on the 13th March 2020 the proposed terms of…a £1.8bn devolution deal between the government and the local authorities of West Yorkshire[1] and the West Yorkshire Combined Authority were published. In line with devolution agreements for Greater Manchester, Liverpool, Sheffield Teesside and the West Midlands, the deal will devolve a range of powers and responsibilities to the West Yorkshire Combined Authority, including new powers on housing and planning along with a new, directly elected West Yorkshire Mayor. This blog provides a summary of some of the key points in the Devolution Deal as well as lessons that can be taken from similar deals in neighbouring Mayoral Authority Areas. The Powers and Funding The planning and housing powers to be transferred to the West Yorkshire Combined Authority are in keeping with the powers for other established combined authorities, and include: The preparation of a statutory Spatial Development Strategy for West Yorkshire; Mayoral land assembly and compulsory purchase powers; The power to designate a Mayoral Development Area and to create Mayoral Development Corporations to support the delivery of housing on strategic sites; Eligibility to bid for a newly established Brownfield Housing Fund with a £400m envelope; and, The establishment of a Strategic Place Partnership with Homes England supplemented by £3.2m in government funding across 2020/21 and 2021/22 to support development of a pipeline of housing sites across the region; A significant funding package for specific projects has also been announced as part of the deal which includes: £317m to invest in public transport, cycling and walking through Transforming Cities Fund; £500,000 to support master-planning in Bradford City Centre to maximise regeneration opportunities from Northern Powerhouse Rail, and funding for the next stage of development of the Outline Business Case for Leeds station redevelopment; A £25m Heritage Fund towards the development of a ‘British Library North’ in Leeds and, A five-year integrated transport settlement starting in 2022/23 and exploring the case for West Yorkshire Mass Transit. British Library North A key part of the deal is the £25m Heritage Fund in recognition of West Yorkshire’s ambition for the conservation and re-use of heritage buildings. The fund will be provided by the Government to support the work of Leeds City Council with the British Library in establishing a potential ‘British Library North’. If successful, the move would also come as part of a wider plan to mark Leeds' year of cultural celebration in 2023. Leeds is already home to the British Library Depository, Archive and Reading Room at Boston Spa. The preferred location for the move has been identified as Temple Works in Temple. The Grade I listed building lies at the heart of proposals for the South Bank Leeds regeneration area. The building is controlled by CEG, and Lichfields has been working with CEG for a number of years on wider regeneration proposals at South Bank, including securing consent for a £350 million mixed-use development at Globe Road. Leeds City Council is now working with British Library and CEG to explore the future potential of the building and develop plans for the new library. Innovation District The aim for the Innovation District, located in Leeds City Centre, is to create a world-class hub for research, innovation and entrepreneurialism in priority sectors that delivers transformational economic growth for the City Region. The District is home to a number of world class teaching, medical and research institutions, including Leeds Teaching Hospital Trust, University of Leeds, Leeds Beckett University and Leeds Arts University. A notable inclusion is the Leeds General Infirmary and the recently approved £450 million ‘state of the art’ adults’ hospital and children’s hospital for which Lichfields helped secure planning permission last year. The devolution deal outlines that the West Yorkshire Combined Authority and Government will establish a West Yorkshire Innovation network through the Connecting Innovation programme. This network will provide a dual-hub for the community of entrepreneurs, start-ups and SMEs within West Yorkshire. The hub will initially be secured through the presence of the NEXUS Innovation Centre at the University of Leeds and the Buckley Innovation Centre at the University of Huddersfield with further regional opportunities to be explored in the future. This network will bring together business support services from the Leeds Growth Hub, local Universities and Innovate UK. Lessons from Neighbours The devolution deal for West Yorkshire will see the combined authority join its northern neighbours, which have already agreed devolution deals and which have elected Metro Mayors (Greater Manchester, Liverpool City Region, Tees Valley, Sheffield City Region and North of Tyne). Indeed, 7 of the 10 mayoral combined authorities (including West Yorkshire) in England are located in the north in a clear signal of the governments intent to shift control of investment funds and development powers to the ‘Northern Powerhouse’. Lichfields’ has a breadth of experience of working in these regions and has performed a key role in responding to the development of emerging Spatial Frameworks on behalf of clients. Through this experience we have identified a number of key issues which will need to be properly considered in the West Yorkshire Spatial Framework: The deal provides statutory plan making powers to produce a spatial development strategy for West Yorkshire. It will be interesting to see if West Yorkshire can avoid the delays in production of an agreed planning framework that has dogged Manchester, for example, whose spatial framework has seen several delays since preparation first began in 2014. There is a big focus on brownfield site release with £400m funding identified as part of the deal. Whilst this funding is welcomed to unlock difficult urban sites, there is a need to balance regeneration sites with the release of greenfield and even Green Belt sites where appropriate, to ensure that there is a steady delivery of land and reduce the risk of a delay should brownfield sites not be brought forward in time to meet identified needs. Greater Manchester has assumed that the entire Spatial Framework area is a single housing market area. However, sufficient evidence has not always been provided to justify the position and in some areas, a single HMA is not seen to accurately reflect the varying characteristics of different areas. This is no different for West Yorkshire which, as well as covering a large geographical area of some 2,000 sq.km, contains distinct and varied housing markets with significant contrasts in character and values. Finally, it is imperative that the West Yorkshire Spatial Framework is founded upon a consistent evidence base. It is inevitable that existing local authority evidence base documents will have adopted different approaches in reviewing baseline data and forecasting future needs, however there is a clear need for consistency when formulating the Regional Spatial Framework.    Conclusion The recently announced devolution deal will see a number of significant powers and funding transferred to West Yorkshire. The powers secured will give the combined authority greater flexibility to take decisions when addressing local concerns and needs. Lessons can be learned from deals in neighbouring authorities as well as the range of issues that would need to be considered in the West Yorkshire Spatial Framework. Careful thought is needed to ensure that there is a consistent evidence base when formulating the framework and ensuring that a flexible approach is taken when assessing the varying needs and characteristics across the region. However, without a doubt, the Devolution Deal presents a great opportunity for West Yorkshire to build on its strengths and unlock the area’s latent potential for well-planned economically sustainable growth.   [1] Comprising Bradford, Calderdale, Kirklees, Leeds, and Wakefield Councils Image credit: Tim Green 

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