Against High Rise Buildings

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Andrew Boff AM
Chair of the Planning and Regeneration Committee
2 September 2021
Dear councillor,

Housing typologies investigation findings

In Autumn 2020 the Planning and Regeneration Committee conducted an investigation
into COVID19, Housing Typologies and Design in London.

A key emphasis was on housing density and thedevelopment of tall buildings for residential use in London.

As Chair of the Committee, I wanted to write directly to local councillors to share our findings from this investigation, which I hope you will find of interest and relevance to your work. This letter may
have particular interest for those with planning responsibilities or those commenting on local
planning applications.
This letter discusses the following issues:
• The costs of tall buildings
• Density
• The impact on families
• Quality of design
• Post-COVID 19
Our key finding is that the Committee does not believe that tall buildings are the answer to
London’s housing needs and should not be encouraged outside of a few designated and
carefully managed areas.


At our Committee meeting on 21 October 2020, we heard oral evidence from the following experts:
Yolande Barnes, Chair of the Bartlett Real Estate Institute at University College London (UCL);
Professor Philip Steadman, from the UCL Energy Institute; Matthew Carmona, Professor of Planning
and Urban Design at The Bartlett School of Planning at UCL; Jo McCafferty, Director at Levitt
City Hall
The Queen’s Walk
More London
London SE1 2AA
Tel: 020 7983 4000
Bernstein; and Michael Ritchie, Place Shaping Team Leader at the London Borough of Tower
Our investigation also formed the basis of our response to the ‘Good Quality Homes for All
Londoners’ Supplementary Planning Guidance (SPG) public consultation which closed in January
2021, in which we focused on the ‘tower’ housing type.

The costs of tall buildings

During the Committee investigation, we heard about the relationship between high building density
and building and maintenance costs, including how the whole life-cycle costs of tall buildings are
not always fully considered at the development stage. Servicing tall buildings can be costly and this
often results in high service charges to residents. High management costs and service charges often
preclude affordable tenures, and well-designed family homes are harder to achieve as they are
remote from shared amenity space. Jo McCafferty told us that there is a direct relationship between
density, but specifically tall buildings and high cost. Drawing on the Tower Hamlets experience,
Michael Ritchie reflected that tall buildings are a “system and they need constant maintenance and
they need to be efficiently run”.
Professor Philip Steadman told us about a study conducted by UCL1
a couple of years ago into tall
office buildings, mostly in London that found the increase in storeys from six storeys to 20 doubles
the energy intensity per square metre
. As set out in the Committee’s subsequent SPG consultation
response, energy use is higher in tall buildings, with electricity use twice as high due to increased
solar gain, as well as other conditions prevalent at higher altitudes, including more wind and colder
temperatures. The taller the building, the higher the amount of embodied energy required per
useable square metre as low-carbon materials such as timber are not viable. Tall buildings also suffer
more from heat loss for the same amount of insulation as lower buildings because of the higher wind
The Committee finds there is a growing evidence base demonstrating that tall buildings are less
sustainable than those which provide a similar quantum of development in other configurations. The
Committee advocates that the long term and lifetime costs associated with tall buildings should be
carefully considered in development proposals. It particularly believes the development of towers
should only happen after robust evidence has been presented about how their social impacts will be


The Committee is of the view that proposals for tall buildings should be required to demonstrate that
other building configurations, which would achieve similar densities, have been considered. During
the investigation, Matthew Carmona indicated his view that up to a medium density of 56 dwellings
per hectare better enables access to local facilities within a neighbourhood. The Committee has
specific concerns relating to density, and has called on the Mayor to distinguish between high
density and ‘superdensity’ (above 350 dwellings per hectare) in the final SPG. The Committee also
1 UCL Energy Unit’s ‘High-Rise Buildings: Energy and Density’ project which ran from 2015-2017
takes the view in general that bed spaces per hectare is the most appropriate way to measure

The impact on families

The Committee is concerned that while delivering higher densities may seemingly make more
effective use of land, tall buildings will not produce the high-quality homes and neighbourhoods
that London needs. During the investigation, Matthew Carmona said that “… in general families are
disadvantaged if they are living in tall buildings. The sociability that children are able to gain in
terms of opportunities for play, for meeting others and so forth within tall buildings is often not
Furthermore, Jo McCafferty expressed that “direct access to external space for families is absolutely
crucial to the successful and healthy functioning of that household and that becomes incredibly
difficult with tall buildings.” She explained that a high-density, medium- to low-rise model can work
more easily for families, enabling communal or individual gardens at lower storeys that are closer to
individual family homes than tall buildings allow. She said “There are lots of opportunities whether it
is in higher-density development or even medium-density development where those opportunities
with social spaces for children and children of all ages, in fact, to gather in small groups is really
Following research conducted within Tower Hamlets, Michael Ritchie reflected that opportunities to
make other parts of buildings playable, as in the public realm around entrances, have been
considered within the Tower Hamlets High Density Spatial Planning Document2
. He commented that

the tall buildings guidance in Toronto and other international examples had also informed the
Borough’s design guidelines. Professor Steadman similarly described the case of San Francisco where
there is a “general limit on height of about 12 metres or four to five storeys” and where a height limit
is driving developers to “find ingenious ways of achieving high density other than tall buildings.”
Tall buildings tend to contain a majority of mainly studios and one- beds, and a proportion of twobedroom flats, resulting in a lack of family-sized housing and poor use of space. The Committee has
long advocated for more family-sized housing to be built in London but believes that family homes
in tall buildings are only appropriate with certain design measures in place, for example access to
amenity such as play space and suitable positioning within a development. The Committee is of the
view that families should not be housed above the fifth floor in public housing, and that
consideration should be given to design of access and surveillance of children’s play space and
amenity space for children in relation to tall buildings. Overall, it believes that high density housing
can be achieved by approaches that are more suitable for families, more in keeping with London’s
traditional form, and are less intrusive on the skyline.

2 Tower Hamlets Borough Council, High Density Living Supplementary Planning Document, December 2020

Quality of design

In its investigation, the Committee heard about the importance of building mixed environments that
combine different housing densities. Professor Yolande Barnes expressed that “The characteristic
and experience of a neighbourhood is a very complex thing. It has to do with street layouts, the
space syntax… the global connectedness, right down to access to amenities, the ability to work from
home, exercise, socialise and so forth.” She conveyed that street design has a “profound impact on
(a) your ability to achieve mid-rise density and (b) how it is then experienced by people.” Similarly,
Michael Ritchie told us about the holistic nature of housing quality – the building, residential quality
and contribution to surroundings. He commented that there “should be standards, metrics and
things that we can measure, but it is also how all these things work together to produce a place.”
The Committee also heard comments about the contribution of Design Review Panels, such as Urban
Design London (UDL)3
and Mayor’s [Design] Advocates4
. It was the opinion of Matthew Carmona

“The huge success in London has been design review and the spread of design review over the
last 10 years with increasingly more professionally run panels in local authorities giving advice to
planning authorities.” He also drew attention to the Place Alliance’s5
‘Home Comforts’ report6

published in October 2020. Based on a nationwide survey of 2,500 households, it found a link
between “lack of comfort” and the age of the property. The newer the home, the less comfortable it
was found to be. He told the Committee the same survey found: “Those in social housing tended to
be less comfortable than those in private or private rental. Also, the higher you got off the ground,
the less comfortable you were in terms of your living environment and your happiness with your
neighbourhood.” While Jo McCafferty advocated the importance of amenity space being directly
connected to living space and being “big enough, robust and have the right outlook and
orientation”, including ‘acoustic privacy’ between and within homes.

Post-COVID 19

During the investigation, reference was made to housing standards in the light of the potential
changing context post-COVID 19, which the Committee also addressed in its consultation response.
Professor Philip Steadman commented that “One of the interesting things that is going on at the
moment with COVID is how the use of the existing stock is being transformed by people working from
home, by offices being emptied, by people planning to move out.” Jo McCafferty highlighted that
creating flexibility in housing design will be an important post-COVID 19 response. Although
Michael Ritchie warned against a “kneejerk reaction to design a new world based on COVID-19”,
Matthew Carmona said “our homes have to cater for a lot more different functions than they did in
the past, particularly space for many of us to work at home, either full-time or part-time. That is
something that we certainly need to be thinking about in London.” The Committee believes the
pandemic and the lockdowns that resulted have highlighted the critical importance of access to
greenspace, private outdoor space, outdoor play space, and adaptability needed for home working.
3 Urban Design London (UDL)
4 Mayor’s Design Advocates and Advocate Organisations
5 The Place Alliance is Chaired by Professor Matthew Carmona and hosted by UCL Bartlett School of Planning. It
increasingly has a campaigning role and “provides a forum for its supporters to come together, debate and work towards
raising the national consciousness regarding the importance of place quality”
6 UCL, Place Alliance Launches New Report: Home Comforts 28 October 2020
Overall, the performance of tall buildings should be considered against the standards relating to
diversity and housing mix, and whether or not tall buildings are suited to meet London’s diverse
housing needs, particularly in respect of family and affordable housing and creating inclusive

We hope that these findings may be of use to you in your role as councillor. I would be very happy
to discuss our investigation and findings with you in more detail, should that be of interest.

Andrew Boff AM
Chair of the Planning and Regeneration Committee