Historic England published revised guidance on tall buildings on Friday 4th March 2022. The purpose of ‘Historic England Advice Note 4’ (HEAN4) is to provide advice on planning for tall buildings within the historic environment. The document supersedes a 2015 iteration that itself was seen as a replacement for the 2007 guidance jointly authored with CABE.
HEAN4 is a constructive document written in a positive tone e.g. permissive of development rather than restrictive. Historic England positively acknowledge the role that tall buildings have to play in delivering sustainable development, whilst also highlighting that they can also be of heritage value themselves – see Centre Point in London, or Alpha Tower and Rotunda in Birmingham. There are also some notable omissions in the guidance that may either present missed opportunities or, hopefully, areas to be evolved in the future.
It seeks to champion best practice planning processes and exemplar schemes to guide stakeholders towards a better outcome for the historic environment. Stakeholders, and in particular local planning authorities, will find guidance within it for the preparation of development plans and navigation of the development management process.
Some key themes and notable inclusions in this new version include:
1. Greater emphasis on a plan-led approach towards identifying suitable locations for tall buildings.
This follows guidance in the 2021 National Model Design Code and the benchmark set by locational requirements of the 2021 London Plan policy D9. The offshoot of this is that developers will be encouraged to, and should, proactively engage with the development plan preparation process to ensure sites are recognised as suitable for tall buildings at the application stage.
The London test case has already proven that the time and resource required by local planning authorities to prepare an evidence base and adopt these policies is incredibly absorbing. Moreover, even when adopted, policy relating to locational requirements for tall buildings must acknowledge that the evidence base for such designations may require updating and/or are often based on a high level of analysis rather than detailed building design. In short, taller schemes could still be justified at the application stage, notwithstanding if a site is not identified as suitable in the development plan.
2. Setting out the evidence required by local planning authorities to undertake a sieving process to identify appropriate locations for tall building (see appendix 1).
This is an incredibly helpful checklist to ensure greater consistency between authorities when preparing a tall building policy.
3. A checklist to inform the drafting of tall building policies within the development plan.
In the absence of existing tall building policies, this also forms criteria that local planning authorities may draw upon to assess tall buildings (see checklist 1). Again, this list goes towards quality and consistency of drafting to ensure policies are “sound” as required by the 2021 National Planning Policy Framework (NPPF). It will be particularly helpful for authorities that have had very little previous exposure to tall buildings applications and do not currently have sufficient policies in their development plan.
4. Recommendation to explore alternative forms of development to deliver high density development.
It cites reasons to achieve this objective as paragraph 32 of the NPPF and, where an Environmental Impact Assessment (EIA) is required, paragraph 2, Schedule 4 of the Town and Country Planning (EIA) Regs 2017. Applicants will be encouraged to model, test and assess alternative forms to understand whether they are more or less impactful to sustainable objectives (economic, social and environmental), in particular to the setting and significance of heritage assets.
In my experience options testing is something that is rightly already being undertaken; however, now all applicants will be encouraged to undertake this process from feasibility through to the application submission stage. It will also require proper and transparent documenting within the application submission pack.
The guidance also highlights tools that can improve transparency and aid decision making. Examples recommended as best practice include: presentation of schemes to design review panels, provision of both fixed and kinetic views, and undertaking zone of theoretical visibility studies to understand extent of visual impact.
Finally, it’s worth nothing that this guidance is informed by a 2021 research document prepared by a Birmingham-based practice, Node, titled ‘Assessing the Impact of Tall Buildings on the Historic Environment’.
Recommendations made in the Node document which are not included in HEAN4 offer an insight into future guidance that could add significant value. Of note, the Node document suggests “Historic England should coordinate with partners to better standardise best practice processes for impact assessment and tall buildings”. In doing so, it “could engage with the Landscape Institute to examine closer collaboration between landscape and heritage professionals and their assessment methods, including promoting the use of standardised assessment matrices”.
In my opinion this recommendation – to standardise processes, including assessment matrices – would help remove or reduce much disagreement between stakeholders during the development management process.
Ultimately, difference in professional judgement regarding heritage impacts would remain but matters between parties would narrow. In turn, this could reduce significant resource drains at pre-application, post-submission and, in a worst-case scenario, appeal stages.
Reaching a consensus on standardisation would, of course, take time due to consultation with multiple stakeholders. I therefore hope that this is a work-in-progress, as opposed to an omission and missed opportunity. This is a valuable exercise that would help the objectives to make the planning system more efficient and achieve more responsive designs.
Image from Cityscape Digital. Existing and consented (shown as photorealistic renders) tall buildings on the Isle of Dogs skyline from Greenwich