Consultation draft

This advice note identifies the updates since the last published version from 2015 and sets them out below: 

Historic England published its consultation on its updated draft advice note to guide the planning and design of tall buildings on 4 March 2020, with consultation closing on 26 April 2020. This advice note identifies the updates since the last published version from 2015 and sets them out below: The introductory context text has been updated to advise that what is considered a tall building in one location (for example in a predominantly two-storey neighbourhood) may not be considered a tall building in another (for example in a city centre). Therefore, definitions of tall buildings need to be based on local context when local authorities are developing planning policy. Examples of realistic wording are taken from Oxford's and Cambridge's policies, which define tall buildings in the context of existing skylines or well known taller local buildings.

The role of Planning Practice Guidance and the National Design Guide has been added in the National Planning Policy section, and the recognition that these give to the importance of design responding to context and the positive role that tall buildings can play in the right context, providing their design has been well considered. The forthcoming publication of a National Model Design Code (expected during 2020) to support the NDG is also welcomed.

Paragraph 3.2 specifies the benefits of including tall building policies in local plans. Added to the previous advice note is the recognition that areas need to be identified that both are and are not appropriate for tall buildings. It has also been updated to show that when selecting sites for tall buildings, due consideration has been given to alternative sites and forms of development to meet local needs.

Paragraph 3.3 provides more detailed guidance than previously on the assembly of the evidence base for plan building, and how these can help, using evidence such as:

• Statements of heritage significance
• Conservation area appraisals
• Characterization studies
• Inter-visibility studies
• Urban design and townscape analysis
• Master-plans
• 3D modelling
• Views studies

The guidance then goes on to discuss what should be considered when assessing the suitability of land for tall buildings, such as conservation areas and heritage assets.

The guidance acknowledges the role of urban design frameworks, and in addition to the previous guidance supports the use of the master-planning process for areas of significant regeneration, and how this needs to consider heritage sensitivities. It promotes the use of 3D modelling at plan-making stage, and looks at the significance of taking in to account important views with emphasis on heritage assets.

Development plan policies have been included in this updated guidance note, whereas previously there was no mention of these. Policies which propose tall buildings should demonstrate that impacts on the historic environment have been considered along with alternative locations. SPDs are also identified as being important tools to help to deliver good design.

Locations for where tall buildings are appropriate will be the most effective way of ensuring plan led development, in particular in towns and cities where tall buildings are proposed or likely to come forward. Without site allocations, plans will need to have specific criteria against which proposals are assessed, to ensure that consideration is given to the historic environment. It refers back to paragraph 31 of the NPPF (proportionate evidence to justify the approach).

Where a regional plan is also in place, strategic level policies (and SPGs) relating to tall buildings must also be considered alongside managing strategic views.

The guidance gives specific information in relation to making a planning application, and what steps need to be taken as part of this process. These steps include consultation with the LPA, and other relevant parties such as Historic England (as specified in the NPPF paras 39 – 46), and the part that design review panels can play in assessing the impact of a proposal. It also discusses the use of Statements of Heritage Significance and Design and Access Statements. A checklist of documents for a planning application which involves tall buildings is provided, which notably now includes a World Heritage Site Impact Assessment where relevant, and a 3D model. 3D models and AVRs are now recommended to assist with assessing impact on the surrounding area. It also discusses various considerations in relation to design quality, pointing out the ability of well designed tall buildings to provide an inclusive environment, with improved permeability and accessibility. The possibility of enhancing unattractive tall buildings to reduce their negative impacts on the local area is also acknowledged.

Of significance is the mention of ensuring that planning applications have considered the longevity, sustainability and viability of taller buildings, including the ability for future retrofitting. Fire safety considerations in older tall buildings also, understandably in the light of the Grenfell Towers disaster, receive a mention.

When assessing planning proposals, HE make reference to their Good Practice Note 2 (Managing Significance in Decision Taking). The guidance also discusses particular issues in relation to tall buildings proposals. These include:

• quality of design
• the need to improve an area's character and quality
• conserving and enhancing the historic environment
• the importance of input from a range of technical specialists (urban designers, heritage advisers)
• site visits, especially where heritage assets are likely to be impacted
• the use of technology in assessing impacts (3D, virtual reality).