Design Tall Buildings and Historic Environment

8/13/2019 Design Tall Buildings and Historic Environment

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1. Is the CAAP approach to tall buildings clear, consistent andbased on credible evidence / research? Are the boundariesfor tall building clusters appropriate?

Relevant r epresentat ions:

• 000017/00004/008 (English Heritage)

• 002959/00004/004 (Sackville Developments (Reading) Ltd)

• 004100/00001/017 (GVA Grimley on behalf of privateclients)

Relevant r epresentat ions on sit e al locat ions r epresentat ions:

None

1.1 The Tall Buildings Strategy prepared by Entec UK Ltd is based on

considerable research and evidence. This includes assessments oftownscape, topography, open space, flooding, historic assets andconservation. For example, one of the matters that were thoroughlyassessed for the Tall Buildings Strategy was the historic context ofthe central area. The results of that analysis are summarised atSection 4.5 of the Tall Buildings Strategy (Bac005) and Section 1.3 ofthe updated City Centre Framework (Bac004). These sections need tobe read together. The Tall Buildings Strategy contains more focusedcomments and consideration of historical aspects as part of theindividual character area analysis that appears in Section 5 andAppendix 2. A fuller more detailed account of the history of the

growth and development of Reading is set out at the end of Appendix2 of the Strategy.

1.2 Detailed character area appraisals of the various parts of the centralarea were prepared taking account of a wide range of originalresearch and evidence. These character area appraisals took accountof the historic analysis and factors such as flooding. The appraisalswere also based on detailed visual assessments taken from a widerange of viewpoints. The assessment of viewpoints was aided by thebuilding of a digital 3D model of the central area, which was used by

the consultants to accurately consider the impact both in relationsurroundings but also for a wider area. The area appraisals, alongwith the various other evidence has informed the Tall BuildingsStrategy that forms the basis for the RCAAP approach to tall buildingsas set out in Policy RC13.

1.3 In addition, the council commissioned consultants separately toresearch and advise on the marketing and viability of tall buildings inthe central area. Knight Frank carried out focussed research on thelikely market for tall buildings in Reading in the future. Theconclusions were that the market for tall buildings in Reading will be

limited and involve relatively modest levels of floorspace andresidential units. This has helped to ensure that the study was



realistic and deliverable in relation to market factors and not solelybased on visual considerations.

1.4 The council believes that the RCAAP approach to tall buildings isclear. It is consistent with CABE and English Heritage advice on

producing tall buildings strategies and it compares well with variousbest practice. It is based on extensive and credible evidence andresearch.

1.5 The boundaries defining the areas within which tall building clusterswill be appropriate were derived from the 26 character areas thatwere defined as part of the strategy. These areas were definedthrough a thorough townscape analysis as set out in Section 4 of theStrategy. The boundaries generally reflect lines where the generalcharacter of an area changes. They are therefore appropriate indefining areas of different character in the Central Area. However,

inevitably, there is potential for instances where the line is somewhatarbitrary, where the change in character between areas is notmarked or where it runs through what might be called a zone oftransition between areas of differing character. A case in point is thesouthern boundary between Character Areas 1 and 3, which hasbecome the boundary of the Station Area Cluster (RC13a). This isreferred to in the representations made by Sackville Developments.

1.6 Sackville are seeking a change in the alignment of the boundary inthis location in order to slightly extend the area which has been

defined as appropriate for tall buildings in the Station Area Cluster.The Council requested an assessment of the proposed change fromEntec UK Ltd, the authors of the Tall Buildings Strategy, to determinewhether, had the original character area boundaries been drawn tofollow the line suggested by Sackville, the conclusions of the Strategywould have been any different. A copy of Entec’s assessment of thisproposed change is included at Appendix 1. Their conclusion is that,in this instance, there would be no harm as a result of moving theboundary of the area by a small amount as there transition betweenCharacter Areas 1 and 3 in this location is not clear-cut. Theboundary is shown along the south side of Garrard Street, which

represents the bottom of the change in levels down from Friar Streetto the south. There is a zone of transition between the character ofproperties fronting onto Friar Street and the generally poor blockyenvironment along Garrard Street. The conclusion is that a relativelyminor change in the boundary in this location will have littleconsequences. The Council therefore considers that, should theInspector be minded to accept the change proposed by Sackville, theresulting policy will be sound, and will continue to be based on robustand credible evidence.

1.7 As far as the Council is concerned, the other boundaries definedistinct changes in character and are therefore wholly appropriate.



2. Do the Council’s proposed changes make the guidance onmaximum height clear?

Relevant Submi ssion r epr esent at ions:

• 002634/00004/007 (GOSE)

Relevant r epresentat ions on sit e al locat ions r epresentat ions: None

2.1 The Council considers that the proposed changes B23, B24 and B25(see the Schedule of Suggested Minor Changes, Exa006) clarify theguidance on maximum height. The Tall Buildings Strategy was basedon commercial building storey heights, which tend to be slightlyhigher than residential storeys, and it makes sense to reflect this inthe policy. It is also accepted that there could have been confusionover whether the policy on RC13b referred to the maximum existing

or maximum acceptable heights around the station, and the proposedchange B24 should now resolve this. It should be noted that GOSE(the original objector on this issue) has commented that it is contentwith the changes proposed (see Exa010).

3. Is the approach to tall buildings sufficiently sensitive tohistoric buildings in the central area?




None

3.1 As indicated in response to question 1 above, considerable researchwas undertaken and evidence gathered on the historic environment inpreparing the Tall Buildings Strategy. The preparation of the Strategyfully considered the historic environment of the central area.

3.2 The Tall Buildings Strategy was based on assessments of townscape,topography, open space, flooding, and historic assets andconservation. The historic context of the central area was fully

researched as a separate task in the preparation of the Strategy. Theresults of that analysis are summarised at Section 4.5 of the TallBuildings Strategy and Section 1.3 of the City Centre Framework. TheTall Buildings Strategy contains more focussed comments andconsideration of historical aspects as part of the individual characterarea analysis that appears in Section 5 and Appendix 2 of the study. Afuller, more detailed account of the history of the growth anddevelopment of Reading, particularly Central Reading is set out atthe end of Appendix 2 of the study.

3.3 Detailed character area appraisals of the various parts of the central

area were prepared taking account of a wide range of originalresearch and evidence. These character area appraisals took account



of the historic analysis. The assessment of impacts on the historiccharacter of the Central Area from particular viewpoints was aided bya digital 3D model of the central area, which was used by theconsultants to accurately consider these impacts on the historicenvironment and individual historic buildings.

3.4 The results of the strategy have been carefully taken forward intopolicy RC13, including criteria in sub-section (iii) and (iv) on keyviews, and requirements at sub-section (v) relating to the historicenvironment and the surrounding urban context.

3.6 In the view of the Council, the approach to tall buildings both interms of the preparation of the Tall Buildings Strategy and therequirements of Policy RC13 has been highly sensitive to historicbuildings in the central area.

4. Is it appropriate for the station tall buildings cluster to be thesouth rather than the north of the station? Should it beextended to include Friars Walk?




• 002979/00004/002 (Morley Fund Management)

4.1 The Station Tall Buildings cluster area is intended to encompass sites

both to the north and south of the Station and main railway line.While the area to the south is already occupied by tall buildings andis closer to the centre of Reading, the intention of the RCAAPstrategy is to extend the centre to the north of the railway. Thevision is that tall buildings will occupy the sites immediately to thenorth and south of the Station. English Heritage have maderepresentations that in their view it would be better to develop tallbuildings to the north of the station rather than to the south as thiswould reduce the risk of detrimental impacts on heritage features.The Council accepts that the historic environment is an importantconsideration in terms of potential impacts but that achieving theoverall strategy for the regeneration and development of the ReadingCentral Area, involves a wide range of considerations. In addition, tallbuildings in themselves can be sensitively designed and developedwith little adverse impact on heritage features.

4.2 The Council has long believed that tall buildings will be appropriateon sites both north and south of the station, including in the Council’sCity 2020 Vision (Pla007) in 1999. Tall buildings are currently a realityin the part of the cluster south of the station, although some are ofpoor architectural quality. The Council continues to consider that

north and south of the Station are appropriate for tall buildings,



although each has different sensitivities that need to be considered inany detailed design.

4.3 The first consideration, as indicated in the RCAAP Background Paper(Bac001), is that the areas north and south of Reading Station are two

of the most accessible and therefore most sustainable locations in thewhole of the UK. Reading Station gives direct access to over 350destinations. The sites will be even more accessible once ReadingStation is upgraded after 2011. This extremely high level ofaccessibility needs to be maximised in terms of sustainability. Itprovides an ideal location for intensive commercial and residentialdevelopment and almost demands that adjacent land is used asefficiently as possible, within the context of other materialconsiderations.

4.4 The second major point is that the existing utilisation of land and

premises both north and south of the station is both very inefficientand in need of urgent regeneration. The area to the north of thestation comprises generally single storey sheds accommodating a postoffice sorting office and a retail park. Along with the emergingproposals for the upgrading of Reading Station, this area will be anarea of significant change in the near future.

4.5 South of the station are a series of 1960’s and 1970’s developmentsthat have passed their useful life and are now run down and dowdyand in urgent need of regeneration. They have a severely detrimental

impact on the rest of the town centre and provide a very poor imageto visitors to Reading and central Reading exiting the station orarriving by bus. Without redevelopment, the area will continue todeteriorate and blight not only the station area, but also the widerarea south of Friar Street.

4.6 Thirdly, both the areas to the north and south of the station havevery high existing use values. To the north of the station, althoughvery inefficient, the existing retail uses have a high existing use valueand the comprehensive, sustainable redevelopment of this area in themanner envisaged in the RCAAP will need to generate significant

values to be viable. That suggests an intensive form of development.To the south of the station, there is already a considerable amount ofcommercial floorspace that needs to be removed (a very expensiveoperation in itself). Allied to its superb location, the existing usevalue is very high. The comprehensive, sustainable redevelopment ofthis area will need to generate significant values to be viable. Thatalso suggests an intensive form of development as envisaged in theRCAAP.

4.7 As previously set out, the Tall Buildings Strategy has undertaken awide-ranging analysis of the suitability of all areas within the centreof Reading for tall buildings, including impacts on the historic



environment. The balanced conclusion of that strategy is that sitesboth north and south of the station are appropriate for tall buildings.

4.8 In terms of Friars Walk, the issue raised by Sackville regarding achange to the boundary of the cluster in the vicinity of Garrard Street

by Friars Walk is dealt with fully in the answer to question 1 above. Aminor change in the boundary in this location is not viewed as beingdetrimental. However, Friar Street, onto which Friars Walk fronts, isof a very different character to Garrard Street and allied to levelsdifferences, it would not be appropriate to extend the area anyfurther southwards towards Friars Street or to incorporate the wholeof the existing Friars Walk.

5. Does it allow sufficient flexibility?


• 004100/00001/017 (GVA Grimley on behalf of privateclients)


None

5.1 Reading has been in need of a strong and proactive tall buildingspolicy for some time. The policy as submitted provides the strengthand certainty required to deal with the issue of tall buildings inReading. The alternative would presumably equate to reliance oncriteria based policy for tall buildings. Various alternative policy

approaches were fully considered and the proposals put forward byGVA Grimley for a more criteria based policy is similar to alternativeRC13 (viii). This is detailed along with reasons for excluding thisalternative in section C15 of the RCAAP Background Paper.

5.2 Commercial realities have informed the Tall Buildings Strategy andpolicy, through the market assessment prepared by Knight Frank(Bac006), and there is no evidence to suggest that there is likely tobe a commercial necessity for significant amounts of tall buildingsoutside the defined areas. Obviously, if there is evidence of a vastlydifferent commercial reality in future years, the matter can berevisited in any review of the RCAAP.

6. Does the CAAP provide sufficient guidance for balancing newdevelopment with the historic environment?


• 000017/00004/001

• 000017/00004/005

• 000017/00004/006

• 000017/00004/007

• 000017/00004/008



• 000017/00004/010 (all English Heritage)


None

6.1 Balancing modern, intensive development with the historic

environment is an underlying principle of the RCAAP that hasinformed the spatial strategy. It should be seen in this context ratherthan as something that needs specific policy guidance in thedocument. It has been a major component of the strategy of directingthe major development to the Major Opportunity Areas, which tendto be located away from the most historic areas in the centre (seefigure B5.3 of the RCAAP Background Paper). It has also informed thepolicies on the individual Major Opportunity Areas, which ofteninclude criteria on the historic environment and the character of thesurrounding built environment (for instance RC1 (vi)). In addition, ithas informed the designations of the Other Opportunity Sites, where,for instance, the need to reflect the height of the surroundingconservation area has informed the likely appropriate dwellingnumbers on sites in the Market Place.

6.2 In addition, all development in the central area will be subject topolicy CS33, which protects historic features and areas of historicimportance.

6.3 In more specific tall buildings terms, as indicated in the answers toquestions 1 and 3 above, the tall buildings strategy upon which the

RCAAP policy is based fully considered the historic environmentalcontext in reaching conclusions over which areas could and could notaccommodate tall buildings without undue detrimental effects. Theresponse to question 3 above sets out how Policy RC13 deals with thehistoric context in considering proposals for tall buildings. Theresponse to question 1 above outlines the range of considerationsrelevant to the role of tall buildings in the RCAAP and how theseconsiderations are balanced with the important priority of respect forthe historic environment. While, inevitably, the policy will be seen asan attempt to balance a number of competing issues, the council is ofthe view that the strategy fully considered the historic context in

terms of the areas that have now been taken forward fordevelopment for tall buildings and that the policy provides criteriathat gives appropriate guidance and considerable weight to thepotential impacts of tall buildings on the historic environment.

7. Is the CAAP consistent with CS Policy 33 with regard toprotection of features and areas of historic importance?



Relevant r epresentat ions on sit e al locat ions r epresentat ions: None



7.1 The Council considers that the RCAAP is entirely consistent with

policy CS33 of the Core Strategy, and it should be borne in mind thatthis policy will also apply to all development in the central area.

7.2 The concerns voiced by English Heritage seem to relate mainly to tallbuildings. The answer to question 3 sets out in full how the approachto tall buildings is sensitive to the historic environment. The wordingof the criterion in sub section (v) of policy RC13 requires that tallbuildings preserve and, where appropriate, enhance the setting ofconservation areas and listed buildings. This is consistent with therequirement in Policy CS33 that in relation to the historicenvironment ‘all proposals will be expected to preserve and enhancethe character and appearance of the area in which they are located’.



APPENDIX 1: TECHNICAL NOTE FROM ENTEC ON SACKVILLE’S PROPOSEDCLUSTER BOUNDARY CHANGE



Technical Note

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© Entec UK Limited

15 August 2008

Reading Tall Buildings Strategy: Characterarea 1 boundary change

1.1 Introduction

The purpose of this short note is to assess the proposal made by Sackville Developments to

change the boundary of character area 1 as defined by The Reading Tall Building Strategy 2008.

An assessment is made of whether the boundary change can be made without effecting the

judgements set out in table 5.1 of the Reading Tall Building Strategy (2008) which results in the

conclusion that the character area has a high suitability as a location for developing tall

buildings.

1.1.1 The proposed changes

The proposed boundary change is shown on Figure 1 below. It is proposed that the car parks to

the south of Garrard Street, and three other buildings also to the south of Garrard Street, move

from character area 3 to character area 1.

Figure 1: Boundary change proposed by Sackville

© Crown Copyright. All right s reserved. Reading Borough Counci l. Account No. 100019672. 2008



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1.2 Methodology

There are two sections to the methodology adopted for assessing the feasibility of the boundary

line change to include a greater area of land within character area 1.

1. Does the area of proposed change share the townscape characteristics of character area1?

When completing the ‘Reading Tall Buildings Strategy’ the central area of Reading was

separated into 26 character areas. The distinction between each character area was made based

on the following criteria:

• Architectural style

• Urban grain and townscape scale

• Presence of townscape designations;

• Townscape condition; and

• Key views.

The small area of townscape which it is proposed to move from character area 3 to character

area 1 is assessed against the above criteria and compared with the assessment made for

character areas 1 and 3.

2. Could the area of proposed character area change be judged to have a ‘high suitability’as a location for tall buildings, in keeping with the judgement made for character area 1?

The Reading Tall Buildings Strategy makes an assessment of suitability for tall building

development within all character areas judged to have capacity for tall buildings without an

adverse effect on the townscape character. This includes Character Area 1 which is judged to

have a low sensitivity to tall building development in townscape terms. The criteria used for theassessment of character area 1 are:

• Townscape Sensitivity to the inclusion of tall buildings

• Historical significance

• Surrounding historical sensitivities

• Key views within the character area

• Key views into the character area

• Tall Building Planning Applications

• Market demand

• Flood Risk

• Transport

• Suitability as a location for tall buildings



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© Entec UK Limited

15 August 2008

This technical note makes an assessment of whether the proposed boundary change would result

in a change to the overall suitability of character area 1 as a location for tall buildings, as judged

against each of the above criteria (see Table 2).

1.3 Rationale for boundary change1. Does the area of proposed change share the townscape characteristics of character area

1?

Table 1 below assesses the area of proposed change against the characteristics of character areas

1 and 3 in order to determine whether there are shared townscape characteristics between the

area of study and character area 1.

The table demonstrates that the area of proposed boundary change shares strong similarities of

townscape character to Area 1. In terms of architectural style, urban grain, townscape condition

and in terms of the absence of key views, the two areas share the same characteristics. The

topography does differ on Garrard Street where the road falls into a dip, but the topography

change is partially screened from view by surrounding built form. The differing topographydoes not result in a markedly different townscape character from Character Area 1.



Technical Note

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© Entec UK Limited

15 August 2008

Table 1

Character Area 1 Character Area 3 Area of proposed change

Arch itecturalstyle The architectural style ispredominantly 1970s.

Concrete is a widely used

material. Ramps andstaircases navigate the

awkward spaces and level

changes.

The street has beenredeveloped over many

decades and as such the

building frontage line has notbeen retained consistently

and the architectural style is

very varied. Some Victorian

facades remain above the

shop frontages but in manycases the architecture is

undistinguished.

All of the buildings within theproposed area of change are 1970s

style concrete and brick blocks.

Urban grain and

townscape scale

The large block size and

occasionally tall buildings,

the tallest being ThamesTower (11 storeys) and

Western Tower (17storeys) create a large

townscape scale.

The tightly packed buildings

and the relatively low skyline

(generally 4-6 storeys)creates a medium scale

townscape.

The buildings are all large blocks of

four storeys or more separated by

expanses of hard standing.

Presence of

townscapedesignations

No townscape

designations areapplicable to this area.

No townscape designations

are applicable to this area.

No townscape designations are

applicable to this area.

Townscape

condition

The buildings are

occasionally derelict and

all are either of a poorcondition or an

unexceptional design

quality.

The spaces between the

buildings are awkward

shapes and sizes and

poorly maintained. Theoverall effect is of a poor

quality townscape.

The buildings and public

realm along the street is

generally in good condition

Similarly to character area 1, the

buildings of this area are either of a

poor condition or an unexceptionaldesign quality. The spaces between

the buildings are awkward shapes

and sizes and poorly maintained

Key views within

the character

area

There are no key views

within this area.

Views along Friar Street

eastwards towards the

Market Place and St.

Lawrence’s church

There are no key views within thisarea.

Key views intothe character

area

Views of current buildingswithin the character areaare possible from the A4,

A327 and A33 when

travelling into the city.From the elevated positionof Caversham Park,Balmore Park and HorseClose, built form within thecharacter area contributesto the view of centralReading.

From the elevated positionof Caversham Park,Balmore Park and HorseClose, built form within the

character area contributes tothe view of central Reading.

From the elevated position ofCaversham Park, Balmore Park andHorse Close, built form within thecharacter area contributes to the

view of central Reading.. Thebuildings of this area do not formpart of any other key views definedby the Reading Tall BuildingsStrategy (2008). Within the ReadingTall Buildings Strategy the write upfor character area 3 refers to viewsalong Friar Street to St Laurence’schurch and the Market Place. Thebuildings within the area ofproposed boundary change do notform an element of this view as theyare hidden by built form along FriarStreet.



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© Entec UK Limited

15 August 2008

2. Could the area of proposed character area change be judged to have a ‘high suitability’

as a location for tall buildings, in keeping with the judgement made for character area 1?

As stated above, the area of proposed character area boundary change contains buildings with alarge block size, contributing to the large townscape scale. There is also an absence of any

historic townscape features, buildings in the area dating from the mid to late 20th

century. The

buildings within the area are not tall, but as the buildings do share an architectural style with the

area to the north, it is experienced as part of the general character area in which the tall Thames

Tower and Western Tower are located.

The area of proposed boundary change shares the characteristic of townscape to the north in

character area 1, of having narrow spaces between buildings which include ramps and hard

standing associated with the car park and access roads. These confined and dark routes

contribute to the poor townscape condition and restrict views out to the surrounding townscape.

The criteria used for assessing the suitability of character area 1 as a location for tall buildingsare set out below. For each criteria a note is made as to whether the boundary change would

result in an altered suitability judgement.

Character Area 1 as established inthe Reading Tall buildings strategy

Character area 1 includingadditional area proposed by

Sackville

Townscape Sensitivity to the

inclusion of tall buildings

Low: The large townscape scale and

the precedence for tall structures,

contribute to this area having a high

capacity for the development offurther tall buildings in terms of

townscape character.

As stated above, the area which

character area 1 would be extended

into shares the characteristic of large

townscape scale. This judgementwould therefore remain unchanged.

Historical significance Railway town and growth ofmanufacturing and commerce: post

1840.

Any tall building development should

be sensitive to the setting of the listed

station building and Great WesternHouse (now Malmaison).

The proposed boundary changewould not result in any additional

buildings of historical significancefalling within character area 1.

Surrounding historical sensitivities The character area is locatedapproximately 250m away from

Forbury Gardens at its nearest point.

Tall buildings within the characterarea e.g. Thames Tower, already

form a feature of views from the park,

creating a strong identity as a centralReading park.

The character area is located

approximately 100m away from the

Market Place at the nearest point. Any tall building development should

consider the potential impact of tall

buildings on views experienced within

the Market Place.

The proposed change would notresult in tall buildings being located

significantly closer to either Forbury

Gardens or the Market Place.

Key views within the character area No key views have been defined The area of proposed boundarychange would not result in there

being any additional key views within



Technical Note

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© Entec UK Limited

15 August 2008

Author:

Holly Robinson

...............................................................................

Reviewer:

Vera Seibold

...............................................................................

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