For the aten�on of Gemma Delves
City of London
Guildhall
PO Box 270
London EC2P 2EJ
23 April 2024
Dear Gemma
Ref: 23/01423/FULEIA
1 Undersha�, London EC3A 8EE
Representations by C C Land, owners of The Leadenhall Building
Further to our leter of 19 February 2024, please access from the links below our Representa�ons on the 2023 redevelopment plans for 1 Undersha�, submited as part of the statutory post submission Neighbour Consulta�on process.
Review:
htps://issuu.com/1undersha�/stacks
Download and/or print: htps://www.dropbox.com/scl/fo/miba7vuzle3xb7vqh9g9m/ALMLpuxuSNDdqQjdLqwYWS8?rlkey=7 xseg2meiugc32murakj05pxf&st=b9sya3w3&dl=0
These Representa�ons have been produced with the assistance of the following professional team:
Architect dMFK
Landscape Architect Kim Wilkie
Heritage Consultant
Planning Consultant
Stephen Levrant Heritage Architecture
JDA Planning Consultancy Limited
Planning Legal Taylor Wessing
The 2023 redevelopment plans have a detrimental impact on occupiers of the eastern half of the Leadenhall Building in terms of overlooking, loss of daylight and loss of views. Whilst we believe these are relevant concerns, we understand that they are not planning maters. We have considered the 1 Undersha� proposals primarily as a long-term stakeholder in the future of the City of London.
In summary our fundamental objec�on to the 2023 redevelopment plans for 1 Undersha� can be summarised by the resul�ng loss of St Helen’s Square:
1. The loss of its exis�ng character and scale as the primary public open space in the City Cluster.
2. The loss of a unique, unforgetable and interna�onally significant viewpoint of the City.
3. The loss of much needed respite to the City’s workers, residents and visitors.
4. The loss of any beneficial/transforma�ve role St Helen’s Square can or could play in successful placemaking for the future City Cluster.
A direct comparison of the 2023 redevelopment plans with the 2019 consent details the disturbing impact the current 1 Undersha� proposals would have upon the surrounding environment, if progressed:
• The largest public open space in the City Cluster, the 2,433 sq m St Helen’s Square, is shrunk by 710 sq m (-29.2%) to 1,723 sq m. Only 723 sq m (41.9%) continues to be open to the sky and elements. The 2019 consent would have increased the size and stature of St Helen’s Square and remained un-covered.
• The des�na�on sunken garden “Rockefeller” plaza offered as part of the 2019 consent is lost to a lacklustre and poor quality landscape design, coming at a �me when placemaking and bringing as much ac�vity as possible into the streets and spaces of the City is vital.
• The new emphasis on crea�ng a park and public offer in the sky, aims to draw pedestrian ac�vity and visitors away from street level, further reducing its vitality and viability.
• By choosing to project over almost the entirety of St Helen’s Square, the new scheme significantly lowers the quality of the environment at street level demoting a vitally important civic area to a secondary and transient space.
• The physical and visual connec�vity between two Grade I medieval churches, a substan�al heritage benefit of the consented scheme omited from the 2023 proposals, is also lost.
There is no aspect of the public realm proposals within the 2023 redevelopment plans which could objec�vely be considered as an improvement upon either the exis�ng situa�on, or the 2019 consent.
Given the accepted deficiency in open space in the Eastern Cluster, the City Corpora�on should not countenance any loss of street level public open space as part of any redevelopment. Preserve and enhance public space must be the key principle
The asser�on that viewing pla�orms or access controlled public spaces are an adequate replacement for street level public open space is incorrect.
The idea that covering the public realm and the resultant loss of sky will have no effect on the use and enjoyment of the space at street level is a falsehood. We know this from our direct experience on The Leadenhall Building.
We recognise the significance of the 1 Undersha� site in the City Cluster and the role this site needs to play in the future of the City of London. Indeed, C C Land fully support the exis�ng 2019 planning consent for 1 Undersha�.
However the 2023 redevelopment plans do not comprise the op�mum solu�on for this site. The proposals do not comply with the exis�ng key design and public space policy objec�ves or the dra� City Plan 2040. There is serious harm to the public realm, townscape and se�ng of heritage assets. Our Representa�ons evidence why and set out where the proposals are not policy compliant.
The materially detrimental impact of the proposals to St Helen’s Square and damage to the unique environment surrounding 1 Undersha� is unnecessary and completely avoidable, were the Applicant to adopt a different approach to bulk, massing and aesthe�cs.
We strongly believe that a beau�ful building of outstanding architectural quality, and considerable stature, providing a variety of depth of floor plates, a range of working and leisure experiences with world class street level public realm, could be created on the 1 Undersha� site.
We request that revisions are made to the 2023 redevelopment plans for 1 Undersha� which deliver:
a) No loss of street level public open space from the exis�ng situa�on
b) Preserve and enhance St Helen’s Square as a vitally important civic space and focus for placemaking in the City Cluster for workers, residents, and visitors
c) No harmful townscape or heritage impact
d) Architectural excellence within the City Cluster
C C Land believe it is incumbent upon stakeholders in the City of London to engage in the planning and development process. We trust that Officers will address our concerns over the current 1 Undersha� proposals with the Applicant.
If no material changes are progressed, we believe Officers would be unable to support the 2023 redevelopment plans and the Planning Applica�ons Sub Commitee should refuse the applica�on un�l the material issues outlined in this document are resolved.
We believe our Representa�ons to be clear. Should you have any queries, wish to discuss any aspect further or require addi�onal informa�on, please contact our planning consultant, John Adams, in the first instance.
Yours sincerely
Jus�n Black Head of DevelopmentC C Land UK jus�nblack@ccland.co.uk +44 (0)203 870 7473
Cc john@jdaplanningconsultancy.com louise.overton@dp9.co.uk anthony.fitzpatrick@cityoflondon.gov.uk henry.colthurst@cityoflondon.gov.uk