For the aten�on of Gemma Delves
City of London
Guildhall
PO Box 270
London EC2P 2EJ
14 June 2024
Dear Gemma
Ref: 23/01423/FULEIA
1 Undersha�, London EC3A 8EE
Representations by C C Land, owners of The Leadenhall Building
I write further to the recent submission of revised and addi�onal informa�on by the Applicant to the 2023 applica�on and our mee�ng of 23 May 2024.
This submission, dated 10 May 2024 on the City of London’s (‘CoL’) planning portal , has been reviewed in full by our professional team. Their commentary is atached to this leter as an Addendum to our 23 April 2024 representa�ons - the content of which I do not propose to repeat in this correspondence.
As you know, the Applicant has chosen not to amend the public realm design and no aspect of the amendments presented in the 10 May 2024 submission atempts to address any of the concerns detailed in our 23 April 2024 representa�ons.
Consequently, C C Land’s posi�on is unchanged and we con�nue to strongly object to the current proposals, which are fundamentally flawed
The concerns detailed in our 23 April 2024 consultation response are not unique to C C Land. As well as statutory bodies such as Historic England, these worries are widely shared by workers, residents, businesses, industries and property owners in the local area.
Some have formally shared their concerns and engaged in the consultation process. Others have not, in the belief that voicing any un-supportive opinion will have no effect on the City’s decisionmaking process for this planning application.
We believe disregarding known legitimate concerns raised by those who will be directly affected by the 1 Undershaft proposals to be extremely ill advised.
We re-iterate our support for the principle of redevelopment of 1 Undershaft, but not at any cost.
The materially detrimental impact of the proposals on St Helen’s Square, heritage assets of the highest importance, and the permanent loss of irreplaceable street level public open space to private commercial use is wholly unacceptable and entirely avoidable.
The harm to St Helen’s Square and the immediate environment largely results from the massing/footprint of the proposed building from Ground Floor up to Level 11 and could be resolved, were the Applicant to adopt a different approach to bulk, massing and aesthe�cs for the lower third of the building. The resultant loss of floorspace would be less than 4%.
The Applicant has not demonstrated that alternative designs have been explored to avoid harm, and there is clearly an urgent need and jus�fica�on for this exercise to be undertaken (in accordance with the requirements of the Planning (Listed Building and Conserva�on Areas) Act 1990 and the NPPF)
We again request that revisions are made to the applica�on scheme 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
When previously pursuing the utmost increase in height (+171.9m) and floor area (+100,007m2 or +203.7%) on 1 Undershaft, there was a determined effort by the Applicant to compensate through material improvements to the existing street level public realm.
This time around, in seeking another significant increase in floor area (+31,266m2 or +2 1 0%) above the 2019 consent (149,100m2), the Applicant has degraded the existing street level public realm, both in size and status, in favour of additional private commercial floorspace. A raised viewing terrace, promoted by CoL on previous projects, has been plonked into the design, erroneously portrayed both as an adequate replacement for the loss of everyday street level public realm and a significant public benefit
The Applicant appears to be progressing on the assumption that providing CoL with certainty over the redevelopment of 1 Undershaft trumps all other concerns and therefore the poorly articulated design and non policy compliant proposals will have to be accep ted by everyone, warts and all.
C C Land’s posi�on is that this is not a planning applica�on where the perceived benefits can �p the scales and overcome the very significant harm that would arise were the 2023 applica�on to be progress without further revision
The 10 May 2024 design changes are cosme�c and make no sincere atempt to overcome concerns raised by a range of objectors, including C C Land. Indeed in their 7 June 2024 leter, Historic England believe that these design changes actually increase the harm to the built historic environment, pu�ng the Outstanding Universal Value (“OUV”) of the Tower of London World Heritage Site at grave risk.
We con�nue to consider that officers, on any proper assessment of the scheme against the development plan and other material considera�ons, should find themselves currently unable to support the 2023 redevelopment plans.
We believe our concerns with the 2023 applica�on to be shared by other stakeholders, clear, fully jus�fied and thankfully resolvable by the Applicant pursuing further revisions to the design.
It is clearly premature for the applica�on to be determined by CoL in the absence of serious considera�on of alterna�ve designs, at the very least for the base of the building, to avoid demonstrable harm to interests of acknowledged importance.
We urge the Applicant to reconsider their posi�on and would happily meet with CoL officers and the Applicant’s project team to assist the progression of any revisions which resolve our stated concerns.
If no material changes are progressed, our formal objec�on to the proposal remains and we will invite the Planning Applica�ons Sub Commitee to refuse the applica�on or defer a decision pending further scheme revisions to address our concerns.
We trust that CoL officers will now act to address the concerns detailed within our 23 April 2024 representa�ons.
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