The State Party submitted a report for the site on 30 January 2006, which was reviewed by the World Heritage Centre and ICOMOS. Four main issues have been identified:
a) Two tall buildings which impact on the Tower have been given planning permission and further high rise buildings are being considered, which could impact adversely on critical views of and from the Tower;
b) Policies to protect London World Heritage sites within the London Plan currently seem not to be applied effectively;
c) Revised planning guidelines on London views, currently out for consultation, could limit the protection of views around the Tower;
d) The management plan for the Tower of London, which should strengthen protection for this site, has not yet been finalised or approved by the relevant authorities.
These are considered in further detail:
Proposed High-rise Constructions:
Two tall towers, the Minerva Tower, 217m, near the Tower of London and the so-called Shard of Glass Tower, 306m, at London Bridge, were both opposed by English Heritage for their impact on the Tower of London World Heritage property and its setting, and yet were still given planning permission. The Minerva Tower will appear directly behind the White Tower when viewed from Tower Bridge. Two further tall buildings, the Bishopsgate Tower, 324m, and 20 Fenchurch Street, 209m, have now been submitted for approval by developers. Both will be highly visible to the north-west of the Tower of London when viewed from London Bridge.
Although modern buildings have been built around the Tower complex, they have not altered significantly the relationship of volume and scale. However, it is different in the case of high-rise towers in the vicinity, including the so-called “Gherkin”, designed by Foster, and for the new development authorised. In this case, regardless of the high quality of the design, the new architecture constitutes an alteration of the historic urban landscape of the World Heritage site.
The London Plan:
The planning approvals are not in line with policies within the agreed London Plan. Approved in 2003, this contains policies that clearly spell out the need to protect World Heritage properties and their settings.
Current protection for key London views is being revised and the proposals recently put out for consultation narrow the protected views to a point that would give much reduced protection, particularly to the north across the River Thames.
Although a Plan was drafted in 2001, this has still not been approved.
The State Party provided a combined report on 30 January 2006 for both the Tower of London and Westminster Palace, Westminster Abbey and Saint Margaret’s Church World Heritage properties. This sets out the planning framework within which decisions are taken and acknowledges that decisions on new development have to balance heritage considerations against others and decide ‘which should be given greater weight’. It further states that ‘this may mean that on occasion it is necessary to accept some small diminution of the visual setting of a World Heritage property in order to meet other planning objectives’. It also states that ‘decisions on developments have to be taken within the context of why London is important. Unlike many other urban centres ... London is not a product of one architectural period or style’. It quotes the Vienna Memorandum and says that accepting a small adverse impact in order to maintain the overall vitality of the area is justified and is in line with this document.
The report submitted by the State Party indicates that the management plan is unlikely to be agreed upon before 2007, as further discussion is still needed amongst key stakeholders. On the question of a detailed study of the impact of development, the State Party maintains that this was initially proposed by the State Party and appears in the decision of the 27th session but that no discussion has taken place.On the current state of development, the State Party records the way approval has been given for the two approved tall buildings: the further two applications are not mentioned; one of these was submitted after the end of January.
ICOMOS and the World Heritage Centre consider that the impacts of the tall buildings already given approval and those subsequently submitted will have far greater than a “small adverse impact” on the Tower of London. If built, these buildings could confuse what remains of the Tower’s silhouette.
In order to determine more precisely the impacts on views, both of the Tower and outwards from within its Inner Ward, a thorough skyline study should be commissioned to assess and document the setting of the Tower and the key views connected to its World Heritage status.
Any new development within London should aim to maintain or enhance the setting and critical views associated with the Tower, as well as the World Heritage property of Westminster Palace, Westminster Abbey and Saint Margaret’s Church. It is of concern that the management plan for the Tower has not yet been finalised in the light of the rapid development planned in the surrounding area. Any reduction in statutory protection of the views associated with the Tower, or narrowing of those views, would mean a diminution in protection of its World Heritage values.