Palace of Westminster and Westminster Abbey including Saint Margaret’s Church

• Interpretative and visitation facilities (Construction proposals in the immediate vicinity of the property that could have an adverse impact on the setting, related vistas and integrity of the property)
• Buildings and Development (Continuous development pressure for high-rise buildings that pose changes to skyline and strong visual impact, whilst there is lack of an in-depth visual impact study on possible impacts of development projects)
• Management System/Management Plan (Lack of an approved management plan and need for protection of the immediate surroundings of the property through an adequate buffer zone)

On 30 November 2018, the State Party submitted a state of conservation report, which is available at https://whc.unesco.org/en/list/426/documents/, and reported on the following issues:

• National, regional and local planning policies are under review. The National Planning Policy Framework (NPPF) was revised in 2018. The London Plan is perceived as the urban planning framework to assess the impact on Outstanding Universal Value (OUV) and is currently under review, while a final draft is reported to be available. Individual borough local plans are also being reviewed;
• The decision-making process includes the possibility, in situations when Historic England objects to a proposed development for its potential negative impact on the OUV of the property, to refer the case to the Secretary of State who will decide whether to call it in;
• The Vauxhall Cross and Vauxhall Island Site project has not been built and a revised application was due for determination in late 2018. However, this has been delayed as it has been referred to the Secretary of State for a decision. As of now there is no stated determination date;
• Updates on the proposed Holocaust Memorial and Learning Centre and on the Westminster Ceremonial Streetscape Project have been provided. For both proposals, relevant Technical Reviews have been sent to the State Party;
• The review of the Management Plan is not yet finalized, but according to the State Party, significant progress has been made, with a formal public consultation foreseen for spring 2019. Moreover, a detailed conservation plan is being prepared for the Palace of Westminster and a Conservation Management Plan for Westminster Abbey. Once completed, they will be linked to the Management Plan of the property;
• The 23 recommendations of the 2017 joint ICOMOS/ICCROM Reactive Monitoring mission are reported to be followed, as well as the creation of an independent charity, World Heritage UK.

Concerning the update of planning regulations and policies, a heritage-led vision focused on the protection of OUV is yet to be delivered by the relevant statutory and management documents. The State Party should submit the draft London Plan and the relevant parts of the individual borough local plans to World Heritage Centre for review by the Advisory Bodies, prior to their approval and in a timely manner. The revision of the NPPF has been already approved, without prior consultation.

For the Restoration and Renewal project for the Palace of Westminster, the World Heritage Centre and the Advisory Bodies reiterate their request to receive the detailed proposal and the relevant Heritage Impact Assessments (HIAs), in conformity with Paragraph 172 of the Operational Guidelines, prior to taking any decisions that would be difficult to reverse. Moreover, further updates should be provided on the current status of the Vauxhall Cross and Vauxhall Island Site.

Although ICOMOS strongly supports the idea of a Holocaust Memorial and Learning Centre in London, the proposed monument and its underground rooms located in Victoria Tower Gardens, as currently presented, would have an adverse impact on the OUV of the property, and would unacceptably compromise a key part of its immediate setting and key views. Alternative locations and/or designs should be considered.

The creation of a buffer zone is indeed challenging, but it would significantly contribute to raising awareness of potential threats to the property. The State Party should address the issue of an updated database for tall buildings with an indication of the level of their finalization, and submit this to the World Heritage Centre. The development of the dynamic 3D modelling system would help identify, prevent and manage the cumulative effects, as well as assist in the delineation of an appropriate buffer zone.

The revision of the Management Plan of the property should be finalized as soon as possible, and the State Party should submit it for review by the World Heritage Centre and the Advisory Bodies, prior to its adoption. It is highly advised to take into consideration the creation of a joint committee for all World Heritage properties in London and to appoint a coordinator or site manager for this property.

The State Party should be encouraged to follow the recommendations of the 2017 mission, to comply with the Committee Decisions, and find solutions that will allow the inputs of the Committee and the Advisory Bodies in the national decision making process. The role of Historic England in the decision-making process should be further reinforced, especially when determining whether a project application should be called in by the Secretary of State. For projects with a potential negative impact on OUV, the State Party should produce an HIA, with the input of Historic England, and should notify the World Heritage Centre in conformity with Paragraph 172 of the Operational Guidelines, prior to taking any irreversible decisions.

Additionally, the creation by the Government of an advisory committee with a strong influence on decision making, which would contribute to the management of all World Heritage properties in the United Kingdom, would be very beneficial. The cumulative impacts on this World Heritage property, especially from high-rise developments with strong visual impact, combined with the difficulty to challenge planning permissions and currently inadequate management is a potential threat to this property, and the State Party should provide more detailed information to clarify whether such an advisory committee would be possible.