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

a) Construction proposals in the immediate vicinity of Westminster Palace, Westminster Abbey and Saint Margaret's Church that could have an adverse impact on the setting, related vistas and integrity of the property;

b) Lack of an in-depth visual impact study on possible impacts of development projects, as well as lack of an approved management plan;

c) Need for protection of the immediate surroundings of the property through an adequate buffer zone.

On 1 February 2011, the State Party submitted a report on the state of conservation of the property. The report addresses the issues raised in paragraph 5 of Decision 33 COM 7B.128, in particular measures taken to strengthen the protection of the setting of the property and views from and to the property.

a) Dynamic Visual Impact Studies

The State Party reports that the five key views that relate to the Outstanding Universal Value (OUV) of the property have been identified and assessed under the methodology set out in “Seeing the History in the View: a method for Assessing Heritage Significance within Views’’, due to be published by spring 2011. This general publication can serve as a basis for visual impact studies. The analysis of the five views, once finalized, should provide a baseline study identifying the relevance to the OUV, and to other significances/values encapsulated in each view, for use by developers and decision-makers. Other views will be assessed as resources permit. These views appear not to be protected in any way.

The State Party further reports that the publication of ‘The Setting of Heritage Assets: English Heritage Guidance’, will be published in summer 2011. It will be a part of the publication ‘Seeing the History in View’.

b) Guidance

The State Party reports that the ‘Revised Supplementary Planning Guidance – London View Management Framework’ was published in July 2010. This guidance designated the Palace of Westminster as a ‘Strategically Important Landmark’, and a new designated view of the property in Parliament Square is proposed for inclusion. The guidance requires developments in the background of a designated view to respect the view. The precise nature of the proposed designated view or its scope is not set out.

The State Party reports that the protection of World Heritage properties in the United Kingdom has been strengthened by “Circular 07/09 on the Protection of World Heritage Sites”, the “Accompanying English Heritage guidance to Circular 07/09 The Protection and Management of World Heritage Sites in England and Planning Policy Statement 5: Planning for the Historic Environment (March 2010)” and the “PPS5: Planning for the Historic Environment: Historic Environment Planning Practice Guide (March 2010)”. Furthermore, the State Party reports that “The London Plan: Spatial Development Strategy for Greater London” and the “City of Westminster and London Borough of Lambeth planning documents” that are both currently undergoing statutory revision contain policies to protect heritage in general as well as the World Heritage properties.

In addition to the revised ‘Supplementary Planning Guidance – London View Management Framework’ the State Party offers extracts and links to further documentation, including the ‘Consolidated Revisions to the October 2009 London Plan’ and ‘The English Planning System and Dynamic Visual Impact Studies for development affecting World Heritage Sites’. It also reports that publication of the Westminster City Council draft ’Supplementary Planning Guidance Metropolitan Views 2009’ has been delayed pending completion of the ‘Local Development Framework’, and publication of the ‘London View Management Framework’.

c) Buffer Zone

The State Party reports that, in following the Operational Guidelines, it considers that where adequate layers of protection already exist, buffer zones are not necessary in every case. It also reports that further work following the 5 Views Baseline Study will assess existing and possible additional, protective measures for the property with a view to informing the 2012-13 management plan review.

The submitted extract from the draft London Plan states that the Mayor will work with relevant stakeholders to define the setting of World Heritage sites.

d) Development

The State Party reports that there are no major conservation issues currently within the property, although it does report that a number of development applications have been made that could have a potential impact on the property. These include the 22- and 27-storey high Elizabeth House development at Waterloo across the River Thames; developments at Victoria Transport Interchange 1; those near Battersea Power Station and Nine Elms; and developments at Vauxhall Broadway, pending a public enquiry in 2011.

e) Other issues

The management plan of the property was published in 2007. In 2008, the World Heritage Committee in its Decision 32 COM 7B.113 regretted the ‘lack of clarity on the management system set out in the management plan for addressing conflicts between conservation and development, particularly in the setting of the property’. This issue still seems not to have been addressed.

The World Heritage Centre and the Advisory Bodies note that the State Party has addressed the visual threats to the property in a variety of publications and strategy papers that have already been or will be published in the near future. However, they note with concern that, since the last report to the World Heritage Committee, the setting of the property, both the immediate setting that would normally be covered by a buffer zone, and the wider setting and views have not been given formal specific protection. Although five views have been identified by the Westminster World Heritage property Dynamic Visual Impact Study Steering Group in connection with the publication ‘Seeing the History in the View,’ this measure does not provide any specific protection for the property. The ‘Revised Supplementary Planning Guidance – London View Management Framework’ offers the possibility of a designated view of the property, but this has not yet been put in place and it is not clear how one view will have a substantial impact on the protection of the whole setting. This guidance does not incorporate the original intentions of the suggested “Skyline Study” that was said to be in preparation at the time of the 2006 reactive monitoring mission. Accordingly, no additional protection is provided.

Although the State Party states that a buffer zone is not necessarily needed as there is adequate protection in place, it is not clear what this protection is – particularly as it is stated that a number of development applications have been made that could have a potential impact on the property as the State Party itself acknowledges. There is a mention of possible additional protective measures for the property that might be included in the 2012/2013 revision of the management plan, but it is not clear what these are or how the plan could give them effect. The draft London Plan mentions definition of the setting, but not the protection this setting will have.

The World Heritage Centre and the Advisory Bodies consider that given the acknowledged vulnerabilities of this property from development near its tight boundaries, there is an urgent need to define the immediate setting of the property and to give it protection as a buffer zone, to define the wider setting in relation to the OUV, and to put in place appropriate protection for longer key views, in order to provide a framework for development and avoid confusion amongst stakeholders, as highlighted by the 2006 mission.

The World Heritage Committee requested that the ‘review of the supplementary planning guidance, and the London Views Management Framework, should fully take into account the relevant recommendations of the November 2006 joint World Heritage Centre / ICOMOS reactive monitoring mission’. This mission stated that it was ‘essential for the UK authorities to close the existing gap between theory and practice, between UK national policy on World Heritage and its interpretation and implementation at the local level, which has recently lead to inconsistencies and confusion’. It also stated that ‘the comprehensive skyline study currently in preparation should determine which views to and from the site are critical for maintaining the site’s integrity and for appreciating its setting to the fullest. Until this study has been finalized and further protective measures are in place, proposed new development could impact adversely on the values of the World Heritage site’. It further stated that “a dynamic visual impact study” to facilitate a thorough and rapid assessment of future planning applications,’ needed to be put in place.

The World Heritage Centre and the Advisory Bodies recommend that the Committee deeply regret that none of these concerns have yet been addressed and that it cannot be stated that substantial progress has been made. The possible inscription of the property on the List of World Heritage in Danger might be considered at the 36th session of the World Heritage Committee in case of further deterioration of the property’s state of conservation.