The State Party submitted its report on 31 January 2008 and has provided comments on the actions undertaken and development proposals since the 31st session of the World Heritage Committee (Christchurch, 2007). It also submitted a draft Statement of outstanding universal value. This will be examined by the World Heritage Committee under Item 8B of the Agenda (Document WHC-08/32.COM/8B).
a) Dynamic Visual Impact Study
The State Party has reported that this study is still on-going. It is part of a wider study being undertaken by English Heritage called ‘Seeing History in the View’ which will set out a methodology for assessing the impact of development on views to and from World Heritage properties. No further details have been provided to the World Heritage Centre on this study and no timescale is given for completion. There is concern that the study being undertaken is generic rather than specific to the Tower of London. The World Heritage Committee made a specific request for a skyline study of the Tower, its setting, and views, in order to allow rapid assessment of the potential impact of proposed development.
b) Buffer Zone
The World Heritage Committee requested measures on protection of the immediate surrounding of the Tower through an adequate and commonly agreed buffer zone. The buffer zone is not mentioned in the State Party’s report and no further information was provided at the time of the preparation of this document.
c) Management plan
In July 2007 the State Party had submitted the completed management plan for review by ICOMOS.
Historic Royal Palaces were responsible for the preparation of the plan. Implementation and monitoring of the management plan are the responsibility of Historic Royal Palaces, in consultation with the Tower of London World Heritage property consultative Committee.
The ambition of the Plan is to “embrace the physical preservation of the Tower, protecting and enhancing the visual and environmental character of its local setting, providing a consideration of its wider setting and improving the understanding and enjoyment of the Tower as a cultural resource.” As well as providing an agreed framework for long-term decision-making on the conservation and improvement of the Tower, the Plan provides a mechanism to consider the setting of the Tower.
In assessing challenges for the property, in ICOMOS’ opinion, the management objectives face the challenges but do not always explicitly address the core of these issues.
The division of spatial planning responsibilities means that the setting of the Tower could be vulnerable to inconsistency in the definition and application of policy objectives between these authorities.
Issues like the status of the immediate surrounding (definition of possible buffer zone), additional reduction of statutory protective measures in London View Management Framework, the abandonment of the visual assessment tool elaborated by Historic Royal Palaces as a qualitative visual assessment methodology, are not explored.
The weak point in the management process is the definition of the zones around the World Heritage property in relation to the possible impact of local development on the outstanding universal value and integrity of the property. There is no defined statutory buffer zone. The management plan refers to external policies relevant to the preservation of the property, but the mechanisms for future negotiation between stakeholders and possible conflicts resolution are not explored. It is not clear enough to what extent the World Heritage management plan is the subject of a formal agreement and who endorses the plan.
d) Statutory Protection of iconic view from the South Bank
In its report, the State Party indicates that the London View Management framework was published in July 2007. This confirms statutory protection on one view to the Tower of London from a point on the south bank of the River, but in comparison to the draft presented to the mission, reduces the protected view angle from 20 to 15 degrees. This framework allows English Heritage and the Historic Royal Palaces to comment on proposals that might impact on this protected view.
e) Update on legislation
The State Party provided information on the draft “Heritage Protection Bill”, previously mentioned as the “Heritage Protection White Paper”. This will be put before Parliament in 2007-2008. In advance of this, three new measures are also being considered regarding procedures for development proposals, strengthening the protection of World Heritage properties and guidance on the status and use of buffer zones.
f) Development proposals
The State Party provided the following information on development proposals affecting the Tower which were mentioned at the time of the mission but has not provided information on other proposals which will affect the Tower (see below):
- Shard of Glass: Construction of this tall 66 story tower to the south of the Tower which was permitted in 2003 is likely to start in 2008 after demolition on the site which has already begun;
- 20 Fenchurch Street: This 39 storey building to the west of the Tower, to which the Historic Royal Palaces and English Heritage objected, was approved as a result of a public inquiry in July 2007;
- Potters Fields: This proposed development is for 8 elliptical towers up to 19 storeys high, between Tower Bridge and the Greater London Headquarters (from where the protected view begins on the South Bank) was objected to by English Heritage but given permission in February 2006 by the Secretary of State who acknowledged that there would be impact on the World Heritage property but considered that it would fit well into the thriving city of London.
The World Heritage Centre and ICOMOS consider that progress has been made with the development of the management plan but express concern that it has not been made clear how conflicts between conservation and development in the setting of the Tower might be addressed, in the absence of further protection from a statutory buffer zone or a specific skyline study that could be used for rapid assessment of the impact of development proposals on the setting of the Tower. Up till now English Heritage and the heritage lobby have lost every inquiry into major projects that were supported by the Greater London Authority, and it is not clear how this will change in the future.
No measures have been put in place to change the current status of the setting of the Tower, apart from theone narrow, 15 degree, designated view from a point on the south bank of the river towards the Tower. This is having the effect of prompting further high-rise development immediately to each side of this view cone. For instance, to the north a group of buildings known as Trinity Square was submitted for planning last year and is being revised for re-submission. This includes glass towers that are outside the view cone but will be seen immediately to its left.
Another similar proposal is at Goodman’s Fields, Tower Hamlets, where residential towers are planned. These are being modified so they do not appear from the view cone ‘point’, but from elsewhere will be seen between turrets of the White Tower. These are being objected to by English Heritage but supported by the Greater London Authority who sees them as exciting.
The 307 metre Bishopsgate Tower is currently being built to the north-west of the Tower and other tall buildings are being planned around it, such as the Foster scheme in Hackney and three more including the Bishopsgate Goods Yard.
Further proposals are expected after 8 April 2008 when new ‘call-in’ arrangements will be in place that will allow the Mayor, after a pubic inquiry, to make a final decision on major proposals rather than a Minister.
The lack of protection for the setting of the Tower apart from one narrow view cone is leading to development proposals coming forward that will in effect enclose this one view. The integrity and setting of the Tower are in danger of being severely compromised, in the absence of any real support from the letter of the law.