Tower of London

At its 27th session (UNESCO, 2003), the World Heritage Committee recommended the State Party to avoid any construction in the immediate vicinity of the property that could harm the setting and integrity of the property and requested a report for examination at its 28th session (Suzhou, 2004). This request was repeated at the two subsequent meetings because the State Party had failed to provide an in-depth study on possible impacts of development projects.

At its 30th session (Vilnius, 2006), the Committee noted with great concern that proposed new developments around the Tower of London and Westminster Palace, Westminster Abbey and Saint Margaret's Church World Heritage properties appeared not to respect the significance of the World Heritage properties, their settings, and related vistas. The London Plan policies to protect the World Heritage properties and their environment did not seem to be applied effectively, statutory protection for views to and from the Tower could be diminished, and the management plan had still not been finalised.

The requested in-depth study on the possible impact of development projects in the immediate vicinity of the World Heritage property had not been submitted and no detailed skyline study of the Tower, its setting, and views had yet been carried out. The Committee urged the State Party to carry out such a skyline survey as soon as possible to provide a qualitative framework for assessing the impact of new developments on the views and setting that contribute to the outstanding universal value of the Tower.

The State Party was requested to invite a joint World Heritage Centre/ICOMOS reactive monitoring mission as soon as possible to assess the impact of current planning proposals in the spirit of the 2005 Vienna Memorandum on World Heritage and Contemporary Architecture, Managing the Historic Urban Landscape, and to review the possibility of inclusion of the property in the List of World Heritage in Danger, including benchmarks and timeframes for corrective action. The State Party was requested to provide the World Heritage Centre with an updated report by 1 February 2007 on the progress of its undertakings in this area, and on the state of conservation of the property, for examination by the Committee at its 31st session in 2007.

In its report, the Joint World Heritage Centre/ICOMOS Mission (which visited both the Tower of London and the Westminster World Heritage properties) commented that the overall state of conservation of both properties was good, with only minor issues affecting the properties such as the planned removal of trees at the Tower. No major problems were identified inside the core zones of either World Heritage property.

A tall buildings development strategy was actively being promoted by the City of London, in harmony with the policies of the Mayor of London (Greater London Authority – GLA), of which the result had been the submission and approval of various applications for tall buildings of over 100m, several of them in the vicinity of the Tower of London, clustered in the City of London. Several such buildings were being refurbished, had recently been built, or were under construction. Several other tall buildings had received planning permission or were currently under study.

Of the two cases discussed by the World Heritage Committee in 2006, the planned construction of the 216m Minerva Tower could be considered a direct threat, as the building site was located in the eastern side of the City and therefore with a significant impact on the visual background of the Tower of London. However, the developers had cancelled the project for a tall building, owing to financial considerations. The mission concluded that it was essential for the UK authorities to close the existing gap between UK national policy on World Heritage and its interpretation at the local level. There was a need to incorporate local development policies of Boroughs and Management Plans for the World Heritage properties into the GLA strategic development plan. Absence of management plans prepared by relevant bodies despite their declarations to respect and integrate cultural heritage in development concepts needed to be overcome.

Finalization of the Management Plan of the Tower of London and its Environs was key and in this Management Plan supplementary planning guidance should be provided to statutorily protect the remaining iconic views of the Tower from the south over the River Thames. These views had been identified in a study on the possible impact of development projects, The London View Management Framework, which is currently out for consultation.

a) The mission considered Paragraphs 178–186 of the Operational Guidelines (List of World Heritage in Danger) and Paragraphs 192–198 (Procedure for the eventual deletion of properties from the World Heritage List), and concluded that: in terms of ‘serious deterioration of architectural or town-planning coherence’ (Paragraph 179 a. iii), ‘serious deterioration of urban space’ (Paragraph 179 a. iv), or ‘threatening effects of town planning’ (Paragraph 179 b. iv), the imminent or potential dangers to the Tower of London posed by the approved planning applications for the Minerva Tower (Houndsditch, 216m) and the London Bridge Tower (Shard of Glass, 303m) had been partially averted, because of the cancellation of the Minerva Tower, which was positioned in the iconic view from the South Bank towards the Tower of London. The “Shard of Glass” however, remains a potential danger, the impact of which is difficult to assess owing to an absence of a detailed skyline study of the Tower, its setting and views;

b) As regards ‘modification of juridical status of the property diminishing the degree of its protection’ (Paragraph 179 b. i) or ‘lack of conservation policy’ (Paragraph 179 b. ii), improvements are under way in policies to protect London World Heritage properties, in particular the publication in March 2007 of the DCMS Secretary of State’s White Paper on Heritage Protection, the in-depth study on the possible impact of development projects with a proposal for view protection of the Tower put forward in the London Plan (The London View Management Framework – Draft SPG), and the advanced stage of drafting of the Management Plan for the Tower of London.

The mission made the following recommendations:

a) The existing trees on and around the premises of the Tower, which would be removed in the short term, should be replaced with a new vegetation screen in order to create a visual buffer between the Tower and its surroundings. Together with an overall cleaning of the White Tower, this would make the monument better stand out visually against its urban backdrop;

b) The Greater London Authority should adopt a policy of concentration of tall buildings in the City, thereby limiting the impact on the Tower of London’s surrounding urban landscape. The mission was of the firm view that establishing a statutory protection for the iconic view from the South Bank, in order to keep the last remaining visual axis unobstructed, was key to the conservation of the visual integrity of the Tower. The proposal currently put forward in the London Plan (London View Management Framework – Draft SPG, April 2005), to identify three limited circles from a viewpoint from City Hall to the Tower of London, improves the situation, but should be widened considerably to include a buffer zone extending up to 1km from the Tower of London over the eastern section of the City of London into the Borough of Tower Hamlets;

c) The Management Plan for the Tower of London should be finalised in time for it to be available for the 31st session of the Committee. It should include a protection of the immediate surroundings of the Tower through an adequate buffer zone, which would allow better protection and guidance as regards height and volume of future planning applications. This plan and the development plans for the Boroughs must be incorporated into the GLA Development Strategy.

The State Party submitted a detailed report to the World Heritage Centre in January 2007, responding to the Committee’s Decision in 2006. It reported that the following actions had been taken:

a) Revised guidance on tall buildings prepared by English Heritage and the Commission for Architecture and Built Heritage, statutory advisers to the Government on the historic environment, was out for public comment;

b) The Further Alterations to the London Plan would contain new references to strengthen the protection of World Heritage properties;

c) A working group was in place and at work on the Management Plan for the Tower of London;

d) A new protected view of the Tower would be included in the London View Management Framework, the first time the Tower would have such protection. Details remained to be finalized and a detailed plan would be submitted to the Committee.

The Heritage Protection White Paper (consultation paper), entitled The UK Heritage Protection Review, published in March 2007, proposes that:

a) Statutory protection would be provided within the planning system for World Heritage properties in order to control development within properties and their settings;

b) Planning policy would be updated to enhance protection of World Heritage properties within the planning system;

c) Specific call-in notifications would be introduced in respect of significant developments affecting World Heritage properties;

d) World Heritage properties would, where appropriate, be given buffer zones.

World Heritage properties would become equivalent in planning terms to other protected areas, such as Conservation Areas, National Parks, and Areas of Outstanding Natural Beauty (AONBs).

The mission concluded that the property would meet criteria for Danger Listing (according to Paragraphs 178-182 of the Operational Guidelines) if either a statutory protection for the iconic view from the South Bank towards the Tower, which is key to the conservation of the visual integrity of the Tower, has not been established by the time the World Heritage Committee meets for its 31st session, or the Management Plan, including a protection of the immediate surrounding of the Tower through an adequate and commonly agreed buffer zone, has not been finalized by the time the World Heritage Committee meets for its 31st session.

The statutory protection of the iconic view and the management plan could be considered the benchmarks also for a potential removal of the property from the List of World Heritage in Danger.

On 16 March 2007 the State Party responded to the mission report and assured the World Heritage Centre of the UK’s commitment to the protection of the World Heritage property. A substantive response to the issues raised in the mission report will be available in time for the 31st session of the World Heritage Committee.