Tower of London

a) Construction proposals in the immediate vicinity of the Tower of London that could harm the setting, related vistas and integrity of the World Heritage property;

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

c) Lack of protection of the immediate surroundings of the Tower of London through an adequate and commonly agreed buffer zone.

The State Party submitted a state of conservation report on 22 March 2012. A reactive monitoring mission to the property was carried out from 5 to 8 December 2011. The mission report is available online at the following web address: https://whc.unesco.org/en/list/488/documents/.

a) Tower of London Local Setting Study and visual integrity of the property

The State Party reports that the study provides guidance for managing change in the immediate setting of the Tower, essentially the area visible at ground level from its perimeter. It acknowledges the impacts on the visual integrity that have occurred as a result of past developments, but also notes that other proposals have been modified to lessen their potential impact which reflects efforts in protecting the historic environment. Strengthened policies now in place should lessen the risk of inappropriate development that could cause additional impact on the visual integrity of the property.

The mission noted that the visual integrity of the property has been compromised by the Shard of Glass which will be 310m tall on completion. It underscored the need to better regulate the further build-up of the area and recommends that if any tall buildings are planned, these should not exceed the height by which they would become visible above the on-site historic buildings that are part of the Tower complex. The mission considers that any additional tall buildings in the area would destroy the visual integrity of the property and severely compromise its Outstanding Universal Value (OUV), possibly beyond repair.

b) Mechanisms for the protection of the setting

The State Party’s report provides information about the measures currently in place to protect the setting, including Planning Policy Statement 5, CLG (Communities and Local Government) Circular 07/09 Protection of World Heritage Sites and English Heritage’s The Setting of Heritage Assets elaborated in 2011. The State Party indicates that the need to protect or enhance the setting of heritage assets will be further elaborated into the new draft National Planning Policy Framework which will consolidate government planning policies into a more concise and useable format. In addition, the revised London Plan, adopted in July 2011, includes explicit requirements for the protection of the property and its setting. Additional Supplementary Planning Guidance (SPG), London’s World Heritage Sites - Guidance on Settings SPG (2012), has also been published by the Mayor of London to clarify implementation through decision-making and plan-making processes. The London View Management Framework SPG was also updated in 2012 in line with the London Plan policies 7.11 and 7.12. It identifies geometrically defined “Protected Vistas” which are subject to development control and designated views that are subject to Qualitative Visual Assessments. A series of assessment points were identified and linked to form a dynamic view to ensure that the silhouette of the WhiteTower is protected. The State Party notes that the publication of English Heritage’s “Seeing the History in the View” is also a methodological tool for managing change in the view. These tools provide the framework, at the national level, for boroughs, in this case the City of London and Southwark, to develop their own policy and decision making; in the case of the Tower of London, adjoining boroughs manage the setting of property which currently includes policies in their plans to protect the property. The report notes the intention of Southwark Council to develop a Supplementary Planning document to clarify how and where development can take place and to define building height thresholds so as to inform the appropriateness of subsequent development proposals.

The mission noted the shift in development strategies of Greater London resulting from the change of Mayor which is reflected in the spatial development strategy published in July 2011. Although areas surrounding the property are still earmarked as “opportunity areas” or “areas for intensification” and “regeneration”, emphasis has been placed on identifying appropriate areas for high-rise development based on local character. It notes that guidance documents have been approved and published to address gaps highlighted by the 2006 reactive monitoring mission. It further noted that provisions in the Management Plan for the property have been included in the new London Plan’s Policy on World Heritage sites.

c) New construction projects

The State Party indicates that developments affecting the property and its setting are screened to evaluate whether an Environmental Impact Assessment is required, including an evaluation of potential impacts on the OUV of the property. It states that the recent issuing of SPG on London’s World Heritage Sites – Guidance on Settings (2012) will provide further guidance on how to assess impacts of development on the setting of the property.

The mission evaluated two redevelopment projects, one underway and one proposed. The proposed 8-storey Tower House is situated to the north of the property at the entrance of the Tower Hill Underground station at Trinity Gardens. The area is highly visible from the Tower so the mass and scale of this new building should be kept within the perceived scale of the World Heritage site so that the monument can maintain its prominent place within the setting. The other redevelopment project concerns ThreeQuaysWharf, a recently started warehouse-style construction. Considering its close proximity to the Tower’s entrance at the MiddleTower, the mass and height of this redevelopment will be important in terms of the perceived scale of the Tower in its setting. The scheme was approved under the previous city administration. The mission also noted that the development project of Potters Field has been revised and the new proposal includes less bulky buildings and maintains only one tall structure.

d) State of conservation

The mission noted that the property is in a good state of conservation in terms of the fabric within the boundaries. The LondonTower has been completely restored, including the Outer Curtain Wall (the fortress walls), and trees that obstructed the viewpoints have been removed.

The World Heritage Centre and the Advisory Bodies take note of the mechanisms currently in place for the protection of the property and the local setting. They would highlight, however, that the current local setting comprises only a small area around the property and not the wider setting, and that the definition of what a setting entails requires further elaboration in relation to the OUV of the property. They consider that the process to develop the new National Planning Policy Framework will be crucial in addressing these remaining gaps and developing an effective system with clear provisions and mechanisms to stop adverse development and for dispute resolution. In addition, they consider that ensuring robustness of the system, through statutory protection in some cases, is critical to withstand shifts derived from changing politics and the potential that continues to exist to overrule decisions made by the boroughs and English Heritage.