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; and statutory protection of the iconic view from the South Bank of the River Thames towards and beyond the Tower.

On 1 February 2011, a report on the state of conservation of the Tower of London was submitted by the State Party to the World Heritage Centre. The report addresses the issues raised in accordance with Paragraph 8 of Decision 33 COM 7B.127,in particular measures taken to strengthen the protection of the setting of the property and views from and to it,and includes a draft Statement of Outstanding Universal Value for approval by the World Heritage Committee.

a) Dynamic Visual Impact Study (DVIS)

The State Party reiterates that one view of the Tower has been designated to protect its silhouette from the south. Although the ‘Seeing the History in the View: Assessing Heritage Significance within Views’ by English Heritage, to be published in spring 2011, is mentioned (as is the case with Westminster), no further non-statutory views have been considered.

The State Party also reports that the publication ‘The Setting of Heritage Assets: English Heritage Guidance’ is due in summer 2011. It will be part of the publication Seeing the History in View and should serve as a basis for visual impact studies.

Further Supplementary Planning Guidance is currently being prepared that will set out guidance for defining the setting of World Heritage properties in London.

b) London View Management Framework (LVMF)

The State Party reports that the ‘Revised Supplementary Planning Guidance – London View Management Framework’ was published in July 2010. This guidance designated the Tower of London as a ‘Strategically Important Landmark’. The guidance requires development in the background of a designated landmark to respect the view.

The State Party also reports that policies to protect the property are set out in the emerging ‘Local Development Framework’ of the City of London, London Borough of Tower Hamlets and London Borough of Southwark local authorities.

c) Tower of London Consultative Committee

The State Party reports that the collaborative ‘Tower of London Local Setting Study’, commissioned by the Tower of London Consultative Committee, was developed with reference to the draft Statement of Outstanding Universal Value (OUV), submitted to the World Heritage Centre on 1 February 2011. It is reported that discussions are underway with the relevant planning authorities to include the recommendations as part of their planning policies. The ‘Tower of London Local Setting Study’ comprises an analysis of the significance of eleven individual views in the surrounding of the Tower with recommendations how they might be sustained or improved in terms of public realm, etc. No further protection of these views is envisaged in the report. However, these vistas are largely irrelevant from a conservation point of view: five are within the boundaries of the property, three extend just a couple of metres beyond the boundaries and three run across the river. Consequently, none of them affects any building area. The study also defines a ‘local setting’. This is a small area immediately outside the boundaries of the property and cannot be said to define even the immediate setting of the property.

d) Buffer Zone

The State Party notes that, according to paragraph 103 of the Operational Guidelines, buffer zones are not necessary where adequate layers of protection already exist. It also informs that the finalized report on the local setting, together with the policies in the emerging planning documents, will provide a wider framework to ensure that the property and its setting are conserved. The State Party also notes that the London Borough of Southwark is currently preparing a consultation supplementary planning document for Bankside, Borough and London Bridge.

e) Other Issues

The State Party reports that the substantial conservation work programme on the White Tower is now complete and that a tree strategy is now in place. However, the State Party also reports that there is an intense change occurring in the commercial area surrounding the property, including a number of high-rise buildings such as the approved 160m high building at 20 Fenchurch Street; the Shard of Glass at London Bridge; the proposed 31 storey building, The Quill, at St Thomas’s Street (currently called in by the Secretary of State); and the granting of permission for a 21 storey tower at Pottersfield directly opposite the property on the South bank of the river.

f) Guidance

The State Party reports that the protection of World Heritage properties in England has been strengthened by the recent release of three publications – ‘Circular 07/09 Circular on the Protection of World Heritage Sites’; accompanying ‘English Heritage guidance to Circular 07/09’; and ‘PPS5: Planning for the Historic Environment: Historic Environment Planning Practice Guide (March 2010)’ – and that other related policy documentation, such as ‘The London Plan: Spatial Development Strategy for Greater London’ is in production with more specific reference to the protection of the property.

The World Heritage Centre, and the Advisory Bodies note with great concern that since the 2009 state of conservation report, the setting of the property, both the immediate setting that would normally be covered by a buffer zone, and the wider setting, have not been given specific formal protection, apart from one designated view that was already in place.

The State Party reports that further guidance for settings is being prepared, and that the results of the local setting study will be acknowledged in Local Authority Plans but neither appears to offer definition of the wider setting and wider views to and from the property, nor formal protection of a buffer zone or equivalent.

The Tower is not better protected than it was two years ago and meanwhile, as the State Party acknowledges, development projects with tall buildings that could have an impact on the property, continue to be approved whilst all the policy issues associated with the property and its setting have not yet fully been resolved or promulgated. The setting of the Tower has seen drastic changes in the last decade and appears not to have been ‘managed’ to respect the OUV of the Tower. Building work has impacted on the setting of the Tower on three sides and the resulting glass structures do not enhance the presence of the Tower or allow it to project its former role.

The recommendations of the 2006 joint World Heritage Centre / ICOMOS reactive monitoringmission to put in place ‘protection of the immediate surroundings of the Tower through an adequate and commonly agreed buffer zone, which would allow better guidance as regards height and bulk of future planning applications’and that ‘This plan must be incorporated in the Greater London Authority’s London Plan’, have not been achieved.

Furthermore, the recommendation of the Committee at its 33rd session (Seville, 2009) to ensure that the ‘new sub-group of the Tower of London World Heritage Site Consultative Committee, fully considers the need for protection of the immediate surroundings of the Tower of London through an adequate and commonly agreed buffer zone’; that ‘progress towards a buffer zone as soon as possible and bringing together guidance on visual impact in order to put in place a coherent approach’ , and that ‘the Mayor's review of the supplementary planning guidance, the London Views Management Framework, fully takes into account the relevant views of the November 2006 joint World Heritage Centre / ICOMOS reactive monitoring mission’ have not been achieved.

In view of the above, the World Heritage Centre and the Advisory Bodies note with deep concern that no substantial progress has been made to protect the setting of the property and that the property remains under threat. They therefore suggest that the World Heritage Committee examines the state of conservation of this property, with a view to inscribing the World Heritage property of the Tower of London, United Kingdom, on the List of the World Heritage in Danger.