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 surrounding 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.

At its 32nd session (Quebec City, 2008), the World HeritageCommittee noted the actions taken by the State Party in developing a management plan, starting to prepare guidance on methodology for assessing development in World Heritage views, and progress with protection to the view of the Tower from the South Bank.

However it regretted that no buffer zone with protection had been put in place and that no specific skyline study of the Tower, its setting and views, had been carried out, to allow assessments of the impact of development proposals and that there appeared to be lack of clarity on the management system set out in the management plan for addressing conflicts between conservation and development, particularly in the setting, resulting in large development projects with tall buildings continuing to be approved.

In the light of some progress made, the World HeritageCommittee deferred consideration of the inscription of the property on the List of World Heritage in Danger to its 33rd session in 2009.

The State Party submitted its progress report on the issues raised by the World Heritage Committee on 18 February 2009.

a) Buffer zone with protection

The report recalls that the 2007 management plan includes objectives in relation to managing the immediate setting of the Tower, and states that a sub-group of the Tower of London World Heritage Site Consultative Committee is working with all concerned to develop a design guide for the public realm, and ensure interested parties collaborate to assess the feasibility of preparing an assessment of the local setting. A brief for an assessment of the local setting has been prepared and agreed, funding secured from the sub-group for the first stage, a project manager appointed and a process of appointing specialist consultants in hand for them to be in place by spring 2009. There is no mention of the scope or extent of this local setting or how it will be protected.

b) Skyline study of the Tower, its setting and views

The report states that there is some confusion about the skyline study for the property which has long been overtaken by the work related to the London Views Management Framework and on a dynamic visual impact study (in response to Decision 31 COM 7B.90). In rehearsing a variety of related initiatives taken during the period of 2001 - 2007 the report notes that the State Party had no discussions with the World Heritage Centre or the World Heritage Committee what form such a study might take, or what purpose it might serve, and had not committed to undertake a Skyline Study. The State Party therefore requests that any reference to “Skyline Study" be omitted from future draft Decisions.

No update is provided on progress with the Dynamic Visual Impact Study, although the report indicates that an explanation of how such a Study fits within the United Kingdom planning system is currently being considered. This has the aim of articulating the process for assessing the potential visual impact of a development proposal on a London World Heritage property within the context of other studies affecting relevant planning applications so that they avoid duplication and maintain clarity. The report notes that the publication of English Heritage’s "Seeing the History in View: a method for Assessing Heritage Significance within Views" is underway and applies to heritage sites generally. It included "The City Hall to Tower of London World Heritage Site protected View" case study for information.

The London Views Management Framework, which is supplementary planning guidance, is being reviewed. The review will seek to strengthen and protect a view of the Tower from the south bank and will provide clearer guidance about what type of development should or should not occur in this part of the setting of the property.

c) Management system/management plan

The report notes that all United Kingdom World Heritage properties have management plans, many of which are going through revision. It states that the current Tower of London World Heritage Site management plan has been agreed and endorsed by all relevant stakeholders. They state that it is this group which provides a mechanism to identify and address conflicts arising that affect the protection and management of the property, although ultimately they need to be resolved through the formal planning framework.

d) Large development projects

The report indicates that when the joint World Heritage Centre/ICOMOS reactive monitoring mission visited London in 2006 it was demonstrated that the Tower of London was being managed to the highest standard. The State Party also emphasised at the time that the London skyline was a diverse mix of architectural styles, charting the development of the capital over two millennia, and that restricting economic development would be detrimental to London and its heritage. Specifically, in relation to the Tower of London, the State Party recognises the need to protect the setting from development impacts, but notes that they are aware that not all tall buildings are inappropriate. They also state that it is not possible under the United Kingdom planning scheme to withhold final approval if all other stages of the planning procedure have been completed. The State Party reports significant progress with the London Plan Spatial Development Strategy and the London Views Management Framework which takes into account the potential impact of large development proposals on London World Heritage properties and offer more protection to the views of London's landmarks.

e) Continued approval of development projects with tall buildings

The State Party reports that whilst policies for the protection of the property are in place they are still looking for opportunities to reinforce and clarify this level of protection. The State Party notes that in relation to individual applications the Secretary of State for Communities and Local Government follows strict proprietary guidance. In taking a balanced approach to all development proposals Communities and Local Government consider that there is a good case for growth and development which need not be at the cost of heritage.

London Bridge Tower (Shard of Glass): With planning permission for the 66 storey tower granted in November 2003, demolition of existing buildings on the site is proceeding.

Potter's field – Southwark: Planning permission was granted in 2006, for a development of eight elliptical tower's ranging between 12 and 19 storeys high on a site, opposite the Tower of London, part-owned by Southwark Council. A new design for a mixed-use development has been prepared, 4 to 18 storeys, comprising up to 500 residential units, non-residential floor space, communal and associated car and cycle parking. It is understood that a planning application is expected to be submitted in 2009.

Bishopsgate Tower (The Pinnacle): Approved in 2006, demolition on site has been completed and piling is well advanced. Subject to available funding it is intended to proceed with construction of the building. There is no information on the completion date.

20 Fenchurch Street (The Walkie Talkie): Permission was granted in 2007 following a public inquiry. Demolition is complete but it has been reported that construction will not commence in the current market.

Aldgate Bus Station Site: In 2007 the Historic Royal Palaces wrote to the City of London noting that the proposed application would appear in the background to views of the Tower of London from City Hall and Queens Walk. The application was amended to reduce the mass of Building 2. The City of London granted planning permission subject to various matters. It seems not likely that work starts in the near future.

f) Protection:

The State Party previously informed of the publication of a draft Heritage Protection Bill but notes that, whilst the Government remains committed to introducing this legislation, it has been delayed until a legislative slot becomes available. In the meantime a number of reforms to the system are being pursued without the need for legislation including:

- Since 1 October 2008, World Heritage properties have been included in Article 1(5) land designation in the General Permitted Development Order. This means that certain permitted development rights are withdrawn to give more control over small-scale changes which could incrementally have an adverse effect on the Outstanding Universal Value.

- In Spring 2009 specific notification and call-in requirements for significant development affecting World Heritage properties will be introduced where English Heritage have objected on the grounds that a proposed development could have an adverse impact on the Outstanding Universal Value and significance of a World Heritage property and has been unable to withdraw that objection following discussions.

- A new planning circular on World Heritage with an accompanying English Heritage guidance note is due to be published in Spring 2009. These documents will emphasise the key role planning authorities have in protecting World Heritage properties through policies in regional and local level Plans

g) The London Plan

The reports states that the new Mayor of London has since 2008 indicated his commitment to World Heritage properties and that tall buildings will be required to respect the context of the area in which they are to be located, protect and enhance the environment, meets sustainable design standards and be of outstanding architectural quality. Furthermore the Mayor is reviewing the 2004 London Plan to ensure that all new buildings are of a highest standard of design, relevant to their context and sensitive to heritage, archaeology and local character. A draft of the revised London Plan will be published for public consultation in 2009.

h) Counter-terrorism measures

Within the context of the management plan work is underway to enhance the counter terrorism defences at the Tower against vehicle penetration.

i) The White Tower

Conservation and repair work is underway on the White Tower to clean, repair and conserve external elevations and carry out roof repairs. The project will be completed in 2010.

The State Party notes that it is continuing to protect the property, it setting and related vistas, and that the Committee should consider the removal of a reference to "in danger listing" from the Decision on the Tower of London World Heritage property.

The World Heritage Centre and ICOMOS consider that there seems to be considerable continuing difficulty in reconciling the needs of the World Heritage property and that of a functioning city. Misunderstanding or misinterpretations regarding the need or otherwise for a Skyline Study appear to have been running for some time before the State Party has attempted in the current report to have the issue omitted from future draft Decisions. This is argued on the basis of other related work which has progressed. An integrated approach to World Heritage planning considerations in London inevitably links the Tower of London with the Palace of Westminster World Heritage property issues, further adding to the complexities involved.

Although the overall impression from the State Party report is that developments involving high-rise structures will continue to be an issue affecting the World Heritage property, some emphasis is being put on the changes being brought about by the new Mayor of London. However currently there is no clearly defined overall planning structure that would appear to bring together all needed constraints, nor is a protected buffer zone yet in place.