Palace of Westminster and Westminster Abbey including Saint Margaret’s Church

• Interpretative and visitation facilities (Construction proposals in the immediate vicinity of the property that could have an adverse impact on the setting, related vistas and integrity of the property)
• Buildings and Development (Continuous development pressure for high-rise buildings that pose changes to skyline and strong visual impact, whilst there is lack of an in-depth visual impact study on possible impacts of development projects)
• Conservation works (possible impact of the Restoration and Renewal project for the Palace of Westminster)
• Management System/Management Plan (Lack of coordination within the management system, an approved management plan and need for protection of the immediate surroundings of the property through an adequate buffer zone)

On 1 December 2020, the State Party submitted a state of conservation report, which is available at https://whc.unesco.org/en/list/426/documents/, and reports on the following issues addressed by the Committee at its previous sessions:

• Significant progress has occurred with the New London Plan, which sets out policies for London with a strengthened approach to protection of the Outstanding Universal Value (OUV), consistent with the findings of the 2017 joint ICOMOS/ICCROM Reactive Monitoring mission. The London-wide plan requires detailed policies from the 32 borough councils to provide clear guidance and afford priority to protection of OUV. The Westminster City Plan is proceeding through a public examination process. The Plan includes specific policy guidance on the property, including monitoring indicators and a policy requirement to undertake Heritage Impact Assessment (HIA). Progress continues with implementation of the 23 recommendations from the 2017 mission. Review and updating of the Management Plan also continues, in conformity with the Westminster City Plan. Historic England has commented on some of the draft Management Plan and further stakeholder engagement and full public consultation will follow. The draft Management Plan will be submitted to the World Heritage Centre for review. 3D digital mapping systems are being used to facilitate analysis of proposals and their cumulative impacts, having regard to the London View Management Framework;
• The proposed Palace of Westminster ‘Restoration and Renewal Programme’ involves major refurbishment. An updated Conservation Management Plan (CMP) has been prepared. Engagement has commenced with Westminster City Council and Historic England. The State Party will provide regular updates and will notify the World Heritage Centre at the scoping stage of the HIA process;
• The planning application for the UK Holocaust Memorial and Learning Centre has been called in by the Secretary of State. A public inquiry has occurred, to which ICOMOS’ Technical Review was submitted, but no decision has yet been made. The Vauxhall Cross/ Vauxhall Island sites proposals have been revised, with a new design by Zaha Hadid Architects, featuring a two-tower scheme, higher than the earlier approved scheme, but with more slender form and massing. This new application has been granted planning permission following a public inquiry. The tall buildings database for the property has been submitted to the World Heritage Centre;
• The State Party has considered the Committee’s decisions regarding advisory and decision-making processes. Historic England plays a significant role in policy development and decision-making and is a statutory consultee for development proposals. It is not intended to establish a further World Heritage advisory group, as requested by the Committee, as this would duplicate existing sound arrangements.

The State Party continues to respond to Committee decisions and the findings of the 2017 mission, in particular through affording weight to the protection of OUV through national, regional and local planning processes. The New London Plan is generally comprehensive and appropriately focused on OUV, but also recognizes other heritage values. Policies HC2 ‘World Heritage Sites’, HC3 ‘Strategic and Local Views’, and HC4 ‘London View Management Framework’ together provide a sound framework, but the heritage provisions in Chapter 12 ‘Monitoring’ do not adequately address the World Heritage status of the property nor protection of its OUV. It is appropriate that the borough councils must establish plans that incorporate the New London Plan requirements.

The Westminster City Plan also provides for an improved heritage planning and protection of OUV, but appears to require amendments, particularly to address the sensitivity of key potential development sites and to align more closely with the New London Plan. HIAs are required to determine the appropriate scale for new development. The Westminster City Plan and New London Plan would benefit from greater alignment, consistent with recommendations already provided by Historic England (through the document: Statement of Common Ground Westminster City Council and Historic England – October 2019) and further review and advice from the Advisory Bodies.

The preparation of a CMP for the Palace of Westminster is welcome, as are assurances about the thoroughness of the process for preparing plans. Noting the long timeframe for this project, the Committee should request that the CMP be submitted for review and reiterate its previous request to receive the detailed proposals including HIAs, in conformity with Paragraph 172 of the Operational Guidelines, prior to any decisions that would be difficult to reverse.

The revised proposal for the Vauxhall Cross and Vauxhall Island Site is acknowledged as a significant improvement, but, in view of the Committee’s specific previous request, it is regretted that the new scheme was subject to a public inquiry and has received consent, without referral to the World Heritage Centre for review by the Advisory Bodies.

Although a Holocaust Memorial and Learning Centre in London is strongly supported, the proposed location in Victoria Tower Gardens, would have an adverse impact on the OUV of the property, and would unacceptably compromise a key part of its immediate setting and key views. The Committee should remind the State Party of its previous request to consider alternative locations and/or designs.

The updated database for tall buildings and advice regarding use of 3D modelling systems is welcome. Consistent with the intent of the New London Plan and the Westminster City Plan, these tools should contribute to the identification, prevention and management of the cumulative effects of new tower buildings that affect the OUV of the property (irrespective of the location within or outside the property), as well as assisting with delineation of an appropriate buffer zone.

The State Party should be encouraged to continue to pursue approaches that facilitate the inputs of the Committee and the Advisory Bodies in the national decision-making process. In the absence of a specific World Heritage advisory group reliance on Historic England’s advice during decision-making processes will continue to be vital in addressing the ongoing threat to this property posed by cumulative impacts, especially from high-rise developments.