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Victoria Tower Gardens Conservation and Site Included on Historic THE VICTORIA TOWER GARDENS, WESTMINSTER, LONDON, S.W.1. PROPOSED MEMORIAL AND LEARNING CENTRE DEVELOPMENT A RESPONSE BY THE THORNEY ISLAND SOCIETY TOGETHER WITH SAVE VICTORIA TOWER GARDENS 1. INTRODUCTION 1.1 This report has been prepared on behalf of The Thorney Island Society together with Save Victoria Tower Gardens. 1.2 The report conveys the objections of the groups to the current application for Planning Permission for the proposed development of a significant part of the Victoria Tower Gardens for the installation of the United Kingdom Holocaust Memorial and Learning Centre as submitted in December, 2018 by the Secretary of State for Housing, Communities and Local Government to Westminster City Council – reference 19/00114/FULL - and the basis of such concerns in relation to the potential impact of the proposals on the character, appearance and significance of the Westminster Abbey and Parliament Square Conservation Area; on the settings of the immediately adjacent Smith Square and nearby South Bank Conservation Areas; on the settings of the two parts of the nearby Palace of Westminster and Westminster Abbey including Saint Margaret’s Church World Heritage Site; and on the settings of nearby listed buildings and structures. 1.3 The objections of the groups to the proposed development are Section 2 of the report. These are related to the relevant national, London-wide and local planning policies and guidance, A summary of the particular heritage assets which will be affected by the proposals are set out in Section 3 of the report – this complements the London Parks and Gardens Trust’s Victoria Tower Gardens Conservation and Significance Statement of January, 2019. A summary of the potential impact of the proposed development on those particular heritage assets are set out in Section 4. 1.4 The groups confirm their full recognition of the assessment of the heritage significance and amenity value of the Victoria Tower Gardens set out in the London Parks and Gardens Trust’s Statement and their unreserved support for the Trust’s representations as set out in its letter to the City Council of the 4th February, 2019 in relation to the potential impact of the proposals on the Victoria Tower Gardens as a site included on Historic England’s Register of Parks and Gardens of Special Historic Interest (and in the National Heritage List for England) and as a park included in the Trust’s London Inventory of Historic Spaces. 1 1.5 The groups also confirm their unreserved support for the representations of ICOMOS as set out in its letter to the City Council of the 15th February, 2019 in relation to the potential impact of the proposals on the Palace of Westminster and Westminster Abbey and St Margaret’s Church World Heritage Site, and the representations of Historic England as set out in its letter of the 1st March, 2019 in relation to the potential impact of the proposals on heritage assets. 1.6 At the outset, the groups would stress that their objections relate exclusively to the potential impact of the proposed development on this particular site and should not be construed as conveying or implying comment on the principle of developing a memorial to the Holocaust and a related learning centre on any other site in London or elsewhere within the United Kingdom. 1.7 The heart of the groups’ objections is the potential and substantially harmful impact of the proposed development on the Victoria Tower Gardens as a designated heritage asset and public amenity; on the character, appearance and significance of the Westminster Abbey and Parliament Square Conservation Area; on the setting of the immediately adjacent Smith Square Conservation Area; on the settings of the two parts of the nearby Palace of Westminster and Westminster Abbey including Saint Margaret’s Church World Heritage Site; and on the settings of nearby listed buildings and structures. The groups are most seriously concerned that development proposals which conflict so fundamentally with the Government’s own formal policies for the protection of the historic built environment as set out in the National Planning Policy Framework of July, 2018, have been submitted by the Secretary of State for Housing, Communities and Local Government on land owned by the Department for Digital, Culture, Media and Sport. 2. THE OBJECTIONS OF THE GROUPS 2.1 The groups’ objections are based upon a careful assessment of the extensive documentation submitted in support of the application; an assessment of the contribution made by the Victoria Tower Gardens to designated and non-designated heritage assets and public amenity in the affected area; and an assessment of the potential impact of the submitted proposals on those designated and non-designated heritage assets and that public amenity against the relevant national, London-wide and local planning policies and supplementary planning guidance. 2.2 The groups believe that proposals involving the loss of some 26.9% of the present green-space within the Gardens (see LPGT Plan 3 attached to the London Parks and Gardens Trust’s representations of the 4th February, 2019) will be contrary to paragraphs 97 and 98 of the National Planning Policy Framework of July, 2018; Policies 7.4. B, 7.5.B and C, and 7.18.B of the London Plan of March, 2016; Policies S25 and S35 of Westminster’s City Plan of July, 2016; saved Policies ENV 15 (A), ENV 16(A) and 2 DES 12 (B) of the City of Westminster Unitary Development Plan of January, 2007; and Priority 1of The City of Westminster Open Space Strategy SPD of February, 2007. 2.3 The groups also believe that such proposals will also have a substantially harmful impact on the special historic interest and significance of the Gardens as a designated heritage asset and on the character, appearance and significance of the Westminster Abbey and Parliament Square Conservation Are as a designated heritage asset; and a seriously harmful effect on the setting of the immediately adjacent Smith Square Conservation Areas as a designated heritage asset; on the settings of the two parts of the nearby Palace of Westminster and Westminster Abbey including Saint Margaret’s Church World Heritage Site as a designated heritage asset; and on the settings of nearby listed buildings and structures as designated heritage assets; contrary to Paragraphs 193, 194, 195 and 196 of the National Planning Policy Framework of July, 2018; Policies 7.4.B., 7.5.B., 7.8.C. and D., 7.9.B. and 7.10. B. of the London Plan of March, 2016; and Policy S25 of Westminster’s City Plan of July, 2016; saved Policies of the Unitary Development Plan of January, 2007; the relevant provisions of Westminster City Council’s Westminster Abbey and Parliament Square Conservation Area Audit and Management Proposals SPD of September, 2008; and Objective 1 of The Palace of Westminster and Westminster Abbey including Saint Margaret’s Church World Heritage Site Management Plan of May, 2007. 2.4 The groups believe that proposals involving the creation of substantially scaled built development both above ground and below ground and associated with significant changes to the existing landscape of the Gardens will be contrary to paragraphs 97 and 98 of the National Planning Policy Framework of July, 2018; Policies 7.4. B, and 7.5.B and C of the London Plan of March, 2016; Policies S25 and S35 of Westminster’s City Plan of July, 2016; saved Policies ENV 15 (A), ENV 16(A) and DES 12 (B) of the City of Westminster Unitary Development Plan of January, 2007; and Priority 1of The City of Westminster Open Space Strategy SPD of February, 2007. 2.5 The groups also believe that the proposals will also have a substantially harmful impact on the special historic interest and significance of the Gardens as a designated heritage asset and on the character, appearance and significance of the Westminster Abbey and Parliament Square Conservation Area as a designated heritage asset, and a seriously harmful effect on the setting of the immediately adjacent Smith Square Conservation Areas as a designated heritage asset; on the settings of the two parts of the nearby Palace of Westminster and Westminster Abbey including Saint Margaret’s Church World Heritage Site as a designated heritage asset; and on the settings of nearby listed buildings and structures as designated heritage assets; contrary to Paragraphs 193, 194, 195 and 196 of the National Planning Policy Framework of July, 2018; Policies 7.4.B., 7.5.B., 7.8.C. and D., 7.9.B. and 7.10. B. of the London Plan of March, 2016; and Policy S25 of Westminster’s City Plan of July, 2016; saved Policies DES 9 (F), DES 10 (D) and DES 12 (B) of the City of Westminster Unitary 3 Development Plan of January, 2007; the relevant provisions of Westminster City Council’s Westminster Abbey and Parliament Square Conservation Area Audit and Management Proposals SPD of September, 2008; and Objective 1 of The Palace of Westminster and Westminster Abbey including Saint Margaret’s Church World Heritage Site Management Plan of May, 2007. 2.6 For the reasons set out in paragraphs 2.2, 2.3, 2.4 and 2.5 above, the groups would urge that the application should be refused. 3. AN ASSESSMENT OF THE CONTRIBUTION MADE BY THE VICTORIA TOWER GARDENS TO THE CHARACTER, APPEARANCE AND SIGNIFICANCE OF THE WESTMINSTER ABBEY AND PARLIAMENT SQUARE CONSERVATION AREA; TO THE SETTING OF THE IMMEDIATELY ADJACENT SMITH SQUARE CONSERVATION AREA; TO THE SETTINGS OF THE TWO PARTS OF THE NEARBY WESTMISTER WORLD HERITAGE SITE: AND TO THE SETTINGS OF NEARBY LISTED BUILDINGS AND STRUCTURES 3.1 Together with College Green (formerly known as Abingdon Street Gardens), Black Rod’s Garden (sic), Broad Sanctuary, Canning Green, College Gardens, Cromwell Green Dean’s Yard, Little Dean’s Yard, New Palace Yard, Old Palace Yard, Parliament Square, Speaker’s Green, St Margaret’s Churchyard and the garths of Great Cloister and Little Cloister (within the Abbey Precinct), the Victoria Tower Gardens forms a group of both green and hard-paved open-spaces of considerable historic and landscape interest and significance within the historic heart of Westminster.
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