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.

1.5 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

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

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. Importantly, however, the Victoria Tower Gardens is by far the largest of these open- spaces and, importantly, is a publicly accessible green space, surrounded by very fine, mature trees, and bordered on its eastern side by one of the most significant stretches of the Thames as it flows through the centre of London. (See Figure 126 in Westminster City Council’s Westminster Abbey and Parliament Square Conservation Area Audit and Management Proposals attached, showing open spaces, etc.).

3.2 The Victoria Tower Gardens are a creation of the last quarter of the 19th century. The greater part of the existing Gardens replaced a series of riverside wharves and other industrial premises that once extended along the riverbank between the southern end of the Palace of Westminster in the north and the old Lambeth Bridge in the south, whilst the lesser, eastern part was developed by the infilling of part of the former riverbank behind a new embankment wall extending southwards from the earlier embankment wall serving the rebuilt Palace of Westminster to Lambeth Bridge.

3.3 Today, the considerable landscape interest of the Victoria Tower Gardens is reflected in their formal inclusion at grade II on the Register of Parks and Gardens of Historic Interest. The particular interest and significance of the Gardens are explained in the description accompanying their entry in the National Heritage List for England and assessed in detail in the London Parks and Gardens Trust’s Victoria Tower Gardens

Conservation and Significance Statement, which also includes detailed references to the several, listed structures and art-works contained within the gardens. These include S.S. Teulon’s Buxton Memorial Fountain of 1865 (listed at grade II*), Rodin’s The Burghers of Calais of 1915 (listed at grade I) and Arthur George Walker’s Emmeline Pankhurst of 1930 (listed at grade II). The northern end of the Gardens is defined by the southern boundary-fence to Black Rod’s Garden (sic), the eastern edge by the parapet of the grade II listed embankment wall, and the southern end by the grade II listed Lambeth Bridge approach wall, obelisk and steps. The western side of the Gardens abuts Abingdon Street in the north and Millbank along the reminder of its length.

THE WESTMINSTER ABBEY AND PARLIAMENT SQUARE AND SMITH SQUARE CONSERVATION AREAS

3.4 The Victoria Tower Gardens are located within the Westminster Abbey and Parliament Square Conservation Area, first designated as a separate conservation area in 1987, and previously designated as part of the larger Government Precinct Conservation Area in 1969. (See Figure 80 in Westminster City Council’s Westminster Abbey and Parliament Square Conservation Area Audit and Management Proposals attached, showing the boundary of the conservation area, listed buildings and unlisted buildings of merit). Similarly, before 1987, the adjacent Smith Square Conservation Area was designated as part of the same, larger Government Precinct Conservation Area. Whilst the Victoria Tower Gardens fall within the Westminster Abbey and Parliament Square Conservation Area, they form an essential part of the immediate setting of the Smith Square Conservation Area, on the western side of Abingdon Street and Millbank between Great College Street in the north, and Horseferry Road in the south. (See Figure 10 in Westminster City Council’s Smith Square Conservation Area Audit attached, showing the boundary of the conservation area, listed buildings and unlisted buildings of merit). The eastern boundary of the Westminster Abbey and Parliament Square Conservation Area runs down the centre- line of the river between Westminster Bridge and Lambeth Bridge, as also that of the Smith Square Conservation Area upstream of Lambeth Bridge.

3.5 In September, 2008, Westminster City Council adopted the Westminster Abbey and Parliament Square Conservation Area Audit and Management Proposals as a supplementary planning document.

3.6 The published document contains a detailed analysis of the character of the area (Section 4), placing the Victoria Tower Gardens with the Palace of Westminster in ‘Area 1’ – see Figure 11: Character areas) – describing the Gardens as follows: ‘The Victoria Tower Gardens, to the south of the Palace, provides an attractive escape from the busy routes around. This large area of green open space enjoys a riverside location, with expansive views along the Thames and to the Victoria Tower’ (paragraph 4.4). ‘The large open space of Victoria Gardens, to the west (sic) of

Victoria Tower, was created as part of Victorian improvements and slum clearance (sic) and provides a sheltered public garden and an escape from the adjacent busy roads. The gardens are enclosed by an abundance of planting to the roadside and by the Thames to the east…’ (paragraph 4.23). in Section 5 of the published document headed ‘Townscape detail’, the Gardens are described as follows: ‘Victoria Tower gardens, the largest area of green open space within the conservation area, is located beside the Thames, framed by the river embankment granite wall and stretching from the southern façade of the Palace down to Lambeth Bridge. It was originally laid out as a Victorian metropolitan public space and has an abundance of mature London Plane trees around open lawns and flowerbeds. The area also has a small children’s playground to the south and shrubs and lawns around the perimeter of the garden. It is on the English Heritage Register of Historic Parks and Gardens, Grade II’ (paragraph 5.59).

3.7 Importantly, the Gardens through their particular size and location and attractive landscape character, contribute positively to the character, appearance and significance of not only ‘Area 1’ of the conservation area as defined in Figure 11 of the Council’s Westminster Abbey and Parliament Square Conservation Area Audit and Management Proposals document, but to the character, appearance and significance of the conservation as a whole – the ‘designated heritage asset’. Importantly, too, the Gardens form a significant feature of the conservation area as seen and valued from the edge of the designated area and from outside the area, such as from Abingdon Green (within Area 3), from along both the western and eastern sides of Abingdon Street and Millbank, from the eastern ends of Great College Street, Great Peter Street, Dean Stanley Street and Horseferry Road, and from the downstream side of Lambeth Bridge and from across the river along Albert Embankment.

3.8 Whilst falling just outside the eastern boundary of the Smith Square Conservation Area, the Victoria Tower Gardens contribute positively to its setting. In January, 2005, Westminster City Council adopted the Smith Square Conservation Area Audit as supplementary planning guidance.

3.9 The published document contains a detailed analysis of the character of the area (Section 4).

3.10 The eastern edge of the conservation area to the north of the junction of Millbank and Horseferry Road is defined by a series of substantially scaled, early-20th century and inter-War office buildings extending along the western side of Abingdon Street and Millbank, to north and south of the junctions with Great Peter Street and Dean Stanley Street. The Victoria Tower Gardens, and the very fine, mature trees along their eastern side in particular, provide an essential counterpoint to the height and visual dominance of the office buildings.

3.11 To the south of the junction of Millbank with Horseferry Road, the southern part of the Victoria Tower Gardens, and the very fine, mature trees in that part of the Gardens in particular, play an important role as a back-drop to the rond-point as seen from the south-western corner of the junction at the foot of Thames House North, and as an essential counterpoint to the height and visual dominance of the north- eastern corner of Thames House North.

THE TWO PARTS OF THE WESTMINSTER WORLD HERITAGE SITE

3.12 Whilst the Victoria Tower Gardens do not fall within the Palace of Westminster and Westminster Abbey including Saint Margaret’s Church World Heritage Site, they are clearly located within the ‘Study Area’ identified in the map on page 6 of the Management Plan (see below) and clearly included within the ‘Palace of Westminster and Victoria Tower Gardens Character Area’ in the map of character areas on page 64 of the Management Plan (see below), and form an essential part of the settings of the two respective parts of the World Heritage Site. (See Figure 14 in Westminster City Council’s Westminster Abbey and Parliament Square Conservation Area Audit and Management Proposals attached, showing the boundary of the Westminster World Heritage Site).

3.13 The vision, objectives and proposed implementation for the Westminster World Heritage Site are set out in the Palace of Westminster and Westminster Abbey including Saint Margaret’s Church World Heritage Site Management Plan as formally adopted in May, 2007.

3.14 In Sub-section 1.6.2 of the Management Plan – Spaces of the Management Plan, the Victoria Tower and Gardens are included as one of the ‘important spaces adjoining all the principal buildings in the WHS…’ (paragraph 1.6.2.1.). In the same section, the Gardens are described as follows:

‘Victoria Tower Gardens has remained as conceived, framed by the river embankment granite wall and railings on the roadside. Following the completion of the Palace, it was laid out as a Victorian metropolitan scale public open space with mature London Plane trees. It contains statues, the Suffragette Memorial Wall, the Buxton Memorial, a small children’s playground to the south, riverside raised benches and perimeter shrubs and lawns. This space currently lies outside the WHS boundary’ (paragraph 1.6.2.1).

3.15 Under Section 1.7 of the Management Plan – Outside the WHS: The Immediate environs, and in Sub-Section 1.7.2 – Victoria Tower Gardens, the Gardens are described as follows:

‘At present the Victoria Tower Gardens to the south is not included in the WHS boundary but forms an important part of the setting. It contains a number of

memorial sculptures, in particular the Pankhurst memorial and the Burghers of Calais, by Rodin’ (paragraph 1.7.2.1).

3.16 Anomalously, unlike other World Heritage Sites, the Palace of Westminster and Westminster Abbey including Saint Margaret’s Church World Heritage Site has no defined ‘buffer zone. Instead, Objective 7 of the Management Plan proposes a remedy to the omission:

‘To assess the feasibility of establishing a Buffer Zone, (defined Local Setting) or similar designated area, within the context of the policies contained in the London Plan, the Westminster City Council Unitary Development Plan, and the Unitary Development Plans or Local Development Frameworks of other Local Planning Authorities affected, as well as national policies. The establishment of the Buffer Zone (Defined Local Setting) could be preceded by an assessment of the key local views affecting the WHS and the characteristic of the immediate setting of the WHS , the variety of scales of adjoining buildings, the River Thames corridor and approaches from all sides, and views especially to and from south (sic) of the river. Such studies may assist in informing reactions to development proposals’.

3.17 Importantly, under Section 5 of the Management Plan – Objectives for the Management Plan, Objective 1 – the overall objective is stated as:

‘To safeguard the Outstanding Universal Value for which the Westminster WHS was inscribed which are embodied in the buildings, spaces, monuments, artefacts and archaeological deposits within the site, the setting and views of and from it, its iconic status and the activities which take place within the WHS. The Management Plan should seek to guide, influence and advise those who are managing the organisations involved in the site’.

3.18 Quite clearly, as noted in paragraph 3.13 above, the Victoria Tower Gardens is clearly regarded as ‘an important part of the setting’ of the Westminster World Heritage Site’ under the Management Plan and that safeguarding its setting and views of and from it is seen as a first objective. Importantly, the northern end of the Victoria Tower Gardens abuts the southern end of the Palace of Westminster part of the WHS, whilst the northern end of the Gardens is located in close proximity to the south-eastern quarter of the Westminster Abbey and Saint Margaret’s Church part of the WHS, only separated by Abingdon Green and Abingdon Street. Not only do the Gardens enjoy a close relationship with both parts of the WHS in terms of proximity, but also and importantly they enjoy a close visual relationship in terms of views from the Gardens into the WHS and views from the WHS into the Gardens.

THE SETTINGS OF NEARBY LISTED BUILDINGS AND STRUCTURES

3.19 Not only do the Victoria Tower Gardens abut or contain a significant number of listed structures and art-works including the parapet of the grade II listed embankment

wall, and the grade II listed Lambeth Bridge approach wall, obelisk and steps, S.S. Teulon’s Buxton Memorial Fountain of 1865 (listed at grade II*), Rodin’s The Burghers of Calais of 1915 (listed at grade I), and Arthur George Walker’s Emmeline Pankhurst of 1930 (listed at grade II), but they form an essential part of the settings of a significant number of nearby listed buildings and structures and unlisted ‘buildings of merit’ as defined by and identified by Westminster City Council in the Westminster Abbey and Parliament Square Conservation Area Audit and the Smith Square Conservation Area Audit. (See Figure 80 in the former and Figure 10 in the latter).

3.20 In the immediate proximity to the Gardens and of the greatest importance in this context are the grade I listed Palace of Westminster – in particular The Victoria Tower and the southern elevation - and the separately listed grade I listed Victoria Tower Lodge and Gates to Black Rod’s Garden. Of the many listed buildings and structures, and unlisted ‘buildings of merit’ within the area, it is the grade I listed 14th century Jewel Tower, the grade I listed ‘Former dock retaining walls to the moat around the Jewel House, the grade I listed, early-mediaeval Abbey Precinct Wall defining the eastern and southern boundaries to the Abbey Garden, Henry Moore’s grade II* listed Knife Edge Two Piece bronze on College Green, the grade II listed no. 1, Abbey Garden, the grade II listed Nos. 1 and 2, Millbank, the unlisted No. 4, Millbank (on the southern corner of Millbank and Great Peter Street Great), the unlisted Westminster House (on the northern corner of Millbank and Dean Stanley Street), the unlisted Cromwell House (on the southern corner of Millbank and dean Stanley Street), the grade II listed Norwest House (formerly ICI House), (fronting Millbank), the grade II listed Thames House North (on the southern corner of Millbank and Horseferry Road), and the grade II listed Lambeth Bridge, the settings of which will be most substantially affected by the proposed development in the Victoria Tower Gardens on the directly opposite (eastern) side of Millbank.

4. THE PROPOSALS AND THEIR POTENTIAL IMPACT

4.1 The groups note that the proposals involve the introduction of substantially scaled development, both above ground and below ground in the centre and southern part of the Victoria Tower Gardens, including radical changes to the existing landscape of the Gardens.

4.2 Despite the extraordinarily extensive and detailed material submitted in support of the application for Planning Permission and the Environmental Statement, it is quite clear from the Design and Access Statement (specifically the Introduction, Project context, Design considerations, and Design proposals); the submitted drawings, the Verified and architectural views; and the Built Heritage, Townscape and Visual Impact Assessment (in Volume 3 of the Environmental Statement) that the proposed development is not only entirely insensitive to its internationally renowned context and to an area of much valued public amenity but will have a substantially harmful impact on the particular

special architectural and historic interest, character, appearance and significance of the Victoria Tower Gardens and the surrounding area.

4.3 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 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.

4.4 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 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.

4.5 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.

4.6 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 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.

21st March, 2019.

Figure 126 from the Westminster Abbey and Parliament Square Conservation Area Audit showing Open spaces

Figure 80 from the Westminster Abbey and Parliament Square Conservation Area Audit showing the boundary of the conservation area, listed buildings and unlisted ‘buildings of merit’

Figure 10 from the Smith Square Conservation Area Audit showing the boundary of the conservation area, listed buildings and unlisted ‘buildings of merit’

Figure 14 from the Westminster Abbey and Parliament Square Conservation Area Audit showing the two parts of the Westminster World Heritage Site