United Kingdom Holocaust Memorial and Learning Centre Environmental Statement Addendum (Volume 3) Built Heritage, Townscape and Visual Impact Assessment April 2019 The Secretary of State for Housing Communities and Local Government All Ordnance Survey Plans are © Crown Copyright. All rights reserved. Licence Number: 100007624 © Copyright 2019. All worldwide rights reserved. No part of this publication may be reproduced, stored in a retrieval system or transmitted in any form by any other means whatsoever: i.e. photocopy, electronic, mechanical recording or otherwise without the prior written permission of the copyright holder. Any enquiries should be directed to: Montagu Evans LLP 5 Bolton Street London W1J 8BA. Tel: +44 (0)20 7493 4002 CONTENTS 1.0 INTRODUCTION 4 Scope and purpose of this addendum Policy Review Heritage Impact Assessment 2.0 ADDENDUM BUILT HERITAGE AND TOWNSCAPE ASSESSMENT 8 Heritage Summary Townscape 3.0 ADDENDUM VISUAL ASSESSMENT 14 View 9: TC4 View 11: Millbank towards North View 12: Horseferry Road View 15: Great College Street View 17: TC3B View 18: TC3A View 19: Victoria Tower Gardens View 22: TC6A View 23: Southern extent of Victoria Tower Gardens 4.0 HERITAGE IMPACT ASSESSMENT PROCESS 60 2 © Montagu Evans LLP 2019 | United Kingdom Holocaust Memorial and Learning Centre 1.0 // UNITEd KINGdoM HoLocaust MEMoRIAL ANd LEARNING CENTRE Introduction 4 IntroDUCTION 1.0 INTRODUCTION 1.1 Montagu Evans LLP has been instructed by the Ministry for Housing, Communities and Local Government to prepare this addendum to the (Built) Heritage, Townscape and Visual Impact Assessment (the ‘HTVIA’) for proposals to develop the United Kingdom Holocaust Memorial and Learning Centre (the ‘Proposed Development’). The HTVIA comprises Volume 3 of the Environmental Statement (ES) submitted for the application. 1.2 An application for planning permission (PP-00114/FULL) was submitted to Westminster City Council (‘the Council’) in December 2018 for: “Installation of the United Kingdom Holocaust Memorial and Learning Centre including excavation to provide a basement and basement mezzanine for the learning centre (Class D1); erection of a single storey entrance pavilion; re-provision of the Horseferry Playground and refreshments kiosk (Class A1); repositioning of the Spicer Memorial; new hard and soft landscaping and lighting around the site; and all ancillary and associated works”. 1.3 During the consultation process, the proposals have evolved in response to consultee comments. In broad terms, the parameters of the Proposed Development remain the same as for the submitted scheme, however a number of revisions have been made. These are illustrated at Figures 1.1 and 1.2. 1.4 The design changes which may potentially have an effect upon heritage, townscape and visual receptors are: A revised design for the entrance pavilion; and Adjustments to the design of the Memorial courtyard. 1.5 Notwithstanding these material changes, the potential effects upon built heritage, townscape and visual receptors are broadly very similar to those identified as part of the submitted scheme, because the memorial as a whole retains the same overall form, as shown in the drawings accompanying this revised application, and the verified views at Section 2.0. Figure 1.1 Image showing the revised entrance pavilion from Lambeth Bridge steps © Montagu Evans LLP 2019 | United Kingdom Holocaust Memorial and Learning Centre IntroDUCTION 5 1.6 The revisions to the Proposed Development also include internal changes at basement level. These changes will not affect the aforementioned receptors, and therefore are not described in our assessment. The character, functioning and appearance of the memorial would not change as a result of these modifications. 1.7 The HTVIA, and this further addendum, have been prepared by individuals of suitable qualifications in planning, urban design and heritage. Scope and purpose of this addendum 1.8 In light of the above design modifications, this addendum considers any potential change to the likely significant effects described Volumeat 3 of the ES, and should be read in conjunction with that volume. 1.9 Additionally, a diagram showing townscape character areas was erroneously omitted from Volume 3 of the ES; this should have been included at Figure 6.1 and 1.1.3 in Technical Appendix 1.1. This plan is included in this document at Figure 2.1. 1.10 Due to the scale and position of the entrance pavilion and courtyard, the experience of those elements of the proposals which are the subject of this addendum would be limited. Therefore, professional judgment has been used to select those built heritage, townscape and visual receptors which may experience a different effect from that identified in the HTVIA as a result of the change to the proposals. 1.11 The methodology for the assessment of effects remains the same as that outlined at Section 2.0 in Volume 3 of the ES. Figure 1.2 Image showing the Proposed Development from the south of Victoria Tower Gardens Built Heritage, Townscape and Visual Effect Assessment: Environmental Statement Addendum | April 2019 6 IntroDUCTION Policy Review 1.12 In writing this addendum, we have carried out a review of the relevant policy provisions and best practice guidance outlined in Section 3.0 of Volume 3 in the ES, to identify any which may have changed since the submission of the ES in December 2018. National Planning Policy Framework (2019) 1.13 Minor changes were made to the text of the NPPF and published on 19th February 2019. This does not affect our assessment. Westminster City Plan 2040 1.14 Consultation on the draft City Plan 2019-2040 closed on Friday 21st December 2018, and statutory Regulation 19 consultation is anticipated to take place in early 2019. The plan remains unadopted and therefore of limited weight and does not affect our assessment. Heritage Impact Assessment 1.15 In response to post-submission consultee comments, and for clarity, we also provide a synthesis of how the sections set out in our assessment relate to the stages of Heritage Impact Assessment (‘HIA’) as set out at Appendix 4 of the ICOMOS ‘Guidance on Heritage Impact Assessments for Cultural World Heritage Site Properties’. To be clear, this does not change our assessment of the impact of the Proposed Development on the Outstanding Universal Value of the World Heritage Site, and is intended to facilitate the reader’s clear understanding of how our assessment relates to the ICOMOS HIA framework. This is included at Section 4.0. © Montagu Evans LLP 2019 | United Kingdom Holocaust Memorial and Learning Centre 2.0 // UNITEd KINGdoM HoLocaust MEMoRIAL ANd LEARNING CENTRE Addendum Built Heritage and Townscape Assessment 8 AddENdUM Built Heritage ANd TowNSCAPE ASSESSMENT 2.0 ADDENDUM BUILT HERITAGE AND TOWNSCAPE ASSESSMENT 2.1 In composing this addendum, we have carried out a review of the 2.10 Therefore, we consider that the overall effect of the Proposed Victoria Tower Gardens (grade II RPG) baseline to identify any heritage or townscape receptors which have Development on the Conservation Area would remainModerate 2.20 The new entrance pavilion would occupy a smaller area than the changed, or been designated, from those identified inSections 5.0 and Beneficial. submitted scheme and be lower in height. The materials have been 6.0 in Volume 3, and Appendix 3.1 of the ES. 2.11 This effect would be direct, local and permanent. chosen to create a lightweight appearance which will allow light and 2.2 Our review finds that there are no new receptors to be included in this views into the space within. Westminster Abbey and Parliament Square Conservation Area addendum. 2.21 The simplified boundary fence to the memorial will allow a clearer view 2.12 The creation of the new National Holocaust Memorial and Learning Heritage toward the Buxton Memorial from the west, and the changed, triangular Centre would remain a new, symbolic feature which commemorates form of the entrance pavilion preserves and frames views from the 2.3 The heritage value of receptors within the study area is set out at and memorialises victims of the Holocaust. The principle of its Millbank entrance to the park to the Lambeth Bridge entrance. Section 5.0 and Appendix 1.3 to Volume 3 of the ES. establishment befits the existing character of the Conservation Area, and the high quality of the design of the memorial as a whole would 2.22 These changes will improve the appearance of the entrance pavilion 2.4 At site preparation and construction phase, we do not identify any make an important contribution to its character and appearance. within the park, as well as navigation around Victoria Gardens outside change to the effects identified Volumeat 3 of the ES. of the memorial. 2.13 The revised entrance pavilion would be experienced within a limited 2.5 Below, we consider any change to the effects of the Proposed area within the park, and its form would occupy a smaller area, and be 2.23 These changes relate to an aspect of the proposals which would be Development on heritage receptors. lower in height than the submitted scheme. The materials have been experienced as part of the whole. 2.6 For clarity, we include the Heritage Receptor Plan at Figure 2.1. chosen to create a lightweight appearance which will allow light and 2.24 Therefore, in ES terms, the impact of the Proposed Development would Palace of Westminster, Westminster Abbey and St Margaret’s Church views into the space within. remain the same. World Heritage Site 2.14 The simplified boundary fence to the memorial will improve the 2.25 The overall effect of the Proposed Development on the Victoria Tower 2.7 As described at Section 8.0 of Volume 3, the experience of the Holocaust permeability of the new courtyard space within the park, and allow a Gardens would be Moderate Beneficial.