United Kingdom Holocaust Memorial and Learning Centre Environmental Statement (Volume 3) Built Heritage, Townscape and Visual Impact Assessment December 2018 The Secretary of State for Housing Communities and Local Government All Ordnance Survey Plans are © Crown Copyright. All rights reserved. Licence Number: 100007624 © Copyright 2018. 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 EXECUTIVE SUMMARY 3 5.0 ASSESSMENT OF HERITAGE ASSETS’ SIGNIFICANCE 46 APPENDICIES The Proposed Development: UK Holocaust Memorial and Learning Centre 01: HERITAGE BASELINE 6.0 BASELINE: TOWNSCAPE AND VISUAL 60 Assessment Methodology 02: HAYES DAVIDSON METHODOLOGY Key Considerations 7.0 POTENTIAL IMPACTS AND MITIGATION MEASURES 70 Summary of Effects Conclusion 8.0 ASSESSMENT: HERITAGE RECEPTORS 74 Operational Phase 1.0 INTRODUCTION 8 Registered Parks and Gardens Purpose of the Report Listed Buildings Accurate Visual Representations Conservation Areas Pre-Application Consultation 9.0 ASSESSMENT: TOWNSCAPE 86 2.0 METHODOLOGY 12 Baseline Assessment of Value 10.0 ASSESSMENT: VISUAL 92 Assessment of Sensitivity and Magnitude 11.0 CUMULATIVE EFFECTS 208 Likely Significant Effects 12.0 SUMMARY AND CONCLUSIONS 200 3.0 LEGISLATION AND PLANNING POLICY 20 The Proposed Development: UK Holocaust Memorial and Learning Legislation Centre Development Plan Policy and Approach Material Consideration Overview of Assessment: Heritage Emerging Policy Overview of Assessment: Townscape 4.0 BASELINE: BUILT HERITAGE 30 Overview of Assessment: Visual Overview of Historical Development Conclusions 2 © Montagu Evans LLP 2018 | National Holocaust Memorial EXecutive SUMMARY 3 EXECUTIVE SUMMARY This Chapter of the Environmental Statement (ES) assesses the The development of the project began in 2015 with the establishment of The process we have adopted in our volume follows technical and best Proposed Development of the United Kingdom Holocaust Memorial the UK Holocaust Memorial Foundation Advisory Board. The design has practice guidance, as outlined inSection 2.0 and 3.0 of this document. and Learning Centre and whether it has any effects on built heritage, been created by Adjaye Associates and Ron Arad Architects, who were We have also had regard to statutory considerations and the policies of townscape, and visual amenity. The impacts of the proposals on selected through a competition-process judged by a panel comprising the development plan, which require or imply a particular methodology. strategic views as defined in the London View Management Framework the Secretary of State for Communities and Local Government, the The process involves identification of what are known as ‘receptors’ are also considered. This chapter has been prepared by Montagu Evans Mayor of London, the Chief Rabbi, and Holocaust Survivors. in an analysis of what are termed ‘baseline conditions’. A receptor is LLP on behalf of the Secretary of State for Housing, Communities and Victoria Tower Gardens was selected as the correct location for its something or someone which experiences a proposed development in a Local Government. proximity to Parliament. way which matters to the planning process. The ‘baseline’ is, broadly, the The purpose of this summary is to identify impacts of particular existing situation taking into account certain consented schemes on a The location is significant for two reasons. Firstly, it will provide the relevance to the decision-making process. The range of potential case by case basis made clear in the documentation. context for visitors’ examination of the British Government’s response significant direct and indirect effects is described in detail, according to to the Holocaust, which supports the function as a Learning Centre. Thus, in this volume, there are three baselines; Built Heritage, each topic, in the ES Chapter. The relevant sections of this Volume of the Secondly, the distinctive form of the memorial will serve as a poignant Townscape (defined in relation to areas of particular and identifiable ES should be consulted for the full range of effects. reminder of the importance of democratic government, at the seat of character) and Visual. The latter category includes both incidental views, Our assessment has been undertaken by qualified professionals (MRTPI/ one of the world’s oldest Parliamentary Democracies, and thus facilitate experienced by a user of an environment, and planned views, including IHBC) and informed by best practice guidance, including Historic an ongoing dialogue concerning the role of the state not just in 20th those formally designated in the London View Management Framework England guidance on significance and setting, GLVIA 3, the Mayor’s century history, but in the evolving modern world. Parliament is part of (LVMF) (2012). Impacts on views can, for example, be ones which affect guidance on protecting the setting of World Heritage Sites, ICOMOS a system of government which enshrines the rule of law; the murder of our ability to appreciate what is special about the historic environment, Guidance on Heritage Impact Assessments for Cultural World Heritage European Jews stands outside this political framework. or the way in which people experience a scene. This form of assessment, Properties and relevant Supplementary Planning Documents. In carrying it is accepted, concerns views from publicly accessible viewpoints, and Assessment Methodology out this appraisal we are mindful of the statutory considerations relating not from private land or accommodation. Heritage setting impacts occur This HTVIA ES Chapter is designed to meet the terms of regulations to the setting of listed buildings and development in a conservation area. irrespective of public access. In this case, all of the heritage setting and so assist the local planning authority in the determination of this Section 2.0 describes this decision-making framework. impacts affect publicly accessible views. application. The HTVIA is also there to inform statutory consultees, The Proposed Development: UK Holocaust Memorial and Learning amenity societies, local groups and individuals affected by the Centre proposals or with some interest in them. We have sought to prepare The proposals for the UK Holocaust Memorial and Learning Centre a document which addresses these different audiences. For the non- (UKHMLC) seek to create a memorial to the Jewish people of Europe specialist reader, this executive summary is intended to highlight the and all other victims of the Nazi persecution, with an exhibition which most relevant impacts. The purpose of an ES is not to identify ALL of a will set the Holocaust within the British narrative. proposal’s impacts, just those which have a significant indirect or direct effect. What comprises a significant effect is a matter of judgment, but generally a significant effect will be one which is material to the exercise of planning judgment and hence planning decision making. Built Heritage, Townscape and Visual Impact Assessment: Environmental Statement | December 2018 4 EXecutive SUMMARY Key Considerations Summary of Effects Whilst the memorial would appear in some views from the south of the park towards the WHS, introducing a new feature in the view of The salient consideration as applicable to this Volume is whether the In relation to the Westminster WHS, the salient consideration is whether Victoria Tower and associated parts of the Palace, the elevational Proposed Development will preserve or enhance the character and the Proposed Development would preserve or enhance the Outstanding treatment, scale and form of the above ground elements of the NHM appearance of the surrounding area, including the contribution made by Universal Value (“OUV”) of the Westminster WHS, situated to the north have been designed to respond, and remain subservient to, the Houses the Site to designated heritage assets and their settings, the functioning of the Victoria Tower Gardens. In undertaking our assessment, we have of Parliament. and use of the space, and the visual amenity of those experiencing views had regard to the ICOMOS ‘Guidance on Heritage Impact Assessments of the Site. In approaching our assessment of these impacts, we note for Cultural World Heritage Properties’ (2011) and the Mayor’s ’London The impact of the UKHMLC at night has also been considered. This is that the scale of the proposals and the surrounding urban environment Word Heritage Sites – Guidance on Settings’ SPG (2012). We have relied addressed in more detail in the Visual Impact Assessment at Section mean that the UKHMLC would only be experienced within a relatively on the published World Heritage Site Management Plan (2007), which 10.0, but, in brief, the scheme of lighting has been designed so as to contained area. We have paid particular regard to the impact of the details the reasons for the designation and explains the nature of its preserve the pre-eminence of the Palace of Westminster in night-time proposals on the ability to appreciate the Outstanding Universal Value of OUV. With this in mind, we conclude that the Proposed Development views (evening viewing conditions), as well as the relative tranquillity the Westminster World