Historic England has warned the City of London Corporation’s draft policies for tall buildings represent a ‘real threat’ to the Tower of London’s World Heritage Status. The public body has also raised a litany of concerns about the wider heritage impacts of the City’s draft local plan, entitled City Plan 2040, describing it as ‘unsound in its current form’.
Deputy Shravan Joshi, Chair of the Planning and Transportation Committee, said the plan offers ‘a bespoke and exhaustive approach to tall buildings and heritage’, and that its policies will ensure development projects celebrate heritage assets while supporting the capital’s economic growth.
The City Plan 2040, which is in the process of going through consultation, will be the Corporation’s guiding document when it comes to developing the Square Mile. From housing needs to offices and cultural spaces, it details the City’s priorities and policies to steer future planning decisions.
In his introduction to the draft plan, Deputy Joshi wrote: “The City of tomorrow will be shaped by many people, groups and organisations – as has this City Plan. It sets out our vision for a Square Mile that is economically, socially, and environmentally sustainable; a City that becomes ever more vibrant and competitive; a place that welcomes everyone; a place that – as it changes – continues to be utterly, thrillingly unique.”
Concerns regarding the City’s approach to heritage assets have been raised in response to a number of recent planning applications. London Wall West, which will involve demolishing the former Museum of London building and Bastion House and replacing them with office blocks, received particularly vociferous opposition. It was granted approval in April this year.
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The extent to which the draft plan would protect key heritage assets in the City has also been previously called into question. A representation loaded on the City Plan 2040 webpage from Bevis Marks Synagogue, the UK’s oldest synagogue in continuous use, called for the Corporation to better protect its setting and amenities from tall buildings. The synagogue is currently opposing plans for a 43-storey tower at 31 Bury Street, which it says would affect the site.
The Local Democracy Reporting Service (LDRS) has now received a copy of the submission by Historic England, the Government body tasked with protecting and enhancing the country’s historic environment, which describes the draft plan as ‘unsound’.
The representation, which is dated May 24 and has not been made public, does praise the ‘positive aspirations’ for the Square Mile’s heritage and history listed in the City Plan 2040, including its expanded archaeology policy and policies on retrofit and refurbishment of existing buildings.
However, it continues to note there is ‘a very serious inherent conflict and incompatibility between the draft Plan’s general, high level aspirations for the historic environment’ and its target of adding 1.2 million square metres of office floorspace, to be delivered via tall buildings in the ‘City Cluster’ and ‘Fleet Valley’ zones.
This is partly due to a lack of clarity on some of the data, though Historic England also argues that concentrating such a volume of new office space in the defined ‘cluster’ areas would result in ‘serious adverse effects’ on the historic environment.
The public body also directs attention to a number of sites it believes will be particularly impacted. This includes the Tower of London, on which it wrote: “Our concern is such that we believe that policies relating to tall buildings and the City Cluster in the draft Plan represent a real threat to the World Heritage Site status of the Tower of London.
“We would particularly point out that UNESCO has requested a State of Conservation report for the WHS following recent notifications about tall building proposals in the City affecting the Tower of London. To support the management of the WHS the State Party has notified UNESCO of the draft Plan and requested a Technical Review. We will share this with the Corporation once it is made available.”
Historic England further mentions both Bevis Marks Synagogue and St Paul’s Cathedral, on which it wrote it disagrees with the Heritage Impact Assessment drawn up to accompany the draft plan. “We consider that the quantum of development proposed would result in severe harm to the significance of St. Paul’s Cathedral and the Outstanding Universal Value of the Tower of London,” the submission reads. “In the case of St. Paul’s, our conclusion is supported by the setting study which we and the Dean and Chapter have jointly commissioned.”
Historic England added the study ‘makes clear the critical contribution that setting makes to the cathedral’s significance, and, therefore, its vulnerability to the effects of unsympathetic development. We consider that a number of elements of the evidence base should be revisited to ensure it is comprehensive, appropriate and better reflects the level of impacts and harm’.
Concluding its submission, Historic England wrote it does not consider the City Plan 2040 ‘would be effective in its objectives’, with the policies relating to offices and tall buildings likely to ‘severely harm’ assets such as St Paul’s and the Tower of London.
“Historic England is acutely aware of the important role the City of London plays in both the regional and national economy. We wish to work with the City to find ways to accommodate growth while conserving the historic environment. Both objectives are necessary ones, and both are fundamental objectives of the National Planning Policy Framework.
“Finding a way to reach an appropriate balance between the strategic objectives and to revise the Spatial Strategy will clearly require further work on the part of all stakeholders. However, we consider this is both important and necessary if both conservation of the City’s extraordinary historic environment and growth are to be successfully enabled.”
Responding to Historic England’s representation, Deputy Joshi said: “The Square Mile is both the historic heart of the capital and a world-leading business district. The City Plan 2040 is underpinned by a robust evidence base that shows how demand for quality office space in the Square Mile is expected to rise, with City workers and businesses being enticed back to the City and the vibrant and dynamic working environment the Square Mile provides.
“The City Plan sets out how we will deliver additional office floorspace up to 2040 at the same time as celebrating the City’s heritage. Recognising the exceptional significance of the World Heritage Site and the Cathedral, the Plan takes a bespoke and exhaustive approach to tall buildings and heritage. The policies in the Plan will ensure development protects and celebrates all our heritage assets while continuing to support the economic growth of the capital.
“In the City, growth and conservation combine to define what is unique about the Square Mile, and this is ultimately at the heart of the Plan.”
The consultation on the City Plan 2040 is due to run until June 17. It will then be submitted to the Secretary of State before being examined by the independent Planning Inspector. It is expected to be adopted by the City of London Corporation in 2025.
A spokesperson for Historic Royal Palaces, which manages the Tower of London, said: “We support the concerns raised by Historic England regarding the proposals for the City Plan 2024. We have raised similar concerns in our own response.” Historic England was also approached for comment.
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