In an extraordinary farce on Monday 28 Nov 2011 Tower Hamlets's Strategic Development Committee (or rather two of its members) stuck two fingers up to UNESCO. Having been defeated in their attempt to use Trinity Square Gardens for corporate entertainment, Tower Hamlets are determined to grant planning permission for a grotty glass box that will dominate the space. This was despite councillors voting to reject the application on 27 October.
The ghastly apparition above is the proposed CitizenM hotel on top of Tower Hill Underground Station, the structure in the foreground in Trinity Square Gardens is the Merchant Seaman's Memorial on the walls of which are recorded the names of 24,000 merchant seaman who gave their lives in the second world war, but whose bodies were never recovered. The photmontage below shows how the hotel will look from the Tower of London.
All is not lost however, Tower Hamlets planners omitted to tell the councillors of draft Supplementary Planning Guidance entitled ‘London World Heritage Sites – Guidance on Settings' published by the Greater London Authority on 31st October 2011 - a fatal error. This means that the matter ought to go back to committee again, but only after the applicants have submitted new material required by the new planning policy document. You can make your views known to Tower Hamlets by emailing Simon.Ryan AT towerhamlets.gov.uk or writing to him at LBTH Planning Department, Mulberry Place (AH), PO Box 55739, 5 Clove Crescent, LONDON E14 2BE quoting reference Tower House, 38-40 Trinity Square, London EC3N 4DJ Ref No: PA/11/00163.
Local amenity society Trinity Square Group have asked the Secretary of State to call-in the planning application for a ministerial decision after a public inquiry so you should copy your objections to John.Pierce AT communities.gsi.gov.uk or or by post to him at the national Planning Casework Unit, DCLG, Eland House, Bressenden Place, LONDON SW1E 5DU
If you enlarge this image by clicking on it you may notice a small patch of green immediately to the left of the proposed box. That is the roof of the grade I listed Trinity House less than fifty feet across the road from the application site.
UNESCO inspectors are due to visit the Tower of London on Wednesday, having just visited Liverpool, where the Liverpool Daily Post reports
"The three-day Unesco inspection, led by Ron van Oers, had left the city with clear guidance “100%” that, unless Peel’s Liverpool Waters project was radically changed, they will recommend the city be stripped of the World Heritage accolade. The official inspectors’ report will be written by December 23 and will then be sent to Liverpool council and Peel within two to four weeks."
UNESCO & WORLD HERITAGE STATUS Anybody reading journalists such as Jonathan Glancey about Liverpool or Simon Jenkins about the Tower of London might easily assume that World Heritage Status is something imposed by UNESCO on unwilling cities. The reality, as is clearly set out on the DCMS website http://j.mp/vnwuyx , is that localities around the country ask the UK government to nominate them to UNESCO.
WORLD HERITAGE STATUS & TOWN PLANNING Problems constantly arise because it is the Department of Culture, Media and Sport (DCMS) that deal with UNESCO, but it is the Department for Communities and Local Government who deal with Town Planning (DCLG). When towns and cities seek World Heritage Status DCMS persistantly fail to explain the town planning implications, and when UNESCO'S World Heritage Committee express concerns about the setting of World Heritage Sites DCMS fail to tell local authority planners. The situation is excarbated by the simple fact that DCMS officials do not understand town planning.
On 1 February 2011 DCMS official Peter Marsden wrote to Francesco Bandarin, the Director of the UNESCO World Heritage Centre in Paris. In the letter Mr Marsden claimed that "The Revised Supplementary Planning Guidance - London View Management Framework (LVMF) was published in July 2010..." & "The revised SPG strengthens protection for the Tower of London World Heritage property by:.. ..requiring planning authorities to consult with English Heritage, Historic Royal Palaces and the Tower of London World Heritage Site Consultative Committee on applications affecting World Heritage Sites and their settings;" It is simply not true that the LVMF requires planning authorities to consult with the Tower of London World Heritage Site Consultative Committee (and given that Mr Marsden is a member of that committee (see minutes of 5 May 2011 extremely difficult to understand how he made the mistake.)
The 35th session of the UNESCO World Heritage Committee held in Paris, France on 19-29 June 2011 considered a report regarding the Tower of London World Heritage Site http://whc.unesco.org/document/106540 pp229 - 233 (pp230 - 234 of the pdf) which stated in the third paragraph of its conclusions:
"The Tower is not better protected than it was two years ago and meanwhile, as the State Party acknowledges, development projects with tall buildings that could have an impact on the property, continue to be approved whilst all the policy issues associated with the property and its setting have not yet fully been resolved or promulgated. The setting of the Tower has seen drastic changes in the last decade and appears not to have been ‘managed’ to respect the OUV of the Tower. Building work has impacted on the setting of the Tower on three sides and the resulting glass structures do not enhance the presence of the Tower or allow it to project its former role."
In the end the UNESCO committee did not add the Tower to the List of World Heritage in Danger, but their decision is still somewhat robust:
The World Heritage Committee,
1. Having examined Document WHC-11/35.COM/7B,
2. Recalling Decision 33 COM 7B.127 adopted at its 33rd session (Seville, 2009),
3. Acknowledges the completion of the "Tower of London Local Setting Study", however, expresses great concern that this study only addresses individual views and a very narrow local setting, while the overall setting of the Tower in relation to the Outstanding Universal Value has not been defined and provided with protection in line with Decision 33 COM 7B.127 adopted by the Committee at its 33rd session (Seville, 2009);
4. Considers that the incremental developments around the Tower over the past five years have impacted adversely its visual integrity;
5. Requests the State Party to evaluate the impact of proposed changes to the visual setting of the property on its Outstanding Universal Value, and to develop and apply effective mechanisms for the protection of the setting as a matter of urgency;
6. Also requests the State Party to refrain from approving new construction projects in the vicinity of the property without assessing their potential impact on the Outstanding Universal Value of the property;
7. Further requests the State Party to invite a joint World Heritage Centre/ICOMOS reactive monitoring mission to the property to discuss with national and local authorities the overall situation of the property with regard to the state of conservation of the site in its urban context and how current and proposed construction projects in its neighbourhood may affect the Outstanding Universal Value of the property, and how appropriate protection for its setting may be put in place for examination by the World Heritage Committee at its 36th session in 2012;
8. Requests furthermore the State Party to submit to the World Heritage Centre, by 1 February 2012, a report on the state of conservation of the property and on the steps taken to implement all the decisions of the Committee, for examination by the World Heritage Committee at its 36th session in 2012.
However the DCMS officials who attended Paris did not tell local planning authorities of UNESCO's concerns when they met at City Hall on 2 August 2011 and they only found out through planning objections.
UPDATE: 3 April 2012 On 1 March 2012 the matter eventually went back before Tower Hamlets Strategic Development Committee. Despite officers trying to tell members that the draft Supplementary Planning Guidance should be given little weight and generally seeking to distract attention away from design matters the councillors, by 4 votes to nil, refused the application. On 9th of March the Supplementary Planning Guidance was formally adopted by the Mayor of London, and on 13 March the planners finally capitulated and published the formal letter refusing the application. The formal reasons for refusal are:
1. The proposal, in terms of its height, scale, bulk, design and elevational treatment represents an inappropriate form of development and fails to preserve or enhance the character, appearance and setting of the Tower of London World Heritage Site, the Tower Conservation Area and surrounding conservation areas, adjacent listed buildings and the adjacent Scheduled Ancient Monument. As such, the proposal fails to accord with Planning Policy Statement 5 (2010), policies 7.6, 7.7, 7.8, 7.9 and 7.10 of the London Plan (2011), policies SP10 and SP12 of the Core Strategy Development Plan Document (2010), saved policy DEV1 of the Unitary Development Plan (1998), policies DEV2, CON1, CON2 and CFR18 of the Interim Planning Guidance (2007), which seek to protect the character, appearance and setting of heritage assets. The proposal also fails to accord with the aims and objectives of Tower of London World Heritage Site Management Plan (Historic Royal Palaces, 2007)
2. The proposal will have a detrimental impact upon protected views as detailed within the London Plan London Views Management Framework Revised Supplementary Planning Guidance (July 2010) and would fail to maintain local or long distance views in accordance policies 7.11 and 7.12 of the London Plan (2011) and policy SP10 of the Core Strategy Development Plan Document (2010) which seek to ensure large scale buildings are appropriately located and of a high deign standard, whilst also seeking to protect and enhance regional and locally important views
3. The proposal will provide inadequate arrangements for site servicing and coach drop off which will result in unacceptable vehicular and pedestrian conflict within the immediate locality to the detriment of highway safety, contrary to policy 6.7 of the London Plan (2011), policy SP09 of the Core Strategy Local Development Framework (2010), saved policies T16 and T19 of the Council’s Unitary Development Plan (1998) and policy DEV17 of the Council’s Interim Planning Guidance (October 2007)