Link to Planning Application: https://tinyurl.com/SaveVTG
Link to our website: https://www.savevictoriatowergardens.co.uk
Link to our petition: https://tinyurl.com/SaveVTGpetition
The Planning Application for the Holocaust Memorial and Learning Centre in Victoria Tower Gardens was submitted to Westminster City Council before Xmas; it is now going through a lengthy process that will most likely conclude sometime in LATE SPRING with a Planning Committee hearing, during which a decision will be reached as to whether Planning Permission should be granted or refused.
During the intervening weeks the Case Officer for this scheme, with his team of in-house experts, will be looking very carefully at all 150 documents that have been submitted, assessing the scheme in relation to a whole host of planning policies, and consulting with a large number of Statutory Consultees (such as Historic England, Royal Parks, local amenity groups, Metropolitan Police, the GLA, Highways, Waterways etc) - and also with the general public.
Based on all these assessments and consultations, the Case Officer will then put together a very thorough report, which will form the backbone of his recommendation to the Planning Committee, either to CONSENT (possibly with amendments required), or to REFUSE the scheme as it stands. Very occasionally, if the pros and cons are finely balanced, the Case Officer might decide not to make a recommendation, leaving the final decision entirely to the Committee.
So this is where we all come in.
If we are going to be successful in influencing both Case Officer and the Committee, we need to submit the maximum number possible of OBJECTING “Comments”, clearly asking the officer to REFUSE Planning permission.
The Case Officer will take our objections into account– so if you do want to stop this totally inappropriate development in our park, please take the time to write in and object!!!
To do so, please click on this link https://tinyurl.com/SaveVTG , which will take you directly to the planning application page for this project (you can also go to: https://www.westminster.gov.uk/planning-applications-decisions-archived-records - our planning case reference is 19/00114/FULL). Click on “Comments” – then Click on “Login and make a comment”. Please note that once submitted, your comments will be posted on the WCC portal, but will remain anonymous - if you do not sign the body of the text.
The official deadline for submitting a Comment is 11 February 2019. While it is a good thing to write early, in reality the Council will look at all comments submitted virtually up to the day of the Planning Committee Hearing. So if you have missed the deadline, please write in anyway….
Here are a few tips on how to write in:
Please find below a list of the reasons why we believe it is important to object to this development in Victoria Tower Gardens. These are reasons that we consider to be bonafide planning considerations that the authorities will take into account, as they are in conflict with all sorts of Planning policies - whether stipulated by Westminster, by the London Plan, by the National Planning Policy Framework (NPPF) or other sorts of guidance.
Personal aesthetic preferences, personal inconvenience, or any sort of ‘sentimental‘ NIMBY-ish attachment for the park will not be considered, if not backed up by hard policy arguments, or professional criteria – so please do not indulge in writing about these!
The topics listed below are in a loose order of priority corresponding to importance. Please feel free to write about as many topics as you can – it only helps our case!
Most importantly, please use, as much as possible, YOUR OWN WORDS in making your objections, though you can of course use my text as a guideline.
REASONS TO OBJECT
VTG= Victoria Tower Gardens
HMLC= Holocaust Memorial and Learning Centre
UKHMF= UK Holocaust Memorial Foundation
1. According to every type of current Planning policy, from national to London-wide, to local, existing public open green spaces should not be built on, and their loss must be resisted, unless they are surplus or being replaced – two conditions that do not apply to VTG.
2. Indeed, Victoria Tower Gardens acts as one of the main public green open spaces for a very large surrounding residential area, mostly consisting of flats. The proposed development reduces considerably the useful open space that can be occupied by visitors wanting to spend leisure time in the park - and significantly alters the park’s existing configuration, in such a way as to impede its normal enjoyment.
3. With sections of the surrounding residential neighbourhood already on the register as an area suffering from a ‘public open space deficiency’, it is clear that building such a large facility in VTG will only make matters much worse.
4. It is intended that the recently refurbished playground will be demolished and moved further into the Southern corner, totally separating young children and their parents from the current lawn, much-used by all ages, and obliterating views of the Houses of Parliament.
5. Victoria Tower Gardens is a ‘Designated’ (i.e. protected) Historic Asset, a Listed Grade 2 Royal Park, is within a Conservation Area, is within the Setting of a World Heritage Site, and in immediate proximity of the River Thames. It also contains several highly Listed monuments and is in a Tier 1 Archaeological Priority Area. It is therefore a highly sensitive site from a planning perspective. The proposal is contrary to a large range of planning policies protecting the designated heritage assets from “harm”.
6. While Historic Building experts will need to present the myriad of existing heritage policies that are being ignored with this scheme, it is uncontroversial that the proposed building is totally incongruous in this setting, undermining the character of the existing surrounding architecture, and particularly that of the Houses of Parliament in the background. This insensitive design greatly harms the large number existing historic assets and should not be allowed.
7. The new proposal will alter forever the character of the park on many levels. Topographically, the creation of a large mound with fins, 9.4m high, splits the park into two very separate sections; architecturally, the jagged entrance, grassed mound and brutalist security Bunker are all very alien to the current serene beauty of the park; atmospherically, the park will be transformed into an uncomfortable collision of a public place/ sombre mass tourist destination with a relaxed, leisure oriented green space enjoyed by thousands of visitors; functionally, the park will now be tasked with accommodating queues, ticketing, security, drop offs, refreshments, deliveries, plant requirements etc , all of which will have a huge impact on its identity and charm.
8. Existing Planning Policy stipulates that new developments must be sympathetic to local character and history, including surrounding built environment and landscape. This development ignores such guidance.
9. The massing of this proposal will kill the wonderful views from Lambeth Bridge to the Houses of Parliament. It will also appear as a highly visible intrusion from the opposite Lambeth Embankment, and from the River. Most importantly, it will alter beyond all recognition the view from Smith Square tothe Buxton Memorial, which will now be seen in the background behind two narrow glass security balustrades, on the other side of the busy, enclosed sunken courtyard.
10. The Buxton Memorial is possibly the only monument in the UK that commemorates the Abolition of Slavery and the holocaust of tens of millions of slaves who endured atrocities for centuries. It might have been reasonable therefore to expect that following the recent Windrush scandal, great care and attention would be given to preserving and enhancing this significant, filigree and beautiful Grade 2 * monument. It is therefore unacceptable that the Buxton Memorial will be obscured and dwarfed by the design of the new HMLC, relegated to be enveloped by the security enclosure and obscured by the landscaping devised to shield the sloping access courtyard.
11. If this “small pocket of green space”, as Victoria Tower Gardens is described by Royal Parks itself, is to be the home of a number of memorials celebrating freedom, they must be of a compatible size, and they must each allow visitors equal access. This will not be the case, should the HMLC go ahead, as it will take over the identity of the whole park.
12. Victoria Tower Park sits within one of Westminster’s Monument Saturation Zones. It is indeed already the home to several memorials, and on the edge of one of the world’s most congested tourist destinations, the Westminster World Heritage site.
13. It is anticipated that the new HMLC in VTG will attract up to 1m visitors to the new facility, stretching beyond capacity every type of local infrastructure, and generating a large amount of additional pedestrian and vehicular congestion.
14. A new Memorial and Learning Centre in VTG, by their very nature, will sadly increase the risk of terrorist or other attacks in this area. Having already witnessed several recent violent events, Westminster is very focused on deploying extremely high security policing. This is reflected in the requirement for the ‘Entrance Bunker’, and for the high wall that surrounds the proposed sunken courtyard.
15. A future need to increase security measures to the remaining park would have very deleterious effect on the nature of this calm oasis. Indeed it is conceivable that another terrorist incident might result in the gates to the park being policed by armed guards, subverting forever the carefree spirit in which normal citizens visit urban recreational open areas. As mentioned above, we believe that the co-habitation of this memorial with a place of calm, normal enjoyment is an impossible one.
16. The HMLC should be built on a site where there is no programmatic conflict, such as College Green or the IWM site originally suggested.
17. On the topic of security, the insertion of the only refreshment facility for 1m annual visitors immediately adjacent to a playground area is misguided, and could prove to be very concerning for parents. Furthermore the playground should not be separated from the main lawn (where older children will play), and should not be immediately adjacent to the Entrance Bunker, where large queues of people might be forming and a lot of un-supervised activity will be taking place all day long.
18. One of Victoria Tower Gardens’ greatest asset is its double row of over 100-yr old plane trees. Having consulted widely with senior professional arboriculturalists, and with organisations and charities that fight for the preservation of parks, we now know that the proponents of this underground scheme have not carried out the investigations required to ascertain that the roots of these majestic trees will be sufficiently protected. To the contrary, we have been told that as the project stands, there is a strong likelihood that the trees will be severely damaged, and possibly killed off within the next ten years.
19. We must therefore ask WCC to insist that further excavations are required to establish the location of the deepest roots, and that all data relating to these issues should be made public. Damage to these wonderful trees would be a disaster for the park, an unforgivable tragedy for London, and contrary to several policies, including ones contained in Westminster’s Emerging Plan
20. The increase and management of pedestrian and vehicular traffic is another considerable concern in relation to the creation of a new, mass tourist destination. Given the current existing overload of local tourist activity, we are not convinced that the arrangements for drop-off and collection, taxis, coaches etc for the HMLC have been thought through in a comprehensive and realistic manner, to protect local residential amenity (also in relation to noise, air and light pollution), in accordance with Westminster’s own emerging Plan.
21. The architectural intent, concept and quality of this proposal also deserve careful scrutiny. Originally chosen from a shortlist as the winner of a prestigious international competition, we were told that this scheme was selected largely because of its chosen location within the park – tucked up in the narrow southern third of the site, leaving the majority of the green swathe untouched. This arrangement however was short-lived, as it was soon proven to be unfeasible due to the proximity of the foundations to the trees. This resulted in a major shift North, with a significant reduction in floorspace imposed by the tree roots. The other major change to the scheme was the introduction of the security Bunker, and the unfortunate enclosure of the sunken courtyard, separating the visitors to the HMLC from the rest of the park.
22. The scheme has been lambasted by many different architectural critics, and high- profile members of the Jewish community, for its inability to connect in any obvious aesthetic or architectural way to the real essence of the message that the Memorial would wish to convey. It remains a bombastic, bling, generic monument to the architect and its clients, rather than the moving, genuine place of remembrance that was always intended.
23. Ever since the beginning of the Save Victoria Tower Gardens Campaign we have been highlighting the fact that this ‘green pocket’ is too small for such an ambitious project; the realities of the site have forcibly reduced the building to a facility that in many ways will be insufficiently generous from the start, not meeting the original brief contained in the 2015 document A Promise to Remember. A far better solution would have been to join forces with the IWM, a world-class institution less than a mile away, and the official UK custodian of all the Holocaust artefacts, with huge experience in outreach activities.
24. While there are many more issues that could still be raised – particularly in relation to heritage matters, we are expecting that experts hopefully will be investigating them in depth and submitting their reports to the Case officer. One major issue however remains to be exposed. This relates to the process of this project from its inception until now. As objectors, we fully expected that we would be afforded many opportunities to express our views, that we would be privy to essential information (such as that concerning the Tree Protection zones) that could shape our arguments.
25. Most importantly, we expected to be told about how VTG was chosen as a site for the HMLC, what criteria made this site better than others given all its limitations, and how other sites were vetted to ensure that the most appropriate one was selected. Given the strength of our opposition, in line with current planning policy, we would have expected a number of alternative sites to be offered, rather than a blank refusal to even consider our arguments. We remain totally in the dark regarding these issues, as we do regarding the business case for this project. This has not been a transparent and open process; it can be seen as a real missed opportunity, and a very unpropitious beginning for a project that deserved so much more.
Many thanks for writing in your Comments.
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