Holocaust Memorial, Victoria Tower Gardens

We support having a UK Holocaust Memorial, however we believe that the proposals in this location would cause serious harm to the significance of the historic Victoria Tower Gardens, the listed Buxton Memorial, and the Westminster Abbey and Parliament Square Conservation Area.

The plans would have a significant impact on the heritage of this relatively small site. Introducing a series of large structures to the Grade II registered park would fundamentally change its character. The proposals would also have a detrimental impact on the significance of the Grade II* listed Buxton Memorial by encroaching on its setting and diminishing its prominence.

It’s very likely that Victoria Tower Gardens has important archaeological remains. We haven’t yet seen enough evidence of the impact these proposals would have on potential archaeology. We are also concerned about the impact on the mature trees that are fundamental to the park. We have advised Westminster City Council to seek further evaluation, amendments and safeguards from the applicant before determining the application.

We believe the proposals represent serious, but less than substantial, harm to the historic environment. However, less than substantial harm does not mean that the harm is acceptable if the public benefits are insufficient. Ultimately, it is for Westminster City Council to weigh the harm identified by us and other organisations, against the public benefits of the proposals as part of the decision making process.

1 March 2019

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