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When commenting on the Westminster planning site, comments do not have to be long, but we suggest that they touch on planning-related matters (ideas below), for example:

  • Loss of green public space and reduced accessibility
  • Trees likely to be damaged, or even killed
  • Blocking views of Parliament and this historic area
  • Effect on Buxton and other memorials
  • Changes to the playground
  • Safety & security
  • Traffic management & risk to cyclists
  • Air quality

Your objection can be as short as long as you wish, but it should be in your own words. You may wish to refer to comments already on the planning website for ideas. 

Loss of green public space and reduced accessibility
  • Parts of the surrounding residential neighbourhood are already on the register as an area suffering from a ‘public open space deficiency’
  • The creation of a large mound with fins, 9.4m high, splits the park into two very separate sections; the park will be transformed into an uncomfortable collision of a public place/ sombre mass tourist destination
  • Functionally, the park will now have to accommodate queues, sell tickets, manage security, make sure drop offs are done safely, sell refreshments to large numbers, receive deliveries, make sure central heating, air conditioning etc plant requirements are met etc , all of which will have a huge impact on its identity and charm.
  • The development will cause the loss of a significant amount of green space. It will change the park to a civic space.
  • The learning centre will dominate the park and change its atmosphere from informal and relaxed, to reflective and sombre.
  • The number of park users is forecast to be at least 3-4 times the present amount at average times and 5 or more times at peak times. This will contribute to footpath crowding, as it will no longer be possible to walk north / south across the lawn.
  • The slope that covers the learning centre is 10m high, or equivalent to a large three storey house. It will be dangerous in wet weather and inaccessible to elderly and disabled visitors
  • This proposal goes against many recent national and local planning policies which prohibit the loss of green space. This includes the National Planning Policy Framework, the London City Plan and the Westminster City Plan
  • Most of the current lawn between the Buxton Memorial and the playground will become an enclosed, hard-surfaced area, requiring ticketed access. 

Trees likely to be damaged, or even killed

  • A number of respected arboriculturists have expressed concern about the reliability of the tree risk assessment given in the application. They believe that the learning centre will certainly cause damage, if not death, to most of the 44 hundred year old plane trees near it.
  • We believe that there have not been sufficient investigations carried out 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. 
  • 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

Blocking views of Parliament and this historic area
  • Victoria Tower Gardens is a Grade II park falling partly within the UNESCO World Heritage Site
  • Although the competition brief asked for an underground learning centre, this proposal is the equivalent of three four-storey buildings above ground. 

Effect on Buxton and other memorials
  • 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. It also contains several highly Listed monuments and is in a Tier 1 Archaeological Priority Area.
  • The Buxton Memorial is possibly the only monument in the UK that commemorates the Abolition of Slavery. It might have been reasonable 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. 
  • Victoria Tower Gardens falls within the Westminster Council Monument Saturation Zone, recognising that this part of London is overprovided with civic memorials of all types.
  • The proposed development will overshadow and sideline the important Buxton Memorial which commemorates the abolition of slavery. Visitors will have to walk around the new development to reach the Buxton Memorial, and it will be invisible from many points within the park. 
  • The existing memorials are all perfectly scaled for the park, and celebrate positive events - the abolition of slavery, votes for women and freedom from oppression. 

Changes to the playground
  • The proposal claims to maintain the size of the current playground. This is not quite true, because a cafe with outdoor seating will now occupy part of the playground space. 
  • Large numbers of visitors to the learning centre will walk past or through the playground
  • The queue for the learning centre will be next to the playground and the café inside the playground. 
  • The sombre atmosphere of the ‘reflection courtyard’ may constrain childrens’ enjoyment of the playground. 
  • The shrubbery near the road will be removed, moving the playground closer to traffic fumes. 
  • 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 

Safety & security
  • The security measures for the memorial will be very intrusive for park users and are likely to get worse in future.
  • It is not clear how people will be prevented from jumping / falling off the top of the fins 
  • It is not clear how people will be prevented from throwing objects down into the courtyard

Traffic management & risk to cyclists
  • Traffic - the project will increase the amount of coach and tourist traffic in Abingdon Street very significantly.
  • Bicycle lane – coach parking for the development will obstruct the Abingdon Street bus and cycle lane for nearly 4 hours a day. Cyclists will have to pull out into a busy road, to circumvent the coaches.
  • It is not clear how traffic to the learning centre will affect, or be affected by, regular road and bridge closures in this area for sporting events and protests 

Air quality
  • Pollution - the increased traffic will add to the pollution especially in the children's playground as the coaches will drop off and pick up outside there
  • The development will lead to a drop in the Healthy Streets Audit result from 70 to 65, at a time when this rating should be going up, not down. 

​​How To Object

To object to this scheme, you will need to visit the Westminster Council planning site.

If you have never used this site before, and want to comment, you will need to register. This is a simple process. 
Comments don’t have to be long, but they should mention one or more planning-related issues, (ideas below).


Your comment will show up on the list of ‘Public Comments’, but will be anonymous. 


If you would like any help or more information please email us using the contact form