January 2012
RBKC Supplementary Planning Document (SPD) for the Grounds of the
Natural History Museum
The Brompton Association, Earl’s Court Society, Knightsbridge Association
and the Onslow Neighbourhood Association have made a joint submission to
the Council about the SPD for the Natural History Museum (NHM). The
Brompton Association has asked TRA to support their position in a letter to
the Council.
The issue of how to use the NHM Grounds is complex and contentious. For
the best overview, please refer directly to the Council SPD and the full
comments by the aforementioned local groups.
The Council had been working on the SPD for well over a year. The purpose
of the SPD is to set out the Council’s view on balancing the use of the
Grounds in the context of the Museum’s demands and requirements.
There are many issues to be considered in formulating a framework for the
decision-making strategy. These include:
 recognising the strategic importance of both the Museum itself as a
heritage asset and of the South Kensington Museum Area in terms of
urban landscape and conservation
 the importance of the Grounds as a local green space in an area
deficient in local public open space
 addressing concerns about the scale, duration and nature of
“temporary” events, recognising explicitly the highly residential as well
as institutional nature of the surrounding area and the needs of
residents as well as those of the Museums and visitors
 the historical significance of the Grounds, their role in a Conservation
Area, and the setting of the listed buildings.
It is critical that the Council gets this right.
TRA will be taking a survey on this important issue shortly.
Cont/.
COMMENTS ON THE PROPOSED KEY DECISION VERSION OF THE
COUNCIL’S SUPPLEMENTARY PLANNING DOCUMENT FOR THE
GROUNDS OF THE NATURAL HISTORY MUSEUM
VIEWS OF THE BROMPTON ASSOCIATION. EARL’S COURT SOCIETY,
KENSINGTON SOCIETY, KNIGHTSBRIDGE ASSOCIATION AND
ONSLOW NEIGHBOURHOOD ASSOCIATION
The Associations are making a joint representation on the extensively revised
draft SPD following the recent meeting to discuss some of the issues.
Although in many respects this is a better document, there are still a number
of key outstanding issues - especially the ones that were raised by us at the
recent meeting which were not on the agenda proposed by the Council.
We have listed the key outstanding issues below and explained why we are
still seeking further changes. We also attach an annotated text containing
proposed amendments in “track changes”.
Proposed Changes: Key Points
We specifically propose:

recognising the strategic importance of both the Museum itself and of
the South Kensington Museums Area in terms of urban landscape and
conservation;

deleting all reference to Palaeontology Grounds and referring to that
space as the East Lawn, the name by which it has always been
known;

giving more emphasis to the importance of the Eastern Grounds and
particularly the East Lawn as a local green space in an area deficient
in local public open space;

recognising and addressing the concerns about the scale, duration
and nature of the “temporary” events which prompted the need for the
SPD;

deleting all proposals to use Museum Lane as a “catering facility”;

recognising that the Museums are surrounded by residential areas;

setting a limit to the duration of temporary events and the cumulative
total time that the East Lawn and East Grounds are used for such
events where its dual use as a local green space is precluded;

community involvement, accountability, monitoring and forward
planning – not relying on lots of individual applications and
enforcement.
Strategic importance of both the Museum itself and the South
Kensington Museums Area in terms of Urban Landscape and
Conservation
The Greater London Development Plan (1976) recognised the strategic
importance of the South Kensington Museums as an Area of Special
Character in conservation and urban landscape terms, which justified special
policies for the area. This was specifically recognised in UDP as an Area of
Metropolitan Importance and is reflected by Policy CD10, which protects
important views and vistas around the South Kensington Museums Area, and
Policy CD11, which sets out ways in which the precinct character of the
museums area may be preserved and enhanced.
More recently there has even been a suggestion that the South Kensington
Museums Area should become a World Heritage Site. All this suggests that its
strategic, national and even international significance in conservation terms
suggests that a passing reference to the Queen’s Gate Conservation Area in
para 2.9 is an inadequate assessment of its heritage value as an area. An
amendment is also proposed to para 4.3.
Proposal: We propose:

a rewrite of para 1.2 to recognise more fully the importance of the
Museum as a nationally-important heritage asset;

recognise the South Kensington Museums Area, of which the Natural
History Museum is the finest building, as an Area of Metropolitan
Importance (see GLDP and UDP) and its possible candidature for a
UNESCO World Heritage Site status; and

an expansion of para 1.9 to recognise better the competing demands;

a new paragraph after current para 1.5 to recognise that at the Londonwide level the South Kensington Museums are recognised for their
urban landscape and conservation value – a “super conservation area”
of much greater significance than the Queen’s Gate Conservation
Area.
Delete references to “Palaeontology Grounds” – revert to East Lawn
There is absolutely no provenance to the name “Palaeontology Grounds” –
the only reference is the draft SPD. This term appears to have been invented
to distinguish it from the East Grounds. It has always been known as the East
Lawn – certainly since before Hilary Temple was a small girl. Residents see
the change in name as an example of “Newspeak”, to deny the main
character of this area as a lawn. We regard this as a central issue in the
debate and strongly object to this backhanded way of clearing the decks for
proposals to pave over this area (see para 5.4 (3)(e)).
As we pointed out at the 29 November meeting, a word search of the NHM
website reveals no reference to this term, whilst the name that has always
been used is– the NHM contains hundreds of references to the “East Lawn”,
right up to the present in its press releases and signs for the Ice Rink. East
Lawn is the name that the Museum has always used and by which it is
popularly known.
Whilst this term may have been invented by the Planning Department to
distinguish this area from the East Grounds, it seem like elimination of this
name as a denial of the role of this area as a lawn and as a local green space.
We do not consider that our concerns on this issue have been considered
previously.
Proposal:
All references to “Palaeontology Grounds” are changed to “East
Lawn”.
Importance of the East Lawn as a publicly-accessible local greenspace:
The South Kensington Museums Area is in an area of public open space
deficiency, defined as “areas outside a 400m walk of publicly-accessible open
space” – outside an area served by a district, metropolitan or local park – see
Map on page 221 of the Core Strategy and Table 7.2 of the London Plan
(2011).
The UDP and Core Strategy define public open space not in terms of
ownership but on whether the general public have access to it - the other type
of open space - urban open space - includes private, communal and nonaccessible open space. Deficiency is measured in terms of the status of the
open space and the catchment it serves. The Museums Area is not within 5
minutes/400m of a Local Park.
We are concerned that the Council has put little weight on development plan
policies for protecting local open space and addressing local deficiencies, as
required by PPG17, the London Plan Policy 7.18 and Policy CR5 of the
Borough’s Core Strategy. We have been unable to assess the Council’s
needs assessment and its open space strategy which would inform the
decision on this particular local greenspace.
The London Plan’s Public Open Space Categorisation (London Plan 2011,
Table 7.2) would classify the East and West Grounds and the East Lawn as
“Small Open Spaces” – gardens, sitting out areas children’s play spaces or
other areas of a specialist nature, including nature conservation areas, as
they are under 2 hectares, providing accessible open space for a 5
minute/400m catchment.
The introduction of other open spaces in the general area is totally
inappropriate:
 Thurloe Square is outside the area, is not publicly accessible and does
not contribute to the setting of the Museum or, even, to the setting of
the South Kensington Museums; and

the triangular space to the east of the Ismaili Centre is extremely small,
open to the roads and a highly unattractive space for people to use.
Proposals:

para 1.1: where the key roles of the Grounds are mentioned, although
para 1.3 does recognise that they “offer an important green landscape
contribution in an otherwise built up environment”, it needs to recognise
its function as a local green space for the area;

all references to the East Lawn being “primarily for visitors” without
mentioning its use as an open space for residents and workers
undervalues its importance – and should be changed to reflect its
importance to both residents and workers (see also paras 1.9 and 3.3)

para 4.1: need to break out the role as a “breathing space” in an
otherwise intensively built-up area” as separate from its contribution to
a varied townscape;

para 4.16: Add “It is also highly valued as a publicly-accessible local
green space”;

para 4.17: This should be deleted the two spaces are not part of the
SPD nor do they provide any amenity to this site. The gardens on the
peninsula between Brompton Road and Cromwell Road are an
unusable, unused “amenity” because of its environment and Thurloe
Square is even further outside the area of this SPD. Their existence,
far from undermining the case for maintaining the East Lawn as a
publicly-accessible open space in an area of open space deficiency,
emphasises the deficiency.

para 4.22: this is the only reference which recognises the importance of
the Grounds not only for visitors, but also for residents and workers.
Museum Lane
We understand that Museum Lane is the northern boundary of the Natural
History Museum, which means that the grassed area on the north side of
Museum Lane is not actually part of the Grounds of the Natural History
Museum. See proposed changes to paras 1.3. Para 4.9 (5) recognises that
this area “is physically separate from other parts of the Grounds – in fact they
are not even part of the Grounds. Para 4.15 may need to be deleted. Its
omission from the Site of Nature Conservation Importance (para 4.18) may be
indicative of this.
With regard to para 5.7, we are very concerned that there has been no real
consultation on proposals to introduce outdoor catering in this area. Indeed,
there has been no opportunity to consider whether or not a location is suitable
for outdoor catering. There has been no consideration of the use of this area
against existing Council policies on outdoor catering/cafes/bars. This
statement is therefore improper and should be removed from this document
until such time as proper consultation and consideration has taken place.
Proposal:
This section needs to be reconsidered or deleted. It is only partly
within the Grounds. The lack of consultation on the proposals is
also a concern with residents who strongly object to the text
Recognising that the Museums are surrounded by residential areas
The concerns of residents, the Planning Applications Committee and the
Public Realm OSC were initially concerned about the impact of events on
residents’ amenity – noise, traffic and visual impact of the events, and then on
the scale, duration and cumulative effects which excluded residents from
using the local green space that the Grounds provide.
Proposal: It would be good to recognise this in para 1.1
Setting a limit to the duration and scale of temporary events and the
cumulative total time that the East Lawn and East Grounds are used for
such events where its dual use as a local green space is precluded
The original purpose of drawing up these guidelines was for the Council to
gain greater control over a succession of “temporary events” often involving
major structures. The original concern was the sudden escalation of the
number, scale and duration of events which meant that the East Lawn in
particular was out of bounds except to paying customers during the setup,
operation and breakdown of events and, especially in the case of the ice rink,
required a considerable recovery time and returfing before the green space
was sufficiently recovered to allow public access.
Both residents’ and the Planning Applications Committee were concerned that
guidelines be drawn up to address the issues of scale, duration and
cumulative effects of a succession of events in terms of the appearance and
public enjoyment of the Grounds, especially the East Lawn.
The Public Realm Overview and Scrutiny Committee commented on the draft
SPD asking for it to be more specific. In fact, although Guideline 2 covering
the East Lawn is more detailed, it totally fails to address any of the original
concerns about scale, duration and the cumulative impacts of a succession of
these events. The guidelines are only suitable for assessing individual events.
This is why we have proposed an annual meeting where the monitoring
results of the previous year and the proposed programme for the coming year
can be reviewed with all the key stakeholders. This need not be onerous as
most of the material should be available through the Museum’s own review
and planning processes.
Proposals:


There should be an introductory paragraph to Section 5 to explain what
the guidelines are trying to achieve.
Guideline 2 for the East Lawn needs to be expanded to deal with:
o the scale and duration of events;
o the types of events; and
o the cumulative effect of a “programme” of events – ie the total
“downtime” – setup, event, breakdown and recovery time - as a
result of the total programme over the year.
Community involvement, accountability, monitoring and forward
planning – not relying on lots of individual applications and
enforcement.
The Natural History Museum’s approach has been to seek consents for
individual events, often at short notice. The approach has often appeared to
“push the envelope”. Attempts at a more planned approach – a Grounds
Strategy – has not managed to engage residents at an early stage in the
process.
Proposals:
As part of a new approach we propose:

setting up a stakeholder group; and

holding an annual meeting to assess the events of the last year,
identify any problems and agree solutions, and to present the proposed
programme for the coming year;
Most of the material should be generated by the Museum’s normal planning
and review processes and should not involve much extra work. It would build
in accountability and help ensure that applications are dealt with more
smoothly, and that problems are avoided rather than have to rely on
enforcement.
Detailed Comments:
Para 4.11: Delete reference to the petrified tree. Does this really detract
from the setting? It may appear “miscellaneous”, but it has been there for a
very long time and was part of the division between the “extinct” and “live”
worlds that the Museum exhibited. Indeed one of Hilary Temple’s earliest
memories was of running up the East Lawn (sic) and discussing trees with her
mother. The petrified tree is a definite part of the NHM’s history and is