Contribution
My Lords, I will speak to Amendments 25 and 40 in my name. Before I do so, I express support for Amendment 26, in the name of the right reverend Prelate the Bishop of Saint Albans, about the refreshment kiosk. I believe that it is neither appropriate nor fitting to have somebody selling burgers and chips and ice cream in a place that should be devoted to reflection and remembrance of the cruel murder of 6 million people and the lifelong impact on the lives of survivors and their families. I also support Amendment 43, in the name of the noble Baroness, Lady Finlay, on fire risk. That is on the basis of public safety, which underpins my amendments as well.
Among the dangers associated with the choice of siting an underground learning centre in Victoria Tower Gardens, the most serious is the flood risk. This is a critical issue, given that large numbers of visitors, including children and people with disabilities, are expected to visit. The site chosen for the learning centre is in flood zone 3a according to the Environment Agency, which means that it has a one in 100 or greater annual probability of river flooding if undefended. Normally, planning regulations would not allow a basement development in a zone 3a area. Atkins and Co carried out a flood zone 3 risk assessment for the original planning application. It is clear that the risks revealed by that report have not been correctly considered.
There are four kinds of flood risk, the most serious of which is the risk of inundation from the nearby tidal River Thames. This could happen either by overtopping of the embankment wall, if the water level is higher than the defences, or by breach flooding, in the case of a break in the wall. The latter would be catastrophic to life and property, as the proposed development is below ground level and the design of the proposed building has no above-ground refuge.
I turn first to the danger of overtopping. Because of the development’s proximity to the river, the Environment Agency requires that it must be a minimum of 16 metres from the flood defence wall—presumably to avoid the development undermining the wall’s foundation—and that the wall must be demonstrably high enough and in good condition for the lifetime of the development. A visual assessment at the time showed some defects that required maintenance, ongoing monitoring and inspection. However, the Environment Agency had no current plans for maintenance of the river wall at this location. I therefore ask: who is going to do it? We do not really know the effect on the wall of the construction work of this major underground development.
Because of climate change, and the fact that presumably the building is meant to last until at least until 2100, if not longer, the EA plans that the wall’s height will need to be raised by then to take account of the rise in sea level and consequent river level. By then, the EA expects the peak river level to rise by 950 millimetres above the current level. When this is reached, it will be more than 1 metre above the general level of Victoria Tower Gardens and the entrance to the proposed below-ground learning centre. However, there is a margin of error of only half a metre between the proposed increase in wall height and the expected river level, which is very little in a storm. The learning centre could have to be closed, not just on three days a year but on several days every month because of the risk of river water overtopping the wall.
Flooding has happened here before. The southern section of the site is partially within the area of the historic flooding information. However, data confidence is low because the records were hand-drawn and their extent is limited. It could be even more at risk than the records show.
Breach flooding is much riskier. Westminster City Council’s map shows what would happen if there was a breach in the embankment wall—perhaps in the case of terrorist action, contact by a vessel, a disastrous collapse of an adjacent building, or undermining of the foundations of the wall by unusual pressure from several storms one after the other, such as we have had this winter. What the map clearly shows is that the site is not only smack bang in the middle of the likely inundation area but right in the middle of the area that would be flooded within 30 minutes of the commencement of such an inundation.