City Plan 2040 had been waiting on a sharply defined choice over the future City Cluster skyline after an additional examination hearing put Historic England’s warning about the Tower of London directly against the City Corporation’s economic case for retaining its tall-building contours. The Minister lifted the direction on 23rd September 2026, as noted in the update below.
Historic England says there is a real risk that the Tower could be recommended for inscription on the List of World Heritage in Danger next year if effective corrective measures are not taken. The City counters that the alternative contours could affect a minimum of about 32,000 sq m of office floorspace and, in its upper viability scenario, up to 106,000 sq m, with modelling extending to 6,800 jobs and £1.2 billion of annual GVA.
Those upper figures are scenarios, not offices or jobs already lost. UNESCO has also not decided to place the Tower on the Danger List: its 2026 decision calls for closer monitoring and refers to possible inscription, while Historic England makes the stronger assessment about the risk of a recommendation next year.
The examination was reopened for one question
The City Plan 2040 Local Plan examination had been moving towards its final stages when Housing and Planning Minister Matthew Pennycook intervened.
His revised direction of 16th July 2026, made under section 20(6A) of the Planning and Compulsory Purchase Act 2004, prevents Inspectors J Bridgwater and A Phillips from issuing their examination report for the time being.
The reopened examination is deliberately narrow. The Inspectors were directed to compare the City Corporation’s City Cluster tall-building contours with Historic England’s alternative, assess the economic and heritage consequences of each, and decide which strikes the most appropriate balance between protecting the Tower of London’s World Heritage status and not unduly restricting economic growth.
The additional hearing took place on 2nd September 2026. A second session had been programmed for 3rd September, but the City’s examination page confirms that it was not required.
Historic England says the risk has moved up a level
Historic England’s case is not simply that more towers would appear in views from the Tower. It says the form, scale and location of development enabled at the eastern side of the City Cluster would cause further serious harm to the Tower’s Outstanding Universal Value as a World Heritage Site.
Its concern is about the Tower’s landmark siting, physical dominance and historic relationship with the Thames and the City, as well as the cumulative visual effect of increasingly tall development behind and around it.
Historic England says the City’s contours shift greater high-level bulk eastwards and create a harder edge closest to the Tower. In its view, that would further erode the sense of separation between the fortress and the modern commercial skyline.
What has changed since the earlier examination hearings is the international context. Historic England now describes the Tower as having entered a period of heightened risk following the World Heritage Committee’s 2026 decision.
What UNESCO actually decided
UNESCO World Heritage Committee Decision 48 COM 7B.49 expresses continuing concern about high-rise development and cumulative impacts in the wider setting of the Tower. It also calls for stronger protection of the property’s Outstanding Universal Value through planning and development-control systems.
The Committee requested a Reactive Monitoring mission before 1st February 2027. Among other things, that mission is to consider changes in the Tower’s setting and how effective the planning system is at preventing cumulative adverse impacts.
The UK is also asked to submit an updated state-of-conservation report by 1st February 2027. The Committee said the urgent conservation needs require broad mobilisation to preserve the Tower’s Outstanding Universal Value, including the possible inscription of the property on the List of World Heritage in Danger.
That is an important warning, but it is not a decision to put the Tower on the Danger List. Historic England goes further in its hearing statement, saying there is now a real risk of a recommendation for Danger List inscription next year if effective corrective measures are not taken.
A Danger List inscription is a formal World Heritage mechanism for properties facing serious threats and is intended to focus attention and corrective action. It is not the same thing as removing a site from the World Heritage List.
Historic England is not asking for a ban on the City Cluster
The alternative contours are more limited than the headline dispute might suggest. Historic England is not proposing to stop tall-building development across the City Cluster.
Its changes concentrate on the eastern edge closest to the Tower. The objective is to retain more clear sky around the fortress, reduce the visual dominance of future tall development and create a skyline profile that leans away more clearly from the World Heritage Site.
The official comparison images show a more graduated eastern edge rather than the harder step or “cliff-edge” profile criticised by Historic England. In practical terms, some of the highest potential upper floors on affected sites would disappear from the planning envelope.
Historic England accepts that this would reduce hypothetical additional office capacity by about 32,000 sq m net internal area. It puts that at roughly 2–3% of the City Plan’s need or potential supply.
Its evidence says the City’s overall potential office supply has been assessed at around 1.325 million to 1.474 million sq m. On that basis, Historic England says removing 32,000 sq m would still leave capacity above the City Plan requirement of 1.2 million sq m.
The City says the economic downside could be much bigger
The City Corporation says its own contours already strike the right balance and that Historic England has not demonstrated a material improvement to the Tower’s Outstanding Universal Value from its alternative profile.
It also stresses that the contour map is only a starting point. A site falling within a tall-building contour does not obtain planning permission as a result. Individual proposals still have to satisfy the City Plan’s heritage, design and other policies, together with the London Plan and other parts of the development plan.
The economic disagreement begins with the same 32,000 sq m figure. The City accepts that as a minimum amount of potential floorspace directly affected by Historic England’s contours, but argues that the real development consequence could be substantially larger.
If every affected scheme whose viability or deliverability was undermined by the reduced contours failed to come forward, the City models a theoretical maximum of about 106,000 sq m net internal area at risk.
It translates the range into a potential 2,100–6,800 jobs and about £366 million–£1.2 billion of GVA per year. For the City’s own Community Infrastructure Levy, it models more than £5.3 million at the 32,000 sq m end and around £17 million at the upper end. The equivalent Mayoral CIL figures are more than £9.6 million and about £31.6 million.
The City is explicit that the underlying capacities are theoretical rather than specific development proposals. The upper end is therefore a risk scenario, not a forecast that 106,000 sq m, 6,800 jobs or £1.2 billion of GVA will definitely be lost.
Why 32,000 sq m becomes 106,000 sq m
The difference between the two headline floorspace figures comes down to how each side treats development viability.
Historic England’s 32,000 sq m figure is essentially the office floorspace directly removed by lowering or reshaping the contour. The City argues that those lost floors are often the higher and more valuable parts of a tower.
On constrained City sites, where cores and unusual footprints already limit usable floorplates, removing that high-value floorspace could make an entire redevelopment scheme less viable or undeliverable. The City’s 106,000 sq m upper scenario therefore counts the full potential uplift on affected sites if those schemes were not to proceed.
That does not make one figure “right” and the other “wrong”. They answer different questions, and that is exactly the economic issue the Inspectors have been directed to weigh.
The Tower’s setting is more than whether it can be seen
This dispute is a useful illustration of what planners mean by the setting of a heritage asset.
The question is not simply whether a future tower blocks a direct view of the White Tower. The heritage case includes the fortress’s apparent dominance, its landmark siting, the amount of clear sky around it, its relationship with the Thames and the historic City, and the cumulative impression created by many tall buildings rather than one isolated scheme.
That is why the two contour maps can look relatively similar on paper while the parties disagree sharply about their heritage effect. A change at the eastern edge can alter the visual relationship with the Tower even if the Tower itself remains visible.
The current NPPF 2026 heritage framework still has to be applied alongside the statutory development plan and the international importance of the World Heritage Site.
Contours are not planning permissions — but they still matter
There is an important practical planning point here. Neither the City’s contours nor Historic England’s alternative would grant permission for a skyscraper.
A future tower would still require a full planning application and detailed assessment of heritage, design, views, townscape and other impacts. Where heritage significance may be affected, a proper Heritage Impact Assessment remains central to that exercise.
But the contours matter enormously because they shape the development envelope against which landowners, developers, officers and decision-makers plan. They influence the height and massing that the emerging plan treats as potentially acceptable before the detailed application-stage tests are applied.
This is therefore strategic planning at its most exposed: protection of a heritage asset of the highest international significance on one side, and the development capacity of one of Britain’s most productive commercial centres on the other.
What happens next?
As at 5th September 2026, the City of London examination document library does not show the Inspectors’ post-hearings letter following the 2nd September session. It also shows no further Main Modifications arising from the additional hearing.
That letter is the next formal step required by LD33. The Inspectors must set out their written findings to the City of London Corporation before the examination can move on.
Crucially, the Minister’s direction still prevents the Inspectors from issuing their examination report, and the directions remain in force until withdrawn by the Secretary of State. The City cannot simply move from the hearing straight to adoption.
The City Corporation’s planning guidance, updated in August, currently says adoption of City Plan 2040 is anticipated in late 2026. That remains an ambition rather than a guaranteed date while the ministerial hold and the remaining examination steps are unresolved.
Update, 24th September 2026: the Housing Minister has now lifted the intervention after accepting that the Inspectors’ further work, the City Plan’s heritage policies and site-specific Heritage Impact Assessments provide sufficient safeguards. See Government lifts City Plan intervention after Tower safeguards satisfy minister.
Primary sources
The City of London City Plan 2040 Examination in Public page confirms the 2nd September hearing and that the planned 3rd September session was not required.
The City’s examination document library contains LD33, the City Corporation, Historic England, Historic Royal Palaces, Tower Hamlets, SAVE and other hearing statements, together with the hearing timetable and earlier examination material.
UNESCO’s World Heritage Committee Decision 48 COM 7B.49 records the Committee’s 2026 conclusions on the Tower of London and the requested Reactive Monitoring mission.
Updated: 24th September 2026 | City Plan 2040
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