He claims the building would be a “softer target” as the park is open to the public and because the park is a small open space near a road.
These factors would allow the building to be susceptible to an attack from a vehicle, a suicide bomber or a “close quarters attack”, Mr Tudway writes.
The report says that the “security implications of this proposal would permanently and completely change the use of this public space”.
“Anyone entering [Victoria Tower Gardens] will need to be screened even if the site […] is target hardened significantly,” Mr Tudway says.
“Given the lack of footpath space, multiplied by the significant increase in anticipated footfall, this proposal creates a ‘perfect storm’ of vulnerabilities.
“The Government assertion that the proposal would not substantially disrupt normal users of the park is untenable.
The memorial is expected to attract up to 10,000 visitors a day and would be opposite the BBC, ITV and Sky News TV studios at 4 Millbank, giving the media what the report calls “a front row seat” to any attack.
Building the memorial centre in Victoria Tower Gardens would, the report argues, be “a gift” to extremists.
Last month Lord Carlile said the memorial centre would be a “sitting target for terrorists”.
The proposal to build the memorial has enjoyed widespread political support but faced opposition from heritage and conservation groups because of its potential impact on the space.
Writing in the JC, Chief Rabbi Ephraim Mirvis defended the plans, calling a memorial "a great blessing, but will also be a crucial expression of what it is to be British in these troubled times. It is nothing less than a sacred mission".
Jewish peer Baroness Deech has voiced concerns about the memorial, telling the House of Lords: “The principle threat comes from jihadi-inspired terrorists, as evidenced by the atrocities that have occurred in Europe targeted against Jews and Jewish associated buildings recently.”
Speaking to the JC, Baroness Deech previously said that “Holocaust memorials, very sadly, do not appear to do anything to hold back the spread of antisemitism.
“If it’s turned down, put it somewhere else. No one is saying there shouldn’t be one.”
The Communities Department, which is overseeing the project, said in a statement: "We are fully aware of the security implications associated and are in regular contact with Parliamentary Security, the Government Security Services, and the Metropolitan Police Service.
"We have been advised on physical and operational security measures to mitigate risks, and we are confident that the proposed site will be secure.
"The Holocaust Memorial will stand as a reminder to all in Parliament, and the whole nation, of our responsibility to remain vigilant against intolerance and bigotry.”
