Author: Cyril Richert
Following our comments on Wandsworth Council’s consultation on local”protected” views we have received a response from the officer in charge of the policy document. The draft revised Local Views Supplementary Planning Document (SPD) aims at defining the different types of view that have some local significance and deserve protection within the borough.
In answering our different comments, the officer made the following response highlighted in green. We have added our own comment in red in this article.
You refer to a meeting of the Planning Forum in April 2013 where it was reported that there would be a shorter list of views. The reference to 7 is a drafting error and should be 6. I fully recognise that the change is substantial from the previous draft. This is a result of comments from the GLA, which suggested a more focussed document. In the introduction we state that there are many important views within conservation areas that were identified previously and these will now be set out within the Borough’s Conservation Area Appraisals and Management Strategies.
Although we dispute the necessity of such work with only 6 views, more than half of them subject to changes due to already granted outline planning schemes or schemes under discussion, we also think necessary to see the documentation sent by the GLA which has caused the planners to virtually eliminate all the local views.
I understand your concern that the content of views 3-6 will change as a result of development in Nine Elms. We recognise this in the document but feel it is even more important that these views are there in the SPD to ensure that developers take full cognisance of them if they propose any tall buildings, which impact on Battersea Power Station.
Saying that it ensures that “developers take full cognisance of them if they propose any tall buildings” may imply that they do not pay such attention to the Borough’s Conservation Area Appraisals and Management Strategies, and therefore contradict/undermind the consideration given to the other “important views” as stated in the previous paragraph.
In paragraph 28, we were concern that the draft document said “Where development is proposed in the silhouette of a heritage asset this may cause undue harm“, and not “will”. The officer’s response is:
I note you would prefer to substitute the word ‘will’ for ‘may’ in the context of the impact of a proposal in the silhouette of a heritage asset. We feel that the use of ‘may’ is more appropriate because the visual impact of any particular proposal will depend on the nature of any development. Some proposed developments in the silhouette may not be visible so this allows a judgement to be made in each case.
However saying that it is justified because “some proposed developments in the silhouette may not be visible” is in contradiction with the paragraph saying that it concerns “where development is proposed in the silhouette of a heritage asset“. It seems bizarre to apply a guideline to a building that has no impact as not visible…
Photography and wide angle lens
In paragraph 2.49 of the adopted DMPD reference is made to the fact that wide angle lenses can distort perspective. This is true hence the need for the cautious approach set out in Appendix 1, which is extracted from the Mayor’s guidance on Strategic Views set out in the London View Management Framework (LVMF).
The LVMF states that ‘where a proposal needs to be shown in a broad context choices must be made between using wide angle photography, which may give rise to less natural perspective at the edges of the images or by combining additional images taken from the same position. Where this latter technique has been used AVRs should include additional annotation to indicate how images have been combined’.
The whole purpose of AVRs is to show a proposed development as accurately as possible.
We have already shown that the way the DMPD was worded, using the word “can”, is too vague (as we demonstrated that in all cases it will distort, but for representation of plane surfaces). That was also admitted by a planning officer who considered the policy a bit clumsy.
Therefore, instead of making sure that developers will provide images as the naked eye will see, it will continue to allow AVR using wide angle lenses, not specifically described as such (also LVMF says so already Wandsworth Council has never enforced it), to illustrate proposals.
It is a misunderstanding of AVR to write that their purpose is to show a development as accurately as possible. As explained by experts (Miller Hare) in their methodology, the goal is to provide additional information such as context, number of buildings, etc.
The Local Views SPD will be reported back to the Council early next year along with the results of the public consultation.