London's view guidance ties protected-view images to survey data

The picture

In March 2012, the Greater London Authority published the London View Management Framework Supplementary Planning Guidance, underpinning what the London Plan calls Policy HC4. The SPG defines the Accurate Visual Representation, or AVR, as 'a static or moving image that shows the location of a proposed development, the degree to which it will be visible, its detailed form and/or the materials to be used', combining an image of the proposal with a representation of the existing view. The London Plan 2021 carries this forward through Policy HC4, directing that a local view, once identified, be defined through mapping or 3D modelling.

What the documents show

The 2012 SPG ties every AVR to a defined Viewing Place, Viewing Locations and named Assessment Points, each with a stated field of interest, so an image responds to a mapped position rather than a chosen angle. The London Plan adds the statutory hook: development exceeding a Protected Vista's threshold height must be referred to the Mayor and consulted on with bodies such as Historic England, and the 2012 SPG's own guidance is what boroughs apply. Neither document states AVR is a tall-building-specific requirement in isolation; it is the evidence format for development affecting a Designated View, of which tall buildings are the most frequent trigger. The London Plan does not restate the AVR methodology, only the policy relying on it.

What it is allowed to decide

An AVR prepared to the 2012 SPG's Assessment Point methodology can plausibly support Class 4 Planning: it lets the Mayor, a borough or a statutory consultee test a claim about a surveyed viewpoint before granting consent. It holds Dimensional authority, since the Viewing Location and Assessment Point are fixed by the Management Plan rather than the applicant. Neither document assigns it Photometric authority: an AVR describes location, visibility, form and materials, not modelled sunlight or fixture data, and calling one lighting-accurate would go beyond what either source states.

The disclosure label

An AVR under the 2012 SPG would carry a label reading, in substance: this is an Accurate Visual Representation prepared to the GLA's View Management Framework; it can support Class 4 Planning decisions on a Designated View; it holds Dimensional authority through a fixed Viewing Location and Assessment Point; it does not hold Photometric authority, since light and atmosphere are not specified; dated 16 September 2026. The applicant's visualisation consultant, working to the planning authority's brief, would plausibly assert it, since the SPG places that burden on the proposal's proponent.

• Is the image tied to a Viewing Location and Assessment Point named in the Management Plan, or to a viewpoint the applicant selected?
• Does the development exceed a Protected Vista threshold, triggering referral to the Mayor and statutory consultees?
• Does the material describe location and form only, or also claim a lighting or material accuracy the framework does not require?

The framework's force comes from tying an image to a named, mapped position, not from any claim about how faithfully it renders light or material, a narrower promise than 'accurate visual representation' suggests on its own.