Lambeth officers' report wrote:6.4.4. The Conservation and Design Officer has raised concerns regarding raising the ground level of the gardens and building retaining walls. The Council's Landscape Architect has also raised concerns regarding the boundary treatment. Their comments are included below.
6.4.5. Policy 80 seeks the improvement of Jubilee Gardens with exemplary landscape design proposals, with visual and pedestrian links between Waterloo Station and the London Eye. The applicant argues that the proposed site forms only a part of the area (around 50%) to which Policy 80 applies and therefore cannot be expected to achieve all of the aspirations laid out in it.
6.4.6. The key concerns in relation to Policy 80 of the RDUDP are the relationship of the gardens with the surrounding townscape and
degree to which the gardens can accommodate people passing through. The design proposes to ‘welcome and engage' those who wish to visit the gardens and deter those who currently use it as a short cut. Therefore, the submitted design seeks to discourage pedestrian "commuters" and creates a strong physical separation between the gardens and the surrounding streets and public spaces.
It should however be noted that Policy 80 and its supporting text are not prescriptive. The scheme essentially creates a secluded and distinctive place (almost comparable to a walled garden) rather than one that opens up the routes and views from the hinterland to the river and so on. This cannot be said to be wrong, but it is important that this approach is clearly understood. It means that any criticism of the impact of the height of the boundary walls on the surrounding streetscape is at odds with the basic concept of the design.
6.4.7. It is considered the boundary treatment will create a very unsatisfactory relationship with the wider townscape, when it should be trying to integrate - physically and visually - the very different urban environments on each of the four sides of the park. Whilst the white cliff edge treatment could work along elevation C (London Eye), where there is space to visually absorb a hard barrier 2.7m in height. The boundary treatment is certainly less successful along elevation A (Hungerford Car Park), creating an uncomfortable walkway for commuters coming from Waterloo. The applicant argues that the proposed gardens have been designed to take into account the potential extension of the gardens across Hungerford Car Park in the future, and that the path to the north could be removed or incorporated in this eventuality. The elevation of the cliff along Belvedere Road is considered less forbidding but still creates a wall in places up to 3.0m in height, hard up against a pavement which is just a little wider - again, not comfortable. The Queens Walk elevation is more open, but still rises to heights of up to 3.1m.
6.4.8. In a number of places, especially the east-west route, adjoining the car park, and from Belvedere Road, the existing views will be lost due to the blank wall, over 2m high. It is recognised that the London Eye will still remain visible from many areas, given its significant height. However, views would be lost in some places, such as along Belvedere Road and to the north of the site. It is considered that it should be possible to see into, and across the gardens from all directions and that the boundary treatment and the extent to which the ground is to be raised
requires rethinking. The significant number of trees proposed would result in the loss of views across the park and could also have security implications.
6.4.9. The applicants contend that particular attention has been paid to views of the London Eye from within the gardens, and also that the proposal aims to hide the ‘less attractive' mechanism and boarding platform at the base of the London Eye. The applicant also contends that views and direct routes to the London Eye along the ‘Eye strip' to the south of the site will be maintained, however, it should be noted that this strip is already quite a crowded area.
6.4.10. In this context it might simply be noted that concerns have been raised that the pattern of paths may lead to the establishment of informal desire line paths, excessive wear in certain of the grassed areas, and that the design of the Gardens will have a significant impact on the character of the public realm outside the Gardens. The applicants argue that the scheme features top quality soil, and has appointed an agronomist to work on the proposal. Details of the soil have been submitted with the application.
6.4.11. Given the above, it is not considered that the proposal will enhance the South Bank Conservation Area, the setting of the River Thames and County Hall or the Waterloo area. It is considered that the proposal would unsatisfactorily relate to neighbouring thoroughfares and uses, and the context of the gardens in general. The raising of the walls would create some unappealing areas, particularly along Belvedere Road and the proposed walkway to the north of the site. Whilst the concept of the white cliffs boundary treatment is recognised, these would serve to close the gardens off from the area, to the detriment of the surrounding area and to local views and therefore fails to accord with the above policies.
Nevertheless, it is not considered that there are sufficient conservation or design grounds on which to refuse planning permission. Although there are a number of concerns outlined above, officers have taken an on Balance view of the proposal as a whole, which is outlined in the conclusion below.
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