Natural England exposed as sham with sacrifice of Richmond Park for "15-minute City" in Kingston
Kingston Council is preparing a new Local Plan with consultation on the current draft open until 29 February 2023
The draft Local Plan is full of generalities and vague statements about the council's growth plans. However, the Local Plan is just preparing the ground for the creation of a so-called "15 minute City" in Kingston Town the details of which have already been agreed by Kingston's elected representatives and which will come forward after the Local Plan consultation has closed
The Kingston 15-minute city will result in the doubling of the area of Kingston Town Centre right up to Richmond Park, and will allow many buildings with heights up to 21 storeys or more across the whole area*
The "15-minute City" in Kingston will also include commercial, hotel, leisure and entertainment development, all sandwiched between The River Thames and Richmond Park and with no additional recreational green space
Richmond Park is full of fragile habitats and ecosystems
The Park is legally-protected for its ancient woodlands and trees because it is one of the last strongholds in England for the rare stag beetle, England's largest and most ferocious-looking - but harmless - beetle
You would think that Natural England would be up in arms
But the contrary is true
Natural England has told Kingston Council that they have "no comment" on the draft Local Plan
If Natural England has no comments on a Local Plan that will see a 15-minute City easy walking distance from Richmond Park, which contains habitats and species that should benefit from the highest level of protection from development, what exactly is Natural England's priority?
I have asked Natural England to explain their absence of comment on Kingston's draft Local Plan. You can read my letter to Natural England here
But things get even worse
By law, Kingston Council has to commission what is called a Habitats Regulations Assessment or HRA of the likely effect of its development plans on Richmond Park, given the stag beetle and the trees and woodland in Richmond Park enjoy legal protection under the Habitats Directive
However, the company that has conducted the HRA has said that the vast development that is planned in Kingston will cause no damage to or deterioration of the park's fragile habitats and ecosystems or threaten the long-term survival of the stag beetle in and around Richmond Park
The conclusion that vast development right up to the edge of Richmond Park will cause the Park no harm ignores more recent advice published by Natural England in 2016 and, more importantly, ignores the evidence in front of our own eyes of the harmful effect that increasing visitor numbers is having on Richmond Park
The company has also said that there is no
existing threat or pressure from pollution to the park and will not be any in the future.
But this conclusion is based on a complete absence of evidence as there have been no surveys conducted of current pollution levels in and near the park
A busy road runs through Richmond Park from Kingston to Richmond, alleviating pressure on the only other road that connects the two towns, and which winds round an extremely narrow corner in Petersham
The A308 also runs from the A3 to Kingston Town within metres of Richmond Park in places, and Park Road that runs close to and parallel with the western edge of the park is labelled as a "fast and busy" road in documents that form the evidence base for the Local Plan
If Kingston Council builds a "15-minute City" with a minimum of 10,000 new residential properties in the "new" Kingston Town and there is average occupancy in each property of 2.67 people, and each person visits Richmond Park only twice a week, this will increase the number of visitors to the park in one year by 2.8 million
The latest visitor survey conducted by The Friends of Richmond Park estimated in 2015 that there were 5.4 million visitors to the Park that year.
We all know this number has soared since that time
But even if visitor numbers have risen 50% in the last 7 years to 8 million visitors a year, the population increase being planned in the Kingston "15-minute City" will increase the numbers by a whopping 35%, and that's assuming people only visit the park at the weekend
And people are likely to visit Richmond Park more than twice a week given the government is encouraging people to be active and to have regular "access to nature" in the new 15-minute city model of living where everything is easily accessible on foot and by bike
And it is particularly true given the lack of any alternative green space in the north of the borough where much of the high-rise city is planned to be built
I have written again to Natural England asking them if they will challenge the basis of the conclusions of "no harm" to Richmond Park from Kingston's draft Local Plan and giving evidence of why they must do so
You can read my letter here
I have asked Natural England for their opinion on the basis upon which it has been decided that vast development in Kingston will not cause harm from recreational pressure, habitat fragmentation and pollution to Richmond Park and to say what they think the effects of building a "15-minute City" will be on Richmond Park's fragile habitats, ecosystems and the increasingly rare and threatened stag beetle
* Locations for very tall buildings are shaded very pale, making them very hard to see. You need to click on and off the relevant height square in the key on the right hand side of the interactive map and stare intently at the map to see them