My response to Kingston Council's draft Local Plan
Please feel free to use my response to inform your own reply. Deadline is today at midnight.
You can read my response to Kingston Council's draft Local Plan here
Great care must be taken not to over-develop Kingston in a way that is not sustainable, and against national planning policy and London Plan policy requirements.
The growth laid out for certain areas of Kingston in policy SD1 of the London Plan for “opportunity areas” - where the biggest growth is planned - is referred to as “some” development. The type of development being planned for the whole of Kingston is not “some development”. It is a great deal of development, indeed it is a great deal of over-development.
There is already a lack of infrastructure to support people living, visiting and working in Kingston and the projects in the draft Infrastructure Delivery Plan that is meant to support planned growth are largely unfunded with no indication of where funding will come from. The only transport investment the plan says we will see is to make existing train and bus services more "accessible and attractive".
The role that the fragile and rare habitats of Richmond Park SAC and Wimbledon Common SAC play in providing “access to nature” for the residents of Kingston and will play for 30,000 and more new residents coming to live in the Borough from development proposals coming forward through policies in this Plan is overlooked. And that is not to mention trees. If this plan goes through in its current form, the default will be to fell trees to facilitate development rather than protect them.
It is ironic that Zac Goldsmith, erstwhile MP for Richmond Park stated only in May 2022:
“And we will value ancient woodland and ancient and veteran trees, making sure they are recognised for their natural capital and cultural value, and making an increasing contribution to our health and wellbeing. In this way we can ensure we hand over these irreplaceable habitats in a better state for the next generation.”
Meanwhile, the plan’s policies allow housing proposals for the old, the vulnerable and the disabled to be approved near major highways away from public transport, community facilities and social infrastructure, and which are often in isolated locations. Development proposals with “poor doors” will be able to be approved and there will be no requirement for development proposals to be accessible to disabled people.
Meanwhile, the council intends to support the further development of Kingston University, Kingston College and Chessington World of Adventures, to facilitate build to rent on a large scale, and to allow the potentially unlimited conversion of family homes in established neighbourhoods in to “shared living” accommodation.
Proposed policies on Minimising Greenhouse Gases will make it unaffordable for people to build their own homes and for the small housebuilders to make development work financially. The policies will push development in to the hands of the major housebuilders who are able to recognise economies of scale but whose proposals are most likely to mark the end of our established neighbourhoods and communities with their dense, high-rise developments.
Lastly, the Plan contains a single diagram that mentions a “Zone of Influence” around Kingston Town. The “Zone of Influence” is not defined or explained. It appears that this may be a sneaky way of expanding the boundary of Kingston Town. If this happens, Kingston Town will - in one fell swoop - become an area more than double the size of Kingston Town as it exists today, and throughout which high rise mixed-use development will be facilitated by the policies of this plan all the way to Norbiton and right the way up to within a stone’s throw of Richmond Park.
The plan needs to be rewritten.
Kingston cannot sustain the scale and type of growth that this plan has in mind and sustainable growth policies and policies containing housing supply targets need to be rewritten with growth at a much lower level.