20 more reasons to say NO to HARM from Cambridge Road Estate redevelopment in Kingston

Policies and law exist to protect people and the natural and historic environment around us from harm

I submitted my initial response to the hundreds of documents supporting Countrywide Properties' and Kingston Council's (the "joint applicants") application to demolish just over 800 properties on the Cambridge Road Estate in Kingston and replace them with tower blocks containing around 2100 properties, most for private sale in July 2021

In that response, I listed 23 reasons why the demolition must not be allowed to go ahead

Since that time, the joint applicants have posted many more documents as part of the planning application, including one as recently as yesterday, 6 December 2021. The application is now made up of 524 documents. The council has not notify me, as one of the people who responded previously to the original consultation, of the addition of these documents to the application, so I imagine that many people will not be able to respond to this late material

I nevertheless recently responded to the new information that the joint applicants had submitted since July 2021

In my response, I identified a further 19 possible national, regional and local policy and legislative breaches in the planning application to demolish The Cambridge Road Estate and replace it with high-rise towers at three times density in an area with a lack of natural green space and which already suffers unacceptably high levels of pollution

Policies and legislation exist to protect communities and the environment across Kingston, London and England from harmful development and to ensure people's safety and well-being, especially in the context of increasingly closely-built high-rise dense development

Any possible breach is a serious matter and creates a significant risk of harm. Evidence is urgently needed to show how possible breaches are being adequately addressed so that current and future residents and the places in which we live will be protected from such harm

I have also identified a possible breach of the requirements of the Building Research Establishment Environmental Assessment Method (BREEAM) Sustainability Assessment Methodology that sets standards for the environmental performance of buildings through the design, specification, construction and operation phases

Below is a summary of the further reasons why I believe that the planning application to demolish and rebuild The Cambridge Road social housing Estate at three times its existing density must be refused. You can read the evidence supporting my beliefs here

Cambridge Road Estate Planning Application - Further Reasons for Refusal

A. Nineteen possible breaches of planning policies

i. London Plan Policies

1. SI 7 – Reducing Waste and the Circular Economy

2. SI 5 – Water Infrastructure

3. D2 – Infrastructure for Sustainable Densities - A 1 and 2 and D2, B

4. D9 - Tall Buildings

5. D12 – Fire Safety 6. D11 Safety, Security and Resilience to Emergency

7. T4 – Assessing and Mitigating Transport Impacts

8. G6 D - Impact on biodiversity

9. G7 C – Retention of trees and appropriate valuation system to be used to evaluate the value of trees to be removed

ii. National and local policy and legislation

10. The National Planning Policy Framework 2021 (The “NPPF”) Policy 43 which insists that “the right information is crucial to good decision making”

11. The Town and Country Planning (EIA) Regulations 2017 4 2 (b)

12. The Town and Country Planning (Environmental Impact Assessment) Regulations 2017 18 (3) (b) and 18 (3) (c)

13. The Town and Country Planning (Environmental Impact Assessment) Regulations 2017 18

14. The NPPF 180 (b) - development on land outside an SSSI that will have a significant adverse effect should not normally be permitted

15. The NPPF 180 - development that results in the loss or deterioration of irreplaceable habitats (such as ancient woodland and ancient or veteran trees) should be refused

16. The NPPF 182 - “the presumption in favour of sustainable development does not apply where a project is likely to have a significant effect on a habitats site (either alone or in combination with other projects) unless an appropriate assessment has concluded that it will not affect the integrity of the habitat site”

17. The NPPF Policy 199 - great weight should be given to the conservation of a heritage asset , irrespective of the amount of harm that a development may cause and that the more important the asset, the greater the weight should be.

18. The NPPF Policy 200 - “any” harm or loss to the significance of a designated heritage asset should require clear and convincing justification

19. Policy DM 6 of Kingston’s Core Strategy requires that developments “protect and promote” biodiversity

B. BREEAM requirements appear not to be met

i. BREEAM targeted rating of EXCELLENT

ii. Mandatory credits needed for Excellent scores

iii. Detailed breakdown of adjustments to scores for Transport & Land Use and Ecology

1. Transport

a. Very low PTAL rating of Cambridge Road Estate

b. No guarantee of improved public transport accessibility in future

c. Planned reduction of train services through Norbiton by South West Trains

2. Land Use and Ecology

a. Survey & Evaluation and Determining Ecological Outcomes

b. Managing Negative Impacts on Ecology

c. Change and Enhancement of Ecological Value

d. Long Term Ecology Management and Maintenance

C. APPENDICES

i. BREEAM Water Consumption standards

ii. Schedule Four of The Town and Country Planning (Environmental Impact Assessment) Regulations 2017

iii. Human Impact on Richmond Park SAC, protected under The Habitats Directive and a Grade I listed park

iv. Expert Opinion on Impact Pathways for the stag beetle and protected ancient woodlands

v. BREEAM assessment of evaluation of existing ecological value and conditions