New local Plan – our response
The new Local Plan, when adopted, will replace the current Local Plan (called the Core Strategy, 2012). The plan will include policies which will be used to decide whether to approve or refuse planning applications in the borough. Below is our response:
This feedback is submitted by Riverside Residents Association (RRA) following member discussions in response to the above mentioned Further Engagement document published in July 2021.
The RRA represents residents in the area bounded by: South and East Lane to the north, Portsmouth Road to the west, Milner Road/County Hall to the East, Woodbines Avenue to the south and east, including The Bittoms, Oaklea Passage, and Avante. The RRA is a community group that looks to protect and enhance our locality and the Borough for the benefit of all residents, present and future.
This is the Association’s response to the issues raised in the Council’s Engagement document. It does not strictly follow the format of the Council’s questions, but identifies the issues that we as Borough residents consider need to be addressed by the Local Plan.
The big picture
The big picture and over-riding issue for the Borough is how to meet the housing target set by the London Plan; 964/pa is much higher than previous targets set by the Mayor of London. We are concerned that the London Plan target for Kingston is reliant on the delivery of Crossrail 2, which it is true would make areas of the Borough much more accessible, and would represents a real step change in public transport provision. We know that the housing numbers and Crossrail 2 are inextricably linked because the Council said so in its responses to Matters raised by the Inspectors examining the London Plan in 2019/20. Indeed, in those responses the Council went as far as to say:
It is also considered that delivery of the required number of homes within theborough’s Opportunity Area (OA) is predicated on a positive commitment to Crossrail 2, with funding and clear timescales. Without this investment, the level of housing set out in the new London Plan is not deliverable.
Given the above we are greatly concerned that if the Council attempts to meet the housing target through for example providing an additional 6,000 dwellings in Kingston Town Centre (as is the intention) then the existing infrastructure – especially roads and rail – would not be able to cope. The pre-Covid trains were already overcrowded, and the road network very congested; it would be existing and future residents’ quality of life that would suffer. This is not acceptable, and not what the Mayor of London refers to as good growth.
We know that this is the case because the Council’s 2019/20 London Examination Plan submissions go on to say:
Existing transport studies (e.g. Kingston Transport Forecasting Report 2018) that show the transport network suffers some significant stresses over the next 20 years under current London Plan growth (i.e. without OA growth) with increases in traffic (both local and strategic) leading to increasing delays during peak periods at pinch points, in particular in the main town centres and along key routes such as the A3 and A240, while the South West Mainline starts to suffer severe crowding in peak periods on services to London. The transport network effectively reaches its capacity under current London Plan growth, with significant interventions required to accommodate any additional new development and resulting trips.
We call upon TfL to enter into the next phase of Crossrail 2 consultation and determine the project’s funding streams at the earliest opportunity, as additional capacity and frequency are urgently needed on these rail lines to support delivery in line with Kingston’s OA.
With Crossrail 2 now ‘mothballed’, the Council and Mayor of London have some serious thinking to do. It is clear from the Council’s representations that without Crossrail 2 growth in any of the Opportunity Areas at the scale needed to reach the London Plan target will have a major negative impact on residents’ quality of life. It is clear this is the case not only in Kingston Town, but also in the district centres that are also identified for substantial growth (Tolworth etc). None of these centres / Opportunity Areas are now going to benefit from Crossrail 2 for most, if not all of this Plan period.
The extent of the Council’s concerns with the housing target set for Kingston by the Mayor of London is clear from RBK’s Examination Matters response (Dec 2018):
RBK strongly urges the Mayor to amend the London Plan to halve the housing target and make it contingent on the commitment to delivery of Crossrail 2, on the basis that without this infrastructure, the borough cannot accommodate that level of housing.
The position could not be clearer. The Council held that the housing target was double what it should be, AND could only be delivered sustainably with the step change in transport provision that would be delivered by Crossrail 2. The position is now materially very different – Crossrail 2 mothballed MUST mean downward revision of the housing numbers if we are to avoid unacceptable negative impact on quality of life for all of us.
A very important point in respect of what must now be acknowledged to be undeliverable housing numbers is that the numbers were based on site capacities that were untested, and appear likely to have be an exaggeration of what could be sustainably delivered. The Council’s response to the London Plan Inspector’s Matters explains the position in respect of the potential capacity in Kingston Town Centre:
Ultimately it is noted that whilst desktop studies have identified the potential for significant capacity [6,000 homes in Kingston Town Centre], this will be tempered by the need to conserve and enhance the town centre’s listed buildings and the Conservation Area, and their settings. Whilst it is recognised that the presence of heritage assets does not preclude large-scale development and that the application of effective design principles will play a significant role in supporting such levels of growth, this will nonetheless impact on development capacity at a detailed level.
Thus, the London Plan housing target is predicated on a desktop study that did not consider or safeguard our heritage, or indeed did not consider other aspects that would constrain site capacity. This is quite frankly an intolerable position, and the new Local Plan must ensure site capacity is robustly assessed and realistic.
This Association supports optimising the reuse of our brownfield land resources in the town centres and elsewhere. In accordance with the Mayor of London’s good growth approach optimising means balancing development needs against other factors to ensure for example that we do not irrevocably harm the fantastic heritage assets that we have in Kingston Town. The London Plan makes it clear that the Mayor has, and the boroughs should move away an approach based on maximising housing development at all costs. We support this approach, and have been very disappointed and concerned that recent decisions made by the Council have got this balance very badly wrong and placed far too much weight behind housing and/or economic growth at the expense of our heritage. The Eden Campus decision illustrated this unbalanced approach by failing to apply London Plan policy that required the applicant to explore alternative less harmful schemes, alternatives that should have included using existing and available off-site car parking rather than knocking down and rebuilding on-site car parking provision that contributes to the height and bulk of a scheme that will ‘loom’ over the Market Place. It is decisions like this that frustrate residents; we could and should have had the Unilever jobs AND protected our heritage assets.
Our final point on the housing target is that we think the Council should investigate the potential of Green Belt and Metropolitan Open Land to accommodate some of the growth. This would of course be subject to consideration of the quality of the Green Belt / MOL, and the infrastructure constraints that no doubt exist. However, given the scale of the housing challenge all potential sources of capacity need to be considered and assessed.
Conclusions on the big picture
Given the strength of the Council’s concerns about the housing target as expressed in the Examination Matter representations, and the fact that the means of triggering delivery has been mothballed, it is perplexing why the Council’s current Engagement document now seeks to meet the Mayor’s target principally through intensification in the Opportunity Areas and what it calls “incremental development in suburban areas”, in full knowledge that this will harm our quality of life. The Council needs to demonstrate to the Mayor and the future Local Plan Inspector that the housing targets are unrealistic and cannot now be met without causing irrevocable and unacceptable damage to our quality of life. An important aspect that we expand upon later, is that the Council would be forced to accept all and any housing schemes in the town centres, schemes that may be on sites better suited to meet the need for town centre uses such as commerce, education, public services, community, cultural and leisure uses. The Local Plan needs to find space for these uses, and must avoid these uses being ‘squeezed out’ by residential, with consequential loss of potential for economic growth. Sites need to be allocated and safeguarded for important town centre activities.
We would support a review of Green Belt and Metropolitan Open Land to assess the potential of these areas to deliver growth, albeit that would be likely to be conditional on the provision of substantial infrastructure requirements in the same way that development in the Opportunity Areas can only be optimised through delivery of Crossrail 2. We will support identification of a housing target and sites with capacity to meet that target, where the Council has rigorously assessed optimum capacity, capacity that gets the balance right and will not generate unacceptable harm to heritage assets. We, like the Mayor of London want to see ‘good growth’, not development at any cost. We want development that brings jobs and homes AND enhances our locality.
We support the Mayor of London’s concept of ‘good growth’, which is “about working to re-balance development in London towards more genuinely affordable homes for working Londoners to buy and rent. And it’s about delivering a more socially integrated and sustainable city, where people have more of a say, and growth brings the best out of existing places while providing new opportunities to communities…….Good Growth is also not about supporting growth at any cost, which for too long has been the priority, leaving many Londoners feeling excluded and contributing to a lack of community cohesion and social integration”. London Plan Foreword page 12
With the Council’s expressed concerns about the London Plan housing targets, we urge the Council to set out the case to demonstrate why attempting to deliver on those housing targets in the Opportunity Areas and through intensification in the suburban areas without the step change in public transport provision that Crossrail 2 would lead to higher levels of congestion and pollution and a reduction in quality of life – a long way from good growth and the sustainable city sought by the Mayor.
We want a sustainable city and development to be balanced. In our town centres we want to see (re)development opportunities optimise site capacity by having due regard to, and respect for our heritage assets, and also delivering the full range of facilities, services, infrastructure and jobs, not just housing. When it comes to housing we want homes that meet the local identified need not just housing that provides the developer with the greatest profit margin. We want our affordable housing target to match the Mayor’s with review mechanisms to ensure where schemes are delayed or phased the Borough does not lose out. This is what good growth means to us.
We do not want Kingston to become a dormitory, where the focus is solely on providing homes in the Borough to support jobs in the CAZ. As the Council pointed out in its 2018 submissions to the London Plan Examination, our transport infrastructure is already overcrowded, and needs substantial improvement to accommodate any growth at all.
Neither do we want growth at any cost, where the balance between growth and other issues is not right, such as the impact on the environment – historic and natural. As we refer to earlier, recent Council decisions have got the weighing up very wrong.
Our town centres are a huge asset providing such a wide range of activity, and in particular jobs and leisure pursuits. Land and sites to accommodate the raft of town centre uses are at a premium. Many town centre uses such as offices, community facilities and services and educational institutions are major trip generators, and need to be located in centres. There is little flexibility over where they are best accommodated. Such uses are critical to the functioning and success of towns, and it is vital to plan for these uses, and to allocate land for them. In considering land and premises in town centres we want the Local Plan to fully consider and optimise all opportunities for leisure/cultural, community services and facilities, educational and commercial uses.
Updated site assessments
Our comments relate to County Hall, Penrhyn Road, a site that was promoted in the 2019 Early Engagement for civic and educational uses.
This building/site is located in Kingston’s civic and educational quarter, and is currently allocated in the adopted Plan for civic and educational uses. Its proximity to Kingston University’s Penrhyn Road campus and Kingston College’s main College roundabout site means it is uniquely located and suited to accommodate the future needs, be that expansion or consolidation, of either (or both) of these two key institutions in Kingston Town. The College and University are two of the biggest employers in the Borough, and their graduates have an excellent track record of moving on to set up entrepreneurial businesses. Thus, to support current and potential future employment opportunities there is an imperative to allocate and if necessary safeguard the County Hall site to support the growth of either institution.
The County Hall building has recently been upgraded to Grade 2* status, and it is relevant to note that a function of listed buildings is to provide some public benefit, and not just private benefit. National Guidance on the Historic Environment states “Where a heritage asset is capable of having a use, then securing its optimum viable use should be taken into account in assessing the public benefits of a proposed development”. Guidance on the Historic Environment 18a-016-20190723
We see the potential for the repurposing of County Hall to accommodate a wide range of public benefits, town centre uses – community services and facilities, cultural and art space, education and others, optimising the building’s usage, retaining public access. What that mix entails is to be determined, but there is precedent elsewhere for workable schemes as we refer to below. The building has real character and is ideally located not just for civic and educational uses, but these are the most obvious uses and we know there is interest from Kingston University. The Council intend to vacate the Guildhall complex, and there will be a need for some Council services (most obviously the registry and the Local History centre, but others too) to remain centrally located. Where better, and more appropriate for the Council to have a public counter than County Hall, a building built for this purpose. We residents know GP services and dentists are under pressure locally, and there could be scope to accommodate these and other community uses and services under one roof to service the needs of a much larger town centre population.
There is also a prime opportunity to use the site for education of all ages with new schools which will surely be required in safe walking/ cycling distance where the 6,000 proposed new homes to come forward. More reason to retain this quarter of Kingston Town for civic and educational uses.
Kingston University has a strong entrepreneurial tradition with business start-ups particularly strong in the arts, design and other creative activities, but the Borough lacks space for emerging and budding businesses, and has not been able to accommodate these entrepreneurs, and businesses reluctantly start-up elsewhere. Kingston needs space for fledgling businesses to start-up, to grow-on and to flourish. We know there is interest from the County Hall development team and the University to explore the prospect of utilising space in County Hall for start-up / incubator / grow-on workspace that could come forward as a creative industries hub in County Hall – a prominent prestigious building located next to the main University site; this is a really exciting prospect.
Furthermore, we think, and perhaps the Council’s (unpublished) Employment Land Review will confirm this, that there is a need for more managed workspace to meet demand in the general commercial market to accommodate a workforce that is increasingly entrepreneurial and focused on micro and small businesses. The building is attractive, characterful and has a presence, it was RRA response last used for civic back-office functions, it is very well located in terms of public transport access (served by both Kingston and Surbiton rail stations / bus routes), and adjacent to Kingston University with all the research and resources contained therein. In this regard we note that the developer/owners of the listed former Bromley Town Hall [click the link] has recently received planning permission to repurpose that building for workspace to meet the business needs and help drive the economy in that Metropolitan town centre. We are excited about the potential to do something similar here with County Hall. This really is an opportunity for the Council to shape an exciting positive economy driven future.
We are aware that Kingston University are interested in occupying County Hall, albeit given we remain in a pandemic it is unrealistic at this point to expect the University to be clear and categorical on what their requirement might be. Clearly though there are potentially huge educational and economic driven possibilities stemming from County Hall, and its future reuse is a matter that must be considered thoroughly. Residents do not wish to see opportunities to consolidate our well respected University and to shape a positive economic future passed up. Indeed, this is why the Local Plan has a 20-year horizon, we are not planning for the short term.
We also note that the southern part of the County Hall site (the Surrey Club building and the tennis courts) is subject to a restrictive covenant that states:
“ And also that the County Council their successors and assigns will not use orsuffer the said piece of land hereby conveyed or any buildings or erections which may be built or erected thereon to be used for any offensive noisy or dangerous trade business pursuit or occupation or for any purpose which shall or may be or grow to be in any way a nuisance damage grievance or annoyance to the said Charles Jemmett his heirs or assigns or his tenants or for any purpose which may tend to depreciate or lessen the value of the estate of the said Charles Jemmett or any part thereof for residential purposes”…
A number of RRA members are successors in title from C Jemmett, and are firmly of the view that building on the tennis courts and/or enlargement on the existing Surrey Club building site would be certain to engage this covenant. We have advised the new owners of County Hall that this is the case, and we would robustly defend our interests should they propose building on the tennis courts or intensifying development on the Surrey Club site.In summary, County Hall could have a very exciting future if repurposed to accommodate a wide range of uses, and become an important asset to the town, the Borough and its residents. Offering educational opportunities, a range of civic and Council services, a creative hub for entrepreneurial innovation and business development as well as general employment opportunities for Borough residents. All in a centrally located building with character and prominence, that given its Grade 2* listing status should be required to provide public and community benefits. The opportunity to be visionary must be taken, to do something really exciting and positive with this building for educational and economic growth, for the town and the Borough community. The community, Council and building owner must not take the all too easy route of falling back on the housing numbers here, let’s plan positively, be bold and visionary and deliver good growth.
Design heritage and culture
The Engagement document states: The historic environment is an important part of the borough bringing multiple benefits to growth through economy, culture and quality of life
We agree with this and a further reference to the London Plan expecting Boroughs to conserve and enhance their local heritage to contribute to the asset’s significance and sense of place.
The Borough’s heritage policies have been strongly supportive of conserving and enhancing heritage assets in the past, but what we have found recently is that when the Council have come to determine planning applications, heritage protection has carried relatively little weight (insufficient weight) when the Development Plan policies are considered as a whole. Time and again heritage policies are set aside in favour of supporting growth. In this regard we note the London Plan’s ‘good growth’ intent, not (being) about supporting growth at any cost. For us good growth means respecting and celebrating our heritage assets not devaluing them. The Local Plan’s heritage policies (and indeed the design and cultural policies) need to be afforded appropriate weight so that the Borough, in line with the London Plan’s intent can move away from the “development at any cost” approach that is detrimental to our heritage and to residents’ quality of life.
We want strong policy support to protect and enhance our heritage assets. Kingston Town’s heritage assets are a major reason why people chose to visit, start businesses and live their lives in this Town. Devalue these assets and you devalue our quality of life, and lessen Kingston’s unique selling point and attraction. The Council needs to get the policy weighting balance right, and this clearly means affording the heritage policies more weight.
The Engagement document (pg30) states: Responses to the earlier engagement suggested the new Local Plan should seek to make town centres more appealing, providing unique attractions, preserving history and providing spaces for art and entertainment.
We agree with this, and would wish the Council to ensure that our town centres continue to provide a wide range of attractions – cultural and social as well as leisure, retailing and commerce. What we do not want is for residential to ‘crowd out’ these other uses that may not offer developers the financial benefits that residential offers, but these uses are so important to the provision of strong dynamic, economically thriving, lively, culturally diverse and entertaining town centres. This is where buildings like County Hall are so important, offering as it does opportunity for a range of activities, business space as well as educational facilities. That building must remain allocated and safeguarded for civic, education uses, but should be broadened out for leisure, arts and commerce – uses that provide community facilities and deliver public benefit.
Notwithstanding our earlier comments on the undeliverable nature of the London Plan’s housing targets, tall buildings will inevitably continue to be promoted because of the need to intensify the use of our scarce land resource. London Plan D9 must be applied and strictly adhered to in decision-making. In accordance with D9 the new Local Plan must identify where tall buildings are / are not going to be supported. There must be no room for policy misapplication as there was with the recent GLA consideration of the Eden Campus proposal. Policy in this regard must make it clear that buildings above the specified height (the height where impact on heritage assets causes harm) will fail that policy test.
There is insufficient emphasis in the Engagement document about the need to enhance our heritage assets. The previous consultation and the GLA Direction of Travel rightly set out a balanced approach between development and heritage. Preserving and enhancing heritage brings benefits in terms of attracting people in to Kingston Town and the Borough generally, and brings huge quality of life benefits through living in a quality environment. The new local plan needs to reflect this balance – we now have the Mayor of London’s request for ‘good growth’, and we have moved away from ‘development at all costs’, our Borough Local Plan needs to reflect this.
Community services and facilities
We agree with the Engagement documents view that community services and facilities have an important role in developing and supporting strong and inclusive communities. It makes an important contribution to residents’ quality of life and positively impacts a wide range of health, social, and economic outcomes.
We also agree with the suggestion that land (or buildings) should be safeguarded where there is a clear infrastructure requirement (page 37).
Making provision for community services and facilities very much accords with the Borough’s existing Core Strategy policies that support educational uses and community facilities (policies 15 and 16), and also the new London Plan’s support for community infrastructure and education provision (policies S1 and S3). The new Local Plan should follow this policy approach.
The new Local Plan could help by identifying and safeguarding sites that are needed for infrastructure and community services and facilities, so that with the pressure for residential, these do not become lost opportunities. If we do not maintain and grow our social infrastructure we will not build balanced and sustainable communities, and we will not deliver good growth.
The community services and facilities policies are very relevant to our consideration of the future repurposing of County Hall. Its Grade 2* listed status means it should provide public benefits, and as we have previously stated this building is optimally located to support educational uses – linked to KU and/or KC, but also perhaps school education for which there is likely to be a requirement in Grove/Town centre over the plan period. The building is substantial, and could provide a range of community uses, and as referred to earlier could provide much needed commercial floorspace, in a highly prominent building in a prime location. We acknowledge that it will take time to establish our community use requirements, and the Council should start this process now. What the Local Plan must not do is close off the opportunity to allow the building to be repurposed for predominantly community uses. It must ensure there is opportunity to bring forward community uses by allocating / safeguarding the site for the requisite uses.
It is clearly important at this time to support the local economy, and it is the role of the Local Plan to ensure that economic growth is not constrained by a lack of sites suitable and available to deliver opportunities for new businesses entrants and for established businesses to expand.
The Engagement document refers to the London Plan’s support for Opportunity Areas within the Borough, and it is noteworthy that it makes very clear that future change in these areas is not simply about housing. These areas have opportunity “to provide leisure, cultural and night-time activity, commercial and retail uses, as well as high density housing”.
To ensure there is a supply of the most appropriate sites for economic uses the local plan needs to allocate sites.
The London Plan states that Crossrail 2 will improve Kingston’s attractiveness as an office location and therefore support additional commercial growth in the town centre, building on links with Kingston University and Kingston College. The London Mayor clearly sees the potential for commercial growth building on the strengths of Kingston University and Kingston College. London Plan Policy E8 supports the pursuit of jobs and innovation linked with higher education. We support that too.
Regardless of when Crossrail 2 gets reprioritised the Mayor clearly sees the economic opportunities that could flow out of the Borough’s educational establishments, and recommends boroughs consider detailed affordable workspace policies in Local Plans, in light of local evidence of need and viability. Planning policies should also encourage the provision of new employment floorspace for smaller businesses in town centres. The Engagement document goes on to say (pg38): businesses are in a position to support educational outcomes such as apprenticeships, work experience and skills training. Affordable workspaces, workspaces linked to academic institutions will be ideally placed to do this.The Engagement document asks how the Local Plan could help the local economy, and suggests further policies could be put in place to protect valuable floorspace and safeguard jobs by restricting changes of use on sites.
We agree, and support this policy approach as without this policy protection sites capable of supporting employment uses will come forward for residential use, providing bigger developer returns, but denying the local community the opportunity of educational and community assets and also job opportunities.
We thank the Council for providing the opportunity for this Association to present what the key issues and potential planning solutions are for us, and we look forward to seeing the Council’s response and next steps given the expressed intention to shape the future together.
Robin Catlin FRICS
Vice Chair, and Chair of Planning and Development Sub Group
Riverside Residents Association