Kingston Draft Local Plan – Summary of comments document
RBK has published the summary of received feedback for the Local Plan consultation. (link here)
During the last few months RBK have been reviewing the feedback from the consultation on the first draft. All of the comments they received are being considered as they develop the next, Publication version of the Local Plan.
In the meantime this interim document provides a summary of some of the key points raised during the consultation on each policy or topic area.
RBK will publish a Statement of Consultation with responses to the comments and where changes have been made to the Plan and policies, alongside the Publication version of the Local Plan.
General comments on the draft Local Plan and consultation process:
Ensure all policies conform with national planning policies or the London Plan
Review the Local Plan to ensure it aligns with latest census information and/or needs assessments and ensure this is reflected in what the borough needs to provide for existing and future communities
The language is too vague in places making it impossible for it to be applied when development proposals are being considered
Simplify some policies to remove ambiguity
Clearer explanations needed around some terms such as ‘design-led’ and ‘masterplan approach’ and what ‘good design’ means
Check that the Glossary captures all terms
Viability of the Local Plan was raised (this will be tested before the next version of the Local Plan is published)
Concern about the impact of the Plan on different genders
Concerns about the publication dates of some of the evidence base documents
Concerns about how the plans and policies can be put into effect
Criticism that the consultation portal was confusing and the questionnaire was too long and could have put people off responding.
What’s happening next? RBK say:
All of the comments we have received are being considered as we develop the next version of the Local Plan. We are also working on a number of studies which will provide an evidence base for the Local Plan and its policies.
When this is all ready we will prepare the Local Plan for its next formal stage of consultation. This will be the Publication version of the Plan. We will then carry out a consultation under Regulation 19 of the Town and Country Planning (Local Planning) (England) Regulations 2012.
We are hoping to finalise the plan and ensure it is aligned with all the evidence-based documents and other strategies by winter 2023/24.
Following a final phase of consultation on the Publication version in the spring/summer 2024, we will prepare to submit the Local Plan to the Secretary of State for public examination later in 2024.
We also find the detailed policy map link very useful.
SOME OF THE ISSUES KINGSTON SOCIETY RAISED:
In its Shaping the Future paper the Council stated that it intended to promote what it and the Mayor of London calls ‘good growth’. But the Mayor of London’s Plan identifies an undefined Opportunity Area in Kingston where new development is to be focussed. Previous documents produced by the Council have suggested that this Opportunity Area would be focussed around the Crossrail 2 route and stations within the borough but, as we know, Crossrail 2 is unfunded and unprogrammed and effectively kicked into the long grass. What is the Local Plan therefore going to say about the Opportunity Area and associated housing targets? There is no allocated funding and no agreed timetable for its delivery. How can Opportunity Area can proceed for Kingston without Crossrail 2?
There is a confusion created around the Kingston Town Centre vision, ie. “Your Vision Our Future: A Plan for Kingston Town Centre”. It appears that this is a ‘vision document’ covering an area which comprises the Kingston Town Centre Area (KTAC) plus the ‘Zone of Influence’. However the consultation on the document does include a question as to whether the boundary should be adjusted so clearly this boundary could change. There is a clear element of risk in the Council taking a full consultation through on an Supplementary Planning Document (SPD) when it is not known how the Local Plan might require to be changed following the Planning Inspector’s report on the statutory Local Plan Examination in Public.
The relationship of the so called Opportunity Areas + KTCA and Zone of Influence vision, plan and delivery document with the draft local plan is currently not fully resolved and confusing to public.
This confusion is further exacerbated by recent government pronouncements about a new class of supplemental planning documents potentially being created which have the same weight as statutory local plans.
The Site allocations: In the past we argued that the RBK’s consultation on the updated site assessments report is of limited value because the context of and purpose and objectives of the consultation have not been properly explained. At this stage we are puzzled with the Council’s over reliance on demolishing of Car Parks including Seven Kings Car park which is relatively a new built. We think some of these sites are not carefully considered and should be removed from the Site Allocations list.
Much of the new development is proposed within the area of the historically important but now so called “Zone of Importance” area zone. We are aware that there are three Grade I, six Grade II*, and 42 Grade II listed buildings in this particular zone alone. We are very concerned about the Encouragement for tall buildings in this sensitive location with high intensity. (see Tall Buildings notes below)
In the past we also asked what is the Local Plan going to say about a strategy for the Council’s green and open spaces? How can the quality of our Green Belt and Metropolitan Open Land be improved? How can areas like Seething Wells Filter Beds be restored to their fulfil their status as MOL or Green Belt? How will the Local Plan ensure that the Arcadian River Thames in our borough is protected from inappropriate development? We are not still not clear.
Much of the new development is proposed within the 4 Town centres. As Society we are working with the Council to create more engagement and discussion within the neighbourhoods and Pilot Urban Room Kingston is created with this vision in mind. We believe the Council should consider outcome of Urban Room discussions to any proposals for development in these Neighbourhood areas.
We understand the consultation on the Draft Local Plan (including Policy KD11 Tall Buildings) will inform the next phase of work to establish if there are locations in the Borough where tall buildings may be an appropriate form of development. The Emerging Tall Buildings Strategy (link) shows where the tall buildings might be located. We know the London Plan defines a ‘tall building’ as anything over 21 metres however tall buildings policy suggests certain areas of Kingston -mainly Kingston town centre -could be targeted for buildings up to 78m high. A comprehensive analysis of heritage and design matters must be an integral part of the Local Plan and any Tall Buildings Policy. In the absence of such document the Plan could give way to an onslaught of speculative Applications which may be difficult to refuse.