Our response to Kingston’s final draft Local Plan

After a good deal of reading, discussion and rather more planning jargon than is healthy for anyone, the Kingston Society has completed its response to the Council’s Regulation 19 consultation on the draft Local Plan 2028–2043.

Kingston Local Plan 2028–2043:

What is Regulation 19? This is not another general consultation asking residents what they would like the Local Plan to say. That largely happened at earlier stages. Regulation 19 is the point at which the Council publishes the plan it intends to submit for independent examination. Representations therefore need to concentrate on whether the Plan is legally compliant and “sound”: broadly, whether it is properly justified by evidence, capable of being delivered, consistent with national policy and an appropriate strategy for the borough.

That has shaped our response. We have not attempted to comment on every policy or every site allocation, nor have we repeated objections simply because we dislike a particular proposal. Instead we have concentrated on a relatively small number of issues where we believe there is a genuine question about the evidence, the policy wording or the effectiveness of the Plan.

The bigger picture. One of our main concerns is that some of the Plan’s growth assumptions were developed when Crossrail 2 and a Kingston Opportunity Area were expected to support considerably greater development. Crossrail 2 is no longer a realistic prospect within the Plan period, while the emerging new London Plan points towards a substantially lower housing target for Kingston. We are not suggesting that every allocation should simply be reduced, but we do think the Council needs to show that its most consequential choices remain justified in these changed circumstances.

Tall buildings and design. We support growth and appropriately located taller buildings, but the Plan’s mapping can give a much broader signal for tall development than the Council’s own detailed evidence appears to support. We want clearer, site-specific limits on height, massing and the protection of important views, heritage and the Thames. We also support the strengthened emphasis on design codes, provided that they implement clear local expectations rather than leaving fundamental decisions to developers later in the process.

Green Belt, MOL and sensitive sites. We have questioned whether the evidence justifies some proposed releases, particularly at Clayton Road, Chessington, and whether the proposed treatment of Motspur Park Gasholders properly reflects its Metropolitan Open Land, ecological, transport and townscape constraints.

Other parts of our response cover Kingston town-centre parking, Beverley Brook, biodiversity, Seething Wells, conservation areas and a selected group of individual site allocations.

Our full response explains the evidence behind each concern and, importantly, the modifications we believe would resolve it. The aim is not to stop Kingston changing. It is to help ensure that the Plan guiding that change to 2043 is as clear, evidence-led and effective as it can be.

The full report is here