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 first draft response, if you have comments or additions please let us have them as soon as possible as time is short.
1. VISION – PLANNING FOR GOOD GROWTH
(Questions 1.1, 1.1A, 1.2, 1.3, 1.4)
1.1 The Council has stated that its intention via the new Local Plan is to promote ‘good growth’. ‘Good Growth’ in the Mayor of London’s foreword to the new London Plan 2021 is defined as ‘working to re-balance development in London towards more genuinely affordable homes for working Londoners to buy and rent.’ He goes on to say that ‘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.’
1.2 Furthermore the Mayor goes on to say that ‘Good Growth is 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’.
1.3. For the Borough of Kingston upon Thames, the Kingston upon Thames Society (KTS) believes that the Council must clearly set out its own vision of ‘good growth’ for the Borough. This may well begin from a position which coincides with the Mayor of London’s view but it must also respond to Kingston’s specific and local needs as expressed by Kingston’s residents and businesses. Moreover this must be a SPATIAL vision clearly setting out where development is actively encouraged and where it is only conditionally encouraged or actively discouraged. Where development is discouraged such as in the green belt or in sensitive Conservation Areas and Thames riverside locations, then the Council should actively put in place measures for the good stewardship and management of these areas through properly funded enhancement and management strategies and plans.
1.4 The inter-related issue of housing targets and Opportunity Area status must be tackled. We understand that although Opportunity Area status for Kingston is contained within the London Plan the extent and nature of the Opportunity Area including boundaries and the proportion of the borough’s housing targets to be met within the Opportunity Area has not yet been finalised. Indeed it will and should be the task of the Local Plan to determine these matters. We are aware of the previous Direction of Travel (DoT) document dating from 2016.
1.5 Although the DoT document is stated to be Supplementary Planning Advice to the London Plan on page 4 of the document, this does not in fact give it significant weight in planning terms. Supplementary Planning Advice has lower status than Supplementary Planning Guidance, the document has not been through any formal inquiry or hearing process and circumstances have significantly changed since it was produced in that the Crossrail 2 project has been effectively halted. It was Crossrail 2 which was essentially the guiding force behind the designation of Opportunity Area status to particular parts of the Borough where increased transport provision was seen as the key to promoting more concentrated housing provision. The Local Plan must therefore address this significant change and be clear that those levels of development can only be contemplated if Crossrail 2 is reinstated and convincingly programmed. Given the delays and increased funding problems for Crossrail1 (the Elizabeth Line), what justification could there be for simply proceeding without question with the central thrust of the DoT document within the Local Plan period?
1.6 The Kingston Society would not be critical of the Council for starting from the premise of a deliverable Opportunity Area for the Borough given that it is part of the London Plan with which the Local Plan must comply. But if the infrastructure required to deliver the OA cannot be guaranteed, then it cannot be a sound planning process simply to proceed as if nothing has happened. There has to be some kind of reassessment and the Kingston Society would be happy to work with the Council and others in a collaborative way to take such a reassessment forward.
1.7 The reassessment will need to take account of the post-pandemic scenario. There will need to be even more focus on the 15 minute city and other similar concepts of more local sustainable development. There may well be a need to promote more local employment, and certainly more local employment ‘hubs’ where ‘home workers’ can have better access to office-type environments if they are not commuting to offices in central London but have space and other constraints at home.
1.8 The Kingston Society has been generally supportive of the Neighbourhood Planning [NP] process currently underway in North Kingston. The details of the NP will need to proceed through the statutory process including a public examination and the necessary local referendum. The Council should indicate as early as it can whether any aspects of the NP will be adopted into the Local Plan or indeed whether any aspects of the NP are contrary to the emerging Local Plan.
2.0. HERITAGE AND DESIGN
2.1 A comprehensive analysis of heritage and design principles must be an integral part of the strategy of the plan. These issues cannot be seen as add-ons or relegated to box-ticking environmental assessments outsourced to consultants with insufficient local knowledge and little reason to have any lasting commitment to the consequences of their assessments. There is a known deficiency within the Council of a lack of in-house professional built heritage conservation advice. This needs to be remedied soon as possible if the heritage of the built environment is to be given the correct weight in the Local Plan’s policies and proposals.
A programme of Conservation Area enhancement studies needs to be devised, and commenced as soon as possible so their conclusions can be incorporated into the Local Plan where appropriate and necessary. In addition, greater resources should be devoted to improving and extending theBorough’s list of Locally Listed Buildings, identifying more qualifying buildings and promoting knowledge of the existing locally listed buildings through an online register.
2.2 Urban Design has risen up the government’s agenda in recent months. The establishment of the Office for Place under the chairmanship of Nicholas Boys Smith in July of this year together with the emphasis on drawing up local design codes must be reflected in the Local Plan. The lack of a local Kingston policy on building heights and tall buildings in particular has been noted by the Greater London Authority in recent reports. Establishing a sound building heights policy must be an essential part of the Local Plan. A framework for the commissioning of local ‘design codes’ must also be established in the Local Plan. The codes must not be only developer-driven.
3.0. GREENING OF THE CITY AND THE SUBURBS/GREEN BELT
(Questions 3.1, 3.1A, 3.3, 3.4, 3.5)
3.1 The concept of biodiversity net gain is gaining more and more recognition and is likely to be further enhanced in the forthcoming Environment Bill. It must be a guiding principle for the Local Plan. Similarly, carbon offsetting fund contributions and infrastructure projects must play a major part in the Local Plan. What the Local Plan will need to do is to embed the policy that will enable these to be delivered within the Local Plan period.
3.2 There needs to be a full review of open space in the Borough, not just from a biodiversity point of view but also from the point of view of active and positive management and use. If all the Green Belt and Metropolitan Open Land [MOL] is to be maintained as such this needs to be fully justified in the Plan and appropriate proposals need to be brought forward for any underperforming areas of GB or MOL such as the Seething Wells Filter Beds should be brought up to the required level.
3.3 The Arcadian Thames Area Framework produced by RB Kingston, neighbouring boroughs and the GLA should be revisited to see how its aims and objectives can be incorporated into the Local Plan. To quote Sir David Attenborough, “the Arcadian Thames is one of this country’s greatest treasures. It contains palaces, historic gardens and former royal hunting parks as well as commons, wetlands and long towpath walks. Taken as a whole it is the largest open space in London. No capital city in Europe has anything like it.”
3.4 The Local Plan should acknowledge that the Kingston Arcadian Thames is under immense development pressure and its fundamental character is under threat. The new local plan must address this with a robust policy including a Tall Buildings policy to protect the Arcadian Thames and views to and from it for future generations.
3.5 The principle of ensuring minimum discharge of embodied carbon from the demolition of buildings should be embraced.
4.0. CALL FOR SITES AND SITES ASSESSMENT DOCUMENT
4.1 The Kingston Society understands why the Call for Sites process needs to take place and welcomes the resulting Sites Assessment Report which has been produced as part of the current Local Plan consultation. The Society will comment separately on the contents of that report. What is important however is that the Local Plan should include a Site Allocations Document and that this document should not simply be a reflection of the sites promoted by others via the Call for Sites but should be an embodiment of the Council’s strategy as the local planning authority acting on behalf of local communities. The document will need to be clear as to whether to include sites emerging from the North Kingston Neighbourhood Plan and should include sites not brought forward in the Call for Sites process where the Council considers they are an essential part of the Vision and Strategy of the Local Plan.
5.0. LOCAL ECONOMY
5.1 The creative industries are hardly reflected in the consultation document. It does not mention RBK’s adopted Cultural Strategy entitled “Made in Kingston: a strategy to hardwire growth into culture” (April 2018). This omission is highly surprising because two of the Action Plan Tasks of “Made in Kingston” (p12) involve the new Local Plan.
As the Local Plan develops, “Made in Kingston” should be taken into account and recognition of the importance of the creative industries to the Borough must be adequately reflected.