Thank you all for your support and for the letters and emails you have sent.

Kingston Council will be appearing at the Examination in Public of the proposed “Opportunity Area(s)” for the Borough next Wednesday 23 January. This is an independent assessment of whether the designation of Opportunity Area status for the Borough in the London Plan is sound, and the Council needs to be aware of your concerns.

Please can as many people as possible write to Councillor Liz Green, the Leader of Kingston Council  at liz.green@kingston.gov.uk with your questions? 

You might want to bring up some of the following issues which relate to the Opportunity Area(s), The Direction of Travel, the need for infrastructure investment, and development in and protection of the Green Belt and Metropolitan Open Land in the Borough:

·       Why hasn’t the new administration sought to withdraw their agreement for the designation of vast swathes of the Borough as “Opportunity Area(s)” as defined by the GLA, given there is strong evidence that the basis of that designation, the Direction of Travel document, is deeply flawed and they voted against it in 2016?

·       Given that – in the Direction of Travel - the council has agreed for large-scale growth whether Crossrail 2 happens or not: “… growth in these immediate areas is not dependent on Crossrail 2” and “development proposals in these areas should plan for its arrival”, and given that the current administration claims to oppose this view in their election manifesto, why have they not, since May 2018, been actively and robustly challenging the growth targets in the draft London Plan? Why have they not sought residents’ support in doing so? Is the council’s submission to the Examination in Public too little too late: https://www.london.gov.uk/sites/default/files/m14_rb_kingston_2607.pdf

• What is the relationship between the need for the provision of adequate infrastructure (rail including CrossRail 2, roads, schools, GP and other medical facilities, leisure facilities) and the scale of development that will be expected to happen and that the council will have to allow to happen in different locations throughout the Borough if Opportunity Area status is given to the Borough?

·       Does the LibDem administration plan to protect the Borough's Green Belt and Metropolitan Open Land, particularly in Chessington, the Hogsmill Valley and Tolworth? Will development targets in these areas reflect such protection?

·       Why is the LibDem administration exploring at the Examination in Public whether protection offered to MOL and Green Belt can be lifted (see below) given its manifesto commitment?

The Liberal Democrat Manifesto – May 2018

Amongst other things, The Liberal Democrats said that, if they won the council in the 2018 local elections:

·       We will robustly challenge the new draft London Plan, where the Mayor of London wants to increase Kingston's housing target from 643 units to 1,364 units per year, working together with central government and other London boroughs, to get the level of housing we need, whilst keeping the quality of life our residents value.

·       There should be no large-scale developments on the Green Belt or Metropolitan Open Land; not in Chessington, not in Surbiton, not anywhere our vital green lungs are needed

Please see below Kingston Council’s 1. recently published Assessment of the Green Belt and Metropolitan Open Land and 2. Submission to the Examination in Public on Opportunity Areas:

1.     https://www.kingston.gov.uk/downloads/file/2780/green_belt_and_metropolitan_open_land_assessment

EXCERPT:

3.7 Major Developed Sites in the Green Belt and MOL

38. There are two sites allocated in the RBK Core Strategy (2012) – Chessington World of Adventures and the Thames Water Sewage Treatment Works – as Major Developed Sites (MDS) in the Green Belt/MOL. These designations allow for development in keeping with the current use within the defined MDS boundary. 

39. The Assessment shows that the parcels4 within which the MDS are contained contribute to Green Belt/MOL purposes, although this Contribution is not considered to be significant, reflecting the built-up character of these parcels. 

40. The MDS definition reflects national policy that was originally contained in PPG2: Green Belts which was current when the RBK Core Strategy (2012) was being prepared and examined. PPG2 was superceded by the NPPF (2012) which no longer refers to MDS in the Green Belt. Consequently, it is unlikely that the designation can be used in the Council’s new Local Plan.

41. In light of this Assessment, the Council will need to consider carefully the importance of the activities on these sites to RBK and more widely, and the implications of applying national and London-wide Green Belt/MOL policy without a MDS designation. Included in such a consideration could be whether Exceptional Circumstances exist to justify the removal of Green Belt/MOL policy from such sites. If Exceptional Circumstances are found to exist, the Council will need to define the precise boundary of these site in the Local Plan.

2.       https://www.london.gov.uk/sites/default/files/m14_rb_kingston_2607.pdf

EXCERPT: 

Chessington 20. Chessington North is more mixed in character, and Chessington South is more dominated by inter-war development similar to Berrylands. It has a number of designated local shopping parades and two large areas of employment at Barwell Business Park (a Strategic Industrial Location) and Chessington World of Adventures, a large theme park washed over by a Green Belt designation. The Green Belt designation extends to the immediate south of Chessington South station and up the western boundary of the borough. Capacity identified for housing for sites outside the Green Belt are estimated to be between 1,000-2,000 homes. Therefore again, without extending development into the Green Belt, it is difficult to understand the additional capacity for growth following the opening of Crossrail 2.
 
21.The policy position on Green Belt is set out in NPPF (2012) where paragraph 83 states that ​“Once established, Green Belt boundaries should only be altered in exceptional circumstances, through the preparation or review of the Local Plan. At that time, authorities should consider the Green Belt boundaries having regard to their intended permanence in the long term, so that they should be capable of enduring beyond the plan period.”
​If the delivery of a Crossrail 2 station in Chessington South is considered to be “exceptional circumstances” in terms of allowing for the release of Green Belt to the immediate south, this should be fully evidenced and justified through the London Plan process. The proposed London Plan Policy G2 Green Belt states that ​“development proposals that harm the Green Belt should be refused”​ and “Its de-designation will not be supported”. This would suggest that the presence of a Crossrail 2 station would not justify release of Green Belt. It is also noted that, as part of a delta of train lines, the increase to public transport accessibility is relatively modest with an increase from two trains per hour to four trains per hour.
 
22.In this context, the text in 2.1.24 should be clarified in relation to the Green Belt and MOL designations.