
1. Please sign my Call-In of the Council’s Local Implementation Plan (LIP) that will form part of the Mayor’s Transport Strategy to 2041 if it is not successfully challenged.
I believe the LIP does not meet the requirements set by the Mayor for Borough LIPs, does not reflect the “local context” in Kingston and does not address the demands that will be put upon the Borough by such huge levels of development, and that consultation with residents and residents’ groups on the Council’s plans has been inadequate. A link is given below.
2. Please write to your MP: zac@zacgoldsmith.com for Canbury, Tudor, Coombe Vale and Coombe Hill Wards, and edward.davey.mp@parliament.uk for all other Wards in the Borough and tell them about any concerns you have about plans for mass over-development, particularly on large sites, and how it will affect your neighbourhood and the nature of the Borough, and tell them that these plans have been cooked up behind our backs with no consultation and are therefore unsound and undemocratic
SUMMARY
HOUSING TARGETS 2019-2041: Growth of 46,317 homes
EMPLOYMENT: 2019 – 2041: Provision for 43,000 jobs, up from 13,000
COMPARISON: Vauxhall, Nine Elms and Battersea Opportunity Area COMBINED is for minimum 20,000 homes and 25,000 jobs
CONTEXT
Kingston Council is not challenging the targets for development on large sites across the Borough which represent the majority of our 20 year development targets for homes and jobs in the new London Plan. Large site development will see Kingston change beyond recognition, will place huge pressure on transport and social infrastructure and the natural and historic environment, and will cause substantial damage to our existing neighbourhoods and communities.
And yet, in their joint submission on small site development to the Examination in Public of the London Plan which is currently taking place, The South London Borough of Kingston, Richmond, Merton and Sutton say the following about the inadequacy of CrossRail 2 to meet population growth in order to justify the request for a reduction in small site housing targets. This is inconsistent and nonsensical for Kingston when the majority of our growth will be on large sites (see figures below):
"1.12 Furthermore, the choice of public transport in outer London is severely limited, particularly for London Underground services (there are more tube stations outside the Greater London boundary than serve all South London boroughs). For example, Table A.2 in Annex 2 shows that Sutton has no London Underground stations, no London Overground stations, no Crossrail stations, no Crossrail 2 stations and a single London Tramlink stop (located in an industrial area on the borough boundary with Merton).
Kingston currently has none of these transport options in place but would potentially benefit from Crossrail 2.
1.13 However, Crossrail 2 is neither confirmed nor funded and its timescales do not facilitate delivery in the 10-year period covered by the draft London Plan targets. We still await the conclusion of the Independent Viability Review, the findings of which may significantly delay delivery of this crucial infrastructure, possibly precluding delivery within the London Plan period. Repeated delays have already created uncertainty that is difficult to navigate, particularly in the context of building new homes. The recent announcements regarding delayed opening of the Elizabeth Line will have knock on impacts to the funding profile of Crossrail 2. Additionally the recent Kingston Transport Forecasting Report (prepared by TfL) shows that Crossrail 2 simply returns the network back to 2011 levels of passenger congestion (rather than providing any significant step improvement). Therefore it should not be taken into account as future transport infrastructure which would support housing delivery against Kingston’s housing target. To add to this situation, there is a historical lack of orbital connectivity across South West London, particularly by public transport, further hindering growth potential across the region."
THE NUMBERS
1. GROWTH IN HOMES
Kingston has a minimum housing target in the new draft London Plan 2019-2041 of 30,008 homes (Opportunity Area large site development target of 9000 homes and 5000 jobs are a minimum) without any additional railway infrastructure improvements.
In addition, we have to build an extra 16,309 homes on large sites when construction starts on CrossRail2 according to the Strategic Housing Land Availability Assessment - part of the evidence base for the new London Plan.
This adds up to an extra 46317 homes in the Borough in just 20 years. Currently there are about 66,000 homes in Kingston-upon-Thames.
If you take away from this figure the 13640 currently planned to be built in Kingston in the first 10 years of the new draft London Plan (1364 pa x 10), that leaves a minimum of 32,677 homes to be built in the second decade of the plan.
If small site development keeps happening in the second decade of the London Plan at the initial predicted level of 625 units a year (which local authorities are arguing is highly optimistic), 6,250 of the 32,677 homes will be delivered on small sites, leaving a further minimum of 26,427 homes to be built on large sites across the Borough
Worse still, there appears to be a massive UNDER calculation of the housing we are expected to build in the 2018 Kingston Transport Study Model Forecasting Report, http://bit.ly/RBK-TransportStudy18:
"The Greater London Authority, TfL and the Royal Borough of Kingston (RBK) have proposed to produce a Local Plan for Kingston and have identified the potential for an additional 15,000 new homes ... in the borough by 2041, over and above the current London Plan*. "
The "current 2016 London Plan*" has a target of 643 homes a year. This means that the transport study considers growth in housing for Kingston from now to 2041 of 643 x 22years = 14,146 + 15,000 = 29,146 homes.
This is way short of the 46,317 MINIMUM homes the new London Plan is currently saying we will have to build. It means that the projections in that report of whether Cross Rail 2 can meet demand from the forecast increase in population in Kingston are unsound in that they underestimate the minimum demand for transport services that will come with CrossRail 2.
CrossRail 2 (CR2) seems like a big red herring. There is no sound evidence that it will bring relief to the transport problems we face throughout the Borough.
Based on base development target of 30,008 new homes for Kingston Borough in the London Plan period plus an additional 16,309 units associated with CR2, we would need at least a 70% increase in transport capacity (46,317 new homes divided by current homes in the Borough of 66,000) across the Borough merely to sustain the status quo which is crowding and congestion which is "currently severe and predicted to worsen" according to the council's own officers.
2. GROWTH IN EMPLOYMENT PROVISION
In addition, employment growth was originally forecast to grow in the Borough in the 2016 London Plan by 13,000 people from 2011-2036 from 78,000 to 91,000 people. The above Transport Study now projects need for the provision of premises for 43,000 people, a rise of 30,000 people over the 2016 London Plan figures:
"The Greater London Authority, TfL and the Royal Borough of Kingston (RBK) have proposed to produce a Local Plan for Kingston and have identified the potential for ... 30,000 new jobs in the borough by 2041, over and above the current London Plan"