Come to the council meeting at The Guildhall at 19.30 when the council will try and push through its still deeply flawed “consultation” on the Issues and Options for the Borough’s new Local Plan

This is the start of the council’s plans to see vast swathes of the Borough treated as a “large brownfield site in need of regeneration", euphemistically called an “opportunity” area. It is an insult to us all.

This is your chance to tell councillors that this document is deeply flawed and must not be approved. Let’s see if they listen to the residents who elected them to represent our interests

Why you must come

Despite the decision to publish the document being called in by residents in December 2018, it is still deeply unsound and inadequate as the basis for consultation. At the call in, despite rejecting the majority of the reasons for the call in, the council agreed that the document was too vague, incomplete and uninformative and that, as it stood, “major changes” would be made to it that would not be subject to democratic scrutiny before it was published

These issues have not been addressed and the Committee should not therefore approve that it goes out for consultation

Why the consultation document is deeply flawed

1. The document does not present different development options to residents and the information presented is confused and unclear

2. The council have failed to respond to the request for clarity, completeness and information to allow an informed response from residents. Instead they appear to have interpreted the request that we are stupid so have failed to give complete information for us to consider. They have filled the document with unexplained “images, graphics and maps” that it is impossible to understand or consider in an informed way. They argue that this makes the document “more accessible to our communities when we go out for public consultation” by “removing lots of technical speak and making the document more user friendly and engaging”. What this actually does is take away any possibility of informed consideration of the information presented or of informed response by residents

3. The council fails to lay out clearly the actual growth and elevated densities on large sites that the Borough may see if it is treated as a “large brownfield site in need of regeneration” or an “opportunity” area in the new London Plan. The council confirmed last night that the housing targets for large sites that form part of our 1364 annual housing target in the new London Plan, do NOT take in to account the fact we will probably become an “opportunity” area. These areas see vastly increased densities of development over even the highest Central London density targets. Our housing target for large sites will therefore increase significantly if and when the designation is agreed

4. The document fails to clarify the council’s role in designating, and support for, the Borough as the first whole Borough in London to be treated as a large brownfield site in need of regeneration, aka an “opportunity area” 

5. The definition given of an "opportunity area" is incorrect

GLA website: “What are Opportunity Areas?
Opportunity Areas are London’s major source of brownfield land which have significant capacity for development – such as housing or commercial use - and existing or potentially improved public transport access.
Typically they can accommodate at least 5,000 jobs, 2,500 new homes or a combination of the two, along with other supporting facilities and infrastructure

6. The council has not clarified that our housing targets for the “opportunity” area are minimum targets that will also increase with CrossRail 2

7. The document fails to clarify the Council’s request in its written submission to the Examination in Public of the new London Plan for power to de-designate the Green Belt and Metropolitan Open Land throughout the Borough*

8. The council fails to clarify information about and relationships between each, all and any of housing targets, housing densities, the “opportunity” area, and CrossRail 2

9. The council fails to discuss CrossRail 2 and the implications for the Borough if we get it or if we do not get it

10. The document remains incomplete with no or inadequate text accompanying many images and graphs and maps missing from the document

11. The council gives misleading and incomplete information, for example, in stating that our housing targets have been imposed upon us and that they are “challenging” those targets

12. The council fails to give sufficient detailed information for residents to consider and respond in an informed way to the questions being asked of them in the “consultation”.

Examples include but are not limited to the following:

• Information and explanation of small site versus large site development policies and likely impact of these on actual development that takes place

• Relationship between forecast population increase of 34,000 people and our minimum housing target (before uplift with Opportunity Area status) of 30,008 homes without CrossRail2 and 46,317 homes with CrossRail 2. If we build 46,317 homes, 0.7 of a person will be living in each unit

• There is a lack of any environmental impact assessment of plans for such massive growth and statements make no sense, for example: “The borough also needs to make sense for nature, creating habitat and ensuring our natural environment can continue to play its life-giving role.” The assessment of “Environmental and Air Quality Implications"  is totally inadequate:  "This stage of consultation is the first step towards a new Local Plan. As the statutory plan which directs sustainable development, a Local Plan has a key role in securing positive environmental outcomes, including environmental and natural protections, resource use and pollution"

• There is no meaningful clarification of the policies driving the local plan process

• There is no explanation of the process by which residents and other stakeholders will be consulted at formative stages of the planning process and how the council will give evidence that our stakeholders’ views have been taken in to account in a meaningful way

• The council does not clarify that there is NO additional infrastructure and transport schemes, apart from the GoCycle route, guaranteed to support the exorbitant levels of growth in the Borough

• The council does not explain sufficiently how it will confirm with policies for protecting heritage assets and why the presence of heritage assets “does not preclude large-scale development”

* Kingston Council submission to EiP on Green Belt and MOL (M65- 2607):
“Policy G2 …It would be difficult for the borough to plan strategically in its Local Plan, as well as approve development within the area if ‘very special circumstances’ cannot be applied and there is no scope for a review of the Green Belt boundaries through development of Kingston’s local plan.”
“…the Council recommends that the following policy amendments are made to remove the inconsistency:
“G2 B. The extension of the Green Belt will be supported, where appropriate. [Its] Any de-designation [will not be supported] must be supported and justified by a Green Belt assessment demonstrating the exceptional circumstances which justify the boundary modifications.” Text in red = proposed London Plan wording
“It is … considered that the new policy approach to retain the total quantum of MOL has not been properly justified. …the retention of the quantity of MOL causes confusion. For this, and the reason above, the London Plan policy approach to MOL ‘land swaps’ is not justified, and there is insufficient clarity about how boundary alterations should proceed.”