Petition update

Wherein lies the truth? You decide

Caroline Shah
Kingston upon Thames, ENG, United Kingdom

May 9, 2019 — 

Excerpt from Chessington District Residents' Association (CDRA) April 2019 available online


( i ) Over Development in Kingston – Last month we discussed the work that Caroline Shah is doing to try and fight ‘over development in Kingston’. She believes that the Council were wrong to agree to Kingston becoming an ‘Opportunity Area’ without prior consultation with residents which means that Kingston have a very high target of homes to build in Kingston"

A councillor sent the CDRA an email commenting on this item"

My response to excerpts from this email:

1. "Caroline Scott Shah has not fully understood what is happening. She has not believed the explanations. The call for sites was an exercise started a couple of years ago where developers - not the Council - were invited to put forward any ideas they might have for land that could theoretically be developed.”

The council had already planned for massive scale development on large sites throughout the Borough before the call for sites in 2017. The Direction of Travel document (DoT) acted as the Council’s approval and carte blanche for massive large site development across the Borough. It laid the framework for the call for sites in 2017

In addition, the large site housing target for Kingston in the London Plan is closely linked to the designation that our council is seeking for the borough to be an “opportunity area” for mass development. Without the council’s 2016 in principle agreement arising from the DoT to develop large sites across the Borough, the “opportunity area” could also never happen. It needs multiple large sites to exist

Our council has laid the foundations for a minimum of 33,000 homes to be built across the Borough on large sites

Some of those sites are on the Green Belt and on Metropolitan Open Land, some are not near decent public transport. Some are private and some are owned by the council. Where are they? And why has the council asked for the exceptional ability to remove protection from the Green Belt and Metropolitan Open Land?

Please bear in mind that it is the Council who worked with the GLA to decide which sites could reasonably form the basis of our large site housing target:

Strategic Housing Land Availability Assessment 2017 (SHLAA)
2.6: “local planning authorities were required to undertake a site appraisal for each site and ‘confirm’ or ‘edit’ the site’s status, constraints, phasing and density, drawing on their own local knowledge”

The Council can choose to make PUBLIC the sites it put forward to inform our large site target but it has so far not done so:

SHLAA 2.4: “It is for each local planning authority to determine what if any information on potential sites should be made publicly available at site level through their Local Planning Documents, housing trajectories and brownfield registers”

Our large sites targets are massive: 32,000 new homes, plus 43,000 jobs (Kingston Transport Study 2018)

Our large site target of 739 units a year is a MINIMUM target. This is based on the sites that our council put forward to the GLA and follows an assessment by our council of the PROBABILITY that development will occur on those sites at certain densities

Our large site housing target has been calculated on the basis that we are not yet an “opportunity area” for mass development. The target will increase on any site within the desired “opportunity area”. This is because opportunity area densities are far greater than anywhere else:

Excerpt from the SHLAA
Density assumptions in Opportunity Areas 2.34 Higher density assumptions are applied in opportunity areas to reflect their strategic importance in terms of the delivery of new development in London and to ensure that the SHLAA does not under-estimate the potential housing capacity in these key growth locations. These assumptions are set out below in Table 2.10 and assume that: � sites with ‘suburban’ settings could potentially be developed at ‘urban’ densities � sites with ‘urban’ settings could potentially be developed at ‘central’ densities � sites with ‘central’ settings could potentially be developed at ‘central+’ densities. These are set above the relevant maximum range in the density matrix

In addition, our large site target is actually 16,309 units higher than stated because of the additional homes that Kingston Council has agreed to build as a result of getting CrossRail 2. So, as far as we know, we have to build at least 739 units a year on large sites for 22 years plus an additional 16,309

This gives a minimum number of new homes on large sites for the Borough of 739x22 = 16,258 + 16,309 = Large sites homes target is 32,567

The council has been directly involved in negotiating the density of development that would be possible on the sites it put forward as well as agreeing the likelihood that development could happen on those sites. The numbers were NOT imposed on us by the GLA but agreed with our council

M19 statement by Kingston, Richmond, Merton and Sutton Council to the Examination in Public of the London Plan on Housing Targets
“The Partner Boroughs do not have fundamental concerns with the approach to large sites in the SHLAA as these were discussed in detail with the GLA, including the methodology and individual sites, and are supportive of this Collaboration”

From the SHLAA
"2.6 For sites that are not approvals, the way the SHLAA system works is that site boundaries overlap with GIS layers to inform the initial system default assumptions in terms of density, status and probability. However, these system default assumptions are a starting point and local planning authorities were required to undertake a site appraisal for each site and ‘confirm’ or ‘edit’ the site’s status, constraints, phasing and density, drawing on their own local knowledge"

2. "so that we can start to fulfil the house building targets that the Mayor has set, although we are also lobbying against them"

The Mayor has not "set" the targets. Large site targets were negotiated with Kingston Council

3. "The Crossrail 2 issue is also a consideration but so long delayed that it probably won't be in my lifetime!"

This statement is not correct. It diverts from the true situation of which all councillors should be aware

The SHLAA clearly states of increased density on large sites near future CrossRail 2 stations that “additional capacity… can be secured ahead of scheme opening”

SHLAA on CrossRail 2:
"8.3 As a long term infrastructure improvement, not expected to be delivered until the early 2030s, the ability for the scheme to increase development capacities is most likely to take place within the second half of the plan period (i.e. between 2029 – 2041) – phases four and five of the SHLAA. However, in some instances it may be appropriate to plan in anticipation of the scheme, ensuring that development capacities are optimised and potentially realised sooner [1]
8.4 For the purposes of this scenario, it is assumed that for some sites, the benefits of Crossrail 2 will start to feed through decision making following approval of the Hybrid Bill, which is currently expected in 2023
8.5 It is therefore not the purpose of the Crossrail 2 scenario to alter development capacity within the SHLAA (or to alter borough targets). The purpose is to provide confidence that during and beyond the 10 year target period, there is an opportunity (subject to the scheme being delivered in line with existing timescales) to increase development capacity within the Crossrail 2 Growth Corridors (north and south) so that London can meet its long-term housing requirements.
8.6 The Crossrail 2 scenario is therefore an indicator of the potential additional capacity that could be realised as a result of infrastructure investment…

[1 ] Given the intrinsic link between the investment in Crossrail 2, associated transport benefits and subsequent market response, it will be difficult to secure substantial uplift in housing delivery ahead of its planned opening in the early 2030’s. However, evidence from Crossrail and other major infrastructure schemes suggests that a firm commitment to Crossrail 2 (with powers to construct and agree a funding package), alongside proactive and supportive policy frameworks, will in some instances mean that additional capacity can be secured and the benefits realised ahead of scheme opening. This is particularly the case in relation to larger development opportunities that are phased over a number of years."

Lastly, CrossRail 2 is mentioned 35 times in the DoT document. Who would believe that Kingston’s core development targets are NOT linked to us getting CrossRail 2?

4. "Caroline is spreading a great deal of alarm that isn't justified"

I attempt to give the facts, although it is often a battle to find them

Please read what I have written above and judge for yourself

You can see more on my website at

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