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Other Consultations

See also : Major Schemes & Minor Schemes

There are a number of important consultations the Society has commented on lately.

This is a summary of our position on the following current and recent major consultations:
Kindly contact the editor if you see any errors or omissions: 

The Consultations:

Tolworth Area Plan Cock’s Crescent SPD
Kingston Riverside SPD Go-Kingston
London Plan  

London Plan

Jan 2018: Our response to the London Plan consultation:

  Referring to Page 38 of the draft:

The Society has consistently opposed the designation of the Borough as an “Opportunity Area”. We opposed this in our response to the Kingston Direction of Travel sent to RBK on 27th July 2016. This designation sets the tone for potentially a huge increase in the density of new developments throughout the Royal Borough, something which we think will gradually destroy the character of the area. This has evidenced by the considerable amount of residents’ opposition to the recent 3 approvals given by the Council to 3 recent very tall & very dense developments in the centre of Kingston ie. the TOPO site, eden Walk & the likely approval of the Surrey house site[expected in the next month or so] & the deferred decision for 960 units on the former Government offices site alongside the A3 at Tolworth.

We think that the residents of all 4 of the target areas ie Kingston, Norbiton etc., New Malden & Tolworth do not want to suffer the erosion of what are now reasonably pleasant areas in which to live & work, by tall & very dense new development as identified at Page 38 of this Plan.

All this development partly assumes that Crossrail 2 will be granted approval but this has neither been given yet, nor has its funding been explained. We understand that its earliest date for its completion is 2033 by which time residents will have been dominated & overshadowed by a large number of new development changing the character of the area forever.

What we do know from the Council is that the Council of this Borough will be expected to contribute a substantial amount of cash towards the construction of CR2, none of which has been made public to residents of the Borough & to which they may have very strong objections, as it will probably mean yet further increases in their Council tax, which is currently one of the highest in London.

Re. the Tables 4.1 & 2 on pages 146 & 156: We think the housing targets set for this Borough are completely unobtainable. There is simply no possibility that there is enough land available to either justify or support these numbers, without large scale demolition across the Borough.The annual total count is just under 2000 units. We do not think that existing residents have been informed about the consequences of this demolition which may well affect either their homes or those nearby.

We do however support the H5 Policy but on the understanding that the 50% target must not be lowered in any way but this 50% should also apply to Policy H6 & not the 355 as written as it undermines what is contained in H5.

Regarding Policy H17: Due to recent new developments which have been granted but have mean the land used has not been available for ordinary housing to be built, this Borough now has an oversupply of very ‘expensive to rent’ student accommodation. Our members think that there is absolutely no demand for any more for the forseeable future, especially as Kingston University is shrinking its numbers by around 35% over the next few years.

We can see no references in the Plan to making empty properties available in particular those bought for investment purposes by rich owners from abroad. This has been mentioned in the past by the Mayor, & it could go a long way to getting homes available immediately for Londoners to occupy. Something also needs to be done.

Nothing has been mentioned about the disastrous consequences of Mrs. Thatcher’s policy of the “Right to Buy” policy which has meant that Councils have never been able to build new Council owned properties as replacements.The ”Right to Buy” Policy should be abolished & something to address this should be included in this Plan.

In general the Policies contained in Chapter D2 are worthy of support. However they need to be more specific as they are open to very wide interpretation. The use of design review panels is a good idea but they must - in our view - include a sensible proportion of local residents, & local design professionals such as architects & landscape architects. We think that the Tall buildings Policy D8 is far too general & therefore it needs to be more specific & must be strengthened. For instance the City of Liverpool has strengthened theirs.

Re Chapter 7: Conservation areas as such are barely mentioned, & yet they are of vital importance to this historic Royal Borough.More detailed advice & stronger Policies should be written in this plan, and heritage assets need better clarification as most residents do not understand what these are, & therefore how they may be endangered & so this part of the Plan needs strengthening. After all we know that heritage & conservation is one of the reasons why London is supposed to be the 2nd most popular city to visit.

The Policies in Chapter 8 are sensible & the Society endorses all that is written there.

We trust that our views will be taken properly into consideration, & look forward to hearing about the next stages of consultation & appearing at the Examination in public in due course.


Tolworth Area Plan

Oct 2017: Public Consultation

"The Tolworth Area Plan sets out a future vision for Tolworth to help inspire new development and initiatives capable of delivering physical, social and economic improvements. The document will therefore help to focus discussions around the form and type of future development, promoting coherence and consistency between individual projects."

Of note is the design guidance from page 104 onwards:

A) Focus higher densities and taller buildings around Tolworth Station.
B) Intensify the workspace at Red Lion Road Business Park and Chessington Industrial Estate.
C) New landmark development to help deliver new public realm and improve the crossing of the A3 junction.
D) Introduce landmark building at the junction of Ewell Road and Tolworth Broadway to signify the northern entrance to the Broadway and create a distinctive local character. 
E) Deliver a landmark building at the station to provide a focal point for development south of the A3.

Incorrect boundary excludes some stakeholders 
The Society firmly believes that the boundary lines for this whole Plan are wrong & therefore flawed, especially to the North & North East [pages 28 onwards]

The Plan should have included the conurbation of Berrylands which historically has always comprised the area of suburban house & roads, whose postal addresses in the past were known as Tolworth. Residents in the Berrylands area often use either Berrylands or Tolworth Stations for rail travel & many use the shops in Tolworth either for ‘top up’ or weekly shopping as it is closer than Surbiton & more convenient/easier to park or by bus. The Society believes that the boundary lines should be Hollyfield & King Charles Roads to the North, the road actually called “Berrylands” further north which is a clear cut off point before residents tend to think that they are in “Surbiton”.

The natural physical boundary to the east should have been the Hogsmill River which clearly defines a line between the conurbations of New Malden & Berrylands. This would have taken in Raeburn Avenue & all the roads leading off it & running towards the centre of Tolworth.

Ditton Road is the obvious line between Surbiton & Tolworth, so all the roads to the east of it & running up to & including Red lion Road should have been included within a more realistic boundary. Similarly, all the roads running between Ewell Road & King Charles’ Road should have been included, as residents there would tend to imagine that they have a Tolworth address even if the Post Office doesn’t support that notion.

Residents in roads such as Douglas Road & all those right up to Hook Road - which is yet another natural line - have been excluded from this plan, yet they would certainly not ally themselves with Chessington, or even Hook as their natural town centres. These residents are likely to use Tolworth as a shopping & leisure destination & their children may well attend either Tolworth Girls School or Southborough Boys School, the latter having been excluded from this Plan. All these students are within the obvious catchment area of both schools & they may grow up & wish to use what is being planned for the Tolworth town centre yet those house have been missed off this map.

Nevertheless the Society agrees & supports some of the guiding Principles in the “Vision Statement” but with some strong reservations.

Cross Rail 2
The first of these which is fundamental to the entire Borough & has been accepted as fact in the ‘Direction of Travel Document’ [page 20 refers]& to which this Society & many other bodies across Kingston strongly objected in 2016*, is the premise that Cross Rail 2 actually will be built [page 23 of the plan].

The Market Analysis referred to on page 39 is now out of date & flawed if the following facts are taken into account:

In the recent budget statement by Philip Hammond on November 22nd there was absolutely no mention of CR2 being funded. Indeed it is well known that the GLA & the London Mayor’s office will not have the funds to pay for all of it, nor will London Boroughs such as RB Kingston. The downgrading of the Chancellor’s Growth predictions suggest that the country & Kingston in particular is facing a significant slowdown in the economy, which is not expected by many experts to get the country out of recession until the mid-2020’s. So if Crossrail 2 is never built or seriously delayed are existing residents across the Borough & especially in Tolworth expected to put up with the enormous amount of development which is being forced upon them whether they like it or not? Should CR2 ever be built informed opinion suggests that it is not likely to be until started until the late 2030’s.

This CR2 premise is another in which this Action Plan is seriously flawed in the opinion of the Society. In his recent decision on the “Tesco” site, the Planning Inspector questioned what amount of weight could or should be afforded to the construction of CR2 & stated that it should not be given undue weight due to the uncertainty of it ever being built.

A3 'decking' travel plan
While the Society does not usually comment upon traffic matters nevertheless we are concerned about the plans for the decking over some of the A3 adjacent to Tolworth in Page 22 of the Plan & in the 2016 Direction of Travel document. These are in the Society’s opinion complete fantasy. It is uncosted & quite frankly in the current & future economic climate [mentioned above] we think that it will never, ever happen. This another ridiculous idea- which may blight residents’ lives & homes in that vicinity - & should be removed from both documents as it is fundamental flawed.

TFL appear to be happy with both this & the plans for Site H in terms of air quality, but as there assertions have not been published in detail in this document we have to question whether either of these proposals can be acceptable regarding their impact on the resulting air quality.


Permitted or anticipated residential schemes would allow around 1360 dwellings to be built in Tolworth, whereas the 2012 Core Strategy suggested less than half that of around 600. This Core Strategy document has been superseded by the DOT* adopted in 2016 but this did not identify specific sites only that “selective redevelopment could take place in this part of the Borough” [page 22 last para]. However the DOT now suggests that Tolworth might accommodate a figure of 2,000 resumably based upon the subsequent various design studies that are set out in the later parts of the document?

The Society questions this figure & objects to many of these studies. We quote from Page 21 of the Plan which.. “reflects upon the quality of the existing built form & characteristics of the area to consider what an appropriate scale & form might be within this area..” The Society is deeply concerned that this statement is not then reflected in any way whatsoever in the development proposals illustrated in later pages.

On page 57 under the heading of Economic Strategy para 3 suggests that existing & future residents are taken into account but if the area has been wrongly drawn* some of them will be affected but haven’t been stakeholders included in this Plan. Ditto on page 56 with the heading ..”movement..” para 1 “connect neighbourhoods” the same opinion of the Society applies.


1. Sites C & D ESSO filling station Ewell Road/Broadway junction

We question why is this is seen as an improvement & how might it be reconfigured? What on earth is a ‘parklet’ [not explained in the Plan] & who would enjoy sitting in a ‘parklet’ on the edge of the busy A240 road? We don’t think such a notion would ever be used or indeed pleasant, refer to the serious Air Quality issues referred to elsewhere in the Plan. The proposed development is far too high at 8.5 storeys especially in relation to the adjacent RC Church & immediate houses opposite as well as the shops & flats above them on the Broadway.

We suggest that some redevelopment might be appropriate on this site but on a much more modest scale while decrying the loss of the last petrol station in the whole area. Motorists in future would have to use valuable petrol & travel to either Hook or to the Tesco site on the outskirts of New Malden.

2. Site H : The BROADOAKS & A3 “ sites

The proposed “peninsularisation” […another new word!] is in the Society’s opinion a completely untenable & mad idea. It would cause massive disruption to the traffic which currently flows reasonably well - other than at some but not all- peak times. To suggest that drivers will accept such a drastic alteration especially those exiting the A3 from either the Hook or New Malden direction is quite frankly complete nonsense. It will never work & is likely to be dropped due to public opposition. The development proposals sitting on the back of this notion are therefore fundamentally flawed .The suggested heights of 10-12 storeys on page 124 are completely out of keeping with adjacent house on the A3 slip road & Hamilton Avenue. Who is going to use the benches illustrated on the plan, with traffic immediately in front them & the appalling air quality from all the cars surrounding them likely to affect their breathing?

We might support the idea of some modest redevelopment but 11.5 storeys is just far too high & out of character with the surrounding properties on this side of
the Broadway.


We support these ideas & the suggested heights as they are more acceptable due to the lower impact upon adjacent residential properties, except for the impact upon the 2.5 storey flats** close to the vacant Marshall House site. In all other respects it relates better given the presence of the new Premier Inn & the approved Lidl HQ.


We support in principle the redevelopment of this site as it would remove a long standing & inappropriate use in an otherwise pleasant residential & parkland area. The notion of an Old persons’ home is very sensible; however we think that the plan shown is far too close to the rear gardens of houses in Elgar Avenue.


We think that some redevelopment is welcome as the current building is an eyesore but we do not support the notion of a building of 14.5 storeys. We think that a maximum of 5 storeys might be more appropriate, especially as it would sit next to the adjacent 2.5 storey high flats**.

6. SITE P : The “GOALS” site

We strongly support these ideas as they would strengthen the current sports & leisure use of this site which could be a very attractive draw for residents from Tolworth & from a much wider catchment area.

Public Realm & Open spaces

We support all the ideas contained under this heading as they would hugely benefit residents & visitors from a wider area of the Royal Borough of Kingston & from much further afield.

In conclusion we appreciate the huge amount of effort & work that has gone into creating this very lengthy & detailed document & while we cannot support some of the ideas that we have referred to above nevertheless we will look forward to how it is received by residents & Councilors alike.

We hope to make further representations when the document is finally debated in early 2018 & put before the Growth Committee of the Borough Council for amendment & approval.


Cock’s Crescent SPD, New Malden

Nov 2016: Adopted

This Supplementary Planning Document (SPD) guide to the redevelopment of the Cocks Crescent site in New Malden would carry material weight for consideration as part of decision making in the development management process.  The goal of the SPD is to achieve comprehensive regeneration of the site and deliver maximum community benefit and it had been developed with significant community input, to set out a shared vision for the future redevelopment of the site. 

This is a mixed use development site with a new Community Sport and Wellbeing Hub and public square. The site is proposed to be redeveloped in a way that responds to the aspirations and needs of the local community and the wider borough.
New Malden Futures and Malden Independent Community Organisation will arrange a meeting to establish common ground. New Malden Futures will visit sites at Tooting and Streatham which are held to be models of the type of development planned by RBK for Cock’s Crescent.

The Society on the whole supports this in principle, but is concerned about the lack of information since the SPD was adopted.

Kingston Riverside SPD, Kingston 

March 2018: Consultation on the SPD for Kingston Riverside

Here follows our feedback on the Draft SPD for Kingston Riverside, on behalf of the Kingston upon Thames Society.

1. Canbury Gardens

An excessive amount of fishing platforms is shown in Canbury Gardens. We question if there should be any as they are likely to interfere with the enjoyment of other residents & visitors who wish to walk alongside the riverbank.

There is serious concern about the amount of shared cycle-ways with pedestrians in Canbury Gardens. It can be quite dangerous for pedestrians who are unaware that a cyclist is moving near them. If there could be some designated space set aside specifically for cyclists next to the river and not elsewhere in the park, this would be sensible thus allowing the rest of the Gardens to be calmer in nature, & not therefore not so dangerous.

Canbury Gardens has never been a “formally laid out public park” as described in the consultation document. Instead its informality helps create a pleasant open space to relax. “Formal” and “relax” don't go together.

We don't think that the band stand should be moved. There is absolutely no need to do this. It has been a valuable addition to the park & is enjoyed by the many hundreds of visitors & residents every Summer, so it should remain in its current position.

Some of the planting alongside the riverside need to be refreshed.

Thought and funding needs to go into ongoing maintenance.

2. Central area

Too much is left open to interpretation. E.g. what are classed as “non essential activities” ?

We need to protect some of the characterful old buildings along the river, which could be under threat with the desire to maximise commercial, leisure and recreation etc. Suggesting that maximisation is good will only encourage developers to make unwanted & unnecessary applications for yet more new development.

We also need to keep free-to-use open spaces and seating such as the area to the south of the Ram Pub, & where possible to create more but not by developers demolishing existing properties many of which are part of the town’s heritage stock.

3. Queens Promenade

“Turks Boats” either should not be here, or should be condensed to half its current footprint. At present they occupy an area considerably bigger that can be justified & they are not an attractive asset to the area.

Reinstating the Foot ferry crossing to complete a circular walk sounds a good idea. This would be a sensible attraction for residents & visitors alike.

The present character of this area benefits from calm views of the river, and visual separation from the Portsmouth Road. We fail to see how

suggesting in this document that more could be crammed in without it being seriously detrimental to it peaceful character.

We don't support additional moorings in this area which is completely be at odds with the character of the Promenade.

Lastly, the Society agrees with the concerns written by Commodore of Minima Yacht Club: in that there should be a 6th theme as part of the new SPD , reflecting the principles of the adopted National and London Planning Policy Frameworks as they specifically apply to Kingston:

“The Thames riverside depends on the river, and riverside developments should not encroach on the river.“

The Society entirely agrees with the Commodore in his concerns that there must any erosion of the river itself.

But in addition the Society would add “that the Borough must not allow erosion by developers or other organisations” of the Borough’s greatest natural asset, the River Thames itself.


Go-Kingston Programme

2015 onwards: Various consultations 

The council hopes to use the £30 million it successfully bid for in 2014 to relieve the pressure of a growing population on the borough's transport network by improving cycling facilities and road safety, while at the same time enhancing Kingston's public spaces.

The Wheatfield phase has started. Completion is not expected until next year.
The Society is concerned that that the different sections of  the programme did not appear to be “joined-up”.