Kingston Society’s Comments

The Kingston upon Thames Society, founded in 1962 and affiliated to the Civic Trust, is Kingston’s major voluntary and independent organisation concerned with planning and conservation. The Society has no statutory right of consultation. A link to their website can be found in here.

The mission of the Society is to promote high standards of planning, conservation and design in the Royal Borough. Following the full application for the Motspur Park Gas Holders Development, the Society has submitted the following comments:

1. As the site is Metropolitan Open Land (MOL), there is a strong presumption against any form of built development.  Furthermore, the site is not identified in RB Kingston’s Tall Buildings Strategy as being suitable for the sort of tall buildings that are being proposed.  In addition the PTAL (Public Transport Accessibility Level) for the site is 1 and only reaches 2 closer to Motspur Park Station. The access route for pedestrians to the site is down a long and poorly overlooked path which gives rise to concern about the personal safety of users particularly on winter evenings and nights.

2. For all the above reasons, the Society does not consider the site is suitable for the type and amount of residential development which is proposed. The Society is also aware of the existing and potential nature conservation value of the site with one Site of Interest for Nature Conservation (SINC) being within the red line boundary and another immediately adjoining on the other side Beverley Brook. The Brook itself is also of nature conservation value and on a visit to the site which was kindly facilitated by the developer, herons and a peregrine falcon were observed.

3. In light of the above, the Society considers that any development of the site would need to be significantly reduced from the level set out in the application as submitted.  It would need to be at a level such that the integrity and value of the wider area of MOL within which the site is located was not compromised and such that the nature conservation interest of the site was not reduced. Indeed the principles of biodiversity net gain (BNG) would indicate that a positive nature conservation benefit should be provided.

4. We had understood during the pre-application process that some significant restoration of graded riverside banks along the brook would be included within the application particularly along the vehicle access road from the south. However it appears from the application as submitted that there is much more limited riverside bank regrading mostly in the north of the site.

5. The Society’s view is that any built development on the site should only be considered within the floor plan/site area and heights of the existing gasholders on the site.

6.  It is understood that there will be some retention on site of an operational gas facility and clearly there will need to be appropriate safety measures taken including decontamination before an acceptable development proposal can be produced.

7.  The Society has real doubt about the applicant’s stated intention to deliver 35% affordable housing as part of the proposed development. For a start, by number of housing units, the affordable housing percentage appears to be nearer 30%.  More importantly however, Table 7.1 on page 30 of the Planning Statement submitted with the application states that even with zero affordable housing, the proposed development is not financially viable.  Indeed footnote 14 on page 31 of the same document indicates that the 35% offer will not be met if national government or the GLA announces that there is to be a change in the percentage of affordable housing to be sought in London. Such an announcement has of course now been made, reducing the 35% figure to 20%, although this has yet to be the subject of public consultation.

8.  If residential development is to be permitted on the site, any built form that is so exposed should at the very least reflect the footprints of the landmark gasholders as indicated in point 5 above.  Such an approach would at least be a nod to the memory of their existence.  Interestingly such forms of development are currently proposed in another planning application at the former Regent’s Wing at Kingston Hospital (ref 25/02172/FUL).  If the cylindrical form is deemed not suitable then any alternative proposal has a civic duty to respond to the exposed nature of the site and be an exemplary piece of architecture and not a generic brick clad tower block.


Although the views expressed are not necessarily those of the Society, the Chair has also has written this article about the development