Letter to the GLA team members for the Environment and Regeneration
The letter below was despatched 18.6.21. We are hoping that making this public might facilitate a response
For the attention of:
Stephanie Griffiths (Regen)
Iqbal Ahmed (Environment)
Cambridge Road Estate (CRE) regeneration Cambridge Road, Kingston upon Thames 20/02942/FULWe are writing to express concern at matters disregarded at the above redevelopment (GLA’s response Planning File). We were pleased to see the GLA questioning the lack of SuDs proposed in the FRA. (Flood Risk Assessment).
However, we are disappointed that the London Mayor’s own policies on Areas of Deficiency of Access to Open Space and Access to Nature have been ignored. The Mayor has committed to reducing the distance that people live from quality green space/Sites of Nature Conservation Importance - deemed as Areas of Deficiency- yet much of north Kingston is within an AoD (more than 1km from quality open space) refer to map appended.
The Barton Wilmore Environmental Statement, attests that the Open Space in proximity to CRE is within policy guidelines; includes a burial ground SINC and Richmond Park SAC SSSI (another borough) and that wildlife will not be affected by an increase to 6881 people. Can new residents walk their dogs in the cemetery? On graves, during funeral services? This was news to us especially after the cemetery was locked for three weeks during 2020 and continued access is on a permissive basis with Dawson road and ‘Lower Bonner Hill’ road gates LOCKED at weekends.
Will the cemetery continue to be ‘Public open space’ after the planning application is granted by Kingston planning authority or will it return to the former locking regime this assertion that Kingston Cemetery is Public Open Space is disingenuous?
In addition, land designated for leisure services and open space within our ward is being developed at Kingsmeadow/204 Cambridge Road as one of the decant sites and for a Church School, ensuring POS will be further diminished.
Loss of amenity and PROW’s (Public Rights of Way)
Approximately, 2km of Public Rights of Way on the estate will be lost in the application. The council has ignored the PROW’s as existing as the definitive map has not been updated for twenty years. This was apparent due to a recent appeal to the Secretary of State and now the council have an undertaking to correct this oversight. This is about connecting with local amenities, many of which have been closed to facilitate regeneration of the area in this needless damage to our neighbourhood. We have lost shops, pubs, the health clinic and local businesses.
This proposal will result in a massive loss of footpaths to Norbiton and a huge loss of amenity. These footpaths help create the informal areas that wildlife can also use. The privatised model of the gated estate- enclosure 21stcentury style- ensure formal gardens as the dominant culture; not community, but exclusivity and disconnectedness.
BiodiversityThe London Plan includes policy (7.19) Biodiversity and Access to Nature, which links to policies and proposals on approaches to strategic planning in the Mayor’s Biodiversity Strategy. Policy 7.19 contains the following statement;
The Mayor’s Biodiversity Strategy sets out criteria and procedures for identifying land of importance for London’s biodiversity for protection in LDFs and identifying areas of deficiency in access to nature. Protecting the sites at all levels, serves to protect the significant areas of Biodiversity Action Plan (BAP) priority habitat in London and most priority species. This policy is employed by the Mayor of London when considering those larger planning applications referred to him for direction under the Town and Country Planning (Mayor of London) Order 2000. Local Development Frameworks of the London Boroughs have to be in general conformity with the London Plan. It is through these local policies that most protection of priority species will occur. Yet 4 lines seems to cover Biodiversity in the GLA response.
The house sparrow population on the estate is one of the largest in Kingston. It was identified by the council as being 25 birds when it is in fact, 125. This is one of the Nation’s priority species and falls under the Natural Environment and Rural Communities Act 2006. This has not been acknowledged during the consultation. In order to achieve a sustainable solution house sparrow, require a healthy environment, food, areas to have dust baths etc. they will not thrive in highly manufactured landscapes.
Cumulative impactThere is no mention of the cumulative impact of these developments on protected wildlife species; the slow worm population or badger welfare issues at the decant sites at 204 Cambridge Road, Kingsmeadow and Cumberland House, Kingston Hill.
It seems an oversight not to assess the cumulative impact on wildlife species when the cumulative impact on the unprecedented amount of development occurring in Kingston has been mentioned in the Environmental Statement 2 regarding air pollution.
Air Pollution in Kingston
1. Air pollution has not been given sufficient attention
Kingston has a serious air pollution issue and this development will be compounding the problem. The greatest number of the most vulnerable people will be exposed to high levels of air pollution during the demolition. Deprived communities are more vulnerable to the effects of pollution. It is unfair that the council has targeted Norbiton, to be an Opportunity Area when there is such health inequality.
2. The cumulative impact of several developments occurring in the borough at the same time needs more serious attention.
The issues highlighted in the Environmental Statement are very worrying
3. The canyon effect of the towers may cause polluted air to be drawn into the estate.
Street canyons are generally highly polluted urban environments due to high traffic emissions and impeded dispersion. Pollutant concentrations in a street canyon depend on canyon geometry, traffic characteristics, atmospheric stability, entrainment of emissions from adjacent streets, and turbulence induced by prevailing winds The effect of so many towers has not been satisfactorily modelled.
Alison Fure and Damon Hart-Davis (Willingham Way).
Response from Sian Berry 7.10.21 (Sian was the only person to respond or even acknowledge the letter which we sent twice) nb: reproduced without footnotes
email@example.com 020 7983 4391 @sianberry facebook.com/sianberrygreen
Sian Berry AM
The Queen’s Walk
LONDON SE1 2AA
Royal Borough of Kinston upon Thames Guildhall II Kingston upon Thames Surrey KT1 1EU
07 October 2021
Dear Ms B,
Re: Cambridge Road Estate, Cambridge Road, Kingston Upon Thames KT1 3JJ, Ref 20/02942/FUL (and associated applications)
Constituents from Kingston have contacted me to raise their many concerns about this application. In particular, they highlight the following issues:
1. Areas of Deficiency of Access to Open Space and Access to Nature
The London Plan states in Policy G4 Open Space, part B: Development proposals should: 1) not result in the loss of protected open space; 2) where possible create areas of publicly accessible open space, particularly in areas of deficiency.”
According to mapping from the Greenspace Information for Greater London CIC, Cambridge Road Estate is an Area of Deficiency of Access to Open Space and Access to Nature. Residents do not consider the nearby Kingston Cemetery and Crematorium, despite being a Site of Nature Conservation Importance, as Public Open Space.
In response to the Stage 1 referral to the Mayor, the Deputy Mayor Jules Pipe considered that this application does not yet comply with the London Plan, saying
“Green infrastructure and urban greening: Given the size of the site, the proposed development represents an opportunity for further greening, particularly in complementing the adjacent SINC. The Urban Greening Factor policy target should therefore be seen as a ‘minimum’ and the applicant is encouraged to seek to deliver an exemplar greening scheme. Given that this is a hybrid application, delivery of the UGF at reserved matters should be secured by condition for subsequent phases of the proposed development.”
The current proposals for redevelopment of the Cambridge Road Estate do not meet the London Plan.
2. Public Rights of Way
Residents informed me that Cambridge Road Estate contains two kilometres of Public Rights of Ways (PROWs). These were the subject of a referral to the Ombudsman for Local Government & Social Care, which found in the complainant’s favour.2 These PROWs have now been mapped but are not being compensated for in the new scheme as there appear to be no dedicated walking routes through the estate. This loss of PROWs could lead to increased car usage as the proposed estate design does not appear to support walking in the same way as the current landscaping.
The plans for the demolition of the Cambridge Road Estate include the destruction of 61 mature trees, out of some 180 trees comprising over 30 different species. Many of the trees to be felled are over 50 years old, and the amount of CO2 they soak up and air pollution they minimise will be substantial, along with benefits they provide in flood protection.
I am also told by residents that four bat species have been recorded on Cambridge Road Estate, many of which apparently roost in the cemetery and have ‘commuting routes’ through the estate. The loss of trees and the change in estate design could prove catastrophic to these bat communities.
House Sparrows are protected by the Wildlife and Countryside Act 1981, are on the ‘Red List for Birds’ since and are one of only two urban species on the list. Again, residents tell me that there are around 30 territories of sparrows (some 60 birds) on Cambridge Road Estate, which could be permanently lost to the area.
4. Lack of Affordable homes
In the 2020 Affordable Housing Monitor, it shows that in the period 2016-20, Kingston borough had the lowest level of affordable housing completions across London of just 244. Kingston borough also had the lowest percentage of affordable starts of Social Rent/London Affordable Rent tenure of just one per cent.
Yet, the proposed tenure mix of homes for Cambridge Road Estate does not provide any uplift for the shortfall of provision over the last five years. As the Mayor’s Stage 1 response to this application says: “the provision of affordable housing represents 0.4% of the uplift of residential accommodation, by habitable rooms. Overall, this equates to 36% affordable housing by habitable room.”
Furthermore, the additional homes being provided by the demolition and rebuild comprise 100 shared equity and 1,145 for private purchase. Shared equity homes are not a formally recognised affordable housing product and this tenure mix does not meet London Plan Policy H6 Affordable Housing Tenure, which requires: “a minimum of 30 per cent low-cost rented homes, as either London Affordable Rent or Social Rent” and “a minimum of 30 per cent intermediate products which meet the definition of genuinely affordable housing, including London Living Rent and London Shared ownership”.
For all the reasons outlined above, I urge you to not approve this application, along with those applications linked to it.
Green Party Member of the London Assembly
cc: Cllr Roy Arora, Chair, Planning Committee, Kingston
Cllr Kim Baily, Vice Chair, Planning Committee, Kingston
Cllr Mark Beynon, Member, Planning Committee, Kingston
Cllr David Cunningham, Member, Planning Committee, Kingston
Cllr Lorraine Dunstone, Member, Planning Committee, Kingston
Cllr Simon Edwards, Member, Planning Committee, Kingston
Cllr Lesley Heap, Member, Planning Committee, Kingston
Cllr Malcolm Self, Member, Planning Committee, Kingston
Cllr Stephanie Archer, Member, Planning Committee, Kingston
Cllr Dave Ryder-Mills, Member, Planning Committee, Kingston
Cllr Olly Wehring, Member, Planning Committee, Kingston