Chessington Golf Course 25/02953/OUT

 
 
                                                             One of two ponds Chessington G.C. 2018

A planning application has been lodged to develop the former Chessington Golf Club site with 256 units between 2.5 and 4 stories high on 11.6 Ha of land. Objections need to be lodged before 9.2.26.

Paragraph 2.1 of the Design and Access Statement, describes the site as a “poorly performing Green Belt site”, on the basis that it is enclosed on three sides by development. Enclosure by development does not, in itself, indicate poor Green Belt performance. Under the NPPF (2024), the assessment turns on how land performs against the five Green Belt purposes, particularly openness, prevention of sprawl, and safeguarding the countryside from encroachment. Sites at settlement edges commonly perform these functions precisely because they form a defensible boundary.

                                      Photo showing trees in landscape to be lost (2018).

 
Ecological and landscape value The site contains:

  • Veteran and mature trees, which make a strong contribution to landscape character and openness. 37 will be felled within the application. This is not in line with the councils policy on Climate Action.

    The proposal would result in  irreversible harm to retained trees, including a veteran oak (T1), through encroachment into Root Protection Areas (RPAs), intensified access arrangements, and reliance on mitigation measures that are demonstrably unworkable in practice.

    The removal of buildings, creation of new footpaths, and continued road use would all take place within, or immediately adjacent to, the RPAs of trees identified for retention. These impacts are not incidental: they represent repeated incursions into critical rooting zones.

    Of particular concern is veteran oak T1, where the proposed access road directly conflicts with the tree’s RPA. This level of pressure on the rooting environment will not necessarily result in immediate failure, but is highly likely to lead to progressive decline and eventual loss, which is entirely predictable and avoidable.

    Veteran trees are especially sensitive to:

    • soil compaction,

    • changes in drainage,

    • root severance, and

    • prolonged disturbance.

    The proposal therefore fails to demonstrate that T1 can realistically be retained in the long term.

    The removal of 37 trees represents a significant loss of:

    • canopy cover,

    • stored carbon, and

    • ecosystem services.

    This loss is not aligned with the Council’s own climate and biodiversity policies, which seek to retain mature trees wherever possible and recognise their role in carbon sequestration. Replacement planting cannot replicate these benefits within any meaningful timescale.The application relies heavily on mitigation measures such as Heras fencing and RPA protection, yet there is substantial evidence that these measures are routinely ineffective in practice.

    Kingston Council’s own development at the Cambridge Road Estate has failed to consistently implement such protections. Harris/Heras fencing has frequently not been maintained, and retained trees’ RPAs have been:

    • driven over by site plant,

    • used for storage, and

    • subject to repeated compaction.

    These failures have been extensively photographed and documented. Against this background, it is not credible to suggest that the same mitigation measures will be successfully enforced on this site over a prolonged construction period involving heavy machinery and access routes. As a result, the claimed mitigation cannot be relied upon to prevent harm.

    Paragraph 5.33 of the Arboricultural Report refers to pruning works. Experience shows that this is often where mature and veteran trees are irreversibly damaged, particularly where pruning is undertaken asymmetrically to accommodate development.

    Such works commonly result in:

    • loss of natural form,

    • structural imbalance,

    • increased susceptibility to decay, and

    • long-term decline.

    Pruning undertaken to enable development, rather than for arboricultural reasons, should be regarded as harm, not mitigation.

    Taken together, the proposal:

    • conflicts with BS5837 principles,

    • places unacceptable pressure on RPAs,

    • threatens the long-term survival of a veteran oak,

    • removes a substantial number of trees with associated carbon loss, and

    • relies on mitigation measures that have repeatedly failed elsewhere within the borough.

  • Hedgerows identified in the archaeological report as falling within the Hedgerows Regulations, confirming their historic and landscape importance.There is also a Drovers route or Drove Road at the end of Green Lane along the Bonesgate stream see previous post  Drovers routes in Kingston

  • Two ponds, forming part of a wider ecological network (the ponds at Horton C.P. contain GCN's)

  • An adjoining Site of Importance for Nature Conservation (SINC), demonstrating the site’s role in the wider Green Belt and ecological corridor. The SINC extends on two sides of their boundary, as it includes the hedge along the eastern boundary. The impact on these and features of International Importance have not been recognised such asHorton C.P. and the Epsom and Ashtead Commons SAC Special Area of Conservation (termed a SSSI) designated a National Nature Reserve in 1995. It hosts: 2300 Oak pollards; veteran trees; and rare fungi. There is also Roman archaeology including a Roman tile kiln.

  • Protected species, including:

    • Two species of reptiles and toads recorded during surveys (a 'good population of Viv. lizard);

    • Brown hairstreak eggs identified in blackthorn;

    • Nesting birds and associated habitats.

      The reason why GiGl didn't return any Badger records (Environmental Impact Assessment)  is because this is close to the borough boundary and they are the London Biological Records Centre.

      The application site lies close to the Surrey boundary and within the known roaming range of a large and established badger population associated with Horton. Badgers are frequently encountered along Green Lane by local residents, and there is well-documented regular activity in the area, including animals that are habituated to human presence. Some residents in nearby flats actively feed badgers, indicating sustained and repeated use of this landscape for foraging and movement.

      Given the size of badger territories and their use of established routes, it is likely that the Chessington Golf Course forms part of a wider cross-boundary habitat network rather than an isolated site. It is therefore unclear whether the submitted ecological information adequately reflects the true extent of badger activity, particularly in relation to commuting corridors, outlier setts, and disturbance arising from construction and increased human activity.

These features are characteristic of functioning countryside and high-value Green Belt land, not degraded or low-performing sites.

The Design and Access Statement appears to downplay the value of approximately five hectares of existing grassland, terming it 'heavily modified', in order to present the proposed restoration of approximately two hectares as ecological compensation. The grassland has a different character across the site and has numerous forbs. I would characterise some of this as at least 'Other Neutral Grassland', ONG and not 'heavily modified'. The UKHab system calls ‘modified grassland’; often a monoculture of perennial rye-grass and white clover. In botanical terms, ONG represents a halfway house between the very good and the poor. The photograph shows a dominance of wild carrot despite the photo being taken in the winter (January).

                         Wild-carrot dominates the grassland in places, attractive to a wide range of pollinating insects

Existing semi-natural or ONG grassland within the Green Belt contributes to openness, ecological function and landscape continuity. Its value cannot be dismissed simply because it does not fit the proposed development narrative. The loss of established habitats cannot be offset by a smaller area of newly created or restored grassland, particularly where that habitat is fragmented and constrained by built form. The value of the grassland in performing eco system services will be greatly diminished

Invasive species as a red herring:

Reference to Crassula helmsii is also given disproportionate weight. The presence of invasive species does not equate to poor Green Belt performance or low ecological value. As demonstrated in nationally significant landscapes, including the Royal Parks, such species can and are managed without undermining the fundamental function or importance of the land. The ponds function well for amphibians.


Taken as a whole, the evidence demonstrates that the site:

  • Retains openness and countryside character

  • Performs a clear settlement-edge and containment role

  • Supports protected species and priority habitats

  • Contributes positively to the Green Belt’s ecological and landscape functions

The assertion that the site is “poorly performing Green Belt” is therefore unsupported, selectively argued, and contrary to both the evidence base and the intent of the NPPF (2024). On any reasonable assessment, the site does not meet the definition of Grey Belt and should continue to benefit from full Green Belt protection.

There are now relatively new Council Policies on Climate Action and Biodiversity Action: 

The council has a Climate Action and Emissions summary. Within this Theme 3 (species and natural environment). Species and Habitat Action Plan groups were established alongside the Biodiversity Action Plan launched in September 2023. 

The council will continue to use available policy and planning instruments to reinforce protection for natural assets across the borough. This includes identifying priority opportunities for nature recovery, as well as locations suitable for future habitat enhancement, creation, and restoration.

Natural Carbon Capture and Storage

Interventions will be delivered to increase carbon removal and long-term storage through natural assets such as soils, woodlands, wetlands, and grasslands. The carbon dioxide impact of these interventions will be measured to demonstrate their contribution to emissions reduction and climate resilience.

Above all, the application fails to quantify or meaningfully assess impacts on sensitive areas beyond the red line boundary, including:

  • Green Lane, which functions as an important wildlife movement corridor;

  • the Bonegate Stream, a sensitive riparian habitat; and

  • Horton Country Park, which forms part of a wider network of semi-natural and natural green space.

These areas are ecologically connected to the application site and cannot be considered in isolation. The submitted ecological information does not adequately assess functional connectivity, nor does it address the likely increase in pressure on these habitats arising from the scale of residential development proposed.

The proposal will introduce a substantial number of new residents, with a corresponding increase in:

  • domestic cats,

  • dogs, and

  • general recreational pressure.

The impacts of domestic pets on wildlife — including predation, disturbance, and displacement — are well documented and predictable. Yet the application provides no quantification or mitigation for these effects, particularly in relation to:

  • ground-nesting birds,

  • small mammals,

  • amphibians, and

  • species reliant on linear corridors such as hedgerows and watercourses.

In an already constrained landscape, this additional pressure will significantly reduce the capacity of the site and its surroundings to support wildlife, effectively leaving no functional refuge for species currently present.

The development lies close to administrative boundaries, and its ecological impacts will extend into neighbouring areas. The absence of a robust cumulative impact assessment — taking account of:

  • increased access via Green Lane,

  • pressure on the Bonegate Stream corridor, and

  • displacement of wildlife into Horton Country Park —

represents a serious omission. Without such an assessment, the Council cannot be confident that the proposal complies with national and local biodiversity policy.By failing to quantify impacts on connected sensitive areas and by ignoring predictable post-occupation pressures from domestic animals and recreational use, the application significantly underestimates its ecological footprint. The resulting harm would not be confined to the application site, but would be felt across the surrounding landscape, undermining biodiversity and ecological resilience

Grey Belt
The NPPF (2024) introduced the concept of Grey Belt, representing a generational change in the application of policies relating to the Green Belt. As per the NPPF definition, Grey Belt is defined as “land in the Green Belt comprising previously developed land and/or any other land that, in either case, does not strongly contribute to any of purposes (a), (b), or (d) in paragraph 143. (see Golden Rules) Hook Park Chessington
 
Since this change endless polemic has been written about Grey Belt policy' it is not a blanket release mechanism and it has become very politicised.

 The NPPF 2024 does not say:

  • All edge-of-settlement land is Grey Belt

  • All constrained sites should be released

  • Housing need alone justifies Green Belt loss

    Across appeal decisions, Inspectors have repeatedly confirmed that:

Golf courses are not “previously developed land” and are generally open, countryside uses that are compatible with Green Belt purposes.

  • This remains true even where:

  • There are clubhouses, car parks, maintenance buildings

  • Parts of the course are landscaped or engineered

  • Public access is limited

So the baseline is: Golf courses normally perform well as Green Belt land

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