Author: Caroline Shah-Scott

PETITION: Call to properly scrutinise provision of transport in light of massive development forecast

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Canbury Ward campaigner, Caroline Shah Scott, is calling for Kingston Council to properly scrutinise plans for the provision of local transport infrastructure to support the massive development forecast across the Borough from now until 2041.

This could see the development of more than 46,000 new homes and building for at least 43,000 new jobs across KIngston Town, Norbiton and New Malden, around Surbiton station and down to the Hogsmill Valley, Chessington, Tolworth and south of the A3.

The call for scrutiny comes as the Council has failed its manifesto commitment to ‘robustly challenge’ these shocking targets in the new London Plan.

It does not come clean in its Local Implementation Plan about the extent of future development, the negative effect it will have on our existing neighbourhoods or the fact that the vast majority of development is due to happen without CrossRail 2.

Caroline said: “Liberal Democrats have broken their promise to ‘robustly challenge’ the London Plan, and are moving forward with unsound plans. It is now up to us, as local residents, to make sure what happens in Kingston is in the interests of the residents who have chosen the Borough as their home and is not pushed through in hidden and confused agendas.

“Kingston’s Local Implementation Plan is full of assertions and claims which are based upon undisclosed housing and development targets which constitute gross overdevelopment for our Borough. We must act now to bring these plans back to a scrutiny panel for proper investigation.”

Join Caroline’s call for the Council to scrutinise these plans by signing below:

CALL IN: Local Implementation Plan

  

Call in of Decision Two (Part 2) on 12 February 2019 by The Environment and Sustainable Transport Committee of Kingston Council to approve the 3rd Local Implementation Plan (the “LIP”) for the Borough.

The Greater London Authority Act 1999 (The GLA Act) requires each borough to prepare a LIP containing its proposals for the implementation of the Mayor’s Transport Strategy in its area.

We, the undersigned, call in the decision to approve the Borough’s LIP for the following reasons:

The LIP breaches Requirements laid out in TfL guidance on how to prepare LIPS https://tfl.gov.uk/info-for/boroughs/local-implementation-plans and more specifically in http://content.tfl.gov.uk/third-lips-guidance-2018.pdf – Guidance for Borough Officers on Developing the 3rd LIP, March 2018. The following Requirements of the latter guidance are breached:

R3 – Statutory Consultation. There is no evidence that all the consultees listed were actually consulted or demonstration that all consultees views were taken in to account in the final LIP. Specifically, there is no evidence that eight residents’ associations were consulted. Additionally, it is not democratic to choose 8 residents’ associations as representative of residents’ views across the Borough. It also is not correct not to seek the opinion of representative organisations such as the North Kingston Forum and associations that represent large numbers of residents. No evidence has been made available about which associations were consulted and the outcome of such consultation. The requirement to consult with stakeholders registered on the Local Plan consultee database also appears to have been breached.

R5 – Strategic Environment Assessment (SEA). There is no evidence that an up-to-date SEA has been completed. No such SEA is available on the Council’s website.

R7: Local Context – the LIP does not give detail of “other characteristics of the Borough”, which it could easily have done using the Borough Character Study. The local context demographic information does not include coherent, full, accurate or up-to-date information on the Borough, of recent population changes as development has happened and of how these are affecting the local context. There is no detailed and up-to-date information on forecast increases in population and the changes that such growth will bring to the predominant characteristics of different areas of the Borough. Under Employment, the requirement for the Borough to provide for an additional 30,000 jobs on top of the 2016 London Plan expectation of 13,000 jobs (Kingston Transport Forecasting Report 2018) is not mentioned. No reference is made in this section to the Direction of Travel growth strategy approved by the Council in 2016 and no explanation is given of its implications for the Borough. No meaningful reference is made, detail or explanation given of the planned “nascent Opportunity Area” for Kingston.

R11: The LIP fails to set locally-specific objectives for the 9 outcomes of the Mayor’s Transport Strategy, namely Outcomes 3,8 and 9. Objectives for some of the other outcomes are vague, for example, 5.1 Kingston “supports” CrossRail2 and subsequently, many are not specific, measurable, achievable, relevant and time-orientated .

R12: The LIP does not reflect directly, specifically, accurately, clearly and consistently how other Mayoral strategies, such as the Mayoral strategy on Housing (summer 2018) and the forthcoming draft new London Plan (late 2019), that has set clear and massive development targets for Kingston in terms of new housing and the provision of jobs, will affect the Borough.

R13 and R16: the LIP does not list CrossRail 2 as a project that will help contribute to the delivery of the Mayor’s Transport Strategy out to 2041.

The draft LIP is currently not available for residents or other stakeholders to see on the Council’s website
The Mayor’s Transport Strategy does not mention a Kingston Opportunity Area. It is therefore incorrect and misleading for the LIP to include mention of an Opportunity Area in Kingston in point 2.4 and in the map on page B40.

Forecast household, population and employment growth figures in the LIP are not consistent, comprehensive or accurate with latest available data. No coherent picture is given of Kingston’s recommended growth targets. Figure 3 is unclear and not explained. Points 2.14 to 2.18 give historical transport trend information and do not use data from the Kingston Transport Forecasting Report 2018 on predicted growth and the effect on transport requirements. Figures given to the Mayor’s office in a bid for mini-Holland monies and the impact of what has been built and what has been planned to be built have also been omitted.

Misleading statements are made about CrossRail 2 (CR2) in points 2.24 and 2.81 which link CR2 explicitly and positively to the Borough’s ability to meet its housing targets, when Kingston’s core housing and employment growth figures are not dependent on the arrival of that infrastructure project. The misleading statement in 2.81 fails to inform people that the majority of the 20,000 extra housing units that must be built when construction of CR2 starts will be in Kingston. In addition, CrossRail 2 does not show up in any conveyancer infrastructure searches for people purchasing property in Kingston.

The council’s Sustainable Transport SPD (STS) dates from May 2013. There is no evidence of an up to date STS for the Borough and no up-to-date STS is available to view on council website despite reference to it in Appendix C of the Council’s LIP which links the Mayor’s Transport Strategy’s nine key outcomes to the STS.

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PETITION: Demand better on development in Kingston

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Canbury Ward Campaigner, Caroline Shah, has launched a resident petition asking for the Scrutiny Panel to re-evaluate the decision to put out an ‘Issues and Options’ document to consultation, to form the new Local Plan.

The Council propose building over 30,000 new homes in the borough between 2019 and 2041, without providing information on where these homes will be built, with the misleading assumption that a Borough wide Opportunity Area is a foregone conclusion, and without consultation on whether residents agree with this target. This figure is also nearly three times the number of homes needed even for the huge increase in population that the Council is planning

Caroline said: “Many of the questions the Council are asking residents are based on limited and closed or biased information, often focus on meaningless detail, and are biased in issues and content towards jobs and business, overlooking key issues such as CrossRail 2.

She added: “Furthermore, it is unacceptable that the decision to put this incomplete document out to consultation, given the scale and type of growth envisaged, was the penultimate item on a long agenda, with the meeting, and discussion on this decision, being brought to a premature close after nearly five hours. One councillor even abstained because they didn’t feel able to make a reasoned decision past midnight.

“We need your support to take this decision to the Scrutiny Panel, to ensure decision making in Kingston is sound and based on the facts. We demand better for residents on the issue of growth and development in Kingston.”

Sign the petition below:

Call-in of Issues and Options for the Local Plan decision

  

We, the undersigned, hereby call in the decision number 3 of the Strategic Housing and Planning Committee of Kingston Council on Thursday 8 November 2018, Issues and Options for the Local Plan, for the following reasons:

- “The Opportunity Area” referred to on page 6 of the document does not exist
- The Council appears to have agreed with the GLA behind closed doors to merge the creation of a Local Plan with the creation of an Opportunity Area Planning Framework. The nature of the growth strategy that Kingston council is pursuing with the GLA is not made clear in this document
- The possible creation of an Opportunity Area(s) should be conducted as a separate process and residents should be consulted as part of this process. The council’s approach will mean that residents will be deprived of their democratic and statutory right to be consulted on the possible creation of Opportunity Areas in the borough. The council will also fail the requirement to be transparent and to consult fully with residents
- The Direction of Travel referred to on page 7, note 7 did not establish any Opportunity Area(s) or confirm agreement for large scale development in any area of the Borough
- The Direction of Travel is unsound and should be discarded – see Appendix One (http://kingstonindependents.org.uk/wp-content/uploads/2018/11/Appendix-One-Call-In-Why-the-Direction-of-Travel-is-unsound.docx) for the reasons supporting this assertion
- The Council gives a figure for growth of new homes in the Borough, taken from the draft London Plan, of 30,008 between 2019 and 2041. The council should ask residents if they believe this target is correct for the Borough and challenge the figure if people believe it is too high
- The figures given do not make sense and need further clarification. Planned population growth is 23,000 people from 2019 to 2041, yet, in the same period, the council intends to build 30,008 new homes. Assuming two people per household, this number of homes would accommodate 60,016 people. The council should provide information that explains why it wants to build nearly treble the number of homes that it needs
- The information presented on sites is unclear, lacks meaningful detail and does not provide a reasonable and clear context for informed consideration by residents to take place. The basis on which the sites came forward is also not explained. It is unclear why these specific sites are being presented, how they compare in size and location with other sites that remain confidential, and no information is presented on which have a viable possibility of development. The exact location of sites is not explained
- The questions that the Council proposes to ask are inadequate, often unclear or based on limited and closed or biased information, often focus on meaningless detail, and are biased in number and content towards business and jobs, overlooking key issues such as CrossRail2 – see Appendix Two (http://kingstonindependents.org.uk/wp-content/uploads/2018/11/Appendix-Two-Call-in-Issues-and-Options-Questions.docx)
- This item was the penultimate item on a long agenda. It is unacceptable that discussion about a document about growth on the scale and type being envisaged should happen between 10.35pm and 00.12 and at the end of a meeting that lasted 4 hours 37 minutes in total
- No councillor was in a position to make an informed and intelligent decision at this time of night. One councillor even felt unable to make such a decision because of the late hour and abstained from the vote. Councillor Sharon Young, at 4.32.40, said: “I feel that its getting so late that I know myself I can not contribute anything meaningful at this moment in time”. She also requested that the meeting was “wrapped up” soon which the Chair person promptly did
- The document and proposed consultation makes no attempt to identify the key issues that residents may have about growth in the Borough
- An Issues and Options document is meant to help the council identify the “issues” that exist in the Borough in the context of putting together a new Local Plan so that it can use this information to put together viable and acceptable options to put to residents. Instead, this document presents two basic options and asks residents to choose between them. In addition, only one option presented would bear the growth planned by the Council. This gives a clear impression that the council’s plans have been predetermined
- On the GLA’s website, dated 28/1/16, in the meeting notes of the Opportunity Area Growth Board, it is stated that “we need to do a with and without scenario because of Crossrail”. This document fails not only to present a with and without scenario, it fails to discuss CrossRail2 in any detail whatsoever
- The document presented to Committee was so vague and incomplete and uninformative and confusing that it should not have been approved in its current form. The final consultation draft, with what will doubtless be major changes, should come back to the Strategic Planning and Housing Committee for approval before going out for consultation

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Caroline has produced two supplementary documents regarding this call-in, which can be found below:

Appendix One – Call-In Why the Direction of Travel is unsound

Appendix Two – Call-in, Issues and Options QuestionsT