Directorate of Place
Head of Planning & Transport – Viv Evans
Development, Planning, and Regeneration
Boris Johnson, Mayor of London
Guildhall 2
(FALP)
Kingston upon Thames
GLA City Hall,
Surrey KT1 1EU
The Queen’s Walk
LONDON
Enquiries to: DPR Team
SE1 2AA
Email: xxx@xxx.xxxxxxxx.xxx.xx
Phone:
020 8547 5002
By email
10th April 2014
Consultation on: Further Alterations to the London Plan
Please find enclosed this Council’s consultation response to the proposed FALP. The
three key issues raised in this Council’s response are:
support for the Crossrail 2 Regional option, which would trigger significant growth
opportunities in Kingston Town Centre;
the opportunity for Kingston Town Centre to be identified as an Opportunity Area;
and
the serious concerns with the proposal to disperse student accommodation for
Central London institutions into areas of Outer London that are remote from the
place of study.
If you have any questions in respect of this response please contact the Council’s
Development, Planning and Regeneration team via
: xxx@xxx.xxxxxxxx.xxx.xx or 020
8547 5002.
Yours sincerely,
Councillor Simon James
Lead Member for Place, Sustainability and Sport
Encl – RBK Response to the FALP consultation
Royal Borough of Kingston
Response to the FALP consultation
FALP Proposals / RBK Response
Issues
Increase in
The Council has recently reviewed the SHLAA sites and identified
Housing Targets
three sites that for reasons set out below are no longer available for
Policy 3.3 and
residential development in the target setting period and should be
Table 3.1.
removed/re-phased in the Mayor of London‟s Strategic Housing
Land Availability Assessment. The sites and the reasons why they
will not come forward for housing are:
The proposed
1. The North Kingston Centre - the whole of the site is needed to
643pa target for
deliver a 6 FE secondary school. No scope for residential.
RBK
2. Moor Lane – the site has been identified for an „Achieving for
Children project‟ under CLG‟s „Transformation Challenge Award‟
that will provide learning facilities for children with disabilities.
There is only very limited scope for some specialist residential
ancillary to the main use.
3. Wood St – the office building has recently been the subject of a
large office occupier let (to Saipem, an oil company) on a 15
year lease. The letting significantly reduces the opportunity for
the site to come forward for residential in the short to medium
term. In the longer term the building and the block in which it is
situated (opposite Kingston Station) has significant potential for
mixed use redevelopment, which would be greatly enhanced if
the Crossrail 2 Regional option were to be confirmed as the
preferred route.
The effect of removing these sites from the SHLAA target setting
period will be to reduce RBK‟s annual delivery target by 31 (from
643pa to 612pa).
The uplift in the housing targets will have a significant impact on the
need for new and improved infrastructure provision, much of which
will have a sub-regional dimension such as healthcare. The FALP
needs to make clear that the Mayor of London will work with the
boroughs to deliver sub-regional infrastructure needs, through the
Mayor‟s London Plan Implementation Plan. Policy 3.3 and the
complementary policies should make this clear.
The Need for
We are concerned that this proposal could encourage developers to
Specialist Student disperse student accommodation for Central London institutions in
Accommodation
areas of Outer London that are remote from the place of study and
Paras 3.53A
in locations where there is already a pressing need to provide
accommodation for local institutions. It is not the case that student
A more dispersed
halls in Outer London necessarily provides more affordable
distribution of future accommodation; rents in the privately owned halls in Kingston
student
average between £250/£290pw.
accommodation
provision away
The proposal runs counter to building sustainable communities –
from Central
places where people can live and in this context study, and also
London
runs counter to the London Plan policy objective of building lifetime
neighbourhoods. Sustainable communities should not rely on the
need for students to commute long distances between place of
study and the place they live. There are already huge issues with
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Royal Borough of Kingston
Response to the FALP consultation
FALP Proposals / RBK Response
Issues
students being viewed by the wider community as a transient
population, and the FALP proposal will only serve to reinforce this
problem, and undermine community cohesion and ownership of
place.
Kingston is one of just a small number of outer London boroughs
that host a University. Approximately 21,000 students are enrolled
at Kingston University, and there is an acknowledged need for a
further 2,500 student bedspaces to accommodate first and third year
students requiring places in halls of residence. Addressing this
significant under-provision is a priority set out in the Council‟s Core
Strategy, and the Borough should not be required to also
accommodate students attending Central London institutions.
The need to address Kingston University‟s significant student
bedspace shortage is already putting severe pressure on the
Borough‟s limited land availability to meet its conventional housing
needs. There is a lot of local community concern about the
problems that emanate from the „studentification‟ of parts of the
Borough by Kingston University students, and the impact this has on
availability of housing for residents. The FALP proposal would
potentially multiply this problem undermining social cohesion.
The Plan
should be strengthened to make it clear that where need is
identified to provide student accommodation for local educational
institutions in Outer London (as in the case of Kingston), this is the
need that must be addressed and not the needs of Central London
institutions.
The Need for
The Council supports the proposal for promoters of student
Specialist Student accommodation schemes that do not have an undertaking with
Accommodation
specified academic institutions to seek to deliver “an element” of
Paras 3.53B
student accommodation that is affordable.
Proposal to seek to The FALP should clarify what is meant by both
“an element” and
deliver
“an element” indeed what is
“affordable”. „An element‟ needs to be a meaningful
of student
proportion – we suggest 50% would be reasonable, in line with
accommodation
affordable housing requirements. Affordability needs to be defined
that is affordable
.
by consensus at the Mayor‟s Academic Forum. Locally a rate of
£150/week is considered to be affordable.
Opportunity Areas The Council proposes that Kingston Town Centre should be
and Areas for
identified in the FALP as an Opportunity Area.
Intensification
Policies 2.13 and
Evidence indicates that Kingston Town Centre is capable of
para 6.18B; and
accommodating significant new job opportunities and new housing
Annex 1.
of a scale broadly comparable to that identified for Bromley Town
Centre (a centre proposed for inclusion in the FALP as an
Opportunity Area).
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Royal Borough of Kingston
Response to the FALP consultation
FALP Proposals / RBK Response
Issues
The scale of ambition set out in the Council‟s Kingston Futures
programme is evidence of the Borough‟s plans for regeneration.
The plans for Kingston Town Centre include in the region of 1,500+
new homes and up to 54,000sqm net of comparison goods retail
floorspace and up to 6,400sqm net of convenience goods floorspace
up to 20281. There is a significant complementary need for
additional leisure and commercial floorspace in Kingston Town
Centre as set out in both the FALP Table 1.1 and the Council‟s
latest Economic Analysis Study. The Study points to a Borough-
wide floorspace requirement for B1 uses of up to 101,000sqm net
that could generate as many as 6,660 B1 jobs2, a significant
proportion of which will be located in Kingston Town Centre. Thus,
the forecast is for significant jobs growth in office and the retail and
leisure service sectors.
The prospects for growth in Kingston Town Centre outlined above
are evidenced by the considerable amount of developer interest in
the town. This interest together with the recent investment in public
realm schemes such as the Ancient Market Area and the planned
£30 million Mini-Holland investment in the cycling network, and the
prospect of Crossrail 2 coming to Kingston combine to clearly
indicate that Kingston could deliver Opportunity Area levels of
growth and investment.
Crossrail 2:
The Council supports the „Regional‟ route option for Crossrail 2 that
Policy 6.4;
will deliver wider growth opportunities as well as delivering transport
Paragraph 6.18B
and accessibility improvements to a much wider part of the network
than the „Metro‟ alternative.
Sets out a strong
intent to promote
South-west London is comparatively poorly served by public
and develop
transport. Kingston town centre is over reliant on the bus, with
Crossrail 2
relatively poor train accessibility and no tube or tram connections.
The relatively poor transport position is a negative factor in business
and investor decision-making, and Kingston currently loses out to
other better connected locations such as Wimbledon and Croydon
where there has been significant private and public investment in
recent years.
The improvements to journey times (faster journeys to many central
London locations), journey frequencies (service frequency would
triple to 12 trains per hour under the Regional option) and
connectivity for Kingston town centre, but also for the Borough‟s
three other town centres, will deliver significant economic growth
potential.
Offices and hotels are particularly affected by poor accessibility, and
1 Source: RBK Town Centre Study, prepared by GVA Nov 2013
2 Source: RBK Economic Analysis Study, prepared by NLP April 2014
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Royal Borough of Kingston
Response to the FALP consultation
FALP Proposals / RBK Response
Issues
the step change in public transport provision offered by Crossrail 2
will open up significant opportunities for growth in these sectors in
Kingston town centre. However, opportunity is not only in these
sectors; there is scope for high density mixed use redevelopment
including substantial residential accommodation in the town centre,
and particularly on the eastern-side of the town centre, where there
are a number of significant potential development sites – that could
accommodate large scale redevelopment akin to the expectations
for Opportunity Areas. These sites could be unlocked by the step
change in public transport provision provided by Crossrail 2, and
help deliver the Mayor‟s jobs and housing growth ambitions.
Whilst the Council warmly welcomes the Crossrail 2 proposal we do
seek clarification that existing sub-urban frequencies (eg Waterloo to
Chessington South and Waterloo to Shepperton) will not be reduced
as a result of Crossrail 2 services
The issue of funding mechanisms for Crossrail 2 also needs to be
addressed; it would be helpful if the FALP provided clarity on how
Crossrail 2 could be funded. For example, the Mayor‟s Community
Infrastructure Levy should be used as part of the approach to
funding, in line with the approach taken to fund Crossrail 1.
However, the MCIL levy rates will need to ensure that development
is not rendered unviable in Kingston Town Centre and more
generally across the Borough. It is not appropriate or acceptable to
seek to fund Crossrail 2 through development located in Green Belt,
MoL or other landscape designations.
Housing
The Council supports this proposal.
Policy 3.8(B(a1))
RBK‟s objective, as expressed in the SW London Intermediate
Support for the
Housing Strategy, is to target intermediate housing at households
institutional private entirely excluded from the market in SW London. RBK is currently
rented sector in
looking to develop a landlord incentive to bring more rented properties
addressing housing onto the market. The private rented sector is critical in helping local
needs
authorities to provide affordable housing and reduce homelessness
and costs.
Housing
The Council objects to the proposed widening of eligibility.
Paragraphs 3.61-
3.62
Widening the eligibility of Affordable Housing/Rent to include larger
family households, with salaries up to £80,000, moves away from
Widening the
targeting assistance to where it is most needed.
eligibility of
Affordable Housing Kingston provides home ownership opportunity for Borough residents
/ Rent to include
with income levels between £19,000 and £30,035, well below the
larger family
existing upper limit, and the even higher level proposed. Some
households, with
developers may see a raised upper threshold as an opportunity to
salaries of up to
devise schemes that cater for households earning just below that
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Royal Borough of Kingston
Response to the FALP consultation
FALP Proposals / RBK Response
Issues
£80,000, up from
threshold, and cite this as a reason not to comply with local (borough
£64,300
or sub-regional) affordability criteria.
The Council therefore requests this proposed change is not taken
forward.
Town Centres
The Council welcomes support for the proactive management of town
Policy 2.15D and
centres, particularly given the structural changes in the ways retailing
Policy 4.8B
is undertaken and the impact this will increasingly have on how town
centres operate. The Council supports the Mayor‟s aim for centres
Support for
such as Kingston to consolidate their position as key shopping, leisure,
proactive
cultural and commercial destinations through planned re-development
management of
including multi-channel shopping facilities and complementary
town centres
activities.
Look for new and The Mayor‟s strategic direction accords with the Council‟s Kingston
innovative forms of Futures programme, which sets out a proactive approach to lead the
retail activity
redevelopment of Kingston Town Centre. The Kingston Futures work
that is currently on-going involves proactive engagement with local
landowners, and the preparation of briefs to guide redevelopment
within the town centre.
Kingston is well placed to attract and develop new and innovative
forms of retailing. The town centre is Metropolitan in scale, there is
considerable developer interest from national firms as well as local
developers and critically it has the knowledge and research resource
of Kingston University to call on. There is also a demonstrable need
for new Grade A office floorspace in Kingston Town Centre.
A recently prepared retail need assessment identified the principal gap
in Kingston‟s retail provision as the higher quality end of the retail
market where there is considerable unmet demand for representation
in the town. However, in addition and as set out in the FALP, retail
continues to evolve, and there will be a need to accommodate new
innovative forms of retail floorspace that will service the changing
requirements of shoppers operating in this electronic online shopping
age. Kingston, because of its profile is a prime candidate to host this
type of innovation.
Town Centres
Whilst in principle we understand and support the strategic aim of this
Policy 2.15D c2
policy shift, which is to reinforce poorly performing centres through the
replacement of under-utilised retail space with residential. However,
Proposal for
we are concerned that if applied as a blanket approach, there is a risk
diversification of
that the better performing more vibrant mid-sized centres, such as the
uses away from
successful District Centres of Surbiton, New Malden and Tolworth in
retail functions in
this Borough, could lose retail units to residential. Loss of retail units,
the mid-sized
for which there is a demand, to residential use would undermine a
centres
centre‟s attraction to shoppers and investors, and harm the centre‟s
vitality and viability and its role at the heart of the community.
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Royal Borough of Kingston
Response to the FALP consultation
FALP Proposals / RBK Response
Issues
The FALP policy change needs to be caveated to require that changes
of diversification will only be supported where there is clear evidence
that the centre is underperforming and there is clearly an over-supply
of retail floorspace.
Town Centres
The Council supports the control of clustering uses in town centres
Policy 4.8B
where these create a negative impact. The intrusion on the „high
Paragraph 2.72A
street‟ of clusters of uses such as betting shops and fast-food
takeaways can be detrimental to the wider development of the local
Proposes that
economy. For instance, in New Malden District Centre there is soon to
Council‟s should
be a sixth betting shop. When retailers are replaced by such uses, the
monitor, manage
opportunities for local entrepreneurs and other businesses to
and control clusters establish, and the overall attraction of the high street could be
of uses in town
diminished.
centres
Town Centres
The Council expresses serious concerns over the proposed
Table A2.1
downgrading of office employment prospects in Kingston Town
Centre. This is very unhelpful and does not accord with the local
Proposed
evidence that demonstrates demand for new high quality office space.
downgrading of
For example Oil company Saipem has recently taking up occupancy of
office employment 8,200 sqm of high quality town centre office space bringing 800
prospects in
employees to the town. Neither does the proposal accord with the
Kingston Town
2014 Borough Economic Analysis Study, prepared by NLP that like the
Centre from a
FALP points to significant growth prospects. This need for new high
category “A/B”
quality office space has been compounded by the considerable loss of
rating to category office space to residential across the Borough under the recent
“B”.
changes to permitted development rights. There is evidence that the
lack of high grade office space in Kingston Town Centre is not only a
bar to new entrants, it is also forcing some established businesses
displaced by change of use to residential to move out of Kingston.
Critically in terms of strategic policy the downgrading sends the wrong
signal in the context of the transformational prospects that will be
delivered through the prospect of Crossrail 2, and the Council‟s
proactive Kingston Futures delivery strategy. Such a downgrading is
contrary to the evidence, and will only serve to undermine the potential
of these strategic initiatives and the future growth prospects of
Kingston Town Centre.
The Council therefore requests this proposed change is not taken
forward.
The Economy
The Council welcomes the undertaking from the Mayor to monitor the
Policy 2.15C
impact of the relaxation of permitted development rights - from office to
Policy 4.2(A(e)) and residential (use class B1 to C3). This Council‟s experience is that
Paragraph 4.13A
whilst the change is delivering housing units, the quality of that
housing is substandard, and because of the lack of planning control
Proposes that the and lack of infrastructure contributions the change is creating poor
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Royal Borough of Kingston
Response to the FALP consultation
FALP Proposals / RBK Response
Issues
Mayor will monitor quality places.
the impact of the
Government
The Council requests that the Mayor also closely monitors the soon to
relaxation of
be introduced A1/2 to C3 permitted change. In this Council‟s view the
permitted
Government‟s relaxation of the rules runs counter to building
development rights sustainable communities – places where people can live, work and
shop, and counter to the London Plan policy objective to build lifetime
neighbourhoods.
The Council urges the Mayor to take a strong and robust position in
seeking to limit the relaxation to the current three year period with no
extended period.
The Economy
The Council supports the employment forecasts as set out in Table
Table 1.1
1.1. The Borough‟s very recent Economic Analysis report identifies
that employment growth in the Borough averaged 14% over the past
Employment growth 16 years with the main focus of job growth in the administration and
in Kingston forecast support, retail, education and professional services sectors. The
to rise from 78,000 report, prepared by NLP forecasts that these sectors will continue to
in 2011 to 91,000 in expand over the next 15/20 years, and additionally significant growth
2036, providing
is also forecast in the creative industries sector.
13,000 additional
jobs.
There is significant potential to expand the creative industries sector
(arts, performance, design, film, culture & leisure, software and
technology/media) in Kingston, particularly given the activity at
Kingston University and Kingston College. Creative industry
businesses initially require a minimal footprint with room to grow as
they become successful, scale up to „production‟ and add staff. These
industries develop fast and have the potential to increase economic
growth, employment and attract other complimentary supply
businesses into an orbit around them.
Kingston is well placed to expand its creative industries sector, which
will help diversify the Borough‟s employment base, and making the
Borough less reliant on retail, public sector and education employment
opportunities. The Council are keen to pursue an „Innovation and
Growth Hub‟ in one of the Kingston redevelopment opportunity areas.
Whilst the majority of future employment floorspace demand is likely to
be for small, inexpensive work spaces or work units, there will
continue to be demand for/from larger employers to locate sizeable
workforces in single buildings in the Borough. Oil company Saipem
have recently relocated to the Kingston Town Centre bringing 800
office-based employees, and there have been other such enquiries
from companies looking to accommodate hundreds of staff centrally
on one site with all the ancillary facilities - staff restaurant, fitness
facility and car park etc. Additionally, the NLP report highlights a need
for more mixed use/affordable workspace for business start ups and
small & medium sized enterprises. The local Chamber of Commerce
has also identified this opportunity.
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Royal Borough of Kingston
Response to the FALP consultation
FALP Proposals / RBK Response
Issues
The Economy
The Council supports this change.
Policy 4.10 and
The opportunity for growth from start-up units to larger space as
Paragraph 4.53
growth comes (with a long-term financial commitment) is important
in developing local businesses from micro start-ups to small/medium
Support for the
sized companies with resulting bigger employment opportunities and
promotion of start-
would be good for furthering broad-scale economic development.
up, co-working and
grow-on space.
There is already a comparable policy in place in the London Plan in
respect of another key affordability issue - small shop units – that
encourages Councils to work with developers to provide affordable
small shop units suitable for new start up retailers. This proposal to
assist start-up business space will compliment the affordable shops
policy and is supported.
There is an emerging proposal within the South London Partnership
to consider the creation of a south London Innovation Centre,
designed to promote spin-out and commercialisation through
targeted incubation, such as expert support, partnership
development or availability of appropriate space. Kingston Council is
leading on this work and will keep the GLA informed of progress.
The Economy
The Council welcomes this proposal because it will go some way
Paragraph 2.36
towards „levelling the playing field‟ with office locations in neighbouring
Surrey Districts, where parking standards are much more relaxed. A
A more flexible
more flexible approach to town centre parking in outer London would
approach to the
remove a major disincentive to office development in areas of the
provision of office Borough where public transport is comparatively poor.
parking standards
in neighbourhoods
with low public
transport
accessibility levels
Climate Change
The Council welcomes the support for the pursuit of low carbon
Policy 5.4A
decentralised low carbon energy opportunities, and points out that
these measures will contribute to improving security and efficient use
New policy on
of energy (in turn reducing CO2 emissions) via demand side
strategic
management and low carbon decentralised low carbon energy
investment in
generation. Developers working with the energy providers will be
power
accountable for future investment in the energy infrastructure to
service new development, and this change should be a powerful driver
towards greater energy efficiency in buildings thus reducing overall
demand.
Climate Change
The Council supports the encouragement for boroughs to allocate
Policy 5.4A
suitable sites for low carbon heat generating infrastructure.
Where land is
This Borough has recently prepared a Decentralised Heat Network
required for energy masterplan that indicated potential for a viable heat network based on
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Royal Borough of Kingston
Response to the FALP consultation
FALP Proposals / RBK Response
Issues
infrastructure,
key commercial, civic and educational heat receptors. The work is
boroughs should
currently progressing to the feasibility stage where the opportunities
allocate suitable
for energy station(s), pipe networks and heat receptors will be
sites
explored in more depth.
Climate Change
The Council welcomes the new more realistic targets for the
Table 5.3
management of municipal solid waste arisings, and commercial and
industrial waste arisings.
New borough-level
waste management
targets
Sustainable
The Council enthusiastically supports the Cycling mini-Hollands
Transport
initiative, and the changes to the cycling policy that are positive for
Policy 6.9; and
Kingston. This includes the implementation of a network of cycle
paragraph 6.45
routes that are safe, convenient and attractive to users. The changes
reflect this Council‟s ongoing work with TfL to deliver various
Promotes cycling
infrastructure projects to encourage cycling and improve associated
mini-Hollands
safety. Indeed this Council has been successful in a bid to the Mayor
for mini-Holland funding with the aim of transforming cycling in the
Borough through substantial investment concentrated in specific
areas. The Council would also consider supporting well designed
extensions to existing Cycle Superhighways (routes 7 and 8) linking
with the Borough.
The Council is committed to delivering a step change in cycling
provision in support of the growing number of cyclists in the area. This
Borough is making good progress towards meeting the Mayor‟s aim to
increase the cycling mode share to 5% across London (Kingston‟s
share is now almost 3%, the third best performing outer London
borough). The securing of additional cycling infrastructure is a matter
of priority to ensure targets are met.
Public Houses
The Council supports the recognition of the important role played by
Policy 4.8; and
public houses in the social fabric of communities. Where there is
paragraph 4.48A
evidence of need, community asset value and viability of pub use the
Council would support the retention and enhancement of public
Encouragement to houses.
prevent the loss of
“valued community The proposed reinforcement of policy in the London Plan compliments
assets (specifically Policy DM24 in the Council‟s Core Strategy.
pubs) where
justified by robust
evidence”
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