Height and Massing

Objections

We object to the Proposed Development on the grounds that its height and massing are excessive, visually intrusive, and misrepresented in the planning documents — undermining transparency and public trust.

Misleading Visual Presentation

The applicant’s Verified Views and visual materials appear deliberately framed to obscure the true impact of the development:

• Key viewpoints are obstructed by trees, bushes, or wide-angle distortion, making the towers appear smaller or hidden.

• Images are taken from distant or low-visibility angles, failing to reflect how the buildings will dominate the skyline from everyday vantage points.

• It is implausible that five blocks of up to 16 storeys will not be visible from surrounding streets and homes, as the visuals suggest.

This selective framing misleads decision-makers and the public, violating the spirit of transparency required in major planning applications.

Seasonal Manipulation of Views

The applicant has conveniently used summer-time imagery, when trees are in full leaf, to mask the true visual impact of the towers. This tactic significantly underrepresents the development’s visibility:

• In winter, deciduous trees lose their foliage, exposing clear sightlines to the proposed buildings.

• Residents and schoolchildren will face a drastically altered view, especially from Green Lane Primary and Nursery School, Kingshill Avenue, and Marina Avenue.

• The seasonal choice of imagery distorts public perception, presenting a softened version of what will be a stark, year-round visual intrusion.

This manipulation undermines the credibility of the Verified Views and violates the principle of honest representation in planning submissions.

Excessive Scale and Visual Intrusion

The proposed buildings far exceed the scale of surrounding structures and will:

• Overwhelm the low-rise character of Motspur Park, which is predominantly 2–3 storeys

• Disrupt views from sensitive locations, including allotments near Kingshill Avenue and residential areas near Marina Avenue

• Overshadow Green Lane Primary and Nursery School, with emergency exits and play areas directly adjacent to the site

Side-by-side comparisons with the existing gas holder show that the new blocks will tower above current structures, This represents a dramatic increase in vertical scale, with no meaningful transition or mitigation.

 Planning Policy Context

The London Plan and local planning guidance require that new developments:

• Respect the scale, massing, and character of their surroundings

• Avoid visual dominance or townscape disruption

• Provide accurate and honest visual representations to inform decision-making

This proposal fails on all counts. The misleading visuals and excessive massing undermine the integrity of the planning process and risk irreversible harm to the area’s character.

We respectfully request Kingston Council to;

• Reject the proposal on the grounds of excessive height and massing

• Require accurate, transparent visual materials that reflect real-world impact

• Require seasonally balanced, transparent visual materials 

• Protect the low-rise character and visual amenity of Motspur Park

Flawed Visual Impact Assessment – Misleading Baseline and Overstated Benefits 

The Townscape and Visual Impact Assessment (TVIA), including the alternative future baseline scenario, is flawed, selectively framed, and fails to meet the standards required under London Plan Policy D9 and national guidance. 

Misleading Use of Alternative Baseline

• The assessment assumes that the removal of the gasholders would not alter the visual amenity value of the site, yet simultaneously claims that the proposed development would be “beneficial” when seen against an unobstructed sky.

• This contradiction undermines the credibility of the VIA. If the gasholders are removed, the site becomes open land—offering an opportunity to restore openness and character, not justify high-rise massing.

Overstated Benefits and Subjective Judgement

• The TVIA claims “Major Beneficial” effects for users of Sir Joseph Hood Memorial Playing Fields, Motspur Park sports ground, and commuters, based on “high quality architecture” and “improved landscape treatment.” yet these are subjective assertions not validated by independent review or community feedback .

• These are subjective assertions not supported by independent public consultation or verified visual receptor analysis.

• The assessment fails to account for the psychological and social impact of introducing five tall buildings into a low-rise suburban context.

• The AVR images show significant massing and skyline disruption, particularly from residential viewpoints near Marina Avenue and Kingshill Avenue, yet these are interpreted as “beneficial” without acknowledging the loss of openness, privacy, and visual continuity. 

see below from Townscape_and_Visual_Impact_Assessment_Part2 - pg 85

Limited Receptor Sensitivity Analysis

• The sensitivity of residents and amenity users is downplayed throughout the assessment. For example, residents are assigned “Low-Medium” sensitivity despite being directly adjacent to the site and facing permanent skyline transformation.

• The claim that “susceptibility does not change” post-demolition ignores the fact that removal of the gasholders increases the expectation of openness and visual relief—not intensified development.

• The TVIA does not adequately assess the impact on visual receptors from Kingshill Avenue, Marina Avenue, and other residential streets directly bordering the site. 

Strategic View Impact Minimised

• The site falls within two “Very Highly Important Views” (VHIV2 Hampton Court Palace and VHIV6 Bushy Park).

• The VIA claims these views are unaffected due to distance and vegetation, yet fails to provide verified images or cumulative skyline analysis to support this conclusion.

Lack of Community Validation

• The assessment relies on professional judgement and developer led analysis - without incorporating community feedback or independent review.

• Residents have consistently raised concerns about height, massing, and visual intrusion—concerns that are not reflected in the TVIA’s conclusions

The Visual Impact Assessment is incomplete, inconsistent, and fails to provide a robust, policy-compliant evaluation of the proposed development’s impact. The use of an “alternative future baseline” without the gasholders, has been used to overstate the benefits of the proposed tall buildings and obscure their true impact on local character and amenity.