Embedded Files
Objections
A Non-Viable Affordable housing proposal
The applicant admits:
“In all scenarios it is concluded that the Proposed Development is in deficit and significantly non-viable… even when the level of affordable housing is reduced to 0%.”
See below from the planning statement section Table 7.1 pg 30
This admission is critical. It confirms that the scheme:
Fails to meet basic viability thresholds, even without affordable housing
Relies on speculative market growth assumptions, not policy-compliant financial modelling
Avoids a Late-Stage Review mechanism, removing safeguards for public benefit
The applicant proposes to deliver 35% affordable housing (by habitable room), claiming compliance with the London Plan’s Fast Track Route under Policy H5 and Footnote 59, which applies to utilities infrastructure sites with substantial remediation costs.
However, the applicant also acknowledges that the scheme is not financially viable — a contradiction that undermines the credibility of the offer. If the development cannot viably support its own affordable housing provision, then:
It should not qualify for Fast Track status, which is contingent on genuine deliverability without public subsidy
It cannot be used to justify building on MOL, which requires “very special circumstances” beyond numerical housing targets
It risks future reductions in affordable housing, through post-permission viability reviews or re-negotiations
Moreover
Affordable housing need must be met through policy-compliant regeneration, not speculative encroachment on ecologically sensitive land
We urge decision-makers to:
Reject the use of speculative viability as justification for building on protected land
Uphold MOL protections, especially where the scheme fails to deliver policy-compliant affordable housing
Prioritise sustainable, viable regeneration on appropriate urban sites, not ecologically sensitive land
Failure to Meet Family Housing Targets Undermines Policy DM 13
Planning statement section 7.24
"While the proposed unit mix does not accord with the policy expectations set out in the out of-date KCS Policy DM 13, it has been demonstrated that the proposed number of 3 bedroom homes will optimise the capacity of the Site and the delivery of the scheme. This is particularly important in RBK where the delivery of market and affordable homes is so dire and where the Plan and its policies for the provision of housing are out of date. "
The applicant proposes just 10.2% of homes as 3-bedroom units, falling well short of the 30% minimum required by Kingston’s Core Strategy Policy DM 13. This also fails to meet the RBK Local Housing Needs Assessment (LHNA) recommendations of:
50% 3-bedroom homes for market sale
35% for affordable rent
20% for affordable ownership
While the applicant cites viability constraints, this admission reinforces a broader concern:
The scheme is not policy-compliant, even in its housing mix — and is technically non-viable, even at 0% affordable housing.
Key points:
Family housing is urgently needed in RBK, especially affordable 3-bedroom units
The proposed mix prioritises smaller units, which may not meet long-term community needs
Policy DM 13 remains valid, and deviation must be robustly justified — speculative viability does not suffice
Moreover:
The LHNA explicitly states that its mix should not be applied prescriptively unless deviation is justified — yet the justification here is based on a non-viable scheme
The claim that smaller units will “free up” existing family homes is unsubstantiated and speculative
The proposal’s tallest buildings (up to 52m) and MOL encroachment undermine the argument for site optimisation
We urge decision-makers to:
Reject the under-provision of family housing, especially where it contradicts local policy and evidence
Scrutinise the viability claims, which appear to drive housing mix more than genuine need
Protect MOL and uphold Policy DM 13, ensuring new development meets the full spectrum of housing needs
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