Objections
We object to the Proposed Development’s parking strategy on the grounds of the risk of over spill onto surrounding residential roads and relying on speculative behavioural assumptions rather than robust evidence.
Inadequate Parking Provision
The Proposed Development’s residential parking provision, which includes only 89 spaces — equating to a parking ratio of 0.15 spaces per dwelling. This falls significantly below the expected standards set out in Policy T6.1 of the London Plan, which allows for up to 1.5 spaces per unit in Outer London locations with low public transport accessibility (PTAL 0–1).
This shortfall raises serious concerns about:
Overspill parking into surrounding residential streets, increasing congestion and reducing safety.
Accessibility impacts for residents with mobility needs, families, and older people who rely on private vehicles.
Strain on local infrastructure, especially in areas with limited public transport options and no clear mitigation strategy.
The proposed ratio is not only non-compliant with planning policy, but also disregards the lived realities of Motspur Park residents, many of whom depend on cars due to poor transport connectivity. We urge decision-makers to reject the proposal and demand a revision that reflects both policy and community needs.
Developer’s Own CPZ Survey Confirms Anticipated Parking Over spill
Before submitting the application, the developer commissioned a Controlled Parking Zone (CPZ) survey in the adjoining streets. This is a clear admission that over spill parking was anticipated and required investigation. If the developer truly believed that residents would not park beyond 250m or that the proposed provision was sufficient, such a survey would have been unnecessary.
This undermines the credibility of their claim that:
Residents are unlikely to park off-site due to distance or inconvenience
Overspill is “not anticipated” due to behavioural assumptions
Car club spaces and low parking ratios will fully mitigate demand
Instead, the CPZ survey confirms that:
Overspill risk was real and foreseeable
Surrounding streets were considered vulnerable to increased parking pressure
The development’s transport strategy is reactive and speculative, not preventative or evidence-led
We urge decision-makers to treat the CPZ survey as material evidence that the developer expects parking displacement. This reinforces the need for a revised, accountable parking strategy that protects surrounding streets, residents, and road safety.
Misleading Assumptions About Over spill Risk
The developer claims that over spill will be “precluded” because the nearest local road is more than 250m away, citing the Lambeth Methodology for parking beat surveys
Healthy Street Transport Assessment Part 1 Section 4.32
"It is envisaged that the opportunity for car parking overspill onto local roads will be precluded by the fact that the nearest local road from the proposed residential blocks is beyond 250m, which exceeds the limit set by the Lambeth Methodology for parking beat surveys. Essentially, people are unlikely to park their vehicles outside of the development due to lack of convenience and concerns about theft/damage. Parking overspill is not anticipated to occur on surrounding roads due to the following reasons: • Parking at the development will be restrained by the proposed parking ratio, therefore residents will know whether they have access to a space when moving in or not; and • The expectation that residents would walk beyond 250m, with the minimum distance to Kingshill Avenue exceeding 500m, to reach their parked vehicle is considered an unreasonable and highly improbable scenario; "
However, this distance-based rationale is flawed and misleading:
Residents without on-site parking may still choose to park on surrounding roads, regardless of distance, especially if they own vehicles at the time of purchasing / renting properties at the development and find no viable alternatives.
The 250m threshold is a survey design parameter, not a behavioural guarantee. It does not reflect real-world decisions made under pressure, such as lack of space, cost or public transport accessibility needs.
Kingshill Avenue, Green Lane, and surrounding streets already face parking pressure. Even a modest increase in demand could exacerbate congestion, reduce visibility, and compromise pedestrian safety — especially near schools and nurseries.
Additional Concerns include
Car club spaces are proposed but not guaranteed. Their delivery is contingent on future demand, and no binding commitment is made. Even if implemented, three car club spaces cannot offset the parking needs of hundreds of households.
Zipcar’s claim that each car club space removes 10–14 vehicles from the road is aspirational, not site-specific or outer london specific. It does not account for local demographics, car ownership trends or the limited public transport options in Motspur Park.
Contradictory Use of Walking Distance to Justify Amenity Access but Dismiss Parking Over spill
We object to the developer’s dismissal of parking over spill risk on the grounds that it contradicts their own walking distance benchmarks cited elsewhere in the Healthy Streets Transport Assessment.
In support of active travel, the developer references national guidance and case law to argue that:
“Although 800m remains the desirable goal, in reality people will walk further, and 2km or indeed 3.2km is not an unreasonable upper threshold.”
Healthy Street Transport Assessment Part 1 Section 3.42
"In summary, and as supported by case law, although 800m remains the desirable goal, in reality people will walk further, and 2km or indeed 3.2km is not an unreasonable upper threshold"
This is used to justify the site’s connectivity to amenities and public transport, suggesting that residents will willingly walk long distances for daily needs.
Yet when addressing the likelihood of parking overspill onto Kingshill Avenue — located approximately 500m from the site — the developer claims such a walk is “unreasonable and highly improbable.”
This contradiction is striking:
Walking 1–3km to reach amenities is deemed acceptable, even desirable.
Walking 500m to reach a parked car is dismissed as implausible.
The inconsistency reveals a selective application of walking distance logic, tailored to support the developer’s narrative rather than reflect real-world behaviour. If residents are expected to walk 1km+ to reach shops and stations, it is entirely reasonable to expect that some would walk 500m to park a vehicle — especially in the absence of sufficient on-site provision.
This further reinforces the likelihood of over spill onto surrounding streets particularly Kingshill Avenue and Green Lane and undermines the credibility of the developer’s parking strategy.