Poor Public Transport Accessibility (PTAL)

Objection Points

We strongly object to the proposed development due to inadequate transport provision, misleading claims of sustainability, and failure to comply with national planning policy regarding cumulative impacts and accessibility. 

PTAL Rating Confirms Poor Accessibility

Transport for London’s WebCAT tool confirms that the majority of the site has a Public Transport Accessibility Level (PTAL) of 0–1b — the lowest possible rating. This reflects extremely limited access to frequent, reliable transport modes and is acknowledged in the developer’s own Transport Assessment (TA 2.32, Figure 2-4).

Despite this, the developer asserts the site is “inherently sustainable” (TA 2.37) due to proximity to Motspur Park and Worcester Park stations and nearby bus routes. This claim is misleading:

• No new public transport infrastructure is proposed

• No upgrades to pedestrian or cycle routes outside the site are included 

• The site remains poorly connected, especially for families, shift workers, and disabled residents

PTAL measures connectivity — not physical access or vehicle capacity. Increasing train size or bus occupancy does not improve PTAL. Only shorter walk distances, higher service frequency, or new routes can raise it. The site’s PTAL rating confirms it is not well-integrated into the transport network.

Rail Access is Unreliable and Unconfirmed

The proposal relies heavily on Motspur Park and Worcester Park stations for commuter access to London Waterloo. However:

• South Western Railway has not announced any peak-time service improvements

• Existing services are already overcrowded and delayed

• A local petition is calling for increased rail frequency, highlighting community concern

This undermines the developer’s assumption that rail access is sufficient to support the proposed density.

Cumulative Impact from Sterling Place (Major development in New Malden) Ignored

The Transport Assessment fails to account for the additional pressure caused by the nearby Sterling Place development in New Malden:

• 456 new dwellings

• Estimated 960 new residents

• Motspur Park Station designated as the primary rail access point

No cumulative modelling or mitigation is included in the developers Transport Assessment. This omission violates the intent of Paragraph 116 of the National Planning Policy Framework (NPPF), which requires consideration of cumulative impacts — not just isolated modelling.

Misleading Sustainability Claims

The applicant describes the site as “inherently sustainable” despite:

• A confirmed PTAL rating of 0–1b

• No new transport links or service commitments

• No cumulative impact modelling

• No upgrades for walking or cycling infrastructure

This claim contradicts both the developer’s own data and the requirements of the National Planning Policy Framework (NPPF), particularly Paragraphs 110, 116, and 117, which call for developments to be located in areas that are or can be made sustainable, and to avoid severe residual impacts on the transport network.

Rail Load : Developer's Own Data (Healthy Streets Transport Assessment section 6.42 )

According to the developer’s own Transport Assessment:

• 172 AM peak rail trips are projected

• With only 5 trains departing Motspur Park during the AM peak, this equates to 34 additional passengers per train — from this site alone

This figure does not account additional pressure from Sterling Place. Without service upgrades or mitigation, this level of demand risks exacerbating overcrowding and undermines the viability of sustainable travel.

Crucially, the modelling assumes that only 20% of new residents will travel during peak hours, raising serious questions about the remaining 80% of residents and their travel demand. This underestimation risks masking the true impact on local transport infrastructure and fails to reflect realistic commuter behaviour. 

In addition there is no evidence is provided that South Western Railway has capacity plans to absorb this additional pressure 

Misrepresentation of walking distances and Amenity Access

The applicant cites Manual for Streets (MfS, 2007) and PPG13 to suggest that walking distances of up to 800m — and even 2km — are acceptable. However, this is selectively applied:

• The actual distance to key amenities, such as Waitrose, Superdrug, Sainsbury’s Local, and Manor Drive Surgery, is 1.4km from the site boundary, and significantly further from the northern tower blocks, where the majority of residents would live.

• These amenities lie outside the 1km radius shown in the applicant’s own mapping (Iceni image), contradicting claims of proximity.

• The claim that residents will walk further if the route is “attractive” is speculative. The “attractive route” ends at the site boundary, and unless Berkeley Homes is committing to significant upgrades to surrounding streets, this justification is invalid.

This undermines the assertion that the development offers genuine sustainable transport choices. In reality, the distance and quality of routes will increase car dependency, especially for families, elderly residents, and those with mobility challenges.

In summary, the  proposal fails to meet the requirements of national and local planning policy. The site’s poor PTAL rating, lack of infrastructure investment, flawed modelling assumptions,render the transport strategy inadequate and non-compliant. 

We believe the cumulative transport impact of Sterling Place — a major development with direct reliance on the same rail infrastructure — should be modelled and mitigated before this application can be considered acceptable. We would urge Kingston Council to reject the proposal unless this critical oversight is addressed.

Policy 

NPPF 110

The planning system should actively manage patterns of growth in support of these objectives. Significant development should be focused on locations which are or can be made sustainable, through limiting the need to travel and offering a genuine choice of transport modes. This can help to reduce congestion and emissions, and improve air quality and public health. However, opportunities to maximise sustainable transport solutions will vary between urban and rural areas, and this should be taken into account in both plan-making and decision-making. 

Kingston Core Strategy 2012 Policy CS 5: Reducing the need to travel  

“To reduce the need to travel, particularly by car the Council will: 

• Protect and enhance the availability of employment and key facilities including shops, healthcare and leisure facilities within local communities.  

• Locate major trip generating development in accessible locations well served by public transport  including Surbiton, New Malden, Tolworth and Kingston Town Centres. Sites that have poor levels of accessibility by sustainable  modes will not usually be considered suitable for development that could generate high numbers of trips.