Poor Residential Quality

Objections

We object to the Proposed Development on the grounds that the residential quality falls short of the expectations set out in London Plan Policy D6 and Kingston Core Strategy (KCS) Policies DM13.

Misleading Use of Space Standards

• The applicant states that all units meet the minimum gross internal floor area requirements of Table 3.1 of the London Plan. However, minimum compliance is not equivalent to high-quality design.

• The comparison with best practice standards (Appendix 1 of the Housing Design Standards LPG) reveals that many units fall short of optimal sizes—particularly 1B1P, 1B2P, 3B5P and 3B6P units, which are only marginally above minimum thresholds and below best practice targets.

• Built-in storage provision is minimal across all unit types, with most units offering only 1–2 sqm—well below what is needed for families or long-term occupancy.

Inadequate Private Amenity Space

London Plan Policy D6

9) a minimum of 5 sq.m. of private outdoor space should be provided for 1-2 person dwellings and an extra 1 sq.m. should be provided for each additional occupant, and it must achieve a minimum depth and width of 1.5m. This does not count towards the minimum Gross Internal Area space standards required in Table 3.1 

• London Plan Policy D6 requires 5 sqm of private outdoor space for 1–2 person homes, with 1 sqm added per additional occupant. This means a 3B6P unit should have at least 9 sqm of private outdoor space.

• The applicant proposes only 6 sqm per unit, regardless of occupancy, which fails to meet the policy requirement for larger households.

• The reliance on communal amenity space (3,640 sqm across the site) does not compensate for the shortfall in private provision, especially for families, elderly residents, and those with accessibility needs.

Inadequate and Non-Compliant Play Space Provision 

We object to the Proposed Development on the grounds that the play space provision fails to meet the requirements of London Plan Policy S4 . The play space proposal relies heavily on off-site provision without sufficient justification, and does not adequately address the needs of future residents or protect the amenity of existing users. 

London Policy S4

2) for residential developments, incorporate good-quality, accessible play provision for all ages. At least 10 square metres of playspace should be provided per child that:

a) provides a stimulating environment

b) can be accessed safely by children and young people independently

Full Planing statement - section 11.9 

The London Plan’s supporting text states that, whilst formal play provision should normally be made on-site, ‘“off-site provision, including the creation of new facilities or improvements to existing provision, secured by an appropriate financial contribution may be acceptable where it can be demonstrated that it addresses the needs of the development whilst continuing to meet the needs of existing residents. This is likely to be more appropriate for the provision of play facilities for older children, who can travel further to access it, but should still usually be within 400 metres of the development and be accessible via a safe route from children’s homes.” 

Policy Requirements and Child Yield

• London Plan Policy S4 requires at least 10 sqm of play space per child, with a strong presumption in favour of on-site provision, especially for younger age groups.

• The GLA’s child yield calculator estimates 240 children will live in the development, requiring 2,400 sqm of play space.

• The proposal provides only 1,643 sqm on-site, with 758 sqm off-site at Sir Joseph Hood Memorial Playing Fields (SJHMPF).

Over-Reliance on Off-Site Provision

• The proposal shifts play provision for older children (9–17) entirely off-site, despite the London Plan stating that off-site provision must:

  • Be within 400 metres

  • Be accessible via a safe route

  • Not compromise existing residents’ access

• No evidence is provided that SJHMPF has capacity to absorb additional demand from new children, nor that existing users will not be displaced or impacted.

• The planning documents do not confirm any formal agreement with the Borough or SJHMPF operators, nor any financial contribution to enhance or expand facilities. 

Misleading Claim of Play Space Compliance – Unsecured Access Route to SJHMPF 

The applicant’s claim that off-site play space at Sir Joseph Hood Memorial Playing Fields (SJHMPF) complies with London Plan Policy S4 is misleading and premature .

• There is no current direct access from the site to SJHMPF and the current route is more than 400m from the site.

• The 400m claim must be conditional on the bridge being delivered 

• The assertion that SJHMPF is within 400 metres walking distance is based on a hypothetical future access route—a proposed footbridge over Beverley Brook that has not been agreed, funded, or secured through a Section 106 obligation. 

• Even if a bridge were delivered, the route would pass through a heavily wooded area, raising serious concerns about safety, visibility, and accessibility, particularly for older children and those with mobility needs. The London Plan requires off-site play space to be safe, accessible, and proximate