Southern Access - Kingshill Avenue

Objection Points

We strongly object to the proposed Southern Access route of the Motspur Park Gasholders redevelopment on the grounds of misleading visual representation, potential land grab, lack of safety infrastructure, light pollution, and unaddressed risks of anti-social behaviour. Despite being described as the primary vehicular route into the site, the Southern Access is not adequately assessed in the planning documents, unlike the Northern Access, which receives a full section (Planning Statement section 18) detailing its design, policy compliance, and community impact. 

Southern Access Road Encroachment — Potential Land Grab 

The Southern Access proposal remains incomplete and potentially hazardous.

The Southern Access is described as the primary vehicular route into the site, yet both the Landscape Design Statement and the accompanying visual render (proposed view looking into the Southern entrance from Kingshill Avenue pg 19) fail to provide adequate clarity or transparency about its real-world context and safety implications.  While the application includes an entire section assessing the northern access (Planning Statement - section 18 )—its design, policy compliance, and community impact—there is no equivalent detail provided for the southern access, despite its significance.

1. Misleading Visual Representation

The image titled “proposed view looking into the Southern entrance from Kingshill Avenue pg 19” omits a critical aspect of the site: the existing residential properties along Kingshill Avenue.

The left-hand side of the image—where back gardens of family homes are located—is visually replaced with landscaped planting and signage, giving the false impression of open space or buffer zones.

This omission conceals the proximity of the new access road to private rear gardens, where children regularly play and families gather.

2. Safety and Privacy Concerns

The Southern Access route runs directly behind existing homes, with minimal separation between the vehicular carriageway and private gardens.

The Landscape Statement acknowledges this narrow corridor but fails to detail any protective measures such as secure fencing, acoustic screening, or safeguarding for children.

"Landscape Statement - 1.3 Opportunities and Contrsaints

Access routes into the Site are long, narrow and linear andrun to the rear of houses - limits the opportunity for passive surveillance"

The proposed 2m footway and seating areas are described as “overlooked from the rears of properties,” yet this passive surveillance does not substitute for active safety infrastructure.

The route will accommodate large vehicles, including refuse trucks and SGN service vehicles, raising concerns about noise, pollution, and risk to children playing nearby.

3. Inconsistent Design Standards

The Northern Access is supported by detailed safety strategies, visibility planning, and references in section 18 of the planning statement.

No equivalent details are mentioned for the Southern Access, despite its greater vehicular intensity and closer proximity to homes.

This inconsistency suggests a lack of parity in safeguarding residents and undermines the claim of inclusive, community-sensitive design.

Harmful Light Pollution from Southern Access — Double Exposure for Adjacent Homes

The Southern Access route runs directly behind existing homes on Kingshill Avenue, many of which have bedrooms backing onto the proposed carriageway. These homes already face street lighting at the front. The proposal would subject them to light pollution from both sides, severely impacting residential amenity, sleep quality, and privacy.

1. Double Exposure to Artificial Lighting

The Landscape Design Statement (pg. 22) confirms that the entire north-south route will be lit to Secure By Design standards, with lighting installed to ensure visibility and safety “day and night.” This includes the Southern Access, which is immediately adjacent to rear gardens and bedroom windows.

"Lighting the north-south route is essential to ensure safe and secure movement into, out of and through the Site day and night. The lighting will be effective, avoiding strong contrast and shadows and will be lit to the required Secure By Design standards. Lighting will be installed that is easily maintained to ensure that should the lighting fail, it can be fixed immediately and quickly" (Landscape Design Statement pg 22)

Residents will be exposed to continuous artificial lighting from both the front and rear, creating a disruptive and unnatural living environment.

2. No Mitigation Measures Proposed

The document makes no mention of shielding, dimming, or directional lighting to protect existing homes from glare.

There is no assessment of light spill, no modelling of lux levels, and no commitment to curfews or adaptive lighting.

The Southern Access is described as “lit at night to the required lux levels for safety and security,” but no consideration is given to residential impact.

3. Contradiction with Landscape Vision

The developer claims to promote “tranquillity and well-being” through naturalistic design, yet the Southern Access introduces urban-scale lighting infrastructure into a quiet, residential setting.

This undermines the stated goal of creating a calming and sustainable place to live.

Anti Social Behaviour

In their Landscape Statement, the developer admits: “Access routes into the Site are long, narrow and linear and run to the rear of houses – limits the opportunity for passive surveillance.” To address this, they promise:

“CCTV will be provided along both the Northern and the Southern Accesses as well as along the Western Edge ensuring there is 24 hour surveillance.”

CCTV is reactive, not preventative. It doesn’t stop mopeds, scooters, or e-bikes from using the route as a cut-through.

While LBM has rightly flagged the risk of anti-social behaviour along the Northern Access and proposed robust mitigations, RBK has not addressed similar or greater risks posed by the Southern Access. This route runs directly behind homes on Kingshill Avenue, with minimal separation from private gardens and children’s play areas. It will be used by large vehicles and lit at night to Secure By Design standards, yet no equivalent safeguards or mitigation measures have been proposed. exposing families to light pollution, noise, and potential misuse by mopeds and e-bikes. Misleading visuals and lack of protective screening—raises serious concerns about safety, privacy, and residential amenity. 

Why has RBK not raised similar concerns or required the same level of protection for existing residents? What steps will RBK take to ensure that the Southern Access is safe, secure, and respectful of the privacy and wellbeing of current residents?

Noise Impacts 

The Environmental Statement is incomplete and inadequate for the following reasons:

• Missing Baseline Data: No baseline noise measurements have been provided for the quiet residential boundary adjacent to Kingshill Avenue, where children’s bedrooms are located just 20 metres from the proposed access driveway. This is a critical omission that undermines the validity of the noise assessment.

• Failure to Assess Key Receptors: The assessment does not consider the specific sensitivity of these receptors—bedrooms during nighttime hours—despite their proximity to the proposed vehicular access and public realm. This violates the requirement to assess impacts on all relevant receptors.

• No Mitigation Strategy for Traffic and Public Realm Noise: The Environmental Statement contains no proposals to mitigate increased noise from traffic movements or people congregating directly behind existing homes. This is a serious oversight given the expected rise in ambient noise levels.

• Unacceptable Bedroom Noise Levels: Traffic noise is likely to exceed the World Health Organization’s recommended maximum of 30 dB(A) for bedrooms during sleeping hours. We reject any justification that relies on residents keeping windows closed to achieve acceptable internal noise levels—this is not a sustainable or equitable solution and contradicts the principles of healthy living environments

We ask Kingston Council to:

• Reject the application based on the lack of a full and transparent assessment of the Southern Access Until these concerns are addressed, the Southern Access proposal remains incomplete and potentially hazardous.

• Request for Justification for the omission of residential context in visual materials and assurance that all access routes meet equal standards of safety and transparency.