PLANNING ISSUES​​

The below offers some references and consideration in to the themes and policies that are relevant in a complaint.

IT IS BEST NOT TO COPY THIS AS IS BUT TO HAVE YOUR OWN VIEWS AND RESEARCH. Some are sourced via AI so should be cross checked.​

1. Height & Massing – “Too Tall, Too Close”

I object to the proposal on the grounds of excessive height and massing. At approximately 30 metres, the building would be around five times the height of neighbouring two-storey houses and significantly taller than typical buildings along the Hogsmill corridor. This scale is far more akin to a town-centre or designated tall-building zone than to a sensitive riverside location on the edge of a conservation area.

The Kingston Local Plan (including policies such as DM10 – Design Requirements for New Development and BE14 / KTC15 – Building Heights, where applicable) expects new development to respect the prevailing scale and built form of the surrounding area, particularly near conservation areas and residential streets. The London Plan’s Policy D9 (Tall Buildings) makes clear that tall buildings should only be located in areas identified as suitable, and that their impacts on character, heritage and amenity must be carefully justified. This site is not identified in emerging tall-building work as an appropriate location for a structure of this scale.  Further policy KTC15 requires new development to relate sensitively to existing townscape character, stepping down in scale where is adjoins lower-rise areas.

The proposal fails to provide convincing townscape justification for this height, nor does it adequately explore alternatives such as stepping down the massing towards the conservation area and residential properties, or limiting the overall height to better match the 20–25 m context of other large Kingston buildings. In my view, the excessive height and bulk are therefore contrary to local and London-wide policy on scale, context and character, and should be substantially reduced.

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2. Conservation Area & Heritage Setting

I object to the proposal due to the harm it would cause to the setting of nearby conservation areas and heritage assets. Although the application site sits just outside the Fairfield/Knights Park Conservation Area, national law and policy are clear that the setting of a conservation area is also protected.

Under Section 72 of the Planning (Listed Buildings and Conservation Areas) Act 1990, the Council has a statutory duty to pay special attention to the desirability of preserving or enhancing the character or appearance of conservation areas. The NPPF reinforces this by requiring great weight to be given to the conservation of heritage assets, including their setting.

The existing riverside townscape is characterised by modest building heights, a strong presence of trees, open sky and the visual primacy of the river corridor. Introducing a 30 m institutional block immediately adjacent to this conservation area would substantially change how the area is experienced – the proposed building would be prominent in key views, draw the eye away from historic buildings and riverside greenery, and undermine the fine grain and human scale of the conservation streets.

The heritage and townscape documents submitted by the applicant appear to downplay this impact, often focusing on distant views or on comparisons with unrelated town-centre buildings. In my view, the proposal does not preserve or enhance the conservation area’s character and therefore conflicts with the 1990 Act, the NPPF and relevant Kingston Local Plan policies on conservation and heritage.

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3. Overshadowing, Daylight Loss & Outlook

I object on the basis that the development would cause an unacceptable loss of daylight, sunlight and outlook for nearby homes, particularly on Mill Street and Portland Road.

The applicant’s own Daylight, Sunlight and Overshadowing Study uses the BRE 209 methodology and shows measurable reductions in Vertical Sky Component (VSC) and Annual Probable Sunlight Hours (APSH) to several neighbouring windows and gardens. Even where the report concludes impacts to be “minor” or “negligible”, these characterisations are subjective – for affected residents, a 20–30% reduction in daylight or sunlight is very significant.

At 30 m high and located on the southern side of residential streets across a relatively narrow river corridor, the building inevitably casts long shadows over gardens and façades, particularly in winter and at spring/autumn equinox. The study focuses heavily on numerical compliance and does not provide clear, visual shadow diagrams from residents’ viewpoints to show what will actually be experienced in homes and gardens. Nor does it fully explore cumulative effects alongside existing vegetation.

Kingston Local Plan DM10 requires new development to safeguard the amenity of adjoining occupiers, including daylight, sunlight and outlook. The London Plan D9 also emphasises that tall buildings must not cause unacceptable overshadowing of nearby residential areas. In my view, the proposal fails these tests: it would materially reduce light levels, significantly increase the sense of enclosure, and replace views of sky and trees with a dominant built form – all contrary to the requirement for a good standard of amenity.

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4. Traffic, Construction Impacts & School Safety

I object to the proposal due to the serious construction and traffic impacts it would impose on local residents, schoolchildren and road users.

The site is accessed via narrow residential streets which already accommodate pedestrians, cyclists and school traffic. The construction documents suggest a multi-year build programme with a substantial number of HGV and construction vehicle movements each week. This would inevitably increase congestion, noise, vibration, air pollution and road safety risks, especially at school start and finish times.

The submitted Construction Environmental Management Plan and Transport Assessment do not provide a fully detailed, enforceable Construction Management Plan. There is insufficient clarity on:

• exact access routes;

• controls on timing of HGV movements;

• how pedestrian and cycle safety will be prioritised;

• where contractor parking will be accommodated; and

• how breaches will be monitored and enforced.

This is contrary to the spirit of London Plan Policy T4 (Assessing and mitigating transport impacts) and Kingston Local Plan policies requiring developments to mitigate adverse traffic and environmental impacts. Given the proximity of two schools and dense housing, it is not enough to rely on vague “best endeavours” or goodwill commitments.

In my view, permission should not be granted in the absence of a robust, secured and independently monitored Construction Management Plan that clearly demonstrates how the safety and amenity of residents and schoolchildren will be protected.

Homes on Mill Street and Portland Road face measurable daylight loss and permanent overshadowing of gardens, views and sky.

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5. Environmental Harm – Hogsmill River & Chalk Stream

I object strongly on environmental grounds, particularly the risk posed to the Hogsmill River, a chalk stream and recognised Site of Importance for Nature Conservation (SINC).

Chalk streams are internationally rare habitats, and the Hogsmill supports a range of species that depend on clean water, natural banks and low levels of disturbance. The development proposes a large increase in hard surfaces and built mass directly adjacent to the river. This raises multiple concerns:

• Surface-water run-off and pollution during both construction and operation, with the potential for silt, contaminants and increased flows entering the river.

• Disturbance to riparian habitat through tree loss, overshadowing and increased human activity.

• Heat-island effects from expansive façades, which can warm adjacent air and water.

• Light pollution from extensive glazing and external lighting affecting nocturnal species.

While the applicant’s ecology reports refer to “biodiversity net gain”, this appears to rely heavily on planting and habitat measures within a constrained urban site, rather than genuinely safeguarding and enhancing the river corridor. The proposals risk undermining the ecological integrity of the chalk stream, contrary to London Plan Policy G6 (biodiversity and access to nature), Kingston Local Plan NE3 (Nature Conservation and Biodiversity), and the NPPF’s strong protection for irreplaceable habitats.

Given the national and local importance of the Hogsmill, the Council should adopt a precautionary approach and refuse any scheme that cannot clearly demonstrate no harm and a genuine, deliverable ecological improvement.

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6. Loss of Trees & the Riverside Green Corridor

I object to the proposed removal of trees and degradation of the riverside green corridor.

The Arboricultural Impact Assessment and tree schedule indicate that a number of trees – including some that contribute significantly to the character, screening and ecological value of the riverbank – would be removed or heavily pruned to make way for the building and associated works. While replacement planting is suggested, this cannot substitute for the immediate and long-term benefits of mature trees, such as:

• Urban cooling and shade;

• Visual softening of built form;

• Carbon storage;

• Habitat for birds, bats and invertebrates; and

• Contribution to the distinct riverside character of this part of Kingston.

Kingston Local Plan NE4 (Trees, Woodlands and Hedgerows) seeks to protect trees of amenity value, especially in or adjacent to conservation areas and along river corridors. The London Plan’s Urban Greening policies similarly require major developments to deliver high urban greening scores and avoid net loss of green infrastructure.

On balance, the scheme appears to cause net harm to the established green corridor, with replacement planting unable to compensate in the short to medium term. This weighs heavily against the proposal.

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7. Light Pollution, Noise & Microclimate

I object to the risk of increased light pollution, noise and microclimatic change associated with such a large building so close to the river and homes.

The proposed structure contains extensive glazing and is likely to be used into the evening. Combined with external lighting for safety and security, this will introduce significant artificial light into an area that currently experiences relatively low levels of illumination at night, especially along the river. Light spill into the water and treeline can disrupt bat foraging, bird behaviour and other nocturnal species, contrary to principles in the NPPF and relevant local biodiversity policies.

Additionally, the mass and height of the building may alter local wind patterns and microclimate, potentially increasing wind speeds at ground level and contributing to heat build-up along the river corridor. These issues are only lightly touched on in the submitted statements and not explored in sufficient depth.

Planning policy expects applicants to demonstrate that developments will not cause unacceptable levels of pollution or nuisance, including light and noise. In my view, the assessment here is incomplete, and the risk of environmental and amenity harm is under-appreciated.

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8. Sustainability, Demolition & Embodied Carbon

I object to the scheme’s sustainability credentials, particularly in relation to demolition, embodied carbon and the circular economy.

While the Sustainability and Energy Statements emphasise operational performance (e.g. low-carbon technologies, energy efficiency), there appears to be limited consideration of the carbon cost of demolishing existing buildings and constructing a large new block. The London Plan’s circular economy policies and broader climate objectives encourage retention, refurbishment and adaptive reuse as a first principle.

The applicant has not provided a convincing options appraisal showing:

• why refurbishment or partial retention was not viable;

• how the embodied carbon of new construction compares with alternatives; or

• how materials will be re-used at end of life.

Given that both Kingston Council and the Greater London Authority have declared climate emergencies, major developments should demonstrate best-practice low-carbon design across the full life cycle. In its current form, the scheme appears to prioritise scale and statement architecture over genuine carbon minimisation, which I believe weighs against its acceptability.

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9. Neighbourhood Integration & Overall Amenity

Finally, I object to the proposal on the grounds that, taken as a whole, it fails to integrate sensitively into the existing neighbourhood and would harm the overall amenity and liveability of the area.

The site sits between homes, schools, riverside paths and conservation streets. A successful scheme here would need to be carefully scaled, stepped and designed to respect the human scale of the surroundings, protect light and outlook, and enhance the riverside as a shared asset.

Instead, the current proposal introduces a single, dominant block whose height, mass and intensive institutional use will permanently change the character of the area. Noise, activity, overlooking, traffic and cumulative visual impact will all increase significantly. This is contrary to the aims of:

• London Plan Policies D1–D4 (context-led design, liveable neighbourhoods); and

• Kingston Local Plan DM10 (high quality places, protecting amenity and character).

In summary, while I support the principle of university investment and modernisation, I do not believe this particular scheme – in this form and at this scale – meets the required standards of good planning. I therefore respectfully request that the Council refuse the application or require a substantially revised proposal with reduced height and massing, stronger environmental safeguards and genuine community involvement.

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