Raynes Park High School - Memorial Playing Fields
This following is the Association's submission to Merton's Planning Committe, in response to Planning Application, 26/FULL/0795,
FOR THE CREATION OF A SYNTHETIC TURF PITCH AT MEMORIAL GROUND RAYNES PARK SW20 9LN, INCLUDING FENCING, FLOODLIGHTING, ANCILLARY EQUIPMENT AND ASSOCIATED WORKS.
at: Playing Field, RAYNES PARK SPORTS GROUND, Westway Close, Raynes Park, Merton
The Raynes Park and West Barnes Residents’ Association (RPWBRA) was formed in 1928 in response to concern over flooding in the Raynes Park area at that time, and our monthly magazine now known as "The Guide" first appeared in 1931. We now distribute over three thousand copies of "The Guide" printed every month to cover the present membership.
We have been contacted by many residents in Linkway and Westway Close who are concerned about aspects of this application. Overwhelmingly, they tell us they are going to submit personal objections. We have heard almost no complaints about the current use of the field, either by the schools or by local sports teams.
When previous major work on the field was carried out in 2010, Raynes Park High School (RPHS) held a consultation evening to explain their proposals. In this case, neither Raynes Park High School, nor The Football Foundation, have made any attempt to consult neighbours whose properties overlook the sports field.
It is important to note that our committee believe that it is very important to encourage children and young people to take part in sport for their enjoyment and health. We have no objection with RPHS wishing to improve sporting facilities for its students and those of the neighbouring primary schools but this application’s aspirations are much broader than that.
The Association believes there are serious problems with this application (26/FULL/0795) for a Synthetic Turf Pitch (STP). We therefore hope that the DPAC will reject it, to allow an alternative scheme which would protect local residents and Raynes Park High School’s reputation. There are many grounds for refusing this application:
1)Increased potential for flooding in the locality;
2)Hours of operation
3)Noise disruption
4)Light pollution
5)Ecology of the RPHS Memorial Grounds
6)Parking
7)Impact on athletics
8)Archaeology
1) Flooding and Drainage
i) Drainage and Flooding Strategy:
We note that the Applicant’s Design and Access Statement (Page 13/39) suggests “that the proposed pitch build up & detention basin provide adequate attenuation …”. We note the Applicant has chosen these words carefully to avoid making a firm undertaking that its drainage design would be fit for purpose.
As such, we conclude that the Applicant has doubt that the proposed design drainage design is complete or adequate.
We also note that the Design and Access Statement (Page 13/39) also implies that, as the proposed pitch is within a Flood Zone 3, a 1-in-100 flooding event would cause the whole area to be flooded anyway, and that therefore, in the midst of a flood covering a large area, flows from the site will, somehow, be contained on the site.
We seriously question the logic of this assertion, as it is is plainly not a sensible justification for increasing the impermeability of an existing open space, within a flood zone.
Page 13/39 of the Design and Access Statement also states, “The full drainage design to be installed is outlined in the drainage design document produced and submitted as part of this application.”
However, the only drainage design documents submitted with the Application are:
•A general arrangement drawing on page 80/80 of SEA’s Flood Risk Assessment, and
•A general arrangement drawing for the Cricket Square (Tgms 1238.3-1)
We note that page 80/80 of the Flood Risk Assessment, indicates that the existing ground levels would be changed, such the entire pitch would slope downwards towards the northwest, with a new attenuation pond to be located adjacent to Barnscroft. However, the various notes on the drawing suggest that much of this outline design is subject to further investigations.
We note that Page 12/39 of the Design and Access Statement proposes that all new surface water drainage will be directed into the existing drainage infrastructure, via one or more of the following:
•A new Attenuation Pond north-west corner (i.e. Adjacent to Barnscroft)
•A gully by the existing pavilion, or
•A potential outfall ditch to the northwest boundary, (i.e. Adjacent to Barnscroft and the Bushey Road embankment).
We also note on Page 12/39, the Applicant also states that,
“Whilst the proposed development is designed to be water compatible …, in the case that percolation into the ground or attenuation within the construction is not enough to prevent surface flooding, …”.
We therefore aver that, whilst the Applicant has commissioned a very detailed theoretical flood risk assessment, this does not constitute a complete and robust drainage design. Considering how prone the area is to regular flooding, we aver that the applicant has failed to produce a drainage design that demonstrates that the proposed development will not exacerbate the existing flooding risk.
ii) Local Flooding Risk:
The Applicant appears to have made no attempt to investigate the flooding history of the site and the surrounding area and the frequency with which this occurs.
In the absence of such information, we provide the following information.
The RPWBRA was founded in 1928, and local flooding was a key reason for the Association’s formation. In more recent times, the Environment Agency has designated that significant parts of our area lie on a flood plain. There is, therefore, an ever-present danger of flooding to property.
We note that the Applicant’s submission lacks any reference to the actual observable and regular failure of the local drainage network to cater for the area’s, now-normal, storm water flows.
Our Association’s members have observed flooding in the streets close to the Application Site, as follows:
•Monday, 24 August 2020
•Monday, 12 July 2021
•Sunday, 25 July 2021
•Thursday, 21 October 2021
•Tuesday, 4 January 2022
•Tuesday, 23 June 2026
That is an average of approximately one flooding event every year, not 1 in 10.
Of course, other areas in the London Borough of Merton (LBM) have had similar experiences on these occasions, but in our area, the following have been flooded: Shannon Corner, Westway, Westway Close, Raynes Park Bridge and Coombe Lane in Raynes Park town centre.
The LBM’s own historic records show several flooding events occurring in Raynes Park, going right back to the early 20th Century. However, with climate change and increased density of development, we observe that such events are becoming much more frequent. Whilst the impact on Raynes Park town centre of these flooding events have been reported in the local press and media, there was less reporting of the other events, occurring in Westway and the adjoining streets.
The recent regularity of these flooding events completely discredits any statistical notions of such events being unusual historical occurrences. They are now very much the norm.
iii) Westway and Westway Close adjoining the Application Site:
During these flooding events, the sewers overflow into the street, as evidenced by water spurting up from the manhole covers. It is self-evident that the existing sewers have insufficient capacity to cope with the flows during these, now-normal, events. On these occasions, it caused flooding of the public highways, private gardens, and threatened homes.
In recent years, there has been a continued loss of permeable surfaces in our area, due to house extensions, the paving over of driveways, infill developments and artificial grass pitches This inevitably results in greater storm water runoff and greater discharges into the existing drainage infrastructure. This all makes overflows more likely.
The Application site has an ever-present risk of flooding from storms, which frequently fill the existing sewers to capacity, such that they cannot cope and overflow into the streets.
With the effects of climate change, the loss of permeable areas and increasing density of development, this problem will continue to become even more common and more severe.
iv) Flood Risk Management Authorities:
LBM’s partners in Flood Risk Management are Thames Water (TW) and the Environment Agency (EA). We have concerns with our recent experience with these two organisations.
Firstly, Thames Water has an obvious conflict of interest because of the attractiveness of new developments adding to its future revenues, which may lead to it playing down the demonstrable inadequacies of its drainage infrastructure and the resulting increasing flood risk.
Secondly, the EA classifies the Pyl Brook as a main river and as a potential source flooding in the Westway area. However, it seems that the EA is uncertain of the exact route of the culverted section between Kings College Playing Field and the level crossing at the West Barnes Lane/Burlington Road junction. The EA sent a speculative letter to residents regarding their possible riparian responsibilities, without verifying the exact course of the culvert. These conflicts of interest and lack of information only make matters worse.
We aver that the Applicant does not have a complete and detailed drainage design and has not taken into account the recent history of flooding in the vicinity.
We therefore recommend that the proposal to increase the impermeability of the existing site, which is located on the Flood Plain, should be rejected.
2) Hours of operation:
The potential to have matches and training every day on the STP from 8am to 10pm is naturally of great concern to neighbours. It is proposed that these times would apply every day of the year. There will therefore never be a time when residents can enjoy peace and quiet in their gardens without the intrusive noise of balls hitting the chain link fence, shouting and, for most of the time, whistles – see section 3).
We believe this constitutes a serious encroachment on residents’ privacy, leading to increased stress levels. We therefore recommend that there should be a condition that there will be no play in the STP from midday on either the Saturday or Sunday every week. This would allow residents to plan get-togethers of friends and family without the disruption caused by noise or lighting. This condition need not affect the use of the rest of the field, e.g. by cricket clubs.
A 9pm closure of the STP on weekdays would be more acceptable to most residents, with a switch-off time of 8.30 for the floodlights. If clubs wish to play or train later on a STP, they should use the artificial pitches on the school’s main site.
When asked about these hours of operation, our Secretary was told that 10pm was the cut-off time for lighting at Raynes Park Vale Football Club (RPVFC) justified this time. However, the nearest houses on Grand Drive are further from the RPVFC pitch and are screened by an area of woodland and/or the garages from Cannon Close. This can easily be seen using Googleview, so the comparison is misleading.
3) Noise disruption to neighbours:
The NIA rightly identifies the need for a noise reduction fence to protect Barnscroft residents. However, Linkway and Westway Close residents will also be impacted by noise when the proposed STP is in use.
Tables 2 and 6 of the NIA give the WHO noise criteria and typical sound levels for various activities, such as 8-a-side training match. Comparison of these tables shows that the sound levels of the STP are likely to exceed the WHO criteria for Linkway and Westway Close residents, despite what is shown in figure 9. The type of noise is also important. The impact of balls frequently hitting the 4.5m surrounding metal fences, even with their neoprene isolators, will be very stressful and prevent residents enjoying their gardens or having open windows. It is also likely to impact those working from home and getting children to sleep. This is recognised in paragraph 8.8 of the NIA:
“With the required barrier, the highest predicted maximum noise levels from the highest individual source location at the window of the façade of the worst case NSR to the west is 63 dB(A), and at the NSR to south is 57 dB(A).”
63dB(A) and 57dB(A) both exceed the WHO “moderate annoyance, daytime and evening” level (50dB) and “serious annoyance, daytime and evening” (55dB)
How often will balls hit the fence to produce the “worst case” levels of noise? It could be many times each minute and is thus an unacceptable intrusion into neighbours’ lives, leading to increased stress levels.
Figure 5 shows where the noise impact modelling was carried out at Coombe Dingle Sports Complex in Bristol. As can be seen, the pitches at Coombe dingle are not surrounded by housing, as is the case at RPHS’s Memorial Ground. Houses in Westway Close and Linkway will reflect sound waves, this increasing the noise levels thus invalidating the noise predictions shown in Figures 9 and 11.
Players and coaches shouting is part and parcel of both practices and matches. Even if the noise levels are as predicted in paragraph 8.6, they would still disrupt neighbours’ privacy.
The NIA clearly states that noise from whistles will be too loud (worst case NSR to the west is 68 dB(A), and at the NSR to south is 65 dB(A) - para 8.7) but the solution is laughable, para 9: “no whistles after 6pm” seems sensible but is then followed by “with whistles only permitted during competitive matches”. A more sensible arrangement would be to prohibit competitive matches after 7.30pm. School matches would therefore be unlikely to be impacted.
The RPWBRA believe that this application should not be granted until more suitable modelling is carried out.
4) Light pollution:
Residents are concerned about the following statement in the DAS (page 17/40):
“LED floodlighting was chosen[…] to facilitate economical / ecological management and prevent ‘over lighting’ to pitch areas when not in use.”
Surely, when the pitch is not in use, all floodlights should be switched off.
Despite the information produced by Signify Uk’s Lighting Application Specialist (LiAS) team and the DAS, local residents have told the RPWBRA of their concerns about floodlighting so close to their gardens, potentially to 10pm every night. We suggest a compromise be found with the lights switched off at 8.30pm and the site closed from 9pm every night, except for either Saturday or Sunday, when the STP should not be used after midday [see 2) Hours of operation].
5) Preliminary Ecological Appraisal:
Residents living in Westway Close and Linkway have rightly described the Preliminary Ecological Assessment as a joke. The RPHS Memorial Ground’s ecology needs to be considered as a whole, not focusing almost entirely on the proposed location of the STP. To give two examples:
i)The ecologists did not see the flock of 60 or so gulls which feed and rest every day throughout the early morning. The flock includes red and amber-listed species: herring, lesser black-backed and black-headed gulls. The reduction on grassland will negatively impact their feeding.
ii)No attempt has been made to list species that use the field and its tree-line: common and soprano pipistrelles, hedgehogs, frogs, toads, house sparrows, dunnock, greenfinch etc… to mention just a few. Residents can provide a full listing. It is likely that the increased noise from a STP would reduce the numbers of birds successfully nesting in this area.
The PEA suggests ways to improve the site’s biodiversity, e.g. wildflower meadow planting and a sparrow nesting box on the pavilion. The RPWBRA agrees with residents that bat and bird boxes could be put in all the mature trees; “bug hotels” near any wildflower planting; and log piles to provide habitat for stag beetles which are regularly found in this area.
6) Parking
The DAS statement “STP parking demands” (page 33/40) states that no extra parking should be allowed on the site, pointing to the negative impact of allowing cars to park on the grass – this is to be commended.
While the local community home teams will probably walk or cycle to the sports ground, members of visiting teams are more likely to come by car. Parking for all visiting cars must be on the Raynes Park High School site; the statement “Additional parking potential at Raynes Park High School. is too vague. Residents were told this would be the policy when the sports field was developed in 2010, but gradually more and more people park in neighbouring streets to reduce their walking time.
The impact of cars owned by residents of Sterling Place has not been taken into consideration: the development has only 220 spaces for 456 apartments. It is likely that some Sterling Place residents will park in Westway Close and Linkway.
A condition of granting this application should be that all parking has to be on the RPHS site.
7) Impact on Athletics:
According to the DAS,
“prior engagement was undertaken with England Athletics to ensure that following development, the proposals would meet their aspirations for continued cricket on the site.”
We assume that the mention of “cricket” is a typo. There is no documentation, however, from England Athletics on the Regulatory Services Hub which seems odd. Please may there be greater transparency.
8) Archaeology:
As Historic England has identified in their comment (71578471782815848_-_26FULL0795-Comments-Historic_260705_073327.pdf) that a desk-based assessment is insufficient. If this application were to be granted, the condition suggested by Historic England must be included in the decision.
Conclusion:
In its current form, we believe that 26/FULL/0795 should be rejected by the DPAC. While some of the issues highlighted in this comment could be addressed by conditions, overall, there are too many serious problems which need to be resolved:
•Flooding and drainage: the theoretical RAs and strategy are based on inaccurate data.
•Hours of operation, noise and lighting: impact on residents’ right to some privacy, peace and quiet. However, the details of this proposal go far beyond any benefits to the students at RPHS, Sacred Heart and West Wimbledon primary schools.
•Ecology: the PEA underestimates the ecological importance of the STP site in the wider field. There is great potential to improve biodiversity – an educational opportunity for RPHS students.
•Parking: all players’ cars need to park at Raynes Park High School.
•Archaeology: fieldwork is needed – another educational opportunity.
We urge the DPAC to reject this application.
Submitted on behalf of Raynes Park and West Barnes Residents’ Association
Jerry Cuthbert and Mary-Jane Jeanes
28/07/2026
Planning Application for All-Weather Pitch
RPWBRA Members should be aware that a planning application has been submitted on behalf of Raynes Park High School for an all-weather sports pitch, with associated floodlighting, nets, fencing and associated works at the school’s Memorial Sports Ground, adjoining Barnscroft, Westway Close, Linkway, Fairway and Greenview Drive.
Members may be concerned about such developments on the Flood Plain, with the obvious repercussions for other roads such a Westway, Greenway and Brook Close.
Full details of the Planning Application, 26/FULL/0795, may be seen on Merton’s website here, by inputting the application reference, 26/FULL/0795, and the clicking on Search / View / Documents Expand / Download.
Representations can be made through the same website and should be submitted by 16th July 2026.
Objection to Berkeley Homes' Application for the Motspur Park Gasholder Site
The following comments on Berkeley Homes Planning Application have been submitted to the Royal Borough of Kingston upon Thames' planning portal on 19 November 2025.
From the RAYNES PARK AND WEST BARNES RESIDENTS’ ASSOCIATION
Serving the community since 1928
The Residents’ Pavilion, 129 Grand Drive, Raynes Park, SW20 9LY
Ref: Planning Application 25/02562/FUL
Application Title:
Demolition of existing gasholders and associated above ground structures and buildings. Phased redevelopment of site to provide 8 to 16 storey 5 No blocks with 586 residential units and ancillary residential facilities (C3 Use Class), together with associated works to the existing accesses and internal vehicular routes, new pedestrian and cycle routes, the provision of new publicly accessible open space, amenity space, hard and soft landscaping, cycle and car parking, works to the brook embankment, re-siting of some gas infrastructure, ground works and plant and associated works.
Comments Submitted by:
Jerry Cuthbert, Committee Member,
On behalf of the Raynes Park and West Barnes Residents’ Association,
129 Grand Drive, London SW20 9LY
Introduction
These comments are submitted on behalf of the Raynes Park and West Barnes Residents’ Association. Our Association has a membership comprising approximately 1800 households located in the Raynes Park and West Barnes wards, within the London Borough of Merton (LBM).
Whilst the proposed development site is mainly located within the Royal Borough of Kingston upon Thames, its northern access is in Merton. This Application therefore, has obvious implications for our members and numerous impacts within our area.
Whilst we have no objections in principle to the redevelopment of the Gasholder Site, we consider the Applicant’s proposals to be completely inappropriate for this location and in conflict with Kingston’s Planning Policies, the London Plan and National Planning guidance.
Therefore, we hereby urge refusal of this Application for the following reasons:
1. Overbearing Massing
1.1 The proposed height of up to 16 storeys is in conflict with the Tall Buildings Policies of Kingston, Merton and Sutton,all of which exclude the areas of Old Malden and/or Motspur Park from the lists of suitable locations for Tall Buildings.
1.2 Additionally, Kingston’s new Draft Tall Building Strategy states that tall buildings should be located in urban centres and that tall buildings should be appropriate for their location. Clearly, the site is not located in an urban centre and the proposed height is, therefore, in conflict with the existing suburban landscape.
1.3 The Applicant claims its proposed massing is designed tocreate a sense of openness within the development. However, the Applicant’s proposal to cram 586 dwellings onto the site results in the exact opposite to a “sense of openness”. In reality, the proposed massing is located in the middle of a large residential area consisting of 2 or 3 storey suburban “between-the-wars” houses.
1.4 The Application is also in conflict with the National Planning Policy Framework. This requires that developments will function well and add to the overall quality of the area, not just for the short term but over the lifetime of the development and are visually attractive, as a result of good architecture, layout and appropriate and effective landscaping. We consider that the Applicant’s proposals fail all these three tests.
1.5 The London Plan also requires massing and height to be appropriate for the surrounding context. It also requires that massing, scale and layout should help make public spaces coherent and should complement the existing streetscape and surrounding area. Again, we consider that Applicant’s architectural proposals are clearly in conflict with these requirements.
2. Conflicting Architectural Character
2.1 Kingston’s Character Study for Old Malden, which includes the Gas Holder Site within “Character Area 5”, states that the views to the north of the gas holders have a significant impact on the character of the area. These “views to the north” encompass areas beyond those of the Study, such as New Malden (in Kingston) and West Barnes (in Merton). These are extensive areas of 2 or 3 storey suburban “between-the-wars” houses.
2.2 Kingston’s Policy DM 10, Design Requirements for New Developments, requires development proposals to incorporate principles of good design. The most essential elements identified as contributing to the character and local distinctiveness of a street or area which should be respected, maintained or enhanced. These include the prevailing development typology, housing types, sizes and occupancy,density of the surrounding area, scale, layout, height, form and massing.
2.4 Again, the applicant’s proposals are in breach of Policy DM10. being in direct conflict with the existing local architectural character.
3. Traffic and Highways Impacts
3.1 We consider that the Applicant’s traffic generation studies will not reflect the reality that will be faced by the occupants of the development.
3.2 The Applicant’s proposed single vehicular access to the site will be through the London Borough of Sutton, from Central Road in Worcester Park, via Green Lane . Thus, the existing road safety concerns in this area will be exacerbated, not just in the vicinity of Green Lane Primary School, but around Worcester Park Athletics Club, and at the junctions with Longfellow Road and Browning Avenue.
3.3 The Application Site has a very low Public Transport Accessibility Level (PTAL) of between “Zero” and “1b”. The Applicant’s traffic analysis is flawed, as it has used as a basis of its traffic assessment, data derived from comparison developments which much higher PTAL scores.
3.4 Road safety concerns on Green Lane and in the Station Estate have already led to multiple traffic calming measures, including a successful petition by residents in 2013. This planning application can only lead to an increase in road safety risks in this and the surrounding area. These risks will be compounded by the inevitable delivery vehicles that 586 homes will attract.
3.5 Old Malden/Motspur Park is not an area that provides significant employment or services. Therefore, the residents from the proposed development will need need to travel for work and to access schools, leisure, health and other services.
3.6 Despite the Applicant’s endeavours to limit the number of parking spaces, it is inevitable that, with such a low PTAL Score (Zero to 1b), the occupants of the proposed development will need to have daily access to private transport.
4. Insufficient On-Site Parking and Inadequate Access
4.1 The proposed development is in conflict with the London Plan (Policy T6 Residential Car parking). This states that in town centres, which generally have good access to a range of services within walking distance, car-free lifestyles are a realistic option for many people living there. However, for sites with an extremely low PTAL score, (e.g. this Application Site), the Policy allows up to 1.5 parking spaces per home for new developments in PTAL 0-1 zones in outer London.
This Application thus ignores this Policy.
4.2 The Application is also in conflict with Kingston’s Core Strategy (Policy CS 5), which has the objective of reducing the need to travel, particularly by car. Major trip generating developments should be in accessible locations, well served by public transport. 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.
4.3 The Applicant’s suggestion that by only providing 86 car-parking spaces for 586 new homes will somehow promote the use of public transport, walking or cycling, at this location is plainly ludicrous. Somehow, the new residents will be forced to find somewhere to park their cars and work vehicles. This will affect neighbouring streets, not only in Kingston, but also in Merton and Sutton.
5. The Proposals conflict with Secured by Design – Marina Avenue
5.1 The Applicant proposes to open the end of Marina Avenue to allow pedestrian and cycle access to Marina Avenue and adjoining residential streets. This is in conflict with the design principles recommended by “Secured by Design” (SBD). This is a UK police initiative that aims to reduce crime by improving the security of buildings and their surroundings, through design principles and security standards.
5.2 Section 8 of the SBD Residential (Homes) Guide 2025, states that the security benefit of a cul-de-sac can be compromised if it backs onto (inter alia) railway lines and long footpaths. This is an exact description of the proposed link to Marina Avenue.
5.3 Additionally, the Guide states that cul-de-sacs that connect footpaths to other parts of a development experience the higher levels of crime when compared to crime levels within a cul-de-sac (i.e. 110% higher) and therefore should be avoided.
5.4 This is thus irrefutable evidence that the Applicant’s proposal to open up access into Marina Avenue will probably lead to an increase in crime, which must be avoided.
6. Loss of Biodiversity
6.1 The Application is in conflict with the London Plan Policy G6, which mandates that biodiversity impacts be addressed from the outset and that priority species and habitats be protected and enhanced.
6.2 Additionally, the statutory framework under the Environment Act 2021 requires a minimum 10% biodiversity uplift based on accurate, unaltered baseline conditions.
6.2 Sadly, in recent years, the current owner of the site has already carried out pre-emptive felling of mature trees along the southern access route of the Site. This has lowered the Biodiversity Baseline of the Applicant’s Biodiversity Net Gain Assessment, thereby understating the impact of the proposed development.
6.3 Currently, the site supports a rich and interconnected ecological network, including common and soprano pipistrelle bats, slow worms and numerous breeding bird species. The proposed development would lead to a degradation of the various habitats that support these species. This Application is therefore in conflict with the requirements of the Environment Act 2021.
6.4 This directly contravenes the London Plan Policy G6 and Nation Planning Policy Framework, (Habitats and Biodiversity), which require planning decisions to secure measurable net gains for biodiversity — not gains manufactured through prior clearance.
6.5 We therefore strongly object to this application on the grounds of its adverse impact on biodiversity.
7 Damage to Metropolitan Open Land
7.1 The Application Site is within of an area of designated Metropolitan Open Land (MOL), which is part of an almost contiguous area of 300 acres. This large single area of MOL extends into the boundaries of three boroughs, Kingston, Merton and Sutton. It is one single area, apart from the narrow space taken by the railway lines.
7.2 The London Plan Policy G3 states that any alterations to the boundary of MOL should be undertaken through the Local Plan process, in consultation with the Mayor and adjoining boroughs. MOL boundaries should only be changed in exceptional circumstances”. Clearly, this Application conflicts with London Plan (Policy G3).
7.3 Further, Kingston Council’s Core Strategy (Policies CS3, CS4, DM5-DM7) provides for the protection and improvement of Kingston’s valued natural and green open space network, including protecting (inter alia) Metropolitan Open Land. Kingston Council also states that it not only wants to protect but add to MOL.
7.4 The proposed development would therefore destroy MOL and degrade openness and the environmental value of the wider Metropolitan Open Land.
7.5 MOL is afforded the same status and level of protection as Green Belt and there is a strong presumption in both national and local planning policy for its preservation. The Applicant’s proposals provide insufficient public green space to compensate for the loss of MOL and are thus in conflict with the above policies.
8 Adverse Impact on The Sir Joseph Hood Memorial Playing Fields
8.1 The London Plan and local planning guidance require that new developments:
· Respect the scale, massing, and character of their surroundings
· Avoid visual dominance or townscape disruption
· Provide accurate and honest visual representations to inform decision-making
8.2 We consider the Applicant’s assessments of visual impact of the proposed development as being misleading for the following reasons:
· Key viewpoints are obstructed by trees, bushes, or wide-angle distortion, making the towers appear hidden or more distant than as seen by the human eye.
· Images are taken from distant viewpoints, failing to show how overbearing the development will be.
· The applicant has conveniently used summer-time imagery, when trees are in full leaf, to mask the true visual impact of the towers.
8.3 In reality, the proposed development will loom over the Sir Joseph Hood Memorial Playing Field, damaging the open aspect of the public park, which is enjoyed by the residents in Old Malden and Motspur Park and visitors from further afield.
9. Conclusion
For the above reasons the Raynes Park and West Barnes Residents’ Association urges the Planning Committee of the Royal Borough of Kingston upon Thames to refuse this application.
Submitted by Jerry Cuthbert, Committee Member,
Raynes Park and West Barnes Residents’ Association,
129 Grand Drive, London SW20 9LY
18 November 2025
RPWBRA Comments to Merton - Motspur Park Gas Holders Planning Application
Application No: 25/P2859
My name and address:
Jerry Cuthbert(on behalf of the Raynes Park and West Barnes Residents’ Association)
129 Grand Drive,
London SW20 9LY
Application:
Demolition of existing gasholders and associated above ground structures and buildings. Phased redevelopment of site to provide 8 to 16 storey 5nos blocks with 586 residential units and ancillary residential facilities. etc.
Comments:
1, Introduction
1.1 We note that this planning application is for a site principally located in the Royal Borough of Kingston upon Thames (RBK). However, the northern of its existing two access points to the public road network in located in the London Borough of Merton (Merton). Additionally, the Applicant proposes opening a new pedestrian/cycle access from the application site to the end of Marina Avenue, which is in Merton.
1.2 The application is for 5 blocks of flats, up to 16 storeys high. Whilst these tall buildings would be located in RBK, their very proximity to the boundary with Merton, obviously means they would have a significant visual impact on Merton. The application site is also within an area of Metropolitan Open Land, which extends across the boundary between RBK and Merton.
1.3 We, the Raynes Park and West Barnes Residents’ Association (RPWBRA), have already submitted an objection to this application to RBK.
1.4 The following comments, therefore, focus on the adverse impacts that this Application would have on Merton:
· Conflict with Tall Buildings Policies
· Traffic & Highways Concerns
· Road Safety and Construction Traffic
· Conflict with Secured by Design – Marina Avenue
· Damage to Metropolitan Open Land
· Architectural Conflict with Neighbourhood Character
· Adverse Impact on Nature Conservation
· Adverse Impact on The Sir Joseph Hood Memorial Playing Fields
2. Conflict with Tall Buildings Policies
2.1 The Application Site is not located within those areas which are nominated within RBK’s Tall Building Policy, as being suitable for tall buildings. Due the site’s close proximity to Merton, and consequent visual impact, we consider that the Applicant should also comply with Merton’s Policy D 12.6 “Tall Buildings”. In particular, Section 3.b requires that “massing, bulk and height are appropriately sized” and ”demonstrate they take into account local character”.
2.2 The Applicant claims its proposed massing is designed tocreate a sense of openness within the development. However, the Applicant’s proposal to cram 586 dwellings onto the site results in the exact opposite to a “sense of openness”. In reality, the proposed massing is located in the middle of a large residential area consisting of 2 or 3 storey suburban “between-the-wars” houses.
2.3 Also, the Applicant has chosen to position the 5 blocks of flats such that the tallest (16 storeys) is located very close to the existing streets in the “KT3” (Motspur Park) area of Merton, i.e. Marina Avenue, Station Road and West Barnes Lane. It would thus be overbearing and loom over these nearby streets and homes.
2.4 The Application is also in conflict with the National Planning Policy Framework. This requires that developments will function well and add to the overall quality of the area, not just for the short term but over the lifetime of the development and are visually attractive, as a result of good architecture, layout and appropriate and effective landscaping. We consider that the Applicant’s proposals fail all these three tests.
3 Traffic & Highways Concerns
3.1 We consider that the Applicant’s traffic generation studies will not reflect the reality that will be faced by the occupants of the development.
3.2 The Application Site has a very low Public Transport Accessibility Level (PTAL) of between “Zero” and “1b”. The Applicant’s traffic analysis is flawed, as it has used as a basis of its traffic assessment, data derived from comparison developments with much higher PTAL scores.
3.3 Motspur Park is not an area that provides significant employment or services. Therefore, the residents from the proposed development will need to travel for work and to access schools, leisure, health and other services.
3.4 Despite the Applicant’s endeavours to limit the number of parking spaces, it is inevitable that, with such a low PTAL Score (Zero to 1b), the occupants of the proposed development will need to have daily access to private transport.
3.5 The proposed development is in conflict with the London Plan (Policy T6 Residential Car parking). This states that in town centres, which generally have good access to a range of services within walking distance, car-free lifestyles are a realistic option for many people living there. However, for sites with an extremely low PTAL score, (e.g. this Application Site), the Policy allows up to 1.5 parking spaces per home for new developments in PTAL 0-1 zones in outer London.
This Application thus ignores this Policy.
3.6 The Applicant’s suggestion that by only providing 86 car-parking spaces for 586 new homes will somehow promote the use of public transport, walking or cycling, at this location is plainly ludicrous. Somehow, the new residents will be forced to find somewhere to park their cars and work vehicles. This will affect neighbouring streets, not only in Kingston, but also in Merton.
4. Road Safety and Construction Traffic
4.1 The Applicant proposes using the existing vehicular access from West Barnes Lane for in-bound construction traffic. This is only a few metres away from the level-crossing gates at Motspur Park. In order to avoid the dangers of turning traffic causing queues across the level-crossing, the Applicant proposes to route all in-bound construction traffic from the north, along West Barnes Lane (i.e. using a left turn only, to access the site).
4.2 However, due to width restrictions in the West Barnes area, this proposed route would have to approach the site from the A3, via the following route:
· Exit the A3 at Shannon Corner,
· Turn northeast along Burlington Road (540 m),
· Turn southeast to join West Barnes Lane, across the level-crossing
· Continue along West Barnes Lane to Motspur Park, turning southwest at the junction with Crossway. (1.2 km)
4.3 This route passes close to two schools, Sacred Heart Primary School and Blossom House School, and passes through residential streets. Therefore, in the event that the Application were approved by RBK, restrictions on the hours of access for the site (both for removal of the gasholders and for construction) should be imposed for reasons of public safety and tranquillity.
5. The Proposals conflict with Secured by Design – Marina Avenue
5.1 The Applicant proposes to open the end of Marina Avenue to allow pedestrian and cycle access to Marina Avenue and adjoining residential streets. Marina Avenue is an existing cul-de-sac, with no access (pedestrian or otherwise) from its far end. This proposal is in conflict with the design principles recommended by “Secured by Design” (SBD). This is a UK police initiative that aims to reduce crime by improving the security of buildings and their surroundings, through design principles and security standards.
5.2 Section 8 of the SBD Residential (Homes) Guide 2025, states that the security benefit of a cul-de-sac can be compromised if it backs onto (inter alia) railway lines and long footpaths. This is an exact description of the proposed link to Marina Avenue.
5.3 Additionally, the Guide states that cul-de-sacs that connect footpaths to other parts of a development experience the higher levels of crime when compared to crime levels within a cul-de-sac (i.e. 110% higher) and therefore should be avoided.
5.4 This is thus irrefutable evidence that the Applicant’s proposal to open up access into Marina Avenue will probably lead to an increase in crime, which must be avoided.
6. Damage to Metropolitan Open Land
6.1 The Application Site is within of an area of designated Metropolitan Open Land (MOL), which is part of an almost contiguous area of 300 acres. This large single area of MOL extends into the boundaries of three boroughs, Kingston, Merton and Sutton. It is one single area, apart from the narrow space taken by the railway lines.
6.2 The London Plan Policy G3 states that any alterations to the boundary of MOL should be undertaken through the Local Plan process, in consultation with the Mayor and adjoining boroughs. MOL boundaries should only be changed in exceptional circumstances.
6.3 This is further enforced by Merton’s policy O 15.2, which places a high value on green infrastructure and strives to protect and enhance Metropolitan Open Land. Clearly, this Application conflicts with these policies, as it would destroy MOL. Consequently, it would also degrade the openness and environmental value of the wider Metropolitan Open Land, including that part which is within Merton.
7. Architectural Conflict with Neighbourhood Character
7.1 Again, whilst the Application Site is located in RBK, it is within an extensive area of 2 or 3 storey suburban mid-twentieth century houses. It would be highly visible from within this part of Merton and we therefore aver that the Application should comply with Merton’s Policy D 12.2 “Urban Design”.
7.2 This Policy requires that proposals should (inter alia):
· Have an appropriate street level presence and roofscape,
· Ensure that scale, height, mass, bulk and form is appropriate and assessed for visual impact, including long distance views,
· Consider the enhancement of views and settings.
7.3 We therefore aver that the applicant’s proposals, being in direct conflict with the existing local architectural character, are in breach of Policy D 12.2.
8. Adverse Impact on Nature Conservation
8.1 Nature’s reach is not constrained by local government boundaries and neither do wild fauna and flora confine themselves to a particular borough. Therefore, development proposals such as this, so close to Merton’s boundary, must have an impact on Merton’s biodiversity and residents’ access to nature.
8.2 We also aver that the Application is in conflict with the London Plan Policy G6, which mandates that biodiversity impacts be addressed from the outset and that priority species and habitats be protected and enhanced.
8.3 Currently, the site supports a rich and interconnected ecological network, including common and soprano pipistrelle bats, slow worms and numerous breeding bird species. The proposed development would lead to a degradation of the various habitats that support these species.
8.4 Merton’s Policy O 15.3 “Biodiversity and Access to Nature”, Section 1e, requires developments to follow the following mitigation hierarchy:
· Avoid damaging ecological features
· Minimise spatial impact and mitigate it.
· Delivery of off-site compensation of better biodiversity
8.5 We therefore aver that the Application does not comply with this requirement, due to its inevitable impact on biodiversity.
9 Adverse Impact on The Sir Joseph Hood Memorial Playing Fields
9.1 The London Plan and local planning guidance require that new developments:
· Respect the scale, massing, and character of their surroundings
· Avoid visual dominance or townscape disruption
· Provide accurate and honest visual representations to inform decision-making
9.2 We consider the Applicant’s assessments of visual impact of the proposed development as being misleading for the following reasons:
· Key viewpoints are obstructed by trees, bushes, or wide-angle distortion, making the towers appear hidden or more distant than as seen by the human eye.
· Images are taken from distant viewpoints, failing to show how overbearing the development will be.
· The applicant has conveniently used summer-time imagery, when trees are in full leaf, to mask the true visual impact of the towers.
9.3 In reality, the proposed development will loom over the Sir Joseph Hood Memorial Playing Field, damaging the open aspect of the public park, which is enjoyed by the residents in Old Malden and Motspur Park and visitors from further afield.
10. Conclusion
For the above reasons the Raynes Park and West Barnes Residents’ Association urges the Planning Committee of the London Borough of Merton to refuse this application.
Submitted by Jerry Cuthbert (Committee Member)
Raynes Park and West Barnes Residents’ Association
Motspur Park Gas Holders - Planning Application
MARCH 2026
Berkeley Homes planning application to Royal Borough of Kingston upon Thames (RBK) for the redevelopment of the Gas Holder site in Motspur Park (Application Ref: 25/02562/FUL) is due to be considered by RBK's Planning Committee on 11 March 2026. The Planning Application will be considered at the Planning Committee to be held at Guildhall, Kingston upon Thames, KT1 1EU on Wednesday 11 March 2026 at 7:30 pm.
The agenda will be published on the Council website five clear working days before the meeting and can be found at the following link: https://www.kingston.gov.uk/your-council then follow “Council meeting calendar”.
Due to the proximity of the site to Merton, the application has also been submitted to the London Borough of Merton (Application reference 25/P2859).
PREVIOUSLY ...
A dedicated website set up by a local resident, encouraging us all the “get involved”, provides an excellent list of the key matters of contention in the applicant’s planning documents, may be found here:
https://motspurparkgasholdersgetinvolved.com/
It also suggests the crucial issues to raise in your objections to Planning Committee for the Royal Borough of Kingston upon Thames and the London Borough of Merton. This website is being updated on a daily basis.
Our neighbouring residents’ association, Station Estate Residents’ Association Kingston (SERAK) has also set up a very informative website, that very clearly sets out the various points of objection to this planning application, together with links to the Kingston Planning Dept website, where you can view all the details of the Berkeley Homes planning application.
https://www.motspurparkgasholderstoptheoverbuild.com/
All members of the public, whether resident in Kingston or not, are entitled to submit their objections to this planning application to both Kingston and Merton.
Our Association's objection submitted to Kingston may be read HERE.
