Local developments
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
Motspur Park Gas Holders - Planning Application
NOVEMBER 2025
Berkeley Homes has now submitted its planning application to Royal Borough of Kingston upon Thames for the redevelopment of the Gas Holder site in Motspur Park (Application Ref: 25/02562/FUL).
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).
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.
Objections must be submitted to Kingston before 12 December 2025 and to Merton by 10 December 2025.
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.
Motspur Park Gasholders - August 2025
PROPOSALS BY BERKELEY HOMES AND SGN TO BUILD 650 NEW HOMES ON THE SITE OF THE MOTSPUR PARK GAS HOLDERS
Where to begin?
As the recent flurry of interest about the development of Motspur Park (spearheaded by Toby Ewin’s enthusiasm) has clarified, prior to the construction of Motspur Park Station, the area was still known as West Barnes.The three gas holders which were built in the 1924, 1932 and 1954 respectively, were known formerly as the Worcester Park Gas Holders.
Originally owned by WANDGAS, the Wandsworth, Wimbledon and Epsom District Gas company - the name of which lives on and is well-known to local youngsters who play football in their grounds and to members enjoying convivial activities in the clubhouse - the holders served a wide area of South London. However, the system of distribution has altered, and gasometers are no longer required, because gas is now stored underground.
Which Borough?
Although the holders are located almost entirely on land owned by Kingston Council, residents of two boroughs, namely Merton and Sutton & Cheam will be impacted heavily, both during construction and after completion.
Who has been consulted?
Despite some well organised public presentations, many of the communities surrounding the proposed development area were not informed and are now sharing information through Residents’ Groups, various WhatsApps and the dedicated website:
https://motspurparkgasholdersgetinvolved.com/
Bearing in mind the need for housing, what are some of the concerns about the Berkeley proposals?
1. Despite assertions in the developer’s publicity, the gasometers are NOT unloved. They are viewed as familiar structures, signalling “home to many, portrayed artistically by urban photographers, and forming the basis of a recent master’s degree in fine arts by Sarah McAlister. Thhe proposed heights are out of keeping and unacceptable. Even though Berkeley’s have discussed reducing from 18 to 16 storeys, this would still overwhelm the local area. The gas holders can be seen from miles around and are an accepted, see-through landmark.
2. There are huge concerns about the inevitable increase in traffic in all the surrounding areas. For instance, the level crossing beside Motspur Park station is already massively congested – and similar problems occur in the other areas which border the site.
3. Although part of the “offer” is an improvement in awareness of biodiversity, this makes no sense in terms of the current situation. The Sparrowfeld Group are concerned about the effect that the development will have on the flourishing bird community, and the Friends of Sir Joseph Hood Memorial Playing Fields are concerned about the effect on the rich mix of flora and fauna in the wonderful SJHMF.
THE KINGSTON SOCIETY'S POSITION
The Kingston upon Thames Society, founded in 1962 and affiliated to the Civic Trust, is Kingston's major voluntary and independent organisation concerned with planning and conservation. The Society has no statutory right of consultation. A link to their website can be found in the comments.
The mission of the Society is to promote high standards of planning, conservation and design in the Royal Borough. Following the third consultation, the Society has stated the following as its position:
1. As the site is Metropolitan Open Land (MOL), there is a strong presumption against any form of built development. Furthermore, the site is not identified in RB Kingston’s Tall Buildings Strategy as being suitable for the sort of tall buildings that are being proposed. In addition, the PTAL (Public Transport Accessibility Level) for the site is 1 and only reaches 2a/2b closer to Motspur Park Station. The access route for pedestrians to the site from the station is down a long and poorly overlooked path which gives rise to concern about the personal safety of users particularly on winter evenings and nights.
2. For all the above reasons, the Society does not consider the site is suitable for the type and amount of residential development which is proposed. The Society is also aware of the existing and potential nature conservation value of the site with one Site of Interest for Nature Conservation (SINC) being within the red line boundary and another immediately adjoining on the other side Beverley Brook. The brook itself is also of nature conservation value and on a visit to the site which was kindly facilitated by the developer, herons and a peregrine falcon were observed.
3. In light of the above, the Society considers that any development of the site would need to be significantly reduced from the level set out in the pre-application consultation details. It would need to be at a level such that the integrity and value of the wider area of MOL within which the site is located was not compromised and such that the nature conservation interest of the site was not reduced. Indeed, the principles of biodiversity net gain (BNG) would indicate that a positive nature conservation benefit should result.
4. We very much welcome Berkeley’s intention to restore the banks of Beverley Brook and increase public access to it. However, the Society’s view is that any built development of the site should only be considered within the floor plan/site area of the existing gasholders and should be much reduced from the height of the existing gasholders and the heights set out in the pre-application consultation. It is understood that there will be some retention on site of an operational gas facility and clearly there will need to be appropriate safety measures taken including decontamination before an acceptable development proposal can be produced.
WHAT NEXT?
The latest communication we have received from Berkeley Homes indicates that the firm is looking again at some aspects of the plans.
We are aware that Kingston is the planning authority making the decisions, but in this very unusual case, the boundaries, roads and green spaces involved are split between three boroughs, and it is important to ensure the best outcomes for all residents. We will hold a meeting about the development to keep you updated.
Do keep in touch with fast-moving developments via the dedicated website:
https://motspurparkgasholdersgetinvolved.com/
Many thanks to everyone who has attended the various presentations and
responded to the consultation.
Report by Clare and John Townsend on behalf of the RPWBRA.
Rainbow Ind Estate - New Plans
Some Background
Some of our members may recall that, when the Rainbow Industrial Estate was owned by Workspace, the company obtained planning permission to redevelop the site.
This industrial estate is located between the railway lines, adjacent to the south-west side of Raynes Park Station. Its access is down a private road at the junction of Grand Drive and Approach Road. (SW20 0JY).
These planning permissions were:
14/P4287 for a mixed-use redevelopment of the industrial estate comprising 224 residential units and 37,000 sq. ft. of new light industrial space, and,
14/P4288 for a “Kiss and Ride” drop-off and pick-up area on the south side of the Station
Although the scopes of these two planning approvals have been partially built, neither has been completed.
On the 8 November 2024, Workspace announced it had sold the partially redeveloped site.
April 2025 - New Plans
Some members have recently received a notice from the new owners that they intend to submit a new planning application, for which a public consultation is running from 22 April 2025 to 6 May 2025.
The information is available at https://rainbowindustrialestate.co.uk/
The notice is shown below:
Merton Building Control
In July 2024, we received the following useful information from Building Control at the London Borough of Merton
From: Building Control <This email address is being protected from spambots. You need JavaScript enabled to view it.>
Our telephone lines are open from 9am-12pm (Midday) on weekdays: 020 8545 3145 or 020 8545 3931. Our surveyors take calls between 2-5pm. For Dangerous Structures call the above numbers, if these are busy or you are calling outside of office hours call: 020 8543 9750.
Your enquiry can often be resolved with these frequently used resources:
Building Control
Building Control Application Forms & Fees
Booking Inspections
We take bookings via the official LABC App:
Planning
Do I need Planning Permission/Permitted Development Rights
If you are a flat, maisonette or a Listed Building you do not benefit from permitted development and you will require the formal consent of the Council.
Should you require a formal determination that you do not require Planning Permission from the Local Planning Authority, you would need to apply for a Lawful Development Certificate. Details of these and how to apply can be found on the Planning Portal link.
If your proposal doesn’t fall within Permitted Development, you can also apply for Planning Permission from the Planning Portal website.
Planning Guidance, Pre-Application advice and Planning Enforcement
Property Searches and Land Matters
Planning & Building Control Documentation/Decisions/S106/TPO’s
Historic documents can be requested by contacting the relevant email address:
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Listed Buildings/Locally Listed Buildings
Land Ownership
We do not hold records of land ownership, please contact Land Registry at;
Land Registry Office, Trafalgar House, 1 Bedford Park, Croydon, CR0 2AQ
0844 892 1111.
Party Wall
We do not deal with Party Wall queries, information can be found on the central government website.
Boundary Disputes
This is a civil matter, you would need to seek Legal advice. If you do not have your own representative, you can to speak to the Merton Citizens Advice Bureau.
Housing and Planning Guidance
We draw attention to the speech by the Prime Minister on 6th March regarding the “housing crises” and the provision of “affordable “housing. The Government is concerned about both the shortage and cost of housing. It appears that developers are permitted to aim for a “suitable return “(i.e. profit) of 20% but often claim that they cannot achieve this AND at the same time deliver the proportion of social subsidised housing - either for sale or rent - which Councils want.
The Government is suggesting that the ‘viability assessment ‘(through which developers can submit that they can only achieve a 20% profit on a scheme by reducing the proportion of social housing required by Councils) should be made public except in exceptional circumstances. Also, there is a proposal to urge developers to aim for a profit margin of about 6% when building social housing with the aim that this would guarantee an ‘end-sale ‘at a known value. It appears that the Government is keen to increase housing supply by encouraging developers to build more blocks of flats and convert and build on top of existing shops and offices provided that the final scheme is not higher than buildings in the immediate vicinity. In short, to build upwards.
The ‘permitted development ‘provisions (which originated in 2013 and currently extend to 2019) may also be amended to permit ‘upwards ‘extensions provided the extension is “consistent with the prevailing height and form of neighbouring properties”.
The Mayor of London (the Greater London Authority) is currently consulting on revisions to the London Plan (the GLA Planning Guidance document). One of the recommendations is that London Councils should seek an “affordable” housing contribution of at least 35% but for large schemes, e.g. on former industrial sites, they should aim for a 50% contribution. Such a high figure would probably meet with strong opposition by developers who would argue that they could not make a reasonable profit AND provide half the housing for ‘social’ needs.
David Freeman - May 2018
