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
