NK13-NK18 Environmental Policies
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5.61 The forecast changes in the climate of urban London are stark through 2050 and beyond. Although parts of North Kingston benefit from the cooling effect of the Thames and the proximity of Richmond Park, the area itself is dense in character with few open spaces and no water bodies.
5.62 Aside from tackling the causes of climate change, some harmful change is already unavoidable in respect of more extreme weather such as heat-waves, droughts and heavy rainfall/flooding. It is therefore crucial to the future of the area for living, working and recreation that measures are taken, using the planning system, to moderate these effects, primarily through investing in improving climate resilience and in protecting and creating new green infrastructure. The plan is positive about growth and each site has been considered within the context of the challenges of climate change. For example, key development principles include requirements for improvements to existing amenity space, or the creation of additional open space, tree planting in landscape schemes, all of which will become very important to North Kingston in years to come. Additionally, the Neighbourhood Plan strategy comprises four complementary policies that together will go some way to ensuring that every opportunity is taken to address this issue. The scale of change in North Kingston will present these opportunities and must not make matters worse.
5.63 New development will be expected to follow best practice in protecting the existing communities of North Kingston and fully mitigating any adverse impacts on the built and the “natural” environment and by demonstrating the crucial importance of tackling climate change.
Policy NK13: Climate Change Mitigation – New Buildings
A. All development must be ‘zero carbon ready by design’ to minimise the amount of energy needed to heat and cool buildings through landform, layout, building orientation, massing and landscaping.
B. Wherever feasible, all buildings should be certified to a Passivhaus or equivalent standard with a space heating demand of less than 15KWh/m2/year. Where schemes that maximise their potential to meet this standard by proposing the use of terraced and/or apartment building forms of plot size, plot coverage and layout that are different to those of the character area within which the proposal is located, this will be supported, provided it can be demonstrated that the scheme will not have a significant harmful effect on the character area.
C. All planning permissions granted for new and refurbished buildings should demonstrate that they have been tested to ensure the buildings will perform as predicted and will include a planning condition to require the provision of a Post Occupancy Evaluation Report to the Local Planning Authority within a specified period, unless exempted by Clause B. Where the Report identifies poor energy performance and makes recommendations for reasonable corrective action, the applicant must demonstrate that those actions have been implemented before the condition will be discharged.
D. All planning applications for major development are also required to be accompanied by a Whole Life-Cycle Carbon Emission Assessment, using a recognised methodology, to demonstrate actions taken to reduce embodied carbon resulting from the construction and use of the building over its entire life.
E. An Energy Statement will be submitted to demonstrate compliance with the policy (except for householder applications). The statement will include a passive design capacity assessment to demonstrate how opportunities to reduce the energy use intensity (EUI) of buildings over the plan period have been maximised in accordance with the energy hierarchy. Designers shall evaluate the operational energy use using realistic information on the intended use, occupancy and operation of the building to minimise any performance gap.
5.64 This policy is in five parts, the combination of which is intended to deliver a step change in the energy performance of all new developments in the neighbourhood area and, in doing so, encourage and incentivise the use of the Passivhaus or equivalent standard of building design. Along with the passive design capacity assessment, it is anticipated that designers will demonstrate compliance using a design for performance methodology such as the Passivhaus Planning package or CIBSE TM34 Operational Energy. Achieving this level of performance will make a significant contribution to mitigating climate change that the Neighbourhood Plan can deliver.
5.65 Clause A of the policy requires developers to ensure they address the Government’s climate change targets and energy performance at the very initial stages of design. ‘Zero Carbon Ready by Design’ means making spatial decisions on layout and orientation of buildings at the outset to maximise the passive design benefits (‘free heat’) of a site and avoids leaving this to technical choices and assessment at the Building Regulation stage, by which time the opportunity may have been lost.
5.66 Its Clause B requires all schemes, no matter what their intended use or size other than householder extensions, to use the Passivhaus Planning Package (PHPP) or equivalent design methodology for all buildings where it is feasible to do so. This means that the applicant must demonstrate those factors that make its use unfeasible, for example, the topography and orientation of the site.
5.67 In respect of scheme viability, any extra over cost of building to the ‘zero carbon ready’ Passivhaus standard (now less than 5%) will diminish to zero well within the period of this Plan, as per both the Governments Regulatory Impact Assessments and research by the Passivhaus Trust. The policy will also ensure that expensive and unnecessary retrofit costs are not passed down to building occupiers in the future, particularly in an area which has relatively high property values. Scheme viability will not therefore be acceptable as a reason for not using the Standard, unless the applicant can demonstrate the scheme has abnormal costs to accommodate.
5.68 The policy requires that the scheme density (measured by dwelling units/Ha) is assessed against that of the local ‘character area’ in the Design & Access Statement. Where that area is part of a designated Conservation Area for which there is an appraisal defining its character, then the applicant will be expected to use that as the baseline for the Statement. Outside of such areas, the applicant may define the ‘character area’ that is relevant for the purpose of this exercise.
5.69 Proposals seeking to apply the PHPP must be able to demonstrate that the Passivhaus standard can be achieved. Prior to commencement a ‘pre-construction compliance check’ completed by a Passivhaus Designer accredited by the Passive House Institute (PHI) will be required and secured by condition. Upon completion a Quality Approved Passivhaus certificate for each building will be required prior to occupation, again secured by condition.
5.70 Clause C requires the developer of a consented housing development scheme of any size to carry out a Post-Occupancy Evaluation (POE) including actual metered energy use, and to submit the report to the local planning authority. It will be implemented by attaching a planning condition, which will only be discharged once the report has been submitted and any recommended actions to rectify any performance gap with the design stage assessment are carried out by the developer. Passivhaus certified schemes will not fail in this way and they are therefore exempted from this policy requirement.
5.71 The policy complements Policies CS1 and DM1 of the Kingston Core Strategy and is in accordance with Policy SI2 of the London Plan 2020 as Clause D requires all development proposals that are not householder applications to be accompanied by a Whole Life-Cycle Carbon Emissions Assessment. This requirement will be added to the Kingston Validation Checklist for outline and full planning applications applying to proposals in the neighbourhood area until such a time that there is a borough-wide requirement.
5.72 Clause E requires an Energy Statement to be submitted to cover the following:
an assessment of the proposal to minimise regulated and unregulated emissions, the embodied emissions and the emissions associated with maintenance, repair and replacement of the new building(s), as well as its dismantling, demolition and eventual material disposal
a calculation of the energy and carbon emissions covered by the Future Homes Standard and Building Regulations and, separately, the energy demand and carbon emissions from any other part of the development that are not covered by the Future Homes Standard or Building Regulations
the proposal to reduce carbon emissions beyond the Future Homes Standard and Building Regulations through the energy efficient design of the site, buildings and services
the proposal to further reduce carbon emissions through the use of zero or low-emission decentralised energy where feasible
the proposal to further reduce carbon emissions by maximising opportunities to produce and use renewable energy on-site, utilising storage technologies where appropriate
the proposal for a demand-side response, specifically through installation of smart meters, minimising peak energy demand and promoting short-term energy storage
an analysis of the expected cost to occupants associated with the proposed energy strategy
5.73 Every new build or redevelopment project in the neighbourhood area provides an opportunity to make a difference and a contribution towards meeting our climate change targets for 2050. This new information requirement need not be an unreasonable expectation of even the smallest schemes for new buildings. Land values in the area are high relative to build costs and ought to be sufficient to ensure requirements to tackle improving energy and carbon performance are viable.
5.74 An industry consensus is emerging on the key sustainable outcomes, which are expected to become the standard measurables for all projects in the future. RIBA itself intends to fully embed sustainability into its Plan of Work and provide the means for teams on any project to target sustainable outcomes in the brief, manage their delivery through each stage and undertake meaningful analysis up to three years after handover.
Policy NK14: Climate resilience
Development proposals should contribute to increasing the resilience of North Kingston to climate change as set out in the London Plan. Specifically, proposals will only be supported where they achieve an Urban Greening Factor of at least 0.5 for developments that are predominately residential and of at least 0.4 for predominately commercial development to take account of the relatively dense urban character of North Kingston.
5.75 The London Plan has introduced the principle of an Urban Greening Factor (UGF) to encourage more and better urban greening as the prime means of increasing climate resilience. The model assists in determining the appropriate provision of urban greening for new developments and is explained in detail in its Policy G5. Urban greening should be a fundamental and integral element of site and building design in the future, incorporating measures such as high-quality landscaping (including trees), green roofs, green walls and nature-based sustainable drainage.
5.76 Policy G5 sets targets for new residential (a factor of 0.4) and commercial (0.3) uses and only applies to major applications. However, the Mayor acknowledges that the model may be applied to smaller proposals so that it is appropriate to each local circumstance. North Kingston is a relatively densely populated urban and suburban area with almost all its green infrastructure on or beyond its fringes. With significant intensification in parts of the area in the coming years, there is a premium on making a step change in its climate resilience. It is therefore reasonable to adopt a higher UGF target than the Mayor and, given land values and the positive approach taken to enabling new development, there is no reason to believe that the target will undermine the viability of new developments.
Policy NK15: Green infrastructure
The Neighbourhood Plan identifies a Green Infrastructure Network, as shown on the Policies Map, for the purposes of promoting sustainable movement and ecological connectivity through and beyond North Kingston. The Network comprises parks, the riverbank, front gardens, street trees, public amenity land, allotments, footpaths, and cycleways. This provides the primary framework for the purposes of promoting sustainable movement and ecological connectivity throughout the whole of the Neighbourhood Area and beyond.
The landscape, biodiversity, open space and access proposals of new development schemes located within the Network should by reference to nationally adopted guidelines or other appropriate recognised criteria demonstrate how the scheme will maintain or enhance the function of the Network. All landscape proposals should include native species and habitats and should demonstrate a net gain in biodiversity.
5.77 The London Plan requires that the city’s network of green and open spaces, and green features in the built environment should be protected and enhanced. It encourages green infrastructure to be planned, designed and managed in an integrated way to achieve multiple benefits. Neighbourhood Plans can identify local green infrastructure features and can identify opportunities for addressing local environmental and social challenges through specific policy actions (Policy G1).
5.78 The policy requires that all development proposals that lie within or adjoin the Network, should consider how they may improve it, or at the very least do not undermine its integrity of connecting spaces and habitats. This may mean that scheme layouts, access points, landscape schemes and amenity spaces are designed to contribute to the effectiveness of the Network where possible without undermining other planning policy objectives.
5.79 In some cases, proposals will enable the creation of new green infrastructure assets that ex-tend the benefits of the Network, and the Forum has identified some of these cases outlined in Plan L earlier and Plan M overleaf. They will be supported provided they are appropriate in other respects and include:
A new Green Corridor(GC) - linking existing Green Corridors with our parks and open spaces via the Neighbourhood Heart at the junction of Acre Road and Kings Road. There are four designated Green Corridors in North Kingston;
GC-i: The Railway Line,
GC-ii: The southern stretch of Canbury Gardens,
GC-iii: Skerne Road and
GC-iv: Richmond Road.
A new Green Secondary Route(GSR) - the proposed new Green Secondary Route will strengthen connectivity from Canbury Gardens to the Neighbourhood Heart and beyond via Acre Road, enhanced by new pocket parks and other potential improvements (see policy NK17 and Plan M).
A network of new Family Friendly Routes(FFR) -
FFR-vi: Linking the Acre Road Green Secondary Route to Kingston Hill
FFR-vii: Linking Park Road to Latchmere Lane via Sopwith Close
FFR-viii: Linking The Kingston Academy to Latchmere Recreation Ground
FFR-ix: Linking Burton Road to Elm Recreation Ground via Acre Road
FFR-x: Linking the Riverside Green Corridor to Ham via Kingsgate Road, Acre Road, Latchmere Lane
FFR-xi: Linking the Skerne Road Green Corridor to Richmond Road via Lower Ham Road
FFR-xii: Linking the Acre Road Green Secondary Route to Latchmere Lane via Dinton Field and Latchmere Recreation Ground
FFR-xiii: Linking Kings Road to Latchmere Recreation Ground via The Keep
FFR-xiv: Linking Richmond Road to the Riverside Towpath via Grosvenor Gardens
5.80 The Family Friendly Routes complement the pedestrian and cycling paths indicated in policy NK13 Access and Movement where the function of those route could be improved and enhanced to facilitate easier access for all members of the community and prioritised for those with reduced mobility where possible.
5.81 Green Corridors are relatively continuous areas of open space that allow plants and animals to be found further into the built environment as covered in Policies CS3 and DM5 of the Core Strategy, and identified on the Royal Borough’s GIS Open Data Portal INSPIRE. Recommendation is made to continue with the full recognition of the existing Green Corridors, and in addition to the proposed new Green Corridor, consideration should be given to extend the existing 3 Northbound Green Corridors to the Ham Border and beyond, further encouraging and supporting increased biodiversity and wildlife connectivity in the Plan area. This is particularly important along the river’s edge and the section of Lower Ham Road adjacent to Canbury Gardens.
5.82 The North Kingston Forum welcomes and wishes to continue its productive relationship with its neighbour, the Ham and Petersham Neighbourhood Forum and in collaboration with Kingston and Richmond Borough Councils to deliver improved sustainable transport connectivity between Kingston and Richmond Town Centres.
Policy NK16: Local Green Spaces
The Neighbourhood Plan designates the following locations as Local Green Spaces, as shown on the Policies Map:
i. Latchmere Recreation Ground;
ii. Elm Road Recreation Ground;
iii. Dinton Field;
iv. Canbury Gardens;
v. Hawker Centre sports pitches;
vi. St Luke’s Vicarage garden;
vii. 1st Kingston Hill Scouts green space;
viii. WWII V2 Rocket Memorial sites;
ix. [Park Road Allotments]
x. [Wolsey Drive Allotments]
xi. [Parkfields Allotments]
xii. Canbury and Tudor Riverside to the Richmond border
Proposals for development will be considered inappropriate unless they are of a type that is exempted by national policy on the Green Belt. Proposals for inappropriate development will only be supported if very special circumstances can be demonstrated.
5.83 The NPPF enables local communities to identify for special protection green areas of particular importance to the community. By designating land as a Local Green Space, local communities are able to rule out new development other than in very special circumstances. The effect of Policy NK16 is therefore to provide Local Green Spaces with the same protection as that which applies to the Green Belt or Metropolitan Open Land.
5.84 To create a consistent and transparent methodology for evaluating potential Local Green Space, the Forum used a robust assessment process. Each space is considered to meet the tests set out in paragraph 100 of the NPPF. This is demonstrated in the separate Local Green Space Study.
5.85 The majority of respondents to the consultation on the initial Draft Neighbourhood Plan carried out in 2019 agreed that many existing open spaces “could benefit from enhancement”. Protecting spaces from inappropriate development in this way contributes to our strategy in mitigating the effects of climate change.
5.86 It is acknowledged that Canbury Gardens, Hawker Sports Pitches, and two sections of Canbury Riverside, are already designated Metropolitan Open Land. Although the NPPF discourages the unnecessary duplication of policies, the Borough Council’s Early Engagement Document May 2019 signals that there may be a scenario where development could be considered on protected land. The Forum recognises that this is mainly in the Hogsmill Valley and Tolworth areas, and parts of the Green Belt in Chessington. However, as these spaces meet the tests set out in paragraph 100 of the NPPF, the Forum believes that local people will want to cover all those spaces that qualify for the designation.
5.87 Canbury Riverside is a part of the Thames Policy Area as outlined in the London Plan (Policy SI14 Waterways) and considered a critically important asset to the North Kingston community, by providing environmental, economic and health and wellbeing benefits.
5.88 Additionally, the river Thames is also a wildlife super highway, a linear corridor that allows wildlife to move between open spaces and is home to seven species of bats, although their numbers are constantly threatened from development, inappropriate lighting and habitat loss. The Thames Landscape Strategy gives guidance to the long-term planning of the river and the careful conservation of riverside habitats. This guidance aligns with our environmental policies and will be prioritised as part of the Neighbourhood Plan.
5.89 Canbury Gardens is a well-loved and popular green space with a distinct history facing a range of challenges as an increasing population places greater demands on our favourite amenity. The council’s proposed Masterplan sets out a holistic vision for future landscape and public realm improvements, which will help preserve and enhance the gardens for existing and future users and will be prioritised as part of the Neighbourhood Plan.
Policy NK17: New Pocket Parks
Proposals to change the use of land to create new Pocket Parks will be supported in the following locations, as shown on the Policies Map:
i. Richmond Park Road
ii. Gibbon Road
iii. East Road
Proposals to develop adjoining land should have regard to the public use of a new park in respect of the Agent of Change principle and must not undermine the future provision of a park.
5.90 The London Plan encourages the creation of new public realm in its Policy D7. Aside from the public realm improvements identified in Policy NK18, the Forum has identified three locations for the creation of small pocket parks utilising both derelict and current highways land. The parks will play an important local role in the North Kingston strategy of tackling climate change and will provide a new outdoor play resource in an area that lacks such public facilities. These pocket parks will be-come an important part of the proposed new Green Secondary Route, and therefore help to further link the Green Infrastructure Network as outlined in Policy NK15.
5.91 This policy also seeks to ensure that future proposals to develop land in these locations have proper regard to these proposals and to the parks once installed. The London Plan ‘agent of change’ principle (of Policy D12) will apply to ensure that the ongoing public enjoyment of the parks is not undermined by those proposals.
5.92 The Acre Road is within the Critical Drainage Area CD008 and the Borough may be exploring a Flood Alleviation Scheme for the Acre Road Area and will be updating their Surface Water Management Plan in due course. We would expect the most up to date Strategy to be implemented and prioritised as part of the Neighbourhood Plan. This policy additionally seeks to ensure that Pocket Parks are part of the wider Borough strategy for sustainable drainage (SuDS).
Policy NK18: public realm
Development proposals in the following locations, as shown on the Policies Map, will be required to contribute to the improvement of the immediate public realm:
Northern entrance gateway – Ham parade junction Tudor Drive/Duke’s Ave/Richmond Road
Southern Entrance gateway: below Kingston Railway Bridge
Southern Entrance gateway: Skerne Road, below Kingston Railway Bridge
Southern Entrance gateway: Richmond Road – Kingston Station
South eastern Entrance gateway: Park Road/ roundabout
Eastern entrances Queens Road: junctions with King’s Road, New Road, Tudor Road
Southern entrance Canbury Park Road/Queen Elizabeth Rd/ under rail bridge
Junction of Kings’ Road/ Acre Road
Junction of Richmond Park Rd /Acre Rd /Cross Rd
Latchmere Recreation Ground
Proposals shall either carry out improvement works in accordance with an agreed scheme if the proposal comprises land in or adjoining the public realm or shall make an appropriate financial contribution to meeting the costs of the scheme through a planning obligation.
5.93 The London Plan requires that “opportunities to create new public realm should be encouraged and explored where appropriate” in its Policy D7. The Forum has identified a series of such opportunities and has received significant support from the local community for their inclusion in this policy. A separate Public Realm Study describes each location and the opportunities for improvement.
5.94 This policy requires development proposals in these opportunity areas to contribute to their implementation. Some types of proposal may include land within the public realm and may therefore directly contribute through their design. Others may not have this potential, but their close proximity will mean they will benefit from improving the attractiveness of the immediate area, and so a financial contribution is justified. The Forum will liaise with the Council and with local landowners and business operators to agree the specification and financing of each improvement scheme.
Plan M: Some of the opportunities available to enhance North Kingston’s Green Infrastructure Network