KKG – Document 31 KKG – Document 32

Dear Neighbour

As you may have read in the extract from the LOSRA Spring 2014 newsletter which was circulated last week, Spelthorne’s Chief Executive, Roberto Tambini, wrote the following, which are the first two sentences of his message which was posted on the LOSRA website on 18 December 2013.

“We welcome this opportunity to make our position on Kempton Park completely clear. As you would expect the Council has regular discussions about future business plans with all the major operations within the borough, including Kempton, but it has not seen or discussed building plans for any development on this site.”

Attached (KKG Document 32) is an exchange of emails in early July last year between the Spelthorne Head of Planning and Mark Boyes, Development Director of Aspire, consultants to the Jockey Club. Read the emails from the bottom up.   The messages indicate that Spelthorne had, indeed, discussed plans for development of the Kempton Park estate – more than five months before Mr Tambini’s text was written.

In fact the messages indicate much more than that. Please note the reference in the email from the Head of Planning to Mark Boyes on 2 July:

“Is there a high level timetable you can share with us re milestones for stages to reach planning application submission by third quarter 2014 please?”

And Mark Boyes’ reply on 4 July:

“…at present I am not able to provide you with our planning milestone programme, however we are adhering to SBC’s timetable of Quarter 4 2014 for a submission.”

SBC’s timetable?

Who is driving this thing forward? The Jockey Club? Or Spelthorne Borough Council?   We think they should come clean on this one…

And just to give you an idea of how much discussion has been taking place, KKG Document 31 (attached) is the pile of documents received so far by fellow residents who have submitted FOI requests to various governmental bodies.

This pile does not include the many documents received by email, or the many more documents not released at all, in order to spare the blushes of The Jockey Club and the Council. But they are still coming in by the bag-full.

The documents relate to an 18 month period. And cover many aspects of the proposed development. Is this what the Council means by “regular discussions”?

As ever, these documents are in the public domain.

Please feel free to pass them on.

Please encourage your neighbours to join the mailing list.

There is more to come, in due course, over coming weeks.

Yours

Keep Kempton Green

KKG – Document 29  KKG – Document 30

Dear Neighbour

Attached are the front page articles from the LOSRA Autumn 2013 and Spring 2014 newsletters.

As ever, these documents are in the public domain. Please feel free to pass them on.

Please encourage your neighbours to join the mailing list.

There is more to come, in due course, over coming weeks.

Yours

Keep Kempton Green

KKG – Document 26

Dear Neighbour

Now it’s shops as well …

Attached (KKG Document 26)  is a brief exchange of emails between Ramboll UK (one of The Jockey Club’s multifarious consultants) and Natural England, dated 20 Sep last year. It includes the by-now-familiar Area of Research map, and a brief note from Ramboll UK. The development is, in this letter, stated as being for 1500 residential units and (not the 1000 to 1500 unit range mentioned in correspondence we have previously circulated). This is such a large development that it needs 10 supporting commercial units to go with it.

We wonder whether the Waitrose supermarket suggested by one member of the Spelthorne Planning Committee at a meeting at Kempton Park is one of them?

As ever, this document is in the public domain. Please feel free to pass them on.

Please encourage your neighbours to join the mailing list.

There is more to come, in due course, over coming weeks.

Yours

Keep Kempton Green

KKG – Document 11 (abridged)

Dear Neighbour

Please find attached (KKG Document 11) an abridged version of the Traffic Feasibility Study for the development at Kempton Park.

In order to reduce the size of the file, we have omitted Appendices F and H, which contain pages of data output from the transport model used by Mouchel.

The forecast extra traffic numbers during peak hours from a development of 1500 units at Kempton Park are on page 3 of Appendix C. During the AM peak, an extra 979 vehicles are forecast to travel in one direction or the other along the A308 between Sunbury Cross and Hampton Court. Given that car ownership in Sunbury is two per household or more, this appears to be a low estimate. Even so, Mouchel assume approximately 1000 extra cars on the local roads during rush hour …

The forecast distribution of these cars on the local road network during the AM peak is shown on the diagram D013 on page 5 of Appendix C. 78% of the extra traffic is forecast to turn right out of the proposed suburb of 1500 units at Kempton Park during the AM peak, and travel towards Sunbury Cross. This entrance/exit would in itself reduce the traffic flow on the A308, as the right-turning (westbound) traffic during the AM peak would have to turn in front of traffic travelling eastbound towards Hampton Court, and join the peak hour queue of traffic traveling westbound towards Sunbury Cross.

20% of cars from Kempton Park are assumed to turn left during the AM peak and travel in the other direction towards Hampton Court and beyond – to Richmond, Kingston and across Hampton Court Bridge towards the A3.

This distribution of the extra Kempton Park traffic is based on an assumption that the employment and lifestyle characteristics of the residents of the new suburb at Kempton Park will mirror those of the existing residents of Sunbury East. The Borough of Richmond, however, asked Mouchel to run the simulation again, but this time using the employment and lifestyle characteristics of the residents of Hampton Ward, our neighbours on the eastern edge of Spelthorne. The result are shown in diagram 1048911-D016-D01A in Appendix D.

Assuming that the residents of the new suburb behave more like residents of Hampton than Sunbury East, the extra traffic towards Sunbury Cross in the AM peak would only account for 2/3 of the total. Nevertheless, although traffic joining the (southbound) M3 is forecast to be significantly less, traffic on the (northbound) A316 would be more than 20% higher.

The remaining third would travel towards Hampton Court. The extra volume of traffic turning left at the Hampton Triangle would be more than triple (17% of the total as opposed to 5%) the number forecast to take that route under the Sunbury East assumption. The extra traffic volume travelling along the side of Hampton Court towards Kingston would be more than 40% bigger.

So, the traffic gets significantly heavier than it already is in both directions, with the direction of travel worst affected depending on how the new residents behave. And this would be on a ‘normal’ day. Don’t forget the week of the Hampton Court Flower show, and all the other events during the year which already cause very heavy traffic congestion on local roads on a regular and frequent basis.

Mouchel have been searching for ways to add this extra traffic to the local roads without causing a permanent gridlock. Hence the proposed massive redevelopment of Sunbury Cross (see KKG – Document 2 sent previously), and hence the proposed reworking of the traffic arrangements at the Hampton Triangle (Appendix G in KKG – Document 11) and the Hampton Court roundabout (Appendix E in KKG – Document 11). The proposed schemes don’t give us any confidence that they could make much of a difference to the existing over-burdened roads, never mind with the extra burden of a new suburb at Kempton Park.

As ever, these documents are in the public domain. Please feel free to pass them on.

Please encourage your neighbours to join the mailing list.

There is more to come, in due course, over coming weeks.

Yours

Keep Kempton Green

KKG – Document 10  KKG – Document 8

Dear Neighbour

Who knew what, when?

The question matters because, at some stage between the beginning of 2012 and the middle of 2013, it seems (we are told) that the plans for Kempton Park changed from a much smaller scheme to be built along the western and southern edges of the Kempton Park estate (bordering the racecourse section of the land), to a much larger scheme for up to 1500 units – possibly bigger – on the eastern half of the Kempton Park estate. (Although, since the entire estate is Green Belt, any development there would be contrary to the current Spelthorne Local Development Plan.)

What we can say definitely so far is:

1. One of Surrey County Council’s Transport Officers on 5 Jun 2013 mentions (see KKG Document 8 attached) being invited to a meeting on 2 Jul 2013 to discuss a potential development of 1500 to 2000 dwellings. That meeting was requested by Mouchel (The Jockey Club’s transport consultants) and was to be held at the Highways Agency office in Dorking.

2. We know from emails released to us between Ramboll UK (a civil engineering consultancy) and the Environment Agency that the EA knew on 7 Jun 2013 of the plans to build on the eastern half of the Jockey Club Estate.

3. Richmond Borough Council knew, at the latest, on 9 Jul 2013 about proposals for a development of 1000 to 1500 units at Kempton Park (see KKG Document 10 attached). That meeting, in Twickenham, was also attended by Mouchel and Transport for London.

So, by 5 Jun last year, Mouchel, the Highways Agency, and Surrey County Council knew of the larger scheme. By 7 Jun, the Environment Agency knew. By 9 Jul, at the latest, Richmond Borough Council and Transport for London knew.

Bearing in mind that a lot or preparatory work would have had to be done by The Jockey Club’s consultants before any of these meetings were arranged, the question is:

When did The Jockey Club first change their mind about the size of the development, and when did they tell everyone else not included in the correspondence and meetings detailed above?

As ever, these documents are in the public domain. Please feel free to pass them on.

Please encourage your neighbours to join the mailing list.

There is more to come, in due course, over coming weeks.

Yours

Keep Kempton Green

KKG – Document 5 KKG – Document 23 KKG – Document 24

Dear Neighbour

One of the documents we circulated previously (KKG Document 5) was a slide from a Power Point presentation by Mouchel, the transport consultants to The Jockey Club. The slide showed a timetable for the preparation and submission of a Planning Application for the proposed development at Kempton Park. It is attached for your convenience.

The topmost bullet-point reads as follows:

“Spelthorne Borough – scheduled 2014 update of Housing Evidence Base likely to set higher residential targets.”

Assuming that Mouchel (and, by inference, The Jockey Club) are correct, why is Spelthorne even considering setting higher residential targets? And why do Mouchel and The Jockey Club think that such higher residential targets will assist an Application to build on Green Belt land?

Under the current local plan, the Council have a target – for the Borough as a whole – of 166 units per year. This target came from the SE Regional Plan in 2005, and was carried forward into the Local Development Framework which was adopted in 2009. The overall target was for the building of 3320 dwellings over a twenty year period ending in 2026.

Although the target of 166 units per year was set initially outside the Borough, the responsibility for setting housing targets has, since the 2011 Localism Act, rested with the Borough itself. Five years since the Local Development Framework started is probably a reasonable interval at which to revisit the housing target, but it has to be said that the existing target has been exceeded consistently since it was first set (see KKG – Document 23, attached). According to the Council’s own figures, the rolling target for the total number of new dwellings will be exceeded by 111 units this year, and will be overshot by 889 units by 2026.

(Although the rolling target for the total number of new homes is being exceeded, the target for affordable homes is not being met.)

As Spelthorne Council itself says in its 2013 Planning Monitoring Report:

“3.6  The housing policies have continued to meet the objectives of the CS&P DPD in providing new housing within the urban area to meet the overall plan target of 3320 dwellings. Despite the fact that some identified and allocated sites have not come forward for development as soon as expected due to the economic downturn, there is no need to take any action to bring forward measures to secure additional sites over and above those already identified.”

Kempton Park is not one of those sites “already identified”. A residential development at Kempton Park is not needed to meet the existing housing target.

And, if the existing housing target is raised, why should Green Belt land be considered a good place for development? Pressure from central government cannot be blamed. Even the Planning Minister, who has become so well known for advocating building on Green Belt and open countryside, has had to make the policy clear (see KKG Document 24).

As ever, these documents are in the public domain. Please feel free to pass them on.

Please encourage your neighbours to join the mailing list.

There is more to come, in due course, over coming weeks.

Yours

Keep Kempton Green

KKG – Document 18 KKG – Document 18a KKG – Document 18b

Dear Neighbour

Let’s put the Green Belt at Kempton Park in context.

The entire estate at Kempton Park, owned by The Jockey Club, is Green Belt. That includes the eastern part of the estate, on which the documents show they are proposing to build this very big housing development.

It also includes the race course itself, and all the attendant buildings and areas on the western side which are needed to run a horse-racing operation at Kempton Park – the grandstand, the stabling facilities, the car park, etc, etc.

These buildings, on Green Belt, are allowed to be there because they are part and parcel of the horse-racing operation. If they were to be replaced by other buildings – residential buildings for example, or a commercial building such as a supermarket or a hotel – not related to the operation of the horse racing operation, then that would be contrary to Green Belt policy in Spelthorne. That would be the case even if the new (not-racing-related) buildings were on the footprint of the old (racing-related) buildings. Such changes should only be allowed in “very special circumstances”.

KKG Document 18 attached shows, in red, that part of the Kempton Park estate upon which, previous documents we have circulated show, the proposed housing development would be sited. Document 18 also shows all the other Green belt sites in Spelthorne (the four large reservoirs are show in a slightly lighter shade of green). We’ll return to that in a moment.

KKG Document 18b shows that red area at Kempton Park in the context of the Green Belt on the western side of London. As you can plainly see, it really is on the front line. The inside edge of the London Green belt has had huge chunks bitten from it over the years, until the present situation where it resembles a coastal archipelago, our, at the risk of overusing a current metaphor, the last flood defences against the one-way incoming tide of high density urbanisation flooding out from central London.

KKG Document 18a shows the red area at Kempton Park in its immediate context. It doesn’t stand alone. It is a substantial part of a local chain of Green Belt, and must be considered, for all the local ecological and environmental reasons, as part of that larger context, which includes Green Belt in the neighbouring boroughs of Hounslow, Richmond, and Elmbridge.

So, the Green Belt at Kempton Park is not just an issue for those most closely situated to it. It is on the front line of the Green Belt around London, it is important in a more local context. And within Spelthorne, it could have huge implications if it were to be built upon.

Returning to KKG -Document 18. A number of residents have been told that, should the development at Kempton Park be approved by Spelthorne Council, it will be a “one-off”.

Imagine Counsel for the owner of some other piece of Green Belt in Spelthorne, rising to his feet, looking up from his sheaf of papers, and putting the following simple question to Counsel for Spelthorne Council: “You gave The Jockey Club permission to build on Green Belt at Kempton Park. Why not us?”

It would be most entertaining, if it weren’t so sad, to watch Counsel for Spelthorne Council answering that one.

So this isn’t just a Sunbury matter. Look at KKG – Document 18. If any of the other pieces of Green Belt in Spelthorne are important to you, then this is your issue too.

As ever, these documents are in the public domain. Please feel free to pass them on.

Please encourage your neighbours to join the mailing list.

There is more to come, in due course, over coming weeks.

Yours

Keep Kempton Green

KKG – Document 19 KKG – Document 19a

Dear Neighbour

We – and a number of residents who have made their own enquiries – have been told by representatives of Spelthorne Council that “no Planning Application for Kempton Park has been received”.

This is perfectly true.

But you can plan without putting in a Planning Application. Indeed, submitting an Application is a step quite far into the process of any development.

The documents we have circulated so far give some idea of the substantial amount of planning work that has already been done, particularly with regard to the traffic spill-over that will result from building a suburb of the size that has been discussed amongst the various participants in this project. Anywhere from 1000 to 2000 dwellings (depending on whose correspondence you read) will generate a lot of extra load onto already overburdened roads.

This work has been in train for some considerable time. So far, the earliest date we have been able to establish with any certainty is 21 March 2012. Attached (KKG Documents 19 and 19a) are the Agenda and Information Pack relating to a Tour of Kempton Park made by representatives of the Council, The Jockey Club and Kempton Park that afternoon.

As ever, these documents are in the public domain. Please feel free to pass them on.

Please encourage your neighbours to join the mailing list.

There is more to come, in due course, over coming weeks.

Yours

Keep Kempton Green

KKG – Document 12 KKG – Document 12a

Dear Neighbour

Attached (KKG Documents 12 and 12a) are a legal agreement and an associated map drawn up between Spelthorne Borough Council, and two bodies associated with horseracing: The Horserace Betting Levy Board (a statutory company established to promote the sport of horseracing, whose funding comes from a levy on the horse racing business of bookmakers) and Racecourse Investments Limited, a Jockey Club Company.

This agreement – the Covenant – is the one referred to in the letter which Kempton Park distributed to residents of Lower Sunbury in November. It was drawn up in 2005 after Spelthorne Council disposed of its leasehold interests at Kempton Park. The agreement expires in 2030.

The important section of this agreement for our purposes is in Schedule 1 starting on page 12. If the two parcels of land outlined in green on the map are developed before 2030 (the Trigger Event) then the three parties to the agreement will be entitled to one-third each of the increase in the value of the land.

These two parcels of land sit right in the middle of the area which is proposed for development at Kempton Park (see KKG – Document 6 distributed earlier). It appears that there were protracted negotiations last year between Spelthorne Council and The Jockey Club concerning the sum of money flowing from this Covenant, and other sums of money required for the redevelopment of Sunbury Cross and other matters.

As ever, these documents are in the public domain. Please feel free to pass them on.

Please encourage your neighbours to join the mailing list.

There is more to come, in due course, over coming weeks.

Yours

Keep Kempton Green

KKG – Document 15 KKG – Document 16 KKG – document 17

Dear Neighbour

This latest in our series of messages gets a little complicated. We will try and keep it as simple as possible.

Costco – the chain of wholesale cash-and-carry stores – submitted a Planning Application to build one of their stores just to the east of the Sunbury Cross roundabout. The application received widespread support at Spelthorne Council, due to the proposed store replacing currently unused warehouses on land unsuitable for housing, and due to the jobs the store would bring with it.

On 4 September last year, Mark Boyes from Aspire, Development Consultants to The Jockey Club, wrote to Spelthorne Council to lodge an objection to Costco’s Planning Application (see KKG Document 17 attached). The letter includes some technical objections to Costco’s Transport statement (which later emails show to have been related to clerical errors, and easily corrected).

However, the letter also says:

“The Costco transport assessment makes no allowance for potential future development at Kempton Park, …”

Being Development Consultants, Aspire will be very aware that, in planning law, Costco are under no obligation whatsoever to take account of “potential future development” anywhere. In any case, it is difficult to see how they could do so in any practical way. They are required to take account of committed developments, and the correspondence shows that they did in fact take account of the developments (not yet completed) at the London Irish ground, Hazlewood, and the old Police College – all in Lower Sunbury – in their transport assessment.

So what was the purpose of the objection by The Jockey Club? Why did they wish to “open a dialogue” with Costco? Could it have been that they were trying to get Costco to contribute to the large cost of redeveloping Sunbury Cross roundabout (see KKG Documents 2, 3 & 4 circulated previously)? Or some other reason? An information request was put in to try and find out, but more on that later.

Another thing. If Costco were to take account of the traffic impact of  “… potential future development at Kempton Park, …” (which they are not at all obligated to do) they would have to know what the size of the potential development at Kempton Park was. The traffic and the size of the development are intricately linked – you cannot know one without the other.

So, if The Jockey Club’s consultants were trying, on 4 September 2013, to get Costco to take account of potential future development at Kempton Park, the size of the potential development, and the traffic generated by it, must have been available in number form. Certainly, at least one department within Spelthorne Council was aware as early as mid-August 2013 that “very large developments (are) being proposed in the vicinity of Sunbury Cross” (from an email we have on file which we have omitted for the sake of brevity.)

Yet, as late as mid-November 2013, representatives of Spelthorne Council were telling residents in the following, and similar words, that “no plan whatsoever (has) been developed for the scale of housing that you allude to”. The scale being alluded to was the +/- 1000 dwellings mentioned in the LOSRA newsletter in October 2013. As it turns out, of course, that 1000 figure turned out to be a significant underestimate – see KKG – Documents 1 & 8 circulated previously.

Anyway, back to The Jockey Club’s objection to the Costco Application. The request submitted, and the reply we got, are set out in KKG Documents 16 & 15 (attached).

A meeting is held, where The Jockey Club discuss, amongst other things, an objection they have to the major and widely welcomed Costco development, and the record of that meeting consists of 5 sketchy handwritten lines?

As ever, these documents are in the public domain. Please feel free to pass them on.

Please encourage your neighbours to join the mailing list.

There is more to come, in due course, over coming weeks.

Yours

Keep Kempton Green