A forum for neighbours

This feedback is submitted by Riverside Residents Association (RRA) following member discussions in response to the Presentation of outline development proposals for the County Hall site by the new owners RER at the end of October 2021.

The RRA represents residents in the area bounded by:  South and East Lane to the north, Portsmouth Road to the west, Milner Road/County Hall to the East, Woodbines Avenue to the south and east, including The Bittoms, Oaklea Passage, and Avante Court.  The RRA is a community group that looks to help shape our locality for the benefit of all residents.

We welcome the opportunity to respond to your proposals that have been presented through this latest round of engagement.  We note that the views expressed through these rounds of engagement are taken into consideration by LPAs, Inspectors as well as the developers hosting the engagement.  We note that the cross-sections to illustrate views to the rear of the block proposed for the Surrey Club and tennis courts that was promised by RER have not materialised, and we therefore reserve the right to comment on these if/when they are provided.

Our comments in the main focus on two matters, firstly a matter of principle – the uses proposed for the County Hall building, and secondly our response to the proposals for the Surrey Club/tennis courts site. The tennis courts are the established lawful use on this site given that SCC never applied for or received planning permission to change the use to a car park.  SCC in their more community spirited days allowed local residents to use the tennis courts for recreational use, and a number of existing RRA members benefited in this way.

We do also briefly comment on other matters such as the quite frankly ludicrous idea of ‘pavilions’ on the Milner Road frontage that has now been quietly dropped.  Unfortunately, their inclusion in the first place rather undermines our confidence in RER’s development team.

Uses proposed for the Listed Building
RER is a residential developer, and its focus is clearly on maximising the residential content of the scheme.  While we are pleased to see commercial use proposed through The Trampery managed workspace, this being confined to the ‘difficult’ elements of the building and no other uses proposed smacks of tokenism.

We want to see uses in the building that bring public benefit.  RER will expect to provide a substantial element of public benefit in the building as they bought a building that not only is listed (and its listing is as much about its former civic/community function as it is about its fine form), but is also allocated in the adopted statutory Borough Plan for public benefit uses – civic and educational.  So, we most certainly expect to see, and expect the Council in its development management capacity to encourage RER to deliver uses in accordance with the Development Plan – educational and civic uses. These uses should continue to be the priority for the listed building, but we as a major representative group within the local community would also support community uses that bring public benefit, and then in a hierarchy of uses we would then favour commercial uses that bring jobs, and we turn to this below, but firstly we consider the opportunities for educational use.

It was notable that the RER presentations were silent on discussions with KU, and indeed silent on whether discussions had taken place with other educational institutions / providers, yet this is the main use we residents and the Council through its adopted statutory local plan wish to see promoted on this site.  RER will have known this from the word go, but the silence on pursuing any educational option is hugely disappointing.  The opportunity and benefit for the University, our town and RER from consolidation of the University campus either side of Penrhyn Road is obvious, and must be pursued.  Working with the University (largest employer in the Borough) so that it can grow and flourish is a Council objective and providing the opportunity for the University to take space in County Hall is confirmed through allocation in the adopted Local Plan.  This is what the Local Plan and this Residents’ Association want to see in the reuse of County Hall.  Instead from RER there has been a deafening silence.

County Hall is a large building, and we also want to see uses in the building that deliver public benefits, maintaining public access, and the building returned to being a public asset for the residents and visitors to the Borough.  Community infrastructure is universally under-provided in this Borough and across London, and this building is an opportunity to provide and help address the under-provision.  We would like to see the local history rooms and the registrar relocate to County Hall.  We would like to see health facilities considered in the building as part of the public benefit; it is increasingly difficult to get a dental or doctor’s appointment locally.

Moving down the uses hierarchy we would like to suggest exploring the option of a boutique hotel for the 1893 element, and much more in the way of commercial space in other parts of the building than RER currently propose.  In this respect we note that Castleforge Partners ongoing redevelopment of the former Bromley Town Hall will provide 70,000 sq ft of work space (and a boutique hotel).  What works in Bromley (albeit with grant funding) will work even better in a more prestigious building opposite one of the best arts, design and creative Universities in Europe. We also point to Hornsey Town Hall another Grade 2* listed landmark building currently undergoing repurposing by Ardmore to provide a range of community accessible uses including a new performance arts centre, co-working and flexible workspaces, restaurants, cafés and versatile event spaces plus an hotel.  Both the Hornsey and Bromley examples demonstrate the type of opportunity Kingston’s County Hall represents.  We urge RBK to work with RER to explore the opportunity to provide a hugely exciting mix of community accessible spaces that would be of major benefit to the town centre, the University and residents.

Kingston University has a strong entrepreneurial tradition with business start-ups particularly strong in the arts, design and other creative activities, but the Borough lacks space for emerging and budding businesses, and has not been able to accommodate these entrepreneurs, and businesses reluctantly start-up elsewhere.  Kingston needs space for fledgling businesses to start-up, to grow-on and to flourish – start-up / incubator / grow-on workspace that could come forward as a creative industries hub in County Hall – a prominent prestigious building located next to the main University site; this is a really exciting prospect.

A public benefit use that is well worth exploring is the potential for the building’s uses to include art gallery and/or museum space.  RER must explore the potential to use Kingston University’s strengths in art and design to  attract an extension of a London gallery / museum, many of which have no space to expand on their central sites, and may be looking for opportunities to extend their collections to gallery space in locations such as our magnificent Grade 2* Listed County Hall.  Such a use within this public building would be very fitting, bringing the sort of public benefit that would deliver a wonderful legacy for residents and visitors to enjoy. This idea is not ‘pie in the sky’, as Kingston First will tell you that Kingston town centre is visited by around 20 million visitors annually, many of whom come for the leisure experience.  Kingston town centre needs more attractions and to diversify and raise its offer, especially to attract those with more spending power – a gallery / museum in such a well located and prestigious building as County Hall would go a long way in helping attract more affluent visitors and help the town centre as a whole raise its offer.

On the same theme Kingston’s existing museum may also present a relocation opportunity given the impending redevelopment plans for the wider area, and there may be interest in expanding collections such as that of Eadweard Muybridge.  Kingston University may be interested in relocation its Stanley Picker gallery, this would certainly benefit from being relocated to a more prominent location, and potentially a hub of other such attractions.  These possibilities need to be explored before RER defaults to residential.

Finally, we return to the opportunity of providing more commercial workspace within the building. We think, and perhaps the Council’s as yet unpublished Employment Land Review will confirm this, that there is a need for more managed workspace than the Trampery alone can provide to meet demand in the general commercial market to accommodate a workforce that is increasingly entrepreneurial and focused on micro and small businesses, propelled in this direction by the pandemic.  County Hall is attractive, characterful and has a presence, it was last used for civic back-office functions, it is very well located in terms of public transport access (served by both Kingston and Surbiton rail stations / bus routes), and adjacent to Kingston University with all the research and resources contained therein.  We would like to see workspace on a more ambitious scale than that currently envisaged by RER, and involving the University. We would also like to see the University given the opportunity to centralise its campus here, administratively and/or teaching, which would give rise to opportunities to rationalise KU’s property assets elsewhere, many of which we think are appropriate for residential use.

Surrey Club
We are not at all impressed by RER’s 8, 6, 4 and 2 storey proposals for the Surrey Club site. Indeed, for the reasons that we set out below we want to see this scaled back to certainly no more (and indeed better still less) than the existing building footprint.  We the local residents who are here for the long haul consider your proposals to be of poor design and to fail to respond appropriately to the context particularly in terms of height/mass/appearance, separation and amenity – in short we see your proposals as being crass over-development and would certainly not create well designed homes and create the type of locality where residents old and new would find the quiet enjoyment that we all want from our homes.

It is also relevant to note in respect of the existing Surrey Club that had the G2* listing been in place in the 1970s then it is very unlikely that the scale and position of the Social Club would have gained planning permission due to its adverse impact on the listed setting. The redevelopment presents an opportunity to restore and enrich the listed building setting, which is cited by Historic England as a positive reason to adapt a listed building. A replacement building should sit further back from Penryn Road and from the Listed Building and be designed in scale to be subordinate to the adjacent G2* listed building, which will improve its setting and the views and progression along Penryn Road in both directions.

Height and massing/appearance
The building would need to be considered against London Plan Policy D9, and we fail to see how the planning decision-makers could possibly consider this location to be appropriate for a tall building. You may argue Town House, to which we would say the context is Reg Bailey and the Milner / Woodbines / Bittoms residential immediately to the rear.

Good design in locations such as this is about transitioning sensitively (as required by London Plan Policy D9C), and not having high rise high density development abutting the boundaries of the suburban residential – such an approach cannot be considered sensitive transition.

We also take issue with the massing and appearance of the new build for the Surrey Club site, which is more akin to the look of a densely massed student halls of residence than the suburban detached and semi-detached residential that it meets to the south and west.

RER have failed to respect the local residential context.  Woodbines, Milner and the Bittoms are that context, located just outside of the town centre boundary and solidly suburban in context. Cramming 100 flats on the Surrey Club/ tennis courts and 350 in the Listed Building represents a huge density totally disproportionate to the context and again not providing a sensitive transition.

Separation
We understand that the separation distance frontage to frontage between our G2* Listed Building and the ‘town cramming’ on the Surrey Club / tennis courts would be some 10 metres.  This would be contrary to both Kingston and the Mayor of London’s minimum standards for visual separation as set out in their Housing SPG /Design SPD.  Indeed this distance is just half the minimum standard required to maintain privacy (the Mayor’s Housing SPG identifies 18-21 m (Standard 28) and the Council’s Design SPD identifies a distance of no less than 21 m (PG16)).  Thus what you propose is totally unacceptable.

The lack of adequate separation / set back is also an issue for our G2* building, as is the height and massing of the proposed replacement building.  We assure you that the scale of Town House does not detract from County Hall because it is remote (on the other side of the road and set back from the highway).  The existing Surrey Club building does detract from the setting of the G2* building, and your proposal that would not only be just 10 metres from the building, but exceed County Hall in height could not possibly be considered to respect or be subservient to the G2* building.

We certainly cannot comprehend that Historic England, the Council or the Planning Inspectorate would consider a residential scheme such as that which RER propose would trigger the wholly exceptional circumstances required to justify the substantial harm wrought on the G2* building by developing in this way within the building’s setting / curtilage.

Separation, loss of privacy and avoiding overlooking issues are real concerns for residents with property boundaries abutting the Surrey Club and tennis courts.  We do not want to have flank walls of 6, 4, and 2 storey residential blocks close to our boundary, looming over our gardens, spaces where we have the right to peaceful enjoyment.  It is difficult to establish distances from the presentation drawings, and we remind RER that we were promised sections to illustrate views from the south and west, but these have not materialised.  What we do observe is that the Milner Road properties are just 14 metres from the boundary, and thus the flats on the western and southern flank of RER’s proposal are likely to need to be single aspect to avoid overlooking, loss of privacy and intrusion issues, which would be very poor and unacceptable design.

Amenity space
We note the amenity space standards in the Council’s Design SPD of 50 sq m plus up to 10 sq m per dwelling where private amenity is not provided, and point out that these are minimums and required to provide residents with space to relax and have quiet enjoyment.  We cannot see any dimensions on the courtyards, but given RER propose in the order of 100 flats we think they will be hard pressed to meet this minimum requirement in each of the courtyards proposed.

The irony is that the existing lawful use for a large part of the site is sports related – the tennis courts – that in recent times were used by SCC as a car park without the benefit of planning permission for change of use.  It is regrettable that RBK did not intervene and require SCC to restore the tennis courts. It is noted that the tennis court perimeter fence remains. The redevelopment presents an opportunity to correct this position and restore this land to its intended recreational use. This will provide an exciting, active recreational facility providing a public benefit for new and existing local residents, which is currently lacking in RER’s proposed scheme.

In summing up on RER’s proposals for the Surrey Club/tennis courts site, we consider our concerns to be fundamental issues that cannot be overcome by design changes to a proposal for dense flatted development.  These issues that you have not addressed require a fundamental rethink about the Surrey club / tennis courts site.  Added to which as RER know there is a restrictive covenant on the Surrey Club and tennis courts land that the Milner and Woodbines residents understandably fully intend to enforce to protect their assets.

Finally
We are encouraged that RER propose an element of public benefit in the scheme – the publicly accessible northern courtyard garden, but we do not support RER’s suggestion that was raised in discussion that this would need to be gated.  We support the Council’s opposition to gated communities (RBK Residential Design Guide SPD), as we know spaces that are overlooked and are active will police themselves with no need for gates.

Two points in regard to the Milner Road frontage:
·      Firstly, while not explicitly referred to on the RER presentation slides, we understand that it is RER’s intention to convert nos. 5-7 Milner Road into flats.  We note that the proposals for what RER refer to as the Staff canteen site would result in the gardens of nos. 5-7 being chopped in half.  We are totally against this proposal, and note that this would be another element of this proposal that is contrary to the adopted Kingston Development Plan, a Plan that this Residents’ Association helped create and a Plan we support. Please refer to Policies DM14 and KT1 of the Core Strategy that seek to protect dwellings such as 5-7, dwellings that are suitable to provide the small to medium sized family housing needed particularly in the Kingston Town neighbourhood (this includes Milner Road) because of the proliferation for many years of flats and apartment accommodation that is not suitable for families.  To provide choice and opportunity for families to find suitable housing in Kingston Town we do need to resist proposals such as RER’s for nos. 5-7 Milner Road.

·      Secondly, now that RER has dropped the Milner Road ‘pavilions’, we would like to see more climate change mitigating tree planting and soft landscaping on the cobbled Milner Road former car park area. Indeed we are hopeful that RBK and the GLA will pursue London Plan car parking standards, and insist on a car free development given that County Hall is located within a Metropolitan town centre and has a PTAL rating of 6a. Thus, there will be plenty of room for soft landscaping for the benefit of any new and existing residents and the environment.  As mentioned by residents at your engagement event, Surrey County Council cemented the cobbles in place a few years ago leaving us with a legacy of a large area of impervious surface and water run off issues.  Addressing this would help you deliver some public benefit.

Mary Webb
Chair