This feedback is submitted by Riverside Residents Association (RRA) in response to the second Virtual Exhibition posted by Surrey County Council (SCC) between 24 November – 8 December 2020 and webinars, and following RRA member discussions.

The RRA represents residents in the area bounded by: South Lane and East Lane to the north, Portsmouth Road to the west, Milner Road to the East, Woodbines Avenue to the south and east, including The Bittoms, Oaklea Passage, and Avante Court.

The RRA responded formally with comments on the first Virtual Presentation on 24 September. SCC is now seeking further feedback on their latest proposals although it is clear that little has changed from the original proposals, other than they appear to have marginally reduced the height, but significantly increased the massing of the new build elements on the Bittoms Car Park site and former tennis courts between the County Hall building and Woodbines Avenue.

In overall terms, the RRA and its members are opposed to the proposed development, as we were in September and we have received nothing from SCC that convinces us otherwise. The fundamental fact is that there are no policies or plans which support or justify the proposals either in terms of change of use, or providing justification for a wholly inappropriate development within the curtilage of a listed building or a cluster of very tall buildings. SCC has continued to show disregard for the amenity of the residents in the surrounding areas, promotion of over-development that will create a poor environment (podium open space, no private gardens, balconies only), and destroying the setting of a valuable heritage asset.

Despite our comments to the first consultation, SCC’s online feedback form remains wholly inadequate, and is clearly designed to prevent interested parties from making full and relevant comments. It still only asks four very specific questions about the in-principle proposals, with virtually no detail to comment on. There is still no mention at all of SCC’s plans to build the tallest building in Kingston on the Bittoms car park, and they have removed any reference to the fact that the site has a Grade 2 listing!

We have therefore again copied our complete response into one of the ‘additional information’ boxes on the feedback page. We shall of course copy our comments to the Borough Planning Dept. and to the ward Councillors, and we hope that SCC will begin to take seriously the concerns of the RRA, their members and other Kingston residents.

SCC has picked out a very limited number of points of concern for feedback from the first consultation, and provided examples of their solutions on Panel 2, all of which are very measured and wholly inadequate, ignoring the key issues. SCC’s complete lack of concern for the amenity of local residents is a cause of great concern.

The RRA’s response to SCC’s proposals as presented in the second Virtual exhibition and at the online webinars is in two parts, firstly we consider the principle of what is being proposed, and secondly we pick up on issues of detail.

The principle

We start with first principles because ultimately the Planning Acts require that planning applications must be determined in accordance with the Development Plan unless material considerations indicate otherwise.

What you propose – the reuse of a civic building for mostly private residential use, development in the curtilage of the Listed Building for residential use and on the Bittoms car park site a cluster of tall buildings, again for residential use. As we explain below all of these elements are contrary to the Development Plan, and the tall buildings element runs counter to the thrust of national guidance and the guidance of the nation’s heritage guardians Historic England.

SCC and its development team refer to their wish to leave a legacy, but as has been pointed out by others, what is very apparent is the approach (e.g. 9 storeys next to County Hall) is to yield maximum financial return, and certainly not to leave a positive legacy for Kingston and its residents.

Our fundamental concerns with what is being proposed are the non-policy compliant use and promotion of tall buildings in a location where there is no plan basis for such.

The use

We were involved in the preparation of the Borough’s Core Strategy and the AAP for Kingston Town Centre, which are Kingston’s adopted Plans, and supported the zoning of the area in which County Hall sits as part of the civic and education quarter. We do not recall SCC contesting the designation at that time, even though SCC has had a desire to relocate to Surrey for many years. Kingston’s plans were soundly based, and as we set out below, the emerging new plan for the Borough retains support for these civic and educational uses, which we can confirm that local residents continue to support.

SCC has not presented any evidence that the opportunity for civic, community or educational institutions to fill some or all of the ̴20,000 sq m space in County Hall has passed. The departure of SCC really does present a once in a generation opportunity to realign Kingston’s civic, community and educational establishments. The opportunity should certainly not be hurriedly passed up. In this regard we note Historic England’s comments. They, like us, ask SCC to provide the evidence that uses more appropriate to the building’s form and function, uses delivering the civic and educational needs of the Borough, and uses as set out in the adopted statutory development plan, are not deliverable. Indeed, HE are very clear that the preferred use should not be determined by yielding the maximum financial return but rather is the most appropriate use for the heritage asset (bottom of page 3 of the 8th Jan 2020 letter).

While SCC seems content to ignore the Development Plan when it suits, they and their development team seek to justify their proposals through reference to the London Plan (intend to publish version) and the Kingston Direction of Travel document, jointly prepared by Kingston and the GLA.

The Direction of Travel document is relevant, and as BECG say it does promote new homes, jobs and investment in the Borough, the focus of which will be within an Opportunity Area (which is earmarked to deliver around 9,000 homes and 5,000 jobs). However, contrary to what BECG claim, the area covered by the Opportunity Area is not fixed, and will be a matter for the Borough to decide. It is possible County Hall will not be a part of that area.

We note that the Direction of Travel document presents a very balanced approach to how development in the Borough should come forward. It is very relevant to note that it refers on pages 26/27 to what Selective redevelopment could achieve, and this includes:

Continuing protection of Kingston’s historic environment (Listed Buildings, Buildings of Townscape Merit and Conservation Areas) Enhanced and improved higher educational facilities

And it concludes by stating: We recognise that new growth must be balanced with the unique heritage and character of the borough.

A balanced approach, where protection of Kingston’s historic assets is important. This balanced approach reflects the requirements of the Planning and Listed Buildings Act that requires special regard to be given to preserving listed buildings and their settings. This is the approach of the Borough and the GLA. We return to consider this in the context of tall buildings later in this submission.

In the context of the London Plan and the Direction of Travel document it is very relevant to note that the cancellation of the Crossrail 2 scheme totally undermines the ability of Kingston to deliver on the housing and jobs targets because the levels of growth proposed were reliant on the step change in infrastructure that CR2 would deliver. CR2’s cancellation means the strategy for growth at the levels proposed cannot proceed, and the whole strategy needs to be reconsidered.

At the same time as the Borough consulted on the Local Plan Early Engagement document, a Sites’ Assessment document was also issued for consultation, this the product of a Call for Sites. We have not seen the original submissions nor any analysis on the content, but we note that County Hall is specifically identified, and its future use is identified as being non-residential. We don’t know who nominated County Hall, but what it does suggest is that SCC either did not engage in the plan-making process at a time when as responsible property owners they should have, or this headlong rush for residential is a much more recent idea.

The Local Plan is timetabled to be adopted in 2023, and is the vehicle SCC should use to work with the Borough Council to deliver a positive legacy for the Borough. We would like to see a civic function, and in this regard we note the Leader’s recent public pronouncement that the Council could vacate from the Guildhall, and also an educational function and potentially other community and business hub activities within the building. This is not far-fetched, it takes place in many such buildings up and down the country. SCC’s departure leaves a civic building that is an opportunity that must be thoroughly examined to explore all potential positive legacies, as SCC states that they desire. We support them in this resolve.

The cluster of tall buildings on the Bittoms Car Park

Kingston’s adopted statutory planning document – the Core Strategy Policy CS8 seeks to guide where tall buildings may be appropriate, and to identify areas where they would be inappropriate or too sensitive, and states the detail will come through Supplementary Planning Documents. It also refers to determining applications on the basis of advice from English Heritage/CABE Guidance on Tall Buildings. The Eden Quarter Development Brief, is one such Supplementary Planning Document. It covers a large swathe within the town centre, and identifies that with the exception of three specific locations where there is a case for landmark tall buildings, the maximum height considered acceptable is 6-8 storeys. At no point was the Borough Council asked to extend the EQDB area to include tall building guidance for the Bittoms area. The inference from this is that the Bittoms car park is beyond the area where landmark buildings could be appropriate or taller buildings could be acceptable because they would not generate harmful impacts; the area is heading towards the edge of the town centre, and beyond the quarter where tall buildings could be appropriate.

Tall buildings have a huge impact on our townscape, and need to be considered strategically, and not on an adhoc, unplanned, speculative basis. The London Plan (intend to publish version) sets out this approach. Policy D9 addresses tall buildings, and makes it clear that it is for Boroughs to identify locations where tall buildings may be appropriate, and that these locations should be identified on maps in Development Plans (D9C(2)). Part B concludes (B3) Tall buildings should only be developed in locations that are identified in Development Plans.

In this regard the recent Direction issued by the Secretary of State for Housing, Communities and Local Government, the Right Honourable Robert Jenrick, is of substantial material significance. In considering the matter of tall buildings, and London Plan Policy D9 specifically, the Secretary of State wrote:

“However, there are some areas where tall buildings don’t reflect the local character. I believe boroughs should be empowered to choose where tall buildings are built within their communities. Your draft policy goes some way to dealing with this concern. In my view we should go further and I am issuing a further Direction to strengthen the policy to ensure such developments are only brought forward in appropriate and clearly defined areas, as determined by the boroughs whilst still enabling gentle density across London.”

The substantial number of proposals for tall building brought forward in inappropriate (unplanned) locations is clearly a matter of great concern for the Secretary of State, and clearly he is determined to do something about them. This is evident from the recent Secretary of State refusal to grant permission for a tall building in the centre of Norwich, a location that has parallels with the situation emerging in Kingston. The Secretary of State’s closing remarks to the Mayor of London in his recent letter were:

“I am sure that you share my concern about such proposals and will make the required change, which will ensure tall buildings do not come forward in inappropriate areas of the capital.”

The Secretary of State could not have been clearer in setting out his concerns, and directing the Mayor of London to further strengthen his policy to ensure tall buildings are only brought forward in appropriate (suitable) and clearly defined areas. The approach required by the London Plan will now be all the more clearly stated; tall buildings must form part of a plan-led approach (i.e. not come forward via speculative applications on non-compliant sites – as would be the case with SCC’s plans for the cluster of tall buildings on the Bittoms car park).

It is clear that Kingston’s existing local Development Plan documents are very much in conformity with the London Plan (intend to publish). What is important to bear in mind is that when the Borough comes again, as part of the preparation of the new Local Plan to assess if/where it may be appropriate to locate tall buildings, this will be done through proper public engagement, giving everybody the opportunity to consider and comment on the matter as a strategic issue, and a move away from what is happening at the moment, i.e. the Borough and residents being forced to respond to speculative applications and promoter’s whim.

In this regard we note that not only are Kingston’s adopted statutory plans in conformity with the London Plan, but the signs are that the next Local Plan will be too. The new Local Plan Early engagement document (May 2019) includes statements questioning where tall buildings should be located. The clear inference being that the location of tall buildings is a matter to be considered through strategic plan-making, as it has been in the past, and is not a matter to be picked up in an adhoc manner in response to speculative planning applications.

Historic England (formerly English Heritage) advice has moved on since the document referenced in the Council’s Core Strategy Policy CS8. The current advice note 4 (Dec 2015) very much accords with the London Plan and the approach taken by the Council “In a successful plan-led system, the location and design of tall buildings will reflect the local vision for an area, and a positive, managed approach to development, rather than a reaction to speculative development applications.”

We contrast the considered planned approach set out in the statutory plans, the HE guidance and the joint GLA/Borough Direction of Travel document referred to earlier that states “new growth must be balanced with the unique heritage and character of the borough” with SCC’s approach, which is said to be “designed to respond to the surrounding context” (BECG letter23rd Nov). SCC’s approach blatantly ignores the context and seeks to develop to the maximum limits, maximising height and massing. What else could we conclude given the opening offer of nine storeys immediately next to County Hall, the rationale for which was because Town House is tall, and also taking reference for the Bittoms cluster of tall buildings from the landmark tall building on the Post Office site that serves to mark the entrance to the town centre and is remote from the Bittoms. And a planning application for a tall building on the Unilever site has now been chopped back, just like your entire scheme will inevitably be.

We are certainly not against redevelopment of the Bittoms car park, but the surrounding context for this is the Courts building and the two storey residential (including the Listed Buildings) that are immediately adjacent to the west. It is stretching beyond credibility that a cluster of three towers of up to 17 storeys is balancing growth with heritage and character. Indeed, into the legacy consideration and the balancing must surely go the residential amenity and welfare of those living close by. It cannot be right that new civic buildings for the residents of Surrey should be funded out of over-development that blights the lives of residents of Kingston.

Specific points

Next, in no particular order, we set out the more specific points raised by RRA members in specific response to the consultation material.

  • Public Consultation. SCC is conducting a “Virtual” Public Consultation which still grossly misrepresents the material facts about the property and the development proposals. Hiding behind the opportunity presented by the COVID-19 pandemic, SCC’s PR consultant has used the remote communication to either ignore or repackage most of the questions raised in the online presentations to avoid the tricky issues which need to be addressed, such as the principal of appropriate use and the statutory Development Plan, and the impact on the listed buildings within and adjoining the site.We are still not convinced that SCC fully notified all local residents of the second Public Consultation, despite the serious failings in the communication of the first consultation.
  • The Virtual Exhibition is grossly misleading, with limited detail on any of the key aspects of the proposals and conveniently buries the key facts. For example, there is no mention of the Grade 2 Listing of County Hall in the presentation, as it is clearly not a concern to SCC, whilst claiming that their development will safeguard the long term future of the historic elements of County Hall. In the first presentation there was one passing reference to the Listing on board 7 of 11.
  • Historic England (HE) – SCC paints a picture of a positive response from Historic England, but ‘’not contentious in principle’’ does not constitute a ringing endorsement of redevelopment on the scale indicated by SCC. We have now received a copy of HE’s response to the development proposals. Understandably with the lack of detail provided by SCC, HE clearly states in relation to the proposed South Block that “Careful consideration will need to be given to the design, scale, and massing of these blocks to avoid adversely impacting upon the setting of the Grade 2 County Hall and nearby conservation areas”.
  • Emerging Local Plan Housing Needs. RBK is well on its way to delivering sufficient sites for the new homes required in the Borough to meet housing needs through to 2041. There is no need to build another 500 units on one of the very few, and almost certainly the only site that is capable of providing the civic, community and/or educational facilities to support the growth in housing and residents elsewhere in the town centre.
  • Civic and Educational Use. SCC claims to have now had full engagement with both Kingston University and RBK following earlier criticism, but as yet we have seen no evidence of these or any other wider engagement or promotion of the site with any potential civic or educational users, having marketed the opportunity openly and widely. SCC has not made a case for why the Borough Council should set aside the adopted Development Plan. When questioned in one of the first webinar presentations on this point SCC was only able to refer to “a conversation with Kingston University”, and certainly not the form of engagement we would expect.
  • Strategic Viewpoints. A full range of strategic views as will be required by RBK in any planning submission, and these should take reference from the Council’s Views Study.
  • Bittoms Cark Park. The re-development proposals for the Bittoms car park are hugely out of scale with the context, and should seek to reduce the impact on the residents in The Bittoms and the listed cottages in Oaklea Passage.
  • Tower Block Development. The creation of new tower blocks overlooking 2 storey residential neighbourhoods, will materially detract in all aspects from not only the listed buildings, County Hall and the cottages in Oaklea Passage, but the whole neighbourhood. The scale and massing of the new buildings proposed on the Bittoms car park site and the former SCC social club and tennis courts is also wholly inappropriate and unjustified.The Eden Quarter Design Brief provides guidance for limited locations where tall buildings could be considered in Kingston. The Bittoms car park is beyond the area where landmark buildings could be appropriate or taller buildings could be acceptable because they would not generate harmful impacts. The area around County Hall is the edge of the town centre, and beyond the quarter where tall buildings could be appropriate. The County Hall site forms the southern boundary of the Kingston Town Centre Area Action Plan where it meets 2-storey residential property. Re-development of this site therefore needs to be doubly sensitive – to consider the context of the surrounding 2 storey residential properties and the Grade 2 listed building.The point of reference for the southern boundary of the site is the Reg Bailey Building, 2-3 storeys fronting Penrhyn Road, but only 2 storeys on the boundary to Woodbines Avenue, and not the Town House as originally stated by SCC. The height of any development should step down from the town centre/inner ring road/ Kingston College, not creating new tower blocks within predominantly 2-storey residential neighbourhoods.
  • Mixed Use. SCC has described their proposal as mixed-use, but in reality it would deliver 500 flats with a token heritage offer in County Hall, and some “white elephant” retail units. The Architect advised in the online presentation that convenience food retail space or cafes would be provided at ground floor level in Oaklea Passage for the benefit of the residents.These would not benefit the existing local residents and are more likely to attract an increase in anti-social behaviour in the area. This is the usual solution for ground floor space in tower blocks where there will be no demand for residential occupation. Demand in these spaces for retail, offices, and cafes/ bars is usually very limited and these units generally remain vacant white elephants.In addition, SCC is proposing 7,500 sq m of office space at podium level, which we assume will be designed to be converted to more flats with Permitted Development Rights when they do not let, putting even more pressure on local services.
  • South Block SCC claims that the proposed South Block development has been reduced from 9 storeys to 4 storeys with a fifth storey set back in order to allay the concerns of the residents in Woodbines Avenue and Milner Road who would have been overlooked and suffer significant loss of privacy.But SCC has greatly increased the massing of this new “E” block, which is still shown located very close to the boundary walls, and these houses and gardens would still be completely overlooked, and would therefore still suffer the resultant and unacceptable loss of privacy.There would inevitably be a huge increase in light and noise pollution from such a large block with so many residents and windows, where there is no current issue. The architect was unable to confirm the distance from the new block proposed to the rear garden walls in Woodbines Avenue and Milner Road. It still looks far too close, sandwiched between the southern aspect of the Grade 2 Listed building and the 2 storey houses and would overlook our private gardens.There is also great concern that SCC plans to locate all of the Affordable accommodation in this block, which experience shows is very likely to result in a low grade, cheap-build block. SCC claims that the location of the affordable accommodation will need to be in one block for estate management reasons, but it is clear that the key reason will be to build a cheap tertiary block as has been witnessed in so many developments around Kingston, for example Coronation Court on the corner of Surbiton Crescent.We would like to know why HE’s sound suggestion to set back the building line of the Club building on Penrhyn Road to ‘reveal’ more of the Listed Building, and improve its setting; has been ignored by SCC. What an opportunity this would be for SCC to actually deliver on its goal of positive legacy. Please don’t pass that up! For our part, and considering the Secretary of State’s recent direction on the London Plan and his comments about reflecting the local character, we think the rear of this location (the tennis courts) should be no more than 2 storeys to be in keeping with the surrounding residential properties and be subservient to, and avoid harming the setting of the Listed Building. That is, if building on one of the few areas of open space is really sensible were County Hall to switch to residential. SCC’s planning consultant stated that the residents of Woodbines Avenue and Milner Road are not entitled to views of the Grade 2 listed building, as they have enjoyed for many years. But equally SCC is not entitled to block and obscure an aspect of a Grade 2 listed building from public view, with an unsympathetic low grade, too high and inappropriate development.
  • Library Consent Precedent. The architect draws precedent for the residential blocks proposed south of the Listed Building from the 2005 outline planning consent that is long expired. That proposal was for a tiered 3-storey building, set back at each upper level, for educational use, and with restrictions on hours of use.It is very relevant that the first and second floors of the 2005 scheme were set back away from the boundary with the residential gardens on Woodbines Avenue /Milner Road, and this was specifically to avoid overlooking of those private residential gardens. Why then we ask, does this current scheme propose 4-5 storeys right up to the very edge of the boundary? The RRA and many others objected to the position of the rear building line promoted in that application, and we wish to put on record that we maintain that the first and second floor rear building line was unlikely to be sufficiently set back to prevent overlooking of the private gardens. This was difficult to assess at the time given the limited material provided in what was an outline application, but simple geometry suggested private gardens would be overlooked.In the intervening period the Council have published Kingston’s Residential Design Guide, and this identifies loss of privacy and overlooking as the top two concerns in assessing residential planning applications, and this applies in respect of both indoor and private outdoor spaces. We understand why the 2005 permission could set a precedent, but SCC’s architect has misread the permission, as it is the rationale for the setback of the first and second floors (to avoid overlooking of the neighbouring private gardens) that is the critical point, and not the overall footprint. We would add that should SCC think of pursuing a blank flank wall on the boundary that would be very poor design (certainly not a positive legacy) and would generate totally unacceptable harm to our residential amenity and fail the Core Strategy policy tests and specifically Policy DM10.
  • Light and Noise Pollution. The proposed change of use to 500 residential units and the development of new tower blocks on the site would generate large amounts of both light and noise pollution to the detriment of all residents in the local neighbourhood. At present there is limited pollution from either noise or light, but with 500 residential units these environmental impacts will be very significant, particularly within those areas of the development closest to existing residential, i.e. Milner Road, Woodbines Avenue, The Bittoms, South Lane, Avante Court and Oaklea Passage
  • Green Amenity Space. A development of 500 residential units requires significant amounts of green space and amenity area for the residents, particularly as Grove Ward has a serious deficit of green space. The pandemic has highlighted the importance of gardens (private or otherwise) and outdoor space, and they will be needed if a residential scheme were to come forward. Balconies are not sufficient, if SCC is to build better, build beautiful as the Government wishes. The open areas around the outside of County Hall should be landscaped, the tennis courts reinstated, not over-developed for maximum profit.To allow space for amenity and green spaces, any future use or re-purposing of County Hall should not be permitted to extend outside the footprint of the existing buildings with any limited parking confined to the inner courtyards. The indicative building footprints and storey heights make it difficult to see how there could possibly be sufficient amenity space for new residents, and preserve the amenity of existing residents and quality of the Grade 2 Listed Building. Linked to this point is the fact that this part of Grove is deficient in open space provision, in respect of which County Hall, a public asset could help address this. We ask SCC to respond to and address this. Could for instance the cobbled car park on the west side be repurposed as a linear park, providing some benefit to residents.
  • Public Realm. SCC states that there would be “a vastly improved Public Realm”. The former tennis courts to the rear of the staff club building, that were open for use by local residents, as well as SCC staff would be an asset worth retaining in this respect. In reality very limited public realm is to be provided in the proposed scheme, other than public access to one of the inner courtyards. Gardens are also to be provided at podium and fourth floor levels of the Bittoms tower block – hardly Public realm!The architect stated that there is plenty of provision of public open space in the area. He referred to a park to the north of County Hall. Maybe he was referring to the Fairfield, but that is not very local, and the fact is that Grove Ward has a significant deficit of green open space. More green amenity open space needs to be included and this should be used as a buffer between the Listed County Hall building and the existing residential properties in Milner Road and Woodbines Avenue.There is still great concern from local residents, particularly in Milner Road and Woodbines Avenue about increased levels of traffic in the local area generated by both residents of the proposed development, and also service vehicles. The next use of County Hall should be the opportunity to reduce traffic flows by limiting all vehicular access to the site from Penrhyn Road only.
  • Levels of traffic need to be reduced in the neighbourhood with the departure of SCC, and traffic calming introduced to remove the high speed joyriders, and those rat running vehicles who already blight this neighbourhood. RBK’s past assertion that the road barriers are sufficient misses the serious issue that has existed for several years.
  • In order to reduce traffic flows and pressure on local on-street parking, allocations on this site need to be strictly limited in the future. SCC has expressed their wish to reduce total parking on the site to 150 spaces or possibly zero, as required by the GLA. We do not expect that these will be empty promises, or that any future occupiers of this site to be entitled to parking permits on the surrounding roads. This should provide opportunity to introduce more green public realm such as the linear park to the west of the County Hall building.Any vehicle parking or service access retained on the site should be restricted to the areas within the inner courtyards. Land surrounding the Grade 2 Listed building should be landscaped, providing sufficient green amenity space for future occupiers and not compromising the amenity of local residents and views of County Hall.
  • Pressure on local services. The scale of the development proposed would impose huge pressures on local services, including schools, health, and transport which are already overstretched. Local residents regard this area as a blackspot for local schools, where it has become very difficult to secure places in local schools within walking or cycling distance. With other major developments already under construction this will only become more difficult.
  • Pressure on local utilities. A development of this scale will generate huge additional demand on local utilities infrastructure such as power, gas, water and drainage, and broadband, and all will require significant investment.No Community Betterment. The development offers no Betterment in the local neighbourhood such as schools, traffic calming, transport improvements etc, which is hugely ironic given it is a public asset and designated for educational use.
  • Purpose of Proposed Planning Application. It is readily apparent to just about everyone engaged with this proposal that the purpose of SCC pursuing redevelopment that is contrary to our Borough’s policy, is to maximise profit to help plug the abysmal state of SCC’s finances, which has been well publicised in the national press including their flagrant waste of public finances to purchase risky property investments. The majority of SCC staff have already been moved into offices in Surrey. Hence there is no need to purchase further property at vast expense, funded at the expense of the local environment and amenity of their long-time good neighbours and hosts in Kingston upon Thames. This development is simply unjustifiable and unnecessary.
  • There has been a thinly veiled reference to an element of heritage space within the Grade 2 Listed Building, but we are very concerned that this is merely a token offer, and this will be lost in the gross over-development. SCC’s departure should be an opportunity to make more, not less public access into what is a wonderful building.
  • Construction Impact. If this development were permitted the construction phases would have a huge impact in the local area for many years of noise, dust and traffic disruption, blighting a thriving residential neighbourhood in order to compromise a historic Grade 2 Listed Building.

In conclusion, the Riverside Residents Association would welcome a response to both the points of principle and the more specific points that we raise in this submission. As before, a detailed response to the RRA is required because SCC have publicly pursued what are quite obviously very hurriedly prepared, ill-conceived and egregious redevelopment ideas, and our residents are very concerned by what they are continuing to see.

We very much hope that our response will encourage SCC to pause and think again (albeit it didn’t the first time), and not to plough on with the submission of a planning application along the lines of what was in the exhibition for uses and scale and massing that are unjustifiable and deeply unpopular.

We would welcome the opportunity to meet with SCC to work out how best to take forward County Hall’s re-use in an appropriate, justified and collaborative way and suggest we look for a date early in the New Year to hold a discussion.

Robin Catlin FRICS

Vice Chair, and Chair of Planning and Development Sub Group Riverside Residents Association