RIVERSIDE RESIDENTS ASSOCIATION’S FULL RESPONSE to the revised applications for planning and Listed Building consent for the redevelopment of Grade II* Listed Surrey County Hall (SCH) – 21/03939/FUL and 21/03970/LBC

(Shown above: composite elevation view of northern new build element – to replace existing 1980s SCH computer wing)

Dear Sirs

Objection to the applications for planning and Listed Building consent for the redevelopment of Grade II* Listed Surrey County Hall (SCH) – 21/03939/FUL and 21/03970/LBC

18 July 2022

We have reviewed the variations made to the above mentioned planning application, and write to confirm our representations on behalf of the Association that represents residents in the local area.

Riverside Residents Association maintains its position and continues to OBJECT to the proposed development on a number of grounds.

With the exception of reducing the height of Building B the variations make no material improvements to this harmful scheme, and represent no more than window dressing. Therefore, our objection made on 4 February 2022 still stands.

Our Objections to this development are as follows:

• The applicant has failed to take resident views into consideration. Please see the table in Appendix A, which highlights the Applicant’s contempt and lack of any real recognition of the views expressed.

• The harmful impact of the proposed new build blocks of flats (Blocks A and B) on i) the Grade 2* Listed SCH Building and ii) neighbouring properties and their residential amenity and (iii) surrounding Conservation Areas.

• The unacceptable proposed mix of uses, the proposal is housing-led, but should be employment-led

• The mix of residential units fails to meet local housing needs, which is for family housing.

• Insufficient proportion and inappropriate distribution of affordable homes

• The unacceptable loss of family housing at nos. 5-7 Milner Road

• The insufficient provision of amenity space

• The impact on car parking and traffic in the neighbourhood

• The impact on social and community services

The Applicant undertook two rounds of public consultation in advance of their application, but they have failed to act on any of the detailed representations which we and numerous local residents have made at each stage of consultation. The Applicant RER has done nothing but pay lip service to their engagement responsibilities throughout. If they had listened to the community, the scheme would be very different with much more employment floor space in the Listed Building and a family housing focused scheme on the former Surrey Club site that responds to both the Listed Building and the context and character of the neighbouring residential properties.

The proposed scheme is still a residential-led development, contrary to the Pre-Application advice of 6 February 2020 given by RBK planning officers to Surrey County Council in relation to their residential-led Planning proposals. RBK stated:

“It is considered that the site should be re-used for employment use, which would include use by the University. On a sliding scale the most acceptable use of the building, in planning policy terms, is for:

  1. a) Redevelopment for Kingston University;
  2. b) Redevelopment of the site for B1a Office accommodation;
  3. c) Redevelopment of the site for other employment uses including for instance, publicly accessible uses/ community/ leisure/ entertainment/ hotel uses;
  4. d) Mixed use employment-led redevelopment of the site;
  5. e) Residential redevelopment of the site”

It is clear that the proposed residential–led scheme is the least acceptable use for a former public sector asset. The marketing evidence provided by the applicant pointed to zero demand for employment uses, but clearly show that neither the Applicant nor Surrey County Council before them have made any real and appropriate effort to market the site rigorously for acceptable use(s).

We now see that having claimed that there was no demand for commercial/ employment space, the applicant has now persuaded over 30 parties to register their interest in the scheme from their Trampery marketing. They continue to ask more companies and individuals to confirm their interest to RBK. We would be keen to see the full extent of commercial interest if the property were rigorously marketed.

We wholeheartedly support RBK Council’s position as set out in that pre-application advice. Residents and the Borough deserve a scheme on this site that delivers so much more than a 1 and 2 bed residential scheme. In our view it is no surprise that a residential developer has not worked very hard to deliver anything other than what is a very largely residential scheme. However, the very purpose of development plan documents and the strategies and policies they contain is so that developers can be guided to come forward with schemes that are in the public interest, in accordance with the Plans to deliver what is now termed good growth.

As we have recently seen in the Tolworth Tower appeal decision those policies and the thrust of the Plans cannot just be set aside because of the age of the adopted Plans or because the Council cannot demonstrate a five-year housing land supply.

We are convinced there is a much better, policy compliant solution for this site that could include Kingston University, and we urge RBK Council to require the Applicant to rethink their approach.

Turning to the amended scheme:

The Applicant makes a marginal increase in the Flexible commercial space in the 1893 and 1963 buildings, but this is far from enough.

Why is it that all the commercial space will be provided for The Trumpery only? We want to see other businesses that do not necessarily need co-worker space given the opportunity of locating in County Hall in an Employment-led development.

Otherwise, the Applicant’s scheme changes are merely tweaks to the design only.

The Applicant has reduced the height of Block B from 6 to 5 storeys as recommended by Historic England. The height and mass of the original proposal was so incongruous when set against the Grade2* listed building that harm was plain to see. However, the design and mass of the reduced height building are still inappropriate over-development. Unlike the other gateway buildings in the immediate area, Grade2* SCH and Kingston University’s Town House, the design is mediocre at best, and will detract from their quality.

But the primary concerns of local residents revolve around the harmful proposals for Blocks A1, A2, and A3 and the scheme for Block A4 (5-7 Milner Rd) where 2 family houses will be lost. There have been no modifications to the layout, height or design of this element of the development, other than some minor changes to a few balconies and privacy screens.

These new-build residential towers planned within the curtilage of the Grade 2* listed building are disproportionately large, far too high (A1 being TEN metres taller than County Hall and blocking views to its bell tower), far too close to the southern and eastern ranges of SCH and far too close to the neighbouring Edwardian two storey suburban homes. The noted ‘grandeur’ of SCH would be compromised exceptionally and permanently as a result.

If the Council is concerned to protect the Borough’s heritage assets and to deliver good growth that we can all agree is positive, then these proposals must be refused and the applicant asked to come back with a scheme that is compliant with the policies in the Development Plan.

Blocks A1 and A2 will be private residential, and are still proposed within 11 metres of the Grade2* and would tower above the Southern and Eastern ranges of County Hall. This is the type of proposed development referred to as ‘town cramming’, far too close to a Grade 2* building, failing to give a civic building and one of the Borough’s most important landmarks an appropriate setting. Development that is respectful to the setting and subservient to the Grade 2*building is required.

Block A1 is a tall building under London Plan Policy D9, as it exceeds 6 storeys. Whilst it is in the town centre, it is not in a location identified for tall buildings, and is highly inappropriate along with Blocks A2 and A3 in the impact they will have on the surrounding neighbourhood, which they will overlook.

Block A3 would still be located close to the boundary of the Edwardian suburban housing to the south and west (Woodbines Avenue and Milner Road), and close to Surrey County Hall to the north. A3 is only 2 metres lower than the south side of County Hall so is again, disproportionate in size. Like Block A2 contrast between the proposed 4 storey flank and the 2 storey Edwardian Houses with gardens over which it will loom will be stark, and will harm the private residential amenity that residents of those houses currently enjoy. As we previously pointed out, this is contrary to Core Strategy policy and the Council’s Residential Design Guidance.

The result of this incongruous and disproportionate development will be a severe loss of the privacy and amenity of the existing local residents, and significant harm to a number of Kingston’s Heritage Assets, including Surrey County Hall, The University Town House, and the surrounding Conservation Areas.

In other terms we see no material change to what we have already objected in detail. For these reasons the Riverside Residents Association continues to OBJECT to this planning application.

Robin Catlin FRICS

Vice Chair, Riverside Residents Association


Riverside Residents Association – Neighbourhood planning meeting 21st July – our comments to the committee:

Good Evening = I am Robin Catlin, Vice Chair of Riverside Residents Association. We represent the majority of local residents in the roads surrounding County Hall and my family has been residents in Woodbines Avenue for 30 years.

RRA and many local residents have objected to this scheme on a number of grounds.

This is a Grade2* building, zoned for Civic and Educational uses. Surrey CC has sold the building to a residential developer for the highest price but it should now revert to a predominantly employment-led use. Where will new and real jobs be created now in Kingston Town Centre if we let this go? The sum total of little pockets in the ground floor of tower blocks will not sustain a local economy.

The Applicant has ignored all of our representations to their public consultations.

Neither the Applicant nor SCC have marketed the site fully or rigorously for educational, employment or civic uses to justify their predominantly residential development with some token serviced offices.

This proposal does not comply with RBK’s Local plan or the London Plan in many ways.

Their scheme will permanently deprive Kingston of one of its most important Gateway and public buildings, and a key Heritage asset, by converting it to a private housing scheme of predominantly 1&2 bed flats, with limited affordable housing and limited family housing. In Milner Road they would also convert 2 perfectly good existing 3-bed family houses to 4 more 1-bedroom flats. There are better alternative uses for Kingston for this unique asset which the Council could investigate.

But the most harmful elements of the entire scheme will be the huge new blocks of flats with inarticulate architecture which will be crammed into the site between Penhryn Road and Milner Road to the south of County Hall. This is development seeks to maximise profit for the developer and is simply not appropriate for Kingston.

It will do immeasurable harm to the setting of both this Grade 2* listed building, Kingston University’s Stirling architectural award winning Town House opposite and the surrounding Conservation areas.

Building A1 at 8 storeys, will be sited only 11 metres from the southern range of County Hall, and will tower over the listed building by more than 10 metres blocking the southern view of the magnificent Bell Tower.

Buildings A1-A3, ranging from 4 to 8 storeys, will also overlook the 2-storey Edwardian houses in Woodbines Avenue and Milner Road, causing a severe loss of privacy and amenity for the local residents, and generating significant amounts of light and noise pollution.

Overall, A1, A2 and A3 too high with too much mass, are mediocre in design compared with County hall and the Town Hall and will entirely dominate the adjacent important buildings.

Building B falls into the same category, despite being reduced from 6 storeys to 5. It is still too high with too much mass, too little architectural detail and failing to respond to the character of the adjacent listed building

This overdevelopment will negatively impact on traffic, parking pressure on local infrastructures.

So the question is whether RBK should sacrifice one of their finest Heritage Assets and a key employment site for a use and design which is far from exemplary, and will remove all sense of Place and deliver zero benefit for the town as whole? For many reasons, RRA conclude this proposal is simply not good enough to approve and we request the council commence an enquiry to consider alternative uses.