RIVERSIDE RESIDENTS ASSOCIATION’S FURTHER FULL RESPONSE

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

5th September 2022 – Supplementary Objections

These objections supplement those we submitted on 4th February and 24th July 2022. They reinforce the point made in the earlier submissions that proposed Building A is totally out of scale with the local context and character – that being the surrounding two storey residential and the Grade 2* Listed Building.

The National Planning Policy Framework requires new development to be sympathetic to local character and history, indeed at para 197 it states in determining applications account should be taken of the desirability of new development making a positive contribution to local character and distinctiveness. The London Plan Policy D3 requires development to positively respond to local distinctiveness through their layout, orientation, scale, appearance and shape, with due regard to existing and emerging street hierarchy, building types, forms and proportions. RBK’s Core Strategy Policy DM10 identifies the most essential elements identified as contributing to the character and local distinctiveness of a street or area which should be respected, maintained or enhanced. This includes having regard to the amenities of occupants and neighbours, including in terms of privacy, outlook, sunlight/daylight, avoidance of visual intrusion and noise and disturbance.

Building A is neither sympathetic to, nor does it positively respond to local character/history, nor does it have due regard to the amenity of the existing residents – thereby failing the policy tests.  This is our view because what is proposed – 4, 6 and 8 storey towers with 3 and 4 storey link buildings – would be located far too close to the boundary of the surrounding two storey residential homes, and also far too close to the Grade 2* Listed Building.

It is not surprising that the applicant has persistently ignored requests from residents and even Councillors, (most recently a request by Cllr Skipwith at the Neighbourhood Planning sub-committee in July) to show how over-bearing and oppressive the sheer walls of their towers would be right next to neighbouring residential houses and gardens; private gardens that the residents have a right, protected by planning policy, to peacefully enjoy.

With no proper illustrations provided by the applicant to illustrate the totally inappropriate scale of what is proposed, Riverside Residents Association has used the applicant’s own elevations to show the scale and massing of new buildings against the existing homes on Milner Road and Woodbines Avenue. Our first image (A) is not a perspective view that would be seen from the street or indeed our back gardens, but the elevations show how unresponsive to context and character towers of 4, 6 and 8 storeys and of very broad mass would be, sited as close as one metre from our garden boundaries.  Image C, the elevations from the south against the houses of Woodbines Avenue, show even the link buildings higher than the houses, and their windows look out on the gardens and rear windows of the existing homes.

The removal of some, and minimising of other windows in the towers because of privacy concerns has made them even less attractive and sinister in appearance, and amounts to an admission that the whole structure is too big, too close and too intrusive.

And the final pair of images (E and F) are visualisations of exactly how much damage the massive A1 tower would do to the public’s view from the top of the Sterling prize-winning Town House and the setting of Grade 2* County Hall — again, the scale is totally out of proportion to the surroundings, and the pale grey bricks only detract from the grand setting, where we were promised reconstituted Portland stone by the applicant.

As previously pointed out in our objections, these images illustrate how this application is gross over-development of the site.  The applicant should be asked to look at the context and think again.  Good respectful and responsive design in this context – which is also the boundary between town centre and suburban residential, would be to step development on the Surrey Club/tennis courts down from the Grade 2* Listed Building to the two storey residential.  Optimising the site’s potential by responding to character and context, rather than maximising over-development.

On a related point the applicant has suggested that the Design Review panel think this proposal makes a positive contribution to local character, and we are at a total loss to understand how they could possibly come to such a conclusion. The bland grey brick material relates neither to the mellow Portland stonework of County Hall, nor to the stock brick of the Reg Bailey building and the surrounding houses.  The bare rectangular design, identical to speculative developments across the area, and maybe acceptable at an open site like Sury Basin, for example, bears no relation to the articulated detail and grandeur of the neighbouring buildings.

Image A – Elevations of towers A1-3 set against the scale of existing suburban houses in Milner Road (Nos. 5-13).

A While these are superimposed elevations, Blocks A1-3 would be just 3m from the rear boundary of the neighbouring gardens, and less than 18m from the back of the houses.  The impact on the Milner Road properties would be deeply and unacceptably harmful.  This image also illustrates the height contrast between Building A and the Grade 2* Listed Building.

How can a building the applicant acknowledges is 10 metres taller than one of Kingston’s most important heritage assets (and as tall as Town House) possibly be considered to enhance that building’s setting?

By contrast Image B below shows the current view from 2nd floor of No 42 Milner Road looking over the roofs of 5-9 Milner Road, the tennis courts, Surrey club and the Reg Bailey to Kingston University’s award winning Town House in the distance.  The full southern range of County Hall can be clearly viewed to the north.

Image B – current view to east from No 42 Milner Road

Image C – the Applicant’s elevations of Blocks A1-3 from the south set against the size of the existing suburban houses on the north side of Woodbines Avenue (Nos. 1-15 plus Reg Bailey Building and Christian Science Church)

Image D – visualisation of view of tower block A2, as an example, viewed from first floor bedroom window and looming over garden of No. 5 Woodbines Avenue.

 Image E – current view from the roof terrace of Kingston University’s Town House

Image F – visualisation of Image D with tower Block A1 in place

We conclude that proposed Building A is too big in terms of height, scale and massing, and would tower over the neighbouring residential homes destroying residents’ right to peaceful enjoyment of their private gardens.  At 10 m taller than the Grade 2* Listed Building it would be out of character – it simply is just not good enough. The applicant needs to radically scale back their offer.

They refer to this area within the curtilage of Grade 2* listed building as “car parking” and “Brownfield”, but it is neither of these.   It is the two tennis courts which were used by Surrey County Council as car parking without planning consent, and should remain public amenity.

Representations of support

Finally, we turn to the representations made to this application.  We checked in March 2022 and at that time there had been around 90 representations made, and all of these objected to the application, many making detailed points expressing concerns with what was proposed.  These were also in the main from neighbours and local residents, people who know, understand and have interest and passion for their local area. Then the Trampery/RER held events to publicise the scheme in June, and those that attended were sent an invitation to fill out an on-line form that ‘County Hall Kingston’ then sent to the LPA as a representation of support.  Here is the link that attendees received: https://form.jotform.com/221372285362050

The representations of support that were all made in a short space of time after the Trampery events, are from ‘Members of the Public’, and many make no more comment other than ‘support’.  It is evident from those that do comment that these representations of support relate solely to the use of the Grade 2* Listed Building for employment purposes. Comments such as support the program and I think it could lead to a thriving local business hub bear this out.  The weight of business related comments suggests two things – firstly there is opportunity for much more employment in the Grade 2* Listed Building, and this is much greater than the applicant suggests. Indeed, this aligns with the views of the Council’s recent Employment Land Review. Secondly, none of these representations in support considered the new build – Building A, their focus was wholly on the reuse of the Grade 2* Listed Building.  Thus, these representations only consider part of the application – ignoring Building A – this omission must be taken into consideration by the decision-maker, and be afforded much less weight than the far more numerous objections made by neighbours and local residents both before and following the period of representations of support.

Please take this letter as a duly made objection to the above mentioned planning application and please take our strongly held views into consideration in your assessment of the scheme.

We urge the Council to refuse the application and require the applicant to listen to the community’s concerns and to respond positively to our suggestions. 

Yours sincerely,

Robin Catlin FRICS
Vice Chair
Riverside Residents Association