This feedback is submitted by Riverside Residents Association (RRA) in response to the Virtual Presentation posted by Surrey County Council (SCC) between 7 – 25 September 2020, following RRA member discussions.

The RRA represents residents in the area bounded by: South 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.

We found the SCC online feedback form rather inadequate. It only asks four very specific questions about the in-principle proposals, with quite amazingly no mention at all of your plans to build the tallest building in Kingston on the Bittoms car park! We have therefore 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, as it is fair to say that SCC’s headlong rush to pursue redevelopment plans for County Hall has raised considerable disquiet and concern within the RRA and indeed beyond.

The RRA’s response to SCC’s proposals as presented in the exhibition and at the online webinars is as follows:

Firstly, and fundamentally, the County Hall site is not designated for residential uses in the adopted statutory Development Plan. The planning system remains plan-led, and key documents in this respect are the Core Strategy and the Kingston Town Centre Area Action Plan, and as SCC will be aware these documents designate this important public asset for continuation of its civic/public use or for educational use. The RRA contributed to the preparation of Kingston’s Development Plan, and are now very disappointed to see SCC’s redevelopment proposals for the County Hall site pay scant regard to the adopted Development Plan, and go straight to a non-designated maximum value use, which is contrary to the Development Plan. There was very little said in the presentations by SCC’s representatives on this issue despite questions being asked. Glossing over this fundamental issue in this way is not in the spirit of public engagement, and frankly is just not good enough.

Our fundamental point is that all potential options for civic, educational or community uses need to be thoroughly explored before alternative non-policy compliant uses are considered. This needs to be done in a thorough and transparent way, so that the local communities whose lives are affected by decisions such as these, can see that appropriate engagement with civic, community and educational institutions and the local authority has been undertaken. The departure of SCC from Kingston really does present a once in a lifetime opportunity to repurpose what is a key public asset in the Borough to provide civic, community and/or educational facilities in Kingston’s designated civic and educational quarter in accordance with the adopted Plan.

Such opportunities in a building suited to institutional use do not come along very often, if at all. It is an opportunity that the County no longer has good reason to force the Borough to rush. The SCC programme smacks of indecent haste, and suggests the County are only interested in ‘turning a fat fast buck’. SCC’s plans for County Hall will have a huge, direct and permanent effect on the members of the RRA, and so we request that in the spirit of engagement SCC explain to us what discussions there have been with key stakeholders in this regard.

Secondly, but notwithstanding the fundamental ‘use’ point above, we provide feedback below on the exhibition material, as invited to do so by SCC. Again here, we firstly raise an over-arching point about the blocks of proposed development in the presentation material. These illustrations represent huge over-development of the site with no regard to the true context of the location.

We illustrate our point by referring to how the architect at the webinar explained the thinking behind the blocks that would replace the Surrey Club, and our comments apply equally to the suggested height, scale and massing on the Bittoms Car Park. The architect stated the reference point for the nine storey building was KU’s Town House building. But, Town House is not the right context for the Surrey Club site, there is a lot more relevant and more appropriate context that should be considered.

  • The Club is on the same west-side of Penrhyn Rd as County Hall (Town House is on the east-side).
  • The Club building is within the curtilage of the listed building, in fact almost within touching distance of the listed building.
  • The two storey Reg Bailey building is immediately to the south, t.
  • The site marks the point where the town centre civic and educational quarter meets non-town centre two storey residential with gardens.

Given that context, we are very unimpressed by the architect’s nine storeys and five storeys on the tennis courts response. The architect’s approach to this part of the site really gives away SCC’s overall strategy here – cram in as much as you think you might possibly get away with. It ignores the real context, takes the wrong references, hides behind London Plan housing numbers, is inappropriate in the context of the prevailing non-town centre residential area it abuts, and can only be considered to be over-development that would certainly not respect the Listed Building’s setting and would fail to deliver on the Government’s aim of ‘building beautiful’.

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 grossly misrepresents the material facts about the property and the development proposals. Hiding behind the opportunity presented by the COVID-19 pandemic, the PR consultants 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 uses.

  • SCC failed to fully notify all local residents of the Public Consultations. There have been a number of complaints, for example, the residents of Avante Court were not notified.
  • The Virtual Exhibition is grossly misleading and conveniently buries the key facts. For example, there is no mention of the Grade 2 Listing of County Hall until information board 7 of 11, and then it is a passing reference.
  • As mentioned in the introduction, the feedback form is totally inadequate.
  • On board 4 – Development Principles, shows plans for 2 new blocks of affordable accommodation of 5 storeys (described as 4 storeys) and 9 storeys, sandwiched between the southern aspect of the Grade 2 Listed building and the 2 storey houses in Woodbines Avenue. This shows a large swathe of open land forming a buffer between the houses and County Hall. This ”buffer” is actually the gardens of the houses in Woodbines Avenue and Milner Road, and SCC has conveniently omitted the boundary, right up against which these buildings would tower.
  • SCC has described their proposal as mixed-use, but in reality it would deliver 400/500 flats with a token heritage offer, and some “white elephant” retail units.
  • Historic England – 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. We would welcome seeing copies of HE’s response to the development proposals.
  • Civic and Educational Use. Reiterating what we say earlier, it appears SCC has had little engagement with any potential civic or educational users, marketing 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 the webinar presentations on this point SCC were only able to refer to “a conversation with Kingston University”, and certainly not the form of engagement we should expect.
  • Purpose of Proposed Planning Application. It is readily apparent to just about everyone engaged with this 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.
  • 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 400-500 units on one of the very few sites 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.
  • Kingston Town Centre Area Action Plan. 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 needs to consider the context of the surrounding 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 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 rising ever higher within predominantly 2-storey residential neighbourhoods.
  • 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 wholly inappropriate and unjustified.
  • SCC’s presentation claims that the existing context in Kingston Town Centre includes some fanciful notion of a planned arc of high rise buildings, many of which have not been built, and may never happen.
  • Strategic Viewpoints. Any high rise development on the County Hall site will blight many strategic viewpoints, most particularly the view from the ancient Kingston Market Place, but also Penrhyn Road, and we ask for the immediate, close up views to be modelled.
  • Development of 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.
  • Retail. The Architect advised in the online presentation that retail space or cafes would be provided at ground floor level in with the Bittoms Car Park development for the benefit of the residents. 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. Questions were asked correctly about viability and demand for this space but dismissed by SCC.
  • Development of SCC former Social Club and Tennis Courts (South Blocks 1&2). The construction of 2 new blocks of affordable flats, 5 storeys and 9 storeys high, will overlook the residents in Woodbines Avenue and Milner Road, and block their views of the Vincent Davis designed wing of the Grade 2 Listed County Hall. As currently proposed these blocks would be constructed right to the boundaries of the existing residential properties, causing considerable intrusion and loss of privacy and light.
  • Materials to complement Grade 2 Listed building. No details have been provided of the materials to be used to treat any of the areas of new build space, and particularly the new blocks on the Bittoms Car Park site and South Blocks 1&2. In the online presentation the architect made reference to the sympathetic treatment of the University’s’ new Town House development which mirrors the red brick of the adjoining University building. The architect was then very quick to dismiss the idea that they might use Portland stone in sympathy with the Grade 2 Listed County Hall building. It is very disappointing to hear that SCC is already intending to dilute the quality of the extensions to a Grade 2 Listed building.
  • Furthermore, if South Blocks 1&2 were permitted for affordable accommodation, the developer will inevitably reduce the quality of the development to the lowest cost specification, which will further blight the Grade 2 Listed County Hall.
  • Affordable Accommodation. SCC is proposing to construct South Blocks 1&2 exclusively for affordable accommodation. Planning legislation now requires that any affordable accommodation is fully integrated into any development. SCC is planning 2 separate blocks of 5 storeys and 9 storeys which will overlook the local residents in both Woodbines Avenue and Milner Road, and blight the Grade 2 Listed building. All affordable accommodation should be included in the conversion of the listed building, and fully integrated into the development, if permitted.
  • Light and Noise Pollution. The change of use to 400/500 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.
  • Amenity space and landscaping. A development of 400/500 residential units will require significant amounts of green space and amenity area for the residents. A first principle of residential design is that one designs back to back gardens. 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 we really are to build better, build beautiful as the Government wishes. The open areas around 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 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. 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.
  • Traffic. There is 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 via 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 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.
  • Parking. 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.
  • 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 ironic given it is a public asset and designated for educational use.
  • Heritage. There has been a 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 will be lost in the gross over-development.
  • Construction Impact. If this development were permitted the construction of the development 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. A detailed response to the RRA is required because SCC have publicly pursued what are quite obviously very hurriedly prepared and ill thought through redevelopment ideas, and our residents are very concerned by what they have seen.

We very much hope that our response will encourage SCC to pause and think again, and to not 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 deeply unpopular. We would very much welcome the opportunity to meet with SCC to work out how best to take County Hall’s re-use forward in an appropriate and collaborative way.