RIVERSIDE RESIDENTS ASSOCIATION’S 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


(Shown above: composite rear elevation view of southern new build element – as would be seen from the

gardens in Woodbines Avenue – to replace existing SCH staff canteen and social club)

This letter of objection is submitted by the Riverside Residents Association (RRA) in response to the above mentioned applications for planning and listed building consent. 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.

At the heart of this area is the Grade II* Listed Surrey County Hall (SCH), which is central in many respects to the area’s character. Therefore, this Association has an extremely strong connection and affinity with the building, and a very keen interest in the plans to repurpose the building and redevelop some elements within the building’s curtilage. Our mission is to ensure the repurposing and any ancillary redevelopment is exemplary in terms of use and architecture as befitting the Grade 2* listing, and that development supports the interests and needs of local residents (current and future) and Kingston town as a whole. We are a proactive and engaged Association that has a proud history of contributing to planning applications and the preparation of Local Plan documents; we want to support the Council and developers to deliver Good Growth.

The RRA Committee has considered these latest applications and found that they raise some major concerns, and generate the reasons for objection that we set out in this letter. The RRA Committee is strongly opposed to the proposal, and the applications in their present form are certainly not good enough to approve, and we urge the Council to refuse permission.

In summary our concerns and reasons for objection to the applications are:

  • The applicant has failed to take resident views into consideration
  • The harmful impact of the proposed new build on i) the Grade II* Listed SCH Building and ii) neighbouring properties and their residential amenity and (iii) surrounding Conservation Areas.
  • The unacceptable proposed mix of uses, including the mix of residential units which fails to meet local housing needs.
  • 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
  • The impact on social and community services

The applicant has failed to take resident views into consideration.

In drawing up proposals for new development to achieve well designed places, as set out in the National Framework, promoters are required to engage with local communities and evolve designs that take account of the views of the community.

In this locality the RRA are the main non-political representative local community group, and have been for many years. RER have met with, and are fully aware of RRA. The RRA submitted responses to both rounds of RER engagement, and in particular RRA expressed serious concern in respect of the plans for the replacement building on the Surrey Club/tennis courts site, which it saw as extreme over-development and extremely unneighbourly to both local residents and to the Grade II* Listed Building. So that the Council can see the range of concerns we raised with RER before the application was submitted, we attach to this letter of objection (enclosure 1) our Nov 2021 response to the second and final round of engagement.

We are very disappointed to say that with the exception of the removal of the pavilions, which were always no more than a smoke screen, none of the other issues or changes that we suggested have been made or taken into account to improve the scheme to the satisfaction of the local community, and deliver a scheme good enough to permit.

Our disappointment is compounded by the fact that the statement of community involvement does not acknowledge our detailed responses (those set out in Enclosure 1). This is totally unacceptable, and is clear evidence that RER have done nothing but pay lip service to their engagement responsibilities. This has certainly not been public engagement in line with the Government’s intention; where in the application have our comments been taken on board?

Not only did RER ignore RRA’s representations, but also, despite numerous requests (and promises made by RER) for some detail of the proposed new building southern elevations at the time of the engagement, nothing was provided. Having now seen the southern elevations, which convey something of the totally disproportionate scale of the proposals, we can see why RER chose to keep them under-wraps!

RER’s application proposes a scheme that is the same as that tabled in the second round of consultation. RRA responded to the second round (as it had to the first), registering serious concerns, but nothing has changed. RER’s application therefore does not take account of local residents views, it falls into the category of proposal that the London Mayor would call ‘growth at any cost’, exactly the type of development that the Mayor is now pivoting away from, and not the kind of development he, the Council or we would call good growth.

Of course the applications do have elements that are ‘good’ – jobs and affordable homes – but simply not enough of either to truly optimise the reuse of the site, which combined with the harm to neighbouring living conditions and the setting of the Listed Building, means that it is not good enough to approve. RER must be required to try much harder to deliver a greater mix of uses, a higher proportion of affordable housing and to propose new build solutions that are appropriate and sympathetic to the context.

Harmful impact of the proposed new build on:

1. the Grade II* Listed Surrey County Hall Building

The statutory and other controls, in place through Listed Building legislation and policy, rightly present a high hurdle for development that would affect the setting of a Listed Building (and Conservation Area). Last year’s upgrading of the Listed Building status of SCH was made in recognition of the building’s significance in architectural terms and also because of its public function. SCH is therefore in the band of heritage assets that are of the highest significance (II* and above) and proposals must be sympathetic to the setting of the building.

In terms of policy we consider the proposal fails to satisfy the requirements of intra alia London Plan Policy GG2 that seeks to achieve an optimum amount of development that means through respecting character and context. The Mayor is clear in his forward that Good Growth is not growth at any cost, it is about optimising uses and scale by responding to context. HC1 that seeks to conserve the historic environment and requires development to conserve heritage assets and avoid harm. D9 that amongst other matters refers to avoiding harm to heritage assets (Cd) Core Strategy CS8 that seek to resist inappropriate development in areas of high quality and historic interest, while seeking opportunities for sensitive enhancement. DM10 requires new development to respect the elements that contribute to local character and distinctiveness, including prevailing densities, set-backs and boundaries. DM 14 that seeks to resist the loss of family homes. The Council’s Residential Design Guide adds detail to guide interpretation of policy and in particular PG 14 and 15 that provide the standards for open space provision, and the avoidance of overlooking, and PG16 that identifies acceptable separation distances. The NPPF seeks development should be that is sympathetic to local character and history, including the surrounding built environment and landscape setting. For the reasons we set out below we are firmly of the view that RER’s current scheme fails to satisfy all of these policy tests.

It is RRA’s view that neither the replacement computer building nor the new build on the Surrey Club and tennis courts site are appropriate in terms of height, scale, massing and architectural style to be good enough to approve.

The proposed replacement computer building (Block B) is taller and bulkier than the Listed Building ranges located on either side as clearly shown in View 2 of the TVIA; it really is a very bulky unit! That view displays an insensitivity to the constraints and opportunities imposed by the heritage assets. It is at least one storey too high, the mansard appears overly ‘heavy’ and dominant, and in terms of form it is neither modern nor of the same style as the neighbouring listed elements; an inferior design compromise not good enough to approve.

The proposed replacement building on the Surrey Club/tennis courts site (Block A) that provides 90(4) units on a site of just over a quarter of a hectare is in our view a gross over-development 300+ units / ha) and the wrong design approach for the following reasons.

The new residential towers planned within the curtilage of the listed building are disproportionately large, too high and far too close to the southern and eastern ranges of SCH and too close to the neighbouring Edwardian two storey suburban homes. The noted ‘grandeur’ of SCH would be compromised exceptionally and permanently as a result for the following reasons:

a. Residential Building A1 is 8 storeys. At 36.8m in height, it would be over 9 metres taller than the south side range of SCH (27.8m) and 17m higher than the 1893 building. This tower is also higher than SCH’s landmark clock tower and will obscure the view of the clock face. If permitted SCH (important for its now historic public function) would be dominated by a large, new private residential tower of inferior design, built in a common modern design, attempting to mimic KU’s Town House, but lacking the setback, depth and articulation of that building, and built within 11 metres of SCH’s southern and eastern ranges. The north to south view of SCH and the clock tower will be seriously degraded as the Listed Building’s profile will be lost against the background of the taller modern tower. This would degrade the value of a very public Grade II* heritage building, thereby devaluing Kingston’s civic and educational quarter notable for its ‘signature’ buildings – Town House and SCH and the Guildhall, and is something the RRA strongly objects to.

The current 1970’s Social Club building, which would be replaced by the 8-storeys A1 block, is just three storeys and a discrete and respectful neighbour in terms of scale. We accept that its form/materials and the narrow gap between it and SCH cause harm to the setting of the Listed Building, but in terms of scale it does step down and sets what we and its architect consider to be the acceptable height in that location – and the acceptable height for a replacement building, subordinate in terms of scale as seen from progressive points along Penrhyn Road. It would also allow an appropriate stepping down in heights from the pre-eminent SCH building, through the replacement Surrey Club building and on to the Reg Bailey and suburban two storey residential immediately beyond, and which are outside the town centre boundary.

b. Residential Building A2 is 6 storeys/ 30.85m high A2 is over 3 metres taller than the south side of SCH from which it will be separated by less than 11 metres. This building is also 10 metres higher than the 1893 building so is disproportionate in size. As a result, the current view of SCH will be lost when viewed from south to north.

c. Residential Building A3 is 4 storeys/24.6m high. This building location is right to the boundary of the Edwardian suburban housing to the south and west (Woodbines Ave and Milner Rd), and close to SCH to the north. A3 is only 2 metres lower than the south side of SCH so is again, disproportionate in size. It is also at least 4.6m higher than SCH’s 1893 building. The contrast between the proposed 4 storey flank and the 2 storey with gardens suburban residential over which it will loom will be stark.

d. Proximity of proposed new buildings to the listed SCH The distance between the southern range of SCH and the new residential buildings (A1, A2 and A3) is far too narrow at just 11 metres, a span that would be a public thoroughfare with no defensible space separating the building frontages containing habitable rooms from the very public areas. The impression we get is that the development would very much resemble a student halls of residence. This 11 metre distance is half the 21 metre rule of thumb commonly used to avoid issues of overlooking and to provide privacy. It is very likely to infringe heritage guidelines too, as such a bulky (A is one building) and tall replacement building squeezed into a gap so close to a Grade II* LB would, in addition to the height domination, mean the southern façade would lack reveal. It is noted that distances to external building lines to the north, east and west sides of SCH are at least 22 metres (Saxon Court).

The south and west sides of SCH border Edwardian two storey family homes with gardens, and provide attractive views of the south and west aspects of SCH. SCH’s south side is particularly impressive in its palatial scale. The view of the south side of SCH would be lost due to being entirely blocked by the planned A1, A2 and A3 mostly private residential towers built using a commonplace, incongruous and unimaginative architectural design.

SCH’s exterior jewel is the clock tower, which can be viewed clearly from another important view point – Barge Walk, which is a popular Thames riverside path for walkers to Hampton Court Palace. SCH and its clock tower would be partly obscured and their importance lessened by the private residential blocks that would loom either side of the Listed Building when viewed from Barge Walk from south to north.

The east side of SCH faces the Kingston University Penrhyn Road campus, where the award winning Town House building sits a little further to the south of SCH. RER claim reference to Town House in their Block A building in terms of architectural style and gateway to Kingston town. However, there are clear and fundamental differences between Town House and RER’s Surrey Club replacement. Town House has considerable setback from Penrhyn Road, and the building’s articulation with deep recesses reduces the massing effect of what is a tall and large scale building. A fundamentally different setting and design when compared to an eight storey private residential tower lacking elevational articulation that would be positioned just 11 metres from, and looming over, the Grade II* listed SCH whose public service past is a critical reference in its listing.

e. Rebuttal of the RER Heritage Assessment

RER’s ‘Heritage justification’ as set out in their Heritage Assessment in relation to Block A finds (and we quote from para 281) that the scale of impact on the setting of the Listed Building would be minor and limited to only a part of the asset. The effect of this change on the significance of its special interest would not be adverse or erosive of the asset’s significance. Whilst the change to the setting of a limited part of the listed building may have an impact, a conclusion of no harm to the overall significance of this heritage asset is found. The section then goes on to list the reasons why they arrive at that finding.

We fundamentally disagree with the reasoning and conclusions drawn by RER, and feel so strongly about what we consider to be such a non-impartial assessment that we have reviewed and respond to RER’s assessment point by point. This we attach to this objection letter at (Enclosure 2). In summary, we disagree with RER on each point they raise, and find that there is indeed harm in relation to the overall significance of the heritage asset and to the townscape. This results from the competing scale, the mass and the architectural language used, as is evident in particular from Views 03 & 08 of the VIA. In terms of the wider context, and how Block A integrates, our view is that the building should be much more ‘transitional’ and step down in height as it relates to the neighbouring terraced suburban houses to the south as this existing townscape context forms no part of RER’s justification strategy.

2. Neighbouring properties and their residential amenity

Buildings A2 and A3 are planned to be built within one meter of the boundaries of gardens of houses on Woodbines Avenue and Milner Road, which would lead to totally unacceptable overlooking from the proposed balconies, roof top gardens and windows into the private gardens and bed/living rooms which they would face. For example, at the end of the gardens of No 1, 3, 5, 7 Woodbines would be a six storey tower within one meter of boundary. Given the scale, with so many new flats in such very close proximity (46 flats in A2/A3) and six storeys in height with slit windows right on the boundary, this is certain to affect natural light and create considerable noise and light pollution. Bringing such a very unneighbourly sense of over-bearing and over-looking to the private gardens just over the fence would generate a hugely harmful impact.

Immediately south and west of the Surrey Club/tennis courts (which are part of the southern boundary of the town centre), is suburban family housing, and this is of moderate, but not ultra-low density – approximately 30 dwellings per hectare. RER’s application proposes 90 units on this land, which is at a density of 300+ units per hectare. We note that there is policy encouragement at national and regional level to increase densities, but there is also policy support to optimise through making an appropriate response to context (LP D3). Squeezing in a block that is ten times the prevailing local density is an inappropriate approach, is not responding to local context, and is simply an attempt to maximise the number of units regardless of context – the discredited old approach of growth at any cost. It would not deliver the beautiful places the Government seeks. Such contrast between the two storey context and what is proposed is shown in the western elevation application drawings where the residential on Milner Road (and indeed County Hall) are dwarfed by the bulk and scale of the proposal looming to the rear. As referred to earlier residents want to see a step down in scale at this point to make what would be a more appropriate response to context – the transition between town centre and suburban homes.

3. Conservation Areas.

Not only is SCH an important and cherished heritage asset on the edge of Kingston town centre, it is also surrounded by three Conservation Areas, all of which will be directly or indirectly effected by the new developments proposed. The three are:

  • Grove Crescent
  • Kingston Old Town
  • Riverside South

The Conservation Area that would experience the greatest level of harm is Grove Crescent which, along with Fairfield/ Knights Park was a planned mid-Victorian estate of houses of various sizes and styles, laid out around 1863 from Grove Crescent, immediately opposite SCH on Penrhyn Road.

The height and density of the new buildings proposed, particularly Blocks A and B will do irreparable harm to the context of the surrounding Conservation Areas (as well as to SCH).

The harm to the setting of Grove Crescent Conservation Area (and indeed SCH) is clearly shown in Views 2 & 3 of the TVIA. The scale and height of both Blocks A & B will detract substantially from the Conservation Area settings that are much more modest in scale and have been designated precisely to avoid this sort of egregious development proposals. Our Conservation Areas must be protected against such damaging proposals.

In summary in respect of Block A, given the sensitivity of the setting of the Surrey Club/tennis courts site, the architectural quality of the replacement Surrey Club building needs to be both exemplary in response to the Listed Building and sensitive to the surrounding non-town centre neighbours, but the proposal certainly does neither. The very widely held view of residents is that Block A is an unremarkable ‘block’, that attempts to mimic Town House, but is a pastiche that lacks the depth and articulation of Town House. At the beginning of this section we summarised our objections to Block B.

Having reviewed the application material, in our opinion neither building is good enough to approve.

Unacceptable proposed mix of uses

• the uses proposed in the SCH building

The adopted Development Plan allocates the site for civic and educational uses, as befitting of its public service heritage, and the local community were and remain very supportive of that allocation. The London Plan (S1G) states that redundant social infrastructure should be considered for full or partial use for other forms of social infrastructure before alternative developments are considered. Social infrastructure includes a range of services and facilities that meet local and strategic needs and contribute towards a good quality of life. It includes health provision, education, community, play, youth, early years, recreation, sports, faith, criminal justice and emergency facilities

RER will have been aware when they purchased SCH of the responsibilities that went along with that purchase in terms of the need to provide social and community infrastructure. With just 2,800 sq m of commercial uses in the part of the building that could not be converted to residential, and no social or community uses proposed, we do not consider this to be genuine attempt at a mixed use scheme as is the policy intention. Where is the evidence that the social /community uses have been explored, or that the commercial uses have been fully optimised – the Savills report suggested there could be interest from local office occupiers, and in that regard what does the Council’s new Employment Land Review tell us? There appears to be a healthy market for workspace in Kingston. In this respect we note the private developer-led Bromley Town Hall redevelopment, another listed former public building, is to accommodate around 7,000 sq m of commercial space plus a boutique hotel. It does appear that local residents and the Council are being short changed in terms of the provision of business space in the building. The

Neither RER nor Surrey County Council before them have made any serious efforts to market the site widely or openly to users for policy compliant or commercial uses. This is clear from the lack of market evidence provided. Apart from engaging with KU as they are required to, Avison Young on behalf of Surrey County Council, only marketed the building to residential developers, and in a very covert and restricted manner. They erected a ‘for sale’ board on the site in October 2020, and then slapped a “sold” slip over the board in late January 2021. They produced limited marketing material which was not openly available, and the key information was held in a limited access on-line information room.

RER has clearly undertaken even less marketing, the most limited engagement with KU to tick a box, and in this respect we note that RER pass the ‘engage with KU’ baton to the Council. They have enlisted a serviced office operator to fit out the most sensitive parts of the 1893 Building where flats were not an option. The marketing evidence which RER has presented with the application extends only to a very sketchy marketing summary from Avison Young, and a market commentary from Savills and a viability analysis which highlights only that RER paid too much for the property, based we suspect on the ‘hope value’ that in so doing this would make all policy compliant uses unviable (no money ring fenced to make the necessary investment to allow for the policy complaint uses), making it ‘open season’ for the higher value non-compliant residential use. Surrey County Council had neglected the building for many years prior to sale and therefore any compliant user for the building, such as Kingston University, would never have been in a position to compete with an avaricious property developer. The public benefits in terms of social and community uses that should rightly accrue from the repurposing of this building cannot be sacrificed just because RER over-paid for the site in terms of price paid and overage.

We understand the pressing need for housing in London, and the Council has struggled to demonstrate a five year supply, but this is a building that should provide a genuine mix of uses, uses that can deliver public benefits. It is not acceptable for RER to immediately default to 92% residential without having considered all the social, community, educational, commercial (including leisure) uses, and RER have not provided evidence that they have exhausted all such opportunities.

While there may be a case for some residential in SCH if designed sympathetically, this should only be as part of a genuinely mixed use development whereby uses with public benefit are included in the mix so that continued public access to the building is maximise. On a related point RER do rightly consider the relevant policies of the development plan because even if the Council is not able to demonstrate a five year housing land supply, and the presumption is engaged, this does not mean the development plan is set aside. It means only that sites, such as SCH that are not identified for residential, can be considered for such.

• the mix of housing size/type

Policy is clear (London Plan Policy H10) that proposals should have regard to local housing need where evidence is available. The Council’s 2016 housing report prepared by Cobweb is such evidence, and it found an acute need in Kingston for family accommodation. Indeed, it concluded that 75% of the Borough’s need was for family accommodation, more so than any of the other neighbouring Authorities. When we look at what type of accommodation has been delivered in the Borough in more recent years, this has been mostly more one and two bed flats, and it can only be the case that the need for family accommodation will now be even more acute.

RER propose 85% one and two bed flats. RER do not refer at all to the Cobweb report, nor do they refer to what is an obvious acute shortage of family accommodation in the Borough, and in Kingston Town in particular.

The mix RER propose would inevitably in part end up occupied by families because of the lack of alternative family homes. There is anecdotal evidence that this form of over-crowding in flats blocks, such as Avante Court, is the reality. Developers and the Council are playing a ‘numbers game’, where the Council to avoid sanctions and in the developer’s case to maximise profit, the focus is the total number of units delivered. Whereas the interests of sustainable development and meeting peoples’ real accommodation needs, the housing mix should be about meeting the housing need.

RER’s application is not policy compliant, they propose 85% one and two beds where the mix should be 85% family accommodation. We accept that this may not be achievable in the Listed Building, but it certainly is achievable on the Surrey Club/tennis courts site, where what is currently proposed (largely one and to beds) is not acceptable. However, were RER to respond to the local context on that land with a more modest and appropriate increase in density (including providing private gardens) they could provide some genuine family housing satisfying that policy requirement.

Insufficient proportion and inappropriate distribution of affordable homes

Planning policy seeks 50% affordable, but RER propose only half of this (25%).

We also note that the application seeks to locate all the affordable in just two parts of the scheme (part of Blocks A and B). We note that this approach may make sense for the affordable housing providers in major schemes elsewhere, but in this case there are only two principle building elements on the one site, and concentrating all the affordable together is unlikely to be necessary from a management perspective, indeed such segregation could be construed to be socially divisive, creating definable “ghettos” in the building.

On both counts – proportion and distribution – the application is unsatisfactory and the affordable housing element should be increased and integrated throughout the development, including in the Grade II* Listed Building.

Unacceptable loss of family housing at nos. 5-7 Milner Road

The Borough, and Kingston Town in particular has for many years experienced an acute shortage of family housing, as is documented in the Cobweb report. The Borough’s local plan (CS DM14) seeks to resist the loss of family housing, and as we point out above the situation is certain to have become more acute in the decade since the Core Strategy was adopted.

RER propose to turn existing family housing at nos. 5/7 Milner Rd into small flats, and to reduce the length of the gardens of 5/7 Milner Rd to accommodate some of the infrastructure requirements of the new build development – such as power plant and waste storage facilities.

We find this element of the proposal particularly unnecessary and objectionable, and assume that this like the pavilions and the height, scale and massing of Block A is RER’s opening gambit, to ‘test the water’ and to push against the boundaries shall we say (pun intended).

We object to the proposed sub-division of nos 5-7 because there is a pressing need for family homes in Kingston. We know this because the Council’s evidence says 75% of the Borough’s need is family housing; this will be higher in Kingston Town. There is no reasonable justification for the proposed loss of this family housing, and nos 5-7 must remain as family houses with gardens. This is yet more evidence of the totally unacceptable consequences of RER’s proposed over-development of the site, that they need the garden space of nos 5-7 Milner to make their scheme work.

The proposed reduction in garden length at nos 5-7 Milner Road compounds our objection as the proposal would have a particularly harmful and totally unacceptable impact on residential amenity for those living closest to nos 5-7. This is because the electricity sub-station and waste compound would be immediately adjacent to their gardens, and this in addition to having the flank wall of Block A rising to 8 storeys at the end of the gardens. The combination of impact on natural light for these properties/gardens, the noise and emissions from the infrastructure and the oppressive nature of having tall buildings so close is totally unacceptable, and is clear evidence that Block A is over-developed.

Insufficient provision of amenity space

Private and communal amenity space standards are set by the RBK Residential Design SPD (PGs 13 and 14). For flats the private space minimum requirement is 10 sq m/unit, which can be delivered by means including balconies. The communal requirement is 50 sq m per development, plus any shortfall from the private space requirement.

RER claim that although there is a deficit in terms of private amenity, overall they more than meet the requirements. However, Block A is not physically linked to SCH building and will operate quite independently, and so should be considered independently of the SCH court yards. Our review, based on RER’s unverified and possibly incorrect area measurements identifies that Block A has an amenity space deficit.

While we understand that developing to the minimal internal space standards is inevitable to optimise use of land, it is regretful that the private open space standards in the new build elements (balcony provision) are not met for the vast majority of units. According to RER’s Landscape Design and Access Statement, and these figures need verifying, Blocks A and B have an overall private space deficit of 365 sq m and 159 sq m. RER only add on one 50 sq m amount of the communal requirement in a literal interpretation of the RBK SPD, whereas we would argue that Block A alone has four development elements with separate communal gardens, and should therefore contribute four times 50 sq m. However, even on the literal interpretation 365 sq m plus 50 sq m exceeds the 380 sq m provision, and so RER are not meeting the very minimum open space standards.

The irony is that Block A would be built on land that previous generations laid out for sport and leisure – tennis courts and a sports/social club, prior to that bowling green. The failure of Block A to meet its self-contained minimum outdoor space standards is yet more evidence that there is simply too much development proposed to adequately meet even minimum requirements; the balance is wrong and the over-development needs to be addressed.

More generally we are very concerned that this application which at every turn provides at best the bare minimum in terms of standards, will in actual fact provide insufficient outdoor amenity space for what could be circa 1,000 residents. The pocket park will in actual fact enjoy comparatively little sunshine, shaded by the building as it would be, and lacking a semi-private setting it will be unlikely to attract residents. We only have to look at the desolate communal (plastic) spaces at Charter Quay to see what can happen if the practicalities of using such spaces is not thought through. There is of course an area within the curtilage of SCH that is south facing, where a pocket park would be much much more successful and would provide a clear community benefit!

Car parking and traffic

London Plan policy would suggest this development should be car free – it is within the Metropolitan town centre and part of the area scores very high (6a) in terms of public transport accessibility (PTAL).

RER suggest an alternative interpretation of the London Plan policy, and propose 51 parking spaces in addition to disabled and the non-residential element. The spaces would be provided on the Milner Rd frontage.

We are very concerned about how a completely/largely car free development would work in practice. We would prefer the whole development to be private car free, with the parking area on Milner Road turned to soft landscaped / linear park. We are very concerned that the new residents will find ways round permit restrictions and will overload the on-street parking on Milner Road/ Woodbines Avenue, and generate high levels of traffic on these streets. This scheme must have zero parking and zero permits, but how will the Council enforce this?

In respect of construction and servicing vehicles such as for waste management, these should all be routed via Penrhyn Road / The Bittoms, and not Woodbines Avenue/Milner Road. This is because the development phase will last for years, cause huge disruption, noise and pollution to sensitive receptors (ie residents). Penrhyn Road has direct access points to SCH, is a much busier route, already has comparatively high ambient noise levels and has very few residents living in close proximity. Whereas Woodbines Avenue/ Milner Road are quiet residential roads that have low traffic levels and has lots of homes very close to SCH.

Impact on social and community services

As has been referred to above there is policy support for former public buildings to be used to provide social and community uses. Evidently a development that could deliver 1,000 new residents will put a huge strain on some local services, and provision of additional services within the development would be an appropriate and justifiable public benefit, for example schools, doctors/ dental surgeries.


As referred to in this objection, these applications infringe significantly on a large number of statutory policies and legal requirements. In the planning balance – we have the harm that is the missed opportunity to deliver genuine mixed use and an appropriate amount and mix of affordable housing, together with the new build over-development (Blocks A and B) that in our view out-weighs by some considerable margin the housing ‘numbers game’ that RER are playing. Considering the Development Plan as a whole, it is clear that the scheme as currently proposed is certainly not good enough to approve.

This is the view of the RRA committee and all the members we have talked with in the course of preparing this objection letter; there is considerable local objection to the applications. There are serious short-comings with these applications – the new build elements are unsympathetic to their context and constitute gross over-development of their sites, and the repurposing of the Listed Building represents a lost opportunity in terms of providing genuine mixed uses that will deliver public benefit in an outstanding building with a long and cherished history of public service. The housing mix is completely wrong and will not help meet the Borough need, and the affordable element is insufficient and the distribution divisive.

Thus, we can only conclude that the proposal is unacceptable in its present form, and should be refused. RER must be advised to look again at the community’s response to their last consultation (appended to this letter), and asked to improve on what they currently propose.

We reserve the right to expand on the reasons for objection should further information come to light.

Yours sincerely,

Robin Catlin, Vice Chair
Riverside Residents Association
13 Woodbines Avenue, Kingston Upon Thames KT1 2AZ

RRA rebuttal of the RER Heritage Assessment

Heritage Assessment, Pt 1 Extract: Effects on Significance of Surrey County Hall (Grade II* LB) in relation to Block A

281. The proposed redevelopment of the Canteen Building plot would bring about change to the setting of the listed building, notably at its southern end and primarily experienced from Penrhyn Road. The scale of impact on setting would be minor and limited to only a part of the asset. The effect of this change on the significance of the asset overall, or one’s appreciation of its special interest or more than special interests, would not be adverse or erosive of the asset’s significance. Whilst the change to the setting of a limited part of the listed building may have an impact, a conclusion of no harm to the overall significance of this heritage asset is found for the following reasons:

“i. The existing Canteen Building does not positively contribute to the setting of the building and does not form part of its significance. It has been identified as being of average quality with a dull frontage. These are not desirable attributes to preserve.”

Residents’ response to point i: The former Canteen Building does actually positively respond to the listed building in terms of its subservient scale. Unlike the current proposals, it’s of a modest proportion and design and is set behind existing trees, especially when viewed within the context of the listed building on Penrhyn Road (VIA View03).

“ii. Only a limited degree of the asset’s significance is drawn from its wider context. To the south of the listed building that context includes a diverse range of buildings of mixed period, style, mass, and form. These include the taller and architecturally distinct University Town House building which is now valued as a landmark. Its presence demonstrates the ability for substantial change within the setting of the listed building.”

Residents’ response to point ii: The ‘University Town House’ is a Stirling Prize winning high-quality architectural design, within the Education/Civic Character Area. We feel this is not sufficient justification to help substantiate erosive change to the setting of a listed building with what appear to be over-scaled residential flats.

“iii. All key attributes of the significance of the Grade II* listed building would remain unaffected by the proposed Block A development. Its presence would not detract from an appreciation of the architectural composition and form of the Grade II* listed building or impact on an understanding of its history and importance. These attributes would be sustained and preserved.”

Residents’ response to point iii: The architectural language of Block A is inspired by the Surrey County Hall’s ‘stepped vertical grid’, generating a similar height building mass with similar fenestration composition. This would ‘compete’ with the character and setting of the listed building rather than being distinct and subservient in terms of its visual impact and neighbouring relationship.

“iv. The proposed development offers significant improvement in terms of architectural and landscape quality, improving the current setting and experience of the southern end of the listed building.”

Residents’ response to point iv: Although there are significant changes to the landscape quality, it is worth noting that up to 10 semi-mature trees are being lost as part of the former canteen buildings redevelopment, along with impact to trees out-with the site boundary, and likely unavoidable impact and damage on their RPA’s (root protection areas) during construction. Category ‘C’ trees still require substantial justification for their removal, which is not evident within the reporting, other than assisting to maximise unit numbers for the developer.

“v. The form, scale and detailed design of proposed Block A would result in a new townscape element that is physically detached and visually distinct from the listed building. Its architectural language would be different from County Hall to not compete with or confuse any understanding or appreciation of the listed building.”

Residents’ response to point v: The language of Block A is wholly inspired by the scale and fenestration of the former County Hall as seen in ‘8.0 The Canteen Site (A)’ within the D&A Statement produced by the developers. Opportunistically, the scale of ‘block A’ draws inspiration from the heights of other surrounding ‘civic’ buildings yet it is a commercial flatted development, not of civic quality and somewhat over-scaled in relation to the terraced residential accommodation to the south.

“vi. Its scale and form reflect its role as the southernmost part of the Civic and Education Townscape Character Area and responds well to the scale of the listed building.”

Residents’ response to point vi: It’s role should not be to extend the civic character with what is ‘non-civic’ commercial flats as noted above. This is conceptually confused in terms of its architectural and townscape residents. The scale and massing compete with the existing listed buildings in terms of height rather than ‘responding well’ also noted above. Conceptually, its role should be that of a ‘transitional’ piece, stepping down in height as it responds to both the adjacent civic and residential area, north and south.

“vii. Whilst the height of the Penrhyn Road fronting block would appear as visible backdrop to the southern range of the Grade II* listed building in local views, other taller building in the context is above the silhouette of the listed building. In views looking north the Kingston College is visible and in views south-west across the southern courtyard the Kingston Townhouse is visible. In this regard the listed building is experienced as part of a town centre urban environment and infringement to silhouette does not detract from the setting as part of the significance of the asset.”

Residents’ response to point vii: The proposed residential flats of block A would have a significant impact on the setting of the listed building when viewed from Penrhyn Road, specifically in view 03 Penrhyn Road at Grove Lane, where rather than the new building being subservient to the listed building, it reads as dominant.

“viii. The design and massing of Block A has sought to complement and respond sensitively to the adjacent listed building.”

Residents’ response to point viii: We feel the design and massing on Block A ‘competes’ with the listed building, both in terms of scale and materiality, but also in terms of fenestration arrangement as noted above, where this is wholly copied from the listed building.

“ix. The proposed architecture has character and identity but references its context, including the Grade II* listed building and the University Townhouse building.”

Residents’ response to point ix: The scheme responds in part to the context, using existing tall buildings as a driver for height. Where the scheme fails to respond to its context is in its relationship to the traditional terraced accommodation to the south, where the massing would be perceived to be overbearing.

“x. The primary change would be experienced in views along Penrhyn Road. The proposals, by virtue of their architectural design, contextual response, materiality and landscaping, would improve this setting of the Grade II* listed building.”

Residents’ response to point ix: Although we appreciate the former Canteen Building is modest in terms of its architecture and scale, we do not think that taller buildings which would block and alter local views to and from the former County Hall should be described as an ‘improvement’ to the setting of the Grade II listed building.

“xi. Deliberate setting back of the frontage (3.3m from existing build line) would open up views of the County Hall frontage, improving visibility of the primary frontage of the landmark building. The clock tower would remain visible in longer distance views from the south.”

Residents’ response to point xi: When viewed from the south the overbearing nature of the new residential building is highlighted again (VIA View8), where visually, the new development is almost double the height of the neighbouring Reg Bailey Building, and the Townscape and Visual Impact Assessment actually notes here “6.70 This would be a change of medium magnitude to a view of medium sensitivity.”

Overall Summary: On review of the ‘Heritage justification’ commissioned by RER Kingston Limited in relation to Block A, we feel there is indeed harm in relation to the overall significance of the heritage asset and townscape, in terms of competing scale, mass and architectural language, notably from View 03 & 08 from the VIA submitted. In terms of how it integrates within the wider context, we feel the building should be more ‘transitional’ and step down in height as it relates to the neighbouring terraced houses to the south as this existing townscape context forms no part of the justification strategy.