Surrey County Hall2021-04-17T16:21:14+01:00

A forum for neighbours

BECAUSE NEIGHBOURS MAKE COMMUNITIES

OUR FEEDBACK AND RESPONSES TO INITIAL  SURREY COUNTY COUNCIL REDEVELOPMENT PROPOSALS

Most recent first

Second online ‘consultation’ here

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

Dear Ms. Webb,

Thank you for taking the time to get in touch. I have responded to each of the issues you raise on a point-by-point basis. We would also be happy to meet with you (virtually) to discuss the proposals in more detail. Please let us have some potential dates and times that would suit that I can share with the project team.

Height and Design: Surrey Club & The Bittoms

The site falls within Kingston Town Centre which is the third largest in London and is designated as an Opportunity Area within the emerging London Plan. Across the Opportunity Area, land is required for 9,000 new homes over the next 10 years. Delivering new homes in highly sustainable locations – those with excellent levels of access to public transport – is a requirement of national planning policy.

We will be required to assess the impact of delivering homes at this density. The team is in the early stages of completing a full Environmental Impact Assessment, which will be supported by a Heritage Impact Assessment and Townscape and Visual Impact Assessment. As soon as this work is developed further, we will be able to share our conclusions with you.

The proposed buildings on the Bittoms car park will be a single building stepping up to the tallest element. This has been designed to respond to the surrounding context and the new buildings approved in the area including the 16-storey Old Post Office scheme along with other proposals coming forward like Eden Campus.

The rationale behind height of for the Surrey Club site was based on the current University building opposite which is a similar height. However, the feedback from the virtual consultation shows that the proposed 9-storeys was a cause for concern. Responding to this, the team are proposing to reduce the height to 4-storeys with a fifth storey set back.

The replacement of the current building will help enable us to deliver affordable housing to address the planning policy set by the Royal Borough of Kingston upon Thames and the Greater London Authority. The design of this block will be a core consideration. We will ensure that it complements the existing County hall complex and Kingston University Town House. The team have been in discussion with Historic England who have issued a positive response to our initial proposals. We will continue to engage with them throughout to ensure the compatibility of our proposals and the surrounding context.

County Hall Designated Usage

Within the London Plan (2016) Kingston is designated as a Metropolitan Town Centre; an area which the GLA considers should be the focus for the majority of higher order comparison goods retailing, whilst securing opportunities for higher density employment, leisure and residential development in a high-quality environment.

A Direction of Travel for the Royal Borough of Kingston upon Thames (RBKuT) (2016) document has also been adopted by the GLA and RBKuT which provides supplementary planning advice to the London Plan policies to support the development and intensification of areas within the borough to provide new homes, jobs and investment.

The site lies within an Opportunity Area (identified for 9,000 new homes within the next 10 years) and within the Department of Transport (DoT) document, Kingston Town Centre is identified as an area of immediate opportunity for growth.

This has been developed further within the ‘Intend to Publish’ draft of the replacement London Plan (2019), which notes that Kingston will be designated as an opportunity area and a focus for growth – especially for the provision of housing.

Because of this and the continuing pressure being placed on RBKuT to demonstrate a supply of housing, we consider that a residentially led mixed use development is an appropriate use for the site.

Public Consultation: Webinar & Virtual Exhibition

I’m sorry to hear that some residents did not receive an invitation to the consultation. Around 8,000 invites were hand delivered to addresses surrounding County Hall and the Bittoms to inform them of the upcoming events and we have had no other cases of non-delivery. The GPS tracking record for the delivery confirm that invites were distributed in the streets surrounding Avant Court. For the second consultation we will post invites to this block to ensure full coverage. We also got in touch with the Surrey Comet so that the consultation was also publicised in the local media.

During the webinar, we responded to all the questions raised. Given the volume of questions, it was impossible to read these out word for word but all issues raised were addressed.

Historic England Response

We have had positive discussion with Historic England surrounding our proposals for County Hall. In the consultation boards, we referenced several quotes that came out of their response to give you a flavour of what was said. I would add that we have not received a final view for the whole scheme but Historic England are comfortable in principle with the proposed approach to the reuse of the building.

I have attached the response from Historic England. I would add that we are maintaining dialogue throughout the project to ensure our proposals respect the important heritage assets within County Hall and the surrounding area.

Civic & Educational Usage

We are engaging at an early stage before the proposed use for the County Hall 1893 building is known. Currently the entire County Hall is in a sui-generis planning use. We are proposing to seek a flexible use for the 1893 element to include for potential civic, community, education or civic uses. We hope to refine this mix of uses as the emerging proposals develop.

Strategic View

We have showcased a number of views during the Virtual Exhibition which you can still view here. We will also be bringing forward more views during the next round of consultation.

Retail Space

This is a very active area with the University, College and Crown Court providing passing footfall for convenience food retail at this location.

Light and Noise Pollution

We will be reviewing the impact of light and noise pollution, but the report has yet to be finalised. This will be submitted alongside the planning application to be then considered by the RBKuT statutory consultees.

Amenity space

We will be providing sufficient amenity space to meet the needs of new residents. The next consultation event will showcase more detail about where this will be providing but I assure you that this will meet policy requirements.

Parking & Traffic

RBKuT and the Greater London Authority have been keen to reduce reliance upon cars in the most sustainable locations. Given that the site has a very high level of accessibility to public transport, we are exploring making this development car-free. However, we feel a small parking provision will be appropriate and will likely be allocating approximately 0.2 number of spaces per unit.

As discussed above, the development would be largely car-free, such that residents buying an apartment would not likely move into an apartment if they owned (or wanted to own) a car. This is in line with the New Draft London Plan policy. Furthermore, future residents would not be permitted to apply for on-street residential parking permits. This, with the other kerb side parking restrictions in the vicinity of the development such as limited hours parking, means that it would not be suitable for residents with cars to park on-street. As such, it is considered that future residents of the development will not have an impact on the existing residential on-street kerbside parking.

With such a low parking provision, we are not expecting the plans to a significant impact on the local road network. We will be conducting a Transport Assessment, which will be submitted alongside the planning application, to show the impact.

Local Infrastructure, Services & Utilities

We appreciate the potential impact the development will have on local services, utilities and infrastructure. An assessment will be carried out to measure the effect of the scheme and Surrey County Council will be looking to provide financial contributions via CIL and S106 to mitigate the impact.

Construction Impact

We will be submitting a comprehensive construction management plan that will show how we intend to mitigate the impact on the local community and avoid disruption where possible.

I hope this responds to all the points you raise. Please get in touch if you have any further questions or have a suitable date for a meeting.

Regards,

Ben Knock​
Account Manager

O: 020 3697 7630
M:07789 465 017
E: Ben.Knock@becg.com

page1image3587579296

Mr Malcolm McGregor
Pringle Richards Sharratt Limited Studio 4
33 Stannary Street
London
SE11 4AA

Dear Mr McGregor

Pre-application Advice

Direct Dial: 0207 973 3749 Our ref: PA01056825

8 January 2020

SURREY COUNTY HALL , PENRHYN RD, KINGSTON UPON THAMES KT1 2DN

Thank you for involving Historic England in your early pre-application proposals relating to Surrey County Hall. It was very useful to see the building and discuss the proposals with you, Surrey Council Heritage Officers and the Royal Borough of Kingston Upon Thames on 6th December 2019.

Significance

The County Hall was originally built in 1893 in a free renaissance style by C.H.Howell, and has been subsequently extended over time as the Council function and staffing levels increased. Architect Vincent Harris was commissioned to extend the building in 1930 and again 1938. He opted for a restrained Portland Stone classical appearance that formed a quadrangle behind the main building. The part known as the Ashcombe Wing was destroyed in the Second World War and successfully rebuilt in 1953. A further range was added in 1963 that sought to architecturally respond to the scale and form of the earlier extensions, albeit with less refinement. The final range was added in 1983 giving the County Hall its figure of eight footprint. The layout of these ancillary ranges in this way provides a harmonious relationship with the main 1893 building, giving the County Hall a strong institutional character and clear hierarchy of spaces that emphasis the dominance of the parent building and the complex’s importance civic and authoritative status.

Internally, much of the principal spaces are accommodated within the original 1893 building and 1930’s extension (including the rebuilt Ashcombe Wing), which we understand contain a high degree of it original plan form, panelling, staircases, fixtures and fittings. In contrast the interiors of the extensions are understood to be relatively simple, lacking architectural features of note, and have been subject to alteration and subdivision.

Impact of the Proposed Development

The proposals consist of three distinct elements; the conversion of the retained listed buildings to either residential or student/university use; the demolition and redevelopment of the 1892 Computer Wing and 1963 extension; and erection of new buildings to the south of the County Hall building.

Conversion of the retained listed buildings
Whilst no proposals have been worked up in detail, the main 1893 building, 1930 Entrance Block and Ashcombe Wing are proposed to have a separate more publically accessible function, with uses as a boutique cinema/cafe, university teaching or leisure/office accommodation muted.

With regards to the 1930 and 1938 ranges, in all the development options provided, these ancillary parts of the listed buildings are earmarked for the greatest degree of change and would involve various alterations to provide either residential or student accommodation. A double-storey mansard roof extension is proposed to the western range to match the neighbouring ranges. The options for residential (For Sale/Rental) conversion would involve extensive internal remodelling of the plan form and insertion of a more intensive cellular form and multiple vertical cores throughout. Student/University conversion would involve intensive subdivision but possibly retain more of the existing plan form and circulation cores.

Demolition of the 1983 Computer Wing and 1963 extension
All development options currently being explored involve the demolition of these two ranges and replacement with a new independent building of between 4 and 6 storeys.

New buildings to the south of County Hall
The Staff Club building that sits adjacent to the County Hall building along Penrhyn Rd is proposed to be demolished and replaced with a new building of between 6-9 storeys and additional 4 storey building would be built to the car park behind the building.

Relevant Legislation and Policy

Section 66 of the Planning (Listed Buildings and Conservation Areas) Act 1990 places a statutory duty for Local Planning Authorities as decision makers to consider the impact of development proposals on listed buildings. They are required to have special regard [my emphasis] to the desirability of preserving the special architectural and historic interest of listed buildings and their settings.

Section 72 of the Act requires that special attention [my emphasis] shall be paid to the desirability of preserving or enhancing the character or appearance of a conservation area.

Guidance on the exercise of that duty is given in the National Planning Policy Framework (NPPF) which establishes the conservation of the historic environment as part of the overarching environmental objective necessary for the delivery of sustainable development.

The Framework goes on to require that any intervention or development likely to affect the significance of a designated heritage asset, should provide an assessment of that impact (Para 189). Local Authorities are instructed to use these assessments to avoid or minimise any conflict between the heritage asset’s conservation and any aspect of a proposal (Para 190). In determining these applications local authorities should take account of the desirability of sustaining and enhancing the significance of heritage assets and putting them to viable uses consistent with their conservation and seeking new development to make a positive contribution to local character and distinctiveness (Para 192). Where harm to significance is likely to result it must be clearly and convincingly justified and outweighed by the delivery of public benefits (Paras 194- 196). In determining the balance of harm and benefit, great weight must be given to the conservation of the heritage asset, and the more important the asset the greater that weight should be (Para 193).

Position

Historic England welcomes these early discussions on managing change of the County Hall site in the interest of securing its long-term future. At present no detailed designs have been produced, so these comments will be limited to the general principle of the proposals and conceptual schematics provided.

When considering change to a complex site such as this, we always recommend that a conservation management plan is undertaken which sets out the significance of the assets affected and identifies how that significance would be sustained through any future use. We are delighted to see that considerable thought has been given to the significance of the building and how your proposals impact on that significance through the production of the Heritage Appraisal.

We are supportive of finding new use for the building, which we understand will be surplus to Surrey County Council’s requirements. The development options presented focus of residential or student led conversions. We understand alternative uses have been explored and it would be helpful if this options appraisal could be shared with us so we can better understand the reasons for those being discounted. Our guidance note ‘Disposal of Heritage Assets’ (<https://historicengland.org.uk/images- books/publications/disposal-heritage-assets/guidance-disposals-final-jun-10/>), provides clear advice on finding alternative uses for heritage assets, and particularly the need 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, which is in accord with paragraph 192 of the NPPF.

Works to 1893 building, 1930 Entrance Block and Ashcombe Wing
We would agree with the submitted Heritage Appraisal that these areas are of highest significance. We recognise these areas offer challenges as well as huge potential to be adapted to economically viable new uses which would secure their long-term future. Therefore we are certainly open to the principle of seeking a new use here that could provide the opportunity to improve public access within these principal spaces. Our concerns will be in the detail of the proposals and impact on these highly significant spaces identified in the heritage appraisal. Careful consideration will need to be given to aspects such as accessibility, signage and servicing. We would be happy to provide advice on these as this develops.

Conversion of the 1930 and 1938 ranges
We are content in principle, with the proposed conversion of these ranges, which in our view could be adaptable for the uses proposed. However, as these areas are where some of the greatest intervention could be made, it will be important to undertake a more in depth analysis of the significance of these spaces, such as the plan form, partitioning and surviving features which should to help to inform the scope of change that can be accommodated here. Excessive intervention to these spaces could risk undermining the coherence and integrity of these part of the heritage asset. Consideration will also need to be given to the relevant local planning policies and building regulations, so a fuller understanding of the impacts of this approach can be understood and is fully achievable.

Mansard roof extension to the western range
As per our advice above, the existing roof form to this range is of significance and we understand retains the original north light lanterns that originally lit the drawing rooms beneath. The function of this room is also evident from street level through the sparse fenestration at second floor level. Before we can provide specific comments on this element of the scheme it would be helpful if further information could be provided so we can understand the significance of the surviving fabric and the quality of the spaces beneath.

Demolition and replacement of the 1963 and 1983 Ranges
This element would present one of the most visible changes to the County Hall’s appearance, which does raise some concerns. These constitute the more modern parts of the Town Hall complex, and appear to be of lower significance. They therefore present the greatest scope for change. In our view, whilst we do not oppose the redevelopment of the 1980s Computer Wing, the loss of the 1963 extension would be regrettable, as although lacking the refinement of the earlier extensions, is a handsome building that is architecturally coherent with the rest of the County Hall site.

We would encourage the retention and adaption of the 1963 building and an alternative design approach be pursued for the northern most range, that is visible recessive and fits sensitively and contextually into the County Hall’s overall composition, ideally retaining and enhancing upon the figure of eight footprint.

Redevelopment to buildings south of County Hall
The demolition and redevelopment of the 1960s Staff Club building and car park to its rear are not contentious in principle. Careful consideration will need to be given to thedesign, scale, and massing of these blocks to avoid adversely impacting upon the setting of the Grade II County Hall and nearby conservation areas. This element of the scheme equally offers opportunities to enhance the setting of the County Hall along Penrhyn Road, by setting this new building further back from the road to open up views of the County Hall.

Next Steps
We encourage you to consider the above advice, which we hope can assist in limiting the potential conflict between the proposals and the significance of this important heritage asset. We would welcome the opportunity to work with you further through the pre-application process to develop these proposals further.

The building’s listing description dates to 1983, and provides a brief and somewhat ambiguous description of the building’s significance. In our experience similar project can attract application for listings late in the process, which can sometimes delay and frustrate projects. It’s advisable to seek a listing enhancement at this early stage, which would provide greater clarity and certainty as to where the significance lies and the degree of change that would be appropriate. Further information on this and how to apply for a listing enhancement can be found on our website <https://historicengland.org.uk/services-skills/our-planning-services/enhanced- advisory-services/listing-enhancement/>.

Yours sincerely

Andrew Scott
Assistant Inspector of Historic Buildings and Areas E-mail: Andrew.Scott@HistoricEngland.org.uk

SURREY COUNTY HALL , PENRHYN RD, KINGSTON UPON THAMES KT1 2DN Pre-application Advice

Information Provided

191128_SCH_Initial_Stage_2_Report.pdf
2019.06.24 Surrey County Hall Heritage Appriasal v3a_A4_op_RFS.pdf 2019.07.02 Heritage Impact Assessment of Options.pdf

4TH FLOOR, CANNON BRIDGE HOUSE, 25 DOWGATE HILL, LONDON EC4R 2YA

Telephone 020 7973 3700 HistoricEngland.org.uk

Historic England is subject to both the Freedom of Information Act (2000) and Environmental Information Regulations (2004). Any Information held by the organisation can be requested for release under this legislation.
We respect your privacy and the use of your information. Please read our full privacy policy for more information https://www.historicengland.org.uk/terms/privacy-cookies/

page5image3609111408 page5image3609111680 page5image3609111952page5image3609112304 page5image3609112592 page5image3609112880

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.

Further information here

Go to Top