Last Updated on February 17, 2022 by Kingston Society

10th February 2022

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

Introduction
The Kingston Society was founded in 1962 and sets, in part, its responsibility to:

1) Promote high standards of environmental design, planning and architecture in or affecting the borough.
2) Secure the preservation, protection, development and enhancement of features of historic or public interest in the borough.

We are as concerned today, as we were 60 years ago, that outside forces are determined to force the townsfolk to accept decisions imposed on them by aspirations that do not originate from the wish to see a place well made but instead to deliver bottom line profits and growth at any cost.

Executive summary

  1. This is a poorly consulted proposal that never intended to respond to local concerns
  2. The new build elements manifestly fail to protect and enhance the Grade ll* listed building but instead create harms to it and the surrounding conservation area
  3. The new build elements neither contribute to the need for exemplar architectural design nor meet the developers self-declared aspiration to match the town House in quality design
  4. The new build elements are inappropriate in terms of height scale and massing
  5. The replacement computer wing building effectively ghettoises affordable housing by creating a ‘poor doors’ block of flats
  6. The mixed use scheme for the SCH building ignores the adopted Development Plan

  1. This is a poorly consulted proposal that never intended to respond to local concerns

Two rounds of public consultation and presentations to the Kingston Society show that not one single thing has changed to reflect our concerns. We refuse to acknowledge here the removal of the so called ‘pavilions’ in Milner Road as an example of active listening as they were so clearly inappropriate, and merely a cynical sacrificial element and were never a serious proposal.

The entire thrust of emerging policy is to actively include communities. The NPPF and Historic England both support the idea of charettes or community co-design. We asked for this but it was not forthcoming.

The developers consistently presented information edited to reflect a partial truth. Requests for additional, clearer drawings and greater transparency fell on deaf ears. Developers have become expert at paying lip service to consultation whilst never intending to interact meaningfully with the public. Consultation has come to mean show with only one seat, theirs, at the table. The new London Plan sets out the Mayor’s plans for ‘Good Growth’, but clarifies that Good Growth is not about supporting growth at any cost.

Our disappointment is compounded by the fact that the Statement of Community Involvement does not acknowledge our detailed responses submitted to both rounds of consultation nor the reality of their attendance at our public meeting in November 2021.


  1. The new build elements manifestly fail to protect and enhance the Grade ll* listed building but instead create harms to it and the surrounding conservation area

SCH with its Grade ll* listing rightly demands development that conserves and enhances heritage assets and avoids harm. Last year’s listing upgrade of importance to this building, which incidentally was entirely due to the activity of local resident groups, reinforces our concern that policy requirements to protect are not being met. The NPPF seeks development that is sympathetic to local character and history, including the surrounding built environment and landscape setting.

The new build elements at the northern  and southern curtilages viz the computer wing and the Surrey Club are grossly inappropriate in terms of height, scale, massing and architectural style to be approved.

The computer wing replacement (block B)
It may well divide opinion whether the old computer wing, with its Brutalist overtones, ever had a rightful place set as close as it is to the original 1893 Court House. The developers considered it too difficult to retrofit and have therefore obliged themselves to create a replacement of exemplar standards of design and scale.

LDF Kingston Core Strategy CS8 seeks to resist inappropriate development in areas of high quality and historic interest, while seeking opportunities for sensitive enhancement.

Policy DM10 says, inter alia: that development proposals will be expected to protect the quality, character, scale and skylines of sensitive areas and safeguard strategic and local views.

The building proposed does we are pleased to note create more breathing space around the Court House and usefully reclaims what is currently a grass verge in front of it for building. But thereafter this is a remarkably insensitive proposal that cannot in any way be the right solution for the new block that is closest to the block C (the 1893 building)

Historic England in its report “Building in Context” requires that new buildings near or next to historic assets should:

  • relate well to the geography and history of the place and the lie of the land
  • respect important views
  • respect the scale of neighbouring buildings
  • use materials and building methods which are as high in quality as those used in existing buildings

We do not consider that the new build elements could in any way be said to be conforming to this.

The Surrey Club replacement buildings (Blocks A1,A2 and A3)
The existing 1970’s Social Club building is just three storeys and a discrete and respectful neighbour to SCH in terms of scale.  Even so its form and the narrow gap between it and SCH cause harm to the setting of the Listed Building.

RER claim in DAS 8.4.3.5 The proposed siting of Building A1 not only provides a strong street alignment to Penrhyn Road but is also positioned forward of the former Surrey County Hall building to ensure the historic setting of the SCH is maintained.

We say It is obtuse of the developers to try to make a virtue from a clear harm of their intention to site the new flats in front of the southern facade and could not possibly be considered to respect or be subservient to the Grade ll* building.

Residential Building A1 is 8 storeys.  This block at 36.8m in height, it is more than nine metres taller than the south side range of SCH and 17m higher than the 1893 building. This building is also higher than SCH’s landmark clock. Surrey County Hall  would be dominated by a large, private residential tower of mediocre quality, built in  the ‘New London vernacular’ design, and claiming  to mimic the architectural merit of KU’s Town House. It  lacks the setback, depth and articulation of that building, and would be built within 11 metres of SCH’s southern and eastern ranges, thus degrading the value of a very public Grade II* heritage building, harming Kingston’s civic and educational quarter notable for its ‘signature’ buildings – Town House and SCH and the Guildhall

Residential Buildings A2 and A3 are proposed to be located within a one metre  boundary of the gardens of the Edwardian housing in Woodbines Avenue and Milner Road, leading to a dramatic loss of privacy and quiet enjoyment. Four houses in Woodbines Avenue would have a six storey block a metre from their gardens. Policy London Plan D3 requires appropriate response to context: shoehorning 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 – simply put: growth at any cost. 

Rebuttal of the RER Heritage Assessment
RER’s Heritage Assessment in relation to Block A finds (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.

We strongly disagree with the reasoning and conclusions drawn by RER, and consider it to be a non-impartial assessment. 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.


  1. The new build elements neither contribute to the need for exemplar architectural design nor meet the developers self-declared aspiration to match the town House in quality design

It’s very clear that responding to this site, built across 90 years, is a design challenge. Good design in locations such as this is about exemplar architecture and sensitive transition, and not about having high rise, high density development abutting the boundaries of listed buildings and existing homes. RER’s approach cannot be considered sensitive transition.

London Policy Plan D3:
Form and layout
1) enhance local context by delivering buildings and spaces that positively respond to local distinctiveness through their layout, orientation, scale, appearance and shape, with due regard to existing and emerging street hierarchy, building types, forms and proportions

Quality and character
11) respond to the existing character of a place by identifying the special and valued features and characteristics that are unique to the locality and respect, enhance and utilise the heritage assets and architectural features that contribute towards the local character

12) be of high quality, with architecture that pays attention to detail. Additionally:

Core Strategy Policy DM10  states:

Design Requirements for New Developments
Development proposals will be required to incorporate principles of good design. The most essential elements identified as contributing to the character and local distinctiveness of a street or area which will require to be respected, maintained or enhanced.

 The Surrey Club replacement buildings (Blocks A1,A2 and A3)
Rolfe Judd and RER identified the Stirling Prize winning Town House as a benchmark for the building they would like to build here but we are certain that they are some way from this. Currently they offer nothing other than the ‘New London Vernacular’. (a kind of ‘neo-brickism ‘which could be described as undecorated angular and modular brick) There is a real opportunity to build something special in this sensitive location.

The Building Better, building Beauty Commission established a revised modern approach requiring we:

Ask for Beauty. We do not see beauty as a cost…It is the benchmark that all new developments should meet. It includes everything … that makes a collection of buildings into a place. So understood, beauty should be an essential condition for the grant of planning permission

 Refuse Ugliness. People do not only want beauty in their surroundings. They are repelled by ugliness, which is a social cost that everyone is forced to bear. Ugliness means buildings that are unadaptable, unhealthy and unsightly, and which violate the context in which they are placed. Such buildings destroy the sense of place, undermine the spirit of community, and ensure that we are not at home in our world.

Could there be clearer mandate for excellence? Could there be a clearer demonstration of  developer who has not tried to aspire to it?

The computer wing replacement (block B)
Arguably this this block is in the most sensitive part of the site. Whilst not impacting on the main building façade it abuts closely at one corner and forms one side of the quadrangle interior courtyard so its impact is enormous.

Rolf Judd’s idea to create a stand-alone block that inserts breathing space into the gap between the oldest part of the site and the newest is we think a well-considered approach. But at ground level what might be the genesis of a well-considered building becomes gratingly disconnected in an ill-conceived attempt to make a colonnade. We find the additional exaggerated mansard roof overbearing, and far from elegant. The use here of reconstituted stone is a mere pastiche nod to the construction of the historic asset and should not be allowed to diminish the need for brave and excellent architectrure. It is beyond mere opinion but visually and self-evidently true that Block B is lumpen, slab sided and figuratively neither fish nor fowl. It neither responds directly to the 1893 building nor bravely suggests a counterpoint.


  1. The new build elements are inappropriate in terms of height scale and massing

The Surrey Club replacement buildings (Blocks A1,A2 and A3)
The building would need to be considered against London Plan Policy D9, and we fail to see how the planning decision-makers could possibly consider this location to be appropriate for a tall building. Is the Town House the precedent here? We think not: the context is Reg Bailey and the Milner / Woodbines / Bittoms residential immediately to the rear.

Good design in locations such as this is about transitioning sensitively (as required by London Plan Policy D9C), and not having high rise high density development abutting the boundaries of the suburban residential – such an approach cannot be considered sensitive transition.

RER have failed to respect the local residential context.  Woodbines, Milner and the Bittoms are that context, located just outside of the town centre boundary and solidly suburban in context. Cramming 100 flats on the Surrey Club/ tennis courts and 350 in the Listed Building represents a huge density totally disproportionate to the context and again not providing a sensitive transition.

Separation
The separation distance frontage to frontage between the G2* Listed Building and the ‘town cramming’ on the Surrey Club / tennis courts would be some 10 metres.  This would be contrary to both Kingston and the Mayor of London’s minimum standards for visual separation as set out in their Housing SPG /Design SPD.  Indeed, this distance is just half the minimum standard required to maintain privacy (the Mayor’s Housing SPG identifies 18-21 m (Standard 28) and the Council’s Design SPD identifies a distance of no less than 21 m (PG16)).  Thus, what is proposed is totally unacceptable.

The lack of adequate separation / set back is also an issue for our G2* building, as is the height and massing of the proposed replacement building.  The scale of Town House does not detract from County Hall because it is remote (on the other side of the road and set back from the highway).

We certainly cannot comprehend that Historic England, the Council or the Planning Inspectorate would consider a residential scheme such as that which RER propose would trigger the wholly exceptional circumstances required to justify the substantial harm wrought on the G2* building by developing in this way within the building’s setting / curtilage.

 The computer wing replacement (block B)
Along with a missed opportunity for good architecture the proposal here in its clear attempt to maximise density is proposing a building that is too big for all the other listed buildings that are alongside and opposite it (both in terms of the interior courtyard and the Bittoms.)

Loss of family homes 5 and 7 Milner Road
The Borough’s local plan (CS DM14) seeks to resist the loss of family housing. RER intends to convert these two (recently refurbished and desirable) family houses into small flats, reducing in the process the size of the already small gardens. This is to provide space for infrastructure  but just adds further harms to he adjacent homes in Milner Road.


  1. The replacement computer wing building effectively ghettoises affordable housing by creating a ‘poor doors’ block of flats

Kingston  Planning policy seeks 50% affordable housing, but RER proposals achieve only half of this at 25%. The application seeks to locate all the affordable units in just two parts of the scheme (part of Blocks A and B).  Whilst this approach may make sense for the affordable housing providers in major schemes elsewhere,  in this case there are only two principle building elements on the one site, and concentrating all the affordable together could be construed to be socially divisive, creating definable “ghettos” in the building. So called poor doors. It will likely also we fear lead to deliberately less well  specified building quality.

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.

Peter Rees, former City of London Corporation chief planner says “Widespread home ownership is a key driver of social division because of the fixation with property values that it produces. This makes developers hypersensitive about anything that could push down the price they can sell homes for, including the presence of a low-income household next door.”


  1. The mixed use scheme for the SCH building ignores the adopted Development Plan

The Kingston Society has never  been convinced that RER has ever responded to the adopted Development Plan which allocates the site for civic and educational uses, as befitting of its public service heritage

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

Neither RER nor Surrey County Council before them have made any serious efforts to market the site widely for commercial uses.   Apart from engaging with KU as were 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.

We understand the pressing need for housing in Kingston, and the Council is already struggling with its requirement for an annual build of 954 new homes 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.

Housing mix
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.

CONCLUSION
To be clear we are not wholly opposed to this scheme: the application has elements that we support in principle if not in detail: events spaces, social spaces, affordable home and jobs – and the exciting (possible) partnership with The Trampery to create co-working creative spaces but, and it is a very significant but, simply not in the right mix to truly optimise the reuse of the site.

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.

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.

Anthony Evans

Chair • The Kingston Society

(The 297 document planning application is on the RBK planning portal here

The most useful and easily understood documents are the Design and Access Statements, and we have combined the seven separate PDFs into one document here (this is a large file – 222 pages – and will take a few seconds to load) and it can be downloaded to your own computer for convenience.)

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