KINGSTON RESIDENTS ALLIANCE RESPONSE TO
SURREY COUNTY HALL DEVELOPMENT
CONSULTATIONS
14/12/20
Whilst we support the re-development of the Surrey County Hall site in principle we see a number of issues unresolved in your second consultation.
Please see our main issues below. Note these are the collective views of a number of residents who have attended your webinars, commented on social media and also visited your virtual exhibition website.
Please note that most of these questions were also raised in CONSULTATION 1 (C1) but, since the CONSULTATION II (C2) made no tangible improvements to the plans, we are repeating the questions raised before. You can see our comments under your replies:
RESIDENTS QUERY 1:
We said before: Finding a new purpose for this very important historic gateway site should be at the forefront of any developer’s plans and should not be left as an afterthought – and it is where this consultation fails most. Without addressing the central issue – the core purpose of the building and its role in the future lives of Kingston residents – this development will never gain full public support.
Why there was no proper community/resident consultation with local residents about the future of this heritage asset?
What does the community gain from these proposals?
DEVELOPER’S EARLIER REPLY to Q1:
County Hall Community Use
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 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.
RESIDENTS RESPONSE AFTER CONSULTATION 2:
Developers still do not seem to know or propose any worthwhile idea on how to use the main County Hall (referred as "High heritage Significance Building") for the community.
1.When and Where was the engagement?
2.How can this be “fixed” after the current plans approved.
3.Who are you engaging with? No one could get a tangible answer in limited chats/webinars.
RESIDENTS QUERY 2:
Why are 2 separate developments confusingly presented as one application?
We said before: We believe that, although these proposals are presented as a single development proposal, it is clear that this consists of two – even some argue three, if including South Block - separate applications. Regardless of the ownership argument presented in your webinar from the Penrhyn Road side, the two sites appear and impact on two totally different neighbourhoods. We found that “mixing the repurposing of historic county hall whilst demolishing a car park to replace with tall building clusters on another site” confuses residents’ understanding of the proposed plans and does not help anyone in these discussions.
DEVELOPER’S EARLIER REPLY to Q2:
Rationale for Single Application
Delivering the two sites together will ensure that the public benefits of the proposals are maximised. This will include delivering the greatest possible quantum of affordable homes whilst ensuring the works to the listed building are viable.
RESIDENTS RESPONSE AFTER C2:
This does not answer our original question. Locating high density residential blocks in the centre of a grade 2 building in the middle of a conservation area is one thing, asking for a 2-3 tall buildings (around 17 floors?) on a separate plot with completely different design and town planning challenges is another. Residents fail to understand how this can be lumped into one main application.
RESIDENTS QUERY 3:
Why are tower block clusters proposed on a site where they are explicitly disallowed by current Council Planning Policy?
We said before: Your architect’s claim of an “emerging tall buildings arc” around Surrey County Hall is news to residents. There has been no local planning document, policy, consultation or public knowledge supporting this idea and we would like the developer to substantiate this argument. Where is the planning or policy document supporting a zone of tall buildings on the Thames Riverside? Trying to be as tall as the “St George’s Tower” is the one least convincing excuse any developer could have provided, and it cannot be accepted by local residents, most of whom vehemently opposed the St George’s redevelopment at the time. The proposed towers would be a competing and dominating presence within the setting of a valued heritage asset, which is visible from numerous viewpoints within residential Conservation Areas, as well as other sites of historical significance such as the Old Market Place.
DEVELOPER’S EARLIER REPLY to Q3:
Arc of Tall Buildings
We appreciate that residents feel that the use of this Arc of Tall Buildings is unjustified. The purpose of this reference was to showcase the direction of travel in Kingston Town Centre to help explain why we feel the levels of height we proposed is justified. However, we will avoid referring to this again in future consultation activities.
RESIDENTS RESPONSE AFTER C2:
You may refer to the Direction of Travel in Kingston Town Centre as much as you want but this is not a policy approved by the Kingston Council and has no statutory basis. There has been no Public Consultation which could justify any changes to the height and density principles set out in the latest local Plan which was adopted after due process and consultation with residents.
“Royal Exchange and Eden Campus are part of the Eden Quarter which has its own SPD- the ‘EQDB SPD’. This SPD clearly identifies the location of the proposed tower at Royal Exchange as the ONLY gateway tower in the Eden Quarter. All other buildings are to be 6-8 storeys. 6-8 has been stretched to 9-10 residential floors in the Royal Exchange and Eden Walk developments, approximately 32-35m. As such, the tower proposed and revised at Eden Campus does not comply with any of the clear planning guidance, from the EQDB SPD, the Kingston Direction of Travel 2016 and the latest London Plan (2019).” (Kingston Society)
Also, you should CORRECT that the tower at Royal Exchange (RE) is 16 storeys not 18 as shown on your drawings.
Please also note that the tower at Eden Campus is NOT approved and is facing major objections from local residents also has been reduced to 16 storeys after resident feedback, although still contested.
A number of heritage and planning institutions in Kingston are objecting against all tall buildings as harmful to multiple heritage assets.
RESIDENTS QUERY 4
What is the justification for tower clusters of up to 17 floors on the Bittoms Car Park site?
We said before: We acknowledge that the developers are trying to create housing units by creating differing block heights, but we do not believe the ad hoc design style would mitigate the adverse impacts resulting from the height, scale and massing of the 17 floor tower blocks proposed at Bittoms Car Park. Surely the developer knows there are 3 Conservation Areas close to the application site. The proposed tower blocks cluster would harm the character and appearance of the area and protected Thames views by their height, scale and massing.
DEVELOPER’S EARLIER REPLY to Q3:
Impact of proposed tower at The Bittoms
The design team is currently in the early stages of preparing an Environmental Impact Assessment which will systematically assess the impact of the proposals at both the Bittoms and Surrey County Hall. It will include a detailed Townscape and Visual Impact Assessment.
RESIDENTS RESPONSE AFTER C2:
How can the developer approach the second stage of consultation without an Environmental Impact Assessment? There is nothing new to see here. This shows the so-called consultation stages are tick box exercises without the necessary detailed consideration of the impact of the proposals. It is therefore a total waste of time for all parties involved.
Just to reiterate: The developer may like to mention that the zone is in an OPPORTUNITY AREA and therefore they can get away with whatever they want, but we do not agree with this argument. There here has been NO public consultation to justify ANY deviations from the current Development Plan which would not allow ANY tall buildings in these locations. The previously published Eden Quarter Development Brief limits ALL buildings on this site to no more than 8 storeys and did not propose tower blocks on this site at all.
RESIDENTS QUERY5:
Where is the Historic England ‘support’ as claimed in your presentation?
We said before: You mentioned in your webinar that you have the “support of Historic England”. As residents we would like to see the proof of Historic England’s ‘blessing’ of 17 floor building clusters as argued in your presentations. We do not believe any heritage organisation would support tower blocks obscuring and dominating views of the Arcadian Thames. In the next stage of this process residents would like transparency and honesty in your communications with local and national heritage organisations and their response.
DEVELOPER’S EARLIER REPLY to Q4:
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 the team have not received expressed support for the whole scheme but are happy in principle with what is being proposed.
RESIDENTS RESPONSE AFTER C2:
We are also in touch with positive discussions with Historic England and happy to confirm that they are extremely concerned about the deluge of tall buildings affecting river views and Kingston’s historic town centre. Surprisingly, we did not get any feedback that supports your “positive lines”. However, we look forward to reading their full comments in the near future. Another low point for Consultation 2.
ON PUBLIC ENGAGEMENT:
For the second phase of this consultation we asked you to do the following:
1.Please work and consult with local residents and develop a vision before proposing a certain number of floors!
Kingston University is not a single entity and does not represent local voices alone. This site is an extremely important asset and should be treated as one. Respect the community you are trying to serve.
We cannot see any tangible evidence in your response to our questions above. Granted, there is a single reduction of height on one corner of the development, but you have failed to understand you need to work with the community to carry this proposal forward positively.
Unfortunately, it seems that the COVID pandemic has been used as an excuse to not engage proactively. The applicant did not display their plans anywhere in the town. Expecting everyone to be able to read small architectural visuals or to access everything through online presentations was very frustrating for some.
2.Your consultation web site is poorly designed, lacks real information and the consultation feedback page is extremely hidden. Can you please improve usability and visibility of that inadequate consultation and feedback page?
In terms of usability, the exhibition website designed for both consultations was incredibly poor. The image carousel did not work or was too slow on some handheld devices. The comments page did not work on some phones. It is going to be interesting to see how many seconds is spent per visitor. Asking for full details of “viewer” even before accessing the “carousel area” shows how little IT developers understand usability in information sites.
Both consultations lacked verified key views. In particular, the absence of a tall buildings angle was notable in the limited number of visuals provided. This was demonstrably misleading as it gave no clarity of how these buildings will be seen in the context of neighbouring buildings.
The text-based “chat” facility was useful, but this should not have been the only means for Q&As. It is not something that all residents would use comfortably and showed a lack of awareness of the needs of different demographic groups in the community. The developers do not seem to have made any real effort to involve the community but rather have seen it just as a hurdle to overcome at the last minute.
Based on all our questions and your answers above
We feel very strongly that these proposals should not be allowed to go ahead until an adequate and lawful public consultation takes place. The next plans should be based on statuary policies that residents have been consulted on, not a speculative attempt to set a ‘new normal’ baseline of tall buildings on any available location in the area.
SURREY COUNTY HALL DEVELOPMENT
CONSULTATIONS
14/12/20
Whilst we support the re-development of the Surrey County Hall site in principle we see a number of issues unresolved in your second consultation.
Please see our main issues below. Note these are the collective views of a number of residents who have attended your webinars, commented on social media and also visited your virtual exhibition website.
Please note that most of these questions were also raised in CONSULTATION 1 (C1) but, since the CONSULTATION II (C2) made no tangible improvements to the plans, we are repeating the questions raised before. You can see our comments under your replies:
RESIDENTS QUERY 1:
We said before: Finding a new purpose for this very important historic gateway site should be at the forefront of any developer’s plans and should not be left as an afterthought – and it is where this consultation fails most. Without addressing the central issue – the core purpose of the building and its role in the future lives of Kingston residents – this development will never gain full public support.
Why there was no proper community/resident consultation with local residents about the future of this heritage asset?
What does the community gain from these proposals?
DEVELOPER’S EARLIER REPLY to Q1:
County Hall Community Use
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 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.
RESIDENTS RESPONSE AFTER CONSULTATION 2:
Developers still do not seem to know or propose any worthwhile idea on how to use the main County Hall (referred as "High heritage Significance Building") for the community.
1.When and Where was the engagement?
2.How can this be “fixed” after the current plans approved.
3.Who are you engaging with? No one could get a tangible answer in limited chats/webinars.
RESIDENTS QUERY 2:
Why are 2 separate developments confusingly presented as one application?
We said before: We believe that, although these proposals are presented as a single development proposal, it is clear that this consists of two – even some argue three, if including South Block - separate applications. Regardless of the ownership argument presented in your webinar from the Penrhyn Road side, the two sites appear and impact on two totally different neighbourhoods. We found that “mixing the repurposing of historic county hall whilst demolishing a car park to replace with tall building clusters on another site” confuses residents’ understanding of the proposed plans and does not help anyone in these discussions.
DEVELOPER’S EARLIER REPLY to Q2:
Rationale for Single Application
Delivering the two sites together will ensure that the public benefits of the proposals are maximised. This will include delivering the greatest possible quantum of affordable homes whilst ensuring the works to the listed building are viable.
RESIDENTS RESPONSE AFTER C2:
This does not answer our original question. Locating high density residential blocks in the centre of a grade 2 building in the middle of a conservation area is one thing, asking for a 2-3 tall buildings (around 17 floors?) on a separate plot with completely different design and town planning challenges is another. Residents fail to understand how this can be lumped into one main application.
RESIDENTS QUERY 3:
Why are tower block clusters proposed on a site where they are explicitly disallowed by current Council Planning Policy?
We said before: Your architect’s claim of an “emerging tall buildings arc” around Surrey County Hall is news to residents. There has been no local planning document, policy, consultation or public knowledge supporting this idea and we would like the developer to substantiate this argument. Where is the planning or policy document supporting a zone of tall buildings on the Thames Riverside? Trying to be as tall as the “St George’s Tower” is the one least convincing excuse any developer could have provided, and it cannot be accepted by local residents, most of whom vehemently opposed the St George’s redevelopment at the time. The proposed towers would be a competing and dominating presence within the setting of a valued heritage asset, which is visible from numerous viewpoints within residential Conservation Areas, as well as other sites of historical significance such as the Old Market Place.
DEVELOPER’S EARLIER REPLY to Q3:
Arc of Tall Buildings
We appreciate that residents feel that the use of this Arc of Tall Buildings is unjustified. The purpose of this reference was to showcase the direction of travel in Kingston Town Centre to help explain why we feel the levels of height we proposed is justified. However, we will avoid referring to this again in future consultation activities.
RESIDENTS RESPONSE AFTER C2:
You may refer to the Direction of Travel in Kingston Town Centre as much as you want but this is not a policy approved by the Kingston Council and has no statutory basis. There has been no Public Consultation which could justify any changes to the height and density principles set out in the latest local Plan which was adopted after due process and consultation with residents.
“Royal Exchange and Eden Campus are part of the Eden Quarter which has its own SPD- the ‘EQDB SPD’. This SPD clearly identifies the location of the proposed tower at Royal Exchange as the ONLY gateway tower in the Eden Quarter. All other buildings are to be 6-8 storeys. 6-8 has been stretched to 9-10 residential floors in the Royal Exchange and Eden Walk developments, approximately 32-35m. As such, the tower proposed and revised at Eden Campus does not comply with any of the clear planning guidance, from the EQDB SPD, the Kingston Direction of Travel 2016 and the latest London Plan (2019).” (Kingston Society)
Also, you should CORRECT that the tower at Royal Exchange (RE) is 16 storeys not 18 as shown on your drawings.
Please also note that the tower at Eden Campus is NOT approved and is facing major objections from local residents also has been reduced to 16 storeys after resident feedback, although still contested.
A number of heritage and planning institutions in Kingston are objecting against all tall buildings as harmful to multiple heritage assets.
RESIDENTS QUERY 4
What is the justification for tower clusters of up to 17 floors on the Bittoms Car Park site?
We said before: We acknowledge that the developers are trying to create housing units by creating differing block heights, but we do not believe the ad hoc design style would mitigate the adverse impacts resulting from the height, scale and massing of the 17 floor tower blocks proposed at Bittoms Car Park. Surely the developer knows there are 3 Conservation Areas close to the application site. The proposed tower blocks cluster would harm the character and appearance of the area and protected Thames views by their height, scale and massing.
DEVELOPER’S EARLIER REPLY to Q3:
Impact of proposed tower at The Bittoms
The design team is currently in the early stages of preparing an Environmental Impact Assessment which will systematically assess the impact of the proposals at both the Bittoms and Surrey County Hall. It will include a detailed Townscape and Visual Impact Assessment.
RESIDENTS RESPONSE AFTER C2:
How can the developer approach the second stage of consultation without an Environmental Impact Assessment? There is nothing new to see here. This shows the so-called consultation stages are tick box exercises without the necessary detailed consideration of the impact of the proposals. It is therefore a total waste of time for all parties involved.
Just to reiterate: The developer may like to mention that the zone is in an OPPORTUNITY AREA and therefore they can get away with whatever they want, but we do not agree with this argument. There here has been NO public consultation to justify ANY deviations from the current Development Plan which would not allow ANY tall buildings in these locations. The previously published Eden Quarter Development Brief limits ALL buildings on this site to no more than 8 storeys and did not propose tower blocks on this site at all.
RESIDENTS QUERY5:
Where is the Historic England ‘support’ as claimed in your presentation?
We said before: You mentioned in your webinar that you have the “support of Historic England”. As residents we would like to see the proof of Historic England’s ‘blessing’ of 17 floor building clusters as argued in your presentations. We do not believe any heritage organisation would support tower blocks obscuring and dominating views of the Arcadian Thames. In the next stage of this process residents would like transparency and honesty in your communications with local and national heritage organisations and their response.
DEVELOPER’S EARLIER REPLY to Q4:
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 the team have not received expressed support for the whole scheme but are happy in principle with what is being proposed.
RESIDENTS RESPONSE AFTER C2:
We are also in touch with positive discussions with Historic England and happy to confirm that they are extremely concerned about the deluge of tall buildings affecting river views and Kingston’s historic town centre. Surprisingly, we did not get any feedback that supports your “positive lines”. However, we look forward to reading their full comments in the near future. Another low point for Consultation 2.
ON PUBLIC ENGAGEMENT:
For the second phase of this consultation we asked you to do the following:
1.Please work and consult with local residents and develop a vision before proposing a certain number of floors!
Kingston University is not a single entity and does not represent local voices alone. This site is an extremely important asset and should be treated as one. Respect the community you are trying to serve.
We cannot see any tangible evidence in your response to our questions above. Granted, there is a single reduction of height on one corner of the development, but you have failed to understand you need to work with the community to carry this proposal forward positively.
Unfortunately, it seems that the COVID pandemic has been used as an excuse to not engage proactively. The applicant did not display their plans anywhere in the town. Expecting everyone to be able to read small architectural visuals or to access everything through online presentations was very frustrating for some.
2.Your consultation web site is poorly designed, lacks real information and the consultation feedback page is extremely hidden. Can you please improve usability and visibility of that inadequate consultation and feedback page?
In terms of usability, the exhibition website designed for both consultations was incredibly poor. The image carousel did not work or was too slow on some handheld devices. The comments page did not work on some phones. It is going to be interesting to see how many seconds is spent per visitor. Asking for full details of “viewer” even before accessing the “carousel area” shows how little IT developers understand usability in information sites.
Both consultations lacked verified key views. In particular, the absence of a tall buildings angle was notable in the limited number of visuals provided. This was demonstrably misleading as it gave no clarity of how these buildings will be seen in the context of neighbouring buildings.
The text-based “chat” facility was useful, but this should not have been the only means for Q&As. It is not something that all residents would use comfortably and showed a lack of awareness of the needs of different demographic groups in the community. The developers do not seem to have made any real effort to involve the community but rather have seen it just as a hurdle to overcome at the last minute.
Based on all our questions and your answers above
We feel very strongly that these proposals should not be allowed to go ahead until an adequate and lawful public consultation takes place. The next plans should be based on statuary policies that residents have been consulted on, not a speculative attempt to set a ‘new normal’ baseline of tall buildings on any available location in the area.