Surrey County Hall Penrhyn Road 20/02462

Presentation of the plans for Surrey County Hall by RER at the  October meeting of the Kingston Society Tiffins School

Surrey County Council (SCC) proposes the repurposing of Surrey County Hall and associated buildings to create a mix of refurbishment and potential partial demolition to include a mixed-use development, including approximately 500 new residential units, additional space for new courts for the Crown Court, office space, shops or financial/professional services and car park.They have submitted an EIA scoping document which omits all of the ecological features at the site. see

The Grade 1 Listed buildings will be retained and a new double mansard roof will be put on a flat roof to create symmetry (or profit). Within this application the prison cells will be retained and the courts retained as lecture theatres or film sets. There will be a hub with rentable space with a cafe area and the Trampery model (see Hackney) was expounded. The cobbles are listed and will be retained which was a reason for not creating habitat. The computer suite wand the canteen will be demolished.

The bad news is that there will be 3 modern new blocks of 8+ 6 + 4 storeys from Penrhyn road built using reconstituted Portland Stone. The 8 storey block will face the Town House and will echo its award winning construction with recessed balconies. 


There will be green roofs on the new blocks and 72 new trees.The 12 TPO's trees with 4 additional trees already on site will be retained.

 Residents objections

During the presentation residents from Woodbines Avenue and Milner Road objected to:

  • the failure to recognise the amenity provided by the existing tennis courts;
  • the failure to address residents concerns, spending an hour discussing listed buildings and 5 minutes the new blocks;
  • the noise from the air source heat pumps that will be heard all through the night;
  • as well as the proximity of the blocks from residents windows.

EcIA or EIA surveys

Unfortunately, the documents for application cannot be viewed on the councils website. Two docs seen from the "EIA METHODOLOGY AND SCOPE" state that the ecological features were proposed to be 'out of scope' given little supposedly present in terms of biodiversity. I objected to this on the grounds of European Protected Species known to roost nearby and two species of birds scheduled under the WCA 1981 associated with the site.

The Preliminary Ecological Assessment or PEA mentioned undertaking bat roost surveys at some point in future but that should be presented now as there is case law that states that protected species information should be presented early so that the mitigation forms part of the Design.

The additions of storeys to one of the most important buildings on this approach to Kingston should not occur on architectural grounds but also because any bat roosts have not been accounted for. There is a bat roost a short distance from this site (also a development site) which was reported to a planning officer earlier in the year. This increases the likelihood of finding bats using nearby buildings and structures.

The PEA did not mention that there are two Schedule 1 birds associated with County Hall and there are records of peregrine falcon and black redstart using the building. I posted photographs of both birds on my blog. The black redstarts particularly enjoy the berries on a chusan palms at the front of County Hall in the Autumn.

Green walls  are not going to improve biodiversity come and see the one we have in Hamden road and suggest what ecological benefits there might be; birds cannot nest in it, there are no earthworms to be extracted or insects to feed on as there is no web of life generated the species chosen which are people-pleasers. For sure, it uses litres and litres of precious water, much of which ends up down the drain. 

The website states that habitats will be created but bird boxes are not habitat according to the Net Gain Metric and they are pointless if there is no habitat to provide food, and the boxes are never apparent post development or only last a couple of years.

The trees require CAVAT assessments, some are protected by TPOs. Arboricultural aspects are proposed as being not necessary to scope now but the applicant had  proposed to fell 3 trees and these are part of the reason there are so many birds associated with the site. As such I object to ecological aspects being left out of the EIA scope.

I would urge strongly that the EIA cope includes arboriculture and biodiversity so there is a baseline to argue from and to ensure real biodiversity and ecological improvements, as well as retaining existing wildlife. 


Below are some of the comments made by C. Mellish in responding to the questionnaire. These a particularly helpful for those who would like to inform themselves of the historic nature of the site. It has been abridged to aid understanding



  • the proposed alterations to the main building

-The details are not enough to say much at this stage, for example interior alterations are barely mentioned but these are likely to be major. Yet, according to English Heritage, "the interior survives as a particularly complete example of a municipal building of this date, with imposing public spaces, and rooms devoted to specific functions; the interior survives as a particularly complete example of a municipal building of this date, with imposing public spaces, and rooms devoted to specific functions".
The inside of this building has many exceptional unaltered features, such as panelling, court rooms and council chamber. What are you proposing?

Dislike the mansard rooftop extension with many windows punched through the original pitched roofs on the corners and central sections - this harms the building's appearance. The extension's height of infil is probably alright but would need to see detail. There appear to be too many windows high up, disrupting the visual balance of the building facing Milner Rd - it does not look in character.
Why are the rooflights being replaced?

the building to replace the Staff club The new building alignment is better with respect to the original County Hall but should be set back further to match the main body of the building not the central and corner towers.Will the spectacular large tree be preserved in front of the staff building?
The new building looks over-massed with tiny courtyards, considering the number of potential units.

  • the new houses facing Milner Road

I am not at all keen on this aspect of the development. The houses block the clean lines and sweep of the Surrey CC building and change the street view irrevocably and for the worse. The houses are not in keeping with grandeur of the building, they look like they're just squeezed in to make the scheme more profitable.
Given the heritage title includes "the western terrace and cobbled forecourt to Milner Road", how can this not harm the heritage status? ( "Surrey County Hall, with lamp standards outside the southern entrance block, cobbled southern quadrangle, western terrace and cobbled forecourt to Milner Road").

  • the amount of parking and cycle storage space provided

Kingston is on the edge of London and more people have cars here than the average for London. The new residents will want cars and 90 spaces for 360 homes (circa 1000 people) will mean their cars will just end up blocking existing roads in the neighbourhood. Even if car ownership conditions are attached to residency, people will find ways round them.

  • the proposed landscaping across the site

There is simply not enough information to say:
- critically there is no information about trees other than 'respecting' the existing treeline. What does this mean in terms of trees across the site, and how many and which will be lost as a result of this development?
- The cartoon landscape has numerous symbols associated with precise points on the plan, but are nonsensical and rather disturbing - for example 'native bird' at only one position (is one bird to be installed there or is this the only point suitable?!), just 2 bird boxes are elsewhere (for the whole site), 'pollinators' (1 position), 'native bugs' (2 positions), 'wild flower' (singular) at 2 sites. Nature and sustainability simply does not function like this.
- The landscaping comes across as style over substance and childish greenwashing.
- Bird and bat boxes are temporary structures and no substitute for natural habitat. -
- I am concerned about potential bat colonies and disruption to both birds and bats with major landscape changes.

- There will be a huge human impact following development and I very much doubt the proposed increase in biodiversity is sustainable in the long term with number of people using the space, nature will likely flee, or be trampled. Will there be any monitoring of the environmental deliverables long term to give confidence the proposals and mitigations are workable?

  • Do you have any suggestions for possible temporary or permanent uses for the original 1893 County Hall areas which will not be converted to residential?

- It would be helpful to give some information about which areas in the building you are referring to!
- I am deeply concerned that no proposals for the interior are presented or even an indication of which areas are to be retained. The heritage listing is just as dependent on the interior as the exterior for the architecture and historic interest.
- Surrey County Hall has been a landmark public building since Victorian times it would be appropriate and appreciated by Kingston and Surrey residents to allow some public access and use of some of these areas.

-The current staff building has serviced the community in recent decades, including staff and students of Kingston University (snooker, table tennis badminton, canteen, etc), so it would be wonderful if there was good public access to, and use of, original County Hall areas. Examples might be functions and meeting venues, arts centre, gallery, cafe etc, provided the interior is not altered much and respected.

  • Do you have any additional comments about the proposals?

- The questions asked in this initial consultation are too detailed for the basic information presented.
-I am deeply concerned that no proposals for the interior are presented or even an indication of which areas are to be retained. The heritage listing is just as dependent on the interior as the exterior for the architecture and historic interest.

- Sustainability is mentioned but no detail or aspirations re carbon neutrality, materials etc given.



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