For the attention of the Assistant Director,
Strategic Planning & Infrastructure.
Planning Department RBK
Guildhall 2

6th November 2019

Dear Sir,

19/02504/FUL : Regents Wing And Pain And Diabetes Building, Kingston Hospital, Coombe Road, Norbiton, KT2 7QB
Demolition of the Regents Wing, Pain and Diabetes Building and part demolition of the c...
Planning Officer: William Flaherty


The Society wishes to strongly object to this Application.
We have read the Heritage Report submitted by the applicants & have to take issue with many of its assertions. We are surprised & disappointed that both Historic England & the Design Review Panel have not objected to this final version of the scheme.

In its earlier discussion with the developers RBK noted that the Regent wing of 1868 & its later extension of 1894 were to be considered when assessing their worth as having the status of a “non-designated heritage asset”. We contend that this status was wrongly dismissed later in the Heritage Report

We wish to remind the Council that Sections 69 & 72 of the Planning [Listed Building & Conservation Areas] Act 1990 requires it as a duty to review from time to time if new conservation Areas should be designated. It is scandalous - but can be seen as very convenient for various developers - that no work has been carried out by the Council to study & upgrade some of the many non-designated assets across the Borough for many years.

The new buildings will be adjacent to [1] the former & very fine Council Registry Office - a Locally listed building merit as designated by RBK & [2] the Wolverton Avenue which is designated as a LASC. This road should have been given the status of a Conservation Area a long time ago, albeit a small CA [there is at least one other CA of similar size & stature in New Malden].

We have to take issue with many of the statements made in JLL’s heritage consultants’ report.

RBK’s Policy CS8 states that the Council will protect the historic character of the Borough from inappropriate development & seek opportunities for sensitive enhancement”. Policy DM12 states”.. that the Council will preserve or enhance the existing ‘heritage assets’ & will allow proposals that preserve or enhance the established character or architectural interest of the ‘heritage asset’.

Historic England’s Guidance Notes [2nd edition] make it clear that the setting of a heritage asset [designated or non designated] are the surroundings in which a heritage asset is experienced. Its extent is not fixed & may change as the asset & its surroundings evolve. Elements of a setting may make a positive or negative contribution to the significance of an asset “ etc. etc.

The Society argues that there can be no doubt that both the former Registry office building, & the very well preserved Edwardian houses in Wolverton Avenue should be considered as “non-designated heritage assets”. The Regent Wing is of considerable historic importance not just because it became the first part of what was to become Kingston Hospital as we know it today. It also was formerly the Union Workhouse which should have been ‘locally listed’ many years ago by RBK as being of local historic importance. This workhouse was designed a well- known local architect -Charles Lock Luck- who designed several listed buildings in the area. There are 2 pieces of entablature above the existing entrance doors in ‘bas relief’ showing the “Pool of Bethesda” which –should the new building be permitted- the Society would like to be incorporated somewhere in the development.
The new 4-8 high storey buildings constitute inappropriate & overbearing development. The buildings neither preserve nor enhance the area. Their design is bland & reflects what we term “anywhere architecture”. There are reams referenced by the JLL Report : 3 RBK Policies, HE Policies & Guidance notes as well as Paragraphs 189-202 of the NPPF Their contents can all be interpreted in a number of ways, depending upon if you want to support a new development or not.
However we fail to understand how the arguments put forward by the JLL Report could possibly be accepted by the Council.

When this Application is discussed by RBK Councillors at the appropriate Committee meeting, we hope that objectors from this Society will be given a further opportunity to voice again their very deep concerns about this appalling scheme.

Yours sincerely,
For and on behalf of the Kingston upon Thames Society

Anthony Evans : Chairman
30 Presburg Road
New Malden KT3 5AH