The evidence against the developer's claims keeps growing
15 September 2026
Since our last update in April, several further submissions have been made to the Council: an objection from the Victorian Society, one of the national amenity societies for heritage; three independent opinions from heritage and conservation professionals; a bundle of recent planning appeal decisions and a High Court judgment; and a further Opinion from our King's Counsel.
The Victorian Society has objected. The national charity for Victorian buildings confirmed that removing the original glazing and replacing it with uPVC has caused "significant less-than-substantial harm," warned about the precedent it sets, and urged the Council to require the lost fabric to be replaced like-for-like.
Three independent expert opinions have been submitted — from a conservation architect (Western Design Architects), a second accredited conservation architect (JaM Design & Architecture), and a firm of specialist historic-building conservators (HBC&R Ltd). Independently of one another, they reach the same conclusions: the damage the windows suffered was ordinary, repairable, age-related wear; genuine alternatives existed (secondary glazing, slim metal frames, re-leading the glass); the chunky 40mm units are the result of standard domestic double-glazing methods, not anything about the historic glass itself; no proper condition survey was ever done before the glass was ripped out; and uPVC was emphatically not the only option. All three recommend removing the uPVC and reinstating the historic glass properly.
Five planning and court decisions have been placed on the record. These include two recent Planning Inspectorate rulings refusing uPVC windows in Grade II listed buildings — dismissed because the burden is on the applicant to prove their case with evidence, and a bare assertion is not evidence. One is a High Court judgment confirming that the presence of uPVC elsewhere is legally irrelevant: harm must be judged against the building's special interest, not against the mess created by the breach. Another is Runnymede's own recent case in Chertsey, which confirms that features not named in a listing are still fully protected. These cases directly rebut the developer's arguments.
A follow-up Opinion from Alex Goodman KC (13 September 2026) is the most significant yet. He advises that the works were deliberate and, being unauthorised, "probably constitute criminal offences"; that new national policy (a new NPPF was published August 2026) requires intentional unauthorised development to be given substantial weight against granting consent; that the Council must disregard the building's damaged state and "ignore any suggestion that what's done is done"; and that, because the developer's agent has flatly declined to provide any evidence that contractors could not do the remedial work, the legal burden simply has not been met.
Tellingly, throughout all of this, the developer says nothing at all about the loss of more than half the original stained glass, 100% loss of the historic leaded light glass, or the "fake" leaded lights made from plastic strips that replaced the genuine historic leadwork.
The application is expected to go before the Planning Committee shortly. Thank you for standing with us — please keep sharing the petition.