Dear Kingston Planning Department

After the Surbiton Neighbourhood Committee Meeting, I rang your office to ask why none of the comments from my 15 page letter had been included in the report to councillors. I was told that they were included in the late material, which I did not see and could not check ( I would like a copy please).

I ask the same question of the report to the Development Control Committee produced for the meeting next Tuesday. I can see ONLY 9 ecology points  entered in the report. None of these include the points made in my last submission regarding:

Comments pertaining to baseline data, who decided what and when the baseline should be:
the current state of the filter beds and Daubenton's bat feeding ecology and that these animals cannot feed in a cluttered environment;
the affect of the deterioration on the habitat and this years low numbers of roosting bats (from 30 animals to 3);
the dispute over whether the maternity colony even formed this year and the noticeable change in bat behaviour;

additional critisms on the methodology including the 'hibernation survey' undertaken so late in the year; and the
ridiculous evaluations: bat records in other parts of the borough; there are 4 records of grass snake for the borough (see the GIGL database) so how are they common, the local status of the Daubenton's roost (well may be that is the case now the filter beds have been drained).

In addition I cannot find any mention from my previous submissions regarding:

Roosting bats at the pumping station which was supported by a letter from a witness from the London Bat Group;
(also confirmed by the London Bat Group letter) and a submission of the the structures on the site with notes on where bat droppings had been found by CPM.

There is case law on providing councillors ALL the information regarding roosting bats before making a planning decision, this includes the information provided by the bat group. It is the legal responsibility of the council to 'Conserve Biodiversity in all of it's functions' under the Natural Environment and Rural Communities Bill 2006. They cannot defer the decisions regarding all other bat species and bat activity to Natural England, implicit in the report.

There are additional errors in the report. I would advise the most important are as follows:
The report states that none of the plants notified in the SNCI were found on site. This is not true and by comparing the SNCI notification with the Middlemarch survey this will become apparent.

Is 5% of the Surrey breeding population of little grebe not a significant breeding population?????

Reptiles do not tend to be aquatic (some may swim but there is confusion here with amphibians)

I hope that these errors can be amended asap as well as omissions from similar letters on the ecology

Yours sincerely,


  1. The papers have already been published and officers are recommending approval.

  2. Hello Matthew, thanks for your comment, the above is responding to the omissions and incorrect statements in those papers. If I'd have had more time the letter would have been twice the length.


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