Planning Application Seething Wells Elmbridge Council 2022/1667

                                                        We know who the sunken boat belonged to......

This objection is work in progress; here is the link to the latest, in a series of failed applications; in this case for a pontoon, perpendicular to the river wall, to provide moorings either side. Pedestrian access will be constructed from the Portsmouth Road to the river wall, with a route down to the pontoons. The shape of the pontoon and the pedestrian access is slightly different between the documents, depending on whether you read the Flood Risk Assessment or the iCON consulting plans, sometimes a T shape, sometimes a ship-shape.

Heritage and Bats

Some of the documents presented in the planning file are under one corporate logo and appear to be a selection from previous planning application 2018/3343 for 2 very thin town houses. These include the Heritage Assessment which ignores most of the heritage at the site. I include the wharf in my objection even though the applicants present  to us only a narrow strip of land (or NSoL) and not the blue line plan, which should detail everything under Cascina's ownership. The Flood Risk Assessment accompanying this application indicates at Fig. 6 that egress and access is via the gates on the wharf opposite the small pumping station or Building of Townscape Merit which is also a bat roost; not mentioned in the Heritage Documents nor the 'Ecology and the no - Bat - survey' report.

Neither does it mention the Listed Lambeth Tunnel which will be impacted by the the proposed pedestrian access. The tunnel was found to be  used by bats in surveys as was more recently, its parallel twin the Chelsea Tunnel, where three species of bat were located during surveys commissioned in 2019. For these reasons alone the application should be dismissed. But it gets worse. This Site was mentioned in the Step 3 Waterworks report 2000 commissioned by Heritage England as of National Importance so chipping away at the bit that lies in Elmbridge and pretending its a NSoL is quite naughty. 

If you are objecting to this application and discussing it's importance for birds you may need to tell Elmbridge council that this NSoL actually spills into Kingston and is part of a Heritage Site of National Importance. I don't know how they would monitor such an access route.

There is no record of professional credentials for any Icon employee, or directors, by online searching. The company's website, given in the documents, doesn't seem to work. As such, it's hard to confirm the expertise on proposals and impacts pertaining to wildlife, ecology, heritage, built structures, etc.This means some of the drawings lack clarity and the features are not identified such as the Lambeth and Chelsea Tunnels in fact, they are more like cartoons. 

The Ecology report was prepared in March by external consultants but the advice given by them is that no further surveys are required yet they are aware of the proximity of the SMINC, SINC, MoL etc. This is the most recent Site of Nature Conservation Importance (SINC) review for the Seething Wells Filter Beds which is in Kingston.

This is a SINC (Borough Grade 1), and still confirmed as such, and as of "notable value", in the recent SINC Review (December 2020):-

"3.15  Seething Wells Filter Beds as identified as being 'at risk' due to the current management practices, which include the treatment and removal of vegetation and trees, being implemented, which has significantly altered the extent and value of the habitats present. This has included the loss of species-rich grassland habitat, which supported calcareous grassland species that are unique to the borough and quality of wetland habitats present. Given the nature of the site, which continues to support wetland habitats, as well as its relationship with the River Thames and its geological character, the site is considered to continue to be of notable value."

The 'current management practices' alluded to are the persistent spraying with herbicide under a licence provided by the Environment Agency for a plant that has never been recorded on the site so that the ecological interest could be totally degraded. The ecology report states that this has contributed to it becoming Open Mosaic Habitat 'but none of the indicators were present'.  

DEFRA and Buglife state that Open Mosaic Habitat on previously developed land is defined by vegetation structure and not specific vegetation types. Open Mosaic Habitat is Priority Habitat because it can support specialist invertebrates and Schedule 1 birds such as the black redstart that has been recorded on nearby heritage buildings and and at Surrey County Hall. Surveys in 2019 stated that 'although no breeding black redstarts were located then, the location is perfect habitat for foraging birds'.

So lets look deeper into this 'insignificant' NSoL (narrow strip of land). We have already said that it will have an impact on the protected Lambeth Tunnel portal. In the 2018, application to Elmbridge council, it included a plan to develop a thoroughfare into the site from the Portsmouth road (on the NSoL). Ecological Surveys found a grass snake in the NSoL and reptile mitigation was included on the planning file (recently, on social media, a grass snake was filmed attempting to move around the wall on the Elmbridge side).

In addition, the 2018 application had a 25m buffer zone drawn around the Daubenton's bat maternity colony 2018. This was the area designed to be a protective shield to avoid disturbing a bat. Otherwise a licence to disturb a bat would be required. So in this case we are presented with an ecology report that misses and dismisses most of the ecology,  fails to undertake species surveys and the mitigation hierarchy ignored. But do not worry as we have bushes planted in the Open Mosaic Habitat.


Recently an unauthorised electrical cabinet was installed on the wharf and Kingston Council decided to take no action (to date). This was perhaps because there is already an enforcement notice at the site. This is  the cabinet that will no doubt provide the connections to operate the lights on the pontoons and pedestrian access. The Ecology Report cops out and states that lighting should follow BCT Guidance. 

Bat Conservation Trust does not give advice to the level of lighting there should be near a Daubenton's maternity colony, because there should NOT be any light. Lighting a Daubenton's bat roost will have profound consequences for the movement of the colony to foraging areas.  This is the darkest part of the River Thames for some distance and the reason the bats have been using the barge tunnel for many years. Elmbridge Council have signed up to 'not allowing any new lighting along river corridors' (see leaflet below) Surrey CC funded the leaflet.

Non - breeding bats use locations along the river wall and they would be severely affected by this application - bats are entombed when lights are shone on their roost sites. This application should be refused.

                                              Send SAE for copy of the leaflet, post requests in the comments box.


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