Planning Application Postponement


The hearing of Planning Application 11/16502/FUL Surbiton Filter Bed Site has been postponed to an unknown date. Kingston Council cannot determine the application without all the relevant survey information. If they determined an application, which did not fully assess the bat interest, the council could be in breach of the law. The consultants retained by the council have advised (as have Natural England, the Bat group etc) that the survey information is incomplete. This is due to the developers:
a. completing only 2 surveys per year (dawn and dusk count as one); and that
b. surveys were undertaken when the filter beds were not ‘in their normal state’.

The applicant must demonstrate to a high degree of certainty that the development will not result in acts which could be an offence under the Habitats Regulations. This has not been done.

 In order for surveys to proceed, the water in the Filter Beds must be reinstated (naturally). Members of the Bat Group have asked for site access during surveys.


The following is the minimum to be expected regarding bat surveys during this coming season:
At least 3 evening bat surveys across the recording season (June, July, August) during good weather conditions in line with Bat Conservation Trust Guidelines;
Emergence and activity surveys should concentrate on surveying for all bat species at all the structures on the Filter Bed site (Chelsea Tunnel, deep wells, small pumping station, pill box, intakes etc) and not repeat what is already known (i.e the Daubenton’s bat roosts on the external wall) ;
Surveys should be undertaken when the water in the Filter Beds is at optimal levels (they should not be drained again this year as this destroys the Site of Nature Conservation Importance, SNCI);
The site is the only known hibernaculum in this borough and its suitability as a hibernacula post-development should be addressed and mitigation for its loss should be included in the report.
It would be  expected that bird, amphibian and reptile and botanical surveys would continue. During our walks last year, several plant species not recorded during the surveys were noted as well as others on the SNCI citation (only updated 6 years ago) so continued monitoring of vegetation changes is desirable as some of these plants are rare in London.
Reporting must evaluate the habitat in context and adequately mitigate for loss of features
The  previous Thames Water application followed the same path. When the appropriate survey information was eventually supplied TW ended up submitting a much reduced scheme. We must therefore test their assertions on all the surveys presented, including the archaeological.

For example the Chelsea and Lambeth tunnels are protected, no one disputes this. But can someone explain why the system that protects them (i.e that they fall within the curtilage of a listed building) doesn’t protect the main intake which traverses the small pumping station and in turn connects to the listed Nuffield building. On-site Buildings and Structures see also underneath Lambeth's pumping station

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