SURBITON NEIGHBOURHOOD
Conservation Areas Advisory Committee

PLANNING APPLICATION COMMENT FORM
DATE: 8 June 2021

CA19
 RBK ref:

21/01305/COND 		Address: 64-68 Brighton Road Surbiton KT6 5PP

Planning Officer: Honey Olaiya

Description of proposed works:

Details required for condition 38 (Urban Greening Factor) of planning permission 20/00977/FUL (Demolition of existing buildings and erection of a new 2 storey building with 3rd storey recess fronting Brighton Road, comprising flexible commercial space(use classes A1, A2 ,B1a,b D1[medical]) on the ground floor and 7 residential dwellings above with 9 terraced properties to the rear, together with associated access, parking, waste, cycle storage and landscaping) Note: the landscaping details underpin the UGF but are covered by a separate conditons 23 and 24 and are therefore for illustrative purposes only at this stage, further to finalisation and submission (100-02, 101-01, 200-00, 201-00, 001-00)

APPRAISAL

By full committee on …… 8 June 2021 …… with …… 4 …… members present

Issued on 9 Jun 2021


1. Positive support
2. No objection
3. Objection
X
4. Objection unless revised as below
5. No comment/neutral
6. Lack of detail
7. Decision already issued



Reason for objection:

Whilst we do not always comment on planning conditions we felt compelled to do so in this instance as we believe the landscape proposals and achieving a policy compliant Urban Greening Factor is an important consideration in respect of the character of Conservation Areas within Surbiton and in this instance the information submitted includes errors and inconstancies as set out below.

We would urge the council to request a re-submission of the UGF calculations and landscape proposals because :
a) the applicants have NOT followed the correct methodology
b) the hard landscape proposals which include permeable surfaces which the UGF has been based, are inconsistent with the drainage strategy etc.

As a result of the above the UGF target (once corrected) will not meet London Plan Policy and therefore we do not find the proposals to be satisfactory within the CA.

a) Methodology - the calculations for the UGF are incorrect - the methodology provided by the GLA within the London Plan states that the calculation must be based on the site area (in this instance the application form describes the site area as 0.17ha) however the UGF Report prepared by Lizard have not used the site area, rather they have added up the areas that contribute to the UGF and used this to base their calculation. (0.108h) - this results in an inflated UGF as they have not accounted for the impermeable areas which score '0' (ie areas of building without green roofs and impermeable surfaces). This has resulted in an incorrect assessment of the UGF and should be corrected.
b) The Landscape Plan (LLD2295-LAN-DWG-101) accompanying the UGF show permeable paving to the parking areas (Tegula Priora). This is in contrast to the Drainage Strategy which states that the parking area will be drained 'via trapped gullies' and that water storage will be 'tanked' - ie the Drainage Strategy does not include for any permeable paving.
Furthermore, Planning Condition 30 requires ' The car parking shown on the approved plans shall be provided with a hard-bound, adequately-drained, dust-free surface' - this, therefore precludes the use of permeable paving.
The Landscape drawing refers to permeable paving for the paths but again, this has not been included on the RPS Drainage strategy plan. The two should be coordinated to ensure consistency and if permeable paths are to be used, this should be included as part of the drainage strategy.
The UGF Report by Lizard includes permeable paving within the calculation however this will need to be updated to reflect the actual surfaces that are to be used. We would also note that Lizard have classed paving slabs within the UGF as permeable, this is incorrect, and again not reflected within the Drainage Strategy.
In conclusion, it is clear that the scheme, as drawn will not meet the 0.4 UGF target required by the London Plan Policy and therefore the scheme should be revisited to ensure the 0.4 target is reached and that the landscape proposals make a positive, long term contribution to Surbiton and the CA.