Click here to see map for location of Friars Garth

23/01451/FULAdditional fourth storey to accommodate 3 x 2 bedroom flats (amendment to approved planning application 21/00701/FUL dated 14.02.2022).

A new planning application has been submitted in respect of a proposal for altering the previous planning permission (21/00701/FUL) approved in February 2022. Construction works have halted at the 3rd Floor, ie approximately mid-way on the overall project. The current proposal is to demolish the part built between top of 2nd floor to mansard roof and replace with a new full 3rd Floor.

ECS strongly suggests that the latest planning application should relate to the whole proposed development (12 new flats, 4 storey height) and not just to the additional floor. Therefore, the Society must OBJECT to the 23/01451/FUL application. While there are clearly issues with the proposal for a four-storey building in this location, the Society’s main objection is that this application cannot be viewed as an amendment to the existing permission, which is for a minor scheme, whereas the proposal for 12 flats should be considered as a major scheme, with concomitant obligation for affordable housing. The Society believes that the site is mid-way constructed and therefore not an existing residential block.

There have been updates to National and Council policy since the granting of the approval to the current, and now halted, development. Epsom has a new Town Centre Masterplan, which has been published and consulted. This plan suggests that buildings up to 4 storeys would be suitable and shows new flats on the north side of The Parade being built to that height. The existing buildings on the south side of The Parade include both 3 and 4 storey heights and high-level mansards. ECS are not objecting to the proposed height of the new development. NPPF 124e supports the opportunity to use airspace for new residential above existing residential.

This application should relate to a development for 12 flats and therefore changes from a minor to a major scheme. This now triggers the requirement for affordable housing. Other considerations should now include additional amenity space, overlooking of neighbours, loss of privacy, overshadowing and car parking spaces. This latest proposal does not provide the additional car parking to adhere to Epsom’s requirements ie 0.75 spaces per flat. Council Policies include review of DM11 (Density) and DM12 (Amenity Space).

The proposal should also review adequacy of foundation designs, drainage volumes and discharge, fire escapes, firefighting and community lobby layouts. Likewise, the necessary high-level demolition works could affect structural designs and connections.

ECS has also considered the proposed works in relationship to the new Town Centre Master Plan. The Parade would become busier with an increase in traffic and pedestrian movement. The existing footpath to the south side of The Parade stops short at the Friars Garth site boundary. ECS believes there is a case for a sec.278 agreement to provide for a new footpath at the front of the site. This is another example of new factors that should be considered relating to a 4 storey development at Friars Garth.

In conclusion, the Society objects to this application as it should have been submitted as a new application for a new 4 storey, 12 flat scheme and not merely an amendment to a ‘half built’ ongoing project. Also, we believe that there are new factors which come into play which need to be recognised.

For all the above reasons, Epsom Civic Society recommends that this application is refused, and a new application for a major scheme be requested from the applicant.

See our letter here.