Briavels Court, Downs Hill Road, Epsom KT18 5HP

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25/01351/PDEAD Prior Approval Schedule 2, Part 20, Class A: New dwellings on a detached block of flats to create a single storey roof extension to accommodate 4 new dwellings.

This is one of seven applications (one for each existing block of Briavels Court), applying under Permitted Development Rights to add a fourth storey to the existing three-storey blocks, adding 21 new flats in total. The Society has objected to them all via the Comments facility on the EEBC Planning website as follows:-

1. It is acknowledged that the applications as presented do probably conform to PD rights and have regard to the applicable conditions and restrictions.

2. ECS has concerns about the proposed buildings each to form four floors without lift provision. Part M of the Building Regulations stipulates that occupiers should be assured ease of access for everyday people including those with disabilities. Whilst it is acknowledged this is not a planning requirement, the practicality and saleability of quality residential accommodation on a new 4th floor with stairs only access is questionable and could be discriminatory for the less able.

3. As a consequence of No.2 if the assumption is correct, in the event of approval(s) being given the applicant may well come back with an amendment to incorporate lifts which, short of a very major change to all floors with an internal lift (highly unlikely) to construct an external lift shaft to serve the new development. Such an application would negate the PD rules. Experience tells that amendments to approvals have the trend of being approved without committee or effective public consultation, that should not be allowed to occur.

4. ECS notes that the number of new car parking spaces proposed to serve the additional 21 flats fall below the prescribed parking standards. However, SCC as Highway authority has stated that the effect of the proposals will be minimal and unlikely to meet unacceptable or severe criteria as prescribed in NPPF 2024.

5. ECS considers that a new updated in school term time parking survey is required as the existing is outdated.

6. Concern is given about the effect of the additional on-site parking particularly to the fine and predominant listed TPO evergreen tree and the effect to the reduction of greenery to the fine landscaping of the site.

7. All the factors enumerated require careful and close examination before determining the applications(s).