Monday 20 January is the revised date for submissions of comments on the council's Local Plan, Partial Review. As has been widely publicised by Residents' Associations and Friends Groups, the revisions to the plan proposed will have wide ranging consequences in our suburbs, and particularly on the loss of more Green Belt (to add to that land the Labour Council freed up for development in 2018). If residents want to protect their area from further damage, now is the time they must stand up for their local area, working with Conservative councillors, writes Conservative Group Leader, Clr Tim Pollard.
You can view the documentation the council has produced here.
You can let the council know your views using the online tools on their documentation page or simply by emailing LDF@croydon.gov.uk
I have made my submission to the consultation today, covering both borough-wide and issues more narrowly relating to my ward. I reproduce it below, in full.
Comments on the Local Plan Partial Review
The Croydon Plan revision in the context of the London Plan
The decision to launch the consultation to which this letter responds was taken on 21 October 2019. On the very same day, Inspectors delivered their report into the inspection of the London Mayor Sadiq Khan’s proposed London Plan.
It seems a curious decision to launch a set of issues and options for Croydon on the very day that the plan immediately above Croydon’s in the hierarchy of plans was to be approved, or amended. As we now know, the changes the Inspectors required to be made the London Plan are substantial and have a huge impact on the residential housing targets which Croydon now needs to put forward its ideas on achieving.
As a result of the Inspectors’ report London Mayor Sadiq Khan has conceded a significant reduction in his new homes target from 65,000 to 52,000 per year across London as a whole.
The inspectors’ report, published in October after some 12 weeks of public hearings, specifically rejected Khan’s proposals for almost 250,000 new homes on small sites, predominantly in Outer London, over the next 10 years. The London figure is then re-apportioned across the boroughs to produce new borough targets.
The London Plan overall housing target for Croydon for the next ten years was 29,490 homes. This has now been reduced as a result of the Examination in Public to 20,790 homes. Within that Croydon figure it is small sites that have been reduced from 15,110 to 6,410, a reduction of 8700 homes.
However, all the options considered in the Croydon Local Plan partial review are predicated on the Mayor’s original, and now abandoned, targets. In his announcement at Cabinet on 21 October, the responsible cabinet member made it clear that the reduction in London-wide and Croydon targets based on the London Plan inspection were not going to reduce the administration’s desire to deliver the much higher targets contained in the Partial Review document it published on the same day. It is therefore clear that this is a political decision, rather than an evidence-driven planning policy decision.
If this decision is confirmed after ‘consultation’, residents will see all the ‘un-necessary’ approved applications for suburban intensification which will doubtless follow such a policy decision in this light: as the actions of an administration which is imposing such a level of change because it wants to, not because it has to.
Such wilful disregard for the now-accepted revisions to the London targets must surely discredit all the options for Croydon now under consideration.
Strategic Options 1 and 2 in the proposal document place significant reliance on ‘windfall site’ – that is to say, suburban intensification and back-garden sites. These are no longer necessary to anything like the proposed extent. Strategic Option 3 involves the de-designation and use of substantial tracts of Green Belt. The target changes render this option completely un-necessary and unjustifiable. The council’s own documentation confirms that the release of Green Belt will be harmful, and it is now in conflict with another part of the Mayor’s Plan: Mayor Khan is clear that Green Belt should not be used for this purpose in London and the Inspectors confirmed that part of his plan. Thus the loss of green belt will not be compliant with the London Plan or NPPF.
The three strategic options are at the heart of the review document. But all three have now been rendered obsolete by the accepted changes to the London Plan.
The council should therefore go back to the drawing board and produce a new options paper which reflects the new reality and is consistent with the London Plan.
The principles underpinning the proposals
Flats vs houses
The proposal document talks extensively about achieving the numbers it desires, and the chief method it uses to achieve that is through construction of flats. There is nothing wrong with building flats and there are people who are at a life stage where a flat is the ideal home. However, for most families, the ideal remains a house with a garden, as the preferred way to raise children. All the proposals involve the construction of huge numbers of flats without much private outdoor space, with a large number of family houses being demolished in the suburbs to create the space for the intensification.
There is an obvious long-term issue here: the tens of thousands of additional residents we will have accommodate in blocks are likely to wish to move out of those locations and into houses, but we are not building the houses for them to move to. In fact, it’s worse than that: we are reducing the supply rather than increasing it. In no conceivable way are we building a sustainable supply of housing that accommodates our families as their needs change.
With the proposed town and district centre expansions in high rise development, we should be specifically protecting all types of family housing in the suburbs to create a sustainable housing supply chain.
Dividing the targets by place
For the first time, the proposals suggest sub-dividing the borough target into place targets, such that each of Croydon’s 16 places will ‘take its share of development’. This seems like a sub-division too far. London’s target clearly has to be sub-divided into borough targets, as each borough is its own planning authority and only the boroughs have the power to implement decisions. The 16 places do not have their own decision making powers and planning decisions will continue to be imposed upon them by a planning committee which may or may not contain representation from that area.
The targets should remain at the same level as the decision-making body – and therefore remain at borough level.
The environment, climate change and biodiversity
The review correctly recognises the importance of countering climate change and maintaining our environment. However, in practice, the review contains a number of proposals both explicit and implicit which don’t just not help our environment, they actively harm biodiversity and carbon reduction.
Far too many developments are coming forward which entirely fill the site – an example being the Barrowsfield development in Sanderstead which fills its site so completely that the play space has to be on the roof. This filling of sites is encouraged in SPD2 and results in a significant loss of biodiversity.
The Local Green Space designation proposed in 2013 was found wanting by the Inspector at this borough’s Examination in Public and the current proposals still lack coherence, with many treasured spaces not attracting any protection through Local Green Space designation.
In the last year the council has demonstrated clearly that its wholly-owned housing developer, Brick By Brick, has been tasked with developing a wide range of green spaces which the residents nearby assumed to be protected. Whereas a commercial housing developer cannot really be faulted for opportunistically trying to develop informal green spaces, the council’s own builder surely can be. The council should be setting an example of best practice through BxB, not an example of commercially greediest practice.
Cars and parking
The vast majority of residents support the desire for public transport and green transport options such as walking or cycling to be enhanced: it is clear that new development should encourage and support this. However, encouraging greener transport does not mean that it is appropriate to be anti-car.
The review rightly recognises that ‘in the south of the borough there are areas with relatively limited public transport coverage and challenging topography, which means currently there is a greater reliance on cars’ but goes on to say that parking is an ‘inefficient use of land’ Therefore, there is a need for more innovation, perhaps using underground parking or creative stacking systems.
In Planning Committee residents frequently ague that parking provision for new developments are inadequate and in the real world will result in substantial overspill. This is clearly a significant issue and this review must introduce stronger cumulative tests for on-street parking stress levels.
Croydon should adopt parking standards that are appropriate to the often low PTAL and hilly topography. This may well see us diverge from the London Plan. Standards should vary to reflect the PTAL and topography issues in many areas and should impose a minimum level of parking that makes a development acceptable.
I support the Brighton Main Line upgrade, which is vital to improve services and encourage residents to shift to train usage.
Employment land and commercial developments
It is extraordinary that this review does not mention the long-desired Whitgift Centre upgrade as fronted by The Croydon Partnership. Most residents and businesses believe that this scheme is vital if Croydon is to regain its former position as a thriving retail and commercial centre, rather than becoming a dormitory town for London. The scheme is now clearly in significant difficulty and its delivery should be an absolute priority for the Council.
I support the work done on the Purley Way transformation and would like to see this area becoming a location for a wider diversity of uses, both residential and commercial. It will, however, need much more than shops and flats if it is to become a desirable place to live.
Article 4 in relation to HMOs
There is an opportunity, as part of this review, to include a full suite of policies to deal with any HMO applications that arise. The council has approved its Article 4 to bring HMOs within its remit as a planning authority, but what is now missing are the policies to ensure that HMO applications come forward which are appropriate and that refusal decisions made by the planning committee or officers are not overturned on appeal because of the lack of defined policies. This should be corrected by the inclusion of appropriate policies.
Issues around my own ward of Sanderstead
Green belt encroachment
As identified earlier in this letter, the proposal to build on Green Belt off Rectory Park and Mitchley Hill should not even be contemplated. This is contrary to NPPF and London Plan policies on Green Belt, is accepted by the council as being harmful and is not necessary if the council accepts the new London Plan housing target for Croydon.
Sanderstead Recreation Ground
Sanderstead Recreation Ground is an intensively used open space with a community café. It is the only park in the locality where team sports can be played and it is used for hugely diverse activities. Under no circumstances should any of this park be salami-sliced off for other purposes, including school expansion. There are less destructive ways that local school places can be provided.
Purley Beeches & Wettern Tree Gardens
A number of local residents have put forward excellent appraisals of the importance of these local spaces which I will not paraphrase here, but which I fully support. These are very important formally managed spaces which should receive full protection from development in our Local Plan.
Also important are a number of informal spaces such as the Green at Elmfield Parade. This is used for regular community events and forms an important context for the local shops – any development on this location would hide the shops from passing trade and would most likely render the parade unviable.
It is suggested that up to 54 homes could be provided on the Waitrose site. This is a relatively recently built store so it is hard to imagine that Waitrose will wish to demolish it so soon, which leads one to conclude that the concept is for development over the car park. This may be acceptable but it is also a fact that overspill parking is already a major issue on Limpsfield Road and Riding Hill/Balfont Close. The vast majority of trade in store relies on customer parking – it is not a location that enjoys much ‘passing trade’. Whatever is developed there should be consistent with Sanderstead’s village character and not be overbearing.
It is also suggested that up to 24 homes could be built on the Good Companions site on the borough boundary. This seems very problematic. In a comprehensive appeal judgement in 2014/15 it became clear that the development of this site for a supermarket is very challenging (and arguably impossible), particularly in relation to lorry access. This is exacerbated by its location opposite the main entrance to a primary school. The difficulties espoused in 2014 have been made more acute by the development of the site opposite (the former Ken’s Autos) which makes the access difficulties look even more difficult to resolve. Adding residential to the mix makes the ultimate development of this site even more difficult. It would perhaps make more sense to make it clear in our plan revision that this site is not appropriate for supermarket use and that a residential-only option is preferred, which would almost entirely negate the lorry access issue.
Development near railway stations
Support is given in the CLP draft documentation for intensification of development within 800 metres of a town centre, or rail or tram station. However in the new London Plan is says ‘Incremental intensification of existing residential areas within PTALs 3-6 or within 800m distance of a station or town centre boundary is expected to play an important role in contributing towards the housing targets for small sites ….. This can take a number of forms, such as: new build, infill development, residential conversions, redevelopment or extension of existing buildings, including non-residential buildings and residential garages, where this results in net additional housing provision. …...”
So the pending London Plan is encouraging developments to be undertaken up to 800 metres from rail stations with a PTAL rating of 3 to 6. However, all land and existing development within 800 metres of Riddlesdown Station has a PTAL rating of 2 or less. The CLP should be much clearer in this respect that no intensification is required within 800 metres of Riddlesdown station, due to it’s poor PTAL rating of 2. The same applies to almost the entire area around Sanderstead Station which lies within my ward.