19/01/2020 17:26:00.......Posted by Helen Pollard
Here is a copy of my submission to the Council in relation to the latest consultation on the Local Plan:
1. THE CROYDON PLAN IN RELATION TO THE LONDON PLAN
The decision to launch the consultation 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 6410, 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 residents will see all the unnecessary approved applications for suburban intensification which will doubtless follow such a policy decision 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 unnecessary 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.
2. STRATEGIC OPTIONS
In relation to the various Strategic Options put forward:
Strategic Option 1
Should be amended as there is no need for ’windfall’ intensification as 8700 less homes needed.
Strategic Option 2
Should be amended to support the Purley Way transformation area as a focus for 12,000 new homes. There is no longer the need for ‘windfall’ sites with the 8700 reduction in the London Plan.
Strategic Option 3
Should be rejected for the reasons outlined above. Furthermore,
- It is incompatible with the Council’s stated aims in relation to climate change, biodiversity and the green grid.
- The Council’s own documents confirm that it will cause more than substantial harm to the setting of the green belt.
- The Mayor of London has re-stated his own commitment to protect the green belt.
- The loss of green belt will not be compliant with the London Plan or NPPF.
- According to the letter from the Minister of State for Housing dated 2nd October 2019 and copied to all local authorities expressly states, “the Green Belt should only be altered in exceptional circumstances” and “to limit the pressure on undeveloped Green Belt” and ensure Councils bring “forward brownfield sites for development”.
- In Addington the sites chosen run alongside tram lines which will restrict access/egress as well as a present safety concerns due to ease of unauthorised access/trespass.
- The area off Lodge Lane represents a ‘green’ boundary between two housing conurbations in New Addington and Falconwood Rd and Forestdale.
- The area in Gravel Hill has no obvious road access given the existing housing, the school premises and the tram lines.
- The area off Lodge Lane will be limited by an access route off the existing main roundabout which is already very busy because of its exit routes to key parts of New Addington and Lidl supermarket.
- The existing tram service doesn’t cope now at peak times with most peak services being overcrowded.
Individual developments tend to envelop the whole site, often encouraged by SPD2, meaning that too much biodiversity is lost.
Instead, I support the Purley Way transformation area which has high potential for mixed use development, improved public realm, greater potential for infrastructure and improved accessibility to the green grid.
Loss of green spaces and gardens will increase water run-off and therefore flooding in vulnerable areas.
4. PROTECTING GREEN SPACES
Local Green Space designation is still lacking with many of the borough’s parks and green spaces failing to achieve local protection through LGS designation, despite the tireless work of Friends’ Groups across the borough.
Small green spaces, such as the space at Covington Way, are just as important as large tracts of green space or local parks. However, these spaces, together with some of Croydon’s parks do not have the protection they need to prevent development. Recent experience indicates that this might actually be a deliberate policy by the Council to allow the sale of green spaces in order to enable development. This policy should not be facilitated by the Local Plan, and the spaces should be protected. The Council should be setting the example of preserving and enhancing green spaces, particularly those in its control, by not building on such spaces through its wholly owned development company Brick by Brick.
Green spaces on council estates, like Monks Hill, should be protected from development. These areas are already intensively developed and they need these green areas.
Precious green areas such as Foxearth Spinney should be protected from land grabs by Brick By Brick, especially in the light of the Mayor’s reduction in the housing target.
In planning terms, Croydon has very different characteristics from inner London boroughs, and yet, it is subject to the same parking policies. Many areas of the borough, including many parts of my own ward of Selsdon and Addington Village, have poor access to public transport. Removing parking spaces from development won’t mean there are fewer cars; it will mean that there are more cars parks on the street and inappropriate places. This will change the character of the area, be dangerous and will not meet the needs of the residents living in these developments.
6. TRANSPORT LINKS
The amount of development envisaged for Croydon will mean there is far greater demand for public transport. A condition of moving ahead with the number of homes planned, should be the delivery of specific transport upgrades and enhancements e.g. upgrade the number of services at East Croydon and other local stations, improve bus services, more GP surgeries.
7. THE CHARACTER OF CROYDON
The impact on the character of an area will be significant where there are many HMOs e.g. in the Chatsworth Road Conservation Area. This plan misses the opportunity to introduce policies around the cumulative impact of HMO’s in many areas across the borough. Whilst the introduction of an Article 4 Direction is helpful there are still minimal policies to deal with the many issues that HMO’s can create.
It is difficult to see how this document can ‘reinforce local distinctiveness, by responding to, and enhancing their context, character and heritage’ when such unjustified intensification is being encouraged and documents such as SPD2 deliberately undermine local character.
8. BUILD IN MORE GREEN SPACE
The Plan does not address the need to increase the amount of green space in the borough and to bring biodiversity even to build up areas.
There should be a coordinated approach to;
- Include more trees and green spaces in all developments
- Invest s106 money in green spaces and parks
- Protect and enhance all green spaces. After all, with more people living in the borough, there will be increasing pressure on all green spaces
- Clear standards for the maintenance and preservation of these spaces
9. TOWN CENTRE
This plan 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.
In District Centres, the Plan should give priority to Community Plans when making decisions about developments. Any developments should be consistent with the plan for the area e.g. Selsdon Community Plan