Response to local planning consultation SPD2
14/10/2018 17:59:00......Posted by Luke Clancy
Documents setting out planning guidance for the borough and how the Council will engage with stakeholders are available for comment. Below are some of the points from my response to the consultation on Suburban Design Guide Supplementary Planning Document (SPD2).
Figures 1.3a, 1.3b and 1.3c are used to justify expected development patterns including ‘backland development’ in the suburbs over a period of 10 – 15 years, “so that change is gradual and can be managed to ensure that the benefits of such growth are optimised.” But the examples given of the types of development expected are not defined in sufficient granularity and are too scattergun to give an objective sense of whether what is being proposed would be acceptable.
In terms of how acceptable a development might be to existing residents, the bullet points provided in paragraph 2.2 will be key, in particular emphasis on two of them: whether a proposal improves or positively contributes to local character; and how the impact on neighbouring amenity can be minimised as far as possible. Much will depend on how sympathetically these policies are applied.
Para 2.3.2: “Smaller suburban proposals providing up to 9 dwellings should also seek to maximise the number of dwellings with 3 or more bedrooms.” It would be helpful if this could be expressed more accurately, perhaps setting a target or requirement for three bedroom family units in developments of 9 dwellings or less.
Para 2.3.6: “A development proposal that seeks to deliver a scheme that could form part of a larger potential development on the same or adjoining land will be assessed as an application for the larger development potential.” Whilst the intention of this policy might be laudable, I have concerns that in borderline cases this could result in developments being tipped over the threshold because more studios, one- and two-bedroom units are built at the expense of larger three bedroom properties which would be suitable for families.
Paras 2.3 & 2.4: “Optimising sites building across boundaries.” Whilst in economic terms this makes sense, in reality the developments that result from such consolidation may not be sympathetic to an area if they create ‘mega’ blocks. The schema in Figure 2.4a is an alarming example of the type of over-development that could result.
Paras 2.6.3 and 2.6.4: ‘Minimal necessary car parking will be the starting point for all development proposals and the borough will encourage lower parking provision in areas of PTAL 4 and above.’ I can see why the Council may want to do this. The Croydon Local Plan currently seeks to reduce the need to travel by concentrating development in areas with a higher PTAL rating. As such, from 2011 to 2014 the majority of new homes (58%) were in areas with a PTAL rating of at least 3 - typically areas that have already undergone a degree of intensification. Only 10% of homes were built in areas with a PTAL of 4. The proposals therefore seek to increase density in less urban areas. But this ignores the fact that areas with PTAL ratings of 4 can have quite patchy access to public transport. Also, that residents in those areas will still aspire to owning a car. Any policy should seek to balance these challenges in part by ensuring sufficient provision of more public transport and other sustainable methods of transport, as is encouraged in 2.6.8.
Para 2.7.2 refers encouragingly to some areas within Croydon “being defined by the predominance of certain types of homes”. This aspiration may give hope to residents that the Council will extend protection to what is perceived to be the character of their areas on those grounds. But the three approaches to how to respond to local character in the design of new developments that the Council goes on to endorse in Para 2.8 would appear to allow a very broad interpretation of what is acceptable in any area, if interpreted loosely. A braver and more specific interpretation of what is acceptable would be welcomed in the SPD.
Para 2.9.9: “Where there is a concern that a development would appear overbearing to a neighbouring property and/or create a poorly designed streetscene, they will not be supported.” This is to be welcomed.
Para 2.15.2: “Proposals which span plot boundaries may seek to achieve this through stepping form to create a link element between two main building forms located on each of the original plots.” I am not convinced that such designs necessarily reduce sufficiently the sense of massing created by developments that incorporate links.
Para 2.23: A prohibition on materials that are proven not to weather well or provide longevity is to be supported.