Planning Report – April 2022

Applications

Additional Matters

Croydon Draft Revised Local Plan – Latest News
London Plan Supplementary Planning Guidance Consultation (Consultation closed 27^th Mar 2022)

Applications

New

26 Gladeside – Ref: 22/00096/FUL
Erection of a two bedroom bungalow fronting Woodmere Close.

Consultation Closes: 27^th Apr 2022
Target Decision: 17^th Mar 2022
• Total Consulted: 34
• Objections: 0
• Supporting: 0

Further developments are in the May 2022 Planning Report.

77 Woodmere Avenue – Ref: 22/00726/FUL
Demolition of single family dwelling and garage to facilitate the erection of a detached 2-storey building with accommodation in the roof space, comprising of 7 self-contained apartments with intergraded bike store and 8 off street car parking spaces.

We objected to the proposed development on the grounds that:

The applicant has failed to provide rear elevations showing the relationship between the proposal and the rear elevations of the adjacent dwellings in order to correctly assess the requirements of SPD2 section 2.11. However, the occupants of 79 Woodmere Avenue have provided local measurements for an assessment of SPD2 para 11.2c for 79 Woodmere Avenue, but we have not had success for similar measurements for 75 Woodmere Avenue.
The validation Checklist Table requires a Sunlight/Daylight Survey assessment to establish if there is any likely adverse impact on the current levels of daylight/sunlight amenity enjoyed by adjoining properties, including their associated gardens or amenity space, as well as levels of daylight in the proposed spaces. We assess this is probable as the proposal fails the 45° Rule SPD2 para 2.11 c). However, this requirement has NOT been addressed or assessed and therefore we request that the case officer require the applicant provides the appropriate evidence for assessment prior to a recommended determination.
It is clear from the Applicant’s provided documentation and Plans that no account has been taken of the London Plan Policies D1 to D3 or H2 or the Current adopted Croydon Plan and there is NO mention of “Design Codes” or their parameters or a “Design-Led Approach” including the “Design-Led Approach or the National Model Design Code and Guidance to determine the Area Design Code(s) “Setting” for this proposal.
Additionally, NO account has been taken on the main thrust of the New London Plan since the omission of the Density Matrix, to assess the proposal meets the London Plan Policies D1 to D4 & H2 with regard to the Design-Led Approach and the requirement to assess whether the Site Capacity has been breached.
The offered Housing Density of the proposal is 61.08Units/ha which is just within the Urban Range at 77 Woodmere Ave is, by all our assessments of the locality, in an Outer Suburban Setting “Design Code” Area Type.
The proposal is inappropriate for “Incremental Intensification” as it is below PTAL 3 and greater than 800m from a Tram/Train Station or District Centre as defined by London Plan Policy H2 para 4.2.4.
The proposal meets most London Plan Policy D6 minimum space Standards other than Flat 3 and Flat 7.
The evidence in the above table indicates a deficiency of Play Space for the probable 9 number of children to be 90 m² which is at 16.8m²is deficiency of:
((16.8 – 90)/((16.8 + 90)/2)) = 73.2/53.4 = 1.37 = 137.079% ≈137.08% deficiency.
The Croydon Plan Residential Parking allocation for this proposal is 8.5 (rounded to 9 nearest integer) and the London Plan allocation is 10.5 when the offered provision is 8 bays one of which is for disabled and one of which has EVC.
Taking all the foregoing evidence when considered in total, the proposed development should be refused on grounds of overdevelopment, inadequate space standards, and insufficient play space for the probable number of children of the future occupants.
The local Design Code Area Type Setting is evident at “Outer Suburban” which limits the Housing Density to a maximum of 40Unit/ha when this proposal is 61.08Units/ha and therefore the Site Capacity of 0.1146hectares has been significantly exceeded.

MORA Submission: 11^th Apr 2021
Consultation Closes: 17^th Apr 2022
Target Decision: 19^th Apr 2022
• Total Consulted: 25
• Objections: 21
• Supporting: 0
Councillor referral: Councillor Sue Bennett (30^th Mar 2021)

Further developments are in the May 2022 Planning Report.

Decided

21 Woodmere Gardens – Ref: 21/03702/FUL
Demolition of single-family dwelling and garage and the erection of 3 x two storey terraced houses with accommodation in the roof space, with 3 off street car parking spaces and a detached 2-storey building with accommodation in the roof space, comprising of 6 self-contained apartments with integrated bike and refuse stores and 6 off street car parking spaces.

We objected to the proposed development on the grounds that:

The proposal has inadequate in-built storage for the future occupants which is an indication of overdevelopment as the Developer is attempting to squeeze as much as possible into a limited site area which does not allow the minimum internal space standards to be implemented. The London Plan suggests these space standards are a ‘minimum’ and should be exceeded, if at all possible, which means reducing the densities accordingly such that all space standards can be generously met.
The most contentious issue raised by local residents is ‘over-development’ of a site. The current adopted Croydon Plan does NOT provide any methodology to determine individual locality “Site Capacities”, “Character Assessments” or “Design Codes” of sufficient detail (for localities within the Places of Croydon), to assess an applications’ Local ‘Site Capacity’ in accordance with the new London Plan (2021) Policies D2 and D3.
Recognising the foregoing, and acknowledging that the adopted Croydon Local Plan is ‘inadequate’ in specifying meaningful ‘growth’ definitions or to implement the New London Plan Policies D1, D2, D3, D4 and H2, Planning Officers must therefore make an assessment, based upon the current and future known public transport accessibility with other available services infrastructure’, ‘Local Character’ and ‘Site Capacity’ to estimate an appropriate level of Residential and Housing Densities for Sustainable Development within the available existing parameters, without ‘cognitive dissonance’, as there is no prospect of local supporting infrastructure improvements in the locality over the lifetime of these Plans.
The objective of the New London Plan is to provide housing to the highest quality whilst “optimising site capacity” to meet the ambitious targets and address housing ‘need’ while maintaining good external and internal design, which is quite different from optimising a single dwelling’s site capacity to provide as many units as possible (9 in this case), that can be squeezed onto a site to maximise profit at the expense of supporting a ‘Sustainable Development Site Capacity’.
This proposal does NOT provide an appropriate acceptable value for “gentle Densification” or “Gradual, Moderate Incremental densification” as assessed according to the London Plan definition for “Incremental intensification” over and above that of the existing locality for a suburban area of PTAL 1a (Less than 3 to 6) and at greater than 800m from a train/tram station and greater than 800m from a District Centre.
We have assessed this proposal using as much evidence as available which is appropriate for evaluation. The Croydon Local Plan Review is not produced concurrently with the new revisions of the London Plan Policies and therefore the adopted Croydon Plan does NOT include the requirements to implement the New London Plan ‘Design-Led-Approach’ Policies. We have used the NPPF references and the National Design Guide and National Model Design Code where appropriate.
The NPPF National Model Design Code 2B indicates Housing Density for Suburban localities should be within the range 40 to 60 units per hectare. This development proposal has housing density of 78.38 Units per hectare which exceeds the Guide maximum of 60 by 30.6333% and should therefore be refused. This proposal should tend toward the lower limit of 40 u/ha as the PTAL is Zero.
The NPPF National Model Design Code ‘Built Form’ indicates that the Floor Area Ratio (FAR) in a suburban setting should be (Less than) <0.5, whereas the Floor Area Ratio for this proposed development is 0.57 and should therefore be refused.
All the foregoing reasoning confirms this proposal is an over development of the site at this location. It can however be logically assumed that “Gentle Densification” or “Gradual, Moderate Incremental Densification” (all undefined) in an area “inappropriate” for “incremental intensification” would have an appreciably ‘discernible’ reduction in Density than those localities categorised and listed in Croydon Local Plan (2018) Table 6.4 – “Accommodating Growth”.
It is overwhelmingly apparent therefore, that this proposal is an overdevelopment for this locality on the many methods of evaluation referenced in our submission, bearing in mind that recent cumulative developments have already placed significant strain on the available supporting infrastructure such that there is now inadequate infrastructure to support this and the previous developments when completed and fully occupied. It is recognised that there is no planned improvement in Public Transport Accessibility in the foreseeable future for the Shirley North Ward.
The Planning Committee emphasise the “compelling need for more homes” for which appropriate targets have been identified. However, the pressure to meet housing ‘need’ in the MORA area has been categorically satisfied by over-provision of the established strategic targets for the Shirley Place. It would therefore be inappropriate to quote this ‘need’ as a significant reason to approve this application as the identified ‘need’ has been more than met within the Shirley North Ward to meet the whole Shirley Place Targets. Or alternatively, explain why the Shirley North Ward should exceed the strategic quota.
We have clearly established that both the New London Plan and the current Croydon Local Plan is ‘devoid’ of any defined policies to determine either acceptable or unacceptable ‘growth’ of any proposals with regard to the ‘Site Capacity’ and the available infrastructure for sustainable Densities which means the Policies are ‘unenforceable’ and ‘undeliverable’ which also means the LPA is not meeting its Statutory obligations to ensure Development Proposals are Sustainable Developments.
The proposal would result in the loss of a family home with generous garden space.
An approval of this Development Proposal would make a ‘mockery’ of all the NPPF Policies, Design Code Guidance and London Plan Policies referenced in this submission.

Permission Refused

Reason(s) for refusal :-

The proposed development, by reason of scale, massing, poor elevational composition, materials and detailing would result in an unsightly, dominant and imposing form of development which would fail to integrate successfully in townscape terms or make a positive contribution to the setting of the local character and immediate surroundings contrary to Chapter 2 and 12 contained within the NPPF (July 2021), policies D2, D3, D4, H2 of the London Plan 2021, policies SP4, DM10, DM26 of the Croydon Local Plan 2018 and the Council’s Supplementary Planning Document Suburban Design Guide (SDG) 2019.
The proposal by reason of its massing and proximity close to neighbouring properties 19 Woodmere Gardens and 101 Woodmere Avenue would result in an intrusive and imposing form of development leading to a loss of outlook for surrounding neighbours, overlooking of neighbouring garden of no.19 and would be contrary to policy DM10.6 (c), DM10.7(d) of the Croydon Local Plan 2018, Policies D3 and D6 of the London Plan and the Suburban Design Guide (SDG) 2019.
The proposed development would result in unacceptable standard of accommodation by reason of sufficient information to demonstrate suitable outlook and light to two of the bedrooms of the proposed houses supplied by velux windows, suitable internal headheight to houses; poor access arrangement, poor accessibility to all levels of the block of flats thereby conflicting with Policy DM10 of the Croydon Local Plan 2018, Policies D5, D6, D7 of the London Plan 2021 and the Suburban Design Guide SPD (April 2019).
The proposed development would result in insufficient level of parking spaces, the creation of more than one crossover on a single site, unacceptable position of parking bays along Woodmere Avenue, insufficient sightline details, inappropriate cycle storage facilities by reason of design and position to one of the houses, insufficient footpath width to enable suitable collection of waste to the proposed houses, inclusion of electrical vehicle charging points or suitable blue badge parking and would therefore be contrary to Policies, SP8, DM13, DM29, DM30 of the Croydon Local Plan (2018) and Policies T4, T5 and T6 of the London Plan 2021.
In the absence of a legal agreement securing sustainable highway contributions and establishing if off street vehicle access can be achieved, the proposal would be contrary to Policies SP8 and DM29 of the Croydon Local Plan 2018 and Policy T4 of the London Plan 2021.

MORA Submission: 16^th Aug 2021
Consultation Closes: 25^th Aug 2021
Target Decision: 22^nd Sep 2021
• Total Consulted: 9
• Objections: 9
• Supporting: 0
Councillor referral: Councillor Richard Chatterjee (31^st Aug 2021)
Permission Refused: 28^th Mar 2022

Further developments are in the September 2022 Planning Report.

Sandrock Pub – Ref: APP/L5240/W/21/3279949
Two storey side and rear extension to The Sandrock Public House to provide an enlarged service (including front seating area) to the existing pub (A4 Use Class) and conversion of the upper floors including extension to form 4 flats (2×2 bed, 2×1 bed) and construction of a three storey building to the rear comprising 15 flats (8×3 bed, 3×2 bed, 4×1 bed); hard and soft landscaping; communal/amenity/play space; car parking between the two buildings; new crossover along Sandrock Place; boundary treatment and refuse and cycle provision.

We object to this development on the grounds that:

The proposal is an over-development for the area. The Residential Density is excessively high which would require a PTAL of 5 when the actual PTAL is just 2. The densities for this location at PTAL 2 at such a high percentage increases are NOT justifiable and compromise the London Plan Policy 3.4 – Optimising Housing Potential and should therefore be resisted – that is Refused.

The proposed development’s massing and height do not reflect the local character and forms of the surrounding locality.

The proposed development does not comply fully with minimum spaces standards for new dwellings or fully comply with the required amenity space standards.

There is no usable communal open space for the future occupants of the proposed development and there is no provision of children’s play spaces for children of the future occupants of the development.

The development is within the grounds of an existing building and is most definitely NOT subservient in terms of height and massing and therefore is non-compliant to the Croydon Plan Design and Character policies of DM10. In addition, the host building does not retain any garden after partitioning and is non-compliant to Policy DM10.4 e)

This proposal has insufficient car parking space and will result in overspill on street parking in the surrounding streets which will cause significant problems to adjacent existing residents.

There would be major overlooking and invasion of privacy to the occupants of number 6 Sandpits Road and 1A Sandrock Place private outdoor space and therefore does result in direct overlooking and should be refused.

On 4th February 2021, revised drawings were added to the online register.

Permission Refused

Reason(s) for refusal :-

The proposed development, by reason of the height, width, depth and overall design of the extensions would poorly integrate to the public house and with the siting and massing of the rear block would be detrimental to the appearance and setting of the locally listed building resulting in a development that would be out of keeping with the character of the area and cause harm to the locally listed building. As such, the proposal would be contrary to Policies D1, D3, D4, HC1 of the London Plan (2021), Policies SP4, DM10, DM18 of the Croydon Local Plan (2018) and the Croydon Suburban Design Guide (2019).
The proposed development, by reason of its combined site layout, height, width and depth would result in a cramped form of overdevelopment that would be detrimental to the residential amenity of neighbouring and surrounding occupiers as well as future occupiers of the development especially in regards to daylight/sunlight. As such, the proposal would be contrary to Policies D1, D3, D4, D5, D6 of the London Plan (2021), Policies SP4, DM10 of the Croydon Local Plan (2018) and the Croydon Suburban Design Guide (2019).
The proposed development, by reason of insufficient on-site parking for future users of the public house would result in overspill parking which would be detrimental to the highway and pedestrian conditions of the area. As such, the proposal would be contrary to Policies T1, T4, T6 of the London Plan (2021), Policies SP8, DM29, DM30 of the Croydon Local Plan (2018) and the Croydon Suburban Design Guide (2019).

Permission Granted on Appeal: 14th Mar 2022

The Planning Inspector’s findings conclude that:

The size and flat roofed nature of the extension has drawn criticism from the Council and in representations as failing to be subservient to the heritage asset and at odds with its character because of the flat roof. While it would be of a considerable size in relation to the retained building, the recessed position of the main elevations would help to make it subservient in appearance and would allow the retained building to maintain its prominence on the corner. The flat roofed design departs from that of the original building, but it has been purposely designed in this way to reduce the height of the extension so that it does not compete with the heritage asset. I consider that to be a legitimate design response to the provision of residential accommodation while seeking to retain the public house building on the site.
The 3 storey residential block would be separated from the public house by a parking and turning area. Because of that separation I consider that it would not appear overbearing in relation to the heritage asset.
I conclude that the development would not harm the character or appearance of the area, including the non-designated heritage asset of The Sandrock Public House, which would be retained as part of the development on its prominent corner site. Consequently, the development would accord with Policies D1, D3, D4 and HC1 of the London Plan and Policies SP4, DM10 and DM18 of the Local Plan, which require new development to be well designed, have regard to the character of its locality, and retain and enhance heritage assets.

MORA Objection Sent: 15^th Jul 2020
Consultation Closed: 16^th Jul 2020
Target Decision: 2^nd Sep 2020
• Total Consulted: 164
• Objections: 122
• Supporting: 0
Case Officer Report recommends: Grant Approval
Planning Committee Meeting: 25^th Feb 2021
Permission Refused: 25^th Feb 2021
Appeal Notice: 9^th Dec 2021
Appeal Representations: 13^th Jan 2022
MORA Appeal Submission: 4^th Jan 2022
Appeal Decision – Permission Granted: 14^th Mar 2022

Hanbury Mews – Ref: 21/05976/FUL
Retention of gates to Hanbury Mews.

We objected to the proposed retention of gates on the grounds that:

Some properties within the surrounding area feature gates to restrict access to private property. However, as most are at the boundary of single dwellings, they have a wholly different relationship with the public realm and do not have the same visual effect in terms of segregating one part of the community from another.
The gates create a barrier within Hanbury Mews that, by their nature, dominate the approach to the dwellings of that road and segregate those dwellings and their access route from the public domain of the surrounding area.
The applicant has indicated that the gates help to provide additional security to the dwellings in Hanbury Mews. These benefits to the residents of Hanbury Mews would not compensate or mitigate the harm to social cohesion caused by the division by the gates.
The separation of the street from its surroundings would cause a harmful segregation of the community that would not accord with the council’s Suburban Design Guide 2019 (SDG) which states that gated developments will not be acceptable.
The main issue is the effect of the development on the character and appearance of the area including the effect on social cohesion.
Retention would NOT comply with guidance and NO applications were submitted prior to commencement of erection of the gates.

Permission Refused

Reason(s) for refusal :-

The development would result in an unsatisfactory outcome for social cohesion in the area by reason of the entrance gate contributing to segregation of the community which would thereby conflict with the Suburban Design Guide (2019), Policies SP4 and DM10 of the Croydon Local Plan (2018) and D6 of the London Plan 2021.
The development would detract from the character and appearance of the area and would be detrimental to the accessibility of the locality by reason of creating a barrier between residential roads and would thereby conflict with Policy SP4.1 and DM10 of the Croydon Local Plan 2018, Suburban Design Guide Supplementary Planning Document and Policy D3 of the London Plan 2021.
The proposed gate and high boundary wall would create a hazard to pedestrians using the footway and vehicles using the highway by reason of inadequate visibility splays and vehicles parked in the carriage way whilst waiting to enter the site and would thereby conflict with Policies SP8 and DM29 Croydon Local Plan 2018, London Plan Policy T6 of the London Plan 2021 and the Council’s adopted Supplementary Planning Document – Suburban Design Guide 2019.

MORA Submission: 27^th Jan 2022
Consultation Closes: 29^th Jan 2022
Target Decision: 17^th Feb 2022
• Total Consulted: 23
• Objections: 2
• Supporting: 0
Permission Refused: 17^th Mar 2022

Further developments are in the December 2022 Planning Report.

Awaiting Decision

5 Elstan Way – Ref: 21/05768/FUL
Erection of single storey (plus loft) dwellinghouse in rear garden of Elstan Way; alterations to existing dwelling, to include a front extension, a roof extension (including 3 front dormers and 1 rear dormer), single storey side extension, removal of rear extension and removal of side garage, and associated elevation alterations.

Consultation Closes: 6^th Feb 2022
Target Decision: 8^th Feb 2022
• Total Consulted: 11
• Objections: 5
• Supporting: 0

Further developments are in the May 2022 Planning Report.

Land To The South Of Firsby Avenue And To The East Of Verdayne Avenue – Ref: 21/06036/FUL
Erection of nine semi-detached and terraced houses, together with associated access, car parking and landscaping.

We hold a neutral stance to the proposed development on the grounds that:

The assessment of the proposal’s Housing Density appropriate for this locality Design Code has been confirmed to be 37.50units/ha which is appropriate to an ‘Outer Suburban’ Setting of 20 to 40 Units/ha.
The Assessment of the Residential Density of 241.67hr/ha or 220.83bedspaces/ha is based upon a conversion factor of an assumed National occupancy of 2.39 occupants per dwelling as defined by the ONS and Statista and therefore the occupancy may be different in this locality. The local PTAL is based upon this conversion factor to be 2.675 or 2.1 respectively but again this is an assumption but is within acceptable tolerance of the available PTAL of 2.
However, using the Office of National Statistic’s data and Statista11 data to convert the Design Code Housing Density to Average National Unit Occupancy, would place the Residential Density Design Code of this proposal into an Urban Setting range of 143.4 to 286.8 bedspaces/ha. The locality is definitely NOT Urban.
The Floor Area Ratio is 0.466 which is <0.5 and therefore acceptable in an Outer Suburban Setting or Suburban Setting.
The proposal’s parking provision meets the London Plan maximum Residential Parking for Outer London Boroughs at PTAL 2.
We are of the opinion that clarifications are required by the Case Officer and the Applicant with regard to the access drive, ‘swept path’ diagrams at the entrance from Firsby Ave., for refuse vehicle and emergency vehicles, and at the “T” and “Y” Turning Heads especially if the upgraded access requires Kerbing throughout the narrow section of the access driveway.
The pedestrian and wheelchair users’ access requires assessment for the safety of these users.
Additionally, details of land ownership of the Access driveway and a statement of future unfettered Access to and from rear gardens in Verdayne Ave properties bordering the proposed site perimeter, requires confirmation prior to a decision being made.
The householders of 50 to 74 Verdayne Avenue must have continued free and unfettered access and use of the Access driveway to their garages and rear gardens via the Access Drive. This access needs to be continued and included as Restrictive Covenants in the Deeds of all the proposed properties if the application is approved.
The access drive is unsafe without a footpath of sufficient width to provide safe passing passage for pedestrians and Wheelchair users when confronted by oncoming and rear coming vehicles whilst entering or leaving the proposed development. The proposed development has unsafe access for both residents and visitors and should therefore be refused.
Resulting from this foregoing assessment and analysis, although concerned of significantly exceeding year on year Targets for the over development of the MORA and Shirley North Ward areas, and the additional significant issues related to the Access Drive, the proposal meets most current adopted Planning Policies but the significant issues relating to Access are not addressed by the Policies which require assessment and evaluation prior to a determination.
We strongly request that Planning Officers address the additional related issues presented in this submission, which are a significant cause for concern without any possible remedial condition appropriate for their resolution. We therefore recommend a refusal on these grounds.

MORA Submission: 29^th Dec 2021
Consultation Closes: 2^nd Jan 2022
Target Decision: 28^th Jan 2022
• Total Consulted: 58
• Objections: 69
• Supporting: 0
Councillor referral: Councillor Sue Bennett (21^st Dec 2021)

Further developments are in the May 2022 Planning Report.

176 – 178 Orchard Way – Ref: 21/06038/FUL
Demolition of existing dwellings, erection of three pairs of two storey 3-bed semi-detached dwellings with roof accommodation and one pair of two storey 2-bed semi-detached dwellings with car parking, formation of accesses onto Sloane Walk together with a new pavement, and provision of cycle, refuse and recycling stores and soft landscaping.

We objected to the proposed development on the grounds that:

The proposal fails to meet the Local Design Code parameters as defined in the National Model Design Code and Guidance.
The proposal fails to meet the Housing Density Design Code for the Setting.
The proposal has a Residential Density which would require Public Transport Accessibility (PTAL) at between 3.64 and 4.0 when the available Accessibility (PTAL) is ≈ 1 with no prospect of improvement prior to 2031.
There is ample evidence of overdevelopment of this proposal at this “Setting” for the “Site Capacity” as shown by the modification of Unit Boundaries and Curtilages, to squeeze the parking within the site area.
It is totally unacceptable for future occupants of Unit 4 to have Unit 5’s Vehicle parked on what would normally be considered Unit 4’s Forecourt, directly in front of Unit 4’s Lounge Window.
Further evidence of over development is shown by the failure to meet the required Floor Area Ratio of <0.5 with the site area for a Suburban Setting as defined in the National Model Design Code and Guide. The Floor Area Ratio offered is 0.66.

MORA Submission: 16^th Dec 2021
Consultation Closes: 1^st Jan 2022
Target Decision: 29^th Jan 2022
• Total Consulted: 101
• Objections: 45
• Supporting: 2
Councillor referral: Councillor Sue Bennett (6^th Jan 2022)
Councillor referral: Councillor Richard Chatterjee (6^th Jan 2022)

Further developments are in the May 2022 Planning Report.

27 Orchard Rise – Ref: 21/05741/FUL
Demolition of an existing house and erection of two semi-detached pairs to provide 4 houses including associated amenity space, landscaping, parking, cycle and refuse storage.

We objected to the proposed development on the grounds that:

This proposed Development would result in the loss of a family home with garden.
The proposal has inadequate in-built storage for the future occupants which is an indication of overdevelopment as the Developer is attempting to squeeze as much as possible into a limited site area which does not allow the minimum internal space standards to be implemented.
Built in Wardrobes are presumed excluded from the minimum standard. The London Plan suggests these space standards are a ‘minimum’ and should be exceeded, if at all possible, which means reducing the densities accordingly such that all space standards can be generously met.
Plot 4 is to M4(3) Wheelchair user accommodation Building Regulation standard, but the disabled Car Parking Bay is furthest from the dwelling instead of a position closer to the disabled dwelling at Plot 4.
SPD2 requires a minimum drive entrance width of 3.6m and for Fire appliance access, this should be increased to 3.7m width. The Site Layout indicates the width is 5.35m at para 9 of the ‘Fire Strategy Statement’ whereas the actual width as physically measured is 3.35m kerb-to-kerb.
It is of significant concern therefore, that the proposal assumes a Fire Appliance could access the drive up to a distance of 20m and be 35m from the furthest dwelling to attend an incident. The Swept path requirement for access from Orchard Rise (5m wide) is Turning Circle ≈15.5m, with a clear Swept trajectory Circle of ≈17.5m which again may be impossible.
The Drive would not support the weight and regularity of construction, earth moving or construction material delivery lorries or the weight of fire appliance tender vehicles of approximately 14 tonnes.
The most contentious issue raised by local residents is ‘over-development’ of a site. The current adopted Croydon Plan does NOT provide any methodology to determine individual locality “Site Capacities”, “Character Assessments” or “Design Codes” of sufficient detail (for any localities within the Places of Croydon), to assess an application’s Local ‘Site Capacity’ in accordance with the new London Plan (2021) Policy D3.
The objective of the New London Plan is to provide housing to the highest quality whilst “optimising site capacity” to meet the ambitious targets and address housing ‘need’ while maintaining good external and internal design, which is quite different from optimising a single dwelling’s site capacity to provide as many units as possible (4 in this case), that can be squeezed onto a site to maximise profit at the expense of supporting a ‘Sustainable Development for the Site Capacity’ .
This proposal does NOT provide an appropriate acceptable value for “gentle Densification” or “Gradual, Moderate Incremental Densification” as assessed according to the London Plan definition for “Incremental intensification” over and above that of the existing locality for a suburban area of PTAL 1a (Less than 3 to 6) and at greater than 800m from a train/tram station and greater than 800m from a District Centre.
We have assessed this proposal using as much evidence as available which is appropriate for evaluation. The Croydon Local Plan Review is not produced concurrently with the new revisions of the London Plan Policies and therefore the adopted Croydon Plan does NOT include the requirements to implement the New London Plan ‘Design-Led-Approach’ Policies. We have used the NPPF references and the NPPF National Design Guide and National Model Design Code where appropriate.
The appropriate Residential Density at PTAL 1a at a Suburban Setting should be in the range 91.5 to 152.2 Bedspaces per hectare, nominally 122 bedspaces per hectare when the proposal is for 172.6 Bedspaces per hectare (i.e., a 41.48% increase from nominal) requiring a PTAL of 2.178 and the available PTAL is 1a (≡ to 0.66). This gives further indication of Over Development. The analysis clearly indicates a simple methodology for assessment when there is NO equivalent Policy in the London Plan or the Croydon Local Plan.
The Planning Committee emphasise the “compelling need for more homes” for which appropriate targets have been identified. However, the pressure to meet housing ‘need’ in the MORA area has been categorically satisfied by over-provision of the established strategic targets for the Shirley Place. It would therefore be inappropriate to quote this ‘need’ as a significant reason to approve this application as the identified ‘need’ has been more than met within the Shirley North Ward to meet the whole Shirley Place Targets. Or alternatively, explain why the Shirley North Ward should exceed the strategic quota
Any additional overspill on-street parking would reduce the road width available to other road users and would cause additional hazards.

MORA Submission: 31^st Aug 2021
Consultation Closes: 8^th Sep 2021
Target Decision: 28^th Sep 2021
• Total Consulted: 10
• Objections: 29
• Supporting: 0

Further developments are in the May 2022 Planning Report.

13 Gladeside – Ref: 21/03518/FUL
Demolition of existing dwelling and erection of a two-storey detached building with accommodation in roof space comprising 6 flats and provision of associated landscaping, car parking, refuse and cycle storage.

We objected to the proposed development on the grounds that:

The proposal has inadequate in-built storage for the future occupants which is an indication of overdevelopment as the Developer is attempting to squeeze as much as possible into a limited site area which does not allow the minimum internal space standards to be implemented.
The proposal does NOT provide adequate Play Space for the children of the future occupants of the development for the life of the development. The London Plan requires 10m² per child and the probable number of children would be 8 requiring 80m² Play Space Area. This is another indication of overdevelopment as the ‘Site Capacity’ does not allow this requirement to be met.
The ground floor Flat 2 is to M4(3) Wheelchair user accommodation Building Regulation standard but there is NO Disabled Car Parking provision within the 4 allocated spaces.
The most contentious issue raised by local residents is ‘over-development’ of the sites. The current adopted Croydon Plan does NOT provide any methodology to determine individual locality “Site Capacities”, “Character Assessments” or “Design Codes” of sufficient detail (for localities within the Places of Croydon), to assess an applications’ Local ‘Site Capacity’ in accordance with the new London Plan (2021) Policy D3 and H2.
The objective of the New London Plan is to provide housing to the highest quality whilst “optimising site capacity” to meet the ambitious targets and address housing ‘need’ while maintaining good external and internal design, which is quite different from optimising a single dwelling’s site capacity to provide as many units as possible (6 in this case), that can be squeezed onto a site to maximise profit at the expense of supporting a ‘Sustainable Development Site Capacity’.
This proposal does NOT provide an appropriate acceptable value for “gentle Densification” or “Gradual, Moderate Incremental Densification” as assessed according to the London Plan definition for “Incremental intensification” over and above that of the existing locality for a suburban area of PTAL 1a (Less than 3 to 6) and at greater than 800m from a train/tram station and greater than 800m from a District Centre.
The NPPF National Model Design Code 2B indicates Housing Density for Outer Suburb to be in the range 20 to 40 Units per hectare and Suburban localities should be within the range 40 to 60 units per hectare. As the Shirley North Ward is located within the Outer London Borough of Croydon, the area could be considered as “Outer Suburban”.
This proposal should tend toward the lower limits of ‘Outer Suburban’ (we are in Outer London Suburbs) at 20 Units per hectare or ‘Suburban’ of 40 u/ha as the PTAL is 1a and at a housing density of 78.38 Units per hectare which exceeds the Guide maximum of 60 by 30.6333% should therefore be refused as inappropriate for the locality.
The NPPF National Model Design Code ‘Built Form’ indicates that the Floor Area Ratio (FAR) in a suburban setting should be <0.5 (less than) whereas the Floor Area Ratio (FAR) for this proposed development has offered GIA of 408.2m² and Site Area of 625.05m² = 0.653 (FAR) and should therefore be refused as it is >0.5 (greater than) and thus inappropriate for the locality.
All the foregoing reasoning confirms this proposal is an over development of the site at this location bearing in mind that recent cumulative developments have already placed significant strain on the available supporting infrastructure such that there is now inadequate infrastructure to support this and the previous developments when completed and fully occupied, it is recognised that there is no planned improvement in Public Transport Accessibility in the foreseeable future for the Shirley North Ward.
It can however be logically assumed that “Gentle Densification” or “Gradual, Moderate Incremental Densification” (all undefined) in an area “inappropriate” for “incremental intensification” (London Plan Policy para 4.2.4) would have an appreciably ‘discernible’ reduction in Density than those localities designated and listed in Croydon Local Plan (2018) Table 6.4 – “Accommodating Growth”.
The Planning Committee emphasise the “compelling need for more homes” for which appropriate targets have been identified. However, the pressure to meet housing ‘need’ in the MORA area has been categorically satisfied by over-provision of the established strategic targets for the Shirley Place. It would therefore be inappropriate to quote this ‘need’ as a significant reason to approve this application as the identified ‘need’ has been more than met within the Shirley North Ward to meet the whole Shirley Place Targets. Or alternatively, explain why the Shirley North Ward should exceed the strategic quota.
Gladeside has blind bends and any additional on-street parking reduce the road width available to other road users and would cause additional hazards.
It is likely that at least 2 on-street overspill overnight parking spaces will be required.
Swept path diagrams should be provided for Bay 1 (nearest the building) to prove acceptable ingress and egress from that bay as it is likely to be a difficult manoeuvre.
The proposal would result in the loss of a family home with generous garden space.

MORA Submission: 23^rd Aug 2021
Consultation Closes: 25^th Aug 2021
Target Decision: 26^th Aug 2021
• Total Consulted: 4
• Objections: 9
• Supporting: 5

Flyer for download and social media sharing.

Further developments are in the May 2022 Planning Report.

75 Shirley Avenue – Ref: 21/02622/FUL
Conversion of and extension to existing dwelling to provide four self contained flats.

We objected to the proposed development on the grounds that:

The proposed development is within an area of PTAL 1b which is inappropriate for “Incremental intensification” as it is NOT in an existing residential area within PTALs 3-6 or within 800m distance of a station or town centre boundary for “Incremental Intensification” as defined in the London Plan (2021) para 4.2.4.
There is NO definition of magnitude for acceptable Gentle Densification or Incremental Intensification and therefore we request that the Case Officer provides justification for the assessment of “Site Capacity” to meet the proposed sustainable development for this Site.
The proposed development does NOT provide full evidence to meet the London Plan Minimum Space Standards with respect to In-Built Storage Space
The proposal is non-compliant to requirement detailed in SPD2 Chapter 4 – Residential Extensions & Alterations. The Ground Floor Plans show the proposed extension at ≈9.8m width when the extension should generally be no wider than half the width of the existing house (5.25m) and no deeper than 45° (in plan) as measured from the assumed nearest habitable room windows on neighbouring properties which requires clarification but gives cause for concern
The ground floor extension 7.4m into the rear garden seems excessive.
The proposal has inadequate parking provision at a locality of PTAL1b for 12 persons probably 8 adults who could own a car or van for business purposes. 6 vehicles may need on-street parking.
The strategic Housing Need for the Shirley “Place” has been exceeded by cumulative developments in the MORA Post Code Area over 2½ years which is just a small portion of the Shirley North Ward (Not even including Shirley South Ward). Therefore, the housing need for the Shirly Place has been exceeded by recent developments and proposals in the MORA Post Code Area alone.

MORA Submission: 25^th Jun 2021
Consultation Closes: 8^th Jul 2021
Target Decision: 14^th Jul 2021
• Total Consulted: 4
• Objections: 33
• Supporting: 0
Councillor referral: Councillor Sue Bennett (26^th Jul 2021)

Further developments are in the May 2022 Planning Report.

Appeals Pending

46 The Glade – Ref: 21/04094/FUL
Demolition of a single storey dwelling and redevelopment with a new building to provide 9 dwellings (Class C3), with associated amenity space, integral refuse, cycle stores and external car parking.

We objected to the proposed development on the grounds that:

The offered Housing Density of the proposal is 88.24Units/ha which is a Setting of Mid-Urban Range and 46 The Glade is, by all assessments of the locality, in an Outer Suburban Setting.
The proposal is inappropriate for “Incremental Intensification” as it is Below PTAL 3 and greater than 800m from a Tram/Train Station or District Centre as defined by London Plan Policy H2 para 4.2.4.
There is NO possible improvement to Public Transport Accessibility in Shirley North Ward at least until 2031 as indicated on the TfL WebCAT for This Post Code or address. We have evaluated the appropriate PTAL which would be required to support this proposal at PTAL 6.202 when the available PTAL is Zero.
The proposal meets most London Plan Policy D6 minimum space Standards given at Policy D6 Table 3.1. The proposal does NOT however, indicate the amount of In-Built Storage of any of the 9 Flats. The Dimensions are NOT stated.
The evidence indicates a deficiency of Play Space for the probable 13 children to be 112.4m² which is a deficiency of 13.538%.
It is noted that the “Vision Transport Assessment” Parking Assessment Report of 13th August supplied as evidence for the applicant, provides an incorrect evaluation of the PTAL for 46 The Glade, indicating a PTAL of 1a when the actual Site PTAL is Zero as shown at TfL WebCAT forecast up to 2031.
The analysis shows that for new developments in areas without controlled parking Zones and at PTAL Zero, would be 10 spaces for the Revised draft Croydon Local Plan Policy DM30 Table 10.1 and 13.5 ≈14 spaces for the adopted London Plan Policy T6.1 Table 10.3 when only 7 are provided. This is a 42.86% deficiency for the Revised Draft Croydon Plan and a 92.86% deficiency for the London Plan Policy.
The accessibility into and exit from each parking bay, with all other bays occupied should be proven by production of swept path illustration to ensure the safety and manoeuvrability is acceptable.
Taking all the foregoing assessments and evidence when considered in total, the whole assessment would combine to provide sufficient proof of overdevelopment for the Setting and the Site, which exceed Site Capacity for 0.102ha at this Setting and locality.

Permission Refused

Reason(s) for refusal :-

The proposed development, by reason of scale, massing, poor elevational
composition, materials and detailing would result in an unsightly, dominant and imposing form of development which would fail to integrate successfully in townscape terms or make a positive contribution to the setting of the local character and immediate surroundings contrary to Policies D4, D8 of the London Plan (2021) and SP2, SP4, DM10 of the Croydon Local Plan (2018) and the Council’s Supplementary Planning Document Suburban Design Guide (SDG) 2019.
The proposal by reason of its massing and proximity close to neighbouring properties at nos. 44 and nos. 48 The Glade would result in an intrusive and imposing form of development detrimental in terms of outlook for these surrounding neighbours and would be contrary to policy DM10 of the Croydon Local Plan (2018), Policies D3 and D6 of the London Plan (2021) and the Council’s Supplementary Planning Document Suburban Design Guide (SDG) 2019.
The proposed development would provide inadequate provision for on-site car parking and would provide poorly accessed, located and amount of cycle and refuse storage facilities and would therefore be contrary to Policies DM10.2, DM13, DM29 and DM30 of the Croydon Local Plan (2018) and Policies T4, T5 and T6 of the London Plan (2021).
In the absence of a legal agreement, the application does not offer a contribution towards sustainable transport initiatives in the vicinity to alleviate traffic generation created by the development, the proposal would be contrary to Policies SP8 and DM29 of the Croydon Local Plan (2018) and Policy T4 of the London Plan (2021).

MORA Submission: 13^th Dec 2021
Consultation Closes: 23^rd Dec 2021
Target Decision: 11^th Jan 2022
• Total Consulted: 14
• Objections: 12
• Supporting: 0
Councillor referral: Councillor Sue Bennett (21^st Dec 2021)
Permission Refused: 3^rd Feb 2022
Appeal Notice: 23^rd Mar 2021

Further developments are in the May 2022 Planning Report.

81 The Glade – Ref: APP/L5240/W/21/3286648
Demolition of existing dwelling and erection of a 4 storey building comprising 9 flats with associated landscaping and amenity space, and relocation of vehicular crossover.

Flyer for download and social media sharing.

Suggested Reasons for refusal:

4 storeys total with accommodation in the roof-space.
No Lift.
Over-Development Residential Density at close on 379.08hr/ha; for Public Transport Accessibility Level (PTAL) at 1a;
Over-Development Housing Density at close on 117.65units/ha at PTAL 1a;
No improvement to supporting infrastructure.
No forecast improvement to Public Transport Accessibility.
Bed Spaces for 30 new occupants and only 7 car parking spaces;
Inadequate Play Spaces for Children
Overbearing of adjacent properties.
Does not respect the character of the Area.

We objected to the proposed development on the grounds that:

The proposed development ‘exceeds’ the “Number of New Homes” for this site at Option 1 by ≈1 dwelling. The proposed development therefore ‘exceeds’ the “Number of New Homes” for this site at the ‘Preferred Option 2’ by ≈5 dwellings.
Based upon the LPA’s own evidence, this proposal is an over development for this ‘typology’ and suburban setting locality based upon the ‘Small Site Evidence Assessment’ for the Local Plan Review. The Residential and Housing Density for this proposal is the ‘maximum possible’ crammed into the Site Area only limited by the need to meet the London Plan Policies on Minimal Internal Accommodation Space Standards.
The reason is assumed to maximise profit, ignoring the local character etc.
A 4-storey (Three Storey with accommodation in the Roof-space) building on a site area of 0.0765ha significantly exceeds ‘Gradual Densification’ or ‘Limited Growth’ for the area and, for the preferred option, it is nearly double the Option 2 “Number of dwellings expected” with Density uplift of 104,58u/ha for this locality which is tantamount to “Focussed Intensification” for the available site area.
Windfall redevelopments in the Shirley North Ward can only be commensurate to “Limited Future Growth” assumed “gradual, moderate incremental densification” as there is no planned improvement in supporting infrastructure to support unrestricted ‘intensification’ i.e., equivalent to “guided” or “Focussed Intensification”
There is no quantifiable definition of “gentle Densification” or “Gradual, Moderate Incremental Densification”. Thus, all these Policies are subjective, vague and inadequately defined for professional assessment. The assessment is at the subjective whim of the case officer. Para 6.66 promotes building height of 3 Storeys whereas this proposed development is 3 storeys plus accommodation in the roof-space.
This proposal is NOT ‘Gradual Gentle Densification’ when there is no planned increase in supporting Public Transport infrastructure for sustainable development at this location for the foreseeable future.
The interpretation of ‘Minor Developments’ Para 3.2.4 for this application, where there is ‘no probability of improvement to Public Transport Accessibility’ over the Life of the Plan and NO LPA “Infrastructure Delivery Plan” for the Shirley North Ward is that the incremental impacts of minor developments should be mitigated by ensuring a much gentler densification of gradual, moderate incremental densification for this locality.
The proposed development does NOT meet the requirement of Policy D2 Para A, B & or C. The proposal does not consider existing or future planned levels of infrastructure for minor developments and as there are NO ‘infrastructure delivery plans or programs for the Shirley North Ward we can conclude that cumulative minor developments would require additional supporting infrastructure to be available for sustainable developments in the Ward (as defined by para 3.2.4).
We challenge the viability of this proposed development as it is NOT acceptable in terms of use, scale and massing given the surrounding built form as defined in London Plan Policy D2 para-C.
The Croydon LPA has NO published ‘Infrastructure Delivery Plan’ or program for the Shirley North Ward to improve Bus or Tram Public Transport Infrastructure for the residents of Shirley North Ward over the life of the plan. In fact, Shirley is not even mentioned in any of the 143-pages of the ‘Infrastructure Delivery Report’.
We have had NO improvement in local infrastructure to support any of the year-on-year cumulative developments and NO visible Community Infrastructure Levy (CIL) contribution has been spent in our area. We have NO knowledge of an ‘Infrastructure Delivery Program’ for our area and NO proposed improvement to Public Transport Accessibility.
The proposed development could NOT be considered of ‘limited’ growth “within the broad parameters of the existing local character reflected in the form of surrounding buildings and street scene” or, for the site area and local character assessment as required by the vague and subjective Policies D2 & D3 ‘Design-Led-Approach’ of the New London Plan.
Therefore, we would seriously suggest that this development proposal’s Residential and Housing Density is significantly too high and inappropriate for the locality and if the case officer is minded to recommend approval of this application in defiance of this ‘overwhelming foregoing evidence’, we would expect a stated justification of how this assessment is derived and that a significant Community Infrastructure Levy (CIL) contribution from the developer is required in order to fund actual ‘significant improvements’ to local Public Transport Accessibility for this high level of Residential Density for an appropriate and actual recognisable improvement in public transport accessibility in The Glade, as required by the Policy.
SPD2 paras 2.6.1 & 2.6.2 recognises increased demand on Public Transport but it is also recognised that this will NOT be forthcoming over the life of the Plan. This will result in occupants making more use of car journeys than otherwise and is detrimental to the Policies of reducing car usage and effects on climate change.
The proposal does NOT reflect the character of the area with regard to Massing or Density, and does NOT reflect the Borough Character Appraisal for the “Shirley Place”.
The proposal does NOT closely relate to the existing surrounding typologies by pursuing a similar density, massing, style, materials and detailing and is therefore not acceptable.
There is No Daylight Study Report to investigate overbearing nature of the proposal on the adjacent property at 83 The Glade and there is no surface water drainage proposal or report on surface water SuDS management.
The height of three storeys, plus accommodation in the roof-space (4-Storeys), of the proposed development will, by its positioning, significantly shield and cast a shadow over the southern aspect and most of the garden of 83 The Glade. The proposed development would undoubtedly appear overbearing to the neighbouring property at 83 The Glade and therefore should not be supported.
The Rear East Facing Elevation of the proposed development and the adjacent property at 83 The Glade shows overbearing and unreasonable impact on neighbours’ amenity and the failure of the development to meet the 45° (vertical) Policy defined in SPD2 Section 2.11 and image 2.11c.
SPD2 recommends that in areas of semi-detached homes in a planned estate, that proposals should not exceed 3 storeys, and that the 3rd storey should be partially concealed within the roof form which, for gentle densification, would be considered a maximum and more appropriate for this location.
The estimated number of children of occupants of the development could be a maximum of 12 which would require a play space allocation of 120m2, to comply with London Plan Policy S4, a deficiency of 16.5m2 – 120m2 = 103.5m2.
This Proposed Development does NOT comply with Policy DM10.4 d). and should be refused.
For this proposed development the number of bays, including disabled bay, = 7 (which is an availability of 0.233 per person), so the proposal is deficient by 6.5 bays, rounded ≡ 7 bays (which is ≈50% below the Policy allocation).
There is no mention of any electric charging points or provision of infrastructure for electric or Ultra-Low Emission vehicles. 20% of 7 = 1.4 rounded = 2 should at least be equipped with such infrastructure.
There are no swept path illustrations to ensure vehicles can enter any parking Bay, with minimum manoeuvres, when all other Bays are full and exit in a forward gear onto The Glade, also when all other bays are full again with minimum manoeuvres.

MORA Objection Sent: 28^th Jan 2021
Consultation Closes: 7^th Feb 2021
Target Decision: 8^th Mar 2021
• Total Consulted: 8
• Objections: 28
• Supporting: 1
Councillor referral: Councillor Sue Bennett (8^th Feb 2021)
Planning Committee Meeting: 21^st Oct 2021
Permission Refused: 21^st Oct 2021
Appeal Notice: 11^th Nov 2021
Appeal Representations: 5^th Apr 2022
MORA Appeal Submission: 30^th Mar 2022

Further developments are in the May 2022 Planning Report.

211 Wickham Road – Ref: APP/L5240/W/21/3279454
Demolition of the existing outbuildings to the rear of the shop and erection of a two storey building containing four flats, with car parking and other associated alterations.

We do not fundamentally object to this proposed development at this location as its character blends well with the surrounding existing properties.

However, there are still areas of concern on access that need to be resolved prior to a decision which could be the subject of amendments or conditions for acceptability.

Accepting that the vehicles are parked as shown on the plans provided, in a forward direction, and that the Access Drive is ≈4.7m wide, it is still unclear how each would park in a forward direction and then exit from the parking bay (if all other Bays were occupied) and then exit the driveway across the footpath safely with adequate sight lines, in a forward gear.

It is suggested that proper full effective swept path illustrations for entrance and exit to/from each parking bay, with all other bays occupied and avoiding any collision with the boundary fencing, be provided for a family sized car of nominal dimensions and wheelbase, to the case officer for examination prior to a decision being made as these vehicle movements would apply for the life of the development.

SPD2 Chapter 2 Suburban Residential Developments Section 2.29.4
“Entrances should avoid tall wall or wooden fences either side of a new driveway that close off the development to the street.”

It is noted that the ≈1.8m Close Boarded fencing on the side boundary of 2 Ridgemount Avenue precludes any visibility splay of the footpath to the north when exiting the new access driveway for the proposed car parking bays into Ridgemount Avenue. It may be possible for the applicant to negotiate a reduction in height of the first fence panel, to less than 0.6m high at the entrance to the side passage to allow safe sight lines to be available for safe exiting from the new parking spaces.

Permission Refused

Reason(s) for refusal :-

The proposed development would fail to offer suitable living conditions for future residents due to single aspect outlook for the flats on the upper floors and poor quality garden layouts for the ground floor flats. The development would therefore conflict with Policy DM10 of the Croydon Local Plan (2018) and the Suburban Design Guide (2019).
The proposed development would by way of its excessive scale and close proximity to neighbouring windows, which serve habitable rooms, cause harm to neighbouring living conditions through the creation of a sense of enclosure and loss of outlook. The development would therefore conflict with Policy DM10 of the Croydon Local Plan (2018) and the Suburban Design Guide (2019).
The proposed off street car parking arrangements would harm pedestrian and highway safety due to the need for drivers to reverse onto the road and the lack of visibility splays. The development would also result in the loss of on street parking bays creating additional and unacceptable on street parking pressures. The proposal would therefore conflict with Croydon Local Plan (2018) policies SP8, DM29 and DM30.
The balconies to the front elevation of the development would appear out of keeping with the character and appearance of the area and the proposed building design. The development would therefore conflict with Policy DM10 of the Croydon Local Plan (2018) and the Suburban Design Guide (2019) and policies DM1, DM3 and DM4 of the London Plan 2021.

MORA Submission: 3^rd Mar 2021
Consultation Closes: 26^th Mar 2021
Target Decision: 14^th Apr 2021
• Total Consulted: 28
• Objections: 1
• Supporting: 0
Permission Refused: 14^th Apr 2021
Appeal Notice: 21^st Jul 2021
Appeal Representations: 23^rd Feb 2022
MORA Appeal Submission: 18^th Feb 2022

Further developments are in the May 2022 Planning Report.

176 – 178 Orchard Way – Ref: APP/L5240/W/21/3281590
Demolition of existing dwellings, erection of three pairs of two storey 3-bed semi-detached dwellings with roof accommodation and one pair of two storey 2-bed semi-detached dwellings with car parking, formation of accesses onto Sloane Walk together with a new pavement, and provision of cycle, refuse and recycling stores and soft landscaping.

Para 4.2.4 of the New London Plan defines the “Incremental intensification” criteria for existing suburban residential areas which are required to be within PTALs 3-6 or within 800m distance of a train or tram station or within 800m of town centre boundary (interpreted as an equivalent to a District Centre – (NOT a Local Centre as defined in the Croydon Local Plan).

The location at 176-178 Orchard Way is assumed to be PTAL 1a (as 176 is PTAL 0 & 178 is PTAL 1b) and the development site falls outside of the 800m limits of these defined requirements, and as such, the locality of this site is therefore inappropriate for “Incremental intensification”.

The ground floor plan and site layout (Drawing PL-04) show that Units 5, 6, 7 & 8 are remarkably close to the new public footpath and the south facing ground floor windows are set at eye level allowing passers-by on the new public footpath to have unobstructed views directly into the ground floor living accommodation of these units. This is unacceptably close for future occupants of this proposed development.

The access to the rear of Plot 5 is shared with Plot 4 and the Bin store for Plot 5 will need the Refuse Bins to be dragged via this route on refuse collection days. There is no specific position for these Refuse Bins (nominally three per property) to be left at the front of the properties which should NOT be on the public footpath (probably in one of the parking bays). There would need to be Refuse Bins for Units 4 & 5 within the front curtilage of Unit 4. This is unacceptable for future occupants of this proposed development.

Similarly for Plots 6 & 7. The Refuse Bins for Plots 6 & 7 need to be dragged from their respective Bin Stores via the shared access path to the front of the properties, but again have no reasonable allocated space for the bins to be positioned awaiting refuse collection. This is unacceptable for future occupants of this proposed development.

The application documentation gives no details of the proposed new Pavement or its specification, whether it provides drop kerbs or any drainage channels (CD 239 Rev1) and where and if draining channels are connected to the Main Drains. Also, if the new pavement is within the curtilage of the new development, who owns and maintains it and is public access allowed? It also needs to be confirmed that provision of the new Pavement will not reduce the Road Width of the existing Sloane Walk public highway.

Strategic Option 2 Map – Bungalows with a medium sized garden – within 800m has an estimated Participations Rate of 1% and beyond 800m is 0.5%. Or Low Density Scattered Housing on medium sized Plots – within 800m has an estimated Participations Rate of 1% and beyond 800m has Participations Rate of 0.5%

It is understood Option 2 is the preferred Option for the Local Plan Review.
Thus, for this proposed development:
Number of expected new homes [18] ≈ PR (0.5%) x Uplift in Housing Density (u/ha) x Area (ha) ≈ 0.5(%) x (42.54u/ha) x (0.14 ha) ≈ 2.9778 units
Thus, Number of new homes (for this site with this local character) is expected at ≈3 units. Whereas the proposal is for 8 Units.

The proposal meets most accommodation standards as defined by the New London Plan (2021) except that the proposal does NOT appear to provide any detail of ‘In-Built’ Storage capacities that are appropriate for the storage of the normal living clutter requirements for future occupants as defined in the New London Plan (2021) Table 3.1.

These are ‘minimum’ Accommodation space standards requirements which the London Plan further recommends that “these minimum standards should be exceeded if at all possible”, in development proposals. It is unacceptable that this detail is NOT submitted in the application documentation.

Units 1, 2, 3 & 4 Parking Bays are on the forecourts of the proposed development configured north/south. If a vehicle enters in a forward gear, exit MUST be in a reverse gear giving the driver extremely limited vision to ensure public using the footpath are not inconvenienced or placed in any danger. Units 2 & 3 have trees restricting the visibility of the driver when exiting in a reverse gear. Any future planting could further reduce visibility splays. See DM30 para b) & c).

Unit 5 Parking has been accommodated by reconfiguring the curtilage of Unit 4 front forecourt to enable a parking provision for Unit 5. This provides evidence that the site capacity is inadequate for the number of units as the plots are not fully self-contained. Unless a physical boundary is visible this arrangement will seem unacceptable to observers and future occupants.

Unit 6 parking bays are staggered such that the first parked vehicle is blocked in by the second subsequently parked vehicle. This will mean that for the first parked vehicle to exit requires the second parked vehicle to previously exit to allow the first parked vehicle to then exit. This manoeuvre would create local confusion and possibly be hazardous to other road users. It may also be the cause of potential conflict if any individual needs use of their blocked vehicle in an emergency. See DM30 para b) & c).

It is not specified if any parking provision is to be equipped with Electric Charging capability or that dropped kerbs are to be provided for each access. In summary, the parking provision has been squeezed in as an after-thought and has not been fully integrated into the design proposal.

The car parking provision has not been considered at the outset of the development and has not been fully integrated in the design (Policy DM30 para 10.43). This is further evidence of over-development of the site as these parking arrangements are NOT consistent.

A minimum of 2 Cycle Storage spaces is required for each new dwelling. Presumably, Units 1 to 5 are provided within the Sheds which could accommodate the two cycles per dwelling (if they are NOT Garden Sheds). Units 6, 7 & 8 have external Cycle Stands which the illustration shows as one cycle per dwelling in the forecourt of Unit 8, which could be construed as within the curtilage of Unit 8, which is inadequate and in an unacceptable location.

Permission Refused

Reason(s) for Refusal:-

The development would be detrimental to the visual amenity of the site and street scene by reason of the excessive amount of forecourt parking across the site and would thereby conflict with Policies D3 and D4 of the London Plan 2021 and Policies SP4.1, SP4.2, DM10.2, DM10.8 of the Croydon Local Plan 2018, and Croydon’s Suburban Design Guide Supplementary Planning Document 2019.
The design of houses numbered 7 and 8 on the submitted drawings would be out of character with the site and surroundings and would not maximise the opportunities for creating an attractive and interesting environment by reason of the poor siting and massing of the front outriggers. It would thereby conflict with Policies D3 and D4 of the London Plan 2021 and Policies SP4.1, SP4.2, DM10.1, and DM10.7 of the Croydon Local Plan 2018, and Croydon’s Suburban Design Guide Supplementary Planning Document 2019.
The development would be detrimental to the amenities of the occupiers of residential occupiers in Sloane Walk by reason of its siting and layout resulting in loss of privacy. It would thereby conflict with Policies D3 and D4 of the London Plan 2021 and Policies SP4.2 and DM10.6 of the Croydon Local Plan 2018, and Croydon’s Suburban Design Guide Supplementary Planning Document 2019.
The development could result in local traffic congestion/additional local parking stress by reason of loss of on-street parking provision in Sloane Walk. It would thereby conflict with Policies T4, T6, and T6.1 of the London Plan 2021 and Policies SP8.3, DM29 and DM30 of the Croydon Local Plan 2018.
The position of the vehicle access to house numbered 1 on the submitted drawings would not be safe, secure or efficient and would thereby conflict with Policy T4 of the London Plan 2021 and Policies DM29 and DM30 of the Croydon Local Plan 2018.
In the absence of a legal agreement, the application does not offer a contribution towards sustainable transport initiatives in the vicinity to alleviate traffic generation created by the development. The development would thereby conflict with Policies T4, T5, T6, T6.1, and T9 of the London Plan 2021 and Policies DM29 and DM30 of the Croydon Local Plan 2018.
The siting and layout of the development could result in the loss of or the putting at risk of valued trees, including trees subject to a Tree Preservation Order, and has not demonstrated a net biodiversity gain and would thereby conflict with Policies G6 and G7 of the London Plan 2021 and Policies DM10.8, SP7, DM27 and DM28 of the Croydon Local Plan 2018.8 The development could result in the putting at risk of a protected species and would thereby conflict with Policy G6 of the London Plan 2021 and Policies DM10.8, SP7.4 and DM27 of the Croydon Local Plan 2018.
The development fails to demonstrate how it would ensure the safety of all buildings users in relation to fire, thereby conflicting with Policy D12 of the London Plan 2021.

MORA Submission: 29^th Apr 2021
Consultation Closes: 15^th May 2021
Target Decision: 25^th May 2021
• Total Consulted: 105
• Objections: 44
• Supporting: 0
Councillor referral: Councillor Richard Chatterjee (26^th May 2021)
Permission Refused: 14^th Jul 2021
Appeal Notice: 24^th Aug 2021
Appeal Representations: 28^th Feb 2022
MORA Appeal Submission: 4^th Feb 2022

Further developments are in the May 2022 Planning Report.

Additional Matters

Croydon Draft Revised Local Plan – Latest News

The Regulation 19 Consultation has now closed. The council received over 800 responses which are now being reviewed.

The next steps are to publish the responses and submit the draft Review of the Local Plan to the Secretary of State for Examination in Public.

It is currently anticipated that submission will not be made before early June 2022.

You can view our representation forms below:

Form #01 (SP1.0A)	Form #02 (SP1.0A para c)	Form #03 (SP1.0A para e)	Form #04 (SP1.0 C)	Form #05 (Policy SP2.2)	Form #06 (DM1A.1)
Form #07 (DM2A.3 para d)	Form #08 (Para 5.19)	Form #09 (DM10.1)	Form #10 (DM10.1 a-h)	Form #11 (DM10.11 a-e)	Form #12 (DM10.11b)
Form #13 (Policy DM11c)	Form #14 (Policy DM10.11d)	Form #15 (Para 11.197A)	Form #16 (Policy 6.62b-e)	Form #17 (Policy SP4.16)	Form #18 (SP3.2)
Form #19 (Para 62 f-k)	Form #20 (Para 4.14)	Form #21 (SP1.0A a, b & c)

Further developments are in the May 2022 Planning Report.

London Plan Supplementary Planning Guidance Consultation

There are an additional two consultations on the London Plan Supplementary Planning Guidance.

The draft Design and Characterisation guidance is a suite of documents that provides guidance on design and urban characterisation in London. It aims to ensure that land is being used in the best way to deliver the right quantity of new housing, at the right quality, in the right place, embedding high-quality design at the centre of housing delivery.

The first five Documents are relating to “Design and Characterisation Guidance”

Characterisation and growth strategy LPG – Publish for consultation.pdf (4.14 MB) (pdf) provides guidance to local planning authorities and neighbourhood planning groups on carrying out a characterisation assessment for their borough or neighbourhood. This assessment should be used to inform an areas capacity for change and growth. This includes identifying if there are locations where tall buildings may be appropriate.
Optimising site capacity – A design-led approach – Publish for consultation.pdf (4.09 MB) (pdf) provide guidance on the London Plan’s design-led approach to optimising site capacity. This involves the setting of design parameters and establishing an indicative site capacity for residential sites.
Small site design codes LPG – Publish for consultation.pdf (8.07 MB) (pdf) provides guidance to local planning authorities and neighbourhood planning groups on preparing area-wide housing design codes for a range of ‘character types’. This includes the development of a coding plan and a design code for each character type to increase housing supply from small sites. The guidance also provide four example small site design codes.
Housing Design Standards LPG – Publish for consultation.pdf (655 KB) (pdf) presents a set of housing design standards for use when designing or assessing new housing.
Design and Characterisation LPGs.pdf (449 KB) (pdf)

What has happened so far
The four guidance documents above have been developed out of the ‘Good Quality Homes for All Londoners’ guidance that went out for a public consultation between 13 October 2020 and 15 January 2021 (13 weeks). The consultation summary report for this consultation can be viewed in the document library. Following this consultation, the documents (previously called Modules) have been revised to each become a separate London Plan Guidance (LPG) document. As a result, Module A of the Good Quality Homes for All Londoners guidance has been split into two documents, the Characterisation and Growth Strategy LPG and Optimising Site Capacity: A Design-led Approach LPG.

The consultation has now closed.

What happens next
All feedback will be reviewed and a consultation summary document will be published alongside the final guidance – this is likely to be autumn/winter 2022.

You can view our representation submissions below:
Characterisation and Growth Strategy
Optimising Site Capacity
Small Site Design Codes
Housing Design Standards

DEREK RITSON
MORA Planning