Planning Report – April 2023

Applications

Decided
Awaiting Decision
Appeals Pending

Additional Matters


Applications

Decided

34 Woodmere Avenue – Ref: APP/L5240/W/22/3305588
Demolition of the existing property and the erection of two blocks of terraced houses, two storey buildings with accommodation in the roof space for three of the units, comprising of a total of four dwellings with six off street car parking spaces.

We objected to the proposed development on the grounds that:

  • The only non-compliance is Apartment 4 In-Built Storage capacity offered at 1.9sq.m. when the London Plan Policy D6 Table 3.1 requires 2.5 sq.m. for a 3b4p Unit. The additional Storage on the second floor is not stated as it is understood has insufficient height to be considered. All other Units meet the minimum Space Standards.
  • The Floor Plans for Apartment 1 indicate a GIA of 84.6m2 whereas the Design and Access Statement Document 4385027 indicates Apartment 1 GIA of 86.6m2
  • The Floor Area Ratio at 0.55 is slightly higher than the <0.5 required of the National Model Design Guide recommendation for Suburban Area Type Settings.
  • There is a significant issue regarding Parking relating to bays #1 and #6 being blocked by vehicles parked in Bays #3 and #5.
  • The requirement to enter and park on the private Driveway of #5 Pipers Gardens when exiting bays #1, #2 or #3 is totally unacceptable.
  • There would be additional difficulties, if any other vehicle were parked outside Nos 1 to 3 Pipers Gardens to exit from bay #5 or #6.
  • The Design Guide Residential Density has been reduced from Urban to within range of a Suburban Area Type Setting although would require a PTAL of 2.24 appropriate for a residential Density of 224.72 bedspaces/ha, or for a PTAL of 3.93 for a Residential Density of 280.90 hr/ha, when the available PTAL is only 1a.
  • The plans indicate that pedestrian access is directly in front of the four Dwellings with absolutely no privacy from the kitchen windows. Passers-by could quite easily peer into the kitchen accommodation from the footpath. This is an unacceptable invasion of privacy.
  • The pedestrian access from Woodmere Avenue is NOT within the scope of this proposal as it is outside the boundary of the proposal. However, there are reasonable questions on the viability of this access as the area has undefined responsibility. The previous owner of 34 Woodmere Avenue undertook responsibility for its upkeep as it was the only access to the dwelling and was the reason for its designation as 34 Woodmere Avenue and not no. 6 Pipers Gardens.
  • This pedestrian access could become a public footpath if the Council obtained ownership but the Land Registry needs to confirm whether the area is retained as 34 Woodmere Avenue or passed to the developer as part of the transaction to purchase the land from the previous owner of 34 Woodmere Avenue. This is not explained in the supplied documents of the Certification B on the Application Form.
  • There is a strip of land between the kerbstones on the East side of Pipers Gardens fronting the development Site but outside the Site Boundary. Ownership of this strip of land is of significance as if not part of the development area, and owned by a third party, the strip would preclude any access to the site from Pipers Gardens. These issues may be “Civil”
    and not Planning matters but the access to the development site is a condition of feasibility of development.
  • At only 1.2m the proposed pavement falls short of this ‘absolute minimum.’ This is particularly relevant for the existing residents of Pipers Gardens, who are more likely to require walking aids or wheelchairs. But also, for the proposed new houses that are likely to attract families with young children who will also require access for pushchairs, or for parents to walk side-by-side with their children. This would not be possible in Pipers Gardens as there is no existing or proposed pavement that provides a continuous, uninterrupted footway between the dwellings in Pipers Gardens and Woodmere Avenue. The footpath width should be a minimum of 1.5m for the safe passage of all pedestrians or any wheelchairs uses from the Dwellings in Pipers Gardens.

Appeal submitted in respect of the Council’s failure to determine planning application reference 22/01806/FUL relating to 34 Woodmere Avenue, Croydon.

MORA Submission: 16th Jun 2021
MORA Addendum: 20th Jun 2021
Consultation Closes: 24th Jun 2022
Target Decision: 24th Jul 2022
• Total Consulted: 18
• Objections: 11
• Supporting: 0
Councillor referral: Councillor Sue Bennett (23rd Jun 2022)
Appeal Notice: 23rd Aug 2022
MORA Appeal Submission: 30th Jan 2023
Appeal Dismissed: 21st Apr 2023

Further developments are in the May 2023 Planning Report.

Hanbury Mews – Ref: APP/L5240/W/22/3307138
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 :-

  1. 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.
  2. 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.
  3. 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: 27th Jan 2022
Consultation Closes: 29th Jan 2022
Target Decision: 17th Feb 2022
• Total Consulted: 23
• Objections: 2
• Supporting: 0
Permission Refused: 17th Mar 2022
Appeal Notice: 16th Sep 2022
MORA Appeal Submission: 9th Jan 2023
Appeal Dismissed: 11th Apr 2023

Further developments are in the May 2023 Planning Report.

116 Orchard Way – Ref: 23/00569/FUL
Change of use of the public house on ground floor to create 2 flats, with associated site alterations and integral cycle and waste storage.

We objected to the proposed development on the grounds that:

  • The proposal would result in the loss of a Public House in a residential environment where there a few local amenities. However, the applicant has made appropriate efforts to retain the Pub, but it has shown it to be unviable in the current economic climate. It is therefore presumed that a change of use could resolve the viability and create accommodation to help meet housing need.
  • Nevertheless, any conversion to residential use requires the proposed changes meet all necessary National and Local Planning Policies for acceptable accommodation for future residents which we have shown to be unacceptable.
  • The number of bedspaces does not meet the requirements of the London Plan Policy D6 Housing quality and standards as shown in our submission. The accommodation as indicated can only provide bedspaces for 8 persons and not the 10 persons as detailed in the Design & Access Statement para 7.4. Therefore, unless the accommodation is revised to meet the guidance of Policy D6, this proposal should be refused.
  • The level of supporting infrastructure would not support the proposed increases in Density as shown in our submission which for illustration would require a PTAL to be at a level of 7.72 from the available PTAL of 1a ≡ 0.66
  • We recommend that this proposal is refused and that the applicant revises the application to be more appropriate for the local Area Type Setting of Outer Suburban within the limits of local “Gentle” densification.
  • There is inadequate off-street parking provision.
  • The proposal could possibly accommodate 5 children for which there is inadequate Play Space.

Permission Refused

Reason(s) for refusal :-

  1. The proposed design of the development would fail to offer suitable outlook from or natural light to the new homes, resulting in poor quality living conditions. The application therefore conflicts with Croydon Local Plan (2018) Policy DM10 and London Plan (2021) Policy D6.
  2. The proposed terraces by way of their poor design would be excessively enclosed and one of the areas would lack privacy due to its position. This would fail to provide suitable living conditions for future occupiers. The application therefore conflicts with Croydon Local Plan (2018) Policy DM10 and London Plan (2021) Policy D6.
  3. The proposed design of the development would not be accessible for all Londoners. The application therefore conflicts with London Plan (2021) Policy D7.
  4. In the absence of a car parking survey for surrounding roads the Council is unconvinced that the proposal would not have an unacceptable impact upon on street car parking availability, which could have negative highway safety implications. The proposal therefore conflicts with Policy T6 of the London Plan (2021) and Croydon Local Plan (2018) Policies SP6, DM29 and DM30.

MORA Submission: 17th Mar 2023
Consultation Closes: 23rd Mar 2023
Target Decision: 7th Apr 2023
• Total Consulted: 41
• Objections: 5
• Supporting: 1
Councillor referral: Councillor Richard Chatterjee (24th Mar 2023)
Permission Refused: 5th Apr 2023

Further developments are in the January 2024 Planning Report.

46 The Glade – Ref: 22/05049/FUL
Demolition of existing property and construction of 2 no. 3 bedroom houses and 2 no. 2 bedroom houses with parking spaces.

We objected to the proposed development on the grounds that:

  • This development proposal is an improvement on the previous proposals for this Site to reflect the Hipped Roof forms prevalent in the neighbourhood and thus relieving the 45 Degree Rule amenity to adjacent dwellings; in doing so this has reduced the two end terraces to two stories and thus reduced the residential density and occupancy ratio of the development.
  • However, the proposed development remains to be an over development for the Site Area Type of <Outer Suburban and would be more appropriate for an Area Type Outer Suburban for Housing Density and for an Area Type Urban for Residential Density.
  • The increase required would not be supported by the existing infrastructure which is currently adequate for Area Type <Outer Suburban as established by the assessment of the Post Code CR0 7QD Area Type Design Code, nor would the Public Transport Accessibility required to support the Residential Density of 2.79 be achieved as the PTAL for this locality is Zero and there is no prospect of improvement over the life of the Plan.
  • The minimum Internal Space Standards required of the London Plan Table 3.1 are not met in terms of In-Built Storage.
  • Consequently, the proposed development fails to meet the Design Code of the locality as defined by the National Model Design Code & Guidance and would result in a harmful effect on the character and appearance of the area. As such, in this respect, it would be contrary to the NPPF Design Codes, the London Plan Policies on Design and the Croydon Plan Policies SP4 and DM10. Together these Policies seek to achieve high quality design which respects local character.

Permission Refused

Reason(s) for refusal :-

  1. The proposed development, by reason of scale, massing, 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 H2, D4, D8 of the London Plan (2021) and SP2, SP4, DM10 of the Croydon Local Plan (2018).
  2. 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)
  3. The proposed development would provide poor vehicle access, poorly accessed and designed cycle facilities and would therefore be contrary to Policies DM10.2, DM29 and DM30 of the Croydon Local Plan (2018) and Policies T4, T5 of the London Plan (2021).
  4. 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: 28th Feb 2023
Consultation Closes: 8th Mar 2023
Target Decision: 31st Mar 2023
• Total Consulted: 12
• Objections: 4
• Supporting: 0
Permission Refused: 30th Mar 2023

Further developments are in the May 2023 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: 31st Aug 2021
Consultation Closes: 8th Sep 2021
Target Decision: 28th Sep 2021
• Total Consulted: 10
• Objections: 32
• Supporting: 0
Case Officer Report recommends: Grant Approval
Planning Committee Slot: 9th Mar 2023
Permission Refused: 9th Mar 2023

Further developments are in the October 2023 Planning Report.

Awaiting Decision

179 The Glade – Ref: 23/00579/FUL
Change of use from single residential dwellinghouse (C3) to HMO (C4)

We objected to the proposed development on the grounds that:

  • The parking arrangements are unsatisfactory as there is no possible method of exit without requiring a number of cars to be moved to allow any movement of another vehicle. This parking arrangement is totally unacceptable.
  • The Plans do not show whether the Shower rooms have WC’s. The London Plan Housing Design Standards require two or more WCs for all dwellings with five or more Bedspaces. The proposal meets this requirement, but one is presumed within the bathroom shared by all occupants.
  • The Application Form at “Description of Proposal” requests:
    i. Has the Works or Change of Use already Started? Answer Yes.
    ii. Has the Work or Change of Use been completed? Answer Yes.
    Therefore, should this application be for “Retrospective” Planning Application rather than for Planning permission, or is it Change of Use with NO structural alterations which is already occupied by tenants and as such is already an HMO.
  • There is a significant difference between the Residential Density of the local Post Code Area at 59.79 bs/ha to the proposed application at 157.92 bs/ha which changes the required Area Type from Outer Suburban, through Suburban to an Urban Area Type Setting Design Code.
  • In addition, the proposal would require a supporting TfL PTAL of 2.81 when the locality has TfL PTAL of just 1b ≡ 1.33 which is forecast to remain at 1b until 2031.
  • It is recognised that conversion of dwellings (C3) to a House of Multiple Occupation (C4) provides much needed accommodation for youngsters starting out in their working lives. These conversions are therefore a source of housing supply which can help to fill that need. However, there are policies to ensure the accommodation is suitable which we have tried to adequately capture in our submission to assist the assessment by the Case Officer.
  • There is also a critical balance required when assessing a proposal for conversion of family dwellings from C3 to C4 HMO usage on the affects and relationship with adjoining neighbours and the locality generally, to ensure continued neighbourly cohesion and to ensure the neighbourhood does not degenerate toward deprivation.
  • Resulting on our detailed assessment, we hold the view that this proposal is a loss of a family dwelling and as a result of an assumed occupancy of 8 (possibly 9 persons (bedspaces), provides inadequate facilities for the possible number of future occupants and therefore the proposal as offered should be refused.

MORA Submission: 16th Mar 2023
Consultation Closes: 30th Mar 2023
Target Decision: 19th Apr 2023
• Total Consulted: 24
• Objections: 2
• Supporting: 0
Councillor referral: Councillor Richard Chatterjee (21st Mar 2023)

Further developments are in the May 2023 Planning Report.

159 – 161 The Glade – Ref: 23/00594/FUL
The proposal is to demolish two existing bungalows and associated garages to create a combined site of 950 sqm which is remodelled to deliver 5 family homes with associated parking. The dwellings consist of four semi detached properties facing The Glade and one detached property on Brookside Way. All family homes have rear gardens and cycle storage. Two additional cycle storage spaces are proposed for visitor parking.

We objected to the proposed development on the grounds that:

  • There is inadequate In-Built Storage capacity to meet the London Plan Policy H6 Table 3.1 for future occupants for the life of the Development.
  • The proposed building has an ugly appearance, with no character or defined fenestration of window or doors.
  • The assessment of the proposed building Types “A” and “B” falls far short of the “Good Design” principles to reflect and respect the Local Character including attractiveness and the respect of local “Roof-Forms” within the locality. We are of the opinion that the proposal with ‘Gabriel’ or ‘Clipped’ Roof Forms look odd at this location and do NOT comply with the predominantly hipped roof forms of surrounding properties and therefore is non-compliant to the adopted Croydon Local Plan with regard to Policy DM10.7 and should therefore be Refused
  • The proposal exceeds the Area Type Setting Housing Density of Outer Suburban Area Type Setting for the Post Code Area of the locality from 29.27Units/ha to 52.63Units/ha, an increase of 79.81% to a higher density Suburban Area Type Setting.
  • The increase in occupancy as measured in Residential Density terms of bedspaces per hectare increases from 41.46persons/ha to 347.37persons/ha, a 737% increase, which would be more appropriate for a Central Area Type Setting.
  • The Public Transport Accessibility Level (PTAL) available at 161 The Glade would NOT be adequate to support the Residential Density and number of occupants resultant on this proposed development as the Residential Density at 347.37bedspaces/ha is more appropriate to a Central Area Type Setting which would require a supporting PTAL of 7.63.
  • The Refuse & Recycling collection point is on the front forecourt of Unit 1 but there is no Refuse or Recycling Storage located behind the Building Line for each individual dwelling. The proposal is therefore non-compliant to Croydon Plan Policy DM13.1 a) or b).

MORA Submission: 8th Mar 2023
Consultation Closes: 19th Mar 2023
Target Decision: 10th Apr 2023
• Total Consulted: 17
• Objections: 3
• Supporting: 0
Councillor referral: Councillor Richard Chatterjee (24th Mar 2023)

Further developments are in the May 2023 Planning Report.

176 – 178 Orchard Way – Ref: 22/05186/FUL
Demolition of existing dwellings, erection of four pairs of two storey 3-bed semi-detached dwellings with roof accommodation with car parking; formation of accesses onto Sloane Walk together with a new pavement; and provision of cycle, refuse stores and soft landscaping.

We objected to the proposed development on the grounds that:

  • The ‘Accommodation Schedule’ indicates Units 1 to 4 are 3 Bed 5 person and Units 5 to 8 are 3 Bed 6 person, increasing the overall capacity from 22 Bedrooms and 40 bedspaces to 24 bedrooms and 44 bedspaces, thus increasing the Residential Density from 285.71bs/ha previously to 314.29bs/ha. This is an increase in ‘overdevelopment’ to the previous refused proposal.
  • The Building Line and ‘Set-Back’ for this development proposal is established by Units 1 & 2 at the corner ‘return’ from Orchard Way into Sloane Walk which sets the building Line at approximately ≈6m from the new footpath along Sloane Walk.
  • However, Units 5 to 8 are less than <1m from the footpath and therefore do not follow the ‘newly’ established Building Line Set-back from the footpath by Units 1 to 4.
  • Additionally, the Dining Room Windows of Units 5 & 6 and Units 7 & 8 fronting Sloane Walk, would be within approximately <1 metre of pedestrians using the new footpath. This closeness would seriously compromise the privacy of occupants of Units 5 to 8 for the life of the development.
  • Unit 5 Parking allocation in the Schedule of Accommodation has one (1) Parking Bay but this Parking Bay is on the forecourt of Unit 4 which is unacceptable. This means Unit 5’s Parking is probably on land owned by the owner (Titleholder) of Unit 4. This is an extremely irrational and inappropriate arrangement irrespective of the Titleholder relationship and would most definitely cause significant confrontation between the future occupants of Units 4 & 5. This is an extremely inappropriate Parking arrangement and definitely NOT considered “Good Design” principles. This is further evidence of overdevelopment, squeezing the required 12 Parking spaces onto the Site Area which cannot adequately cope with the requirement.
  • As there is minimal set-back, the first floor and Dormer Windows of the proposed development at Plots 5 and 6 serving bedrooms are <18metre line of sight virtually directly horizontally with the bedrooms of 26 & 30 Albany/Belgrave Courts.
  • Therefore, the proposal fails this Privacy and Overlooking London Plan SPG Guidance as the horizontal separation is ≈ 11metres i.e., significantly less than the 18 metres recommended. In addition, Plot 4 although set back from Sloane Walk by ≈6m is 17m which also fails the recommended spacing from the facing habitable (bedroom) of 26 Albany Court.
  • The applicant has not addressed the fundamental reasons for refusals or appeals dismissal of previous similar applications and therefore this new application should be refused for the reasons as set out in this submission.
  • It is recommended that the case officer makes an appropriate indication that the configuration proposed is totally flawed and that any new proposal should completely reassess the appropriate configuration for the site and be within the Site Area Capacity limitation for the Area Type Setting. The proposal is a significant over-development for the Site Capacity and Housing Targets for the locality have been significantly exceeded and therefore Housing “Need” for the locality has already been met.

MORA Submission: 7th Jan 2023
Consultation Closes: 16th Jan 2023
Target Decision: 8th Feb 2023
• Total Consulted: 11
• Objections: 53
• Supporting: 2
Councillor referral: Councillor Richard Chatterjee (17th Jan 2023)

Further developments are in the May 2023 Planning Report.

395 Addiscombe Road – Ref: 21/06387/FUL
Erection of four-storey building to provide 145.7sqm GP Surgery (Use Class E(e)) and nine (9) self-contained flats (following demolition of existing two-storey mixed-use building (Use Classes C3 and E(e)), Associated amenity, cycle storage, vehicle parking and waste storage spaces, and Associated alterations including landscaping and formation of boundary treatments

We objected to the proposed development on the grounds that:

  • This location at the corner of Addiscombe Road and Shirley Road is an important local site en-route as a gateway into the Croydon Centre from Bromley via the busy A232 and as such requires a pleasant architecturally impressive and appealing vista. It is disappointing that the offered proposal does not meet this objective. The proposal is of a dominating character which has a cluttered façade which is unattractive and overbearing, having no relationship to the period of local surrounding building architecture.
  • The proposal exceeds the available Site Capacity of 0.0875ha for the local Area Type at an Outer Suburban or Suburban Setting as defined by the National Model Design Code guidance. There is no equivalent guidance in the Croydon Local Adopted or Revised (Dec 2021) Local Plan or the London Plan for Design Code Guidance and therefore NPPF para 129 is the authority for Design Code Assessment. NPPF at Para 129 gives clear direction that in the absence of Local Design Codes and guidance, the National Model Design Code and Guidance should be used for assessing proposals.
  • The locality of the proposal is NOT in a designated area for Moderate or Focussed intensification as illustrated on the Policies Map. However, our analysis above, using the National Model Design Code & Guidance and an assessment for “Gentle” Intensification and the supporting analysis provides comprehensive evidence of overdevelopment of this proposal at this location indicating the Site Capacity is inadequate to support the development.
  • The proposal fails to meet the MINIMUM space Standards required as there is insufficient Site Capacity for Built-In Storage for any Residential Unit.
  • There is insufficient Play Space for the probable 12 Children of the families occupying the 9 Units or any separate communal open space for the residents.
  • The Vehicular Access for the Addiscombe Road for Disabled Parking is hazardous if approaching from the Roundabout as the access is immediately after exiting the roundabout and requires crossing the line of traffic (Addiscombe Road (A232) and the Pelican Crossing “zig-zag” markings and Red Line Parking restrictions. While waiting for a safe gap in the oncoming line of traffic, the stationery vehicle would cause further congestion and tailbacks from the roundabout and the traffic waiting to access the roundabout. Similarly, the Crossover for Access to the Residential Parking is across a Red Route and “zig-zag” markings for the Zebra Crossing.
  • We question the acceptability of “Dropped Kerbs” at locations close to junctions and at positions of “zig-zag” road markings at Pelican and Pedestrian crossings.
  • The illustration of probable ingress and egress swept Paths Parking trajectory, both for the Surgery Parking Bay and the Residential Parking from Shirley Road, are inaccurate, as the illustration only depicts the path of ONE axle which totally ignores the vehicles wheelbase, dimensions or bodywork overhang, front and rear. These illustrations are completely ineffectual and give a completely false sense of acceptability.

MORA Submission: 23rd May 2021
Consultation Closes: 27th May 2022
Target Decision: 14th Jun 2022
• Total Consulted: 31
• Objections: 186
• Supporting: 0
Councillor referral: Councillor Jeet Bains (16th May 2022)

Flyer for download and social media sharing.

Further developments are in the May 2023 Planning Report.

Appeals Pending

211 Wickham Road – Ref: 23/00231/FUL
Demolition of existing structures to the rear of 211 Wickham Road and erection of a two-storey building containing four dwellings (1 x 3 bed and 3 x 1 bed flats) with associated parking and refuse storage.

We objected to the proposed development on the grounds that:

  • The building line is created by the primary front face of buildings along a street and is a key element of Design Code of the locality. The National Model Design Code & Guidance requires all new development should follow the established building line where it exists.
  • Therefore the Building Line Set-Back for this proposed development should follow the existing Building Line Set-back of ≈7m as it follows the curve of Ridgemount Avenue. Failure to meet this Policy is grounds for a refusal.
  • Assessment in accordance with the National Model Design Code clearly indicates that the Housing Density at 123.46U/ha of the proposed development is more appropriate in a “Central” Area Type Setting than the actual “Outer Suburban” Area Type Setting of the Shirley Local Centre. This is conclusive evidence of over development for the “Site Capacity” of ≈0.0324ha in an Outer Suburban Setting at PTAL 2.
  • The proposed development has a site area of 324m2 and the offered Gross Internal Area of 187.7m2 equates to a Floor Area Ratio of 187.7/324= 0.579. exceeding 0.5 recommended in the National Model Design Code Guidance by 15.8%.
  • The Area Type Setting at 211 Wickham Road is “Outer Suburban” for a TfL assessment of connectivity but the Application Density in terms of bedspaces per hectare at 216.05bs/ha is within the mid-range of an “Urban” Area Type Setting.
  • The offered Residential Density in terms of persons (bedspaces) per hectare (bs/ha) would require a PTAL of 4.29 when the available PTAL is only available at PTAL 2.

Permission Refused

Reason(s) for refusal :-

  1. The proposal would result in a poor design with the inclusion of recessed balconies which would fail to enhance and sensitively respond to the existing character and the appearance of properties along Ridgemount Avenue. The proposal is therefore contrary to policies D3 and D4 of the London Plan 2021 and Policy DM10 of the Croydon Local Plan 2018.
  2. The proposal would result in a poor standard of amenity with no communal amenity space and playspace, which is flexible, multifunctional, accessible and inclusive. The proposal is contrary to Policies D3, D6 of the London Plan 2021 and Policy DM10 of The Croydon Local Plan 2018.
  3. The proposed refuse and cycle storage facilities, by reason of design, size and capacity would be contrary to Policies T4, T5 of the London Plan 2021 and Policies DM10 and DM13 of the Croydon Local Plan (2018).

MORA Submission: 2nd Mar 2023
Consultation Closes: 5th Mar 2023
Target Decision: 16th Mar 2023
• Total Consulted: 30
• Objections: 2
• Supporting: 0
Appeal Notice: 20th Mar 2023

Further developments are in the May 2023 Planning Report.

46 The Glade – Ref: APP/L5240/W/22/3312168
Demolition of existing property and construction of 4 no. 3 bedroom houses with parking spaces.

We objected to the proposed development on the grounds that:

  • The proposed development would introduce a substantial Block of 4 Terraced Units of 3-4 storey with gable roofs on this plot. There would be a pronounced increase in height from the neighbouring two-storey properties. The height and bulk would be significantly greater than the rest in the locality and therefore would be visually jarring in this context. The proposed development would therefore harmfully contrast with the limited height and scale of surrounding properties in this area and therefore unacceptably erode its modest character.
  • Policy DM10 of the Croydon Local Plan 2018 (CLP) states that proposals should seek to achieve a minimum height of 3 storeys, but also that they should respect the development pattern, scale, height and massing of the surrounding area amongst other things. This development seeks to increase the density on this site. However, as outlined above, it would be in a form that would be harmful to the character and appearance of the area. Therefore, it would be contrary to these policies in this regard.
  • Consequently, the proposed development would result in a harmful effect on the character and appearance of the area. As such, in this respect, it would be contrary to Policies SP4 and DM10 of the CLP. Together these seek to achieve high quality design which respects local character.
  • The proposed development fails the 45° (Vertical) projection from both adjacent dwellings at 44 & 48 The Glade which impacts on the amenities of both adjacent properties and gives an overtly overbearing and dominant effect and impairs daylight and sunlight, significantly for 48 The Glade as shielded from sun by the proposed development to the South.
  • Parking Bays for Unit 4 occupants are stacked in-line (4a & 4b) such that if both bays are full and the rear vehicle (4b) is required for travelling, the vehicle parked in the forward bay (4a) will need to be moved to allow exit.
  • This is likely to be an extremely onerous aggravation to the future occupants of Unit 4, especially in periods of high precipitation. This Swept Path configuration is NOT shown on the “Proposed Swept Path Analysis” Drawing No. 21031-01. This is considered an extremely poor design and is an indication of inadequate Site Area to accommodate the required Parking provision with acceptable manoeuvrability. This is bad practice and will remain as such for the life of the development, if approved.

Appeal submitted in respect of Croydon Council’s failure to determine planning application reference 22/03970/FUL relating to 46 The Glade, Croydon.

MORA Submission: 27th Oct 2022
Consultation Closes: 30th Oct 2022
Target Decision: 21st Nov 2022
• Total Consulted: 12
• Objections: 5
• Supporting: 0
Appeal Notice: 30th Nov 2022
Appeal Linked with 46 The Glade – APP/L5240/W/22/3305791 (Not the Lead Case)

Further developments are in the May 2023 Planning Report.

44 Orchard Avenue – Ref: APP/L5240/W/22/3309454
Demolition of an existing detached dwelling and construction of a new three storey building comprising 7 apartments with associated private and communal amenity space, refuse and cycle storage.

We objected to the proposed development on the grounds that:

  • The inappropriate 7.5m separation between the existing dwelling at 6 Potters Close remains unacceptable and does not follow the established rear projection building line of Orchard Avenue with adjacent dwellings and is a further example of over development exceeding the “Site Capacity” at this setting.
  • This reduced separation does NOT respect the SPD2 para 2.9.10 (Fig 2.9f) relationship guidance of 18m “New to Existing” 3rd Party dwelling of Separation from the rear elevation of 44 Orchard Avenue to the flank elevation of 6 Potters Close. The flank wall of 6 Potters close has windows and these will be overlooked at this close distance.
  • The rear building line does not respect the existing, extending from 44 to 50 Orchard Avenue and the separation between existing properties in Potters Close and Russet Drive.
  • There is inadequate Children’s “Play Space” in the very limited communal open space which is further evidence of over development, inappropriate for the “Site Capacity” at the Local “Setting”. The Built-In Storage for Apartment 2 is deficient by 0.5sq.m. from the minimum space Standard requirement by London Plan Policy D6 Table 3.1.
  • Analysis of both the London Plan and the Revised Croydon Local Plan Residential Parking at PTAL 2 indicates under provision of 50% which would result in the deficiency in parking provision and a 2-vehicle overnight overspill to on-street parking in Orchard Avenue or Firsby Avenue.
  • The analysis shows that for new developments in areas without controlled parking Zones and at PTAL 2, the Croydon Plan would require a limit of 6 spaces for the Revised draft Croydon Local Plan Policy DM30 Table 10.1 and 6 spaces for the adopted London Plan Policy T6.1 Table 10.3 when only 4 spaces are provided.
  • This is a 50% deficiency for both the Revised Draft Croydon Plan and the London Plan Policy which means a likely overspill of 2 cars. This overspill would likely park in Orchard Avenue, a link road not sufficiently wide enough for both way traffic passing a parked vehicle, with high traffic density linking the A232 with the A222 and a Bus Route.
  • There is now no pressure to meet “Housing need” and “Targets” for provision of further developments in the Shirley North Ward as the housing need and targets for the whole of the Shirley “Place” has already been Met. The assessment is therefore that this proposal should be refused with the objective of the applicant re-applying with a more appropriate and suitable proposal.

Permission Refused

Reason(s) for Refusal:-

  • The proposed development, specifically the rear element, by reason of the scale, bulk, depth, and form, as well as the poor elevational composition, would result in a 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. Additionally, the proposal would not respect the established rear building line and it would result in an incongruous form of development. This is contrary to Policy D4 of the London Plan (2021) and Policy DM10 of the Croydon Local Plan (2018).
  • The proposal by reason of its scale, bulk, and massing, would result in the potential loss of light for No. 46 Orchard Avenue, and an overbearing impact on No. 6 Potters Close which would be contrary to Policies D3 and D6 of the London Plan (2021) and Policy DM10 of the Croydon Local Plan (2018).
  • The proposal does not provide sufficient details on the modified access, in terms of vehicular visibility splays, and the cumulative impact of crossovers on Orchard Avenue. There is a deficiency of car parking and no provision of a Blue Badge car parking space. The car parking and cycle parking do not meet standards. There is a lack of safe pedestrian access through the site. This would be contrary to Policies T4, T5, and T6 of the London Plan (2021) and policies DM29 and DM30 of the Croydon Local Plan (2018).
  • In the absence of a legal agreement, to secure sustainable transport contributions, as well as car club membership for each residential unit for a period of 3 years, the proposal would fail to mitigate harmful impacts and would be unacceptable in planning terms given the shortfall of on-site car parking. The proposal therefore conflicts with T6 of the London Plan (2021) and Policies SP6, DM29 and DM30 of the Croydon Local Plan (2018).
  • The proposed refuse and recycling stores, due to the external location and not integrated into the landscaping, would create visual clutter on the streetscene. Additionally, the location for the bulky waste is inappropriate. The proposal is therefore contrary to policy DM13 of the Croydon Local Plan (2018).
  • The proposal has failed to demonstrate that it would not have an unacceptable impact on trees, contrary Policy DM28 of The Croydon Local Plan (2018) and Policy G7 of the London Plan (2021).

MORA Submission: 20th Jun 2021
Consultation Closes: 1st Jul 2022
Target Decision: 11th Jul 2022
• Total Consulted: 12
• Objections: 2
• Supporting: 0
Councillor referral: Councillor Sue Bennett (23rd Jun 2022)
Permission Refused: 16th Sep 2022
Appeal Notice: 3rd Nov 2022
MORA Appeal Submission: 18th Apr 2023

Further developments are in the May 2023 Planning Report.

21 Woodmere Gardens – Ref: 22/02598/FUL
Demolition of single family dwelling and garage and the erection of one storey semi-detached houses with accommodation in the roof space, comprising of 2 dwellings and 2 off street car parking spaces and a detached 2-storey building with accommodation in the roof space, comprising of 5 self-contained apartments with intergraded bike and refuse stores and 6 off street car parking spaces.

We objected to the proposed development on the grounds that:

  • The Built-In Storage capacity for Apartments 3 & 4 and the Semi-Detached Unit 7 are unacceptable.
  • The Play Space for Children should be provided with Play Activity equipment and furniture and be segregated from the Communal Open Space.
  • The proposed development significantly exceeds the Site Area of 0.121ha capacity for “Gentle” densification of Housing Density for the location of 21 Woodmere Gardens in an “Outer-Suburban” Area Type Setting at Zero PTAL by a factor of 114.26%.
  • The location would require a significant improvement in supporting infrastructure (assessed as a 94.6% increase) and an improved TfL PTAL from Zero to 5.68, in order to support the Density of the proposed development. There are other additional infrastructure physical utility service constraints indicated in the LPA assessment, including Flood Risk at 30yr and 100yr for Surface Water and Gas Pipes Low Pressures.

Appeal submitted in respect of the Council’s failure to determine planning application reference 22/02598/FUL relating to 21 Woodmere Gardens, Croydon.

MORA Submission: 8th Aug 2022
Consultation Closes: 19th Aug 2022
Target Decision: 15th Aug 2022
• Total Consulted: 13
• Objections: 15
• Supporting: 0
Councillor referral: Councillor Richard Chatterjee (23rd Aug 2022)
Appeal Notice: 30th Sep 2022

Further developments are in the May 2023 Planning Report.

77 Woodmere Avenue – Ref: APP/L5240/W/22/3307153
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 16.8m2 is 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.

Permission Refused

Reason(s) for Refusal:-

  1. The quality of accommodation, by virtue of the shortfall of amenity space for Flat 3, would result in a sub-standard residential unit, which is contrary to Policy D6 of the London Plan (2021) and Policy DM10 of the Croydon Local Plan (2018).
  2. The proposed development, by reason of scale, width, roofline and form, poor elevational composition, 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. Additionally, the proposal would not respect the established rear building line and there is a lack of landscaping to compensate for the dominance of the hardstanding to the front of the property. This is contrary to Policy D4 of the London Plan (2021) and Policy DM10 of the Croydon Local Plan (2018).
  3. The proposal by reason of its scale, bulk, massing, and window placement, would result in the loss of light, the loss of privacy, and overbearing impact on Nos. 75 and 79 Woodmere Avenue, which would be contrary to Policies D3 and D6 of the London Plan (2021) and Policy DM10 of the Croydon Local Plan (2018).
  4. The proposal does not provide sufficient details on the modified access, in terms of details and dimension, visibility splays, and a swept path analysis. Additionally, there is a deficiency of information for the car parking, as swept path analysis has not been provided, and would therefore be contrary to Policies T4, T5, and T6 of the London Plan (2021) and policies DM29 and DM30 of the Croydon Local Plan (2018).
  5. In the absence of a legal agreement, to secure sustainable transport contributions, as well as car club membership for each residential unit for a period of 3 years, the proposal would fail to mitigate harmful impacts and would be unacceptable in planning terms given the shortfall of on-site car parking. The proposal therefore conflicts with T6 of the London Plan (2021) and Policies SP6, DM29 and DM30 of the Croydon Local Plan (2018).
  6. The proposed refuse and recycling stores, due to the location of this externally and not integrated into the landscaping, would create visual clutter on the streetscene. Additionally, the location of the bulky waste area is not appropriate. The proposal is therefore contrary to policy DM13 of the Croydon Local Plan (2018).
  7. The proposal fails to provide information to address fire safety, which is contrary to policy D12 of the London Plan (2021).
  8. The proposal has failed to demonstrate that it would not have an unacceptable ecological impact on biodiversity of the area contrary Policy G6 of the London Plan (2021) and Policy DM27 of The Croydon Local Plan (2018).

MORA Submission: 11th Apr 2021
Consultation Closes: 17th Apr 2022
Target Decision: 19th Apr 2022
• Total Consulted: 25
• Objections: 42
• Supporting: 0
Councillor referral: Councillor Sue Bennett (30th Mar 2021)
Permission Refused: 18th Aug 2022
Appeal Notice: 16th Sep 2022
MORA Appeal Submission: 28th Mar 2023

Further developments are in the May 2023 Planning Report.

46 The Glade – Ref: APP/L5240/W/22/3305791
Demolition of single storey dwelling at 46 The Glade and redevelopment with a new building to provide 8 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:

  • It is clear from the Applicant’s provided documentation and Plans that NO account has been taken of the National Model Design Code and Guidance to determine the Area Design Code(s) “Setting” or “Site Capacity” for this proposal.
  • The offered Housing Density of the proposal is 88.24Units/ha which is a Setting of Mid & Urban Range but with public transport access level (PTAL) of Zero which is inappropriate for an Urban Area Type Setting. 46 The Glade, by all our assessments of the locality Design Code, is within the lower of the range of 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 applicant still presumes the local PTAL to be 1a.
  • 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 8 Flats. The Dimensions are NOT stated, however the excess GIFA may compensate for this omission but requires full assessment.
  • The evidence indicates a deficiency of Play Space for the probable 12 children to be 87.75m2 which is a deficiency of (120-32.25)/32.25 = 0.270 = 27%.
  • It is noted that the “Vision Transport Assessment” Parking Assessment Report of 13th August 2021 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 9 spaces for the Revised draft Croydon Local Plan Policy DM30 Table 10.1 and 12 spaces for the adopted London Plan Policy T6.1 Table 10.3 when only 7 are provided.
  • 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.

Appeal submitted in respect of the Council’s failure to determine planning application reference 22/01881/FUL relating to 46 The Glade, Croydon.

MORA Submission: 8th Jun 2021
Consultation Closes: 9th Jun 2022
Target Decision: 1st Jul 2022
• Total Consulted: 12
• Objections: 7
• Supporting: 0
Councillor referral: Councillor Sue Bennett (10th Jun 2022)
Appeal Notice: 25th Aug 2022
MORA Appeal Submission: 17th Apr 2023
Appeal Linked with 46 The Glade – APP/L5240/W/22/3312168 (Lead Case)

Further developments are in the May 2023 Planning Report.


Additional Matters

Planning Sub-Committee Meeting Comments on 9th March

MORA has sent a complaint to Heather Cheesebrough (Croydon Council Director of Planning and Sustainable Regeneration)  relating to the Planning Officers response to Objecting Speaker’s statements relating to Intensification during a planning sub-committee meeting.

Although the Planning Application in question was refused, the basic complaint is that the Officer response was that the Local Plan has “Primacy” over other Planning Policies, which is NOT true.

The weight of Policies are:

  1. The National Planning Policy Framework (NPPF)
  2. Regional Plans ( which were abolished under the Localism Act of 2011 and replaced by a Duty to Co-operate among local authorities)
  3. The London Plan
  4. Local Development Plans
  5. Neighbourhood Plans

The objecting speaker was quoting proposal’s Area Type and Design Codes as defined in the National Model Design Code & Guidance, supported by the London Plan Policy D3 regarding Site Capacity and infrastructure support. In effect the Planning Officer was suppressing and undermining the valid statements put forward in representations by the objecting speaker. Objective is possibly to influence committee members to disregard the comments to prevent committee members from debating these relevant Policies, in order to gain more influence for an approval.

If this is Croydon LPA Policy, it is ignoring changes in higher level Policies as the Croydon Local Plan, dated 2018, is already 5 years out of date and will be 7 years out of date before the revised Croydon Plan is adopted and published.

Further developments are in the May 2023 Planning Report.

DEREK RITSON

MORA Planning

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