Planning Report – December 2023

Licensing Applications

39 Lorne Gardens

Applications

Licensing Applications

39 Lorne Gardens
Application for a premises license to be granted under the Licensing Act 2003

How to make representations on a premises licence application under the Licensing Act 2003

If you wish to make representations on an application for a new premises licence, you can do so if you are an interested party. An interested party can include local residents or businesses who may be affected by the activities of the premises.

Representations must be by letter or email to the licensing team below within 28 days of the submission of the application. Your representations must relate to at least one of the following licensing objectives:

the prevention of crime and disorder
public safety
the prevention of public nuisance
the protection of children from harm

If you wish to make representations in relation to this application, please do so in writing by midnight on the 1.12.23 to the following address:

Postal address of local authority where register of applications is kept for general viewing:

London Borough of Croydon
Place Department, Licensing Team,
3rd Floor, Zone B
Bernard Weatherill House
8 Mint Walk
Croydon, CR0 1EA

Or By Email to: licensing@croydon.gov.uk

It is an offence to knowingly or recklessly make a false statement in connection with an application. The maximum fine on summary conviction for such an offence is £5000.

Further developments are in the January 2024 Planning Report.

Applications

New
211 Wickham Road – Ref: 23/03978/FUL
Demolishing of ancillary storage outbuilding area attached to the shop situated at the rear garden of 211 Wickham Road CR0 8TG and the erection of a detached building consisting of 1 No, three bedroom 4 Person self-contained unit and 3 Nos, 1 bedroom, 1 Person self-contained unit.

MORA has concerns as to whether this application will proceed as it is fundamentally the same application as that which was dismissed at the appeal stage in October 2023.

We recommend that this proposal either be rejected on grounds of similarity with previous refused and Dismissed on Appeal proposals, and not adequately addressing the reasons for Refusal or Dismissal of the Appeal or for failure to meet the additional London Plan – Supplementary Planning Guidance (2023).

We are of the view that the new proposal is not materially different from the previous refused and dismissed Appeal and therefore does not adequately address the Inspectors reasons for dismissal of the previous application and Appeal. It is therefore inappropriate for validation.

MORA Submission: 18^th Dec 2023
Consultation Closes: TBC
Target Decision: 25^th Jan 2024
• Total Consulted: 0
• Objections: 0
• Supporting: 0

Further developments are in the January 2024 Planning Report.

Decided

46 The Glade – Ref: 23/02129/FUL
Demolition of the existing bungalow and the erection of 3 no. two storey houses in the form of a 1 no. detached house and 1 no. semi-detached pair, each with private rear garden containing a cycle store, compost store, and landscaping with native species. 4 no. car parking spaces, waste storage, and soft landscaping will be provided to the front of the houses, with the existing dropped kerb modified to retain vehicular access.

We objected to the proposed development on the grounds that:

This proposal is a significant improvement to the recent refused and Appealed proposals for this site, which is welcomed. However, there are still issues which prevent us from approving this proposal.
The Site is a normal rectangular configuration with an existing bungalow. There are no obvious impediments to the redevelopment of this site. However, the locality as defined by the National Model Design Code and Guidance as related to the Post Code CR0 7QD is of an <Outer (London) Suburban Area Type (≤ 20Units/ha) and additionally has a very Low Public Transport Accessibility Level (PTAL) (Zero) as defined by TfL WebCAT, whereas the Housing Density of the proposal would require the locality of the proposal to be Outer (London) Suburban (≥40 to ≤60 Units/ha) as defined by the National Model Design Code & Guidance and a PTAL of ≈1.79, if based on a linear incremental increasing distribution over the ranges of PTAL and Residential Densities.
The proposed separation between Units 2 & 3 will not meet the 45° Vertical Rule projection from the centre of nearest ground floor windows of the proposals even though they are virtually full width Patio windows. The projected 45° line from the centre of the ground floor (which is normally off Centre toward the adjacent dwelling) which gives greater allowance, still fails the 45° Degree projection which is significant proof of failure to meet the Policy. Units 2 & 3 are definitely too close together.
In addition, the Applicant has shown the 45° Horizonal projection from the centre of the furthest ground floor window instead of the nearest ground floor window of 11 Gladeside which we have shown clearly intersects the 45° Horizontal projection indicating loss of amenity to the occupant of 11 Gladeside by both Horizontal and Vertical failure to meet the Policy.
The Parking provision is inadequate at the available PTAL of Zero and for the three Units would require 4.5 ≈5 (Integer) spaces, as required by London Plan Policy T6.1 Residential parking – Table 10.3, for ‘Outer’ London within PTAL ranges 0 to 1, when only 3 Parking bays are provided. This is a 40% deficiency in the appropriate parking provision for this proposal, which is unacceptable. Parking for Unit 1 will block or significantly reduce access to the rear garden area on Unit 1 and the Parking Space for Unit 3 is on the forecourt of Unit 2.
The Refuse bins for Unit 2 are much too close at ≈2m in front of Unit 2’s Dining room window. This is hygienically unacceptable. The position is likely to cause percolation of smells and attract airborne insects when the dining room window needs to be open for ventilation in periods of pleasant weather or high temperatures.
The proposal would present an increase in Housing Density from 18.54u/ha to 29.41U/ha, a 58.61% increase from <Outer Suburban to Outer Suburban Area Type Setting and a commensurate increase in Residential Densities, from 45.03bs/ha to 117.65bs/ha, a 161.25% increase from an <Outer Suburban Area Type through Outer Suburban to mid Suburban Area Type setting. These increases are significantly less than those offered by the previous refused (and appealed) proposals but still exceed the local Design Code Settings defined by the Post Code in accordance with the National Model Design Code & Guidance.
Although the Floor Area Ratio (FAR) is only slightly higher than the <0.5 Benchmark recommended for “Suburban” Areas, this proposal is in a ‘less than’ <Outer Suburban Area Type Setting, two Settings lower than “Suburban” as defined by the Post Code CR0 7QD which would suggest a lower benchmark ratio commensurate with the local character ratio of the larger garden areas to build footprint. (GEA/Site Area).
We have no confidence in the Vision Transport Assessment as the author must have purposely manipulated and modified the TfL WebCAT search to show the PTAL to be 1a when the interrogation for both the Post Code (CR0 7QD) and the address 46 The Glade returns PTAL Zero (0), to convince the reader of a higher Accessibility Rating than would otherwise be displayed. This has resulted in our complete loss of confidence in the credibility and professionalism of the Transport Assessment Report, as it shows profound unprofessional BIAS which throws suspicion on other parameters that may have been manipulated to give a more positive assessment of the Transport facilities than are actually available.

MORA Submission: 21^st Jun 2023
Consultation Closes: 29^th Jun 2023
Target Decision: 26^th Jul 2023
• Total Consulted: 15
• Objections: 6
• Supporting: 0
Permission Granted: 14^th Dec 2023

Further developments are in the January 2024 Planning Report.

21 Woodmere Gardens – Ref: APP/L5240/W/22/3308020
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: 8^th Aug 2022
Consultation Closes: 19^th Aug 2022
Target Decision: 15^th Aug 2022
• Total Consulted: 13
• Objections: 15
• Supporting: 0
Councillor referral: Councillor Richard Chatterjee (23^rd Aug 2022)
Appeal Notice: 30^th Sep 2022
MORA Appeal Submission: 10^th Aug 2023
Appeal Dismissed: 11^th Dec 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 :-

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).
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)
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).
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: 28^th Feb 2023
Consultation Closes: 8^th Mar 2023
Target Decision: 31^st Mar 2023
• Total Consulted: 12
• Objections: 4
• Supporting: 0
Permission Refused: 30^th Mar 2023
Appeal Notice: 5^th May 2023
Appeal Dismissed: 8^th Dec 2023

Further developments are in the January 2024 Planning Report.

19 Orchard Avenue – Ref: APP/L5240/W/23/3318923
Demolition of existing property and construction of a block containing 8 flats with associated centralised drop kerb and parking.

Illustration due to copyright.
View original documents **here**

We objected to the proposed development on the grounds that:

There is confusion between the Design & Access Statements and the supplied Floor Plans with regard to Occupancy. The D&A Statement indicates 2b3p for Apartments 1 to 6 whereas the Floor Plans indicate Apartments 1 through 6 bedrooms have Double Beds which indicates 2b4p.
This increases occupancy from 22 to 28 for the proposal with consequential increase in Residential Density from 337.5 to 429.47 bedspaces/ha. The habitable room remain at 24 which equates to a Residential Density of 368.21hr/ha.
The confusion on occupancy also impacts on the required GIA for Apartments 1,2 & 3 and 5 which do NOT meet the Required Minimum Space Standards (GIA) of 70sq.m. requirement for 2b4p Units although the Total GIA exceeds the total required by 0.9sq.m.
The proposal does NOT provide any (identified) In-Built Storage for any of the Apartments. A total area of 15sq.m. would be an appropriate minimum, distributed accordingly to the London Plan Policy D6 Table 3.1. This lack of Storage Space is unacceptable.
Apartments 3 to 8 have NO Private Open Amenity Space, in the form of Balconies or veranda. This lack of Private Open Space is unacceptable. There is no compensation from increased GIA.
The Juliet Balconies give NO additional Amenity Space but allow the safety of floor level windows to provide additional internal light. The applicant has NOT provided a Daylight Assessment Study.
The D&A Statement quotes communal garden amenity at 181sq.m. The Communal Open Space required is (50sq.m. + 7sq.m.) = 57sq.m. and for the probable 8 children without a private garden area would require a Play Space of 10 sq.m. per child equals 80 sq.m. thus the total required Communal plus Play Space = 57 + 80 = 137sq.m. The available space is stated as 181 sq.m. which is within this requirement.
However, It would be preferrable if the Children’s Play Space were to be separated from the Communal Open Space for the positioning of exercise and play equipment for the children of the proposed occupants of the development.
The D&A Statement assumes the locality to be “Urban” when all assessment and analysis of the locality in various hierarchical categories from individual sites, Post Code Areas, Ward Areas etc., conclusively show that, by National Model Design Code & Guidance assessment, the locality is within or below the “Outer Suburban” Area Type or Setting.
The Applicant has failed to acknowledge a requirement to meet the London Plan Policy (2021) D3 Design-Led Approach, and the National Model Design Code & Guidance (2021) referenced from the current NPPF paras 128 & 129 (July 2021).
Assessment and Analysis of the locality places 19 Orchard Avenue clearly in an “Outer Suburban” Area Type Setting.
The Area Type Setting at Outer Suburban Site Area of 0.06518ha can accommodate a site Capacity of 4 Units maximum whereas the proposal is for 8 Units. This is conclusive proof of over-development as defined by the London Plan Policy D3 and the National Model Design Code & Guidance referenced from the NPPF.
In addition, the Floor Area Ratio (GIA/Site Area) for Suburban Area Type Settings should be less than or equal to ≤ 0.5 whereas the actual Floor Area Ratio is 520.9/651.8 (ratio in sq.m.) = 0.8 which exceeds the guidance in the National Model Design Code by (0.8 – 0.50/0.50)x100 = 60.
The London Plan and the Revised Croydon Local Plan have a Parking requirement of between 7.5 and up to 13.5 spaces with the proposal only providing 4, one of which is for disabled Parking.
The Design and Access Statement does NOT indicate any Electric Vehicle (EV) Charging points, but the Transport Assessment does assume that all bays will be provided with EV charging capability.
London Plan and Croydon Plan Residential Parking Policies quote parking in PTAL 2 areas to be between 7.5 up to 13.5 spaces.
The allocation is for 4 spaces one of which is for Disabled Parking. The likely requirement is for one vehicle per Family Unit e.g., 8 Parking Spaces which would result in 4 vehicle overspills into adjacent appropriate On-Street overnight parking.
There would probably be 16 adults accommodated in the proposed development and based upon the 2013 survey 67% would own a car which translates to an ownership of (67x 16)/100 10.72 vehicles and a requirement for 6.72 or rounded to 7 vehicle overnight overspill.
For Sustainable Developments, it is necessary for the development to have supporting sustainable infrastructure. A measure of sustainability is the Accessibility to Public Transport services (PTAL).
The TfL Density Matrix has been omitted from the Revised London Plan but is retained for the Public Transport Accessibility Level (PTAL) assessment using the TfL WebCAT. The required PTAL for this proposal with a Residential Density 368.21hr/ha or 429.58bedspaces/ha would be:
For Residential Density: 368.21 hr/ha = 6.55
& Residential Density: 429.58 Bedspaces/ha ≈ 8.
This proposed Residential Density would require a PTAL which significantly exceeds the available TfL PTAL of 2 and is outside the range of the above graphical illustration.

Permission Refused

Reason(s) for Refusal:-

The proposed development by virtue of its lack of family accommodation would result in the loss of a family sized unit and therefore would fail to deliver a choice of quality accommodation to create sustainable exclusive mixed community contrary to policy DM1.1 and would fail to meet the 30% strategic target identified within Policy SP2.7 of theCroydon Local Plan 2018 and Policy H10 of the London Plan 2021.
The proposed development, by reason of its design, proportionality and massing would be out of character with the local character and distinctiveness and would thereby conflict with Policies SP4 and DM10 of the Croydon Local Plan 2018, and Policies H2, D4 and D6 of the London Plan 2021.
The development would result in poor standard of accommodation by reason of its window arrangements leading to lack of privacy, poor outlook and possible low levels of light to ground floor bedroom windows, lack of private amenity space to upper floor flats, failure to provide direct access from the building to the rear communal garden, absence of child playspace details and fails to demonstrate M4(2) or M(3) compliance, conflicting with Policy DM10 of the Croydon Local Plan 2018, and Policies D4, D5, D6 and D7 of the London Plan 2021.
The proposal, by reason of its massing and proximity, would result in an intrusive and imposing form of development detrimental to the visual amenity and outlook for neighbours at 21 Orchard Avenue contrary to policy DM10 .6 of the Croydon Local Plan 2018 and Policy D3 of the London Plan 2021.
The proposed development would cause loss and possible future loss of existing trees which make a positive contribution to the character of the area, whilst insufficient detail has been provided to ensure that suitable replacement trees are secured, contrary to Policy DM28 of the Croydon Local Plan 2018 and Policy G7 of the London Plan 2021.
The proposal has failed to demonstrate that it would not have an unacceptable ecological impact on biodiversity of the area contrary Policy DM27 of The Croydon Local Plan 2018 and G6 London Plan 2021.
Sufficient detail has not been provided to ensure that the proposal would result in provision of adequate refuse storage facilities and therefore would be contrary to Policies DM13 of The Croydon Local Plan 2018.
Sufficient detail has not been provided to demonstrate that the proposal would not have an adverse impact on the highway transport network due to lack of sightlines within the boundary of the site, inadequate swept path manoeuvres, inadequate cycle parking and blue badge car parking space provision, as well as the absence of a legal agreement securing sustainable highway improvements to mitigate the scheme impacts, contrary to Policies SP8, DM29 and DM30 of The Croydon Local Plan 2018 and Policies T4, T5, T6.1H of the London Plan 2021.

MORA Submission: 15^th Jun 2021
Consultation Closes: 23^rd Jun 2022
Target Decision: 20^th Jul 2022
• Total Consulted: 34
• Objections: 7
• Supporting: 0
Councillor referral: Councillor Sue Bennett (23^rd Jun 2022)
Permission Refused: 9^th Nov 2022
Appeal Notice: 24^th Aug 2023
MORA Appeal Submission: 14^th Sep 2023
Appeal Dismissed: 13^th Nov 2023

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: 20^th Jun 2021
Consultation Closes: 1^st Jul 2022
Target Decision: 11^th Jul 2022
• Total Consulted: 12
• Objections: 2
• Supporting: 0
Councillor referral: Councillor Sue Bennett (23^rd Jun 2022)
Permission Refused: 16^th Sep 2022
Appeal Notice: 3^rd Nov 2022
MORA Appeal Submission: 18^th Apr 2023
Appeal Dismissed: 21^st Nov 2023

Awaiting Decision

9 – 13 Gladeside – Ref: 23/02734/FUL
This proposal is for the demolition of 3no existing dwellings and the erection of 5no detached dwelling houses of two storey with accommodation in the roof space. 8 car parking spaces are provided plus cycle and refuse storage.

We objected to the proposed development on the grounds that:

This proposal is an improvement on the previous refused and Appealed proposal Ref: 22/03888/FUL but still has non-compliance to Policies and is an over development in an < Outer Suburban Area Type Setting.
We have set out clear reasons why this proposal should be refused based upon National and Local Planning adopted and emerging Policies.
It is clear from the forgoing that the Site Area is insufficient for the proposed level of Development. The accommodation standards with respect to Storage requirements are not met, although family housing is offered and preferred, the capacity is overly cramped. The Amenity of neighbours is adversely affected by the height and proximity of the proposed development and the raising of the ground level Above Ordinance Datum (AOD).
The proposal exceeds the Local Area Type Setting as defined by the National Model Design Code Area Type Setting of the local Post Code and exceeds the Site Capacity as defined by the London Plan Policy D3 Optimising Site Capacity by the Design Led Approach.
There has been inadequate assessment of the proposed developments increasing the surface water flood risk to the existing adjacent dwellings at 7 and 15 Gladeside.

MORA Submission: 17^th Aug 2023
Consultation Closes: 23^rd Aug 2023
Target Decision: 7^th Sep 2023
• Total Consulted: 17
• Objections: 10
• Supporting: 0
Councillor referral: Councillor Richard Chatterjee (29^th Aug 2023)
Councillor referral: Councillor Sue Bennett (29^th Aug 2023)

Further developments are in the January 2024 Planning Report.

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

Further developments are in the January 2024 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: 23^rd May 2021
Consultation Closes: 27^th May 2022
Target Decision: 14^th Jun 2022
• Total Consulted: 31
• Objections: 186
• Supporting: 0
Councillor referral: Councillor Jeet Bains (16^th May 2022)

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Further developments are in the January 2024 Planning Report.

Appeals Pending

Land B/W 2 & 5 Round Grove – Ref: 23/01204/FUL
Demolition of detached building. Erection of 1 x two-storey two-bedroom detached dwellinghouse including new vehicular access and crossover, landscaping, boundary treatments, car parking, cycle parking and bin storage and all associated site works.

We objected to the proposed development on the grounds that:

The Site area could benefit from improvement and attention, but the proposed development exceeds the Site Capacity for the Area Type Setting as defined by the National Model Design Code & Guidance; also, the proposal does not respect the character of the Area Type Setting and would not integrate well with the existing Street Scene.
The proposal does NOT follow the established Building Line along Round Grove and significantly breaches the building line of the two adjacent dwellings. The proposal offers inadequate storage space for future occupants. The amount of storage space beneath the staircase is undefined in area or volume.
The Area of the proposal is inappropriate for Growth other than “Gentle” Densification but significantly exceeds the Growth appropriate for existing infrastructure provision. The proposal would be a 211.83% increase in Housing Density and a 340.30% increase Residential Density. The Site Capacity for <Outer Suburban for a single Dwelling is limited to a maximum Housing Density of 20Units/ha which equates to a minimum Site Area of =>0.05ha. The available Site Area is given as 203.5sq.m. ≡ 0.02035ha. Therefore, the available Site capacity is deficient by 0.2965ha or 296.5sq.m., for one dwelling in an Area Type Setting of <Outer Suburban.
Thus, the proposal fails to meet the London Plan Policy D3 Optimising site capacity through the design-led approach.

Permission Refused

Reason(s) for refusal :-

The proposal is considered to have an adverse impact on neighbouring amenity by reason of loss of privacy, loss of outlook and visual intrusion. As such, the proposal is contrary to Policies SP4.1,4.2, DM10.6 of the Croydon Local Plan and Policies D3 and D6 of the London Plan.
The proposal would result in substandard living conditions for future occupants due to the insufficient width for the first floor east facing bedroom and a low ceiling height contrary to Policy SP2.8 and DM10 of the Croydon Local Plan, Policy D6 of the London Plan and the Nationally Described Space Standard.
The proposed parking space by virtue of its location and orientation would be detrimental to the road safety, contrary to the Council’s Vehicle Crossovers Guideline, Policies DM29 and DM30 of the Croydon Local Plan and Policy T4 of the London Plan.

MORA Submission: 23^rd May 2023
Consultation Closes: 2^nd Jun 2023
Target Decision: 5^th Jul 2023
• Total Consulted: 4
• Objections: 13
• Supporting: 3
Permission Refused: 6^th Jul 2023
Appeal Notice: 4^th Oct 2023

Further developments are in the January 2024 Planning Report.

13 Gladeside – Ref: 23/01623/FUL
Demolition of the existing detached dwelling and erection of 3no. dwellinghouses with parking, cycle stores and private amenity, and associated works.

We objected to the proposed development on the grounds that:

This proposal is a welcome change to the many recent proposals in this locality as it provides individual family homes with gardens as opposed to blocks of flats of multiple occupation. This development proposal is more suitable for the local area and more appropriately reflects the character of the local area.
It is clear from the forgoing that the Site Area is insufficient for the proposed level of Development. Although family housing is offered and preferred, the capacity is overly cramped with restricted access.
The Amenity of No. 11 Gladeside is adversely affected by the height and proximity of the new adjacent Unit 1.
In addition, the main reason for our concern is the excessive Housing Density of the proposal in an Area Type Setting of less than an (<) Outer (London) Suburban Setting at 17.09Units/ha as defined by the National Model Design Code & Guidance. The proposal would have a Housing Density appropriate for a Suburban Area Type Setting at 48Units/ha, an 180.93% increase, which means the Area Type increases from < Outer Suburban Area Type, bridges the Outer Suburban Area Type Range to the Suburban Area Type without any increase or improvement of supporting infrastructure appropriate for the Suburban Area Type Density.
Similarly, the Residential Density, if assessed on the basis of comparable National Average Unit Occupancy based on the 2021 statistics, would result in the increase in Residential Density at 42.2Persons/ha from (<)Outer Suburban through Outer Suburban, Suburban & Urban to a Central Area Type at 288persons/ha, a 574.23% increase, again with no commensurate improvement in supporting infrastructure.
The appropriate evolutionary “Growth” at this local Area is defined by Policy DM10 and the Policies Map designations. The locality is not designated as an Area for specific levels of densification or intensification on the Policies Map and therefore only appropriate for Regeneration.
The London Plan “Incremental Intensification” Policy H2 is limited to areas of PTAL 3-6 and within 800m of a Tram/Train Station or District Centre, none of which applies to this proposal.
It is therefore considered that the 180.93% increase in Housing Density and the 574.23% increase in Residential Density would NOT be an appropriate level for “Gentle” Densification for natural regeneration.
The Site Capacity for a Site Area of 0.0625ha in an < Outer Suburban Area Type is NOT sufficient for 3 Units as defined by the National Model Design Code & Guidance. The recommended Floor Area Ratio (FAR) as defined by the National Model Design Code & Guidance should be < 0.5 whereas the proposal would have a FAR of 0.62, exceeding the recommended by 24%.
The proposal would clearly fail the London Plan Small Site Design Guide (Feb 2022) (paras 4.1.12/13 & illustration 4.6)

Permission Refused

Reason(s) for refusal :-

The proposed development, by reason of the design of the houses, the layout of the site (front forecourt area), and the uncharacteristic plot sizes would result in a cramped form of development, which would fail to integrate successfully and respond effectively in townscape terms to the wider setting of the local character and immediate surroundings contrary to Policies D3 and D4 of the London Plan (2021) and Policies SP4 and DM10 of the Croydon Local Plan (2018).
The proposed development by reason of its massing (depth) and proximity close to the neighbouring property at No. 11 Gladeside would result in an intrusive and imposing form of development which would result in a sense of enclosure due to the overbearing impact, contrary to Policies D3 and D6 of the London Plan (2021) and policy DM10 of the Croydon Local Plan (2018),
Sufficient detail has not been provided to demonstrate that the proposal would not have an adverse impact on the highway transport network due to inadequate car parking provision for this site due to insufficient tracking to demonstrate all of the car parking spaces can be accessed incurtilage, inappropriate pedestrian sightlines, poor vehicle and pedestrian access, and poor refuse storage facilities, and would therefore be contrary to Policies T4 and T6 of the London Plan (2021) and Policies DM13, DM29, and DM30 of the Croydon Local Plan (2018).

MORA Submission: 13^th Jun 2023
Consultation Closes: 22^nd Jun 2023
Target Decision: 13^th Jul 2023
• Total Consulted: 5
• Objections: 1
• Supporting: 0
Councillor referral: Councillor Richard Chatterjee (27^th Jun 2023)
Permission Refused: 27^th Jul 2023
Appeal Notice: 22^nd Aug 2023

Further developments are in the January 2024 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: 32
• Supporting: 0
Case Officer Report recommends: Grant Approval
Planning Committee Slot: 9^th Mar 2023
Permission Refused: 9^th Mar 2023
Appeal Notice: 20^th Sep 2023

Further developments are in the January 2024 Planning Report.

159 – 161 The Glade – Ref: APP/L5240/W/23/3325637
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).

Permission Refused

Reason(s) for refusal :-

The proposed development, by reason of scale, massing, elevation composition, bulky roof form, materials, detailing and impact on grass verge 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).
The proposed development lacks an appropriate parking strategy due to the unacceptable nature of the new vehicle crossover along The Glade thereby leading to possible increase in on street parking pressure, and 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 DM30 of the Croydon Local Plan (2018) and Policy T4, T6 of the London Plan (2021).

MORA Submission: 8^th Mar 2023
Consultation Closes: 19^th Mar 2023
Target Decision: 10^th Apr 2023
• Total Consulted: 17
• Objections: 3
• Supporting: 0
Councillor referral: Councillor Richard Chatterjee (24^th Mar 2023)
Permission Refused: 28^th Apr 2023
Appeal Notice: 10^th Jul 2023
MORA Appeal Submission: 8^th Nov 2023

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