Planning Report – February 2023

Applications

Additional Matters

Planning Advisory Service Peer Review – Update
Community Engagement (Community Involvement) – Revised Local Plan

Applications

Planning Sub-Committee Meeting (9^th Mar 2023)

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

Further developments are in the March 2023 Planning Report.

New

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.

Consultation Closes: 19^th Mar 2023
Target Decision: 10^th Apr 2023
• Total Consulted: 17
• Objections: 0
• Supporting: 0

Further developments are in the March 2023 Planning Report.

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.

Consultation Closes: 5^th Mar 2023
Target Decision: 16^th Mar 2023
• Total Consulted: 30
• Objections: 1
• Supporting: 0

Further developments are in the March 2023 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.

MORA Submission: 28^th Feb 2023
Consultation Closes: 8^th Mar 2023
Target Decision: 31^st Mar 2023
• Total Consulted: 12
• Objections: 2
• Supporting: 0

Further developments are in the March 2023 Planning Report.

Decided

77 Woodmere Avenue – Ref: 22/05090/FUL
Demolition of single-family dwelling and garage; erection of a detached 2-storey building with accommodation in the roof space, comprising: 6 self-contained flats, 7 car parking spaces, refuse store, cycle parking, and communal amenity space.

We objected to the proposed development on the grounds that:

The applicant has not addressed the fundament reasons for refusals reasons 2 to 4 of the previous refused application. The Build footprint has only been slightly decreased and the proposal remains a significant over-development for the Site Capacity of 0.1145ha. at a low PTAL of 1a (≡0.66)
The reduction of one Apartment reduces the Housing Density from 61.08Units/ha to 52.36Units/ha and the Residential Density from 191.97bedspaces/ha to 165.79bedspaces/ha. This also results in a reduction of the Gross Internal Area from 475.5 sq.m. to 454 sq.m.
The increased roof height of the proposal has exacerbated the loss of amenity to 79 Woodmere Avenue 45° Rule (vertical) projection and the projected intersection from that of the refused previous proposal. Also, the horizontal 45° Rule projection and intersection from 79 Woodmere Avenue is virtually identical to that of the previous refused proposal and again fails the projection intersection requirement.
There are no swept path illustrations of car parking manoeuvrability provided.
The proposed development Refuse & Recycling is located on the front forecourt, in front of the Building Line and not integrated within the Building envelope, and therefore fails to meet the Refuse & Recycling Policy as required of the Revised Local Plan Policy.
The proposed application Housing Density at 52.36Units/ha places the appropriate Area Type Setting required at a “Suburban Setting” when the Area Type Setting for the locality as defined by the Local Post Code CR0 7PX is 11.43Units/ha which is actually “<Outer Suburban” Area Type Setting with a Low PTAL of 1a.
The proposal would present a 358.09% increase in Density from the Local Post Code Housing Density as assessed and in accordance with the National Model Design Code & Guidance.
The Post Code Residential Density for this locality CR0 7XP is 21.81bs/ha (≈22) but the actual proposal Residential Density is 165.79bs/ha, an enormous 654.54% increase on the Post Code Density for the Area; i.e., this density would be more appropriate in a “Urban” Area Type Setting, than an “<Outer Suburban” Area Type Setting.

Permission Refused

Reason(s) for refusal :-

The quality of accommodation, by virtue of the absence of a window for a bedroom within Unit 2 and the lack of through-route to the rear amenity space, would result in sub-standard residential units contrary to Policy D6 of the London Plan (2021) and Policy DM10 of the Croydon Local Plan (2018).
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).
The proposal by reason of its scale, bulk, and massing would result in loss of light and would have an 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).
The proposal does not provide sufficient details on the modified access, in terms of details and dimension, visibility splays, and a swept path analysis. The car parking is sub-standard and falls short of the required provision, and the cycle parking is not acceptable, due to the stand type. The proposal 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).
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 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).

MORA Submission: 11^th Jan 2023
Consultation Closes: 20^th Jan 2023
Target Decision: 1^st Feb 2023
• Total Consulted: 8
• Objections: 44
• Supporting: 0
Permission Refused: 21^st Feb 2023

Further developments are in the March 2023 Planning Report.

21 Woodmere Gardens – Ref: APP/L5240/W/22/3298225
Demolition of single-family dwelling and garage and the erection of 3 x two storey terraced houses with accommodation in the roof space, with 3 off street car parking spaces and a detached 2-storey building with accommodation in the roof space, comprising of 6 self-contained apartments with integrated bike and refuse stores and 6 off street car parking spaces.

We objected to the proposed development on the grounds that:

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

Permission Refused

Reason(s) for refusal :-

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

MORA Submission: 16^th Aug 2021
Consultation Closes: 25^th Aug 2021
Target Decision: 22^nd Sep 2021
• Total Consulted: 9
• Objections: 9
• Supporting: 0
Councillor referral: Councillor Richard Chatterjee (31^st Aug 2021)
Permission Refused: 28^th Mar 2022
Appeal Notice: 5^th May 2022
MORA Appeal Submission: 10^th Oct 2022
Appeal Dismissed: 14^th Feb 2023

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

We objected to the proposed development on the grounds that:

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

MORA Submission: 25^th Jun 2021
Consultation Closes: 8^th Jul 2021
Target Decision: 14^th Jul 2021
• Total Consulted: 4
• Objections: 33
• Supporting: 0
Councillor referral: Councillor Sue Bennett (26^th Jul 2021)
Not Determined Decision: 1st Feb 2023

67 Orchard Avenue – Ref: 22/03552/FUL
Demolition of the existing dwelling and erection of a two-storey building with accommodation in the roof space containing 6 flats with associated access, parking, landscaping, cycle and refuse storage facilities.

We objected to the proposed development on the grounds that:

We challenge the actual Site Area as listed on the Application Form which does not align with an assessment of the Site Area measurement using Google Earth polygon measurement of the boundary as shown in our evaluation at para. 1.1 (see our submission).
The difference between the stated Site Area of 700sq.m. and the measured Site Area of 607.77sq.m. is 92.23sq.m. and illustrates a probable decrease in Area of 92.3sq.m. i.e., a Percentage of decrease = |700 – 607.77|/700 = 92.23/700 = 0.1318 = 13.18% from that stated.
We would suggest that this exaggeration of Site Area by 92.3sq.m. is significantly decreased at 13.18% and may have been intentional by the developer to infer a higher than available Site Capacity or may be a valid mistake.
It is suggested that the Case Officer challenges the developer to supply an accurate value of Site Area or requires a surveyor’s report to determine the actual Site Area to ensure a correct assessment of the Site Capacity in the evaluation of the proposal before making a recommendation.
The proposal fails to follow the existing Building Line Set Back as the Northern extended Bedroom 3 of Flat 1 extends in front of the existing established Building Line set-back. Therefore, the proposal fails to meet the requirement to respect the existing Building Line Set Back as defined by the National Model Design Code & Guidance.
From the Planning Statement and Floor Plans, it is assumed that all Units are M4(2) compliant and there is no specifically designed unit to M4(3) Building Regulation compliance as no unit has wheelchair storage facility over and above the required “In-Built” Storage requirement as defined in the London Plan Table 3.1.
We are of the view that at 6 Units, one should be wheelchair user friendly to M4(3) compliant and provide wheelchair storage space.
The proposal does not meet the London Plan Policy D3 requirement for a Design Led Approach or meet the National Model Design Code Guidance in any respect and has not considered whether the proposal is within the Capacity of the Site. We have assessed the Local Design Code parameters in accordance with the National Model Design Code & Guidance and found the proposal does not comply with this guidance.
We have assessed the Floor Area Ratio in accordance with the National Model Design Code & Guidance which exceeds the recommended value which should be less than (<) 0.5 i.e., GIA/Site Area in both the Applicant’s quoted Site Area and the Google Earth assessed Site Area. This is further evidence of over-development based upon the National Model Design Code.
Our analysis shows that the Site Area Residential Densities would exceed the equivalent Residential Density of Outer and Suburban Settings and would be more appropriate in an Urban Area Type Setting Range with a Google Earth assessment of Site Area into the highest Central Area Type setting Range.
We have evaluated this provision in the Outer Suburban, Suburban and Urban Ranges and have established that the required supporting PTAL is either 4.9 for a Residential Density with Site Area to the Application Form, or a PTAL of 6.6 for the Site Area as calculated by Google Earth. This is conclusive evidence that the available existing PTAL of 1b ≡ 1.33 is inadequate to support future occupants of this proposal.
We have assumed levels of densification to be ⅓ above the Setting of “Outer Suburban” so “Gentle” Densification would therefore be 26.67u/ha. However, the actual densification would be 221.37% increase for the Applicant’s Site Area or 270.15% increase for the Site Area as measured by Google Earth. Both these assessments conclusively prove the proposal would have a significantly increased densification above what would be considered “Gentle” and would exceed the Area Type Settings and place the proposal appropriate
for an Urban Setting which is inappropriate for this proposal.
There is no provision for Communal Open Space for the future occupants of the development which is non-compliant to the emerging Croydon Local Plan requirement of 50sq.m. for developments exceeding 5 Units.
The Play Space for children of the proposed development offered is 20sq.m. when the Policy is for 10sq.m. per child and the proposed development would likely accommodate 6 children requiring 60sq.m. Play Space. As such, the proposed development is deficient by 40sq.m. Play Space for future children of the occupants of the proposed development.
The second-floor balconies of Flats 5 & 6 allow partial overlooking of the rear gardens of 65 & 67a Orchard Avenue even though provided with side elevation ‘privacy screening’ over the depth of the balconies.
67 Orchard Avenue has TfL PTAL at 1b which is low. The Croydon Plan would require up to 7 car spaces and the London Plan would require up to 9 Car Spaces when the offered development has capacity for 6 parking spaces. This is unacceptable at this location as Orchard Avenue is a busy link between the A232 and A222 and Woodland Way to the rear is only 4.8m wide and unsuitable for overspill parking for 3 Vehicles.

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Permission Refused

Reason(s) for Refusal:-

The proposed development and its refuse store would be detrimental to the character of the area by reason of the size, massing, siting and design and would thereby conflict with the DM10, DM13 and SP4.1 of the Croydon Local Plan (2018) and D3 and D4 of the London Plan (2021).
The proposed development, by way of its excessive scale and close proximity to nearby properties and their gardens, would cause harm to neighbouring living conditions through the creation of a sense of enclosure and overbearing mass. The development therefore conflicts with Policy D3 of the London Plan (2021) and Policy DM10 of the Croydon Local Plan (2018).
The development due to the absence of a Flood Risk Assessment and the incorporation of sustainable urban drainage systems in the design has failed to adequately safeguard this or surrounding sites from surface water flooding. The development conflicts with policy DM25 of the Croydon Local Plan (2018) and policy SI13 of the London Plan (2021)
The loss of soft landscaping and excessive proposed hardstanding would be harmful to the amenity of the streetscene and local character; and to biodiversity which fail to comply with Policies G7 of the London Plan 2021 and Policies DM10.8, SP7, DM27 and DM28 of the Croydon Local Plan 2018.
In the absence of a legal agreement, to secure measures to mitigate the impacts of the development as a consequence of demands created by the proposed development, the proposal would fail to mitigate harmful impacts and would be unacceptable in planning terms. The proposal therefore conflicts with T6 of the London Plan (2021) and Croydon Local Plan 2018 policies SP6, DM29 and DM30.

MORA Submission: 20^th Sep 2022
Consultation Closes: 23^rd Sep 2022
Target Decision: 19^th Oct 2022
• Total Consulted: 11
• Objections: 33
• Supporting: 0
Councillor referral: Councillor Richard Chatterjee (5^th Oct 2022)
Permission Refused: 31^st Jan 2023

Further developments are in the February 2024 Planning Report.

Awaiting Decision

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: 7^th Jan 2023
Consultation Closes: 16^th Jan 2023
Target Decision: 8^th Feb 2023
• Total Consulted: 11
• Objections: 53
• Supporting: 2

Further developments are in the March 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: 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)

Flyer for download and social media sharing.

Further developments are in the March 2023 Planning Report.

Appeals Pending

46 The Glade – Ref: 22/03970/FUL
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: 27^th Oct 2022
Consultation Closes: 30^th Oct 2022
Target Decision: 21^st Nov 2022
• Total Consulted: 12
• Objections: 5
• Supporting: 0
Appeal Notice: 30^th Nov 2022

Further developments are in the March 2023 Planning Report.

44 Orchard Avenue – Ref: 22/02015/FUL
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

Further developments are in the March 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: 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

Further developments are in the March 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 :-

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

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

Further developments are in the March 2023 Planning Report.

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

We objected to the proposed development on the grounds that:

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

Permission Refused

Reason(s) for Refusal:-

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).
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).
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).
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).
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 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).
The proposal fails to provide information to address fire safety, which is contrary to policy D12 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 G6 of the London Plan (2021) and Policy DM27 of The Croydon Local Plan (2018).

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

Further developments are in the March 2023 Planning Report.

46 The Glade – Ref: 22/01881/FUL
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: 8^th Jun 2021
Consultation Closes: 9^th Jun 2022
Target Decision: 1^st Jul 2022
• Total Consulted: 12
• Objections: 7
• Supporting: 0
Councillor referral: Councillor Sue Bennett (10^th Jun 2022)
Appeal Notice: 25^th Aug 2022

Further developments are in the March 2023 Planning Report.

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

Further developments are in the March 2023 Planning Report.

Additional Matters

Planning Advisory Service Peer Review

MORA had been involved in a Planning Advisory Service Peer Review, held on 22^nd June, 2022.

They have now published their report on the Croydon Council website for discussion at Cabinet on Feb 22.

The links for reference are below:

Click here for the Agenda for the Feb 22 Cabinet Meeting

Click here for the Croydon Development Management Processes Review

Click here for the Planning Peer Challenge Feedback Report

Click here to read the Planning Transformation Acton Plan

Community Engagement (Community Involvement) – Revised Local Plan
The NPPF and other guidance from Government requires Local Planning Authorities to “engage” with local Community Groups to discuss and agree ‘Plan Making’ and ‘Local Design Codes’ for Area Type Settings appropriate for their localities.

It is reasonable for this local “involvement” to be prior to the final draft of the Revised Local Plan rather than after publication or during a later consultation period.

We wish to constructively contribute to the production of the Revised Local Plan and to that end we have prepared the attached three discussion papers; the first relates to defining local Area Design Codes & Area Type Settings; the second relates to the assessment of development proposals Site Capacities; and the third relates to the assessment of ‘Growth’; (Regeneration, Densification & Intensification).

These documents have been approved by our committee and is endorsed by the Chair of the Shirley Planning Forum (SPF) Trevor Ashby, as our joint contribution to the LPA under the terms of Croydon’s approach to ‘Plan Making’ consultations “Community Involvement” at para 2.10.

For clarification we quote relevant phrases of Para 2.10:
2.10 “… Furthermore, the Council is committed to meeting the needs of all stakeholders to encourage greater participation in the planning process.

Croydon intends to achieve effective community involvement in the creation of development plans by:
• Enabling the community and stakeholders to put forward their own ideas and to participate in the development of options and proposals rather than simply commenting on Council generated ideas
• Investigating community and stakeholders’ problems, needs, and concerns at the earliest possible stage
• Offering an opportunity for the community and stakeholders to respond to, comment upon, criticise and support policies and proposals.”

We have significant concerns relating to the current and proposed definitions of these Planning Policies for application determinations in our locality which we would like to constructively debate and resolve.

DEREK RITSON
MORA Planning

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Planning Sub-Committee Meeting (9th Mar 2023)

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Decided

Awaiting Decision

Appeals Pending

Applications

Planning Sub-Committee Meeting (9th Mar 2023)

New

Decided

Awaiting Decision

Additional Matters

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Planning Sub-Committee Meeting (9^th Mar 2023)

Planning Sub-Committee Meeting (9^th Mar 2023)