Planning Report – July 2022

Applications

Additional Matters

Croydon Local Plan Review Reassessment – MORA Statement to the Mayor of Croydon, Jason Perry
Planning Advisory Service Peer Review
Croydon Draft Revised Local Plan – Latest News

Applications

Decided

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

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

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

On 26^th April amended drawings were uploaded to the online register.

Revised planning application involves reducing the dwellings from 9 to 8 and a new site layout. Swept path access diagrams are also provided.

Our Addendum from the amended drawings has revised our stance from neutral to an objection based on the grounds that:

There remain a number of requirements identified at the Pre-Application discussions of 4th November 21 which have not been addressed or resolved.
Although this may be a civil rather than a planning matter, the ownership and legal access to rear gardens from the access lane from Firsby Avenue should be addressed and resolved preferably prior to a determination.
It is also unclear whether permission to refurbish and strengthen the access drive to sustain regular heavy Refuse or other large vehicles traversing, is required by these third parties as access to their properties from the access lane would be restricted during any major refurbishment or reconstruction works to the said access lane during the period of any such major works.
The upgrade of the access lane to support the heavy duty refuse and other vehicles requires to be to the appropriate Road Specification and that detail and requirement is not included in the amended drawings.
There is no recognition of safety factors for pedestrians, pushchairs or disabled wheelchair users in the face of oncoming vehicles using the access lane.
There is no segregated pedestrian access along the access lane.
There is no perceptible increase in the width of the Access Lane from that previously proposed.
The swept path illustrations assume that the full widths of Verdayne/Firsby Avenues are available when there are no enforced parking restrictions, other than the disabled bay fronting #3 Firby Avenue. Parking fronting dropped kerbs is not enforced by the Council and therefore is regularly ignored by visiting drivers
The dropped kerb access to the Lane may require widening at the entrance to the access Lane, but there are no proposals to do so.
We therefore believe there is sufficient evidence to Object to this proposal on the grounds that inadequate consideration has been given to these issues, some of which were the subject of the pre-application discussions and recommended requirements.
The occupancy of this proposal is 5.75 persons per unit, However, based on the national average occupancy of 2.39 person/unit the Residential Density analysis shows that the required PTAL to support a proposed Residential Density of 252.230 hr/ha would be ≈3.07 or, Residential Density of 227.50 bedspaces/ha would be ≈2.33.
However, the average occupancy of the proposal is =46/8 = 5.75 Persons/Unit which is (5.75-2.39)/2.39 = 140.5% increase in occupancy above the national average.
We therefore object to the amended proposal on the grounds of high Residential Density requiring an equivalent Area Type Urban Setting overdevelopment for the locality at PTAL 2 when the required supporting Public Transport Accessibility for this Residential Density would require a PTAL exceeding 3 and an Area Type Urban Setting when the locality is overwhelmingly an Outer Suburban Area Type Setting.

MORA Submission: 29^th Dec 2021
Consultation Closes: 20^th May 2022
Target Decision: 28^th Jan 2022
• Total Consulted: 58
• Objections: 69
• Supporting: 0
Councillor referral: Councillor Sue Bennett (21^st Dec 2021)
MORA Addendum: 16^th May 2021
Planning Committee Slot: 14^th Jul 2022
Permission Granted: 14^th Jul 2022

Further developments are in the August 2022 Planning Report.

St. George’s Church – Ref: 22/01924/FUL
Erection of a single storey extension with a maximum height of 4.96 metres to the northern elevation of the Church to provide a new annexe to St. George The Martyr with associated internal and external alterations.

Permission Refused

Reason(s) for Refusal:-

The siting of the proposed development would not protect or conserve the particular interest that led to the designation of this building on the Local List of buildings of special architectural or historic interest and would thereby conflict with Policy D3 and HC1 of the London Plan 2021, Policies SP4, DM10 and DM18 of the Croydon Local Plan 2018 and the provision of the National Planning Policy Framework.
The proposed development would be detrimental to the amenities of the occupiers of adjoining property by reason of its size and siting resulting in visual intrusion and would thereby conflict with Policies D3 of the London Plan 2021, Policy DM10 of the Croydon Plan 2018 and the Suburban Design Guide Supplementary Planning Document 2019.
The applicant has failed to demonstrate that the proposal would not lead to the loss of the boroughs valued woodlands, trees and hedgerows contrary to Policy G7 of the London Plan 2021 and Policy DM28 of the Croydon Plan 2018.
The development fails to demonstrate how it would ensure the safety of all buildings users in relation to fire, thereby conflicting with Policy D12 of the London Plan 2021.

Consultation Closes: 13^th May 2022
Target Decision: 4^th Jun 2022
• Total Consulted: 21
• Objections: 1
• Supporting: 1
Permission Refused: 14^th Jul 2022

Further developments are in the August 2022 Planning Report.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Permission Refused

Reason(s) for Refusal:-

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

MORA Submission: 29^th Apr 2021
Consultation Closes: 15^th May 2021
Target Decision: 25^th May 2021
• Total Consulted: 105
• Objections: 44
• Supporting: 0
Councillor referral: Councillor Richard Chatterjee (26^th May 2021)
Permission Refused: 14^th Jul 2021
Appeal Notice: 24^th Aug 2021
Appeal Representations: 28^th Feb 2022
MORA Appeal Submission: 4^th Feb 2022
Appeal Dismissed: 27^th Jun 2022

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

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

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

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

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

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

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

Permission Refused

Reason(s) for refusal :-

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

MORA Submission: 3^rd Mar 2021
Consultation Closes: 26^th Mar 2021
Target Decision: 14^th Apr 2021
• Total Consulted: 28
• Objections: 1
• Supporting: 0
Permission Refused: 14^th Apr 2021
Appeal Notice: 21^st Jul 2021
Appeal Representations: 23^rd Feb 2022
MORA Appeal Submission: 18^th Feb 2022
Appeal Dismissed: 20^th Jun 2022

Further developments are in the September 2022 Planning Report.

Awaiting Decision

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.

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)

Further developments are in the August 2022 Planning Report.

19 Orchard Avenue – Ref: 22/02202/FUL
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.

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)

Further developments are in the August 2022 Planning Report.

34 Woodmere Avenue – Ref: 22/01806/FUL
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.

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)

Further developments are in the August 2022 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.

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)

Further developments are in the August 2022 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 2021)

Further developments are in the August 2022 Planning Report.

187 Shirley Road – Ref: 22/01185/FUL
Conversion of the Property to 5 Self-contained Flats, the Construction of a Ground Floor Rear Extension and Associated External Alterations

We objected to the proposed development on the grounds that:

There is confusion between the Design & Access Statement Schedule at Para 8 “Housing Type and Mix” and to provided Plans in that the accommodation schedule shows Unit 1 as 2b4. Unit 2 as 3b4p and Units 3. 4 & 5 to be 1b1p whereas the Plans show Units 3, 4 & 5 to have Bed sizes appropriate for two individuals (1.4m wide). This increases the occupation from 11 to 14 bedspaces and thus persons. As a consequence of this confusion, the Gross Internal Area (GIA) required increases from 37sq.m. to 59 sq.m. which the offered proposal does not now meet. Unit 3 GIA offered is 40.5 sq.m. Unit 4 GIA offered is 44 sq.m. and Unit 5 GIA offered is 42.8 sq.
In addition, the Unit 1 under stairs In-Built storage Space area is not stated and could be limited by height restriction and not meet the required 2 sq.m. Units 2 to 5 do not have any In-Built Storage capacity identified on the floor plans and therefore are NOT compliant to the London Plan D6 Table 3.1 requirement.
Units 3 and 4 have NO Private Amenity Space provision in the form of Balconies or Terraces.
As the proposal offers 2 parking spaces, there needs to be 2 or 3 overnight overspill parking on adjacent side roads. As Shirley Road is a major A232 dual carriageway with, restricted parking RED Route, it is inappropriate for on-street parking. The nearest side street is Valley Walk, and overspill parking is already an inconvenience to residents of Valley Walk nearest to Shirley Road.

MORA Submission: 20^th Jun 2021
Consultation Closes: 26^th May 2022
Target Decision: 16^th Jun 2022
• Total Consulted: 12
• Objections: 4
• Supporting: 0
Councillor referral: Councillor Sue Bennett (23^rd Jun 2022)

Further developments are in the August 2022 Planning Report.

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

Consultation Closes: 27^th Apr 2022
Target Decision: 17^th Mar 2022
• Total Consulted: 34
• Objections: 2
• Supporting: 0

Further developments are in the August 2022 Planning Report.

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

We objected to the proposed development on the grounds that:

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

MORA Submission: 11^th Apr 2021
Consultation Closes: 17^th Apr 2022
Target Decision: 19^th Apr 2022
• Total Consulted: 25
• Objections: 42
• Supporting: 0
Councillor referral: Councillor Sue Bennett (30^th Mar 2021)

Further developments are in the August 2022 Planning Report.

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

We objected to the proposed development on the grounds that:

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

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

Further developments are in the August 2022 Planning Report.

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

We objected to the proposed development on the grounds that:

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

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

Flyer for download and social media sharing.

Further developments are in the August 2022 Planning Report.

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

We objected to the proposed development on the grounds that:

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

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

Further developments are in the August 2022 Planning Report.

Appeals Pending

34 Woodmere Avenue – Ref: APP/L5240/W/22/3293208
Demolition of the existing property and the erection of two storey terraced houses with accommodation in the roof space, comprising six dwellings with six off street car parking spaces.

We objected to the proposed development on the grounds that:

This proposal, and the cumulative Cluster of Developments in the vicinity of 34 Woodmere Avenue, should be evaluated and considered as a whole as the combined increase in population has implications on the supporting infrastructure sustainability, which is a legal requirement of local planning authorities, serving all the new developments and for the existing residents. This additional proposal would result in a local Population Density of 421.35 residents per hectare, which is a 364.542% increase for the Shirley North Ward, from the 2021 Average Density of 56.806 Residents per hectare for the Shirley North Ward Based upon GLA Data and for the The London Plan Policy H2 Small Site para 4.2.4 limitations of ‘inappropriate’ “Incremental Intensification”.
The recent cumulative cluster of developments in the vicinity of 34 Woodmere Avenue, and including this proposal, all within ≈100m radius and within an area of ≈3.14ha, and all at a PTAL of 1a has and will completely changed the Character of this locality from single dwelling households with associated gardens to blocks of multiple dwelling flats and terraced houses in an area NOT subject to “incremental Intensification” as defined by the London Plan Policy para 4.2.4
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.
There is also lack of stated ‘minimum’ required built-storage capacity for future occupants which, by its omission is further proof of over development. The applicant would have difficulty squeezing all these requirements into the Site Area and straightening the curtilage boundaries, meet all the minimum space standards and design requirements within the site constraints. Although the rear gardens meet the required amenity space standards, they are extremely small compared to the local character of rear gardens generally across the Ward.
The Front curtilage boundary between Units 1 & 2 and Units 4 & 5 are configured slightly to encroach in what would normally be considered within the front curtilage of Units 1 (for unit 2) and Unit 4 (for Unit 5). It is appreciated that this arrangement is necessary to provide adequate Refuse Bin Storage and Parking Provision areas for Unit 2 and Unit 5 within the forecourts, but it provides further evidence that the site is over developed as the Boundary curtilages would normally follow the building line unit separation boundary projected into the front forecourt as is shown with the rear garden unit separation boundaries.
The proposed development Parking Bays are configured North/South on the forecourts of all units and if vehicles are parked in a forward direction will be required to exit in a reverse gear with minimal visibility of any pedestrian or road traffic in the path of the reversing vehicle.

Permission Refused

Reason(s) for refusal :-

The proposed development, by reason of scale, massing, poor elevational composition, materials and detailing would result in an unsightly, dominant and imposing form of development which would fail to integrate successfully in townscape terms or make a positive contribution to the setting of the local character and immediate surroundings contrary to Policies D4, D8 of the London Plan 2021 and SP2, SP4, DM10 of the Croydon Local Plan 2018 and the Council’s Supplementary Planning Document Suburban Design Guide (SDG) 2019.
The proposal by reason of its massing and proximity close to neighbouring properties in Pipers Garden and nos.30 and 32 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.32 and would be contrary to policy DM10 of the Croydon Local Plan 2018, Policies D3 and D6 of the London Plan and the Suburban Design Guide SPD (April 2019).
The proposed development would result in unacceptable standard of accommodation by reason of limited external amenity space for the houses, poor access arrangement, and no details in terms of sufficient fire safety measures, thereby conflicting with Policy DM10 of the Croydon Local Plan 2018, Policies D5, D6, D7, D12 of the London Plan 2021 and the Suburban Design Guide SPD (April 2019).
The proposed development would result in the avoidable loss of a Yew tree (T2) and officers are concerned over the impact the proposal would have on a further Pine tree (T3) both of which offer good prominent visual amenity value, are considered to be of long life expectancy and make a contribution to the character of the area thereby conflicting with policy DM28 of the Croydon Local Plan 2018.
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).
The proposed development would result in inappropriate cycle storage facilities by reason of design and position to one of the houses, does not provide sufficient detail to demonstrate inclusion of electrical vehicle charging points or blue badge parking and would therefore be contrary to Policies, 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: 21^st May 2021
Consultation Closes: 4^th Jun 2021
Target Decision: 24^th Jun 2021
• Total Consulted: 18
• Objections: 12
• Supporting: 0
Councillor referral: Councillor Sue Bennett (3^rd Jun 2021)
Permission Refused: 21^st Jan 2022
Appeal Notice: 4^th May 2021
MORA Appeal Submission: 20^th May 2022

Further developments are in the August 2022 Planning Report.

46 The Glade – Ref: APP/L5240/W/22/3295431
Demolition of a single storey dwelling and redevelopment with a new building to provide 9 dwellings (Class C3), with associated amenity space, integral refuse, cycle stores and external car parking.

We objected to the proposed development on the grounds that:

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

Permission Refused

Reason(s) for refusal :-

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

MORA Submission: 13^th Dec 2021
Consultation Closes: 23^rd Dec 2021
Target Decision: 11^th Jan 2022
• Total Consulted: 14
• Objections: 12
• Supporting: 0
Councillor referral: Councillor Sue Bennett (21^st Dec 2021)
Permission Refused: 3^rd Feb 2022
Appeal Notice: 23^rd Mar 2021
Appeal Representations: 30^th Jun 2022
MORA Appeal Submission: 10^th Jun 2022

Further developments are in the August 2022 Planning Report.

Additional Matters

Croydon Local Plan Review Reassessment – MORA Statement to the Mayor of Croydon, Jason Perry

MORA has presented a Strategy Paper to the Mayor detailing two fundamental issues relating to Local Plan Policies on “Growth” and Targets.

The Executive Summary of the Paper is as follows:

It is understood that the Elected Mayor, Jason Perry, has indicated a reassessment of Planning Policy is high on his priority of actions and has concerns relating to the Supplementary Planning Document (SPD2). However, the crucial issues of concern are Policies in the Revised Croydon Local Plan.

As an active Residents’ Association, without being too presumptuous, we would like to contribute to this reassessment and highlight crucial issues which we believe require modification to reflect the latest National Guidance.

We assess the crucial issues as:

The deficiencies of the specified “Growth” Policies definition.
The deficiencies of the Management and Monitoring of the Croydon Place “Targets.”

In the following submission, I explain the deficiencies in these policies in detail and propose alternative solutions. These issues were raised in our response to the Jan/Feb consultation, but the revised Local Plan document published on the Council Website does not acknowledge these identified deficiencies or consider our suggested modifications or clarified the Policies in any way.

The structure of this paper evaluates the current adopted Local Plan and the Revised Croydon Local Plan and relates those Revised Policies to those defined in the NPPF (July 2021) with references, and the adopted London Plan (March 2021).

Read our submission to the Mayor in full here. We sent this submission on the 4^th June and will await a response.

Planning Advisory Service Peer Review

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

Peer team members included:
Peter Ford from the Planning Advisory Service and
Shelly Rouse from the Planning Advisory Service
Cllr Ian Ward from Birmingham City Council and
Marilyn Smith from the London Borough of Barking and Dagenham.

Representatives from other Residents’ Associations including H.O.M.E (Havelock Rd, Outram Rd, Mulberry Lane, Elgin Road) Addiscombe RA, Coulsdon RA, Norwood RA, and Riddlesdown RA also attended.

To summarise the Review – some of the issues raised were of Councillors on the Planning Committee requiring more training, the LPA’s dismissive attitude towards Residents’ Associations, biased decisions and Officer and Developer relationships, and also the issues of lack of enforcement and backlogs were raised.

MORA raised the issue of our Local Plan being out of step with the National Guidance and the London Plan with regard to London Plan Design-Led Approach policies available in early 2021 and the National Model Design Code & Guidance available in January 2021 both omitted from our Local Plan. Also, that Officers had no credible concept of a development’s Site Capacity to fit in the building, the parking and amenity space with an available site capacity in relation to the local setting or Area Type.

MORA stated that there are no credible distinctions between the intensification designations and officers had no concept of the difference. We had developments in an outer suburban location which were more appropriate to a Central Location.

MORA also raised the issue of Targets not being monitored and that we had met our 20-year target for the Shirley “Place” in our RA area in three years.
We also mentioned that we had raised these issues with the Mayor.

The Planning Advisory team were interviewing others over the next few days and would then give a verbal report to senior Planning management. They will then publish their report within 3 to 4 weeks with their recommendations and the London Borough of Croydon are encouraged to display it on their website. Councils are not duty bound to accept the recommendations, but it is ‘frowned’ upon if they don’t.

Further developments are in the August 2022 Planning Report.

Croydon Draft Revised Local Plan – Latest News

The recently Elected Mayor of Croydon, Jason Perry, has officially removed SPD2 (Croydon Suburban Design Guide Supplementary Planning Document) from Planning Guidance.

The Revised Croydon Local Plan is also being reviewed and we will update you on the progress in due course.

Further developments are in the August 2022 Planning Report.

DEREK RITSON
MORA Planning

< June 2022 Planning Report

August 2022 Planning Report >

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