Planning Report – June 2019

Applications

Planning Committee Meeting (20th June)
Ongoing

Planning Complaints

Additional Matters

Policies

Applications

Planning Committee Meeting (20th June)

32 Woodmere Avenue – Ref: 19/00783/FUL
Demolition of the existing property and the erection of a replacement detached two storey building with accommodation in the roof-space, comprising 7 self-contained flats (2 x 1 bedroom, 3 x 2 bedroom and 2 x 3 bedroom) with 5 off street car parking spaces, bike store, integrated refuse store and site access.

Although the proposed development presented is architecturally acceptable the proposal fails on a number of design requirement Planning Policies which results in an overdevelopment of the proposal for the locality and would not provide acceptable living conditions for future occupants. We therefore objected to this proposed development on grounds of over-development and non-compliant to the current adopted London Plan Policy 3.4 Optimising Housing Potential due to excessive Residential Density of 350hr/ha and excessive Housing Density 116.67 u/ha at a locality of PTAL 1a. without justification.

MORA Objection sent: 14th Mar 2019
MORA Objection (Amended Drawings) sent: 28th May 2019
Consultation Close: 24th Mar 2019 – Extended to 30th May 2019
Target Decision: 16th Apr 2019
• Total Consulted: 42
• Objections: 25
• Supporting: 0
Councillor referral: Councillor Richard Chatterjee (29th Mar 2019)
Case Officer Report recommends: Grant Approval
Planning Committee Slot: 20th Jun 2019
Permission Granted: 20th Jun 2019

Further developments are in the July 2019 Planning Report.

Pegasus (18a) Fairhaven Avenue – Ref: 19/01761/FUL
Demolition of existing dwelling and erection of a 3-storey block, containing 2 x 3 bedroom, 6 x 2 bedroom and 1 x 1-bedroom apartments with associated access, 9 parking spaces, cycle storage and refuse store.

Although the proposed development presented is architecturally acceptable, the proposal fails on a number of design requirement Planning Policies which are unacceptable for future occupants for the life of the development.

We objected on grounds of over-development and non-compliance to the London Plan Policy 3.4. The proposed development does not fully meet the minimum space standards as required by the London Plan Policy 3.5. The width of the access drive is unacceptable and fails to meet the requirements of SPD2 guidance.

We also objected to this proposed development on grounds of inadequate parking provision and non-compliance to the London Plan Policy 6.13 and London Plan Policy 6.11. We objected to the proposed development on grounds that it does not meet the 45° Rule on height as measured from the adjacent dwelling ground floor window as required by the recently adopted Supplementary Planning Document SPD2. We objected to this proposed development on significant issues relating to Refuse Storage facilities on grounds that it does NOT fully meet the requirements of Policy DM13.1, DM13.2 on Refuse and Recycling or requirement of BS 5906:2005.

MORA Objection sent: 8th May 2019
Consultation closes: 17th May 2019
Target Decision: 7th Jun 2019
• Total Consulted: 29
• Objections: 21
• Supporting: 0
Councillor Referral: Councillor Richard Chatterjee (23rd May 2019)
Case Officer Report recommends: Grant Approval
Planning Committee Slot: 20th Jun 2019
Permission Granted: 20th Jun 2019

Further developments are in the July 2019 Planning Report.

Ongoing

14-16 Woodmere Close – Ref: 19/01484/FUL
Erection of 1 two storey dwelling located to rear of No’s 14 and 16 Woodmere Close
New application in the rear gardens of 14 & 16 Woodmere Close adding to the new estate at the back gardens of Woodmere Close. This would be the last one in this series. It is likely to meet all planning policies as all previous applications for this site has met planning policies.

Consultation closes: 31st May 2019
Target Decision: 2nd Jul 2019
• Total Consulted: 28
• Objections: 5
• Supporting: 0

Further developments are in the July 2019 Planning Report.

Sandrock Pub – Ref: 19/01134/FUL
Erection of two storey side/rear extension to The Sandrock Public House and use of first floor as 1 x two bedroom flat for staff accommodation. Erection of a three/four storey building to rear of pub comprising 19 flats (7 x one bedroom, 6 x two bedroom and 6 x three- bedroom flats) with associated car parking, cycle and refuse storage and landscaping.

We objected on the grounds that the proposal is an over-development for the area, which compromises the London Plan Policy 3.4.

The proposed development’s massing and height do not reflect the local character and roof forms of the surrounding locality and does not comply fully with minimum spaces standards for new dwellings or fully comply with the required amenity space standards.

The development does NOT meet the Strategic Policy DM1, and is non-compliant to Croydon Plan Policy DM1. The development is non-compliant to the Croydon Plan Design and Character policies of DM10 and is non-compliant to Policy DM10.4 e).

The proposal’s Refuse Storage facilities do not meet the required capacities for refuse bins and does not give adequate manoeuvrability space for operatives to access and remove refuse and recycling bins safely. The proposal has insufficient car parking space, and there would be major overlooking and invasion of privacy to the occupants of neighbouring properties.

MORA Objection sent: 24th Apr 2019
Consultation closes: 10th May 2019 – Extended to 31st May 2019
Target Decision: 16th Jul 2019
• Total Consulted: 82
• Objections: 153
• Supporting: 0
Councillor Referral: Councillor Jason Cummings (15th May 2019)

Further developments are in the July 2019 Planning Report.

17 Orchard Avenue – Ref: 19/00131/FUL
Demolition of existing detached house, erection of 2- storey building with further floor of accommodation in roof-space comprising 1 x 1 bedroom flat, 3 x 2-bedroom flats and 1 x 3 bedroom flat, formation of vehicular access and provision of 4 associated parking spaces and refuse storage.

We objected on the grounds that the proposal does not meet London Plan Policy 3.5 minimum space standards for new dwellings and is non-compliant to Policy DM10.4 Private Amenity Space.

SPD2 Para 2.29 requires Height of projection of neighbouring properties should be no greater than 45° as measured from the Centre of the closest habitable room on the rear of the neighbouring property. The projected 45° line is not clear of the proposed structure and thus fails the Policy SPD2 45° Rule.

We also objected to this proposal on the grounds that it does NOT meet the requirements of Policy DM13 or Council Guidance on Refuse & Recycling for New Developments.

The proposal is non-compliant to Policy: Shirley Place Homes para 11.200 & Character, Heritage and Design para 11.202, and the policy Shirley Place Transport para 11.205 has NOT been fulfilled.

MORA Objection sent: 3rd Apr 2019
Consultation closed: 10th Apr 2019
Target Decision: 5th May 2019
• Total Consulted: 42
• Objections: 8
• Supporting: 1
Councillor referral: Councillor Richard Chatterjee (16th Apr 2019)
Case Officer Report recommends: Grant Approval

Further developments are in the July 2019 Planning Report.

56 Woodmere Avenue – Ref: 19/01352/FUL
Demolition of a single-family dwelling and erection of a 3- storey block containing 2 x 3-bedroom, 6 x 2-bedroom and 1 x 1-bedroom apartments with associated access, 7 parking spaces, cycle storage and refuse store.

We objected on grounds of over-development and non-compliance to the current adopted London Plan Policy 3.4 Optimising Housing Potential due to excessive Residential Density and excessive Housing Density.

The proposed dwelling does not fully meet the required minimum space standards as required by the current adopted London Plan Policy 3.5, on grounds of inadequate parking provision and non-compliance to the London Plan Policy 6.13 and London Plan Policy 6.11.

We also objected on grounds of non-compliance to Croydon Plan Policy DM10.1 and Para 6.37, and that it does not meet the requirements of Policy DM13 or Council Guidance on Refuse & Recycling for New Developments as published by Croydon Council with regard to Refuse Storage Area Capacity. It is also non-compliant to Policy: Shirley Place Homes para 11.200 & Character, Heritage and Design para 11.202.

MORA Objection sent: 8th Apr 2019
MORA Objection (Amended Drawings) sent: 2nd Jun 2019
Consultation Closes: 18th Apr 2019 - Extended to 20th Jun 2019
Target Decision: 15th May 2019
• Total Consulted: 33
• Objections: 28
• Supporting: 0
Councillor referral: Councillor Richard Chatterjee (23rd Apr 2019)

Further developments are in the July 2019 Planning Report.

Planning Complaints

9a Orchard Rise – Ref: 18/06070/FUL
Demolition of the existing house and office and erection of a two-storey apartment block comprising 4 two-bedroom apartments and 5 three-storey three- bedroom houses, together with associated access and parking.

We objected on grounds of non-compliance with Policy DM25 a) as surface run-off is not adequately managed at the source as required by the policy.

We also objected on grounds of it being inappropriate for the location and Non-Compliant to London Plan Policy 3.5 which requires a presumption against back garden development. London Plan Table 3.3 Minimum Space Standards for new dwellings, storage space; London Plan Policy 7.4 Local Character; Croydon Local Plan Policy DM10 – Design and Character at Policy DM10.1, DM10.2, DM10.5 and DM10.8. Also, on non-compliant to Croydon Local Plan Policies DM13 – Refuse & Recycling at DM13.1 & DM13.2; Policy DM23 – Development and Construction; DM25 – Sustainable Drainage Systems and Reducing Flood Risk and DM27 – Protecting and enhancing our biodiversity. The proposed development has inadequate Fire Precautions as Fire Tenders could not gain access to the site. The proposal Lacks an Ecological and Wildlife Assessment Survey.

MORA Objection sent: 10th Jan 2019
MORA Objection Addendum sent: 25th Jan 2019
Consultation Closed: 30th Jan 2019
• Total Consulted: 59
• Objections: 42
• Supporting: 0
Councillor referrals: Councillor Sue Bennett (25th Jan 2019) & Councillor Richard Chatterjee (25th Jan 2019)
Case Officer Report recommends: Grant Approval
Planning Committee Slot: 21st Mar 2019
Permission Granted: 21st Mar 2019

MORA Stage 1 Complaint(28th Mar 2019) relevant Planning Policies contained in the emerging Supplementary Planning Guidance at Suburban Residential Development SPD2 were NOT adequately considered in the determination of this planning application (Case Number: 4939913).
Stage 1 Response (24th Apr 2019) from Pete Smith, Head of Development Management.
MORA Stage 2 Complaint (1st May 2019)
Stage 2 Response (23rd May 2019) from Shifa Mustafa, Executive Director of Place.
Escalation to the Local Government Ombudsman (4th Jun 2019) Case ID Number 19 000 3809

Further developments are in the July 2019 Planning Report.

Additional Matters

Croydon Council Local Green Spaces Consultation

Croydon Council are asking the public to contribute their views on their Local Green Spaces. The closing date for the survey is midnight, 22nd July 2019.

In order to ensure that your voice is heard, please provide information against one or more of the 79 sites explaining how you use the site, why you value the site, does the site form part of a wider network of open spaces and more. At the end of the 6 week period, all evidence can be collated and can then be attached the completed Evidence and Evaluation document by the Plan-making team.

Further developments are in the July 2019 Planning Report.

Questions to The Mayor of London Sadiq Khan (16th May 2019)
I requested Steve O’Connell (GLA Member Croydon & Sutton) to raise the following questions to the London Mayor at the London Mayor’s Question Time (16th May).

Questions 2 to 7 have been answered (reproduced below) and I have raised supplementary questions on all answered questions and posed one additional question which have been tabled for the next Mayor’s Question Time on 20th June. These were lodged on 4th June.

Removal of density matrix in the new London Plan (1)
Question No: 2019/8973
As Policy D6 of your new draft London Plan does not give clear guidance what densities are acceptable and what densities are not acceptable, Policy D6 does not give any guidance on the actual appropriate densities of proposed developments in relation to the setting or the local PTAL (public transport accessibility level). The policy requires planning officers to assess local development proposals on subjective evaluation of local characteristics and devise their own evaluation criteria. Applicants would not have any guidance on the appropriate densities for a proposed development and therefore the Policy D6 does not reflect para 122 of the National Planning Policy Framework (NPPF).

Therefore, what will planning policy be on managing residential densities of future development proposals, to reflect public transport capacity, if the density matrix is removed from the London Plan?

Answered by The Mayor (21st May 2019)

The current London Plan states that the matrix should not be applied mechanistically, and it is a misconception that the current Plan provides clear guidance on suitable densities. It is a rudimentary tool and the density ranges are very wide. Fifteen years of evidence indicates that the density matrix has provided a poor benchmark or indicator of appropriate densities. Over that period, only 35 per cent of development has been within the density matrix range, whereas 50 per cent of development has exceeded the matrix range for its location and 25 per cent has been double the top end of the range.

Considering London’s housing need, optimising the density of all new development is a strategic matter for London. My draft London Plan explicitly recognises that the appropriate density of a site is an output of a process of assessment, rather than an input. The appropriate density of a site should be arrived at through a design-led approach, taking account of the site context and infrastructure capacity. Paragraph 122 of the NPPF (2019) requires planning policies and planning decisions to support development that makes efficient use of land, taking into account a range of contextual factors. My draft London Plan is consistent with this requirement.

Removal of density matrix in the new London Plan (2)
Question No: 2019/8974
How will applicants or planning officers assess whether proposed developments meet the new NPPF guidance in paragraph 122 part c if and when the London Plan density matrix has been removed?

Answered by The Mayor (17th May 2019)

My draft London Plan explicitly recognises that the appropriate density of a site should be arrived at through a design-led approach, taking account of site context and the capacity of supporting infrastructure, including its existing and planned connectivity by walking, cycling and public transport to jobs and services. In preparing Development Plans, boroughs should plan to meet borough-wide growth requirements, including their overall housing targets, by assessing the capacity of existing and planned physical, environmental and social infrastructure to support the required level of growth and, where necessary, planning improvements to infrastructure capacity through infrastructure delivery plans or programmes to support growth in a timely manner.

Paragraph 122 Part C of the NPPF (2019) specifies that planning policies and planning decisions should take the availability and capacity of infrastructure and services into account. My draft Plan is clearly consistent with this requirement.

Supplementary to Question 2019/8974 for MQT 20th June 2019
Your answer to Question 2019/8974 relating to the Policy D6 using a “design-led-approach” does NOT provide a detailed methodology to evaluate “Site Context” or a methodology to evaluate the “Capacity of Supporting Infrastructure” or a methodology to evaluate the “Planned Connectivity by Walking, Cycling and Public Transport Availability”. These contributing factors are vague and subjective parameter descriptions which would be extremely difficult to define whether a proposal was acceptable or unacceptable as there are no conclusive definitions of the parameters contributing to this “Design-led-approach” criterion or for the analysis of these factors which could indicate whether a proposal was acceptable or otherwise for a specific development proposal at a specific location.
The NPPF para 122 requires Development Plans to take account of the availability and capacity of infrastructure and services and at para 16 d) requires Development Plans should contain policies that are clearly written and unambiguous, so it is evident how a decision maker should react to development proposals.

Policy D6 does NOT meet these requirements.

If it is necessary to produce a detailed supplementary planning guidance to accompany the Plan to provide additional detail on how to effectively optimise the capacity of sites by following the design-led approach, then this is proof that the Policy D6 as stated is inadequate for applicants to establish a suitable proposal of appropriate housing and residential densities for a locality:

        1. How does an applicant establish an appropriate suitable density for a proposed development at a given locality? and
        2. How can community groups assess the acceptability of such proposals?

Removal of density matrix in the new London Plan (3) Question No: 2019/8975
If the London Plan density matrix is removed, what policies will be put in place to mitigate against and over development of a locality which results on local congestion of public transport capacity?

Answered by The Mayor (17th May 2019)

The design-led approach in my draft London Plan requires an assessment of each development site’s context to identify opportunities and constraints that can determine the appropriate built form. My draft Plan is explicit that the density of individual development proposals should be reduced to respond to existing and planned levels of supporting infrastructure, including public transport capacity, where the capacity cannot be sufficiently expanded through the development or through a strategic approach to enhance area-wide infrastructure capacity.

It should be noted that the density matrix in the current London Plan does not mitigate against over-development of a site or locality and that there is nothing inherently sustainable about the numbers in the density matrix. The numbers provide no indication of whether there is enough infrastructure capacity to support the development or not, and they provide no information on the building’s form and whether it will relate well to the surrounding area. The ‘setting’ areas in the matrix cover such large and diverse areas they can’t be used to genuinely ensure the development responds to its context at the site level.

Supplementary Question No: 2019/8975
In response to Question 2019/8975, you state that Policy D6 provides a requirement for an assessment of each development site’s context to identify opportunities and constraints that can determine the appropriate built form and the Plan is explicit that the density of individual development proposals should be reduced to respond to existing and planned levels of supporting infrastructure, including public transport capacity, where the capacity cannot be sufficiently expanded through the development or through a strategic approach to enhance area-wide infrastructure capacity. However, the Policy does not specify any methodology to determine the acceptability or otherwise of these parameters.

How does a Developer or an Applicant assess the appropriateness of these requirements if there is no guidance or methodology to determine these requirements?

New Questions for Mayor’s Question Time on 20th June 2019

        • If the Density Matrix is removed from the Policy and Policy D6 is adopted – how will applicants be able to provide development proposals to meet the Policy if the Supplementary Planning Guidance to accompany the Plan that will provide additional detail on how to effectively optimise the capacity of sites by following the design-led approach, is not published at the same time as the new London Plan is adopted?
        • Will this Supplementary Planning Guidance be included in the Evaluation in Public (EiP) procedures by the Planning Inspectorate?

Removal of density matrix in the new London Plan (4) Question No: 2019/8976
As the draft new London Plan removes the density matrix guidance on setting and PTAL, what guarantees can be given that the replacement Policies for optimising housing densities contained in Policy D6, D2 and D1 will be observed, as the compliance to these policies are very subjective and vague and require local planning authorities (LPAs) to define their own evaluation criteria based on the guidance of these new policies for every planning application that comes before them?

Answered by The Mayor (17th May 2019)

The policies in my draft London Plan set out a clear and systematic approach to assessing development proposals that reflects site specific circumstances. These policies will help boroughs in assessing the optimum density for sites to be allocated in their Local Plans, as well as assessing individual applications. My draft Plan also requires boroughs to proactively establish appropriate site capacity parameters, following the design-led approach, for strategic development sites in their Local Plans. I am currently preparing detailed supplementary planning guidance to accompany the Plan that will provide additional detail on how to effectively optimise the capacity of sites by following the design-led approach.

Supplementary to Question No: 2019/8976
The policies in your draft London Plan do NOT set out a clear and systematic approach to assess development proposals that reflect site specific circumstances. Your answer to Question 2019/8976 indicated that you are preparing detailed Supplementary Planning Guidance to accompany the Plan that will provide additional detail on how to effectively optimise the capacity of sites by following the design-led-approach.

If that is the case doesn’t it prove that Policy D6:

        1. Does not meet the requirements of NPPF para 16 d);
        2. If the Supplementary Planning Guidance is not published at the same time as the New London Plan, how will applicants provide proposals that meet the policy if there is no available guidance between publication of the New London Plan and publication of the Supplementary Planning Guidance;
        3. For London Boroughs to incorporate these requirements in their local plans assumes that they are reviewing their local plans in step with the review of the London Plan and that is not necessarily the case.

Removal of density matrix in the new London Plan (5) Question No: 2019/8977
What monitoring procedures will be put in place to ensure that LPAs do not ignore the requirements of Policy D6, D2 and D1 to maintain appropriate residential and housing densities once the density matrix has been removed from the policy to ensure that appropriate public transport accessibility is maintained?

Answered by The Mayor (17th May 2019)

My draft London Plan is clear that the optimal density of a site should be determined through a design-led approach on a site-by-site basis. The draft Plan requires development proposals to provide a range of measures of density that are more useful than the current single density measure monitored. These include density measures that reflect the number of people or households per hectare, as well as density measures that demonstrate the physical space used (i.e. floor to area ratio, site coverage, and heights). The data I collect through the London Development Database will enable the continued monitoring of development density over the lifespan of the Plan.

Supplementary to Question No: 2019/8977
Your answer to Question 2019/8977 indicated “The draft Plan requires development proposals to provide a range of measures of density that are more useful than the current single density measure monitored. …”

These consist of Policy D6:

Policy D6 paragraph D states:

The following measurements of density should be provided for all planning applications that include new residential units:

1) number of units per hectare
2) number of habitable rooms per hectare
3) number of bedrooms per hectare
4) number of beds-paces per hectare.

What is the methodology to analyse the acceptability or otherwise of these parameters for a specific development proposal once provided!?

These figures are irrelevant if not judged against a methodology to determine acceptability or otherwise with respect to the local context and available public transport infrastructure or if there is no methodology to determine acceptability or unacceptability against each individual proposal?

Removal of density matrix in the new London Plan (6) Question No: 2019/8978
What would be any future use of TfL’s WebCAT in relation to density, if the London Plan density matrix is removed?

Answered by The Mayor (17th May 2019)

WebCAT contains two ways of measuring transport connectivity:
Public Transport Accessibility Levels (PTAL), which assesses the level of access to the transport network, combining walk time to the public transport network with service wait times.

Time Mapping analysis (TIM), which assesses connectivity through the transport network or, in other words, how far a traveller can go expressed as a series of travel time catchments.

It is publicly available and is used by professional planners, developers and the general public, and supports policies in the London Plan. As my Transport Strategy promotes the switch towards sustainable modes, there will be a continuing need for WebCAT, to guide decisions and embed the Healthy Streets Approach.

Policy D6 Optimising Density in the draft London Plan (currently being examined) requires particular consideration be given to a site’s connectivity and accessibility by walking, cycling, and existing and planned public transport to jobs and services. This includes both PTAL and access to local services.

Supplementary to Question No: 2019/8978
Your answer to Question 2019/8978 described the ways of measuring transport connectivity using the TfL WebCAT PTAL and TIM but the answer did not clarify how PTAL and TIM could be used to implement Policy D6 or how these parameters could be used to interpret the appropriate densities of a proposed development.

How should the WebCAT PTAL and TIM parameters be used to determine the acceptability or otherwise of an individual development proposal without some form of detailed guidance or methodology once the Density Matrix has been removed?

Removal of density matrix in the new London Plan (7) Question No: 2019/8979
Would you agree that removing the density matrix is in contravention of NPPF paragraphs 16 and 122 as:
a. It is removing a useful digital tool to assist public and community involvement;
b. It is removing a clearly written and unambiguous policy which was clear evidence how a decision maker should react to development proposals?

Answered by The Mayor (17th May 2019)

No. Paragraphs 16 and 122 of the NPPF (2018) do not mention or advocate the use of a matrix as a suitable tool to determine acceptable density levels. The matrix is not a digital tool; it is a table, which requires a qualitative assessment of the site to determine its matrix setting. The matrix included a set of numbers that communicated little about the nature of a future development to the public. The density ranges in the matrix have been mistakenly assumed to be a proxy for sustainability and, also wrongly, that the ranges in the matrix generated a form of development that would sensitively respond to its surroundings.

Supplementary to Question No: 2019/8979
Your response to Question 2019/8979 related to the Density Matrix but didn’t indicate how Policy D6 would meet the requirements of NPPF Plan Making
Para 16 which states:

16.Plans should:
b) be prepared positively, in a way that is aspirational but deliverable;
c) be shaped by early, proportionate and effective engagement between plan-makers and communities, local organisations, businesses, infrastructure providers and operators and statutory consultees;
d) contain policies that are clearly written and unambiguous, so it is evident how a decision maker should react to development proposals;

Policy D6 does NOT meet NPPF Para 16 b) as without clarification the policy is NOT deliverable; also, para 16 c) as the policy is not shaped by effective engagement between Plan Makers and Communities (communities have no methodology or grounds to challenge proposals);

Also, does NOT meet para 16 d) as the policy is ambiguous in that there is NO specific quantifiable measure of acceptability and therefore it is not evident how a decision maker (or applicant) should react to a development proposal.

Further developments are in the July 2019 Planning Report.

Letter to Sarah Jones MP – Shadow Housing Minister (4th Jun 2019)

To: Sarah Jones MP – Shadow Housing Minister

Dear Sarah
We have had a significant number of residential planning applications recently, none of which fully meet either the London Plan, the Croydon Local Plan Policies or the Supplementary Planning Guidance SPD2 Suburban Residential Developments guidance as detailed in our MORA Comment letters for each of these applications.

  • 20-22 The Glade (Shirley North) – approved – 11 Residents Objected
  • 9a Orchard Rise (Shirley North) – approved – 42 Residents Objected
  • The Sandrock Pub (Shirley South) – Awaiting Decision – 151 Residents Objected – (consultation closed)
  • 17 Orchard Avenue (Shirley North) – Awaiting Decision – 8 Residents Objected – (consultation closed)
  • 32 Woodmere Avenue (Shirley North) – Awaiting Decision – 25 Residents Objected – (consultation closed)
  • 56 Woodmere Avenue (Shirley North) – Awaiting Decision – 28 Residents Objected – (consultation extended to 13 June ; amended plans)

This totals 265 local residential objections and counting, of your constituents who have expressed objections to recent development proposals and you have not given any indication whether you support your constituents, question the compliance of these proposals with the planning policies or approve any of these proposals.

We only object to proposals that are non-compliant to adopted planning policies but although we have copied all our very detailed comments letters, listing many non-compliant policies to you, you have not given any support to MORA or to your affected local constituents to request these non-compliant applications be either refused or to request that the developers reapply with proposals that fully meet the agreed planning policies. Monthly planning reports are available on our website.

We understand the need for more housing units but to have support of the affected communities and local residents, these new homes need to respect the planning policies to ensure acceptable accommodation standards for future occupants and that the dwellings meet the policies to respect local character in which they are destined. In addition, the proposals should reflect the available and forecast public transport infrastructure, local massing and densities.

We are adopting a policy of registering formal complaints against any approved proposal which are clearly non-compliant to the adopted planning policies or the process of approval is considered incongruous and we are listing these now on our website.

As shadow Housing Minister, we assumed you would have a view about these proposals not meeting the adopted planning Policies.

What is your view of the recent residential development proposals in the Shirley Wards and can you explain why you are not supporting the local residents and your constituents when the proposals do NOT fully meet the adopted Planning Policies?
Kind Regards
Derek

Derek Ritson I.Eng. M.I.E.T.
MORA Planning
Representing, supporting and working with the local residents for a better community

Note: With the Pegasus Development added to those already listed in the letter, the total number of residents objecting reaches 286.

Further developments are in the July 2019 Planning Report.

Policies

Croydon Local Plan – Partial Review
The Croydon Local Plan 2018 is due for a partial review, which is underway and due to be adopted in early 2022.

The stages of the partial review are:

Local plan – adopted February 2018
Local plan review – commences early 2019
Preferred and alternative options – public consultation Autumn 2019
Preferred option – public consultation Autumn 2020
Examination in public – Spring 2021
Adoption – early 2022

The partial review is currently in the early stages.

Call for Evidence (local green spaces)
Croydon Council are requesting assistance in evidence gathering relating to green spaces across the Borough. The intention of this call for evidence is to determine areas of green space that could be granted a planning designation that would offer some protection to the site – the more evidence received from the community the more informed the Local Plan evidence base will be.

Croydon Council are asking the public to contribute their views on their Local Green Spaces. The closing date for the survey is midnight, 22nd July 2019.

Call for Sites (development)
The Call for Sites is an opportunity for individuals, landowners, developers and organisations to make suggestions for the future use or development of land within the borough, which will be considered in the early stages of preparation of Croydon’s Local Plan Review.

The council are requesting nominations for sites that should be allocated for development in the Croydon Local Plan Review. The council also wants to know if there are sites where the buildings should be kept but used for something different. What about space to accommodate the various uses that serve the borough’s growing population?

Not all nominated sites are guaranteed to be included in the Local Plan Review. The site suggestions received will be assessed by the council to establish their suitability for development given planning constraints and development requirements. Only appropriate and deliverable sites will be taken forward to Preferred and Alternative Options consultation and be considered as part of the Local Plan Review.

To nominate a site complete the Call for Sites submission form. Please note, that all submissions will be publicly published following the close date.

DEREK RITSON
MORA Planning

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