Planning Report – May 2023

Applications

Additional Matters

Planning Sub-Committee Meeting Comments on 9th March

Applications

New

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

Consultation Closes: TBA
Target Decision: 13^th Jul 2023
• Total Consulted: 0
• Objections: 0
• Supporting: 0

Further developments are in the June 2023 Planning Report.

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

We objected to the proposed development on the grounds that:

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

MORA Submission: 23^rd May 2023
Consultation Closes: 2^nd Jun 2023
Target Decision: 5^th Jul 2023
• Total Consulted: 4
• Objections: 3
• Supporting: 0

Further developments are in the June 2023 Planning Report.

Land R/O 71 Tower View – Ref: 23/01141/FUL
Demolition of an existing side extension and the construction of a new two storey house involving the sub-division of the site, other associated alterations.

Consultation Closes: 12^th May 2023
Target Decision: 17^th May 2023
• Total Consulted: 4
• Objections: 14
• Supporting: 0

Further developments are in the June 2023 Planning Report.

Land Adjacent The Willows 311 Wickham Road – Ref: 23/01327/PA8
Proposed telecommunications installation: Proposed 15.0m Phase 5 Monopole and associated ancillary works.

MORA has commented on the proposed telecommunications installation:

It is understood that Telecommunication Masts have very limited Planning requirements, and it is nigh impossible to object to such proposals. However, the positioning of Masts is particularly important and should be as unobtrusive as possible to the local streetscene and local residents.
It is understood that 5G frequency propagation ‘attenuation’ through buildings and trees is greater at the 5G Spectrum frequencies than at the 4G Frequency Spectrum. However, if separation of masts is greater than the Tree Protection Zones the 5G Frequency spectrum propagation is not significantly attenuated by an adjacent tree canopy and therefore judicious location of this mast within a reasonable distance, outside the Tree protection zones of the proposed location, could minimise its obtrusive visibility from the near dwellings if aligned and positioned slightly to the West to be ‘adjacent’ to the evergreen tree 5m to the left (West)) or 12m to the right (East) ‘adjacent’ to the
deciduous tree in the attached google earth image.
We would therefore request that the Case Officer require the Telecommunication Service Provider to consider moving the location to be less obtrusive to observers and local residents. The request should include provision of any reason for not meeting the request with convincing evidence of any 5G signal strength loss, variation or directional attenuation due to the requested relocation. Wherever possible, let nature mask the mast.

MORA Submission: 28^th Apr 2023
Consultation Closes: 7^th May 2023
Target Decision: 29^th May 2023
• Total Consulted: 28
• Objections: 51
• Supporting: 1
Councillor referral: Councillor Richard Chatterjee (5^th May 2023)

Further developments are in the June 2023 Planning Report.

Decided

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

We objected to the proposed development on the grounds that:

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

Permission Refused

Reason(s) for refusal :-

The proposed development, by reason of scale, massing, elevation composition, bulky roof form, materials, detailing and impact on grass verge would result in an unsightly, dominant and imposing form of development which would fail to integrate successfully in townscape terms or make a positive contribution to the setting of the local character and immediate surroundings contrary to Policies H2, D4, D8 of the London Plan (2021) and SP2, SP4, DM10 of the Croydon Local Plan (2018).
The proposed development lacks an appropriate parking strategy due to the unacceptable nature of the new vehicle crossover along The Glade thereby leading to possible increase in on street parking pressure, and In the absence of a legal agreement, the application does not offer a contribution towards sustainable transport initiatives in the vicinity to alleviate traffic generation created by the development, the proposal would be contrary to Policies SP8 and DM30 of the Croydon Local Plan (2018) and Policy T4, T6 of the London Plan (2021).

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

Further developments are in the July 2023 Planning Report.

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

We objected to the proposed development on the grounds that:

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

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

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

Hanbury Mews – Ref: APP/L5240/W/22/3307138
Retention of gates to Hanbury Mews.

We objected to the proposed retention of gates on the grounds that:

Some properties within the surrounding area feature gates to restrict access to private property. However, as most are at the boundary of single dwellings, they have a wholly different relationship with the public realm and do not have the same visual effect in terms of segregating one part of the community from another.
The gates create a barrier within Hanbury Mews that, by their nature, dominate the approach to the dwellings of that road and segregate those dwellings and their access route from the public domain of the surrounding area.
The applicant has indicated that the gates help to provide additional security to the dwellings in Hanbury Mews. These benefits to the residents of Hanbury Mews would not compensate or mitigate the harm to social cohesion caused by the division by the gates.
The separation of the street from its surroundings would cause a harmful segregation of the community that would not accord with the council’s Suburban Design Guide 2019 (SDG) which states that gated developments will not be acceptable.
The main issue is the effect of the development on the character and appearance of the area including the effect on social cohesion.
Retention would NOT comply with guidance and NO applications were submitted prior to commencement of erection of the gates.

Permission Refused

Reason(s) for refusal :-

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

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

Awaiting Decision

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

We objected to the proposed development on the grounds that:

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

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

Further developments are in the June 2023 Planning Report.

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

We objected to the proposed development on the grounds that:

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

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

Further developments are in the June 2023 Planning Report.

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

We objected to the proposed development on the grounds that:

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

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

Flyer for download and social media sharing.

Further developments are in the June 2023 Planning Report.

Appeals Pending

187 Shirley Road – Ref: APP/L5240/W/23/3316505
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.

Permission Refused

Reason(s) for Refusal:-

The proposed development would provide poor quality residential units by virtue of: inadequate internal floorspace to the 2 person first floor flat; inadequate outlook and privacy to the two ground floor flats; lack of private external amenity space to the two first floor flats; lack of communal amenity and child play space; insufficient information to demonstrate accessible housing either M4(2) or (M4(3); insufficient information to demonstrate Fire Safety, contrary to Policies SP2.8 and DM10 of the Croydon Local Plan (2018) and Policies D3, D6, D7 and D12 of the London Plan (2021).
Insufficient information has been submitted to demonstrate that there would not be addition and harm to local car parking stress and in the absence of a legal agreement the application does not offer a means to mitigate its impacts on the highway network and offer sustainable transport alternatives, to the detriment of the highway conditions of the area and highway safety contrary to Policies SP8, DM29 and DM30 of the Croydon Local Plan (2018) and Policy T4, T6 and T6.1 of the London Plan (2021).
It has not been demonstrated that the proposal would provide satisfactory facilities for cycle storage, refuse and recycling, contrary to Policies DM10 and DM13 of the Croydon Local Plan (2018) and Policy T5 of the London Plan 2021.
The development would be below the 30% strategic target for family sized (3-bedroom) housing in accordance with the Policy SP2.7 of the Croydon Local Plan 2018.

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)
Permission Refused: 11^th Aug 2022
Appeal Notice: 14^th Feb 2023

Further developments are in the June 2023 Planning Report.

9 – 13 Gladeside – Ref: APP/L5240/W/23/3316987
This proposal is for the demolition of 3no existing dwellings and the erection of 7no dwelling houses of two storey with accommodation in the roof space. 11 car parking spaces are provided including 1no accessible space plus cycle and refuse storage.

This proposal is a welcome change to the many recent proposals in this locality as it provides individual family homes with gardens as opposed to blocks of flats of multiple occupation. This development proposal is more suitable for the local area and reflects the character of the local area.

However, we objected to the proposed development on the grounds that:

It is clear from the forgoing that the Site Area is insufficient for the proposed level of Development. Although family housing is offered and preferred, the capacity is overly cramped with access extremely restricted. The Amenity of No. 7 Gladeside is adversely affected by the height and proximity of the new adjacent Unit 1.
In addition, the Access Drive width, although 3.7m wide, includes a pedestrian footpath which is therefore unsound structurally over the full width of the driveway if the pedestrian footpath is not to the same structural design capacity as the Access drive for vehicles. Although this width (1.82m) is adequate for family cars, it is insufficient for emergency vehicles. A fire Tender has Wheelbase width of 2.3m and therefore there is only 1.4m tolerance for pedestrians (3.7m – 2.3m) and if the emergency vehicle deviates slightly, could drift onto the pedestrian footpath of less structural strength.
In addition, the main reason for our concern is the excessive density of the proposal in an Area Type Setting of Outer (London) Suburban Setting as defined by the National Model Design Code & Guidance.
There has been inadequate assessment of the proposed developments increasing the surface water flood risk to the existing adjacent dwellings at 7 and 15 Gladeside.

Permission Refused

Reason(s) for Refusal:-

The proposed development, by reason of scale, design and layout of the houses, would result in a cramped and imposing form of development which would fail to integrate successfully and respond effectively in townscape terms to the wider setting of the local character and immediate surroundings contrary to Policies D3, D4, D8 of the London Plan (2021) and Policies SP2, SP4, DM10, DM26 of the Croydon Local Plan (2018).
The proposed development by reason of its massing and proximity close to neighbouring properties at nos. 7 and 13 Gladeside would result in an intrusive and imposing form of development detrimental in terms of outlook, privacy, overlooking and would lead to loss of sunlight or daylight for these surrounding neighbours contrary to Policies D3 and D6 of the London Plan (2021) and policy DM10 of the Croydon Local Plan (2018),
Sufficient detail has not been provided to demonstrate that the proposal would not have an adverse impact on the highway transport network due to inadequate car parking provision for this site, poorly designed disabled bay, inappropriate pedestrian sightlines, poor vehicle and pedestrian access and poor cycle and refuse storage facilities and would therefore be contrary to Policies T4, T5 and T6 of the London Plan (2021) and Policies DM10.2, DM13, DM29 and DM30 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 to Policy G6 of the London Plan (2021) and Policy DM27 of The Croydon Local Plan (2018).
Insufficient evidence has been provided to demonstrate that the development would satisfactorily mitigate against any surface water and ground water flood risk thereby contrary to guidance in Chapter 14 of the National Planning Policy Framework (July 2021), as well as Policies SI12 and SI13 of the London Plan (2021) and Policies SP6.4 and DM25 of the Croydon Local Plan (2018).

MORA Submission: 10^th Oct 2022
Consultation Closes: 16^th Oct 2022
Target Decision: 15^th Nov 2022
• Total Consulted: 19
• Objections: 22
• Supporting: 0
Councillor referral: Councillor Richard Chatterjee (18^th Oct 2022)
Permission Refused: 13^th Dec 2022
Appeal Notice: 20^th Feb 2023

Flyer for download and social media sharing.

Further developments are in the June 2023 Planning Report.

13 Gladeside – Ref: APP/L5240/W/23/3317040
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.

Permission Refused

Reason(s) for Refusal:-

The proposed development would be detrimental to the street scene and character of the area by reason of the size, massing, footprint, form, and design and would thereby conflict with policies DM10 and SP4.1 of the Croydon Local Plan (2018) and D3 and D4 of the London Plan (2021).
The proposed development would provide a poor quality of residential accommodation by virtue of its inadequate communal amenity space,
contrary to policies D3 of the London Plan (2021) and policies SP2.8 and DM10 of the Croydon Local Plan (2018).
The proposed development would result in a detrimental impact on highways and pedestrian safety as a result of inadequate visibility splays, unsafe manoeuvring, inadequate parking provision and the absence of contributions to sustainable travel in the area, contrary to policies DM29 and DM30 of the Croydon Local Plan (2018) and T4, T6 and T6.1 of the London Plan (2021).

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
Appeal Notice: TBA

Further developments are in the June 2023 Planning Report.

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

We objected to the proposed development on the grounds that:

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

Permission Refused

Reason(s) for refusal :-

The proposed development, by reason of scale, massing, elevational
composition, materials and detailing would result in an unsightly, dominant and imposing form of development which would fail to integrate successfully in townscape terms or make a positive contribution to the setting of the local character and immediate surroundings contrary to Policies H2, D4, D8 of the London Plan (2021) and SP2, SP4, DM10 of the Croydon Local Plan (2018).
The proposal by reason of its massing and proximity close to neighbouring
properties at nos. 44 and nos. 48 The Glade would result in an intrusive and imposing form of development detrimental in terms of outlook for these surrounding neighbours and would be contrary to policy DM10 of the Croydon Local Plan (2018), Policies D3 and D6 of the London Plan (2021)
The proposed development would provide poor vehicle access, poorly accessed and designed cycle facilities and would therefore be contrary to Policies DM10.2, DM29 and DM30 of the Croydon Local Plan (2018) and Policies T4, T5 of the London Plan (2021).
In the absence of a legal agreement, the application does not offer a contribution towards sustainable transport initiatives in the vicinity to alleviate traffic generation created by the development, the proposal would be contrary to Policies SP8 and DM29 of the Croydon Local Plan (2018) and Policy T4 of the London Plan (2021).

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

Further developments are in the June 2023 Planning Report.

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

We objected to the proposed development on the grounds that:

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

Permission Refused

Reason(s) for refusal :-

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

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

Further developments are in the June 2023 Planning Report.

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

We objected to the proposed development on the grounds that:

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

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

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

Further developments are in the June 2023 Planning Report.

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

We objected to the proposed development on the grounds that:

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

Permission Refused

Reason(s) for Refusal:-

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

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

Further developments are in the June 2023 Planning Report.

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

We objected to the proposed development on the grounds that:

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

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

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

Further developments are in the June 2023 Planning Report.

77 Woodmere Avenue – Ref: APP/L5240/W/22/3307153
Demolition of single family dwelling and garage to facilitate the erection of a detached 2-storey building with accommodation in the roof space, comprising of 7 self-contained apartments with intergraded bike store and 8 off street car parking spaces.

We objected to the proposed development on the grounds that:

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

Permission Refused

Reason(s) for Refusal:-

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

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

Further developments are in the June 2023 Planning Report.

46 The Glade – Ref: APP/L5240/W/22/3305791
Demolition of single storey dwelling at 46 The Glade and redevelopment with a new building to provide 8 dwellings (Class C3), with associated amenity space, integral refuse, cycle stores and external car parking.

We objected to the proposed development on the grounds that:

It is clear from the Applicant’s provided documentation and Plans that NO account has been taken of the National Model Design Code and Guidance to determine the Area Design Code(s) “Setting” or “Site Capacity” for this proposal.
The offered Housing Density of the proposal is 88.24Units/ha which is a Setting of Mid & Urban Range but with public transport access level (PTAL) of Zero which is inappropriate for an Urban Area Type Setting. 46 The Glade, by all our assessments of the locality Design Code, is within the lower of the range of an “Outer Suburban” Setting. The proposal is inappropriate for “Incremental Intensification” as it is below PTAL 3 and greater than 800m from a Tram/Train Station or District Centre as defined by London Plan Policy H2 para 4.2.4
There is NO possible improvement to Public Transport Accessibility in Shirley North Ward at least until 2031 as indicated on the TfL WebCAT for this Post Code or address. We have evaluated the appropriate PTAL which would be required to support this proposal at PTAL 6.202 when the available PTAL is Zero. The applicant still presumes the local PTAL to be 1a.
The proposal meets most London Plan Policy D6 minimum space Standards given at Policy D6 Table 3.1. The proposal does NOT however, indicate the amount of In-Built Storage of any of the 8 Flats. The Dimensions are NOT stated, however the excess GIFA may compensate for this omission but requires full assessment.
The evidence indicates a deficiency of Play Space for the probable 12 children to be 87.75m2 which is a deficiency of (120-32.25)/32.25 = 0.270 = 27%.
It is noted that the “Vision Transport Assessment” Parking Assessment Report of 13th August 2021 supplied as evidence for the applicant, provides an incorrect evaluation of the PTAL for 46 The Glade, indicating a PTAL of 1a when the actual Site PTAL is Zero as shown at TfL WebCAT forecast up to 2031.
The analysis shows that for new developments in areas without controlled parking Zones and at PTAL Zero, would be 9 spaces for the Revised draft Croydon Local Plan Policy DM30 Table 10.1 and 12 spaces for the adopted London Plan Policy T6.1 Table 10.3 when only 7 are provided.
The accessibility into and exit from each parking bay, with all other bays occupied should be proven by production of swept path illustration to ensure the safety and manoeuvrability is acceptable.

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

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

Further developments are in the June 2023 Planning Report.

Additional Matters

Planning Sub-Committee Meeting Comments on 9th March

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

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

The weight of Policies are:

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

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

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

DEREK RITSON

MORA Planning

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