Applications
Awaiting Decision
- 27 Orchard Rise – 24/02781/FUL
- 189 Shirley Road – 24/02353/FUL
- 159 – 161 The Glade – 24/01924/FUL
- 116 Orchard Way – 24/01879/FUL
- 8A Oak Way – 23/04017/FUL
Appeals Pending
Additional Matters
- Proposed National Planning Policy Framework Reforms Response
- MORA Revised Croydon Local Plan 2024 Representation Forms
Applications
Awaiting Decision
27 Orchard Rise – Ref: 24/02781/FUL
Demolition of existing dwellings and the construction of 4no. semi-detached dwellings with associated parking, refuse and cycle storage.
We objected to the proposed development on the grounds that:
- The proposed Development would result in the loss of a single-family home with garden.
- The proposal is for two blocks of Two-Storey Semi-detached with gabled room forms, which does not respect the predominant build type of bungalows of the locality.
- The proposal has not shown any 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 exceeds the local Post Code Area Type by 58.52% requiring bridging the established Area Type the range of ‘Outer [London] Suburban’ to ‘Suburban’ with no increase in supporting infrastructure.
- The Post Code (CR0 7QZ) has a ‘Housing Density’ of ≈27.22 Unit/ha (Outer [London] Suburban Area Type) and a ‘Residential Density’ of ≈66.44 Persons/ha (Outer [London] Suburban Area Type). In contrast, the Applicant’s proposal has 43.15 Unit/ha (Suburban Area Type), a 48.52% increase, and 172.6 Persons/ha (‘Urban’ Area Type), a 159.78% increase setting (bridging a Suburban Area Type) as defined by the National Model Design Code & Guidance (NMDC&G). These increases are proposed without any proportionate increase in local Infrastructure, especially accessibility to Public Transport which is currently PTAL 1a (≡ 0.66), and thus clearly indicates an over development for the locality.
- The London Plan Residential Parking provision is given at Policy T6.1 Table 10.3 and for “outer London” at PTAL 0 to 1 which includes PTAL1a. The Parking provision appropriate is 1.5 Spaces per Unit, which again for 4 Units would require ‘6’ Parking Bays.
- The proposal only provides 5 Parking Bays, in a locality of PTA1a (≡ 0.66) which fails to Meet the Croydon Local Plan Policy DM30 or the London Plan Policy T6.1 Table 10.3.
- Our assessment is that the parking provision for the proposal is inadequate in both capacity and Area due to the inappropriate parking configuration with limited manoeuvrebility. The Swept Path analysis clearly indicates that Parking provision is inadequate, and that Parking manoeuvres and clearances proposed would be probably impossible and therefore is ‘unacceptable.
- It is our considered view that the driveway Access is inadequate for the number of additional Pedestrians (16) and (Car 5) regular vehicular traffic movements by occupants and visitors. It does NOT meet Public Realm design requirements. The 3.7m width depicted in the Drawing No ORCHRD-ZZ-04-DR-A-01_302-A3 Date 29-05-2024 is unreliable and misleading.
- We are convinced that a Fire Appliance vehicle with high pressure pump cannot get within 45m of any part of the proposed development to be reached by Pressurised Hose.
- The proposal also fails to meet the Refuse Recycling Bin pull distance and capacity requirements for 4 Units as defined by the Croydon Council Refuse Waste and Recycling Planning Policy.
- The proposal meets most accommodation standards as defined by the New London Plan (2021) except that the proposal does NOT identify any ‘In-Built’ Storage capacities.
- These Standards are appropriate for the storage of the normal living clutter requirements for future occupants as defined in the New London Plan (2021) Table 3.1 which indicates 3b4p Dwellings should provide 2.5sq.m. In-Built Storage per Dwelling and the London Plan Guidance LPG – Housing Design Standards Table 1A.1. indicates a Best Practice for 3b4p dwellings of 3sqm. In-Built Storage per Dwelling.
- These are ‘Minimum’ Accommodation Space Standards which, in addition, the London Plan recommends “these minimum standards should be exceeded if at all possible”. It is unacceptable that this requirement is not fully met and gives further evidence of overdevelopment of the site area of 927m2 or 0.0927ha as there is insufficient space to provide the minimum in-built storage space required.
- We also believe that the configuration with respect to 25 Orchard Rise would allow significant invasion of privacy and overlooking, as the separation distance between the Flank Wall of 25 Orchard Rise, which contains a Window to their Dining Room would be directly overlooked by the proposed development Ground Floor Kitchen and first floor bedrooms at approximately 15.8m perpendicular distance. This fails to meet the recommended 18 to 21 metres recommended spacing between facing windows.
MORA Submission: 2nd Sep 2024
Consultation Closes: 8th Sep 2024
Target Decision: 8th Oct 2024
• Total Consulted: 31
• Objections: 44
• Supporting: 0
159 – 161 The Glade – Ref: 24/01924/FUL
Demolish two existing bungalows and associated garages to create a combined site of 950 sqm to deliver four family homes with associated parking, gardens and cycle storage, and visitor parking. 
We objected to the proposed development on the grounds that:
- The Post Code CR0 7QR has an Area of 0.41hectares and embraces 12 Units (Housing Density 29/27Units/ha) which equates to an Outer Suburban Area Type setting as defined by the National Model Design Code & Guidance.
- The proposed Application would provide 4 units on a site area of 0.095ha equating to a Housing Density of 42.11Units/ha and with 28 occupants, would provide a Residential Density of 294.74Persons/ha.
- These application parameters would place the application in a Suburban Area Type Housing Density with a high Residential Density more appropriate to a Central Area Type Residential Density.
- A proposed development of 4 dwellings on a Site Area of 0.095ha in an Outer Suburban Area Type Setting exceeds the available Site Capacity and is Non-Compliant to the London Plan Policy D3 – Optimising Site Capacity through the Design-Led Approach.
- We understand the need for additional homes; however, we have conclusively illustrated that the proposal offered is much too dense for the local Area Type and that the applicant is attempting to squeeze much too much accommodation into a very small and restricted site capacity which is extremely inappropriate for the locality.
- We have clearly shown that the location CR0 7QR is inappropriate for “Incremental Intensification” and unsuitable for “Growth” beyond the existing Suburban Area Type setting without the offer of significant infrastructure improvement.
- The Site Capacity of 0.095ha is inadequate for 4 Units at a Suburban Area Type setting.
- We therefore suggest that this proposal is refused and that a new proposal is presented which is less dense and more appropriate for the Local Area Type Setting as defined by the local character parameters of the Post Code CR0 7QR.
MORA Submission: 1st Jul 2024
Consultation Closes: 11th Jul 2024
Target Decision: 29th Jul 2024
• Total Consulted: 24
• Objections: 6
• Supporting: 0
Councillor Referral: Councillor Richard Chatterjee (16th Jul 2024)
Councillor Referral withdrawn: 15th Oct 2024
189 Shirley Road – Ref: 24/02353/FUL
Change of use from a C3 dwellinghouse to a 6no bedroom 6 person House in Multiple Occupation.
We objected to the proposed change of use on the grounds that:
- As Policy DM2B.1 Proposals for the conversion of larger homes to Houses in Multiple Occupation (HMO), including small HMOs (3-6 unrelated people) within the area covered by the Article 4 Direction (whole of the borough), will only be permitted where it meets policy DM2B.1 a) to f):
a) We understand “the gross original internal floor space of the existing dwelling” before undertaking building works is greater than 130m2.
b) However, we are convinced that the proposal would give rise to significant adverse amenity impact(s) on the surrounding neighbourhood, including cumulative impacts arising from an overconcentration of HMOs within an area, contributing to increased noise and disturbance.
c) The Location of 189 Shirley Road at PTAL 2 (PTAL output for 2031 (Forecast) 2 Easting: 535238, Northing: 165876); is ‘inappropriate’ for an HMO in accordance with the revised Policy BM2B.1 para c). i.e. the PTAL at 189 Shirley Road is PTAL 2 and for HMO status the locality would need to be ≥ PTAL 4.
d) They provide high quality accommodation that satisfies the relevant policies of the Local Plan, including internal space standards, provision of a satisfactory level of amenity space for occupants and adequate and convenient refuse and recycling storage and collection. – No Comment.
e) Where non-self-contained, have exclusive use of a kitchen or space within a shared kitchen for each household. – No Comment
f) Soft landscaping is incorporated to improve and enhance the site. – No Comment.
MORA Submission: 5th Aug 2024
Consultation Closes: 9th Aug 2024
Target Decision: 10th Sep 2024
• Total Consulted: 10
• Objections: 4
• Supporting: 0
Councillor referral: Councillor Sue Bennett (13th Aug 2024)
Councillor referral: Councillor Richard Chatterjee (14th Aug 2024)
Councillor referral withdrawn: 15th Oct 2024
116 Orchard Way – Ref: 24/01879/FUL
Conversion of public house on ground floor of building to facilitate 1 x 2-bedroom flat and 1 x 3-bedroom flat with integral cycle and waste storage.
We objected to the proposed development on the grounds that:
- All the Application proposals subsequent to the original, significantly exceed the Site Capacity available of 0.0285ha by varying degrees and would require Area Types “Central” or “Urban” when the actual Local Area Type as defined by the local Post Code CR0 7NN is clearly a “Suburban” Area Type.
- The conversion from an existing Pub premises to residential accommodation, has significant limitations which creates difficulties for use as residential dwellings. There is no additional Site Capacity for easily meeting the London Plan Policy D6 – Housing quality and standards amenity requirements or play space for children.
- The proposal would probably have accommodation for four adults and four children for whom 40sq.m. of Play Space would be required.
- We understand the need for additional homes and that the applicant has attempted to market the Pub for sale but without success. The option for conversion to Residential is an obvious option worth considering to make better use of the land.
- We understand that a previous Application for this Site: Application Ref: 20/05960/FUL – Permission Granted; is conditional of the Ground Floor premises being retained as a Public House and are therefore concerned that this application will have repercussions on the validity of this previous approval.
- However, we have conclusively illustrated that the proposal offered is much too dense for the local Area Type and that the applicant is attempting to squeeze much too much accommodation into a very small and restricted site capacity which is extremely inappropriate for the locality.
- The proposal would not provide adequate Play Space for the probable 4 children accommodated by this proposal.
- We therefore suggest that this proposal is refused and that a new proposal is presented which is less dense and more appropriate for the Local Area Type Setting as defined by the local character parameters of the Post Code CR0 7NN.
MORA Submission: 28thJun 2024
Consultation Closes: 4th Jul 2024
Target Decision: 25th Jul 2024
• Total Consulted: 61
• Objections: 21
• Supporting: 6
Councillor referral: Councillor Richard Chatterjee (8th Jul 2024)
8A Oak Way – Ref: 23/04017/FUL
Demolition of the existing bungalow and the proposed erection of of 2 x semi detached houses and a bungalow with associated car parking, refuse storage, cycles storage and landscaping
MORA has a neutral stance on this proposed development for the following reasons:
- This proposal would seem to be in keeping with the local character of semi-detached dwellings and bungalows, and could be a welcome change to the high-density proposals of late.
- The local area Design Code requires to be identified and the proposal assessed against its compliance to this proposals local Design Code within reasonable tolerance.
- The percentage uplift to the Post Code Design Codes of 18.21% Housing and 27.58% Residential Densities do not significantly change the Area Types.
- The Post Code Area Type prior to and after the proposal would remain Outer Suburban and the existing Application Site Area Type would increase from <Outer Suburban to Outer Suburban as defined by the MNMDC&G considered to be within the objectives of NPPF (Dec 2023) para 135 sub paras a) to c).
- The Dwelling Types of Bungalow and Semi-Detached dwellings respect the character of the locality, and the layout reflects the surrounding character of the immediate area. The increase in Residential Density of 200% is the only critical Design Code issue which may be considered inappropriate as the proposal location has very low Public Transport Accessibility at PTAL 1a (assumed numerically ≡ 0.66).
- The interactive spreadsheet calculates the Site Capacity is just 3.02% short of the actual required minimum Site Area for an Outer Suburban Area Type setting. This works out at 30.39sq.m. short which we believe is not sufficient to be the only reason found for a refusal. This is only 30.39sq.m. deficient from the calculated required 1036.39sq.m. for an outer Suburban Area Type Setting.
- The proposal, at of three (3) Units in an area of 0.1006ha would equal a Housing Density of 3/0.1006 = 29.821Units/ha which places the proposal in an ‘Outer Suburban’ Area Type in the range 20 to 40Units/ha. i.e. equal to the locality as define by the Post Code Design Code.
- We have assessed the various Design Code parameters, and the overall assessment is that the proposal generally meets the objectives of the main policy requirements or are within acceptable tolerance limits and would provide welcomed family dwellings.
MORA Submission: 10th Jan 2024
Consultation Closes: 25th Jan 2024
Target Decision: 27th Feb 2024
• Total Consulted: 15
• Objections: 16
• Supporting: 0
Councillor referral: Councillor Richard Chatterjee (27th Feb 2024)
Appeals Pending
219 Wickham Road – Ref: APP/L5240/W/24/3347689
Conversion of existing dwellinghouse to 1x 1-bedroom flat and 1x studio flat. Erection of rear dormer. Associated alterations include provision of cycle and refuse storage.
Permission Refused
Reason(s) for refusal :-
- The proposed development would result in the net loss of 3-bedroom homes without suitable replacement, contrary to policies SP2.7 and DM1.2 of the Croydon Local Plan (2018).
- The proposed development, by virtue of inadequate internal floorspace, private amenity space and communal space, would result in sub-standard accommodation for the future occupants of the proposed flats. The proposed development therefore fails to comply with the Croydon Local Plan (2018), in particular Policies DM10 and SP2, the London Plan (2021), in particular Policies D3 and D6, and the Technical Housing Standards – Nationally Described Space Standard (2015).
- The proposed development would not provide well designed, adequate, and accessible cycle storage facilities to serve the needs of future residents. The proposed development therefore fails to comply with the Croydon Local Plan (2018), in particular Polices DM29, DM30, and SP8, the London Plan (2021), in particular Policies SI 7, SI 8 and T5, and the London Cycling Design Standards (2016).
Consultation Closes: 10th May 2024
Target Decision: 3rd Jun 2024
• Total Consulted: 14
• Objections: 0
• Supporting: 0
Permission Refused: 3rd Jun 2024
Appeal Notice: 27th Aug 2024
116 Orchard Way – Ref: APP/L5240/W/24/3344352
Removal of external staircase and Conversion of public house on ground floor of building to facilitate 1 x 2-bedroom flat and 1 x 3-bedroom flat with integral cycle and waste storage.
MORA has a neutral stance on this proposed development for the following reasons:
- The existing building was not designed for residential accommodation, and it is therefore difficult to convert the building to Residential accommodation and comply with all the Policies for Residential requirements especially so in a Suburban Area Type setting.
- The previous approved application Ref: 20/05960/FUL for providing an additional floor and 4 Flats was ‘conditional’ upon an assumption that the Ground Floor would be retained as a Pub.
- This can be confirmed by reference to para 5.3 of the Case Officer’s Report which stated: “5.3 The development would retain the existing Pub in accordance with Croydon Local Plan Policy DM21 and provide 3x one bedroom and 1x two-bedroom flats spit between the first and second floors. The existing first floor flat to be replaced has 4 bedrooms which is not protected by Local Plan Policy DM1. Whilst the existing dwelling has a floor area of 116 square metres, its loss and provision of additional smaller homes is acceptable in this instance considering the above pub position which is less suitable for families.”
- The new application changes the grounds on which Application Ref: 20/05960/FUL was approved if now the Ground Floor is to be converted to Residential.
- Additionally, the Decision Note for Application Ref: 20/05960/FUL was dated 12th May 2021 and Condition 1 stipulated that the ‘Grant of Permission’ was conditional that the Development should be begun within three years of the Date of the Decision Note. If the delay to decision for the Application Ref: 23/04285/FUL exceeds 12th May 2024 then it is unlikely that work on Ref: 20/05960/FUL would have started on or before 12th May 2024.
- In such a scenario, we would appreciate clarification on whether the Application Ref: 20/05960/FUL would be considered expired and whether a re-application would be required to include all the three floors including the revised Ground Floor as Residential Accommodation?
- The Parking allocation is extremely limited in a very low PTAL area of PTAL 1a and the single retained parking space is the same integral parking space on the ground floor plans for Application Ref: 20/05960/FUL so cannot be included in both proposals.
- This has been a complicated proposal to assess as the existing Building does not lend itself for simple transfer from Retail and Pub to Residential accommodation, but some change of use may be considered necessary. The proposal, however, does not meet the local Area Type as defined by the National Model Design Code & Guidance and our assessment based upon the most recent National Guidance indicates an over development for the locality which is a Suburban Area Type setting.
- The proposal would result in the loss of a Public House in a residential environment where there are few local amenities. However, the applicant has made appropriate efforts to retain the Pub, but it has shown it to be unviable in the current economic climate. It is therefore presumed that a change of use could resolve the viability and create accommodation to help meet housing needs.
- Nevertheless, any conversion to residential use requires the proposed changes to meet all necessary National and Local Planning Policies for acceptable accommodation for future residents which we have shown to be questionable.
- There is inadequate off-street parking provision and inadequate Amenity or Play Space for Children of the proposed accommodation.
Permission Refused
Reason(s) for refusal :-
- The removal of the existing staircase would remove an access to the flats above and to the side of the application site harming the amenities of the neighbouring occupants contrary to Policy DM10 of Croydon Local Plan 2021.
- The proposed design of the development would fail to offer suitable outlook from or natural light to the new homes, resulting in poor quality living conditions. The application therefore conflicts with Croydon Local Plan (2018) Policy DM10 and London Plan (2021) Policy D6.
MORA Submission: 4th Jan 2024
Consultation Closes: 20th Jan 2024
Target Decision: 6th Feb 2024
• Total Consulted: 46
• Objections: 6
• Supporting: 5
Councillor referral: Councillor Richard Chatterjee (22nd Jan 2024)
Permission Refused: 7th Feb 2024
Appeal Notice: 20th Jun 2024
Additional Matters
Proposed National Planning Policy Framework Reforms Response
The Government Consultation has sought views on the proposed approach to revising the National Planning Policy Framework in order to achieve sustainable growth in the planning system.
The Government also sought views on a series of wider policy proposals in relation to increasing planning fees, local plan intervention criteria and appropriate thresholds for certain Nationally Significant Infrastructure Projects.
This consultation closed on the 24th September 2024.
You can view the MORA Response to the National Planning Policy Framework Consultation 2024 here.
MORA Revised Croydon Local Plan 2024 Representation Forms
We have sent 17 representation forms detailing our comments on the Revised Croydon Local Plan to the Local Development Framework Team (LDF).
You can view them below:
DEREK RITSON
MORA Planning
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