Planning Report – September 2024

Applications

Additional Matters

Proposed National Planning Policy Framework Reforms Response
MORA Revised Croydon Local Plan 2024 Representation Forms

Applications

Decided

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.

Permission Refused

Reason(s) for refusal :-

The proposed development, by virtue of the design, layout and size of the communal amenity spaces proposed, would fail to deliver separate children’s play space and all-age communal amenity space that would both be sufficiently-sized, practical, high quality and of high utility to the detriment of the quality and standard of the residential accommodation. Similarly, the private residential amenity spaces proposed, by virtue of their design, layout and utility, would constitute leftover, impractical low-quality, and/or undersized amenity spaces that would not be fit for purpose to the detriment of the quality and standard of the residential accommodation. Therefore, the proposal is considered contrary to Section 12 of the National Planning Policy Framework (December 2023); policy D3 and D6 of the London Plan (2021); and policy DM10 and Table 6.2 of the Croydon Local Plan (2018); and Parts B and C of the GLA’s Housing Design Standards LPG (2023).
The proposed four-storey building, by virtue of its design, form, height, massing, and roof profile, would constitute an overdevelopment of the
application site that would appear conspicuously overbearing and disproportionate, as well as, incoherently out of keeping with the appearance, character, and form of development within the local setting to the detriment of the visual amenity it provides. Therefore, the proposal is considered contrary to Section 12 of the National Planning Policy Framework (December 2023); policies D3 and D4 of the London Plan (2021); and policies DM10 and SP4 of the Croydon Local Plan (2018).
Insufficient information was provided on design measures and supporting strategies to ensure adequate fire safety for future occupiers of the development to the detriment of public safety. Therefore, the proposal is considered contrary to policies D11 and D12 of the London Plan (2021).
The proposed development, by virtue of its landscaping, layout, incomplete urban design, and siting on a corner lot, would fail to provide a high-quality and inviting arrival space for future occupants/visitors, as well as, contribute to the positive evolution of the public realm to the detriment of providing high-quality housing and creating a healthy, inclusive environment in which people choose to walk, cycle and use public transport. Therefore, the proposal is considered contrary to Sections 8, 9, 11 and 12 of the National Planning Policy Framework (December 2023); policies D3, D5, D6, D7, D8, GG1, T2, T3 and T5 of the London Plan (2021); policies DM10, DM16, DM29, SP4 and SP8 of the Croydon Local Plan (2018); and Part A of the GLA’s Housing Design Standards LPG (2023).
A legal agreement was not submitted with the application to secure the sufficient mitigation of the impacts of the development through securing an acceptable travel plan, and a financial contribution toward improvements to sustainable transport in the local area, as well as, prohibiting future occupants from obtaining permits for local Controlled Parking Zones. Therefore, the proposal is considered contrary to Section 9 of the National Planning Policy Framework (December 2023); policies T2, T3, T4, T6, and T6.1 of the London Plan (2021); and policies DM16, DM23, DM29, DM30, SP6 and SP8 of the Croydon Local Plan (2018).
The proposed development, by virtue of the design, layout, siting and size of some of the self-contained flats proposed, would result in substandard dwellings that would be cramped, underlit, undersized and/or vulnerable to undue overlooking and unauthorised access to the to the detriment of the privacy, safety and/or quality of accommodation for future occupants. Furthermore, insufficient supporting information was provided to confirm that the self-contained flats designed as fully wheelchair accessible dwellings or accessible and adaptable dwellings would be compliant with Building Regulations M4(2) or M4(3) to the detriment of providing an accessible and adaptable development. Therefore, the proposal is considered contrary to policies D5, D6, D7, D11, T6 and T6.1 of the London Plan (2021); policy DM10 of the Croydon Local Plan (2018); and Part C of the GLA’s Housing Design Standards LPG (2023).
Insufficient and substandard details were provided on an appropriate tree replanting plan that would sufficiently mitigate the proposed loss of existing trees that are located within or in close proximity to the application site and provide amenity to the host and adjoining properties, as well as, contribute to urban greening and biodiversity. Therefore, the proposal is considered contrary to Section 15 of the National Planning Policy Framework (December 2023); policies D4, G5, G6 and G7 of the London Plan (2021); and policies DM10, DM27, DM28, SP6 and SP7 of the Croydon Local Plan (2018).
Insufficient information and details regarding transport issues (incl. visibility splays, swept path analysis, vehicle parking stress surveys, and on-site vehicle parking generation estimates based on up-to-date data) to allow the Local Planning Authority to assess whether the application site would be, or could be rendered, suitable for the intensification of its existing uses without detriment to highway safety, the availability of on-street vehicle parking, and movement of vehicular traffic on local streets. Furthermore, it has not been demonstrated that the arrangement, design and layout of the off-street vehicle parking space(s) proposed would allow vehicles accessing the car park to conveniently and safely ingress and egress from the individual off-street parking space(s) safely to detriment to highway safety and movement of vehicular traffic on local streets. Therefore, the proposal is considered contrary to Sections 8 and 9 of the National Planning Policy Framework (December 2023); policies T2, T3, T4, T6, and T6.1 of the London Plan
(2021); and policies DM16, DM30 and SP8 of the Croydon Local Plan (2018)
The proposal has failed to demonstrate how the development would provide acceptable arrangements for storing, collecting and managing the solid waste to be generated by the proposed development to the detriment of safeguarding public health, reducing and managing waste generated by the development, and keeping local highways clear of visual blight and impediments to movement. Therefore, the proposal is considered contrary to Sections 8, 9 and 12 of the National Planning Policy Framework (December 2023); policy D6 and SI7 of the London Plan (2021); policies DM10, DM13, and DM30 of the Croydon Local Plan (2018); and Section 5 of the Council’s Waste and Recycling in Planning Policy Document (2018).

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)
Permission Refused: 28^th May 2024

Flyer for download and social media sharing.

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: 2^nd Sep 2024
Consultation Closes: 8^th Sep 2024
Target Decision: 8^th Oct 2024
• Total Consulted: 31
• Objections: 44
• Supporting: 0

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: 5^th Aug 2024
Consultation Closes: 9^th Aug 2024
Target Decision: 10^th Sep 2024
• Total Consulted: 10
• Objections: 4
• Supporting: 0
Councillor referral: Councillor Sue Bennett (13^th Aug 2024)
Councillor referral: Councillor Richard Chatterjee (14^th Aug 2024)

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: 1^st Jul 2024
Consultation Closes: 11^th Jul 2024
Target Decision: 29^th Jul 2024
• Total Consulted: 24
• Objections: 6
• Supporting: 0
Councillor referral: Councillor Richard Chatterjee (16^th Jul 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: 28^thJun 2024
Consultation Closes: 4^th Jul 2024
Target Decision: 25^th Jul 2024
• Total Consulted: 61
• Objections: 21
• Supporting: 6
Councillor referral: Councillor Richard Chatterjee (8^th 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: 10^th Jan 2024
Consultation Closes: 25^th Jan 2024
Target Decision: 27^th Feb 2024
• Total Consulted: 15
• Objections: 16
• Supporting: 0
Councillor referral: Councillor Richard Chatterjee (27^th 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: 10^th May 2024
Target Decision: 3^rd Jun 2024
• Total Consulted: 14
• Objections: 0
• Supporting: 0
Permission Refused: 3^rd Jun 2024
Appeal Notice: 27^th 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: 4^th Jan 2024
Consultation Closes: 20^th Jan 2024
Target Decision: 6^th Feb 2024
• Total Consulted: 46
• Objections: 6
• Supporting: 5
Councillor referral: Councillor Richard Chatterjee (22^nd Jan 2024)
Permission Refused: 7^th Feb 2024
Appeal Notice: 20^th 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.

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:

Form #01 (Para 1.4 Intro)	Form #02 (Table 1.1 Intro)	Form #03 (SP1.0 C)	Form #04 (Affordable Homes SP2.6 a-b)	Form #05 (Quality Standards SP2.8 a-f)	Form #06 (Housing Choice DM1.1 a-g)
Form #07 (Housing Choice DM1.2 Table 4.1)	Form #08 (Ref 20 Table 4.1)	Form #09 (Estate Renewal DM1 A)	Form #10 (Housing Choice DM1B para 4.32)	Form #11 (Design Character DM10.7 a-f)	Form #12 (Design Character DM10 para 6.60 Table 6.5)
Form #13 (Housing Choice DM13 Refuse Recycling)	Form #14 (Design Character Key Supporting Docs)	Form #15 (Policy DM28A)	Form #16 (The Places of Croydon DM34 to DM49)	Form #17 (NPPF Clarification SoS Guidance)

DEREK RITSON

MORA Planning

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