Last chance to comment on Croydon Council's planning policies
A few weeks ago, Croydon Council published the latest version of its planning policies. They have listened to some of the concerns residents raised about a previous version of these proposals - for example, they have dropped plans for travellers sites at Coombe Farm, at Conduit Lane and at Pear Tree Farm - but they are still going ahead with damaging plans to build on Green Belt and Metropolitan Open Land and to allow intensive development that would change parts of Forestdale and Shirley.
We have one last chance to have our say. These representations will be considered not by the Council, but by an independent inspector appointed by the Planning Inspectorate. You can make representations online here or by emailing firstname.lastname@example.org.
Please note that:
a) the deadline is close of play on Monday;
b) you must give your name and an email or postal address; and
c) simply saying you don't agree with something won't do any good. The inspector isn't interested in public opinion; their job is to test whether the Council's policies are sound - whether they are positively prepared (based on a strategy which seeks to meet objectively assessed development and infrastructure requirements); justified (the most appropriate strategy when considered against the reasonable alternatives); effective (deliverable over the plan period); and consistent with national policy.
I have included my submission below. Feel free to lift any sections which you agree with.
Spatial Planning Service
6th Floor Zone B, Bernard Weatherill House
8 Mint Walk
Croydon, CR0 1EA
Croydon Local Plan: Strategic Policies - Partial Review (Proposed Submission) and Croydon Local Plan: Detailed Policies and Proposals (Proposed Submission)
In my capacity as the Member of Parliament for Croydon Central, I would like to make the following representations on Croydon Local Plan: Strategic Policies - Partial Review (Proposed Submission) and Croydon Local Plan: Detailed Policies and Proposals (Proposed Submission).
I broadly support the spatial vision and strategic objectives set out in section 3 of Croydon Local Plan: Detailed Policies and Proposals (Proposed Submission) and in particular the ambition to increase housing delivery. There are four areas that affect my constituency where I believe the Council’s proposals are either not positively prepared, not justified, not effective and/or not consistent with national policy (I have not commented on policies affecting sites in other parts of the borough).
De-designation of Green Belt on land west of Timebridge Community Centre, Lodge Lane
I object to the de-designation of Green Belt on land west of Timebridge Community Centre, Lodge Lane as detailed in the description of site 636 in Appendix 5 of Croydon Local Plan: Detailed Policies and Proposals (Proposed Submission). It is worth noting that there is an inconsistency between Croydon Local Plan: Strategic Policies - Partial Review (Proposed Submission) and Croydon Local Plan: Detailed Policies and Proposals (Proposed Submission) on this point: the former does not refer to any de-designation of this land in Table 6.1.
Assuming the Council is planning to de-designate this land, I believe this is neither positively prepared nor justified because, contrary to the Council’s assertion, there is a surplus of secondary school places in this part of the borough. It is also inconsistent with both national and regional policy. Policy 7.16 of the London Plan states that “the Mayor strongly supports the current extent of London’s Green Belt” (emphasis added). The National Planning Policy Framework (NPPF) is clear that “once established, Green Belt boundaries should only be altered in exceptional circumstances” (paragraph 83, emphasis added). Given that there is a surplus of school places in this part of the borough, this test is clearly not met. The site clearly serves four of the five purposes of Green Belt set out in paragraph 80 of the NPPF, namely
• to check the unrestricted sprawl of large built-up areas;
• to prevent neighbouring towns merging into one another (it forms part of the gap between the settlement of New Addington and the contiguous development in the rest of the borough);
• to assist in safeguarding the countryside from encroachment; and
• to assist in urban regeneration, by encouraging the recycling of derelict and other urban land.
Whether or not the Council is proposing to de-designate the land as Green Belt, it is clearly planning to allow a secondary school to be built on it as set out in Policy DM36.2 and Table 11.5 of Croydon Local Plan: Detailed Policies and Proposals (Proposed Submission). I submit that would be inconsistent with both national and regional policy. Paragraph 89 of the NPPF states that, subject to certain exceptions of which schools are not one, “a local planning authority should regard the construction of new buildings as inappropriate in Green Belt”. Policy 7.16 of the London Plan states that “the Mayor strongly supports...its [the Green Belt’s] protection from inappropriate development”.
Finally, the proposal is inconsistent with the Council’s own policies SP7.2 and DM27.1.
De-designation of Metropolitan Open Land around Shirley Oaks Village
I object to the de-designation of Metropolitan Open Land (MOL) around Shirley Oaks Village as detailed in Table 6.1 of Croydon Local Plan: Strategic Policies - Partial Review (Proposed Submission).
MOL is a designation only used in Greater London. Policy 7.17 of the London Plan states that land designated as MOL should meet one of the following criteria:
1. It contributes to the physical structure of London by being clearly distinguishable from the built up area.
2. It includes open air facilities, especially for leisure, recreation, sport, the arts and cultural activities, which serve either the whole or significant parts of London.
3. It contains features or landscapes (historic, recreational, biodiversity) of either national or metropolitan value.
4. It forms part of a green chain or a link in the network of green infrastructure and meets one of the above criteria.
This land is clearly distinguishable from the built-up area and forms part of a green chain (which the London Plan says can consist of “footpaths and the open spaces that they link, which are accessible to the public”) with Ashburton Playing Fields, Long Lane Woods, the golf driving range on Long Lane, the playing fields around Croydon Arena, South Norwood Country Park and Beckenham Cemetery. The proposal is therefore not justified.
Policy 7.17 of the London Plan also states that “the Mayor strongly supports the current extent of MOL” (emphasis added) and that “the policy guidance of paragraphs 79-92 of the NPPF on Green Belts applies equally to MOL” - for example, paragraph 83 which, as noted above, states that “once established…boundaries should only be altered in exceptional circumstances” (emphasis added). The proposal is therefore also inconsistent with national and regional policies.
Finally, the proposal is inconsistent with the Council’s own policies SP7.2 and DM27.1.
If, despite the above arguments, it is accepted that the land should be de-designated as MOL then all of it that is not allocated for housing should be designated as Local Green Space. Paragraph 77 of the NPPF states that this designation should be used:
• where the green space is in reasonably close proximity to the community it serves;
• where the green area is demonstrably special to a local community and holds a particular local significance, for example because of its beauty, historic significance, recreational value (including as a playing field), tranquillity or richness of its wildlife; and
• where the green area concerned is local in character and is not an extensive tract of land.
The land demonstrably meets the first and third test and the level of public response to the Council’s proposal shows how strongly the local community feels about it.
Croydon Local Plan: Detailed Policies and Proposals (Proposed Submission) replicates the first and third of these tests, but replaces the second test with more detailed criteria, namely that sites should be publicly accessible and at least one of the following:
• a historic park or garden;
• a community garden;
• a children’s play area;
• a tranquil area;
• a natural and semi-natural open space;
• a cemetery, church yard or burial ground;
• a site of Nature Conservation Importance; or
• a playing field or recreation ground.
All of the land that is not allocated for housing is publicly accessible and meets at least one of these tests.
Areas of focused intensification in Forestdale and Shirley
I object to the detail, rather than the principle, of the areas of focused intensification proposed around Forestdale Neighbourhood Centre, Shirley Local Centre and Shirley Road Neighbourhood Centre as detailed in policy DM35.4 and Table 11.2.
Paragraphs 11.14 and 11.15 of Croydon Local Plan: Detailed Policies and Proposals (Proposed Submission) set out what this policy would mean:
“New development located in designated areas would be significantly larger than existing and may be associated with merging smaller properties. Height increase should be up to double the predominant height of buildings in the area. The promoted character types for the areas of focussed intensification are: ‘Medium-rise Blocks With Associated Grounds’, ‘Large Buildings With Spacing’ and ‘Large Buildings With Continuous Frontage Line’. Their gradual introduction will alter over time the predominant character of intensified areas”.
In all three cases, the proposed areas are still too widely drawn including all or part of some residential streets where intensification would fundamentally change the character of the built environment (by way of example - this is not an exclusive list - parts of Huntingfield are including in the Forestdale Neighbourhood Centre area, one side of Eldon Avenue is included in the Shirley Road Neighbourood area and West Way Gardens is included in the Shirley Local Centre area). It would be more justified to limit these areas to the main roads only.
In the case of the two Shirley areas, this argument is strengthened by the fact that they are not a very good fit with the criteria set out in Policy DM35.4. The policy says areas should have “good accessibility to public transport”, but unlike many other areas of the borough Shirley is not served by either the tram or rail network, relying solely on bus routes which run along Wickham Road, Shirley Road and Addiscombe Road, all of which are heavily congested and do not have bus lanes. There is no mechanism in the plan to deliver the necessary improvements to public transport, so this proposal is not positively prepared.
Finally, the Shirley Local Centre area includes properties on the Wickham Road, Hartland Way and Devonshire Way that I understand have restrictive covenants limiting housing density, which suggests that this proposal may not be effective.
I support Policy DM16, which permits tall buildings in certain parts of the borough. However, I have consistently argued that in relation to the Opportunity Area the policy should be amended so that the tallest buildings are allowed in the centre of the town, with heights gradually reducing towards the edge of the tall buildings zone. A policy of allowing very tall buildings immediately opposite two-storey residential housing is not justified.
In my capacity as a constituency MP, I would like to participate in the oral part of the Examination in Public.
Member of Parliament for Croydon Central