Questions about the Local Plan

Members of the Croydon’s Scrutiny Streets & Environment Sub-committee discussed the Local Plan which is under consultation.

I had submitted in advance a series of questions which I sent to all Councillors. The Chairman Cllr Sean FitzSimmons instructed the officers to provide Sub-committee members with copies.

Andrew Kennedy observed the meeting and my list was not mentioned nor specific questions I raised used by Councillors, although some of the questions they did ask echoed two of three of the themes covered by mine. You can see Andrew’s note as an attached document to his posting on Croydon Town Transition Facebook at

It is also on Historic Croydon Facebook.

Andrew tells me that:

  • ‘The whole emphasis of the Council officials presentation was that unless evidence was produced that was valid in planning law, then no changes were going to be made. That the number of objectors was immaterial.’
  • ‘What was taken on board by the planning officials was that there was no summary by location of the planning changes. In fact there were some anomolies in the document where only in one section was a change noted but not on other pages.’

The Questions I submitted

School Playing Fields

  1. Why is there no policy to protect school playing fields and grounds from non-educational development?
  2. Given the emphasis on the health and well-being role of open spaces and gardens why is there no discussion of the value or pupils of school playing fields for physical activity, day light exposure, gardening projects?

Open Spaces

  1. Why are there no proposals for the development of additional open spaces in North Croydon?
  2. Why are there no proposals for the safeguarding of specific small green spaces across the Borough such as at St Helen’s Rd in Norbury?


  1. Why is there no policy for safeguarding library buildings and site proposals for their retention as libraries and as community facilities?

Non-housing use of former housing stock

  1. Why is there no policy and proposals designed to encourage the return of property originally built as housing currently in office and service use with proposals to encourage and/or assist business owners to move into office and service buildings?

Railway Stations

  1. Other than for East and West Croydon Stations why are there no detailed proposals for improving accessibility to and within railway stations and the improvement of the immediate areas around them?

Bus Services

  1. Why is there no discussion of the need for frequency improvements to bus services in the light of the need for more capacity to serve the predicted growing population along London Rd given the car parking policy restrictions?
  2. Why are there no proposals for additional services to enable direct bus journeys to be taken from one part of the Borough to another e./g between Norbury and South Norwood, thereby encouraging more visiting of other centres especially where there are cultural facilities like Stanley Halls?


  1. While there is mention of a tram line along London Rd and across into Lambeth there is no discussion of the practical problems of:

(a)      either laying a one or two track system

(b)      if a one track system where would pass-by sections would be located

(c)      where stops would be located

(d)      competition with vehicle traffic adding to congestion and air pollution?


  1. Given there have been proposals over the last two years for SEGAS House to be converted into a community facility such as a community centre, art gallery, new venue for the Council museum and local studies, why has it been designated for housing use?
  2. Given the proposed closure of Fairfield Halls for two years as part of the Croydon College/Green redevelopment project why has SEGAS House not been seen as a potential temporary performance venue?

Planning Application Processes

  1. Why is there no policy proposal on the planning application process with a view to only validating applications if the documentation provided includes details of discussions with immediate neighbours, the provision of site location maps, design and access statements, and full drawings with clear measurements to ensure that neighbours and others can better understand what is being proposed?

Planning Enforcement

  1. Why is there no discussion on planning enforcement making it clear that the Council will take enforcement action where unauthorised building works are or have been carried out so that the work is undone before an application to regularise what the applicant plans can be validated?
  2. How many planning enforcement officers are currently in post and how many frozen vacancies are there?
  3. How many enforcement notices are outstanding? How old is the longest of these? How many enforcement notices were issued in each financial or calender year between 2008 and 2014? How many enforcement notices have been issued so far in 2015? Are similar statistics available for the actual number enforcement notices acted upon and complied with?

Housing Bedroom Occupation

  1. Since the proposed housing policy envisages that new affordable and social two bedroom homes should be able to cater for the needs of one/two parents and up to two children, will this not lead to the undesirable situation where children of the opposite sex above a certain age have to share a bedroom, and to limited space making the undertaking of homework difficult thereby hampering children’s educational development?

Note: the AECOM Sustainability Assessment Reports mentioned in the next set of questions are referred to as

AECOM 1 – Sustainability Appraisal (SA) of the Croydon Local Plan: Strategic Policies Partial Review &Detailed Policies and Proposals (November 2015)

AECOM 2 – Sustainability Appraisal (SA) of the Croydon Local Plan: Detailed Policies and Proposals Interim SA Report (November 2015) 

Housing Densities

  1. Given that AECOM 1 (p.4) indicates that in relation to Policy SP2 different bases for housing density could have negative effects in relation to housing, transport, biodiversity, flora and fauna, drainage, flooding and water quality and air quality, why are lower densities not being proposed?

Relationship between housing and economic growth

  1. Given that in noting that the Council’s Strategic Housing Market Assessment (SHMA) suggests a need to deliver a yet higher level of growth, AECOM 2 (para. 9.41) states ‘It could be the case that a higher housing growth strategy would support the achievement of economic growth objectives, given Croydon’s strategic position within the sub region; however, this is somewhat uncertain’ and if economic growth includes job creation, how can more employment sites be safeguarded?

Protecting employment sites

  1. As AECOM 1 (p. 8) notes that ‘the proposal to modify the policy approach to protecting industrial/warehouse capacity is … contentious, and that ‘it will be necessary to consider the potential for redevelopment affecting employment sites within Waddon and Broad Green & Selhurst to have a cumulative effect on local communities (recognising that there will be those within local communities who are reliant on light industrial employment, and my find it difficult to transition to other employment’ (p 8), will this issue be specifically highlighted at the public meetings for these areas?

Neighbourhood Centres

  1. While welcoming the introduction of a new ‘Neighbourhood Centres’ designation AECOM 2 (para 10.1.3) states that it how will ‘will be important to ensure that the policy approach to these areas is flexible, and is monitored closely to.’

Development Management

AECOM 1 (p. 8-10) notes that a strong development management and monitoring role is needed in respect of:

  • ensuring that opportunities to develop Neighbourhood Centres as ‘community hubs’ are fully realised
  • ensuring the introduction of low carbon energy infrastructure
  • the protection of urban green space (including garden land) and support the Green Grid
  • achieving ‘positive effects on the biodiversity baseline’
  • avoiding and mitigating noise
  • ensuring that design measures avoid/mitigate negative effects and result in new development that reinforces existing historic built character where possible
  • ‘to ensure that archaeological assets are given due consideration’
  1. Given the increasing staff cuts the Council will have to make how will it be able to ensure that development management monitoring will ensure positive effects can be achieved?
  2. How many planning staff are currently involved in this type of monitoring and how many staff vacancies for it are frozen?

Water Use

  1. Given that AECOM 2 (para 13.4.1) expresses concern that the potential ‘additional strain on already stretched water resources’, and that the Plan ‘it is not clear that this is a notably ambitious approach’, how can the Plan be amended to achieve a higher level of water efficiency in new and refurbished buildings through higher sustainable design and construction measures that specified in London Plan policy?

Drainage, flooding and water quality

  1. Given that AECOM 2 (para 14.4.1) considers that ‘the decision to increase the rate of housing growth in the urban area (where flood risk is focused) does lead to some concerns’ and that it ‘understood that work is ongoing to explore flood risk in more detail, and that this work may yet have an influence on site allocations’, when will that work be finalised and will it be included in the repot to the Cabinet on the outcome of the Local Plan consultation?
  2. Given that the Cabinet approved a Flood Risk Management Strategy on 16 November after the Local Plan documents were re-written and published, are further amendments required to the Local Plan to take account of the Strategy?
  3. Will any amendments required under Q.25 be made public during the consultation to enable members of the public to comment, and will they be included in the report to Cabinet as part of the

Quality of Data

AECOM 2 (pages 65-8) points out that its sustainability assessment was hampered in some respects by lack of any or only limited data in respect of the potential loss of employment sites, energy consumption, water use, air quality, noise and social exclusion.

  • Potential Loss of Employment Sites
  1. If there is no full understanding of the employment sites in the Borough and many of them are changed to residential use, is there a danger that fewer jobs will be provided in the Borough with more and more of the growing number of residents having to seek employment outside the Borough which will be further pressure on public transport and car journeys?
  • Energy Consumption
  1. Does not the lack of data indicate that the Plan’s wish to contribute to action on climate change and to reduce carbon dioxide emissions will not be met?
  2. What proposals are under consideration to strengthen the energy consumption of site options and to increase the measures that applicants will be expected to take?
  • Water Use
  1. What amendments to the Local Plan could be made to ensure the incorporation of high level of water efficiency measures into new and refurbished buildings?
  • Air Quality
  1. Can data-sets be compiled showing how air pollution varies within the Borough with a view to identifying amendments to be included in the report on the results of the Local Plan consultation to be submitted to the Cabinet? 
  • Noise
  1. Can noise contours data be compiled showing the different levels of noise at different times of the day and night across the Borough as influenced by main roads, major road junctions, railways, aeroplanes and helicopters, night-time economy activities and these be submitted to the Cabinet as part of the report on the results of the Local Plan consultation?
  • Social exclusion and Equality

 As AECOM suggests that ‘it is worthwhile considering the implications of development within areas of existing multiple deprivation (as defined by the Index of Multiple

Deprivation)’ what steps are being taken to do this?

  1. As AECOM points out that although ‘Development in an area of relative deprivation is assumed to be a positive step given that it can lead to developer funding being made available for targeted local schemes/initiatives’, ‘it is difficult to draw strong conclusions.’ What proposals are there for ensuring that future developer schemes will possibly address social exclusion and increase equality? 
  • Housing 
  1. As AECOM states that ‘No data exists to inform the appraisal of housing site options in terms of contribution to housing objectives’, how do the officers propose to assess each application for housing development?
  1. Given the current and future policies regarding the mix of bedroom sizes how do the officers propose to monitor the contribution to the achievement of the desired mix, and what measures will need to be taken to ensure that that any mix imbalance is rectified? 
  • Education, skills and training 
  1. In order to rectify AECOM’s view that the lack of data showing the location of existing schools ‘is a notable evidence gap’, can this be made public and submitted with the Cabinet in the report of the outcome on the Local Plan consultation? 
  1. Given that AECOM considers that ‘whilst the Index of Multiple Deprivation does identify areas of education and skills deprivation, this data is not considered suitably reliable’, are there any other data sources that will help improve the understanding of such deprivation, which can be submitted to the Cabinet in the report on the outcome of the Local Plan consultation? 
  • Culture, Sport & Recreation (AECOM. p. 68) 
  1. Given that AECOM states that ‘(l)imited data is available to inform the appraisal of site options’ and that ‘(i)deally, data would be available to show the location of sports and recreational facilities’, can such data be published and included in the report to the Cabinet reporting the results on the Local Plan consultation?

You may want to ask some of these at the public consultation meetings.

If you want further information please email me at 


About seancreighton1947

Since moving to Norbury in July 2011 I have been active on local economy, housing and environment issues with Croydon TUC and Croydon Assembly. I am a member of the Love Norbury Residents Associations Planning & Transport Committees, and Chair of Nobury Community Land Trust. I write for Croydon Citizen at I co-ordinate the Samuel Coleridge-Taylor and Croydon Radical History Networks and edit the North East Popular Politics database. History Project.. I give history talks and lead history walks. I retired in 2012 having worked in the community/voluntary sector and on heritage projects. My history interests include labour movement, mutuality, Black British, slavery & abolition, Edwardian roller skating and the social and political use of music and song. I have a particular interest in the histories of Battersea and Wandsworth, Croydon and Lambeth. I have a publishing imprint History & Social Action Publications.
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