It is time for all Croydon Councillors to stand up against the authoritarian control of the Leadership and its continual operating methods that limit openness and transparency and refuse to rubber stamp the proposed further modifications to the Local Plan until they have been examined by the Planning or Scrutiny Committees and then through Cabinet.
On Monday 5 December the full Council meeting will be asked to rubber stamp the modifications approved by the Leadership and the officers to the Local Plan to be submitted to public inquiry next year.
This procedure was allowed back in July when the full Council failed to reject the Cabinet decision to report directly to Council the outcome of the consultation directly to Council.
The results of the consultation should have been submitted either to the Planning or Scrutiny Committee and then to Cabinet so that it could be properly seen how the officers were responding to the submissions made and people who had made submissions would have had the chance to comment and seek to influence the final modifications.
Submission straight to the Council will just mean the proposed modifications are rubber stamped.
No Proper Review of Consultation Submissions
There is no documents setting out each comment and request modification.
The submissions on Strategic Policies are simply summarised as:
- A need for a review of the Metropolitan Green Belt to deliver the number of homes needed.
- The proposed change of a minimum requirement of 30% affordable homes on sites of 10 dwellings or more
- The proposed clause to the Affordable Homes Strategic Policy (SP2.5) that a Review Mechanism can only be entered into provided that the construction costs are not in the upper quartile of build costs
- That the flexibility provided by paragraph 4.11 regarding the acceptance of commuted sums in-lieu of on-site provision of affordable homes and tenure splits should form part of Affordable Homes Strategic Policy (SP 2.3 – 2.5).
- Justification for proposed change to the Sustainable Design and Construction Strategic Policy (SP6.3 (g))
- The proposed changes to the designation of Metropolitan Open Land at Shirley Oaks Village and Metropolitan Green Belt land at Croham Hurst, Sanderstead Plantation and Purley Downs.
- The change from Local Areas of Special Character (LASC) to Local Heritage Areas with some existing LASCs not being designated Local Heritage Areas.
The Detailed Policies and Proposals consultation is summarised as:
- Objection to policy on protecting back garden land stating that it does not protect back gardens sufficiently
- The policy on vacant building credit is too restrictive and will prevent developers from benefiting from vacant building credit
- Policy DM5.3 (restricting use of ground floors in town centres outside of designated frontages for commercial uses) conflicts with Policy DM16.2 (requiring publically accessible uses on the ground and first floors of tall buildings)
- The wording of Policy DM19 on Heritage is stronger than that in the National Planning Policy Framework and the level of protection is not justified
- Sanderstead Plantation should remain Metropolitan Green Belt and not be a Local Green Space APPENDIX 2 8
- The principle of focussed intensification and impact on character
- The areas of focussed intensification should be reduced in extent to cover only main roads
- The areas of focussed intensification are not justified because they have a Public Transport Accessibility Level rating of 2, not 3 to 4.
- The site allocation at Purley Pool should specify that the swimming pool is a 25m x 10m pool.
- Purley Oaks depot is not suitable for a Gypsy and Traveller site and a site should be provided on Purley Way instead.
- Land in Poppy Lane (site 128) should not be developed for housing as it is not suitable.
- Support for the proposed allocation of Coombe Road Playing Fields as a site for a secondary school
- Objection to the loss of Green Belt for schools at Coombe Road Playing Fields, Portnalls Road and Land west of Timebridge Centre
One of the Strategic Policies is being downgraded. It is proposed to deletion the clause ‘Requiring new build development to consider the incorporation of innovative sustainable construction techniques.’ The reason given is that it duplicates a Detailed Policy to ‘Encourage the use of sustainable and innovative construction materials in buildings’. This will be amended to to refer to techniques as follows ‘Encourage the use of sustainable and innovative construction materials and techniques in developments’.
Welcome modifications are the addition of Beulah Rd as a Local Centre and the green north of Tollers Lane as Metropolitan Green Belt. Croydon TUC/Assembly will be pleased that its proposal to amend the policy of ‘Seeking to return 190 vacant homes back into use by 2026’ by the addition of ‘at least’ has been accepted.
The housing target is to be increased from 31,850 to 32,890 by a reduction from 7,300 to 6,970 homes beyond the Croydon Opportunity Area; an increase of 110 to 10,760 net additional in the Opportunity Area; and an increase from 9,120 to 10,060 across the borough on windfall sites. It notes that 4,890 are either completed or under construction.
There are several welcome Detailed Policies and Proposals Changes.
This amendment should make it easier to protect areas: ‘To ensure that development enhances and sensitively responds to the positive elements of existing character, including built form and spaces, proposals should be of high quality and respect:”
This Policy is being strengthened by the addition of the words in italics. “All flatted development and developments of 10 or more houses must provide a minimum of 10m2 per child of new play space, calculated using the Mayor of London’s population yield calculator and as set out in Table 6.1 below. The calculation will be based on all the equivalent of all units being for affordable or social rent unless a signed Section 106 Agreement states otherwise or an agreement in principle has been reached by the point of determination of any planning application on the amount of affordable housing to be provided.”
A contradiction between policies is being addressed by the deletion of ‘To ensure tall and large buildings are well integrated with the local area, the ground and first floors should incorporate a mix of publically accessible uses and spaces.’ Another section is being re-worded.
“To ensure tall or large buildings respect and enhance local character, and do not harm the setting of heritage assets, proposals will be permitted where they: a) Are located in areas identified for such buildings in Policies DM36 to DM51, in masterplans and in the Croydon Opportunity Area Planning Framework; b) Are located in areas meeting a minimum Public Transport Accessibility Level (PTAL) rating of 4 with direct public transport connections to the Croydon Opportunity Area; c) The design should be of exceptional quality and demonstrate that a sensitive approach has been taken in the articulation and composition of the building form which is proportionate to its scale; and d) The building height, footprint and design relates positively to any nearby heritage assets, and conserves or enhances the significance and setting of the assets and the wider historic environment; de) To improve the quality and access to open space buildings taller than 40 storeys will need to incorporate amenity space, such as sky gardens, atriums and roof terraces, that is accessible to the public as well as residents of the development; and f) To ensure tall and large buildings are well integrated with the local area, they should include at least an active ground floor and inclusive public realm.’ (Changes in italics)
Gordon Crescent playground, Oakland Wood, Auckland Rise children’s playground are being designated as Local Green Spaces. Peabody Close Playing Fields and Allotments are being to the edge of Poppy Lane. One car parking space will now to allowed for minor residential and non-residential developments as opposed to none. There are some changes in potential uses for a small number of sites.
Added: 5 December.
I sent all Councillors the link to this posting. Paul Scott, Chair of the Planning Committee has sent me the following comment: