Evolving the suburbs
15/10/2018 08:25:00.......Posted by Mario Creatura
Today is the deadline to respond to the Council's 'Evolution of the Suburbs' planning document, a piece of work that will provide the framework for a significant number of buildings and developments across Croydon.
Residents have until tomorrow to feed their views into the process - my submission is below. You can find the full document here and email your views to firstname.lastname@example.org.
To whom it may concern,
I am writing as one of the elected representatives for Coulsdon Town ward, please accept this as a submission on the SPD2 Document that is currently out for consultation.
I have a number of concerns about the language used in the paper, not least that it appears to be a subjective document that raises significantly more questions than it is supposed to clarify. The report should be more of a definitive piece of work, instead it appears to allow a substantial amount of interpretation which could have detrimental effects on the character of Croydon.
There appears to be scant suggestion about developing the infrastructure needed to support significant population growth – was this not considered to be something merited in the document? Will there be a supplementary paper outlining the plans for increasing capacity on roads and services to cope with the residential increase? My fear is that the impartiality of the Planning Committee necessitates that each application is considered on its own merits, but that this does not factor in the wider implications of many applications sequentially being considered for the same area over a period of months. Put simply – if 10 applications are considered and approved in the same area over the period of 12 months, what guarantee is there in SPD2 that commensurate infrastructure improvements will be developed and progressed to aid in the increase in parking, sewage and other vital requirements for a good standard of living?
A good example of this is contained in paragraph 2.30 on car parking – an issue that is plaguing my ward in Coulsdon. Multiple blocks of flats are being erected, without commensurate car parking spaces. Residents moving into the properties, knowing that parking space on the street is limited, still bring their vechiles. They feel it will be the job of others to abandon their cars. Coulsdon is on the edge of the North Downs and is quite hilly. Whilst public transport is well-connected, the train service quality is intermittent and most modes do not reach out into Reigate, Banstead and wider Surrey in way that means cars lose their value. The increase in population due to the density of the new developments means there is a huge volume of vehicles needing parking space, causing traffic gridlock most mornings and evenings. Parking is not a luxury, it is a basic necessity to support the sustainability of development and communities.
Has the recently rolled out amended waste service programme being accounted for in paragraph 2.31? If not, then this will have implications on the ability for officers and councillors to interpret the report.
Whilst I am fully supportive of the need to develop new housing opportunities, these can and must be done in line with the reasonable support of the local residents already habiting in the area. Paragraph 4.2 details the papers support for ‘character’ but then details the three residential extension approaches of subservient, innovative and seamless. Can a development policy simultaneously respect the existing ‘character’ whilst being ‘subservient/innovative’? I am fearful that good quality affordable housing that fits into the local community aesthetic will not be a red-line in the document, meaning anything can and will happen to my residents.
In paragraph 2.7 and 2.8 the three types of approaches to character is described as ‘sympathetic and faithful’, ‘innovative and original’, ‘contemporary reinterpretation’. Surely any application, development or scheme can apply to any of these? Isn’t the scope for interpretation so large that this set of descriptions is legally meaningless? How can it be measured and enforced on each application? What happens if it can be easily justified (due to its lack of definitiveness) that a scheme has breached this criterion?
This fear for the respect of the local residents and existing character is not eased when I read paragraph 2.2 which details the overarching principles for development: to provide the right mix of homes in the right location, improve or positively contribute to local character and minimise impact on neighbouring amenity. How is this monitored and maintained? Is this rhetoric or are there tangible figures and targets that can be applied to what is a laudable aim? What is to stop someone ignoring this piece of guidance? To what extent are the views of the local people and their representatives taken into account on inappropriate developments that do not fit this nebulous aspiration?
This subjectivity and lack of clarity also exists in figures 1.3a, 1.3b and 1.3c which detail the evolution of the different types of suburbs, but are open to interpretation.
I believe that SPD2 requires a substantial reworking to address the concerns I’ve outlined above. These are very real, practical fears that I know many of my residents feel. Each time they attend a Planning Committee meeting to comment on a scheme they leave disheartened. I hope that by engaging with some of my concerns that this may be limited in the future.
Croydon badly needs good quality, affordable family homes. I know my residents would support them if they are proposed, and this plan is vital in making that happen.
Cllr Mario Creatura, Coulsdon Town