Areas of focused or moderate intensification are proposed for Coulsdon Town in the Local Plan Review. This we challenge on a number of grounds, particularly soundness of the proposals.
We ask a number of questions and challenge assumptions.
How much consultation has taken place with neighbouring authorities? Is this evidenced? Has there been any consultation with the emergency services? What about contact with Veolia for example? Properties on these roads are very difficult for refuse collection services at present. Any more development would further exacerbate the existing problems.
Coulsdon has suffered severe problems with sewage due to excessive pressure on the system due to an ever increasing number of developments. Chipstead Valley Road and Hadleigh Grove, Coulsdon are just two examples. What contact has there been with, for example, Thames Water for comment about sewage capacity?
More questions. How has the Local Plan been adapted to take into account Covid and increased numbers working from home? The demand for outdoor space and two or more bedroom accommodation has increased. There are too many one bedroom flats remaining on the market. Increased intensification, either moderate or focused, suggests more smaller units when the demand is changing. What evidence do we have that the Plan takes these factors into account?
Leisure facilities for the community are closing (Purley pool and Leisure Centre used by many Coulsdon residents for example) when demand is increasing. The Community Infrastructure Levy is not spent in the South of the Borough in areas where the money is raised. Developments continue apace with little or no regard for infrastructure.
Focused intensification is proposed for Bramley Avenue and roads to the east including (not exclusively) The Grove, The Avenue and South Drive.
Moderate intensification is proposed (again not exclusively) for Woodcote Grove Road, The Ridge, The Vale and Smitham Downs Road.
These roads have already been subjected to intensification. They are primarily narrow roads, with poor PTAL ratings. Developments in these roads have raised many concerns prior to any further intensification, including access for emergency vehicles and refuse collection vehicles.
Parking is a perennial problem in the Town, not just in the centre but also in the roads proposed for intensification.
Furthermore, proposals that will allow for densification of areas that are already densely built up are not compatible with preservation of character. Taller buildings have their place but not in either of these areas.
In order for this Local Plan to pass the Soundness test it should be Consistent with Achieving Sustainable Development. This would, as a minimum, require there to be proper design guidelines for any new developments. No such guidelines have been mentioned in the Local Plan.
The justifications given for intensification of these two areas are weak and unsound. There are other areas that meet intensification criteria that are more appropriate for development.
Croydon generally has exceeded set targets and Coulsdon particularly has played a huge part in increasing house and home provision.
In conclusion, the changes to Coulsdon proposed in the Local Plan Review are unacceptable and we hope that you will take these comments into account as part of the Review and remove the Coulsdon Town intensification elements.
Cllr Luke Clancy
Cllr Mario Creatura
Cllr Ian Parker