Today is the last day that the Council is accepting submissions to it's Local Plan Review - the consultation closes at 5.00pm today.
Rather than struggle with the Council's webpage, you can email your comments direct to: firstname.lastname@example.org
This is a really important consultation as it will impact the type of development which we can expect to see being rolled out across our local area in the years ahead and residents may well share my serious concerns about the degree of intensification being proposed by the labour Council.
I have enclosed below the details of the submission which I lodged this afternoon.
"From: Hale, Lynne
Sent: 17 February 2022 13:44
To: Local Development Framework <LDF@croydon.gov.uk>
Subject: Draft Local Plan Review submission
Regulation 19 Consultation – Proposed submission draft of the Croydon local plan 2019 to 2039.
Please find below my submission with respect to the above consultation.
I would like to start by setting out my concerns about this consultation which I believe fails the soundness test in terms of the required ‘Positively Prepared’, ‘Justified’, ‘Effective’ and ‘Consistency with National Policy’ criteria.
- The consultation has not been widely advertised by the Council and until local political representatives and a few residents’ associations started sharing their submissions through their local networks, few residents were aware of this really important consultation
- The request that submissions be made through a particular webpage made it inaccessible to many residents who found trying to do this very difficult – and many will not be aware that sending an email to the Local Development Framework email address was acceptable. I have received feedback from a number of residents as well as some very planning astute residents’ association representatives about the requirement to respond to the consultation via a clunky council website form. It is very difficult for people to use.
- There is at least one important error in the consultation document which the Council has acknowledged:
“Regrettably, Plan Making Team – Spatial Planning has identified that the original description in the Croydon Local Plan 2018 (324: Purley Oaks Depot – 505-600 Brighton Road) in the Local Plan Review documents has changed from Council Depot to ‘Council Depot and Recycling Centre and Council refuse and recycling centre’ and should read Council Depot only, as set out in the Local Plan 2018. This is an error..”
- This consultation has been rushed out prior to important Mayoral and Local Elections May 2022, which will undoubtedly bring significant change to Croydon and the governance of our Borough. I do not believe that the current administration has the moral authority to submit such an important document to the Secretary of State at such a late stage in the electoral cycle. Many local planning experts and resident associations who have pored over the document have expressed alarm that senior council officials appear to be trying to push through the binding Local Plan revisions with much higher-than-required housing targets ahead of this May’s Town Hall elections.
- Very little time has been given to the public to understand its implications. It is wholly unreasonable to expect the public to go through more than 800 pages of complex and technical information in such a short space of time: 6th January to 17th February 2022.
In terms of the soundness criteria I would comment as follows:
- Not positively prepared:
a. No evidence has been provided that the proposed approach meets Croydon’s needs, nor that those needs have been objectively assessed, nor that this proposed approach will meet such needs. No evidence has been provided as to why a Focused and Moderate Intensification approach has been decided. No attempt has been made to compare and contrast this intensification approach against a design focused approach.
b. Not informed by agreements with other authorities. No demonstration of agreement with other authorities, such as neighbouring Bromley or Sutton, has been provided in this document. Thus it fails this test of soundness.
c. Not consistent with achieving sustainable development. This intensification is contrary to the principles of sustainable development as much is undeliverable. The green spaces which are identified for development are mainly in areas which have poor public transport accessibility and will be car-dependent, so development here would increase congestion and pollution.
2. Not justified:
a. No alternative approaches have been set out at all so there is a complete lack of balance. Sadly it’s another case of the council thinking that it knows best and is content to just tell residents whet they are getting. Since no reasonable alternatives have been offered, the consultation fails the justification test of soundness.
b. Based on proportionate evidence, no information has been given on how this approach of intensification is proportionate, hence this test of soundness has not been met.
3. Not Effective:
a. Deliverable over the plan period: no information has been given on how this approach of intensification is deliverable over the plan period, hence this test of soundness has not been met.
b. Based on effective joint working on cross-boundary strategic matters that have been dealt with rather than deferred: no information has been given on how this approach of intensification is based on effective joint working on cross-boundary strategic matters that have been dealt with rather than deferred, hence this test of soundness has not been met.
c. Able to be monitored: No information given on how this will be monitored, and this council has a poor monitoring track record, hence this test of soundness has not been met.
The wrong development approach has been taken
I believe that there is insufficient focus on the type of homes being built - where is the evidence that residents want 3 or 4 bedroom flats which are currently being pushed into developments?
The focus in this Draft Plan is for intensification led development, but I and many local residents think our development plan should be design led like neighbouring boroughs:
- protecting character of local areas and
- protecting mature suburban gardens with their rich biodiversity offer with
- a stronger emphasis on design and character of heritage assets
There is no evidence that focussed intensification is actually deliverable or desirable and residents are keen to see improved infrastructure and better transport links to cope with the already significant increase in population.
Specific policy points
- The proposals in SP1.0C and DM10.11 to allow for "focused" and "moderate" intensification - entailing building very dense or larger buildings in place of family homes in many peaceful and green suburban parts of the Borough will fundamentally change the character of these areas. These policies take no account of cumulative effects, which may see whole streets of family houses destroyed. I am particularly concerned that protections around character, size and cumulative impact that exist in the current policy DM10.1-10.8 are to be deleted or substantially watered down.
I believe that this is inconsistent with the NPPF's provisions about good design, and wholly without justification.
2. I am concerned about the significant "intensification" proposed for Coulsdon (DM37), Kenley (DM40), Purley (DM42), Sanderstead (DM43), Selsdon (DM44), South Croydon (DM46), Waddon (DM49), which are all peaceful suburban areas.
3. I also believe that the housing targets are simply wrong in the way they are allocated across the Borough.
a) The table on page 34 appears to take little or even no account of the council's own 5 year housing land supply (identified in its own most recent monitoring report) of 17,707 dwellings - almost double the 9,153 required.
b) It appears that the Croydon Opportunity Area figure of 14,500 takes inadequate or even no account of the Brighton Mainline or North End Quarter opportunities, which are huge. These would allow the Croydon Town Centre figure (currently 14,500) to be a lot higher.
c) The target figure for Purley at 5,735 is far too high and would turn a peaceful suburban centre into a small city. This is unnecessary and destructive. The figures for Coulsdon, Kenley, Selsdon and Sanderstead are also inappropriately high as drafted. In all of these areas no recognition has been made of the current inadequate infrastructure which would be required to support such growth, in terms of schools, healthcare facilities, drainage and transport etc.
d) Croydon currently has a comfortable land supply and given that the Brighton Main Line and North End Quarter Opportunity areas are not represented in the figures the significant wider suburban "intensification" is simply not justified as necessary to meeting housing targets. There are ample Croydon Town centre and brownfield sites to meet the housing need in Croydon without "intensifying" the suburbs and turning the whole Borough into a highly dense urban area, with no meaningful planning protection.
4. Policy DM42.1(b) for a 16 storey tower in Purley (where most buildings are 3 floors) has been left in but this has been carried over from the previous Local Plan, and the building is now under construction, so this reference should be removed.
5. I am also concerned that the Purley Way Transformation proposals have many blocks of flats up to 8 floors. This is therefore a missed opportunity to create streets of liveable houses, not yet more tower blocks.
Specific concerns about Sanderstead Ward
- Character, Heritage and Design
Policy number/paragraph: 11.177
This is ambiguous and unspecific with no clarity on the phrase ‘the distinct identities between the northern and southern ends of Limpsfield Road will continue to be defined through differences in the density of the urban grain’.
There needs to be clear analysis and information provided to describe the ‘distinct identities’ which should be supported by written descriptions and zonal maps within the Plan. At the moment the term is meaningless, non-specific and amorphous ‘planning speak’ which needs to be refined to enable residents to understand the proposed policy.
2. Intensification in Sanderstead
Policy number/paragraph: DM10.11D
The policy states ‘in other areas of the borough (excluding Conservation Areas and Local Heritage Areas) to support evolution without significant change, the developments should complement the predominant height, scale and density of buildings in the area.’
Unambiguous confirmation is required that the above policy will be applied consistently in areas with low PTAL ratings and not within any defined area for moderate intensification. The stated policy appears to directly contradict the Croydon Council Suburban Design Guide
If this policy is to be adopted, the Suburban Design Guide needs to be redrafted to align with the policy or completely set aside to avoid ambiguity and to provide clear information and understanding to residents and planning officers.
3. Sanderstead: Designated Green Spaces
Policy number/paragraph: DM26.4
Sanderstead Recreation Ground currently has the National designation of being Metropolitan Green Belt land. The Plan seeks to protect the land under the new local designation of ‘Very Important Community Green Space’. Whilst this would be welcomed as an additional protection, the Plan makes no mention of the recreation ground’s existing Metropolitan Green Belt status.
The Plan should make it clear that Sanderstead Recreation Ground’s ‘Very Important Community Green Space’ protection is in addition to its Metropolitan Green Belt Status.
4. Environment and Climate Change
“There have been a number episodes of surface water flooding in Sanderstead, particularly in the Hamsey Green Local Centre area and along main roads through the area.”
The introduction of the recognition of surface water flooding episodes is welcomed as this needs remedial action as well as taking into account when assessing any new development proposals for the east side of Limpsfield Road.
Overall I believe the Draft Local Pan to be unsound because it lacks justification and fails to enshrine the good design principles required by the NPPF. It is unlikely to be effective as the plan as it stands is not deliverable and is not based on sufficiently evidenced effective cross-boundary strategic matters.
I would like to attend and speak at any public enquiry held by the Planning Inspector.
Cllr Lynne Hale
Sanderstead Ward, L B Croydon