Planning Report – April 2020

IMPORTANT NOTE: Due to the Coronavirus outbreak, all Croydon Council Planning Meetings have been replaced by ‘virtual’ Planning Meetings which will not be attended by either elected representatives or members of the public.

We will keep you fully informed on all Planning Developments, Applications and Decisions during this difficult time.


Awaiting Decision

Planning Complaints

Additional Matters



Land R/O 211 Wickham Road – Ref: 20/01256/FUL
Demolition of existing structures to the rear of 211 Wickham Road and erection of a two storey building containing four dwellings with associated alterations .

The Residential Density at 400hr/ha at PTAL 2 for an Urban Setting is within the range of 200 to 450 hr/ha and Housing Density of 133.33u/ha at PTAL 2 for an Urban Setting is within the range of 70 to 170 units/ha so acceptable Densities for the Setting (Shirley Urban Shopping Centre at area designated “Focussed Intensification” PTAL 2 – This application proves it can be done if suitably planned!).

Ingress & Egress Parking
Accepting that the vehicles are parked as shown on the plans provided in a forward direction, and that the Access drive is ≈4.7m wide, it is unclear how each would park in a forward direction and then exit from the parking bay (if all other Bays were occupied) and exit the driveway across the footpath in a forward gear.

We have requested that the Case Officer requires the Applicant to provide credible swept path illustrations of the ingress and egress of each vehicle if all other bays are occupied, to prove accessibility or otherwise for ingress and egress without fouling the boundary fencing (not shown on the plans) or encroaching too near another parked vehicle.

SPD2 Chapter 2 Suburban Residential Developments Section 2.29.3
Entrances should avoid tall wall or wooden fences either side of a new driveway that close off the development to the street.

It is noted that the 1.8m Close Boarded fencing on the side boundary of 2 Ridgemount Avenue precludes any visibility splay of the footpath to the north when exiting the driveway into Ridgemount Avenue.

SPD2 Policy 2.29 e) states: For “Pedestrian Visibility Splays from 2.8m back from the edge of the public footpath and 3.3m either side. There shall be no obstruction higher the 0.6m”.

MORA Submission Sent: 3rd Apr 2020
Consultation Closes: 15th Apr 2020
Target Decision: 11th May 2020
• Total Consulted: 21
• Objections: 0
• Supporting: 0

Further developments are in the May 2020 Planning Report.


67A Orchard Avenue – Ref: 20/00356/FUL
Front extension and part two storey, part single storey side extension and associated alterations for the conversion of the house into two flats.

This proposal considerably exceeds the Residential Density and Housing Density for this location at a suburban Setting and PTAL 1b and should therefore be refused.

The existing and future planned Infrastructure has NOT been evaluated in accordance with the London Plan Policy 3.4 – Optimising Housing Potential or the emerging London Plan Policy D1A – Infrastructure requirements for sustainable densities or D1B – Optimising site capacity through the design-led approach. As such this proposed development is unsustainable when evaluated using currently available TfL analysis information as clearly set out above with respect to Public Transport Accessibility Level – PTAL and should therefore be refused in accordance with the Policy.

MORA Objection Sent: 26th Feb 2020
Consultation Closes: 27th Feb 2020
Target Decision: 21st Mar 2020
• Total Consulted: 6
• Objections: 6
• Supporting: 0
Permission Granted: 3rd Apr 2020

Further developments are in the May 2020 Planning Report.

67 Orchard Avenue – Ref: 20/00092/FUL
Demolition of existing garage; erection of a two storey side extension, two storey rear extension, loft conversion with roof lights in the front roof slope and dormers in the rear roof slope, the construction of rear basement with terrace area and external staircase and alterations to the front vehicular access and boundary treatment. Conversion of single dwelling into 6 flats – 3 x 1 bedroom flat and 3 x 2 bedroom flat; provision of car parking, refuse and recycling store, soft landscaping and new vehicular access onto Woodland Way, with hardstanding area.

This proposal fails to meet minimum accommodation standards as defined by the current adopted and emerging London Plan Policies which if the proposal were to be approved, would be extremely detrimental for future occupiers for the life of the development.

The proposed Residential and Housing Densities at 300hr/ha & 85.71 units/ha respectively is excessive for a PTAL of 1b as defined by the Transport for London WebCAT.

At Residential Density of 300hr/ha at a suburban setting would require a PTAL of 5.33 and the Housing Density of 85.71 Units/ha would require a PTAL of 5.02 (an Access Index Range of 20.01 to 25.0) which significantly exceeds the current or planned PTAL of 1b (numerically equivalent to 1.33 or an Access Index Range of 1b at Access Index of 2.51 to 5.0 ).

The area of Communal Amenity Space is not specified as an allocation per occupant.

There is NO Designated Play Space for Children – None provided as required (Para 5.4.5 Draft London Plan 2019).

MORA Objection Sent: 4th Feb 2019
Consultation Closes: 16th Feb 2020
Target Decision: 9th Mar 2020
• Total Consulted: 12
• Objections: 6
• Supporting: 0
Permission Refused: 20th Mar 2020

211 Wickham Road – Ref: 20/00299/FUL
Demolition of existing ancillary buildings associated with the shop and erection of a new two storey building containing four dwellings.

Consultation Closes: 20th Feb 2020
Target Decision: 18th Mar 2020
• Total Consulted: 18
• Objections: 1
• Supporting: 0
Application Withdrawn: 17th Mar 2020

Further developments are given above.

Awaiting Decision

195 Shirley Road – Ref: 19/06037/FUL
Demolition of existing property. Erection of 2.5 storey (replacement) building comprising 9 residential flats with associated car/cycle parking, landscaping and waste stores.

We objected to this proposed re-development on the following grounds:

1) Failure to meet the London Plan and Croydon Plan Policy DM10 Minimum Space Standards for the future occupants for the lifetime of the development;

2) Failure to meet the existing adopted London Plan Policy 3.4 – Optimising Housing Potential with respect to Residential and Housing Densities at a Suburban setting at PTAL 2, and forecast to remain at PTAL 2 until 2031;

3) Failure to meet the new Draft London Plan Policy 1DA – Infrastructure Requirements for Sustainable Densities;

4) Failure to evaluate requirements of the proposal as required by the “Design-led approach” as required of the new London Plan Policy 1DA – Infrastructure Requirements for Sustainable Densities at Policy D1A paras 3.1B.23/24;

5) Excessive Overdevelopment for the locality, forecast to remain at PTAL 2 up to 2031 in terms of appropriate Residential and Housing Densities in a “Suburban Setting”;

6) Inadequate Amenity Space or Communal Open Space for the future occupants of the development for the lifetime of the development;

7) No provision of the required “Play Space for Children” of the future occupants of the development’ as required by the London Plan and Croydon Local Plan 2018.

MORA Objection Sent: 24th Feb 2020
Consultation Closes: 26th Feb 2020
Target Decision: 30th Mar 2020
• Total Consulted: 19
• Objections: 5
• Supporting: 0
Councillor referral: Councillor Sue Bennett (24th Feb 2020)

Further developments are in the May 2020 Planning Report.

Orchard Park High School – Ref: 19/04183/FUL
Single storey rear extension, conversion to community gym including external alterations and access arrangements

Design & Access Statement
8.0 Conclusion

  • The opportunity to implement this scheme would utilise an existing building.
  • We believe the conversion to the existing facility will offer fitness to a wider customer base and prove an asset to the area.
  • The change of use for Use Class D2.
  • The proposal will create a range of full-time part time and self-employment opportunities within the local economy.
  • The proposed scheme will involve a large invest by the applicant and will provide a high-quality facility. The facility will offer fitness to a wider customer base and prove a long-term asset to the area.
  • Taking all the above into consideration, we believe the proposal brings into use a vacant building, in a suitable location and satisfies planning policy.

Consultation Closes: 16th Oct 2019
Target Decision: 8th Nov 2019
• Total Consulted: 72
• Objections: 1
• Supporting: 0

Further developments are in the May 2020 Planning Report.

Land R/O The Shirley Inn Public House 158 Wickham Road Croydon: 19/03279/FUL
Erection of a residential development of two detached three storey buildings comprising a total of 6 flats (2×1 bed, 2×2 bed, 2×3 bed), provision of refuse and cycle storage, hard and soft landscaping and provision of two parking spaces.

The proposed development is outside the MORA area but in the Shirley North Ward. The application is in the Spring Park Residents’ Association (SPRA) Area, but we are in support in objecting to this development.

The proposed development fails to meet the objectives of London Plan Policy 3.4 – Optimising Housing Potential Table 3.2 in relation to an Excessive Residential Density of 459.77 hr/ha requiring a local PTAL of 5.031 when the local PTAL is actually only 3 and forecast to remain at PTAL 3 until 2031.

There is no allocated play space for children of the future occupants of this proposed development.

The development has inadequate parking provision in an Urban Shopping Locality of PTAL 3 of only two Parking Bays when the current London Plan Policy 6.13 requires up to 1.5 space at PTAL 3 and Residential Density of 459.77hr/ha & Housing Density of 114.94 units/ha which equates to 9 Parking Bays for 6 dwellings.

This proposed development also does not meet the Croydon Local Plan Policy DM10.1 in that development in the grounds of an existing building which is retained shall be subservient to that building. It also fails to meet the objectives of Policy DM10.9 a) & b) in that the proposed development does NOT respect or enhance the local character specifically the architecture of the host Shirley Inn and Public House.

We object to this proposed development on grounds of direct overlooking into gardens and properties of Barmouth Road.

MORA Objection Sent: 2nd Aug 2019
Consultation Closed: 11th Aug 2019
Target Decision: 6th Sep 2019
• Total Consulted: 45
• Objections: 66
• Supporting: 0
Councillor referral: Councillor Sue Bennett (15th Aug 2019)

Further developments are in the May 2020 Planning Report.

Planning Complaints

16-18 Ash Tree Close – Ref: 19/04705/FUL
Demolition of the existing dwellings. Erection of 8 x 3-bed semi-detached dwellings with associated access, parking, refuse and cycle stores.

Flyer for download and distribution.

Suggested Reasons for refusal:

  • Over Development Residential Density at close on 300hr/ha for Public Transport Accessibility Level (PTAL) at 1a (should be between 150 to 200hr/ha at PTAL 1a);
  • Over Development Housing Density at close on 60 units/ha at PTAL 1a (should be ≈48 units/ha at PTAL 1a);
  • Densities would require a PTAL of >5 for Residential Density and approaching 3 for Housing Density when the locality has PTAL of 1a (numerically = 0.66);
  • Bed Spaces for 40 new occupants and only 8 car parking spaces;
  • Inappropriate Refuse and Recycling Storage for each dwelling;
  • Access limited width and parking difficult to negotiate ingress and egress.
  • The access would limit the available turning head for existing residents at Ash Tree Close Cul-De-Sac.

On 12th Dec amended drawings were uploaded to the online register.

  • Tracking Plans (Bays 1 – 8)
  • Elevations
  • Roof Plan
  • Roof Space Plan
  • First Floor Plan
  • Ground Floor & Site Plans

Case Officers Report Para 8.7 stated:
“8.7 The proposal results in an increased density on the site by eight additional residential units, all of which would be 3-bed, 5 person units. The scheme exceeds the density matrix (150-200) as set out within the London Plan at approximately 300 habitable rooms per hectare. However, given suburban setting combined with the similar footprint, form and spacing of the proposed dwellings in comparison to the surrounding properties, the acute need for new homes and the fact that the site is very close to the intensification area of Shirley, it is considered an appropriate density for this site.”

Whereas the actual distance to the intensification area of Shirley is approx. 1.5km.

MORA Objection Sent: 20th Oct 2019
MORA Objection (Amended Drawings) sent: 19th Dec 2019
Consultation Closes: 30th Oct 2019 – Extended to 28th Dec 2019
Target Decision: 27th Nov 2019
• Total Consulted: 72
• Objections: 62
• Supporting: 0
Councillor referrals: Councillor Sue Bennett (31st Oct 2019) and Councillor Richard Chatterjee (5th Nov 2019)
Case Officer Report recommends: Grant Approval
Planning Committee Slot: 27th Feb 2020
Permission Granted: 27th Feb 2020

MORA Stage 1 Complaint (6th Apr 2020) Our Complaint comprises the following issues:

  • What is the justification for ignoring Policy DM10.7 d)., allowing “Gabled” Roof Forms instead of requiring “Hipped” roof forms, sympathetic to the surrounding locality as defined by Policy DM10.7 d)?
  • This development is within 35 metres of the Environment Agency Flood Map of the encroachment of the “Chaffinch Brook” which in the past has resulted in significant flooding downstream (Fairford Avenue & Monks Orchard School) of this locality. Removal of vegetation and covering the area with 8 dwellings will increase the likelihood of local area surface water flooding downstream, including the effects of climate change. What is the justification for this proposed development to be considered “very low risk of surface water flooding”?
  • What is the justification for the case officer ignoring the required guidance of National Planning Policy (NPPF) para 122 – Achieving Appropriate Densities?
  • Each proposal which is shown to be an “overdevelopment” cumulatively contributes to unsustainable Public Transport Accessibility for the locality which is NOT considered by the LPA but which should be according to the Local Plan Policy at paragraph 6.41. The overall effect in Shirley North Ward requires a local PTAL trending to 5.8! Please provide justification why each over-development’s cumulative effect is not considered when contributing to local unsustainable public transport accessibility when evaluating whether a proposal should be approved?
  • Can you provide justification, exactly why it is acceptable for a development of Residential Density at a suburban setting and PTAL of 1a, which should be in the “broad ranges” of 150 to 200hr/ha equating to a TfL Accessibility Level Range of 0 to 2.5, Requires a Residential Density of 299.63hr/ha in the PTAL RANGE OF 4 TO 6 which equates to a TfL Public Transport Accessibility Level requirement of between 21.5 to 30 ? (This requires a 63.73% increase in Residential Density and a 707.58% increase in required PTAL from the appropriate recommended level of 1a (numerically 0.66) to 5.33 which is UNSUSTAINABLE as the PTAL is forecast to remain at 1a until 2031.
  • Can the Case Officer justify why he considers this development is “very close to the intensification area of Shirley” when it has been measured to be approximately 1.5km (≈1 mile) line of sight from the nearest “Focussed Intensification” boundary with the Shirley Centre? What is the Policy definition of “very close”?
  • 6 of the 8 Parking Bays require an “unacceptable manoeuvre” to exit from their bays and then exit in a forward gear into Ash Tree Close when parked in a forward direction, which is 75% of the provided parking bays (i.e. NOT a relatively small number of spaces as quoted by the Transport Team). The Transportation Team consider this arrangement to be “acceptable” but have NOT considered how this complication would be resolved if future owners wanted to erect garden fences to partition their front garden curtilages to define their areas of responsibility for garden maintenance. Also, it is NOT evident whether the drop-kerbs (Condition of approval #5 B & C) run the whole length of the new footpath as the mounting of the footpath required to exit is not necessarily directly opposite an entry point? This action is illegal, under Highways Act Section 27 [3] if there is no drop-kerbs at the point of mounting the footpath. (i.e. Only drop kerbs directly fronting and of limited width for forward gear access into each of the parking bays would be appropriate). Therefore, why was this allowed in breach of the Highways Act and by what justification for 75% of parking spaces (i.e. the majority of parking bays) required to mount the footpath and encroach on the curtilage of another property to exit from 75% of parking Bays?
  • What justification does the Case Officer have for supporting the application proposal with no turning head in the access drive?

(Case Number: CAS-163554-V7D4M9)
Stage 1 Response (30th Apr 2020) from Pete Smith, Head of Development Management.

Further developments are in the May 2020 Planning Report.

56 Woodmere Avenue – Ref: 19/01352/FUL
Demolition of a single-family dwelling and erection of a 3- storey block containing 2 x 3-bedroom and 7 x 2-bedroom apartments with associated access, 9 parking spaces, cycle storage and refuse store (amended plans and description)

We objected on grounds of over-development and non-compliance to the current adopted London Plan Policy 3.4 Optimising Housing Potential due to excessive Residential Density and excessive Housing Density.

The proposed dwelling does not fully meet the required minimum space standards as required by the current adopted London Plan Policy 3.5, on grounds of inadequate parking provision and non-compliance to the London Plan Policy 6.13 and London Plan Policy 6.11.

We also objected on grounds of non-compliance to Croydon Plan Policy DM10.1 and Para 6.37, and that it does not meet the requirements of Policy DM13 or Council Guidance on Refuse & Recycling for New Developments as published by Croydon Council with regard to Refuse Storage Area Capacity. It is also non-compliant to Policy: Shirley Place Homes para 11.200 & Character, Heritage and Design para 11.202.

On 28th May amended drawings were uploaded to the online register.

  • All Proposed Plans
  • Landscape Maintenance Plan Report
  • Planting Schedule Report
  • Tree Specifications Report
  • Soft Landscaping Plans
  • Hard Landscaping Plans

The main changes are the internal layouts to meet the London Plan Table 3.3 minimum space standards and the addition of two car parking spaces fronting Woodmere Ave.

Planning Committee Agenda Item 6.1 – Thursday 1st August.
Local Resident Richard Chambers spoke on behalf of affected residents.
Decision Deferred on the grounds of architectural design.

Councillor Paul Scott didn’t like the roof form – thought it was ugly so deferred to allow applicant to change to design of the roof and perhaps other aspects. Footprint likely to stay the same.

On 3rd Sep amended plans were uploaded to the online register.

Planning Committee Agenda Item 6.1 – Thursday 24th October 2019.
Local Resident Richard Chambers and Councillor Richard Chatterjee spoke on behalf of affected residents.
Voted 6:3 to Grant Permission.

MORA Objection sent: 8th Apr 2019
MORA Objection (Amended Drawings) sent: 2nd Jun 2019
MORA Objection (Second Amended Drawings) sent: 17th Sep 2019
MORA Objection Addendum (Second Amended Drawings) sent: 20th Sep 2019
Consultation Closes: 18th Apr 2019 – Extended to 20th Jun 2019 – Extended to 25th Sep (Amended Plans and Description)
Target Decision: 15th May 2019
• Total Consulted: 38
• Objections: 31
• Supporting: 0
Councillor referral: Councillor Richard Chatterjee (23rd Apr 2019)
Case Officer Report recommends: Grant Approval
Planning Committee Slot: 1st Aug 2019
Decision Deferred: 1st Aug 2019
Deferred Planning Committee: 24th Oct 2019
Permission Granted: 24th Oct 2019

MORA Stage 1 Complaint (8th Dec 2019) Our Complaint comprises the following issues:
1. Failure to apply the current adopted London Plan Policy 3.4 to Optimise the Housing Potential or the consolidated emerging London Plan Policy D1A – Infrastructure requirements for sustainable densities, in accordance with the Policy on Residential and Housing Density appropriate for the available or forecast Public Transport Accessibility for the locality at a ‘suburban’ setting and at PTAL of 1a, as required by NPPF (2018/19) para 122 – Achieving Appropriate Densities.
2. Failure to consider the overbearing nature of the proposed development with regard to loss of amenity to the adjacent property at 54 Woodmere Avenue as defined by Policy SPD2 Figure 2.11c: Height of projection beyond the rear of neighbouring properties to be no greater than 45° degrees as measured vertically from the middle of the ground floor window of the closest habitable room on the rear elevation of the neighbouring property should NOT intersect the proposed development.
3. Failure to adequately consider the loss of natural light due to the closeness and overbearing nature of the proposed development on the living conditions of the occupiers of 54 Woodmere Avenue and failure to acknowledge and correct the errors in the applicant’s daylight study report.
4. Overbearing massing of proposed development in relation to surrounding properties.
5. Infraction of Planning Policies on grounds that it is more imperative to meet housing targets than to countenance and implement adopted Planning Policies. (Case Number: CAS-123091-Y3J7R2)
Stage 1 Response (18th Dec 2019) from Pete Smith, Head of Development Management.
MORA Stage 2 Complaint (13th Jan 2020)
Stage 2 Response (10th Feb 2020) from Shifa Mustafa, Executive Director of Place.
Escalation to the Local Government Ombudsman (11th Mar 2020) Case ID Number 19 020 965.
NOTE: Due to the Coronavirus outbreak, the Local Government Ombudsman have suspended all work on complaints and will pick up existing complaints when the pandemic has subsided and work can resume. We will update you when we get any news on any further progress.

Further developments are in the May 2020 Planning Report.

Additional Matters

London Plan – Supplementary Planning Documents (SPG’s)
The new London Plan Supplementary Planning Documents (SPG’s) are now available to view prior to public consultation.

What is the Good Quality Homes for all Londoners SPG?
This document is for information only. A draft of the Good Quality Homes for all Londoners SPG will be formally consulted on post publication of the London Plan.
The Good quality homes for all Londoners SPG is a set of documents designed to ensure that land is used in the best way to deliver good quality homes that Londoners’ need.
This housing design guidance is made up of a foreword and four modules that work together to support the implementation of a number of the London Plan’s policies.

  • Foreword: Good Quality Homes For All Londoners
  • Module A: Optimising Site Capacity – A Design-led Approach
  • Module B: Small Housing Developments – Assessing Quality and Preparing Design Codes
  • Module C: Housing Design – Quality and Standards
  • Module D part 1: Housing Design – Case Studies
  • Module D part 2: Housing Design – Case Studies (continued) and Appendices.

Modules B & C are more relevant to Shirley.

First impressions are:

  1. Implementation by LPA’s will NOT be possible as they do NOT have the resources to do it properly;
  2. Far too complicated for each individual in-fill or Windfall single redevelopments as Case Officers do not have necessary time or resources;
  3. The terminology is so complicated, no one could ever challenge a decision;
  4. I have not yet found any relationship between Residential Density (population) and supporting infrastructure but have only done a quick scan; (could be hidden in the text). (Requirement of NPPF Chapter 9).
  5. These are all subjective terms that in fact can be manipulated to allow any development anywhere;
  6. These are NOT Policies but SPG’s (i.e. guidance) and as we have found when making formal complaints, LPA’s can respond that SPG’s are only “GUIDANCE” and can therefore be ignored if inconvenient – as they have done for SPD2 since publication!
  7. Croydon LPA don’t follow the Policies now so unlikely to implement these complicated processes and procedures in the future.
  8. NPPF calls for clear and precise Policies so applicants can understand what is required of their applications. These Modules definitely don’t meet that objective. (NPPF Chapter 3 para 16 d).
  9. If this “Design led approach” is all to do with replacing the Density Matrix which is one simple table 3.2 (because Case Officers were not enforcing the Policy and which could be updated and improved) – then it’s a disastrous retrograde step and unlikely to work!

Croydon Council’s Governance Review
The Labour administration made a commitment to hold an independent review of the council’s governance structure. A cross-party panel was established to undertake the review and to report its findings to the council.

The panel was led by an independent chair, Dame Moira Gibb and the panel’s membership also included: councillors Hamida Ali, Richard Chatterjee, Sean Fitzsimons, Clive Fraser, Simon Hall, Jason Perry, Joy Prince, Helen Redfern, Scott Roche; and Anne Smith (independent member from the Ethics Committee).

Scope of the review
The scope of the review was to assess and review the council’s governance arrangements, to bring together best practice and to develop a model tailored to the needs and aspirations of Croydon’s residents and stakeholders.

The main goals of the review were to:

  • improve councillor involvement
  • improve local democracy and community participation
  • consider if a change in arrangements could improve the quality of decision
  • making and members’ involvement and participation

The panel’s key tasks were to:

  • hear the views of councillors and other stakeholders including residents, community and voluntary groups, business, MPs and other participants in local democracy
  • hear the views and seek advice from experts on participation in local democracy
  • identify those aspects of the council’s governance that work well and identify opportunities to improve councillor and other stakeholder participation in the local democratic process
  • benchmark good practice from areas with higher levels of participation and consider how this can be delivered in Croydon
  • identify the cost and value for money implications of any recommendations that it makes

The panel’s final report and recommendations
The panel submitted the final report detailing their findings and recommendations for consideration at the council meeting on 2 March 2020.

The 11 recommendations made by the panel are designed to:

  • give residents more opportunities to influence council decisions, earlier in the process
  • put local communities at the heart of how council services are delivered
  • give all councillors more opportunity to influence and shape decisions before they are taken
  • make decision making more open and transparent
  • give more support to all councillors and greater recognition of their role as community leaders, and
  • improve the culture of decision making across the council.

The panel’s final report: Croydon Council Governance Review: Enhancing Democracy, Increasing Participation, March 2020 can be viewed below. Key evidence and information gathered by the panel was compiled into a separate Supplementary Evidence Report and published alongside the main report.

Croydon Council Governance Review: Enhancing Democracy, Increasing Participation, March 2020
Croydon Council Governance Review: Supplementary Evidence Report

MORA Planning

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