Planning Report – April 2024


Awaiting Decision
Appeals Pending

Additional Matters


41 Homer Road – Ref: 24/00699/FUL
Erection of 1no. two bedroom bungalow in rear garden, provision of associated parking and vehicular access from Littlebrook Close, cycle and refuse storage, boundary treatments, soft and hard landscaping.

Consultation Closes: 25th Apr 2024
Target Decision: 22nd May 2024
• Total Consulted: 13
• Objections: 0
• Supporting: 0

Further developments are in the May 2024 Planning Report.

30 Ash Tree Way – Ref: 24/00713/HSE
Erection of detached annexe.

Consultation Closes: 27th Apr 2024
Target Decision: 28th May 2024
• Total Consulted:6
• Objections: 0
• Supporting: 0

Further developments are in the May 2024 Planning Report.


67 Orchard Avenue – Ref: APP/L5240/W/23/3326869
Demolition of the existing dwelling and erection of a two-storey building with accommodation in the roof space containing 6 flats with associated access, parking, landscaping, cycle and refuse storage facilities.

We objected to the proposed development on the grounds that:

  • We challenge the actual Site Area as listed on the Application Form which does not align with an assessment of the Site Area measurement using Google Earth polygon measurement of the boundary as shown in our evaluation at para. 1.1 (see our submission).
  • The difference between the stated Site Area of 700sq.m. and the measured Site Area of 607.77sq.m. is 92.23sq.m. and illustrates a probable decrease in Area of 92.3sq.m. i.e., a Percentage of decrease = |700 – 607.77|/700 = 92.23/700 = 0.1318 = 13.18% from that stated.
  • We would suggest that this exaggeration of Site Area by 92.3sq.m. is significantly decreased at 13.18% and may have been intentional by the developer to infer a higher than available Site Capacity or may be a valid mistake.
  • It is suggested that the Case Officer challenges the developer to supply an accurate value of Site Area or requires a surveyor’s report to determine the actual Site Area to ensure a correct assessment of the Site Capacity in the evaluation of the proposal before making a recommendation.
  • The proposal fails to follow the existing Building Line Set Back as the Northern extended Bedroom 3 of Flat 1 extends in front of the existing established Building Line set-back. Therefore, the proposal fails to meet the requirement to respect the existing Building Line Set Back as defined by the National Model Design Code & Guidance.
  • From the Planning Statement and Floor Plans, it is assumed that all Units are M4(2) compliant and there is no specifically designed unit to M4(3) Building Regulation compliance as no unit has wheelchair storage facility over and above the required “In-Built” Storage requirement as defined in the London Plan Table 3.1.
  • We are of the view that at 6 Units, one should be wheelchair user friendly to M4(3) compliant and provide wheelchair storage space.
  • The proposal does not meet the London Plan Policy D3 requirement for a Design Led Approach or meet the National Model Design Code Guidance in any respect and has not considered whether the proposal is within the Capacity of the Site. We have assessed the Local Design Code parameters in accordance with the National Model Design Code & Guidance and found the proposal does not comply with this guidance.
  • We have assessed the Floor Area Ratio in accordance with the National Model Design Code & Guidance which exceeds the recommended value which should be less than (<) 0.5 i.e., GIA/Site Area in both the Applicant’s quoted Site Area and the Google Earth assessed Site Area. This is further evidence of over-development based upon the National Model Design Code.
  • Our analysis shows that the Site Area Residential Densities would exceed the equivalent Residential Density of Outer and Suburban Settings and would be more appropriate in an Urban Area Type Setting Range with a Google Earth assessment of Site Area into the highest Central Area Type setting Range.
  • We have evaluated this provision in the Outer Suburban, Suburban and Urban Ranges and have established that the required supporting PTAL is either 4.9 for a Residential Density with Site Area to the Application Form, or a PTAL of 6.6 for the Site Area as calculated by Google Earth. This is conclusive evidence that the available existing PTAL of 1b ≡ 1.33 is inadequate to support future occupants of this proposal.
  • We have assumed levels of densification to be ⅓ above the Setting of “Outer Suburban” so “Gentle” Densification would therefore be 26.67u/ha. However, the actual densification would be 221.37% increase for the Applicant’s Site Area or 270.15% increase for the Site Area as measured by Google Earth. Both these assessments conclusively prove the proposal would have a significantly increased densification above what would be considered “Gentle” and would exceed the Area Type Settings and place the proposal appropriate
    for an Urban Setting which is inappropriate for this proposal.
  • There is no provision for Communal Open Space for the future occupants of the development which is non-compliant to the emerging Croydon Local Plan requirement of 50sq.m. for developments exceeding 5 Units.
  • The Play Space for children of the proposed development offered is 20sq.m. when the Policy is for 10sq.m. per child and the proposed development would likely accommodate 6 children requiring 60sq.m. Play Space. As such, the proposed development is deficient by 40sq.m. Play Space for future children of the occupants of the proposed development.
  • The second-floor balconies of Flats 5 & 6 allow partial overlooking of the rear gardens of 65 & 67a Orchard Avenue even though provided with side elevation ‘privacy screening’ over the depth of the balconies.
  • 67 Orchard Avenue has TfL PTAL at 1b which is low. The Croydon Plan would require up to 7 car spaces and the London Plan would require up to 9 Car Spaces when the offered development has capacity for 6 parking spaces. This is unacceptable at this location as Orchard Avenue is a busy link between the A232 and A222 and Woodland Way to the rear is only 4.8m wide and unsuitable for overspill parking for 3 Vehicles.

Click here to view a flyer for distribution.

Permission Refused

Reason(s) for Refusal:-

  1. The proposed development and its refuse store would be detrimental to the character of the area by reason of the size, massing, siting and design and would thereby conflict with the DM10, DM13 and SP4.1 of the Croydon Local Plan (2018) and D3 and D4 of the London Plan (2021).
  2. The proposed development, by way of its excessive scale and close proximity to nearby properties and their gardens, would cause harm to neighbouring living conditions through the creation of a sense of enclosure and overbearing mass. The development therefore conflicts with Policy D3 of the London Plan (2021) and Policy DM10 of the Croydon Local Plan (2018).
  3. The development due to the absence of a Flood Risk Assessment and the incorporation of sustainable urban drainage systems in the design has failed to adequately safeguard this or surrounding sites from surface water flooding. The development conflicts with policy DM25 of the Croydon Local Plan (2018) and policy SI13 of the London Plan (2021)
  4. The loss of soft landscaping and excessive proposed hardstanding would be harmful to the amenity of the streetscene and local character; and to biodiversity which fail to comply with Policies G7 of the London Plan 2021 and Policies DM10.8, SP7, DM27 and DM28 of the Croydon Local Plan 2018.
  5. In the absence of a legal agreement, to secure measures to mitigate the impacts of the development as a consequence of demands created by the proposed development, the proposal would fail to mitigate harmful impacts and would be unacceptable in planning terms. The proposal therefore conflicts with T6 of the London Plan (2021) and Croydon Local Plan 2018 policies SP6, DM29 and DM30.

MORA Submission: 20th Sep 2022
Consultation Closes: 23rd Sep 2022
Target Decision: 19th Oct 2022
• Total Consulted: 11
• Objections: 33
• Supporting: 0
Councillor referral: Councillor Richard Chatterjee (5th Oct 2022)
Permission Refused: 31st Jan 2023
Appeal Notice: 31st Jul 2023
MORA Appeal Submission: 27th Nov 2023
Appeal Dismissed: 5th Apr 2024

46 The Glade – Ref: 23/04740/FUL
Demolition of existing property and construction of 2 no. 3 bedroom houses and 2 no. 2 bedroom houses in a terrace with parking spaces.

We objected to the proposed development on the grounds that:

  • This development proposal is an improvement on the previous proposals for this Site to reflect the Hipped Roof forms prevalent in the neighbourhood and thus relieving the 45 Degree Rule amenity to adjacent dwellings; in doing so this has reduced the two end of terraces to just two stories and thus reduced the residential density and occupancy ratio of the whole development.
  • However, the proposed development remains to be an over development for the Site Area Type of <Outer Suburban and would be more appropriate for an Area Type Outer Suburban for Housing Density and for an Area Type Urban for Residential Density for both Options 1 & 2
  • The increases required would not be supported by the existing infrastructure which is currently adequate for Area Type <Outer Suburban as established by the assessment of the Post Code CR0 7QD Area Type Design Code, nor would the Public Transport Accessibility required to support the Residential Density of 2.79 be achieved as the PTAL for this locality is Zero and there is no prospect of improvement over the life of the Plan.
  • The minimum Internal Space Standards required of the London Plan Table 3.1 are not met in terms of In-Built Storage.
  • Consequently, the proposed development fails to meet the Design Code of the locality as defined by the National Model Design Code & Guidance and would result in a harmful effect on the character and appearance of the area. As such, in this respect, it would be contrary to the NPPF Design Codes, the London Plan Policies on Design and the Croydon Plan Policies SP4 and DM10. Together these Policies seek to achieve high quality design which respects local character.

MORA Submission: 23rd Jan 2024
Consultation Closes: 27th Jan 2024
Target Decision: 15th Feb 2024
• Total Consulted: 13
• Objections: 7
• Supporting: 0
Permission Granted: 8th Apr 2024

Awaiting Decision

211 Wickham Road – Ref: 23/03978/FUL
Demolishing of ancillary storage outbuilding area attached to the shop situated at the rear garden of 211 Wickham Road CR0 8TG and the erection of a detached building consisting of 1 No, three bedroom 4 Person self-contained unit and 3 Nos, 1 bedroom, 1 Person self-contained unit.

MORA has concerns as to whether this application will proceed as it is fundamentally the same application as that which was dismissed at the appeal stage in October 2023.

We recommend that this proposal either be rejected on grounds of similarity with previous refused and Dismissed on Appeal proposals, and not adequately addressing the reasons for Refusal or Dismissal of the Appeal or for failure to meet the additional London Plan – Supplementary Planning Guidance (2023).

We are of the view that the new proposal is not materially different from the previous refused and dismissed Appeal and therefore does not adequately address the Inspectors reasons for dismissal of the previous application and Appeal. It is therefore inappropriate for validation.

MORA Submission: 18th Dec 2023
Consultation Closes: 16th Feb 2024
Target Decision: 25th Jan 2024
• Total Consulted: 28
• Objections: 4
• Supporting: 0

Further developments are in the May 2024 Planning Report.

8A Oak Way – Ref: 23/04017/FUL
Demolition of the existing bungalow and the proposed erection of of 2 x semi detached houses and a bungalow with associated car parking, refuse storage, cycles storage and landscaping

MORA has a neutral stance on this proposed development for the following reasons:

  • This proposal would seem to be in keeping with the local character of semi-detached dwellings and bungalows, and could be a welcome change to the high-density proposals of late.
  • The local area Design Code requires to be identified and the proposal assessed against its compliance to this proposals local Design Code within reasonable tolerance.
  • The percentage uplift to the Post Code Design Codes of 18.21% Housing and 27.58% Residential Densities do not significantly change the Area Types.
  • The Post Code Area Type prior to and after the proposal would remain Outer Suburban and the existing Application Site Area Type would increase from <Outer Suburban to Outer Suburban as defined by the MNMDC&G considered to be within the objectives of NPPF (Dec 2023) para 135 sub paras a) to c).
  • The Dwelling Types of Bungalow and Semi-Detached dwellings respect the character of the locality, and the layout reflects the surrounding character of the immediate area. The increase in Residential Density of 200% is the only critical Design Code issue which may be considered inappropriate as the proposal location has very low Public Transport Accessibility at PTAL 1a (assumed numerically ≡ 0.66).
  • The interactive spreadsheet calculates the Site Capacity is just 3.02% short of the actual required minimum Site Area for an Outer Suburban Area Type setting. This works out at 30.39sq.m. short which we believe is not sufficient to be the only reason found for a refusal. This is only 30.39sq.m. deficient from the calculated required 1036.39sq.m. for an outer Suburban Area Type Setting.
  • The proposal, at of three (3) Units in an area of 0.1006ha would equal a Housing Density of 3/0.1006 = 29.821Units/ha which places the proposal in an ‘Outer Suburban’ Area Type in the range 20 to 40Units/ha. i.e. equal to the locality as define by the Post Code Design Code.
  • We have assessed the various Design Code parameters, and the overall assessment is that the proposal generally meets the objectives of the main policy requirements or are within acceptable tolerance limits and would provide welcomed family dwellings.

MORA Submission: 10th Jan 2024
Consultation Closes: 25th Jan 2024
Target Decision: 27th Feb 2024
• Total Consulted: 15
• Objections: 11
• Supporting: 0

Further developments are in the May 2024 Planning Report.

395 Addiscombe Road – Ref: 21/06387/FUL
Erection of four-storey building to provide 145.7sqm GP Surgery (Use Class E(e)) and nine (9) self-contained flats (following demolition of existing two-storey mixed-use building (Use Classes C3 and E(e)), Associated amenity, cycle storage, vehicle parking and waste storage spaces, and Associated alterations including landscaping and formation of boundary treatments

We objected to the proposed development on the grounds that:

  • This location at the corner of Addiscombe Road and Shirley Road is an important local site en-route as a gateway into the Croydon Centre from Bromley via the busy A232 and as such requires a pleasant architecturally impressive and appealing vista. It is disappointing that the offered proposal does not meet this objective. The proposal is of a dominating character which has a cluttered façade which is unattractive and overbearing, having no relationship to the period of local surrounding building architecture.
  • The proposal exceeds the available Site Capacity of 0.0875ha for the local Area Type at an Outer Suburban or Suburban Setting as defined by the National Model Design Code guidance. There is no equivalent guidance in the Croydon Local Adopted or Revised (Dec 2021) Local Plan or the London Plan for Design Code Guidance and therefore NPPF para 129 is the authority for Design Code Assessment. NPPF at Para 129 gives clear direction that in the absence of Local Design Codes and guidance, the National Model Design Code and Guidance should be used for assessing proposals.
  • The locality of the proposal is NOT in a designated area for Moderate or Focussed intensification as illustrated on the Policies Map. However, our analysis above, using the National Model Design Code & Guidance and an assessment for “Gentle” Intensification and the supporting analysis provides comprehensive evidence of overdevelopment of this proposal at this location indicating the Site Capacity is inadequate to support the development.
  • The proposal fails to meet the MINIMUM space Standards required as there is insufficient Site Capacity for Built-In Storage for any Residential Unit.
  • There is insufficient Play Space for the probable 12 Children of the families occupying the 9 Units or any separate communal open space for the residents.
  • The Vehicular Access for the Addiscombe Road for Disabled Parking is hazardous if approaching from the Roundabout as the access is immediately after exiting the roundabout and requires crossing the line of traffic (Addiscombe Road (A232) and the Pelican Crossing “zig-zag” markings and Red Line Parking restrictions. While waiting for a safe gap in the oncoming line of traffic, the stationery vehicle would cause further congestion and tailbacks from the roundabout and the traffic waiting to access the roundabout. Similarly, the Crossover for Access to the Residential Parking is across a Red Route and “zig-zag” markings for the Zebra Crossing.
  • We question the acceptability of “Dropped Kerbs” at locations close to junctions and at positions of “zig-zag” road markings at Pelican and Pedestrian crossings.
  • The illustration of probable ingress and egress swept Paths Parking trajectory, both for the Surgery Parking Bay and the Residential Parking from Shirley Road, are inaccurate, as the illustration only depicts the path of ONE axle which totally ignores the vehicles wheelbase, dimensions or bodywork overhang, front and rear. These illustrations are completely ineffectual and give a completely false sense of acceptability.

MORA Submission: 23rd May 2021
Consultation Closes: 27th May 2022
Target Decision: 14th Jun 2022
• Total Consulted: 31
• Objections: 186
• Supporting: 0
Councillor referral: Councillor Jeet Bains (16th May 2022)

Flyer for download and social media sharing.

Further developments are in the May 2024 Planning Report.

Appeals Pending

Land B/W 2 & 5 Round Grove – Ref: APP/L5240/W/23/3330711
Demolition of detached building. Erection of 1 x two-storey two-bedroom detached dwellinghouse including new vehicular access and crossover, landscaping, boundary treatments, car parking, cycle parking and bin storage and all associated site works.

We objected to the proposed development on the grounds that:

  • The Site area could benefit from improvement and attention, but the proposed development exceeds the Site Capacity for the Area Type Setting as defined by the National Model Design Code & Guidance; also, the proposal does not respect the character of the Area Type Setting and would not integrate well with the existing Street Scene.
  • The proposal does NOT follow the established Building Line along Round Grove and significantly breaches the building line of the two adjacent dwellings. The proposal offers inadequate storage space for future occupants. The amount of storage space beneath the staircase is undefined in area or volume.
  • The Area of the proposal is inappropriate for Growth other than “Gentle” Densification but significantly exceeds the Growth appropriate for existing infrastructure provision. The proposal would be a 211.83% increase in Housing Density and a 340.30% increase Residential Density. The Site Capacity for <Outer Suburban for a single Dwelling is limited to a maximum Housing Density of 20Units/ha which equates to a minimum Site Area of =>0.05ha. The available Site Area is given as 203.5sq.m. ≡ 0.02035ha. Therefore, the available Site capacity is deficient by 0.2965ha or 296.5sq.m., for one dwelling in an Area Type Setting of <Outer Suburban.
  • Thus, the proposal fails to meet the London Plan Policy D3 Optimising site capacity through the design-led approach.

Permission Refused

Reason(s) for refusal :-

  1. The proposal is considered to have an adverse impact on neighbouring amenity by reason of loss of privacy, loss of outlook and visual intrusion. As such, the proposal is contrary to Policies SP4.1,4.2, DM10.6 of the Croydon Local Plan and Policies D3 and D6 of the London Plan.
  2. The proposal would result in substandard living conditions for future occupants due to the insufficient width for the first floor east facing bedroom and a low ceiling height contrary to Policy SP2.8 and DM10 of the Croydon Local Plan, Policy D6 of the London Plan and the Nationally Described Space Standard.
  3. The proposed parking space by virtue of its location and orientation would be detrimental to the road safety, contrary to the Council’s Vehicle Crossovers Guideline, Policies DM29 and DM30 of the Croydon Local Plan and Policy T4 of the London Plan.

MORA Submission: 23rd May 2023
Consultation Closes: 2nd Jun 2023
Target Decision: 5th Jul 2023
• Total Consulted: 4
• Objections: 13
• Supporting: 3
Permission Refused: 6th Jul 2023
Appeal Notice: 4th Oct 2023
MORA Appeal Submission: 29th Feb 2024

Further developments are in the May 2024 Planning Report.

13 Gladeside – Ref: APP/L5240/W/23/3327704
Demolition of the existing detached dwelling and erection of 3no. dwellinghouses with parking, cycle stores and private amenity, and associated works.

We objected to the proposed development on the grounds that:

  • This proposal is a welcome change to the many recent proposals in this locality as it provides individual family homes with gardens as opposed to blocks of flats of multiple occupation. This development proposal is more suitable for the local area and more appropriately reflects the character of the local area.
  • It is clear from the forgoing that the Site Area is insufficient for the proposed level of Development. Although family housing is offered and preferred, the capacity is overly cramped with restricted access.
  • The Amenity of No. 11 Gladeside is adversely affected by the height and proximity of the new adjacent Unit 1.
  • In addition, the main reason for our concern is the excessive Housing Density of the proposal in an Area Type Setting of less than an (<) Outer (London) Suburban Setting at 17.09Units/ha as defined by the National Model Design Code & Guidance. The proposal would have a Housing Density appropriate for a Suburban Area Type Setting at 48Units/ha, an 180.93% increase, which means the Area Type increases from < Outer Suburban Area Type, bridges the Outer Suburban Area Type Range to the Suburban Area Type without any increase or improvement of supporting infrastructure appropriate for the Suburban Area Type Density.
  • Similarly, the Residential Density, if assessed on the basis of comparable National Average Unit Occupancy based on the 2021 statistics, would result in the increase in Residential Density at 42.2Persons/ha from (<)Outer Suburban through Outer Suburban, Suburban & Urban to a Central Area Type at 288persons/ha, a 574.23% increase, again with no commensurate improvement in supporting infrastructure.
  • The appropriate evolutionary “Growth” at this local Area is defined by Policy DM10 and the Policies Map designations. The locality is not designated as an Area for specific levels of densification or intensification on the Policies Map and therefore only appropriate for Regeneration.
  • The London Plan “Incremental Intensification” Policy H2 is limited to areas of PTAL 3-6 and within 800m of a Tram/Train Station or District Centre, none of which applies to this proposal.
  • It is therefore considered that the 180.93% increase in Housing Density and the 574.23% increase in Residential Density would NOT be an appropriate level for “Gentle” Densification for natural regeneration.
  • The Site Capacity for a Site Area of 0.0625ha in an < Outer Suburban Area Type is NOT sufficient for 3 Units as defined by the National Model Design Code & Guidance. The recommended Floor Area Ratio (FAR) as defined by the National Model Design Code & Guidance should be < 0.5 whereas the proposal would have a FAR of 0.62, exceeding the recommended by 24%.
  • The proposal would clearly fail the London Plan Small Site Design Guide (Feb 2022) (paras 4.1.12/13 & illustration 4.6)

Permission Refused

Reason(s) for refusal :-

  1. The proposed development, by reason of the design of the houses, the layout of the site (front forecourt area), and the uncharacteristic plot sizes would result in a cramped form of development, which would fail to integrate successfully and respond effectively in townscape terms to the wider setting of the local character and immediate surroundings contrary to Policies D3 and D4 of the London Plan (2021) and Policies SP4 and DM10 of the Croydon Local Plan (2018).
  2. The proposed development by reason of its massing (depth) and proximity close to the neighbouring property at No. 11 Gladeside would result in an intrusive and imposing form of development which would result in a sense of enclosure due to the overbearing impact, contrary to Policies D3 and D6 of the London Plan (2021) and policy DM10 of the Croydon Local Plan (2018),
  3. Sufficient detail has not been provided to demonstrate that the proposal would not have an adverse impact on the highway transport network due to inadequate car parking provision for this site due to insufficient tracking to demonstrate all of the car parking spaces can be accessed incurtilage, inappropriate pedestrian sightlines, poor vehicle and pedestrian access, and poor refuse storage facilities, and would therefore be contrary to Policies T4 and T6 of the London Plan (2021) and Policies DM13, DM29, and DM30 of the Croydon Local Plan (2018).

MORA Submission: 13th Jun 2023
Consultation Closes: 22nd Jun 2023
Target Decision: 13th Jul 2023
• Total Consulted: 5
• Objections: 1
• Supporting: 0
Councillor referral: Councillor Richard Chatterjee (27th Jun 2023)
Permission Refused: 27th Jul 2023
Appeal Notice: 22nd Aug 2023
MORA Appeal Submission: 26th Feb 2024

Further developments are in the May 2024 Planning Report.

27 Orchard Rise – Ref: APP/L5240/W/23/3329465
Demolition of an existing house and erection of two semi-detached pairs to provide 4 houses including associated amenity space, landscaping, parking, cycle and refuse storage.

We objected to the proposed development on the grounds that:

  • This proposed Development would result in the loss of a family home with garden.
  • The proposal has inadequate in-built storage for the future occupants which is an indication of overdevelopment as the Developer is attempting to squeeze as much as possible into a limited site area which does not allow the minimum internal space standards to be implemented.
  • Built in Wardrobes are presumed excluded from the minimum standard. The London Plan suggests these space standards are a ‘minimum’ and should be exceeded, if at all possible, which means reducing the densities accordingly such that all space standards can be generously met.
  • Plot 4 is to M4(3) Wheelchair user accommodation Building Regulation standard, but the disabled Car Parking Bay is furthest from the dwelling instead of a position closer to the disabled dwelling at Plot 4.
  • SPD2 requires a minimum drive entrance width of 3.6m and for Fire appliance access, this should be increased to 3.7m width. The Site Layout indicates the width is 5.35m at para 9 of the ‘Fire Strategy Statement’ whereas the actual width as physically measured is 3.35m kerb-to-kerb.
  • It is of significant concern therefore, that the proposal assumes a Fire Appliance could access the drive up to a distance of 20m and be 35m from the furthest dwelling to attend an incident. The Swept path requirement for access from Orchard Rise (5m wide) is Turning Circle ≈15.5m, with a clear Swept trajectory Circle of ≈17.5m which again may be impossible.
  • The Drive would not support the weight and regularity of construction, earth moving or construction material delivery lorries or the weight of fire appliance tender vehicles of approximately 14 tonnes.
  • The most contentious issue raised by local residents is ‘over-development’ of a site. The current adopted Croydon Plan does NOT provide any methodology to determine individual locality “Site Capacities”, “Character Assessments” or “Design Codes” of sufficient detail (for any localities within the Places of Croydon), to assess an application’s Local ‘Site Capacity’ in accordance with the new London Plan (2021) Policy D3.
  • The objective of the New London Plan is to provide housing to the highest quality whilst “optimising site capacity” to meet the ambitious targets and address housing ‘need’ while maintaining good external and internal design, which is quite different from optimising a single dwelling’s site capacity to provide as many units as possible (4 in this case), that can be squeezed onto a site to maximise profit at the expense of supporting a ‘Sustainable Development for the Site Capacity’ .
  • This proposal does NOT provide an appropriate acceptable value for “gentle Densification” or “Gradual, Moderate Incremental Densification” as assessed according to the London Plan definition for “Incremental intensification” over and above that of the existing locality for a suburban area of PTAL 1a (Less than 3 to 6) and at greater than 800m from a train/tram station and greater than 800m from a District Centre.
  • We have assessed this proposal using as much evidence as available which is appropriate for evaluation. The Croydon Local Plan Review is not produced concurrently with the new revisions of the London Plan Policies and therefore the adopted Croydon Plan does NOT include the requirements to implement the New London Plan ‘Design-Led-Approach’ Policies. We have used the NPPF references and the NPPF National Design Guide and National Model Design Code where appropriate.
  • The appropriate Residential Density at PTAL 1a at a Suburban Setting should be in the range 91.5 to 152.2 Bedspaces per hectare, nominally 122 bedspaces per hectare when the proposal is for 172.6 Bedspaces per hectare (i.e., a 41.48% increase from nominal) requiring a PTAL of 2.178 and the available PTAL is 1a (≡ to 0.66). This gives further indication of Over Development. The analysis clearly indicates a simple methodology for assessment when there is NO equivalent Policy in the London Plan or the Croydon Local Plan.
  • The Planning Committee emphasise the “compelling need for more homes” for which appropriate targets have been identified. However, the pressure to meet housing ‘need’ in the MORA area has been categorically satisfied by over-provision of the established strategic targets for the Shirley Place. It would therefore be inappropriate to quote this ‘need’ as a significant reason to approve this application as the identified ‘need’ has been more than met within the Shirley North Ward to meet the whole Shirley Place Targets. Or alternatively, explain why the Shirley North Ward should exceed the strategic quota
  • Any additional overspill on-street parking would reduce the road width available to other road users and would cause additional hazards.

MORA Submission: 31st Aug 2021
Consultation Closes: 8th Sep 2021
Target Decision: 28th Sep 2021
• Total Consulted: 10
• Objections: 32
• Supporting: 0
Case Officer Report recommends: Grant Approval
Planning Committee Slot: 9th Mar 2023
Permission Refused: 9th Mar 2023
Appeal Notice: 20th Sep 2023

Further developments are in the May 2024 Planning Report.

Additional Matters

Revised Croydon Local Plan Update

The Revised Croydon Local Plan (2018) was presented to Cabinet on 27th March and approved to be put to the Full Council meeting on 17th April.

The next stage of the review of the Local Plan will follow which is the Publication under Regulation 19 consultation which should follow in May/June and is an opportunity to make representations.

Further developments are in the May 2024 Planning Report.

Government Consultation – Changes to various Permitted Development Rights
This consultation contains proposed changes to the Town and Country Planning (General Permitted Development) (England) Order 2015, as amended.

It covers the following areas:

  • Changes to certain permitted development rights which enable householders to improve and enlarge their homes.
  • Changes to the building upwards permitted development rights which enable the upward extension of a range of existing buildings.
  • Changes to the permitted development right which allows for the demolition of certain buildings and rebuild as homes.
  • Changes to the permitted development rights which enable the installation of electrical outlets and upstands for recharging electric vehicles.
  • Changes to the permitted development right for the installation of air source heat pumps.

This consultation seeks views on proposals relating to permitted development rights.

We are seeking views on proposed changes to the permitted development rights which allow householders to enlarge their homes, make alterations or extensions to the roof, and construct buildings incidental to the enjoyment of the main house, such as bin and bike stores.

We are proposing amendments to certain rights that allow for the upward extension of a range of existing buildings and allow for the demolition of certain buildings and rebuild as homes. The proposed changes will increase the scope of buildings that can benefit from the right. We are also seeking views on whether the prior approval process for these permitted development rights can be simplified or streamlined to improve efficiency.

We are consulting on changes to the permitted development rights that allow for the installation of off-street electric vehicle charging infrastructure. This includes amending the rights to allow the installation of wall-mounted and upstand electrical outlets within 2 metres of a highway and the installation of larger upstands. We are also seeking feedback on whether permitted development rights should allow units for equipment housing or storage cabinets.

Finally, the consultation seeks views on proposed changes to the permitted development right that allows for the installation of air source heat pumps on domestic premises.

For further information and to respond to the consultation online, please click here.

We strongly encourage responses via the online survey, particularly from organisations with access to online facilities such as local authorities, representative bodies, and businesses. Consultations on planning policy receive a high level of interest across many sectors. Using the online survey greatly assists our analysis of the responses, enabling more efficient and effective consideration of the issues raised for each question.

Alternatively, you can email your response to the questions in this consultation to

If you are responding in writing, please make it clear which questions you are responding to.

Written responses should be sent to:

Planning Development Management
Department for Levelling Up, Housing and Communities
Planning Directorate
3rd Floor, North East
Fry Building
2 Marsham Street

When you reply it would be very useful if you confirm whether you are replying as an individual or submitting an official response on behalf of an organisation and include:

  • your name
  • your position (if applicable)
  • the name of organisation (if applicable)
  • an address (including postcode)
  • an email address
  • a contact telephone number

The Consultation closes on Tuesday 9 April, 2024.

You can view the MORA consultation response here.


MORA Planning

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