Planning Report – February 2021

Applications

New
Decided
Awaiting Decision
Appeal

Planning Complaints

Additional Matters


Applications

New

81 The Glade – Ref: 21/00108/FUL
Demolition of existing dwelling and erection of a 4 storey building comprising 9 flats with associated landscaping and amenity space, and relocation of vehicular crossover.

 

Flyer for download and social media sharing.

Suggested Reasons for refusal:

  • 4 storeys total with accommodation in the roof-space.
  • No Lift.
  • Over-Development Residential Density at close on 379.08hr/ha; for Public Transport Accessibility Level (PTAL) at 1a;
  • Over-Development Housing Density at close on 117.65units/ha at PTAL 1a;
  • No improvement to supporting infrastructure.
  • No forecast improvement to Public Transport Accessibility.
  • Bed Spaces for 30 new occupants and only 7 car parking spaces;
  • Inadequate Play Spaces for Children
  • Overbearing of adjacent properties.
  • Does not respect the character of the Area.

We objected to the proposed development on the grounds that:

  • The proposed development ‘exceeds’ the “Number of New Homes” for this site at Option 1 by ≈1 dwelling. The proposed development therefore ‘exceeds’ the “Number of New Homes” for this site at the ‘Preferred Option 2’ by ≈5 dwellings.
  • Based upon the LPA’s own evidence, this proposal is an over development for this ‘typology’ and suburban setting locality based upon the ‘Small Site Evidence Assessment’ for the Local Plan Review. The Residential and Housing Density for this proposal is the ‘maximum possible’ crammed into the Site Area only limited by the need to meet the London Plan Policies on Minimal Internal Accommodation Space Standards.
  • The reason is assumed to maximise profit, ignoring the local character etc.
    A 4-storey (Three Storey with accommodation in the Roof-space) building on a site area of 0.0765ha significantly exceeds ‘Gradual Densification’ or ‘Limited Growth’ for the area and, for the preferred option, it is nearly double the Option 2 “Number of dwellings expected” with Density uplift of 104,58u/ha for this locality which is tantamount to “Focussed Intensification” for the available site area.
  • Windfall redevelopments in the Shirley North Ward can only be commensurate to “Limited Future Growth” assumed “gradual, moderate incremental densification” as there is no planned improvement in supporting infrastructure to support unrestricted ‘intensification’ i.e., equivalent to “guided” or “Focussed Intensification”
  • There is no quantifiable definition of “gentle Densification” or “Gradual, Moderate Incremental Densification”. Thus, all these Policies are subjective, vague and inadequately defined for professional assessment. The assessment is at the subjective whim of the case officer. Para 6.66 promotes building height of 3 Storeys whereas this proposed development is 3 storeys plus accommodation in the roof-space.
  • This proposal is NOT ‘Gradual Gentle Densification’ when there is no planned increase in supporting Public Transport infrastructure for sustainable development at this location for the foreseeable future.
  • The interpretation of ‘Minor Developments’ Para 3.2.4 for this application, where there is ‘no probability of improvement to Public Transport Accessibility’ over the Life of the Plan and NO LPA “Infrastructure Delivery Plan” for the Shirley North Ward is that the incremental impacts of minor developments should be mitigated by ensuring a much gentler densification of gradual, moderate incremental densification for this locality.
  • The proposed development does NOT meet the requirement of Policy D2 Para A, B & or C. The proposal does not consider existing or future planned levels of infrastructure for minor developments and as there are NO ‘infrastructure delivery plans or programs for the Shirley North Ward we can conclude that cumulative minor developments would require additional supporting infrastructure to be available for sustainable developments in the Ward (as defined by para 3.2.4).
  • We challenge the viability of this proposed development as it is NOT acceptable in terms of use, scale and massing given the surrounding built form as defined in London Plan Policy D2 para-C.
  • The Croydon LPA has NO published ‘Infrastructure Delivery Plan’ or program for the Shirley North Ward to improve Bus or Tram Public Transport Infrastructure for the residents of Shirley North Ward over the life of the plan. In fact, Shirley is not even mentioned in any of the 143-pages of the ‘Infrastructure Delivery Report’.
  • We have had NO improvement in local infrastructure to support any of the year-on-year cumulative developments and NO visible Community Infrastructure Levy (CIL) contribution has been spent in our area. We have NO knowledge of an ‘Infrastructure Delivery Program’ for our area and NO proposed improvement to Public Transport Accessibility.
  • The proposed development could NOT be considered of ‘limited’ growth “within the broad parameters of the existing local character reflected in the form of surrounding buildings and street scene” or, for the site area and local character assessment as required by the vague and subjective Policies D2 & D3 ‘Design-Led-Approach’ of the New London Plan.
  • Therefore, we would seriously suggest that this development proposal’s Residential and Housing Density is significantly too high and inappropriate for the locality and if the case officer is minded to recommend approval of this application in defiance of this ‘overwhelming foregoing evidence’, we would expect a stated justification of how this assessment is derived and that a significant Community Infrastructure Levy (CIL) contribution from the developer is required in order to fund actual ‘significant improvements’ to local Public Transport Accessibility for this high level of Residential Density for an appropriate and actual recognisable improvement in public transport accessibility in The Glade, as required by the Policy.
  • SPD2 paras 2.6.1 & 2.6.2 recognises increased demand on Public Transport but it is also recognised that this will NOT be forthcoming over the life of the Plan. This will result in occupants making more use of car journeys than otherwise and is detrimental to the Policies of reducing car usage and effects on climate change.
  • The proposal does NOT reflect the character of the area with regard to Massing or Density, and does NOT reflect the Borough Character Appraisal for the “Shirley Place”.
  • The proposal does NOT closely relate to the existing surrounding typologies by pursuing a similar density, massing, style, materials and detailing and is therefore not acceptable.
  • There is No Daylight Study Report to investigate overbearing nature of the proposal on the adjacent property at 83 The Glade and there is no surface water drainage proposal or report on surface water SuDS management.
  • The height of three storeys, plus accommodation in the roof-space (4-Storeys), of the proposed development will, by its positioning, significantly shield and cast a shadow over the southern aspect and most of the garden of 83 The Glade. The proposed development would undoubtedly appear overbearing to the neighbouring property at 83 The Glade and therefore should not be supported.
  • The Rear East Facing Elevation of the proposed development and the adjacent property at 83 The Glade shows overbearing and unreasonable impact on neighbours’ amenity and the failure of the development to meet the 45° (vertical) Policy defined in SPD2 Section 2.11 and image 2.11c.
  • SPD2 recommends that in areas of semi-detached homes in a planned estate, that proposals should not exceed 3 storeys, and that the 3rd storey should be partially concealed within the roof form which, for gentle densification, would be considered a maximum and more appropriate for this location.
  • The estimated number of children of occupants of the development could be a maximum of 12 which would require a play space allocation of 120m2, to comply with London Plan Policy S4, a deficiency of 16.5m2 – 120m2 = 103.5m2.
  • This Proposed Development does NOT comply with Policy DM10.4 d). and should be refused.
  • For this proposed development the number of bays, including disabled bay, = 7 (which is an availability of 0.233 per person), so the proposal is deficient by 6.5 bays, rounded ≡ 7 bays (which is ≈50% below the Policy allocation).
  • There is no mention of any electric charging points or provision of infrastructure for electric or Ultra-Low Emission vehicles. 20% of 7 = 1.4 rounded = 2 should at least be equipped with such infrastructure.
  • There are no swept path illustrations to ensure vehicles can enter any parking Bay, with minimum manoeuvres, when all other Bays are full and exit in a forward gear onto The Glade, also when all other bays are full again with minimum manoeuvres.

MORA Objection Sent: 28th Jan 2021
Consultation Closes: 7th Feb 2021
Target Decision: 8th Mar 2021
• Total Consulted: 8
• Objections: 21
• Supporting: 0
Councillor referral: Councillor Sue Bennett (8th Feb 2021)

Decided

Sandrock Pub – Ref: 20/02136/FUL
Two storey side and rear extension to The Sandrock Public House to provide an enlarged service (including front seating area) to the existing pub (A4 Use Class) and conversion of the upper floors including extension to form 4 flats (2×2 bed, 2×1 bed) and construction of a three storey building to the rear comprising 15 flats (8×3 bed, 3×2 bed, 4×1 bed); hard and soft landscaping; communal/amenity/play space; car parking between the two buildings; new crossover along Sandrock Place; boundary treatment and refuse and cycle provision.

We object to this development on the grounds that:

The proposal is an over-development for the area. The Residential Density is excessively high which would require a PTAL of 5 when the actual PTAL is just 2. The densities for this location at PTAL 2 at such a high percentage increases are NOT justifiable and compromise the London Plan Policy 3.4 – Optimising Housing Potential and should therefore be resisted – that is Refused.

The proposed development’s massing and height do not reflect the local character and forms of the surrounding locality.

The proposed development does not comply fully with minimum spaces standards for new dwellings or fully comply with the required amenity space standards.

There is no usable communal open space for the future occupants of the proposed development and there is no provision of children’s play spaces for children of the future occupants of the development.

The development is within the grounds of an existing building and is most definitely NOT subservient in terms of height and massing and therefore is non-compliant to the Croydon Plan Design and Character policies of DM10. In addition, the host building does not retain any garden after partitioning and is non-compliant to Policy DM10.4 e)

This proposal has insufficient car parking space and will result in overspill on street parking in the surrounding streets which will cause significant problems to adjacent existing residents.

There would be major overlooking and invasion of privacy to the occupants of number 6 Sandpits Road and 1A Sandrock Place private outdoor space and therefore does result in direct overlooking and should be refused.

On 4th February 2021, revised drawings were added to the online register.

MORA Objection Sent: 15th Jul 2020
Consultation Closed: 16th Jul 2020
Target Decision: 2nd Sep 2020
• Total Consulted: 164
• Objections: 122
• Supporting: 0
Case Officer Report recommends: Grant Approval
Planning Committee Meeting: 25th Feb 2021
Permission Refused: 25th Feb 2021

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.

Permission Refused

Reason(s) for refusal :-

  1. The proposal would result in the loss of educational floorspace and part of an existing community facility. Insufficient evidence has been submitted to demonstrate that there is no longer a need or demand for the use of the premises for community use purposes, nor if there is ongoing or future demand for the education facilities which would be lost. The scheme would therefore be contrary to policy DM19 of the Croydon Local Plan 2018 and policy 3.18 of the London Plan (consolidated with alterations since 2011)
  2. It has not been demonstrated that adequate provision is made for car parking within the site, or that the proposal would not have an adverse impact on the safety and efficiency of the surrounding highways network. The development would thereby conflict with Policies SP8.1 and DM29, DM30 of the Croydon Local Plan (2018) and 6.12 and 6.13 of the London Plan (consolidated with alterations since 2011)

Consultation Closed: 16th Oct 2019
Target Decision: 8th Nov 2019
• Total Consulted: 72
• Objections: 0
• Supporting: 2
Permission Refused: 22nd Jan 2021

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, and this proposed development is clearly NOT subservient to that building which is the Shirley Inn Public House as shown above.

We object to this proposed development on grounds that it 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 or the key features of heritage of the host building and character of surrounding dwellings all which have pitched roofs which clearly clashes with the flat roofs of the proposed two blocks of flats.

We object to this proposed development on grounds of direct overlooking into gardens and properties of Barmouth Road as the rear windows of the proposed development are overlooking the gardens and properties of Barmouth Road at a distance of approximately 19m which is less than the minimum 18 to 21m between facing windows of habitable rooms.

On 16th Jul 2020,  21st Jul 2020,  2nd Aug 2020 & 17th Aug 2020 amended drawings were uploaded to the online register.

MORA Objection Sent: 2nd Aug 2019
Consultation Closed: 11th Aug 2019
Target Decision: 6th Sep 2019
• Total Consulted: 114
• Objections: 69
• Supporting: 0
Councillor referral: Councillor Sue Bennett (15th Aug 2019)
Case Officer Report recommends: Grant Approval
Planning Committee Slot: 21st Jan 2021
Permission Granted: 21st Jan 2021

Awaiting Decision

116 Orchard Way – Ref: 20/05960/FUL
Retention of the Public House on the ground floor and creation of an additional storey with rear extensions and associated alterations to provide 4 flats on the upper floors.

We objected to the proposed development on the grounds that:

  • The applicant has not provided any justification for exceeding the Densities appropriate for the locality which has PTAL of 1a.The proposal has a Residential Density in a suburban setting of 456.14hr/ha which would require a PTAL of 7.42 and a Housing Density of 140.35units/ha in a Suburban setting which would require a PTAL of 6.33.when the available PTAL is just 1a (as shown on the above graph).This is clear proof of overdevelopment for the locality.
  • Flat 2 & 4 have inadequate Built-In Storage and the In-Built Storage for Flat 3 is undefined.
  • The proposal provides NO communal outdoor amenity space as required by Policy DM10.5.
  • There is no allocation of Play Space for the children of occupants of the proposed development as required of Policy DM10 although there are only likely to be 4 children (max) in occupation.
  • There are insufficient car parking spaces allocated for the future occupants of this proposal and on-street parking in the locality is very limited due to access to the local shopping parade and the Pub clientele, There is no legislation to prevent car ownership and thus it is likely that future occupants of this proposed development will require on-street parking provision which will exacerbate local parking stress.
  • Dwellings Approved in the MORA (Post Code Area)i.e. NOT all Shirley North Ward during 2019≈48 which significantly exceeds the maximum yearly average target of 18.29 (i.e. an increase of 162.438%over the target) for the whole of Shirley i.e. Shirley North Ward & Shirley South Ward. Percentage increase= (Increase – Original) ×100. = ((48 –18.29)/18.29) × 100≈ 162.438%
  • The cumulative increase in local population has not seen a complementary increase in any local service provision such as GP Practice support, local improved infrastructure and school places or public Transport infrastructure etc. This level of cumulative increase contributes to local Residents’ total loss of confidence in the Planning Process.
  • The reference to the availability of public access to Glade Wood is not true. There is no public Access to ‘Glade Wood’. The wood is surrounded by properties and there is no access from Littlebrook Close or Lorne Gardens. It is an isolated area of nature.

MORA Objection Sent: 8th Dec 2020
Consultation Closed: 20th Dec 2020
Target Decision: 12th Jan 2021
• Total Consulted: 45
• Objections: 11
• Supporting: 9

Appeal
Old Lion Works 141B Wickham Road – Ref: 20/02022/FUL
Demolition of existing buildings and erection of part 1 storey, part 2 storey building containing 2 x 1-bedroom apartments & 2 x Studio apartments.

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

1) The applicant has not provided any justification for exceeding the PTAL for a Housing Density at 200 units/ha for an urban setting with available PTAL of 3 when the PTAL required for a Housing Density of 200 units/ha required is 5.7.

2) A Housing Density of 200 units/ha in an Urban Setting requires a PTAL of 5.7 which translates to a TfL Access Index Range of 23.5 to 31 when the actual available PTAL of the locality is only 3 which requires a TfL Access Index of 10 to 15 thus proving the proposed development has inadequate access to sustainable Public Transport Infrastructure.

3) This development proposal is within the grounds of an existing building which is retained and therefore the retained existing garden for the host property, after subdivision should be NO LESS than a minimum of 10m (in length) or 200m2 in area. This proposal fails this Policy DM10.4 e). as the retained garden is only ≈4.4m in length.

4) The proposal provides NO communal outdoor amenity space as required by Policy DM10.5

5) The Refuse & Recycling Bins are NOT enclosed and are not an integral element of the overall design and therefore NOT compliant to Policy DM13.1; they are NOT within the building envelope or in covered facilities located behind the Building Line and thus Non-Compliant to Policy DM13.1 a); they are NOT conveniently located for operatives and their vehicles, being approximately 50m from the nearest road vehicle point in Verdayne Avenue.

Entrance to first floor studio apartment’s by external staircase:

6) The Access to the Studio apartments is via an external staircase which traverses above the Apartments 1 & 2 which is somewhat uncommon and possibly subject to transmitted noise and disturbance for future occupiers below of Apartments I & 2.

7) The Access to the first-floor accommodation traverses the roof of the ground floor accommodation. This is considered a potential danger to occupants of the first floor in the event of fire in the ground floor apartments which would trap the first-floor Studio occupants with no alternative means of escape.

Dwellings Approved in the MORA (Post Code Area) i.e. NOT all Shirley North Ward during 2019 = 48 which SIGNIFICANTLY exceeds the maximum yearly average target of 18.29 (an increase of 162.438% over the target) for the whole of Shirley (i.e. Shirley North Ward & Shirley South Ward).

For 2020 approx. half year totals already EXCEED the yearly 2020 targets for the “Shirley Place.” The increase in number of dwellings by possibly 30 when the full year target average for the whole of Shirley North Ward and Shirley South Ward is 18.29.

Permission Refused

Reason(s) for refusal :-

  1. The proposed development would fail to offer suitable living conditions for future residents due the inadequate floor area for the first floor units and the poor quality of private outdoor space and the lack of communal outdoor space and play space for the scheme as a whole. The layouts would also result in a lack of privacy for the users of the gardens serving the ground floor units. The development would therefore conflict with Policy DM10 of the Croydon Local Plan (2018), the Suburban Design Guide (2019) and the Technical housing standards – nationally described space standard (2015).
  2. The proposed development would by way of close proximity to neighbouring windows, which serve habitable rooms, cause harm to neighbouring living conditions through the loss of privacy. The development would therefore conflict with Policy DM10 of the Croydon Local Plan (2018) and the Suburban Design Guide (2019).

MORA Objection Sent: 11th Jun 2020
Consultation Closes: 27th Jun 2020
Target Decision: 22nd Jul 2020
• Total Consulted: 19
• Objections: 3
• Supporting: 0
Permission Refused: 23rd Jul 2020
Appeal Notice: 25th Jan 2021

19 Orchard Avenue – Ref: 20/03721/FUL
Demolition of existing dwelling, erection of 9x flats, revised access, parking, landscaping and relocation of dropped kerb.

We object to this proposal on grounds of significant overdevelopment for the locality if classified as a “suburban setting” at Residential Density of 400 hr/ha and Housing Density of 150 units/ha at an average of 2.67hr/unit. So, this proposed development is an OVERDEVELOPMENT for a Suburban setting at PTAL 2 and forecast to remain at PTAL 2 until at least 2031. These Residential and Housing Densities are more appropriate to an “Urban” Setting.

We object to this proposed development on grounds of excessive Residential and Housing Densities for a Suburban Setting as defined in the current adopted London Plan Policy 3.4 – Optimising Housing Potential, Table 3.2 and DM45.1 – The Shirley Place at locality of PTAL 2 when the Densities would require PTALs exceeding the maximum Residential Density at a numerical value of 4.5 and a Housing Density of 4.22.

There are no other available adopted Policies in the Croydon Local Plan to meet the NPPF requirements of para 16 d) or Para 122 – Achieving Appropriate Densities.

We object to this proposed development on grounds of non-compliance to London Plan Policy 3.5 Quality and design of housing developments Table 3.3 Minimum Space Standards for New Dwellings, as the appropriate information has NOT been provided.

We object to this proposed development on grounds of inadequate off- street parking at a locality adjacent to Red Route restricted parking which will require overspill on-street parking to be a significant distance from the development and cause local congestion along this feeder road which provides the 367-bus route and the link between the A232 and the A222.

We object to this proposed development on grounds of inadequate parking provision in a Suburban setting of PTAL 2 of only four Parking Bays when the current London Plan Policy 6.13 requires up to 1.5 space at PTAL 2 and at a recommended Residential Density of 150hr/ha & recommended Housing Density of 50 units/ha which equates to 13.5 Parking Bays for 9 dwellings.

Also, there are no swept path illustrations to prove that an egress manoeuvre is possible if parked in a forward direction, in a forward gear if all other 3 bays are full – to exit in a forward gear across the footpath and into Orchard Avenue.

Also, there are NO Sight Lines to ensure safe exit over the footpath and into Orchard Avenue and therefore should be refused. Orchard Avenue has a high footfall of pedestrians, including children travelling to the two schools in close proximity.

We object to this proposed development on the grounds that there is no allocated Play partitioned Space for Children of the future occupants and should therefore be refused.

We object to this proposed development as it clearly fails to meet the design guide requirement of SPD2 Chapter 2 – Suburban Residential Development section 2.11c which requires clearance of the projected 45° Rule from the centre ground floor rear window of adjacent properties. This proposed development significantly fails this 45° Rule for both adjacent properties and therefore this proposal should be refused. This 45° Degree vertical rule is totally independent of the daylight and sunlight requirements (as the policy indicates “also” in the definition which indicates the two policies are “mutually exclusive”).

We object to this proposed development on grounds of there being no quantifiable definition of DM10.11 as required by NPPF para 16 d) and NPPF Para 122 Achieving Appropriate Densities for “Focussed Intensification” to allow most efficient use of available infrastructure or capacity for growth, resulting in an overdevelopment as defined by the London Plan Policy 3.4 Table 3.2.

This application is non-compliant to the definition of “incremental
Intensification” as defined in the New Draft emerging London Plan Policy for “Incremental intensification” given at para 4.2A.1 which defines Incremental intensification areas to be within PTALs 3-6 and within 800m of a rail station or town centre boundary. This location is at PTAL 2 and is way over 800m of any rail station or Croydon town centre boundary and should therefore be refused as referenced in Sarah Jones’ MP – letter relating to change of Policy for Shirley intensification.

We object to this proposed development on grounds that it does NOT fully meet the capacity requirements of Policy DM13 or Council Guidance on Refuse & Recycling for New Developments as published by Croydon Council with regard to Storage Area Capacity, Access and location within the building envelope.

As detailed under London Plan Policy 6.13 we reiterate our objection on grounds of Policy DM30 objecting to this proposed development on grounds of inadequate parking provision in an Urban Shopping Locality of PTAL 2 of only four Parking Bays when the current London Plan Policy 6.13 requires up to 1.5 space at PTAL 2 and at a recommended Residential Density of 450hr/ha & recommended Housing Density of 120units/ha which equates to 12 Parking Bays for 8 dwellings and should therefore be refused.

Permission Refused

Reason(s) for refusal :-

  1. The proposed development, by reason of its design, proportionality, scale and massing would be out of character with the local character and distinctiveness and would thereby conflict with Policies SP4 and DM10 of the Croydon Local Plan 2018, Policies 7.6,7.8 of the London Plan 2016 and the Councils Supplementary Planning Document Suburban Design Guide (SDG) 2019.
  2. The development would result in poor standard of accommodation by reason of its unsatisfactory layout which fails to keep to a minimum the number of single aspect flats, has awkward window arrangements leading to lack of privacy, fails to provide safe direct access from the building to the rear communal garden and playspace, and wheelchair access to all levels, conflicting with Policy DM10 of the Croydon Local Plan 2018: and the London Plan Housing Supplementary Planning Guidance Standard 28 (March 2016) and the Councils Supplementary Planning Document Suburban Design
  3. The proposal by reason of its massing and proximity with no.17 and 21 Orchard Avenue would result in an intrusive and imposing form of development detrimental to the visual amenity and outlook for neighbours at 17 and 21 Orchard Avenue and privacy for no.17 Orchard Avenue contrary to policy DM10 .6 of the Croydon Local Plan 2018 and the Councils Supplementary Planning Document Suburban Design Guide (SDG) 2019.
  4. The local authority is not satisfied that sufficient detail has been provided to ensure that a significant amount of replacement trees would be planted to re establish the visual character of this part of Orchard Avenue prior to the proposed felling of trees and therefore would be contrary to Policy DM28 of The Croydon Local Plan 2018
  5. The local authority is not convinced that sufficient detail has been provided to demonstrate that the proposal would not have an adverse impact on the highway transport network contrary to Policies 6.3, 6.9 and 6.13 of the London Plan and Policies SP8 and DM30 of The Croydon Local Plan (2018).

MORA Objection Sent: 7th Sep 2020
Consultation Closes: 17th Sep 2020
Target Decision: 13th Oct 2020
• Total Consulted: 12
• Objections: 2
• Supporting: 0
Councillor referral: Councillor Richard Chatterjee (10th Sep 2019)
Permission Refused: 22nd Oct 2020
Appeal Notice: 6th Jan 2021

67 Orchard Avenue – Ref: APP/L5240/W/20/3260388
Alterations including demolition of existing garage; erection of a two storey side extension, a two storey rear extension, a loft conversion with roof lights in the front roof slope and dormers in the rear roof slope, the construction of balconies at first floor and second floor level, the construction of rear basement with terrace area and external staircase. The conversion of single dwelling into 6 flats; provision of car parking, refuse and recycling store, soft landscaping and new vehicular access onto Woodland Way.

  • The Residential & Housing Densities are too high for a PTAL of 1b which should be in the Residential Density range 150 to 200hr/ha and Housing Density range 40 to 65 units/ha which is a clear indication of overdevelopment for the locality.
  • The proposal fails to fully 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.
  • Failure to provide any Open Private Amenity Space or to identify “exceptional circumstances” why Private Open Space cannot be provided to meet the Private Open Space requirement which requires an increase in the allocation of Gross Internal Area (GIA) to compensate in (“exceptional circumstances”) for lack of Private Amenity Space as defined by the Croydon Plan Policy DM10 paragraph 6.76.
  • Failure to meet the minimum required “built-In” Storage requirement as defined by the adopted London Plan Policy 3.5 Table 3.3 or the emerging London Plan Policy D4 Housing quality and standards for the life of the development.
  • The Allocation of Play Space for children at 8m2 for the likely 4 children of the occupants of this proposal would require 40m2 and as such the 8m2 is inadequate.

Permission Refused

Reason(s) for refusal :-

  1. By reason of its design the materials on the first floor and second floor balconies would dominate and detract from the appearance of the existing building and be detrimental to the visual amenities of the street scene thereby conflict with Policies SP4.1 DM10.1, DM10.7 of The Croydon Local Plan 2018, Policies 3.5, 7.4 and 7.6 of the London Plan (consolidated with alterations since 2011) and Section 4.21 of the Suburban Design Guide SPD (2019).
  2. The proposed development would result in poor quality and substandard living accommodation for future residents by virtue of poor quality outlook from the amenity space from flat 1, insufficient private amenity space for flat 2 and flat 3. The development would therefore conflict with Policies SP4, DM10.4, DM10.5 and DM10.6 of the Croydon Local Plan (2018) and policy 3.5 of the London Plan and the London Housing SPG.
  3. The proposed development, by reason of the removal of informal crossing point and the lack of information in regards to pedestrian and vehicle sightlines, and swept paths to demonstrate the impact is likely to result in a detrimental impact to the highway and pedestrian safety of the area. As such, the proposal would be contrary to Policy 6.13 of the London Plan (2016), Policy T6 of the Draft London Plan, Policies SP8, DM29 and DM30 of the Croydon Local Plan (2018) and the Croydon Suburban Design Guide (2019).

MORA Submission Sent: 2nd Jun 2020
Consultation Closed: 13th Jun 2020
Target Decision: 9th Jul 2020
• Total Consulted: 12
• Objections: 7
• Supporting: 0
Permission Refused: 31st Jul 2020
Appeal Notice: 1st Oct 2020
MORA Representation Sent: 20th Dec 2020


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.

NOTE: We are currently compiling an escalation to the Local Government Ombudsman supported by the consent of local residents.

MORA Objection Sent: 20th Oct 2019
MORA Objection (Amended Drawings) sent: 19th Dec 2019
Consultation Closed: 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.
Stage 2 Complaint (18th May 2020)
Stage 2 Response (15th Jun 2020) from Shifa Mustafa, Executive Director of Place.
Escalation to the Local Government Ombudsman (13th Aug 2020) Case ID Numbers 20 003 522 & 20 008 119.
Local Government Ombudsman Investigation (11th Sep 2020)
MORA Response (30th Dec 2020)
Local Government Ombudsman Final Decision – Ref: 20 003 522 (6th Jan 2021)
Local Government Ombudsman Final Decision – Ref: 20 008 119 (6th Jan 2021)

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)

Although the proposed development presented is architecturally acceptable, the proposal fails on a number of design requirement Planning Policies which results in an overdevelopment of the proposal for the locality and would not provide acceptable living conditions for future occupants. We therefore object to this proposed development on grounds of over-development and non-compliant to the current adopted London Plan Policy 3.4 Optimising Housing Potential due to excessive Residential Density of 350hr/ha and excessive Housing Density 116.67 u/ha at a locality of PTAL 1a. without any Justification. The current adopted London Plan Policy indicates that developments which compromise this policy should be refused.

We object to this proposed development on the grounds that the proposed dwelling does NOT fully meet the required minimum space standards as required by the current adopted London Plan Policy 3.5 as defined at Table 3.3 with respect to no Private Amenity Space for Unit 4, 5, 6, 7 and 9. Also, the proposal has inadequate provision of storage space for all of the Units which is a requirement of London Plan Policy 3.5. minimum space standards.

We object to this proposed development on grounds of inadequate parking provision and non-compliance to the London Plan Policy 6.13 for Outer London Boroughs which would result in overspill on-street parking reducing traffic Flow and contribute to traffic congestion and is therefore non-compliant to London Plan Policy 6.11.

We object to the proposed development on grounds of non-compliance to Croydon Plan Policy DM10.1 and Para 6.37 which although recognises a need for providing detailed guidance on SCALE, HEIGHT, MASSING, and DENSITY; the Croydon Local Plan Does NOT provide any guidance whatsoever or any greater clarity for applicants on either “SCALE, HEIGHT, MASSING, and DENSITY” as required by the New NPPF para 16 and para 122.

Thus, MORA comments on Croydon Plan Policy DM10.1 and para 6.37 are covered by our response to the current adopted London Plan Policy 3.4 Optimising Housing Potential.

We object to the proposed development on grounds that it does NOT meet the 45° Rule on height as measured from the adjacent dwelling ground floor window as required by the emerging Supplementary Planning Document SPD2, Chapter 2 Suburban Residential Developments at Para 2.11 Heights & Depths Projecting beyond Building Lines at pages 36 & 37. The proposed development is to be sunk into a 0.6m hole in the ground in order to meet the adjacent properties height restriction. If the built form is NOT actually sunk into the ground, the built form would be 0.6m higher and the projected 45° Rule would show much more of the proposed development would be above the 45° projection and significantly greater non-compliance to the policy. The built height is therefore extremely critical.

We object to this proposed development on grounds 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, Access to Storage, width of passageway and pull distance from storage area to refuse vehicle and thus the location within the building envelope.

We conclude that the proposed development is an overdevelopment for the locality and does NOT respect the existing residential and housing densities and therefore is non-compliant to Policy: Shirley Place Homes para 11.200 & Character, Heritage and Design para 11.202. There has been “absolutely no improved access or transport links” in Shirley with increased residential occupancy of 328 persons resulting from in-fill and redevelopment and therefore the policy Shirley Place Transport para 11.205 has NOT been fulfilled.

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 Closed: 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.
Local Government Ombudsman Decision (12th Jun 2020)
MORA Response to Local Government Ombudsman Decision (16th June 2020)
NOTE: Local Government Ombudsman complaint has been re-allocated to another case officer due to a potential conflict of interest.
Local Government Ombudsman Investigation (8th Sep 2020)

56 Woodmere Avenue – Ref: 20/06052/DISC
Details pursuant to the discharge of conditions 7 (landscaping), 9 (SUDs), 10 (playspace), 13 (visibility splays) and 15 (emissions) from planning permission 19/01352/FUL for ‘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’

Although this application (Ref: 20/06052/DISC) is NOT identified for public consultation, we would like to place on record our concerns relating to the applicant’s request for approval of Condition 9 (SuDS) with reference to our objections and the Case officer’s report and the AMBI≡NTAL Report on Surface Water Management.

MORA Comment sent: 9th Dec 2020


Additional Matters

Holding Local Planning Authorities to Account
After a number of our complaints have been escalated to the Local Government Ombudsman which, on analysis, conclusively shows that there is no method of holding an LPA to account for any maladministration by a Resident Association as the RA is not ‘materially’ affected by the maladministration and therefore the LGO will not investigate these issues.

Although the occurrences of maladministration are likely to be low and infrequent, there should be an ultimate procedure for accountability – which there isn’t.

This letter (sent 29th Jan 2021) to our MP Sarah Jones sets out our concerns and requests that we would appreciate our MP’s good offices to highlight these issues to those responsible with the objective of defining proposals for a realistic resolution to the problem identified as appropriate.

The letter has been approved and endorsed by our Executive Committee. An excerpt is shown below:

The only way Local Councillors are able to represent our views on planning decisions is at the planning committee meetings where a limited number of representatives are given just 3 minutes each to present their points, mainly objections. ‘Scrutiny’ cannot consider complaints but may consider any policies, practices or procedures that are giving cause for concern. Scrutiny does not consider matters within the remit of the Planning and Licensing Committees and rarely considers issues that affect just one locality in the borough.

All of MORA’s objections to planning applications are presented during the consultation period, prior to the LPA making their decision. These include detailed references in the application to non-compliance with adopted planning guidelines and regulations. As well as points specific to the proposed design of the structure, including accommodation standards, many of these refer to points such as over-intensification, progressive intensification, lack of infrastructure and/or facilities to support the proposal, all of which affect the wider area, not specifically the immediate residents. However, all residents in the wider area are ‘materially’ affected by these issues.

If the LPA refuse a planning application, the applicant has the right to appeal. This appeal process does not question maladministration or service failure, but the appellant’s “grounds of appeal” can question the actual decision itself. In other words, the applicant is allowed to question or appeal the decision.

However, if the LPA approves a planning application, there is no equal and opposite right of appeal by objectors. A challenge can be made by Judicial Review but this is extremely costly and limited to maladministration, not the decision itself.

Therefore, the questions MORA poses to you and wants you to escalate to Government and the Local Authority, are as follows:

1) For the Government:
Can you advise who is responsible for ensuring the LPA abides by its Constitution and adopted Planning Policies and Planning Law if a Planning Officer recommends an application which is then granted based upon suspect guidance or non-compliance to adopted Planning Policies, as we have evidence that the cycle of Stage 1, Stage 2 Complaints and escalation referral to the LGO is limited and inadequate?

2) For the Ministry of Housing, Communities and Local Government:
Can the law/policy be amended to allow objectors’ appeals to the Planning Inspectorate if an approval is given based on suspected or proven non-compliance to adopted Planning Policies or false guidance to the Planning Committee?

3) For the Ministry of Housing, Communities and Local Government:
Can you request an amendment to the Local Government Act 1974 Section 26A Legislation to allow the LGO to investigate complaints from bodies such as Residents’ Associations, when a complaint affects the wider locality, not just a ‘materially’ affected neighbour, on grounds of the “Communities Right to Challenge” Statutory Guidance?

The 1974 Act requires that a complainant must have ‘sustained’ injustice in consequence of maladministration in connection with the action taken by or on behalf of an authority. (“Maladministration” is not defined in the legislation).
And if none of the above are possible, can you inform us who actually holds a Local Planning Authority to account?

4) For the LPA:
Can the Planning Constitution be clarified to indicate that recourse to the LGO is limited ONLY to those residents materially affected by the approval of a development?

London Plan Formal Approval
The Mayor has formally approved a new London Plan, the ‘Publication London Plan’. He has also submitted this to the Secretary of State.

This is a new, stand-alone publication version of the Plan. It has been prepared to address the Secretary of State’s (“SoS”) directions of 13 March and 10 December 2020 to the Intend to Publish London Plan. You can read the SoS’s responses here.

This is the final stage for publication of the London Plan. The SoS has 6 weeks from receiving the Publication London Plan in which to respond (or can request a further extension of time). The Mayor can only publish the Plan after the SoS has given his approval.

Once the SoS has given his approval, the Mayor can publish his London Plan by placing statutory notices in newspapers (which will be the Evening Standard and The Gazette) and notifying the relevant interested and statutory parties. On publication, it will become the Spatial Development Plan for London and part of the statutory Development Plan for Greater London.

You can view the new Publication London Plan and other related documents here.

Our response, sent on 29th December, is as follows:

We would like your assessment and answers to the following analysis of the implementation of para 3.2.4 of new London Plan.

We have major concerns in relation to para 3.2.4 (page 114), Policy D2 Infrastructure requirements for sustainable densities, of the new London Plan which states:

 “3.2.4               Minor developments will typically have incremental impacts on local infrastructure capacity. The cumulative demands on infrastructure of minor development should be addressed in boroughs’ infrastructure delivery plans or programmes. Therefore, it will not normally be necessary for minor developments to undertake infrastructure assessments or for boroughs to refuse permission to these schemes on the grounds of infrastructure capacity.”

Local Suburban Residents have lost confidence in the ‘Planning Process’ due to year-on-year minor in-fill and redevelopments on windfall sites which replace family dwellings with high density blocks of flats, multiple units, totally out of character with the residential area and without any improvement in supporting infrastructure to support the increase in Residential Density of the locality.

We have year-on-year cumulative developments locally, exceeding the current targets for dwellings in the ‘Shirley Place’, as set by the London Plan and the Croydon Local Plan (Review), without any improvement in public transport accessibility or improvement to other public services infrastructure to support the increases in Residential Density locally when analysed by the guidance in the current TfL WebCAT.

We have had NO improvement in local infrastructure to support any of these year-on-year cumulative developments and NO CIL contribution has been spent in our area. There is NO LPA infrastructure delivery program for our area and NO improvement to Public Transport Accessibility. In fact, the Local Plan Review (2019) findings and recommendations states:

 Omitting the Shirley (Focussed Intensification Area) FIA as it looks increasingly unlikely that significant improvements to the public transport capacity in the Shirley area will be delivered over the period covered by the local plan and hence the area only has capacity for limited future growth.”

Our local residential suburban area is nominally at PTAL 1 (1a & 1b) as defined by TfL WebCAT, (only minimal areas surrounding the main A232 exceed PTAL 1), as shown in the histogram attached but the analysis by the TfL WebCAT also shows that the required PTAL for the cumulative Residential Densities is trending towards PTAL 5 plus for the cumulative new developments over the period to date.

http://content.tfl.gov.uk/connectivity-assessment-guide.pdf

In-fill and redevelopment of windfall sites are presented randomly by developers, and NOT influenced by LPA targets.  Therefore, in low PTAL areas with a policy of gradual intensification but without any assessment of appropriate supporting infrastructure (para 3.2.4), the cumulative gradual intensification of local suburban areas will increasingly escalate to unsustainable higher Residential Densities with inadequate supporting infrastructure, as there is no policy to assess or restrain cumulative unsustainable high Residential Density minor developments in the suburban low PTAL areas (para 3.2.4) where there is no prospect of improvements in supporting infrastructure.

If it is now Policy NOT to assess minor developments as stated in para 3.2.4 of the new London Plan, any Residents or Residents’ Associations objection on grounds of high density over-development due to unsustainable supporting infrastructure for cumulative minor developments, will be disregarded by the LPA, quoting para 3.2.4 as the reason.

This Policy will NOT help to regain public confidence in the Planning process. Para 3.2.4 is very unhelpful.

Can you respond to this observation and clearly define how random cumulative in-fill and windfall site minor high Residential Density re-developments, without assessment of available or future supporting infrastructure and Public Transport Accessibility, can be acceptable if there is an acknowledgment by the LPA, of no foreseeable probability of improved supporting infrastructure for sustainable densities for the area?

UPDATE – On 29th Jan 2021, The Secretary of State responded to confirm that the Mayor can publish his new London Plan, with no further changes to be made. The Greater London Authority are now putting the necessary procedural and statutory measures in place to formally publish the Plan.

DEREK RITSON
MORA Planning

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