Planning Report – October 2023

Applications

Decided
Awaiting Decision
Appeals Pending

Applications

Decided

St. George’s Church Elstan Way – Ref: 23/03345/FUL
Erection of a single storey extension with a maximum height of 4.91 metres to the northern elevation of the Church to provide a new annexe to St. George The Martyr with associated internal and external alterations.

We are supporting the proposed development on the grounds that:

  • Although it is understood that a national listing application for St George’s was turned down, Croydon Council have included it on their Locally Listed assets as a building of heritage and having special architectural interest and as such considerations have to be made for authenticity, architectural, historical and technical significance and townscape value.
  • However, it is noted that the Church of St George, Elstan Way, is not listed as a Site of Nature Conservation or Special Scientific Interest, Metropolitan Green Belt, or Metropolitan Open Land in the current adopted Croydon Local Plan or on the current published Policies Map. It is therefore unclear exactly what the Heritage Status is for St. George’s Church. As such, we would suggest it does not attract the significant planning restriction requirements afforded to a formal assessment of a heritage site for this planning application for an extension of a proposed Annexe.
  • The proposal would increase the existing floor space of 387.64sq.m. by 121sq,m. (Application form measurements) to 508.64sq.m. which is a 31.21% increase. However, as a percentage of the full St. George’s Church Site area of 5,920sq.m. (as measured on Google Earth), this 121sq.m. area is only 2.044%.of the total site Area and therefore we would suggest, is a very small reduction in the overall loss of green space area.
  • The proposal would therefore reduce the area of green space by ≈121sq.m. to the north side (very poor sunlight) of the Church grounds. The area is not well maintained and is mainly hidden from general view. This would be a very small loss of green space of ≈2%, when weighed against the benefits of this proposal.
  • We would also suggest the proposal meets or at least does not contravene or detract from any of the requirements of listed Planning Policies.
  • The Policies are mainly subjective to personal interpretation. However, if the Case Officer disputes our analysis, we would respectfully request detailed information supporting such an assessment or raise a condition to rectify the analysis rather than refuse the proposal.
  • It should be recognised that the local community served by St. George’s Church has very few community facilities and the proposal would provide an additional function and activity capacity to contribute to very limited existing local facilities and enhance community cohesion which would be of significant benefit to the local community.
  • In the light of this evaluation and assessment we would strongly recommend that this application is approved.
  • If the Case Officer has concerns regarding any aspect of the proposal in relation to Heritage Policies, it would be helpful that those concerns be ameliorated or resolved by conditions of approval rather than by a refusal of the complete proposal.

MORA Submission: 4th Oct 2023
MORA Addendum: 9th Oct 2023
Consultation Closes: 12th Oct 2023
Target Decision: 26th Oct 2023
• Total Consulted: 18
• Objections: 2
• Supporting: 70
Permission Granted: 20th Oct 2023

Further developments are in the November 2023 Planning Report.

46 The Glade – Ref: APP/L5240/W/22/3312168
Demolition of existing property and construction of 4 no. 3 bedroom houses with parking spaces.

We objected to the proposed development on the grounds that:

  • The proposed development would introduce a substantial Block of 4 Terraced Units of 3-4 storey with gable roofs on this plot. There would be a pronounced increase in height from the neighbouring two-storey properties. The height and bulk would be significantly greater than the rest in the locality and therefore would be visually jarring in this context. The proposed development would therefore harmfully contrast with the limited height and scale of surrounding properties in this area and therefore unacceptably erode its modest character.
  • Policy DM10 of the Croydon Local Plan 2018 (CLP) states that proposals should seek to achieve a minimum height of 3 storeys, but also that they should respect the development pattern, scale, height and massing of the surrounding area amongst other things. This development seeks to increase the density on this site. However, as outlined above, it would be in a form that would be harmful to the character and appearance of the area. Therefore, it would be contrary to these policies in this regard.
  • Consequently, the proposed development would result in a harmful effect on the character and appearance of the area. As such, in this respect, it would be contrary to Policies SP4 and DM10 of the CLP. Together these seek to achieve high quality design which respects local character.
  • The proposed development fails the 45° (Vertical) projection from both adjacent dwellings at 44 & 48 The Glade which impacts on the amenities of both adjacent properties and gives an overtly overbearing and dominant effect and impairs daylight and sunlight, significantly for 48 The Glade as shielded from sun by the proposed development to the South.
  • Parking Bays for Unit 4 occupants are stacked in-line (4a & 4b) such that if both bays are full and the rear vehicle (4b) is required for travelling, the vehicle parked in the forward bay (4a) will need to be moved to allow exit.
  • This is likely to be an extremely onerous aggravation to the future occupants of Unit 4, especially in periods of high precipitation. This Swept Path configuration is NOT shown on the “Proposed Swept Path Analysis” Drawing No. 21031-01. This is considered an extremely poor design and is an indication of inadequate Site Area to accommodate the required Parking provision with acceptable manoeuvrability. This is bad practice and will remain as such for the life of the development, if approved.

Appeal submitted in respect of Croydon Council’s failure to determine planning application reference 22/03970/FUL relating to 46 The Glade, Croydon.

MORA Submission: 27th Oct 2022
Consultation Closes: 30th Oct 2022
Target Decision: 21st Nov 2022
• Total Consulted: 12
• Objections: 5
• Supporting: 0
Appeal Notice: 30th Nov 2022
Appeal Linked with 46 The Glade – APP/L5240/W/22/3305791 (Not the Lead Case)
MORA Appeal Submission: 18th Sep 2023
Appeal Dismissed: 18th Oct 2023

Further developments are in the November 2023 Planning Report.

46 The Glade – Ref: APP/L5240/W/22/3305791
Demolition of single storey dwelling at 46 The Glade and redevelopment with a new building to provide 8 dwellings (Class C3), with associated amenity space, integral refuse, cycle stores and external car parking.

We objected to the proposed development on the grounds that:

  • It is clear from the Applicant’s provided documentation and Plans that NO account has been taken of the National Model Design Code and Guidance to determine the Area Design Code(s) “Setting” or “Site Capacity” for this proposal.
  • The offered Housing Density of the proposal is 88.24Units/ha which is a Setting of Mid & Urban Range but with public transport access level (PTAL) of Zero which is inappropriate for an Urban Area Type Setting. 46 The Glade, by all our assessments of the locality Design Code, is within the lower of the range of an “Outer Suburban” Setting. The proposal is inappropriate for “Incremental Intensification” as it is below PTAL 3 and greater than 800m from a Tram/Train Station or District Centre as defined by London Plan Policy H2 para 4.2.4
  • There is NO possible improvement to Public Transport Accessibility in Shirley North Ward at least until 2031 as indicated on the TfL WebCAT for this Post Code or address. We have evaluated the appropriate PTAL which would be required to support this proposal at PTAL 6.202 when the available PTAL is Zero. The applicant still presumes the local PTAL to be 1a.
  • The proposal meets most London Plan Policy D6 minimum space Standards given at Policy D6 Table 3.1. The proposal does NOT however, indicate the amount of In-Built Storage of any of the 8 Flats. The Dimensions are NOT stated, however the excess GIFA may compensate for this omission but requires full assessment.
  • The evidence indicates a deficiency of Play Space for the probable 12 children to be 87.75m2 which is a deficiency of (120-32.25)/32.25 = 0.270 = 27%.
  • It is noted that the “Vision Transport Assessment” Parking Assessment Report of 13th August 2021 supplied as evidence for the applicant, provides an incorrect evaluation of the PTAL for 46 The Glade, indicating a PTAL of 1a when the actual Site PTAL is Zero as shown at TfL WebCAT forecast up to 2031.
  • The analysis shows that for new developments in areas without controlled parking Zones and at PTAL Zero, would be 9 spaces for the Revised draft Croydon Local Plan Policy DM30 Table 10.1 and 12 spaces for the adopted London Plan Policy T6.1 Table 10.3 when only 7 are provided.
  • The accessibility into and exit from each parking bay, with all other bays occupied should be proven by production of swept path illustration to ensure the safety and manoeuvrability is acceptable.

Appeal submitted in respect of the Council’s failure to determine planning application reference 22/01881/FUL relating to 46 The Glade, Croydon.

MORA Submission: 8th Jun 2021
Consultation Closes: 9th Jun 2022
Target Decision: 1st Jul 2022
• Total Consulted: 12
• Objections: 7
• Supporting: 0
Councillor referral: Councillor Sue Bennett (10th Jun 2022)
Appeal Notice: 25th Aug 2022
MORA Appeal Submission: 17th Apr 2023
Appeal Linked with 46 The Glade – APP/L5240/W/22/3312168 (Lead Case)
Appeal Dismissed: 18th Oct 2023

Further developments are in the November 2023 Planning Report.

211 Wickham Road – Ref: 23/00231/FUL
Demolition of existing structures to the rear of 211 Wickham Road and erection of a two-storey building containing four dwellings (1 x 3 bed and 3 x 1 bed flats) with associated parking and refuse storage.

We objected to the proposed development on the grounds that:

  • The building line is created by the primary front face of buildings along a street and is a key element of Design Code of the locality. The National Model Design Code & Guidance requires all new development should follow the established building line where it exists.
  • Therefore the Building Line Set-Back for this proposed development should follow the existing Building Line Set-back of ≈7m as it follows the curve of Ridgemount Avenue. Failure to meet this Policy is grounds for a refusal.
  • Assessment in accordance with the National Model Design Code clearly indicates that the Housing Density at 123.46U/ha of the proposed development is more appropriate in a “Central” Area Type Setting than the actual “Outer Suburban” Area Type Setting of the Shirley Local Centre. This is conclusive evidence of over development for the “Site Capacity” of ≈0.0324ha in an Outer Suburban Setting at PTAL 2.
  • The proposed development has a site area of 324m2 and the offered Gross Internal Area of 187.7m2 equates to a Floor Area Ratio of 187.7/324= 0.579. exceeding 0.5 recommended in the National Model Design Code Guidance by 15.8%.
  • The Area Type Setting at 211 Wickham Road is “Outer Suburban” for a TfL assessment of connectivity but the Application Density in terms of bedspaces per hectare at 216.05bs/ha is within the mid-range of an “Urban” Area Type Setting.
  • The offered Residential Density in terms of persons (bedspaces) per hectare (bs/ha) would require a PTAL of 4.29 when the available PTAL is only available at PTAL 2.

Permission Refused

Reason(s) for refusal :-

  1. The proposal would result in a poor design with the inclusion of recessed balconies which would fail to enhance and sensitively respond to the existing character and the appearance of properties along Ridgemount Avenue. The proposal is therefore contrary to policies D3 and D4 of the London Plan 2021 and Policy DM10 of the Croydon Local Plan 2018.
  2. The proposal would result in a poor standard of amenity with no communal amenity space and playspace, which is flexible, multifunctional, accessible and inclusive. The proposal is contrary to Policies D3, D6 of the London Plan 2021 and Policy DM10 of The Croydon Local Plan 2018.
  3. The proposed refuse and cycle storage facilities, by reason of design, size and capacity would be contrary to Policies T4, T5 of the London Plan 2021 and Policies DM10 and DM13 of the Croydon Local Plan (2018).

MORA Submission: 2nd Mar 2023
Consultation Closes: 5th Mar 2023
Target Decision: 16th Mar 2023
• Total Consulted: 30
• Objections: 2
• Supporting: 0
Appeal Notice: 20th Mar 2023
MORA Appeal Submission: 26th Jun 2023
Appeal Dismissed: 5th Oct 2023

Further developments are in the November 2023 Planning Report.

9 – 13 Gladeside – Ref: APP/L5240/W/23/3316987
This proposal is for the demolition of 3no existing dwellings and the erection of 7no dwelling houses of two storey with accommodation in the roof space. 11 car parking spaces are provided including 1no accessible space plus cycle and refuse storage.

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 reflects the character of the local area.

However, we objected to the proposed development on the grounds that:

  • 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 access extremely restricted. The Amenity of No. 7 Gladeside is adversely affected by the height and proximity of the new adjacent Unit 1.
  • In addition, the Access Drive width, although 3.7m wide, includes a pedestrian footpath which is therefore unsound structurally over the full width of the driveway if the pedestrian footpath is not to the same structural design capacity as the Access drive for vehicles. Although this width (1.82m) is adequate for family cars, it is insufficient for emergency vehicles. A fire Tender has Wheelbase width of 2.3m and therefore there is only 1.4m tolerance for pedestrians (3.7m – 2.3m) and if the emergency vehicle deviates slightly, could drift onto the pedestrian footpath of less structural strength.
  • In addition, the main reason for our concern is the excessive density of the proposal in an Area Type Setting of Outer (London) Suburban Setting as defined by the National Model Design Code & Guidance.
  • There has been inadequate assessment of the proposed developments increasing the surface water flood risk to the existing adjacent dwellings at 7 and 15 Gladeside.

Permission Refused

Reason(s) for Refusal:-

  • The proposed development, by reason of scale, design and layout of the houses, would result in a cramped and imposing 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, D4, D8 of the London Plan (2021) and Policies SP2, SP4, DM10, DM26 of the Croydon Local Plan (2018).
  • The proposed development by reason of its massing and proximity close to neighbouring properties at nos. 7 and 13 Gladeside would result in an intrusive and imposing form of development detrimental in terms of outlook, privacy, overlooking and would lead to loss of sunlight or daylight for these surrounding neighbours contrary to Policies D3 and D6 of the London Plan (2021) and policy DM10 of the Croydon Local Plan (2018),
  • 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, poorly designed disabled bay, inappropriate pedestrian sightlines, poor vehicle and pedestrian access and poor cycle and refuse storage facilities and would therefore be contrary to Policies T4, T5 and T6 of the London Plan (2021) and Policies DM10.2, DM13, DM29 and DM30 of the Croydon Local Plan (2018).
  • The proposal has failed to demonstrate that it would not have an unacceptable ecological impact on biodiversity of the area contrary to Policy G6 of the London Plan (2021) and Policy DM27 of The Croydon Local Plan (2018).
  • Insufficient evidence has been provided to demonstrate that the development would satisfactorily mitigate against any surface water and ground water flood risk thereby contrary to guidance in Chapter 14 of the National Planning Policy Framework (July 2021), as well as Policies SI12 and SI13 of the London Plan (2021) and Policies SP6.4 and DM25 of the Croydon Local Plan (2018).

MORA Submission: 10th Oct 2022
Consultation Closes: 16th Oct 2022
Target Decision: 15th Nov 2022
• Total Consulted: 19
• Objections: 22
• Supporting: 0
Councillor referral: Councillor Richard Chatterjee (18th Oct 2022)
Permission Refused: 13th Dec 2022
Appeal Notice: 20th Feb 2023
Appeal Allowed: 14th Sep 2023

Flyer for download and social media sharing.

187 Shirley Road – Ref: APP/L5240/W/23/3316505
Conversion of the Property to 5 Self-contained Flats, the Construction of a Ground Floor Rear Extension and Associated External Alterations

We objected to the proposed development on the grounds that:

  • There is confusion between the Design & Access Statement Schedule at Para 8 “Housing Type and Mix” and to provided Plans in that the accommodation schedule shows Unit 1 as 2b4. Unit 2 as 3b4p and Units 3. 4 & 5 to be 1b1p whereas the Plans show Units 3, 4 & 5 to have Bed sizes appropriate for two individuals (1.4m wide). This increases the occupation from 11 to 14 bedspaces and thus persons. As a consequence of this confusion, the Gross Internal Area (GIA) required increases from 37sq.m. to 59 sq.m. which the offered proposal does not now meet. Unit 3 GIA offered is 40.5 sq.m. Unit 4 GIA offered is 44 sq.m. and Unit 5 GIA offered is 42.8 sq.
  • In addition, the Unit 1 under stairs In-Built storage Space area is not stated and could be limited by height restriction and not meet the required 2 sq.m. Units 2 to 5 do not have any In-Built Storage capacity identified on the floor plans and therefore are NOT compliant to the London Plan D6 Table 3.1 requirement.
  • Units 3 and 4 have NO Private Amenity Space provision in the form of Balconies or Terraces. 
  • As the proposal offers 2 parking spaces, there needs to be 2 or 3 overnight overspill parking on adjacent side roads. As Shirley Road is a major A232 dual carriageway with, restricted parking RED Route, it is inappropriate for on-street parking. The nearest side street is Valley Walk, and overspill parking is already an inconvenience to residents of Valley Walk nearest to Shirley Road.

Permission Refused

Reason(s) for Refusal:-

  • The proposed development would provide poor quality residential units by virtue of: inadequate internal floorspace to the 2 person first floor flat; inadequate outlook and privacy to the two ground floor flats; lack of private external amenity space to the two first floor flats; lack of communal amenity and child play space; insufficient information to demonstrate accessible housing either M4(2) or (M4(3); insufficient information to demonstrate Fire Safety, contrary to Policies SP2.8 and DM10 of the Croydon Local Plan (2018) and Policies D3, D6, D7 and D12 of the London Plan (2021).
  • Insufficient information has been submitted to demonstrate that there would not be addition and harm to local car parking stress and in the absence of a legal agreement the application does not offer a means to mitigate its impacts on the highway network and offer sustainable transport alternatives, to the detriment of the highway conditions of the area and highway safety contrary to Policies SP8, DM29 and DM30 of the Croydon Local Plan (2018) and Policy T4, T6 and T6.1 of the London Plan (2021).
  • It has not been demonstrated that the proposal would provide satisfactory facilities for cycle storage, refuse and recycling, contrary to Policies DM10 and DM13 of the Croydon Local Plan (2018) and Policy T5 of the London Plan 2021.
  • The development would be below the 30% strategic target for family sized (3-bedroom) housing in accordance with the Policy SP2.7 of the Croydon Local Plan 2018.

MORA Submission: 20th Jun 2021
Consultation Closes: 26th May 2022
Target Decision: 16th Jun 2022
• Total Consulted: 12
• Objections: 4
• Supporting: 0
Councillor referral: Councillor Sue Bennett (23rd Jun 2022)
Permission Refused: 11th Aug 2022
Appeal Notice: 14th Feb 2023
Appeal Dismissed: 15th Sep 2023

77 Woodmere Avenue – Ref: APP/L5240/W/22/3307153
Demolition of single family dwelling and garage to facilitate the erection of a detached 2-storey building with accommodation in the roof space, comprising of 7 self-contained apartments with intergraded bike store and 8 off street car parking spaces.

We objected to the proposed development on the grounds that:

  • The applicant has failed to provide rear elevations showing the relationship between the proposal and the rear elevations of the adjacent dwellings in order to correctly assess the requirements of SPD2 section 2.11. However, the occupants of 79 Woodmere Avenue have provided local measurements for an assessment of SPD2 para 11.2c for 79 Woodmere Avenue, but we have not had success for similar measurements for 75 Woodmere Avenue.
  • The validation Checklist Table requires a Sunlight/Daylight Survey assessment to establish if there is any likely adverse impact on the current levels of daylight/sunlight amenity enjoyed by adjoining properties, including their associated gardens or amenity space, as well as levels of daylight in the proposed spaces. We assess this is probable as the proposal fails the 45° Rule SPD2 para 2.11 c). However, this requirement has NOT been addressed or assessed and therefore we request that the case officer require the applicant provides the appropriate evidence for assessment prior to a recommended determination.
  • It is clear from the Applicant’s provided documentation and Plans that no account has been taken of the London Plan Policies D1 to D3 or H2 or the Current adopted Croydon Plan and there is NO mention of “Design Codes” or their parameters or a “Design-Led Approach” including the “Design-Led Approach or the National Model Design Code and Guidance to determine the Area Design Code(s) “Setting” for this proposal.
  • Additionally, NO account has been taken on the main thrust of the New London Plan since the omission of the Density Matrix, to assess the proposal meets the London Plan Policies D1 to D4 & H2 with regard to the Design-Led Approach and the requirement to assess whether the Site Capacity has been breached.
  • The offered Housing Density of the proposal is 61.08Units/ha which is just within the Urban Range at 77 Woodmere Ave is, by all our assessments of the locality, in an Outer Suburban Setting “Design Code” Area Type.
  • The proposal is inappropriate for “Incremental Intensification” as it is below PTAL 3 and greater than 800m from a Tram/Train Station or District Centre as defined by London Plan Policy H2 para 4.2.4.
  • The proposal meets most London Plan Policy D6 minimum space Standards other than Flat 3 and Flat 7.
  • The evidence in the above table indicates a deficiency of Play Space for the probable 9 number of children to be 90 m2 which is at 16.8m2 is deficiency of:
    ((16.8 – 90)/((16.8 + 90)/2)) = 73.2/53.4 = 1.37 = 137.079% ≈137.08% deficiency.
  • The Croydon Plan Residential Parking allocation for this proposal is 8.5 (rounded to 9 nearest integer) and the London Plan allocation is 10.5 when the offered provision is 8 bays one of which is for disabled and one of which has EVC.
  • Taking all the foregoing evidence when considered in total, the proposed development should be refused on grounds of overdevelopment, inadequate space standards, and insufficient play space for the probable number of children of the future occupants.
  • The local Design Code Area Type Setting is evident at “Outer Suburban” which limits the Housing Density to a maximum of 40Unit/ha when this proposal is 61.08Units/ha and therefore the Site Capacity of 0.1146hectares has been significantly exceeded.

Permission Refused

Reason(s) for Refusal:-

  1. The quality of accommodation, by virtue of the shortfall of amenity space for Flat 3, would result in a sub-standard residential unit, which is contrary to Policy D6 of the London Plan (2021) and Policy DM10 of the Croydon Local Plan (2018).
  2. The proposed development, by reason of scale, width, roofline and form, poor elevational composition, and detailing would result in an unsightly, dominant and imposing form of development which would fail to integrate successfully in townscape terms or make a positive contribution to the setting of the local character and immediate surroundings. Additionally, the proposal would not respect the established rear building line and there is a lack of landscaping to compensate for the dominance of the hardstanding to the front of the property. This is contrary to Policy D4 of the London Plan (2021) and Policy DM10 of the Croydon Local Plan (2018).
  3. The proposal by reason of its scale, bulk, massing, and window placement, would result in the loss of light, the loss of privacy, and overbearing impact on Nos. 75 and 79 Woodmere Avenue, which would be contrary to Policies D3 and D6 of the London Plan (2021) and Policy DM10 of the Croydon Local Plan (2018).
  4. The proposal does not provide sufficient details on the modified access, in terms of details and dimension, visibility splays, and a swept path analysis. Additionally, there is a deficiency of information for the car parking, as swept path analysis has not been provided, and would therefore be contrary to Policies T4, T5, and T6 of the London Plan (2021) and policies DM29 and DM30 of the Croydon Local Plan (2018).
  5. In the absence of a legal agreement, to secure sustainable transport contributions, as well as car club membership for each residential unit for a period of 3 years, the proposal would fail to mitigate harmful impacts and would be unacceptable in planning terms given the shortfall of on-site car parking. The proposal therefore conflicts with T6 of the London Plan (2021) and Policies SP6, DM29 and DM30 of the Croydon Local Plan (2018).
  6. The proposed refuse and recycling stores, due to the location of this externally and not integrated into the landscaping, would create visual clutter on the streetscene. Additionally, the location of the bulky waste area is not appropriate. The proposal is therefore contrary to policy DM13 of the Croydon Local Plan (2018).
  7. The proposal fails to provide information to address fire safety, which is contrary to policy D12 of the London Plan (2021).
  8. The proposal has failed to demonstrate that it would not have an unacceptable ecological impact on biodiversity of the area contrary Policy G6 of the London Plan (2021) and Policy DM27 of The Croydon Local Plan (2018).

MORA Submission: 11th Apr 2021
Consultation Closes: 17th Apr 2022
Target Decision: 19th Apr 2022
• Total Consulted: 25
• Objections: 42
• Supporting: 0
Councillor referral: Councillor Sue Bennett (30th Mar 2021)
Permission Refused: 18th Aug 2022
Appeal Notice: 16th Sep 2022
MORA Appeal Submission: 28th Mar 2023
Appeal Dismissed: 15th Sep 2023

13 Gladeside – Ref: APP/L5240/W/23/3317040
Demolition of existing dwelling and erection of a two-storey detached building with accommodation in roof space comprising 6 flats and provision of associated landscaping, car parking, refuse and cycle storage.

We objected to the proposed development on the grounds that:

  • 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.
  • The proposal does NOT provide adequate Play Space for the children of the future occupants of the development for the life of the development. The London Plan requires 10m2 per child and the probable number of children would be 8 requiring 80m2 Play Space Area. This is another indication of overdevelopment as the ‘Site Capacity’ does not allow this requirement to be met.
  • The ground floor Flat 2 is to M4(3) Wheelchair user accommodation Building Regulation standard but there is NO Disabled Car Parking provision within the 4 allocated spaces.
  • The most contentious issue raised by local residents is ‘over-development’ of the sites. 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 localities within the Places of Croydon), to assess an applications’ Local ‘Site Capacity’ in accordance with the new London Plan (2021) Policy D3 and H2.
  • 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 (6 in this case), that can be squeezed onto a site to maximise profit at the expense of supporting a ‘Sustainable Development 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.
  • The NPPF National Model Design Code 2B indicates Housing Density for Outer Suburb to be in the range 20 to 40 Units per hectare and Suburban localities should be within the range 40 to 60 units per hectare. As the Shirley North Ward is located within the Outer London Borough of Croydon, the area could be considered as “Outer Suburban”.
  • This proposal should tend toward the lower limits of ‘Outer Suburban’ (we are in Outer London Suburbs) at 20 Units per hectare or ‘Suburban’ of 40 u/ha as the PTAL is 1a and at a housing density of 78.38 Units per hectare which exceeds the Guide maximum of 60 by 30.6333% should therefore be refused as inappropriate for the locality.
  • The NPPF National Model Design Code ‘Built Form’ indicates that the Floor Area Ratio (FAR) in a suburban setting should be <0.5 (less than) whereas the Floor Area Ratio (FAR) for this proposed development has offered GIA of 408.2m2 and Site Area of 625.05m2 = 0.653 (FAR) and should therefore be refused as it is >0.5 (greater than) and thus inappropriate for the locality.
  • All the foregoing reasoning confirms this proposal is an over development of the site at this location bearing in mind that recent cumulative developments have already placed significant strain on the available supporting infrastructure such that there is now inadequate infrastructure to support this and the previous developments when completed and fully occupied, it is recognised that there is no planned improvement in Public Transport Accessibility in the foreseeable future for the Shirley North Ward.
  • It can however be logically assumed that “Gentle Densification” or “Gradual, Moderate Incremental Densification” (all undefined) in an area “inappropriate” for “incremental intensification” (London Plan Policy para 4.2.4) would have an appreciably ‘discernible’ reduction in Density than those localities designated and listed in Croydon Local Plan (2018) Table 6.4 – “Accommodating Growth”.
  • 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.
  • Gladeside has blind bends and any additional on-street parking reduce the road width available to other road users and would cause additional hazards.
  • It is likely that at least 2 on-street overspill overnight parking spaces will be required.
  • Swept path diagrams should be provided for Bay 1 (nearest the building) to prove acceptable ingress and egress from that bay as it is likely to be a difficult manoeuvre.
  • The proposal would result in the loss of a family home with generous garden space.

Permission Refused

Reason(s) for Refusal:-

  1. The proposed development would be detrimental to the street scene and character of the area by reason of the size, massing, footprint, form, and design and would thereby conflict with policies DM10 and SP4.1 of the Croydon Local Plan (2018) and D3 and D4 of the London Plan (2021).
  2. The proposed development would provide a poor quality of residential accommodation by virtue of its inadequate communal amenity space,
    contrary to policies D3 of the London Plan (2021) and policies SP2.8 and DM10 of the Croydon Local Plan (2018).
  3. The proposed development would result in a detrimental impact on highways and pedestrian safety as a result of inadequate visibility splays, unsafe manoeuvring, inadequate parking provision and the absence of contributions to sustainable travel in the area, contrary to policies DM29 and DM30 of the Croydon Local Plan (2018) and T4, T6 and T6.1 of the London Plan (2021).

MORA Submission: 23rd Aug 2021
Consultation Closes: 25th Aug 2021
Target Decision: 26th Aug 2021
• Total Consulted: 4
• Objections: 9
• Supporting: 5
Appeal Notice: 19th May 2023
MORA Appeal Submission: 13th Jun 2023
Appeal Dismissed: 6th Sep 2023

Awaiting Decision

9 – 13 Gladeside – Ref: 23/02734/FUL
This proposal is for the demolition of 3no existing dwellings and the erection of 5no detached dwelling houses of two storey with accommodation in the roof space. 8 car parking spaces are provided plus cycle and refuse storage.

We objected to the proposed development on the grounds that:

  • This proposal is an improvement on the previous refused and Appealed proposal Ref: 22/03888/FUL but still has non-compliance to Policies and is an over development in an < Outer Suburban Area Type Setting.
  • We have set out clear reasons why this proposal should be refused based upon National and Local Planning adopted and emerging Policies.
  • It is clear from the forgoing that the Site Area is insufficient for the proposed level of Development. The accommodation standards with respect to Storage requirements are not met, although family housing is offered and preferred, the capacity is overly cramped. The Amenity of neighbours is adversely affected by the height and proximity of the proposed development and the raising of the ground level Above Ordinance Datum (AOD).
  • The proposal exceeds the Local Area Type Setting as defined by the National Model Design Code Area Type Setting of the local Post Code and exceeds the Site Capacity as defined by the London Plan Policy D3 Optimising Site Capacity by the Design Led Approach.
  • There has been inadequate assessment of the proposed developments increasing the surface water flood risk to the existing adjacent dwellings at 7 and 15 Gladeside.

MORA Submission: 17th Aug 2023
Consultation Closes: 23rd Aug 2023
Target Decision: 7th Sep 2023
• Total Consulted: 17
• Objections: 10
• Supporting: 0
Councillor referral: Councillor Richard Chatterjee (29th Aug 2023)
Councillor referral: Councillor Sue Bennett (29th Aug 2023)

Further developments are in the November 2023 Planning Report.

76 Tower View – Ref: 23/02521/FUL
Demolition of existing detached garage and shed, erection of a pair of two storey semi-detached houses, provision of modified driveway, provision of 3 parking spaces, refuse and recycling stores, and secure cycle parking.

Consultation Closes: 29th Jul 2023
Target Decision: 23rd Aug 2023
• Total Consulted: 6
• Objections: 9
• Supporting: 0

Further developments are in the November 2023 Planning Report.

46 The Glade – Ref: 23/02129/FUL
Demolition of the existing bungalow and the erection of 3 no. two storey houses in the form of a 1 no. detached house and 1 no. semi-detached pair, each with private rear garden containing a cycle store, compost store, and landscaping with native species. 4 no. car parking spaces, waste storage, and soft landscaping will be provided to the front of the houses, with the existing dropped kerb modified to retain vehicular access.

We objected to the proposed development on the grounds that:

  • This proposal is a significant improvement to the recent refused and Appealed proposals for this site, which is welcomed. However, there are still issues which prevent us from approving this proposal.
  • The Site is a normal rectangular configuration with an existing bungalow. There are no obvious impediments to the redevelopment of this site. However, the locality as defined by the National Model Design Code and Guidance as related to the Post Code CR0 7QD is of an <Outer (London) Suburban Area Type (≤ 20Units/ha) and additionally has a very Low Public Transport Accessibility Level (PTAL) (Zero) as defined by TfL WebCAT, whereas the Housing Density of the proposal would require the locality of the proposal to be Outer (London) Suburban (≥40 to ≤60 Units/ha) as defined by the National Model Design Code & Guidance and a PTAL of ≈1.79, if based on a linear incremental increasing distribution over the ranges of PTAL and Residential Densities.
  • The proposed separation between Units 2 & 3 will not meet the 45° Vertical Rule projection from the centre of nearest ground floor windows of the proposals even though they are virtually full width Patio windows. The projected 45° line from the centre of the ground floor (which is normally off Centre toward the adjacent dwelling) which gives greater allowance, still fails the 45° Degree projection which is significant proof of failure to meet the Policy. Units 2 & 3 are definitely too close together.
  • In addition, the Applicant has shown the 45° Horizonal projection from the centre of the furthest ground floor window instead of the nearest ground floor window of 11 Gladeside which we have shown clearly intersects the 45° Horizontal projection indicating loss of amenity to the occupant of 11 Gladeside by both Horizontal and Vertical failure to meet the Policy.
  • The Parking provision is inadequate at the available PTAL of Zero and for the three Units would require 4.5 ≈5 (Integer) spaces, as required by London Plan Policy T6.1 Residential parking – Table 10.3, for ‘Outer’ London within PTAL ranges 0 to 1, when only 3 Parking bays are provided. This is a 40% deficiency in the appropriate parking provision for this proposal, which is unacceptable. Parking for Unit 1 will block or significantly reduce access to the rear garden area on Unit 1 and the Parking Space for Unit 3 is on the forecourt of Unit 2.
  • The Refuse bins for Unit 2 are much too close at ≈2m in front of Unit 2’s Dining room window. This is hygienically unacceptable. The position is likely to cause percolation of smells and attract airborne insects when the dining room window needs to be open for ventilation in periods of pleasant weather or high temperatures.
  • The proposal would present an increase in Housing Density from 18.54u/ha to 29.41U/ha, a 58.61% increase from <Outer Suburban to Outer Suburban Area Type Setting and a commensurate increase in Residential Densities, from 45.03bs/ha to 117.65bs/ha, a 161.25% increase from an <Outer Suburban Area Type through Outer Suburban to mid Suburban Area Type setting. These increases are significantly less than those offered by the previous refused (and appealed) proposals but still exceed the local Design Code Settings defined by the Post Code in accordance with the National Model Design Code & Guidance.
  • Although the Floor Area Ratio (FAR) is only slightly higher than the <0.5 Benchmark recommended for “Suburban” Areas, this proposal is in a ‘less than’ <Outer Suburban Area Type Setting, two Settings lower than “Suburban” as defined by the Post Code CR0 7QD which would suggest a lower benchmark ratio commensurate with the local character ratio of the larger garden areas to build footprint. (GEA/Site Area).
  • We have no confidence in the Vision Transport Assessment as the author must have purposely manipulated and modified the TfL WebCAT search to show the PTAL to be 1a when the interrogation for both the Post Code (CR0 7QD) and the address 46 The Glade returns PTAL Zero (0), to convince the reader of a higher Accessibility Rating than would otherwise be displayed. This has resulted in our complete loss of confidence in the credibility and professionalism of the Transport Assessment Report, as it shows profound unprofessional BIAS which throws suspicion on other parameters that may have been manipulated to give a more positive assessment of the Transport facilities than are actually available.

MORA Submission: 21st Jun 2023
Consultation Closes: 29th Jun 2023
Target Decision: 26th Jul 2023
• Total Consulted: 15
• Objections: 6
• Supporting: 0

Further developments are in the November 2023 Planning Report.

179 The Glade – Ref: 23/00579/FUL
Change of use from single residential dwellinghouse (C3) to HMO (C4)

We objected to the proposed development on the grounds that:

  • The parking arrangements are unsatisfactory as there is no possible method of exit without requiring a number of cars to be moved to allow any movement of another vehicle. This parking arrangement is totally unacceptable.
  • The Plans do not show whether the Shower rooms have WC’s. The London Plan Housing Design Standards require two or more WCs for all dwellings with five or more Bedspaces. The proposal meets this requirement, but one is presumed within the bathroom shared by all occupants.
  • The Application Form at “Description of Proposal” requests:
    i. Has the Works or Change of Use already Started? Answer Yes.
    ii. Has the Work or Change of Use been completed? Answer Yes.
    Therefore, should this application be for “Retrospective” Planning Application rather than for Planning permission, or is it Change of Use with NO structural alterations which is already occupied by tenants and as such is already an HMO.
  • There is a significant difference between the Residential Density of the local Post Code Area at 59.79 bs/ha to the proposed application at 157.92 bs/ha which changes the required Area Type from Outer Suburban, through Suburban to an Urban Area Type Setting Design Code.
  • In addition, the proposal would require a supporting TfL PTAL of 2.81 when the locality has TfL PTAL of just 1b ≡ 1.33 which is forecast to remain at 1b until 2031.
  • It is recognised that conversion of dwellings (C3) to a House of Multiple Occupation (C4) provides much needed accommodation for youngsters starting out in their working lives. These conversions are therefore a source of housing supply which can help to fill that need. However, there are policies to ensure the accommodation is suitable which we have tried to adequately capture in our submission to assist the assessment by the Case Officer.
  • There is also a critical balance required when assessing a proposal for conversion of family dwellings from C3 to C4 HMO usage on the affects and relationship with adjoining neighbours and the locality generally, to ensure continued neighbourly cohesion and to ensure the neighbourhood does not degenerate toward deprivation.
  • Resulting on our detailed assessment, we hold the view that this proposal is a loss of a family dwelling and as a result of an assumed occupancy of 8 (possibly 9 persons (bedspaces), provides inadequate facilities for the possible number of future occupants and therefore the proposal as offered should be refused.

MORA Submission: 16th Mar 2023
Consultation Closes: 30th Mar 2023
Target Decision: 19th Apr 2023
• Total Consulted: 24
• Objections: 2
• Supporting: 0
Councillor referral: Councillor Richard Chatterjee (21st Mar 2023)

Further developments are in the November 2023 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 November 2023 Planning Report.

Appeals Pending

27 Orchard Rise – Ref: 21/05741/FUL
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 November 2023 Planning Report.

19 Orchard Avenue – Ref: APP/L5240/W/23/3318923
Demolition of existing property and construction of a block containing 8 flats with associated centralised drop kerb and parking.

Illustration due to copyright.
View original documents here

We objected to the proposed development on the grounds that:

  • There is confusion between the Design & Access Statements and the supplied Floor Plans with regard to Occupancy. The D&A Statement indicates 2b3p for Apartments 1 to 6 whereas the Floor Plans indicate Apartments 1 through 6 bedrooms have Double Beds which indicates 2b4p.
  • This increases occupancy from 22 to 28 for the proposal with consequential increase in Residential Density from 337.5 to 429.47 bedspaces/ha. The habitable room remain at 24 which equates to a Residential Density of 368.21hr/ha.
  • The confusion on occupancy also impacts on the required GIA for Apartments 1,2 & 3 and 5 which do NOT meet the Required Minimum Space Standards (GIA) of 70sq.m. requirement for 2b4p Units although the Total GIA exceeds the total required by 0.9sq.m.
  • The proposal does NOT provide any (identified) In-Built Storage for any of the Apartments. A total area of 15sq.m. would be an appropriate minimum, distributed accordingly to the London Plan Policy D6 Table 3.1. This lack of Storage Space is unacceptable.
  • Apartments 3 to 8 have NO Private Open Amenity Space, in the form of Balconies or veranda. This lack of Private Open Space is unacceptable. There is no compensation from increased GIA.
  • The Juliet Balconies give NO additional Amenity Space but allow the safety of floor level windows to provide additional internal light. The applicant has NOT provided a Daylight Assessment Study.
  • The D&A Statement quotes communal garden amenity at 181sq.m. The Communal Open Space required is (50sq.m. + 7sq.m.) = 57sq.m. and for the probable 8 children without a private garden area would require a Play Space of 10 sq.m. per child equals 80 sq.m. thus the total required Communal plus Play Space = 57 + 80 = 137sq.m. The available space is stated as 181 sq.m. which is within this requirement.
  • However, It would be preferrable if the Children’s Play Space were to be separated from the Communal Open Space for the positioning of exercise and play equipment for the children of the proposed occupants of the development.
  • The D&A Statement assumes the locality to be “Urban” when all assessment and analysis of the locality in various hierarchical categories from individual sites, Post Code Areas, Ward Areas etc., conclusively show that, by National Model Design Code & Guidance assessment, the locality is within or below the “Outer Suburban” Area Type or Setting.
  • The Applicant has failed to acknowledge a requirement to meet the London Plan Policy (2021) D3 Design-Led Approach, and the National Model Design Code & Guidance (2021) referenced from the current NPPF paras 128 & 129 (July 2021).
  • Assessment and Analysis of the locality places 19 Orchard Avenue clearly in an “Outer Suburban” Area Type Setting.
  • The Area Type Setting at Outer Suburban Site Area of 0.06518ha can accommodate a site Capacity of 4 Units maximum whereas the proposal is for 8 Units. This is conclusive proof of over-development as defined by the London Plan Policy D3 and the National Model Design Code & Guidance referenced from the NPPF.
  • In addition, the Floor Area Ratio (GIA/Site Area) for Suburban Area Type Settings should be less than or equal to ≤ 0.5 whereas the actual Floor Area Ratio is 520.9/651.8 (ratio in sq.m.) = 0.8 which exceeds the guidance in the National Model Design Code by (0.8 – 0.50/0.50)x100 = 60.
  • The London Plan and the Revised Croydon Local Plan have a Parking requirement of between 7.5 and up to 13.5 spaces with the proposal only providing 4, one of which is for disabled Parking.
  • The Design and Access Statement does NOT indicate any Electric Vehicle (EV) Charging points, but the Transport Assessment does assume that all bays will be provided with EV charging capability.
  • London Plan and Croydon Plan Residential Parking Policies quote parking in PTAL 2 areas to be between 7.5 up to 13.5 spaces.
  • The allocation is for 4 spaces one of which is for Disabled Parking. The likely requirement is for one vehicle per Family Unit e.g., 8 Parking Spaces which would result in 4 vehicle overspills into adjacent appropriate On-Street overnight parking.
  • There would probably be 16 adults accommodated in the proposed development and based upon the 2013 survey 67% would own a car which translates to an ownership of (67x 16)/100  10.72 vehicles and a requirement for 6.72 or rounded to 7 vehicle overnight overspill.
  • For Sustainable Developments, it is necessary for the development to have supporting sustainable infrastructure. A measure of sustainability is the Accessibility to Public Transport services (PTAL).
  • The TfL Density Matrix has been omitted from the Revised London Plan but is retained for the Public Transport Accessibility Level (PTAL) assessment using the TfL WebCAT. The required PTAL for this proposal with a Residential Density 368.21hr/ha or 429.58bedspaces/ha would be:
    For Residential Density: 368.21 hr/ha = 6.55
    & Residential Density: 429.58 Bedspaces/ha ≈ 8.
  • This proposed Residential Density would require a PTAL which significantly exceeds the available TfL PTAL of 2 and is outside the range of the above graphical illustration.

Permission Refused

Reason(s) for Refusal:-

  • The proposed development by virtue of its lack of family accommodation would result in the loss of a family sized unit and therefore would fail to deliver a choice of quality accommodation to create sustainable exclusive mixed community contrary to policy DM1.1 and would fail to meet the 30% strategic target identified within Policy SP2.7 of theCroydon Local Plan 2018 and Policy H10 of the London Plan 2021.
  • The proposed development, by reason of its design, proportionality 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, and Policies H2, D4 and D6 of the London Plan 2021.
  • The development would result in poor standard of accommodation by reason of its window arrangements leading to lack of privacy, poor outlook and possible low levels of light to ground floor bedroom windows, lack of private amenity space to upper floor flats, failure to provide direct access from the building to the rear communal garden, absence of child playspace details and fails to demonstrate M4(2) or M(3) compliance, conflicting with Policy DM10 of the Croydon Local Plan 2018, and Policies D4, D5, D6 and D7 of the London Plan 2021.
  • The proposal, by reason of its massing and proximity, would result in an intrusive and imposing form of development detrimental to the visual amenity and outlook for neighbours at 21 Orchard Avenue contrary to policy DM10 .6 of the Croydon Local Plan 2018 and Policy D3 of the London Plan 2021.
  • The proposed development would cause loss and possible future loss of existing trees which make a positive contribution to the character of the area, whilst insufficient detail has been provided to ensure that suitable replacement trees are secured, contrary to Policy DM28 of the Croydon Local Plan 2018 and Policy G7 of the London Plan 2021.
  • The proposal has failed to demonstrate that it would not have an unacceptable ecological impact on biodiversity of the area contrary Policy DM27 of The Croydon Local Plan 2018 and G6 London Plan 2021.
  • Sufficient detail has not been provided to ensure that the proposal would result in provision of adequate refuse storage facilities and therefore would be contrary to Policies DM13 of The Croydon Local Plan 2018.
  • Sufficient detail has not been provided to demonstrate that the proposal would not have an adverse impact on the highway transport network due to lack of sightlines within the boundary of the site, inadequate swept path manoeuvres, inadequate cycle parking and blue badge car parking space provision, as well as the absence of a legal agreement securing sustainable highway improvements to mitigate the scheme impacts, contrary to Policies SP8, DM29 and DM30 of The Croydon Local Plan 2018 and Policies T4, T5, T6.1H of the London Plan 2021.

MORA Submission: 15th Jun 2021
Consultation Closes: 23rd Jun 2022
Target Decision: 20th Jul 2022
• Total Consulted: 34
• Objections: 7
• Supporting: 0
Councillor referral: Councillor Sue Bennett (23rd Jun 2022)
Permission Refused: 9th Nov 2022
Appeal Notice: 24th Aug 2023
MORA Appeal Submission: 14th Sep 2023

Further developments are in the November 2023 Planning Report.

159 – 161 The Glade – Ref: APP/L5240/W/23/3325637
The proposal is to demolish two existing bungalows and associated garages to create a combined site of 950 sqm which is remodelled to deliver 5 family homes with associated parking. The dwellings consist of four semi detached properties facing The Glade and one detached property on Brookside Way. All family homes have rear gardens and cycle storage. Two additional cycle storage spaces are proposed for visitor parking.

We objected to the proposed development on the grounds that:

  • There is inadequate In-Built Storage capacity to meet the London Plan Policy H6 Table 3.1 for future occupants for the life of the Development.
  • The proposed building has an ugly appearance, with no character or defined fenestration of window or doors.
  • The assessment of the proposed building Types “A” and “B” falls far short of the “Good Design” principles to reflect and respect the Local Character including attractiveness and the respect of local “Roof-Forms” within the locality. We are of the opinion that the proposal with ‘Gabriel’ or ‘Clipped’ Roof Forms look odd at this location and do NOT comply with the predominantly hipped roof forms of surrounding properties and therefore is non-compliant to the adopted Croydon Local Plan with regard to Policy DM10.7 and should therefore be Refused
  • The proposal exceeds the Area Type Setting Housing Density of Outer Suburban Area Type Setting for the Post Code Area of the locality from 29.27Units/ha to 52.63Units/ha, an increase of 79.81% to a higher density Suburban Area Type Setting.
  • The increase in occupancy as measured in Residential Density terms of bedspaces per hectare increases from 41.46persons/ha to 347.37persons/ha, a 737% increase, which would be more appropriate for a Central Area Type Setting.
  • The Public Transport Accessibility Level (PTAL) available at 161 The Glade would NOT be adequate to support the Residential Density and number of occupants resultant on this proposed development as the Residential Density at 347.37bedspaces/ha is more appropriate to a Central Area Type Setting which would require a supporting PTAL of 7.63.
  • The Refuse & Recycling collection point is on the front forecourt of Unit 1 but there is no Refuse or Recycling Storage located behind the Building Line for each individual dwelling. The proposal is therefore non-compliant to Croydon Plan Policy DM13.1 a) or b).

Permission Refused

Reason(s) for refusal :-

  1. The proposed development, by reason of scale, massing, elevation composition, bulky roof form, materials, detailing and impact on grass verge would result in an unsightly, dominant and imposing form of development which would fail to integrate successfully in townscape terms or make a positive contribution to the setting of the local character and immediate surroundings contrary to Policies H2, D4, D8 of the London Plan (2021) and SP2, SP4, DM10 of the Croydon Local Plan (2018).
  2. The proposed development lacks an appropriate parking strategy due to the unacceptable nature of the new vehicle crossover along The Glade thereby leading to possible increase in on street parking pressure, and In the absence of a legal agreement, the application does not offer a contribution towards sustainable transport initiatives in the vicinity to alleviate traffic generation created by the development, the proposal would be contrary to Policies SP8 and DM30 of the Croydon Local Plan (2018) and Policy T4, T6 of the London Plan (2021).

MORA Submission: 8th Mar 2023
Consultation Closes: 19th Mar 2023
Target Decision: 10th Apr 2023
• Total Consulted: 17
• Objections: 3
• Supporting: 0
Councillor referral: Councillor Richard Chatterjee (24th Mar 2023)
Permission Refused: 28th Apr 2023
Appeal Notice: 10th Jul 2023

Further developments are in the November 2023 Planning Report.

46 The Glade – Ref: 22/05049/FUL
Demolition of existing property and construction of 2 no. 3 bedroom houses and 2 no. 2 bedroom houses 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 terraces to two stories and thus reduced the residential density and occupancy ratio of the 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.
  • The increase 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.

Permission Refused

Reason(s) for refusal :-

  1. The proposed development, by reason of scale, massing, elevational
    composition, materials and detailing would result in an unsightly, dominant and imposing form of development which would fail to integrate successfully in townscape terms or make a positive contribution to the setting of the local character and immediate surroundings contrary to Policies H2, D4, D8 of the London Plan (2021) and SP2, SP4, DM10 of the Croydon Local Plan (2018).
  2. The proposal by reason of its massing and proximity close to neighbouring
    properties at nos. 44 and nos. 48 The Glade would result in an intrusive and imposing form of development detrimental in terms of outlook for these surrounding neighbours and would be contrary to policy DM10 of the Croydon Local Plan (2018), Policies D3 and D6 of the London Plan (2021)
  3. The proposed development would provide poor vehicle access, poorly accessed and designed cycle facilities and would therefore be contrary to Policies DM10.2, DM29 and DM30 of the Croydon Local Plan (2018) and Policies T4, T5 of the London Plan (2021).
  4. In the absence of a legal agreement, the application does not offer a contribution towards sustainable transport initiatives in the vicinity to alleviate traffic generation created by the development, the proposal would be contrary to Policies SP8 and DM29 of the Croydon Local Plan (2018) and Policy T4 of the London Plan (2021).

MORA Submission: 28th Feb 2023
Consultation Closes: 8th Mar 2023
Target Decision: 31st Mar 2023
• Total Consulted: 12
• Objections: 4
• Supporting: 0
Permission Refused: 30th Mar 2023
Appeal Notice: 5th May 2023

Further developments are in the November 2023 Planning Report.

44 Orchard Avenue – Ref: APP/L5240/W/22/3309454
Demolition of an existing detached dwelling and construction of a new three storey building comprising 7 apartments with associated private and communal amenity space, refuse and cycle storage.

We objected to the proposed development on the grounds that:

  • The inappropriate 7.5m separation between the existing dwelling at 6 Potters Close remains unacceptable and does not follow the established rear projection building line of Orchard Avenue with adjacent dwellings and is a further example of over development exceeding the “Site Capacity” at this setting.
  • This reduced separation does NOT respect the SPD2 para 2.9.10 (Fig 2.9f) relationship guidance of 18m “New to Existing” 3rd Party dwelling of Separation from the rear elevation of 44 Orchard Avenue to the flank elevation of 6 Potters Close. The flank wall of 6 Potters close has windows and these will be overlooked at this close distance.
  • The rear building line does not respect the existing, extending from 44 to 50 Orchard Avenue and the separation between existing properties in Potters Close and Russet Drive.
  • There is inadequate Children’s “Play Space” in the very limited communal open space which is further evidence of over development, inappropriate for the “Site Capacity” at the Local “Setting”. The Built-In Storage for Apartment 2 is deficient by 0.5sq.m. from the minimum space Standard requirement by London Plan Policy D6 Table 3.1.
  • Analysis of both the London Plan and the Revised Croydon Local Plan Residential Parking at PTAL 2 indicates under provision of 50% which would result in the deficiency in parking provision and a 2-vehicle overnight overspill to on-street parking in Orchard Avenue or Firsby Avenue.
  • The analysis shows that for new developments in areas without controlled parking Zones and at PTAL 2, the Croydon Plan would require a limit of 6 spaces for the Revised draft Croydon Local Plan Policy DM30 Table 10.1 and 6 spaces for the adopted London Plan Policy T6.1 Table 10.3 when only 4 spaces are provided.
  • This is a 50% deficiency for both the Revised Draft Croydon Plan and the London Plan Policy which means a likely overspill of 2 cars. This overspill would likely park in Orchard Avenue, a link road not sufficiently wide enough for both way traffic passing a parked vehicle, with high traffic density linking the A232 with the A222 and a Bus Route.
  • There is now no pressure to meet “Housing need” and “Targets” for provision of further developments in the Shirley North Ward as the housing need and targets for the whole of the Shirley “Place” has already been Met. The assessment is therefore that this proposal should be refused with the objective of the applicant re-applying with a more appropriate and suitable proposal.

Permission Refused

Reason(s) for Refusal:-

  • The proposed development, specifically the rear element, by reason of the scale, bulk, depth, and form, as well as the poor elevational composition, would result in a dominant and imposing form of development which would fail to integrate successfully in townscape terms or make a positive contribution to the setting of the local character and immediate surroundings. Additionally, the proposal would not respect the established rear building line and it would result in an incongruous form of development. This is contrary to Policy D4 of the London Plan (2021) and Policy DM10 of the Croydon Local Plan (2018).
  • The proposal by reason of its scale, bulk, and massing, would result in the potential loss of light for No. 46 Orchard Avenue, and an overbearing impact on No. 6 Potters Close which would be contrary to Policies D3 and D6 of the London Plan (2021) and Policy DM10 of the Croydon Local Plan (2018).
  • The proposal does not provide sufficient details on the modified access, in terms of vehicular visibility splays, and the cumulative impact of crossovers on Orchard Avenue. There is a deficiency of car parking and no provision of a Blue Badge car parking space. The car parking and cycle parking do not meet standards. There is a lack of safe pedestrian access through the site. This would be contrary to Policies T4, T5, and T6 of the London Plan (2021) and policies DM29 and DM30 of the Croydon Local Plan (2018).
  • In the absence of a legal agreement, to secure sustainable transport contributions, as well as car club membership for each residential unit for a period of 3 years, the proposal would fail to mitigate harmful impacts and would be unacceptable in planning terms given the shortfall of on-site car parking. The proposal therefore conflicts with T6 of the London Plan (2021) and Policies SP6, DM29 and DM30 of the Croydon Local Plan (2018).
  • The proposed refuse and recycling stores, due to the external location and not integrated into the landscaping, would create visual clutter on the streetscene. Additionally, the location for the bulky waste is inappropriate. The proposal is therefore contrary to policy DM13 of the Croydon Local Plan (2018).
  • The proposal has failed to demonstrate that it would not have an unacceptable impact on trees, contrary Policy DM28 of The Croydon Local Plan (2018) and Policy G7 of the London Plan (2021).

MORA Submission: 20th Jun 2021
Consultation Closes: 1st Jul 2022
Target Decision: 11th Jul 2022
• Total Consulted: 12
• Objections: 2
• Supporting: 0
Councillor referral: Councillor Sue Bennett (23rd Jun 2022)
Permission Refused: 16th Sep 2022
Appeal Notice: 3rd Nov 2022
MORA Appeal Submission: 18th Apr 2023

Further developments are in the November 2023 Planning Report.

21 Woodmere Gardens – Ref: APP/L5240/W/22/3308020
Demolition of single family dwelling and garage and the erection of one storey semi-detached houses with accommodation in the roof space, comprising of 2 dwellings and 2 off street car parking spaces and a detached 2-storey building with accommodation in the roof space, comprising of 5 self-contained apartments with intergraded bike and refuse stores and 6 off street car parking spaces.

We objected to the proposed development on the grounds that:

  • The Built-In Storage capacity for Apartments 3 & 4 and the Semi-Detached Unit 7 are unacceptable.
  • The Play Space for Children should be provided with Play Activity equipment and furniture and be segregated from the Communal Open Space.
  • The proposed development significantly exceeds the Site Area of 0.121ha capacity for “Gentle” densification of Housing Density for the location of 21 Woodmere Gardens in an “Outer-Suburban” Area Type Setting at Zero PTAL by a factor of 114.26%.
  • The location would require a significant improvement in supporting infrastructure (assessed as a 94.6% increase) and an improved TfL PTAL from Zero to 5.68, in order to support the Density of the proposed development. There are other additional infrastructure physical utility service constraints indicated in the LPA assessment, including Flood Risk at 30yr and 100yr for Surface Water and Gas Pipes Low Pressures.

Appeal submitted in respect of the Council’s failure to determine planning application reference 22/02598/FUL relating to 21 Woodmere Gardens, Croydon.

MORA Submission: 8th Aug 2022
Consultation Closes: 19th Aug 2022
Target Decision: 15th Aug 2022
• Total Consulted: 13
• Objections: 15
• Supporting: 0
Councillor referral: Councillor Richard Chatterjee (23rd Aug 2022)
Appeal Notice: 30th Sep 2022
MORA Appeal Submission: 10th Aug 2023

Further developments are in the November 2023 Planning Report.

DEREK RITSON

MORA Planning

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