Planning Report – September 2022

Applications

New
Decided
Awaiting Decision
Appeals Pending

Additional Matters


Applications

New

9 – 13 Gladeside – Ref: 22/03888/FUL
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.

Consultation Closes: 16th Oct 2022
Target Decision: 15th Nov 2022
• Total Consulted: 19
• Objections: 0
• Supporting: 0

211 Wickham Road – Ref: 22/03145/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 as it follows the curve of Ridgemount Avenue. Failure to meet this Policy requirement is grounds for a refusal.
  • Although the development Site is located within an area designated appropriate for “Focussed Intensification” the emerging Revised Local Plan has omitted this “Focussed Intensification” Designation from this locality due to insufficient and inadequate supporting infrastructure currently and in the foreseeable future. The location is therefore only appropriate for “Gentle” densification as defined in the emerging Revised Local Plan Policy SP1.0C c).
  • The TfL Public Transport Accessibility Level (PTAL) is level 2 and remaining at PTAL 2 until at least 2031 (Forecast). There is no probability of improved infrastructure over the life of the Plan.
  • The Local Design Code Area Type Setting evaluated over the Post Code Area of CRO 8TG with an Area of 0.32ha at 15 Dwellings with an occupancy of 17 persons results in a Housing Density of 47.07 Units/ha and Residential Density of 53.34 bs/ha. This places the Design Code Area Type within a “Suburban” Setting in the Range 40 to 60 U/ha as defined by the National Model Design Code & Guidance.
  • 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 “Suburban” Area Type Setting of the Shirley Local Centre. This is conclusive evidence of over development for the “Site Capacity” of ≈0.03ha in a Suburban Setting at PTAL 2.
  • The proposed development has a site area of 324m2 and the offered Gross Internal Area of 199.7m2 equates to a Floor Area Ratio of 324/199.7 = 0.62. exceeding 0.5 recommended in the National Model Design Code Guidance by 24%.
  • The Area Type Setting at 211 Wickham Road is presumed to be “Suburban” for a TfL assessment of connectivity but the Density in terms of bedspaces per hectare at 216.05bs/ha is within the mid-range of an Urban Area Type Setting or at 262.35hr/ha is within the lower of the Central Area Type Setting range.
  • The offered Residential Density in terms of persons (bedspaces) per hectare (bs/ha) would require a PTAL of 3.16 or for a Residential Density in Habitable Rooms per Hectare (hr/ha) a PTAL of 5.11, when the available PTAL is only available at PTAL 2.
  • The proposed development at 211 Wickham Road, with a Site Capacity limitation of 0.03ha and an increased “Gentle” Densification in a “Suburban” Setting should NOT exceed a Housing Density >≈46.67 (i.e., (40+(60-40)/3) = 46.67, but it actually reaches 123.46U/ha.
  • This increase in Housing Density as a % over the minimum of the range reflecting a Low PTAL of 2 is:
    Percentage of increase = |46.67 – 123.46|/46.67 = 76.79/46.67 = 1.645 = 164.5%
    By any assessment, a 164.5% increase cannot be considered a “Gentle” densification, nor by any rational observation.
  • 211 Wickham Road is also greater than 800m from the Shirley Neighbourhood Centre. However, the requirement is to be greater than 800m from a “District Centre” and Shirley is a Local Centre, NOT a District Centre. Therefore, the location of 211 Wickham Road is inappropriate for “Incremental Intensification” as defined by the London Plan Para 4.2.4.

MORA Submission: 26th Sep 2021
Consultation Closes: 28th Sep 2022
Target Decision: 28th Oct 2022
• Total Consulted: 30
• Objections: 0
• Supporting: 0

67 Orchard Avenue – Ref: 22/03552/FUL
Demolition of the existing dwelling and erection of a two-storey building with accommodation in the roof space containing 6 flats with associated access, parking, landscaping, cycle and refuse storage facilities.

We objected to the proposed development on the grounds that:

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

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MORA Submission: 20th Sep 2021
Consultation Closes: 23rd Sep 2022
Target Decision: 19th Oct 2022
• Total Consulted: 11
• Objections: 18
• Supporting: 0

Decided

46 The Glade – Ref: APP/L5240/W/22/3295431
Demolition of a single storey dwelling and redevelopment with a new building to provide 9 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:

  • The offered Housing Density of the proposal is 88.24Units/ha which is a Setting of Mid-Urban Range and 46 The Glade is, by all assessments of the locality, in 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 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 9 Flats. The Dimensions are NOT stated.
  • The evidence indicates a deficiency of Play Space for the probable 13 children to be 112.4m2 which is a deficiency of 13.538%.
  • It is noted that the “Vision Transport Assessment” Parking Assessment Report of 13th August 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 10 spaces for the Revised draft Croydon Local Plan Policy DM30 Table 10.1 and 13.5 ≈14 spaces for the adopted London Plan Policy T6.1 Table 10.3 when only 7 are provided. This is a 42.86% deficiency for the Revised Draft Croydon Plan and a 92.86% deficiency for the London Plan Policy.
  • 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.
  • Taking all the foregoing assessments and evidence when considered in total, the whole assessment would combine to provide sufficient proof of overdevelopment for the Setting and the Site, which exceed Site Capacity for 0.102ha at this Setting and locality.

Permission Refused

Reason(s) for refusal :-

  1. The proposed development, by reason of scale, massing, poor 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 D4, D8 of the London Plan (2021) and SP2, SP4, DM10 of the Croydon Local Plan (2018) and the Council’s Supplementary Planning Document Suburban Design Guide (SDG) 2019.
  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) and the Council’s Supplementary Planning Document Suburban Design Guide (SDG) 2019.
  3. The proposed development would provide inadequate provision for on-site car parking and would provide poorly accessed, located and amount of cycle and refuse storage facilities and would therefore be contrary to Policies DM10.2, DM13, DM29 and DM30 of the Croydon Local Plan (2018) and Policies T4, T5 and T6 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: 13th Dec 2021
Consultation Closes: 23rd Dec 2021
Target Decision: 11th Jan 2022
• Total Consulted: 14
• Objections: 12
• Supporting: 0
Councillor referral: Councillor Sue Bennett (21st Dec 2021)
Permission Refused: 3rd Feb 2022
Appeal Notice: 23rd Mar 2021
Appeal Representations: 30th Jun 2022
MORA Appeal Submission: 10th Jun 2022
Appeal Dismissed: 22nd Sep 2022

44 Orchard Avenue – Ref: 22/02015/FUL
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

13 Gladeside – Ref: 21/03518/FUL
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
Permission Refused: 23rd Aug 2022

77 Woodmere Avenue – Ref: 22/00726/FUL
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

187 Shirley Road – Ref: 22/01185/FUL
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

Awaiting Decision

21 Woodmere Gardens – Ref: 22/02598/FUL
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.

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)

19 Orchard Avenue – Ref: 22/02202/FUL
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.

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)

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 2021)

26 Gladeside – Ref: 22/00096/FUL
Erection of a two bedroom bungalow fronting Woodmere Close.

Consultation Closes: 27th Apr 2022
Target Decision: 17th Mar 2022
• Total Consulted: 34
• Objections: 2
• Supporting: 0

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: 29
• Supporting: 0

Flyer for download and social media sharing.

75 Shirley Avenue – Ref: 21/02622/FUL
Conversion of and extension to existing dwelling to provide four self contained flats.

We objected to the proposed development on the grounds that:

  • The proposed development is within an area of PTAL 1b which is inappropriate for “Incremental intensification” as it is NOT in an existing residential area within PTALs 3-6 or within 800m distance of a station or town centre boundary for “Incremental Intensification” as defined in the London Plan (2021) para 4.2.4.
  • There is NO definition of magnitude for acceptable Gentle Densification or Incremental Intensification and therefore we request that the Case Officer provides justification for the assessment of “Site Capacity” to meet the proposed sustainable development for this Site.
  • The proposed development does NOT provide full evidence to meet the London Plan Minimum Space Standards with respect to In-Built Storage Space
  • The proposal is non-compliant to requirement detailed in SPD2 Chapter 4 – Residential Extensions & Alterations. The Ground Floor Plans show the proposed extension at ≈9.8m width when the extension should generally be no wider than half the width of the existing house (5.25m) and no deeper than 45° (in plan) as measured from the assumed nearest habitable room windows on neighbouring properties which requires clarification but gives cause for concern
  • The ground floor extension 7.4m into the rear garden seems excessive.
  • The proposal has inadequate parking provision at a locality of PTAL1b for 12 persons probably 8 adults who could own a car or van for business purposes. 6 vehicles may need on-street parking.
  • The strategic Housing Need for the Shirley “Place” has been exceeded by cumulative developments in the MORA Post Code Area over 2½ years which is just a small portion of the Shirley North Ward (Not even including Shirley South Ward). Therefore, the housing need for the Shirly Place has been exceeded by recent developments and proposals in the MORA Post Code Area alone.

MORA Submission: 25th Jun 2021
Consultation Closes: 8th Jul 2021
Target Decision: 14th Jul 2021
• Total Consulted: 4
• Objections: 33
• Supporting: 0
Councillor referral: Councillor Sue Bennett (26th Jul 2021)

Appeals Pending

46 The Glade – Ref: 22/01881/FUL
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

34 Woodmere Avenue – Ref: 22/01806/FUL
Demolition of the existing property and the erection of two blocks of terraced houses, two storey buildings with accommodation in the roof space for three of the units, comprising of a total of four dwellings with six off street car parking spaces.

We objected to the proposed development on the grounds that:

  • The only non-compliance is Apartment 4 In-Built Storage capacity offered at 1.9sq.m. when the London Plan Policy D6 Table 3.1 requires 2.5 sq.m. for a 3b4p Unit. The additional Storage on the second floor is not stated as it is understood has insufficient height to be considered. All other Units meet the minimum Space Standards.
  • The Floor Plans for Apartment 1 indicate a GIA of 84.6m2 whereas the Design and Access Statement Document 4385027 indicates Apartment 1 GIA of 86.6m2
  • The Floor Area Ratio at 0.55 is slightly higher than the <0.5 required of the National Model Design Guide recommendation for Suburban Area Type Settings.
  • There is a significant issue regarding Parking relating to bays #1 and #6 being blocked by vehicles parked in Bays #3 and #5.
  • The requirement to enter and park on the private Driveway of #5 Pipers Gardens when exiting bays #1, #2 or #3 is totally unacceptable.
  • There would be additional difficulties, if any other vehicle were parked outside Nos 1 to 3 Pipers Gardens to exit from bay #5 or #6.
  • The Design Guide Residential Density has been reduced from Urban to within range of a Suburban Area Type Setting although would require a PTAL of 2.24 appropriate for a residential Density of 224.72 bedspaces/ha, or for a PTAL of 3.93 for a Residential Density of 280.90 hr/ha, when the available PTAL is only 1a.
  • The plans indicate that pedestrian access is directly in front of the four Dwellings with absolutely no privacy from the kitchen windows. Passers-by could quite easily peer into the kitchen accommodation from the footpath. This is an unacceptable invasion of privacy.
  • The pedestrian access from Woodmere Avenue is NOT within the scope of this proposal as it is outside the boundary of the proposal. However, there are reasonable questions on the viability of this access as the area has undefined responsibility. The previous owner of 34 Woodmere Avenue undertook responsibility for its upkeep as it was the only access to the dwelling and was the reason for its designation as 34 Woodmere Avenue and not no. 6 Pipers Gardens.
  • This pedestrian access could become a public footpath if the Council obtained ownership but the Land Registry needs to confirm whether the area is retained as 34 Woodmere Avenue or passed to the developer as part of the transaction to purchase the land from the previous owner of 34 Woodmere Avenue. This is not explained in the supplied documents of the Certification B on the Application Form.
  • There is a strip of land between the kerbstones on the East side of Pipers Gardens fronting the development Site but outside the Site Boundary. Ownership of this strip of land is of significance as if not part of the development area, and owned by a third party, the strip would preclude any access to the site from Pipers Gardens. These issues may be “Civil”
    and not Planning matters but the access to the development site is a condition of feasibility of development.
  • At only 1.2m the proposed pavement falls short of this ‘absolute minimum.’ This is particularly relevant for the existing residents of Pipers Gardens, who are more likely to require walking aids or wheelchairs. But also, for the proposed new houses that are likely to attract families with young children who will also require access for pushchairs, or for parents to walk side-by-side with their children. This would not be possible in Pipers Gardens as there is no existing or proposed pavement that provides a continuous, uninterrupted footway between the dwellings in Pipers Gardens and Woodmere Avenue. The footpath width should be a minimum of 1.5m for the safe passage of all pedestrians or any wheelchairs uses from the Dwellings in Pipers Gardens.

Appeal submitted in respect of the Council’s failure to determine planning application reference 22/01806/FUL relating to 34 Woodmere Avenue, Croydon.

MORA Submission: 16th Jun 2021
MORA Addendum: 20th Jun 2021
Consultation Closes: 24th Jun 2022
Target Decision: 24th Jul 2022
• Total Consulted: 18
• Objections: 11
• Supporting: 0
Councillor referral: Councillor Sue Bennett (23rd Jun 2022)
Appeal Notice: 23rd Aug 2022

21 Woodmere Gardens – Ref: 21/03702/FUL
Demolition of single-family dwelling and garage and the erection of 3 x two storey terraced houses with accommodation in the roof space, with 3 off street car parking spaces and a detached 2-storey building with accommodation in the roof space, comprising of 6 self-contained apartments with integrated bike and refuse stores and 6 off street car parking spaces.

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 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.
  • 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 localities within the Places of Croydon), to assess an applications’ Local ‘Site Capacity’ in accordance with the new London Plan (2021) Policies D2 and D3.
  • Recognising the foregoing, and acknowledging that the adopted Croydon Local Plan is ‘inadequate’ in specifying meaningful ‘growth’ definitions or to implement the New London Plan Policies D1, D2, D3, D4 and H2, Planning Officers must therefore make an assessment, based upon the current and future known public transport accessibility with other available services infrastructure’, ‘Local Character’ and ‘Site Capacity’ to estimate an appropriate level of Residential and Housing Densities for Sustainable Development within the available existing parameters, without ‘cognitive dissonance’, as there is no prospect of local supporting infrastructure improvements in the locality over the lifetime of these Plans.
  • 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 (9 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.
  • 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 National Design Guide and National Model Design Code where appropriate.
  • The NPPF National Model Design Code 2B indicates Housing Density for Suburban localities should be within the range 40 to 60 units per hectare. This development proposal has housing density of 78.38 Units per hectare which exceeds the Guide maximum of 60 by 30.6333% and should therefore be refused. This proposal should tend toward the lower limit of 40 u/ha as the PTAL is Zero.
  • The NPPF National Model Design Code ‘Built Form’ indicates that the Floor Area Ratio (FAR) in a suburban setting should be (Less than) <0.5, whereas the Floor Area Ratio for this proposed development is 0.57 and should therefore be refused.
  • All the foregoing reasoning confirms this proposal is an over development of the site at this location. It can however be logically assumed that “Gentle Densification” or “Gradual, Moderate Incremental Densification” (all undefined) in an area “inappropriate” for “incremental intensification” would have an appreciably ‘discernible’ reduction in Density than those localities categorised and listed in Croydon Local Plan (2018) Table 6.4 – “Accommodating Growth”.
  • It is overwhelmingly apparent therefore, that this proposal is an overdevelopment for this locality on the many methods of evaluation referenced in our submission, 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.
  • 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.
  • We have clearly established that both the New London Plan and the current Croydon Local Plan is ‘devoid’ of any defined policies to determine either acceptable or unacceptable ‘growth’ of any proposals with regard to the ‘Site Capacity’ and the available infrastructure for sustainable Densities which means the Policies are ‘unenforceable’ and ‘undeliverable’ which also means the LPA is not meeting its Statutory obligations to ensure Development Proposals are Sustainable Developments.
  • The proposal would result in the loss of a family home with generous garden space.
  • An approval of this Development Proposal would make a ‘mockery’ of all the NPPF Policies, Design Code Guidance and London Plan Policies referenced in this submission.

Permission Refused

Reason(s) for refusal :-

  1. The proposed development, by reason of scale, massing, poor 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 Chapter 2 and 12 contained within the NPPF (July 2021), policies D2, D3, D4, H2 of the London Plan 2021, policies SP4, DM10, DM26 of the Croydon Local Plan 2018 and the Council’s Supplementary Planning Document Suburban Design Guide (SDG) 2019.
  2. The proposal by reason of its massing and proximity close to neighbouring properties 19 Woodmere Gardens and 101 Woodmere Avenue would result in an intrusive and imposing form of development leading to a loss of outlook for surrounding neighbours, overlooking of neighbouring garden of no.19 and would be contrary to policy DM10.6 (c), DM10.7(d) of the Croydon Local Plan 2018, Policies D3 and D6 of the London Plan and the Suburban Design Guide (SDG) 2019.
  3. The proposed development would result in unacceptable standard of accommodation by reason of sufficient information to demonstrate suitable outlook and light to two of the bedrooms of the proposed houses supplied by velux windows, suitable internal headheight to houses; poor access arrangement, poor accessibility to all levels of the block of flats thereby conflicting with Policy DM10 of the Croydon Local Plan 2018, Policies D5, D6, D7 of the London Plan 2021 and the Suburban Design Guide SPD (April 2019).
  4. The proposed development would result in insufficient level of parking spaces, the creation of more than one crossover on a single site, unacceptable position of parking bays along Woodmere Avenue, insufficient sightline details, inappropriate cycle storage facilities by reason of design and position to one of the houses, insufficient footpath width to enable suitable collection of waste to the proposed houses, inclusion of electrical vehicle charging points or suitable blue badge parking and would therefore be contrary to Policies, SP8, DM13, DM29, DM30 of the Croydon Local Plan (2018) and Policies T4, T5 and T6 of the London Plan 2021.
  5. In the absence of a legal agreement securing sustainable highway contributions and establishing if off street vehicle access can be achieved, 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: 16th Aug 2021
Consultation Closes: 25th Aug 2021
Target Decision: 22nd Sep 2021
• Total Consulted: 9
• Objections: 9
• Supporting: 0
Councillor referral: Councillor Richard Chatterjee (31st Aug 2021)
Permission Refused: 28th Mar 2022
Appeal Notice: 5th May 2022

34 Woodmere Avenue – Ref: APP/L5240/W/22/3293208
Demolition of the existing property and the erection of two storey terraced houses with accommodation in the roof space, comprising six dwellings with six off street car parking spaces.

We objected to the proposed development on the grounds that:

  • This proposal, and the cumulative Cluster of Developments in the vicinity of 34 Woodmere Avenue, should be evaluated and considered as a whole as the combined increase in population has implications on the supporting infrastructure sustainability, which is a legal requirement of local planning authorities, serving all the new developments and for the existing residents. This additional proposal would result in a local Population Density of 421.35 residents per hectare, which is a 364.542% increase for the Shirley North Ward, from the 2021 Average Density of 56.806 Residents per hectare for the Shirley North Ward Based upon GLA Data and for the The London Plan Policy H2 Small Site para 4.2.4 limitations of ‘inappropriate’ “Incremental Intensification”.
  • The recent cumulative cluster of developments in the vicinity of 34 Woodmere Avenue, and including this proposal, all within ≈100m radius and within an area of ≈3.14ha, and all at a PTAL of 1a has and will completely changed the Character of this locality from single dwelling households with associated gardens to blocks of multiple dwelling flats and terraced houses in an area NOT subject to “incremental Intensification” as defined by the London Plan Policy para 4.2.4
  • It is overwhelmingly apparent therefore, that this proposal is an overdevelopment for this locality on the many methods of evaluation referenced in our submission, 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.
  • There is also lack of stated ‘minimum’ required built-storage capacity for future occupants which, by its omission is further proof of over development. The applicant would have difficulty squeezing all these requirements into the Site Area and straightening the curtilage boundaries, meet all the minimum space standards and design requirements within the site constraints. Although the rear gardens meet the required amenity space standards, they are extremely small compared to the local character of rear gardens generally across the Ward.
  • The Front curtilage boundary between Units 1 & 2 and Units 4 & 5 are configured slightly to encroach in what would normally be considered within the front curtilage of Units 1 (for unit 2) and Unit 4 (for Unit 5). It is appreciated that this arrangement is necessary to provide adequate Refuse Bin Storage and Parking Provision areas for Unit 2 and Unit 5 within the forecourts, but it provides further evidence that the site is over developed as the Boundary curtilages would normally follow the building line unit separation boundary projected into the front forecourt as is shown with the rear garden unit separation boundaries.
  • The proposed development Parking Bays are configured North/South on the forecourts of all units and if vehicles are parked in a forward direction will be required to exit in a reverse gear with minimal visibility of any pedestrian or road traffic in the path of the reversing vehicle.

Permission Refused

Reason(s) for refusal :-

  1. The proposed development, by reason of scale, massing, poor 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 D4, D8 of the London Plan 2021 and SP2, SP4, DM10 of the Croydon Local Plan 2018 and the Council’s Supplementary Planning Document Suburban Design Guide (SDG) 2019.
  2. The proposal by reason of its massing and proximity close to neighbouring properties in Pipers Garden and nos.30 and 32 Woodmere Avenue would result in an intrusive and imposing form of development leading to a loss of outlook for surrounding neighbours, overlooking of neighbouring garden of no.32 and would be contrary to policy DM10 of the Croydon Local Plan 2018, Policies D3 and D6 of the London Plan and the Suburban Design Guide SPD (April 2019).
  3. The proposed development would result in unacceptable standard of accommodation by reason of limited external amenity space for the houses, poor access arrangement, and no details in terms of sufficient fire safety measures, thereby conflicting with Policy DM10 of the Croydon Local Plan 2018, Policies D5, D6, D7, D12 of the London Plan 2021 and the Suburban Design Guide SPD (April 2019).
  4. The proposed development would result in the avoidable loss of a Yew tree (T2) and officers are concerned over the impact the proposal would have on a further Pine tree (T3) both of which offer good prominent visual amenity value, are considered to be of long life expectancy and make a contribution to the character of the area thereby conflicting with policy DM28 of the Croydon Local Plan 2018.
  5. 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).
  6. The proposed development would result in inappropriate cycle storage facilities by reason of design and position to one of the houses, does not provide sufficient detail to demonstrate inclusion of electrical vehicle charging points or blue badge parking and would therefore be contrary to Policies, DM29, DM30 of the Croydon Local Plan (2018) and Policies T4, T5 and T6 of the London Plan 2021.
  7. In the absence of a legal agreement securing sustainable highway contributions and establishing if off street vehicle access can be achieved, 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: 21st May 2021
Consultation Closes: 4th Jun 2021
Target Decision: 24th Jun 2021
• Total Consulted: 18
• Objections: 12
• Supporting: 0
Councillor referral: Councillor Sue Bennett (3rd Jun 2021)
Permission Refused: 21st Jan 2022
Appeal Notice: 4th May 2021
MORA Appeal Submission: 20th May 2022


Additional Matters

LPA Residents’ Association Meeting – July 2022

The Local Planning Authority Meeting was held on July 27th at Bernard Weatherill House, and MORA’s Chairman was in attendance. A summary of the proceedings will be supplied in due course.

Planning Advisory Service Peer Review

MORA has been involved in a Planning Advisory Service Peer Review, held on 22nd June.

Peer team members included:
Peter Ford from the Planning Advisory Service and
Shelly Rouse from the Planning Advisory Service
Cllr Ian Ward from Birmingham City Council and
Marilyn Smith from the London Borough of Barking and Dagenham.

Representatives from other Residents’ Associations including H.O.M.E (Havelock Rd, Outram Rd, Mulberry Lane, Elgin Road) Addiscombe RA, Coulsdon RA, Norwood RA, and Riddlesdown RA also attended.

To summarise the Review – some of the issues raised were of Councillors on the Planning Committee requiring more training, the LPA’s dismissive attitude towards Residents’ Associations, biased decisions and Officer and Developer relationships, and also the issues of lack of enforcement and backlogs were raised.

MORA raised the issue of our Local Plan being out of step with the National Guidance and the London Plan with regard to London Plan Design-Led Approach policies available in early 2021 and the National Model Design Code & Guidance available in January 2021 both omitted from our Local Plan. Also, that Officers had no credible concept of a development’s Site Capacity to fit in the building, the parking and amenity space with an available site capacity in relation to the local setting or Area Type.

MORA stated that there are no credible distinctions between the intensification designations and officers had no concept of the difference. We had developments in an outer suburban location which were more appropriate to a Central Location.

MORA also raised the issue of Targets not being monitored and that we had met our 20-year target for the Shirley “Place” in our RA area in three years.
We also mentioned that we had raised these issues with the Mayor.

The Planning Advisory team were interviewing others over the next few days and would then give a verbal report to senior Planning management. They will then publish their report within 3 to 4 weeks with their recommendations and the London Borough of Croydon are encouraged to display it on their website. Councils are not duty bound to accept the recommendations, but it is ‘frowned’ upon if they don’t.

DEREK RITSON
MORA Planning

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