Why the inspector should reject Croydon’s Local Plan


By - Tuesday 20th June, 2017

Sean Creighton thinks it’s unsound, poorly evidenced, unsustainable, and undeliverable


Croydon Council’s website describes the Local Plan as its ‘vision for enabling future development in the borough from now until 2036, in terms of homes, shops, jobs, schools, hospitals, leisure and recreation’. The Local Plan is a framework of polices and proposals to influence the future development in the borough in these areas. 

The council says that it ‘includes provision for the protection and conservation of our natural and built environment and how we respond locally to climate change’.  Its main sections were adopted in 2013. There was a partial review in 2015, a process open to public consultation, leading to some changes and adoption by the council cabinet in 2016. It is currently being examined by an independent planning inspector. The inspector held nineteen public hearing sessions in May in which I took part.

The council has already submitted and is continuing to submit changes. The inspector is now assessing whether the plan is sound, properly evidence based, sustainable, and deliverable, and whether he should recommend its rejection or adoption.  If he recommends adoption, he may also outline a range of issues the council will need to further consider.

At the close of May’s public hearings, the council officers asked the inspector to approve the Local Plan changes and to make recommendations for the council’s further consideration. They are still considering whether to offer yet more modifications. The inspector made clear that he had to be sure the plan is sound, even if it is not perfect.

Of course the plan cannot be perfect. As every month goes by there will be changes that will make it difficult to interpret: new government and London mayoral policies and new development challenges that could not have been predicted coming from developers, the NHS and others, and economic changes whether in the form of overheating or another crash.

After the close of the public hearings, I submitted a paper to the inspector, arguing why he should reject the plan as unsound, poorly evidenced, unsustainable, and undeliverable.

I set out fifteen main grounds to which I had alluded at the beginning of the hearings. There were also fundamental flaws in the consultation process with dozens of recommendations for changes being ruled out of order on technical grounds without acknowledging that the issues raised might be dealt with in a different way. Many other examples of poor evidence were highlighted during the sessions. Many representations made were concerned about omissions. The inspector made it clear that he could not consider omissions, except in so far as a large number might suggest that the plan is unsound.

Unsustainability

A key issue in relation to new developments is their impact on the surrounding area and the need to evaluate what these may mean in the process of drawing up plans, which for very large schemes will involve a high level of sophisticated meaningful community engagement. This has been sadly lacking in Croydon. It is important to learn lessons from each exercise to assist future ones. If this does not happen, then each scheme is dealt with in isolation, and this does not help sustainability.

Quality of life issues are central to assessing sustainable development. Sustainable development is about integrating the social, the economic and the environmental. This inevitably means that there are conflicts between these different aspects, which the Local Plan is a key tool to moderate. For the plan to be sustainable, it has to show how land use issues assist those three elements.

An over-obsession with meeting centrally and regionally imposed housing targets distorts the integration of these three elements and increases conflict. That is why the plan needs to be robust, to ensure effective moderation of and mediation during conflict. Ambiguity and lack of clarity will not help, as has been tested at several of the sessions.

There will be compromises and trade-offs, as there are no absolute answers. It is therefore crucial that both applicants, the council and the affected residents and special interest groups sit round the table.

 Concerns expressed by council consultants

In its justifications of the plan, the council officers referred frequently to reports by the consultancy AECOM to justify its view that the Local Plan is sustainable. I have listed sets of reservations expressed in these reports relating to loss of employment sites, energy consumption, water resources and use, air quality, and noise and social exclusion, appraisal of site options, sports and recreational facilities, deprivation, the link between housing and economic growth, and existing schools.

In conclusion, I have suggested that it is in the interests of the council that the inspector does not reject the plan, and that it should therefore offer major modifications in order to try and convince him not to the reject it. Where it cannot suggest modifications, it should offer a list of recommendations about additional work the council will need to do to support a more robust, soundly based, sustainable and effective plan.

Sean Creighton

Sean Creighton

A former employee of and freelance project worker with community and voluntary organisations, Sean is active with Croydon Assembly, and Love Norbury Residents Associations Planning & Transport Committee. He is Chair of the Norbury Community Land Trust. He is a historian of Croydon and South-West London, and of British black, , social action and labour movement history. He co-ordinates the Samuel Coleridge-Taylor and Croydon Radical History Networks. He runs blog sites covering Croydon, Norbury and history events, issues and and news. He runs a small scale publishing imprint - History & Social Action Publications. He gives talks on a range of history topics and leads history walks.

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  • Sean Creighton

    As this piece was being published I received 14 emails from the Council’s Freedom of Information Team rejecting 14 requests for information relation to evidence for the Plan. You can see the details at https://seancreighton1947.wordpress.com/2017/06/20/croydon-council-rejects-freedom-of-information-requests-about-local-plan

    Although it was not an issue at the Hearings it is worth remembering that it is 50 years since the then Labour Government introduced Conservation Areas. The Voluntary Action History Society is holding a one day study event to mark the occasion and to consider the future for Areas. The details can be seen at https://seancreighton1947.wordpress.com/2017/06/19/50-years-of-conservation-areas-and-their-future/

  • Robert Ward

    I’m with you on this Sean. The quality of evidence presented in council consultations is very poor indeed. Response to requests for more information is usually that we need to be happy with what we have been given because that’s all we are going to get.

    I recall asking for information on how two traveller sites were chosen and was told that they were chosen based on ‘criteria’ and that they were miles ahead of the other sites evaluated. What the criteria were and which sites came next in the ranking, indeed any other clarification information was refused.

    Yet within a very short period these two sites were abandoned when the council found that they did not own them. Suddenly the Purley Oaks site came out of nowhere because it was a site the council owned, a criterion that must have hardly weighed in their original ranking.

    Similarly with the unrelated landlord licensing consultation. Evidence presented was extensive, but largely irrelevant to the issue at hand.

    Of course the council can over-rule objections, but over-ruling on the basis of no evidence, or at best evidence we are not allowed to see is an abuse of process.