Last chance to improve the Croydon Local Plan

By - Wednesday 4th October, 2017

Local Plan Modification consultation ends next week, but many sections remain deeply flawed

Croydon Town Hall.
Photo public domain.

The council’s proposed Local Plan Modifications consultation ends on 10th October. It is regrettable that so much of the evidence submitted by residents associations and others have been ignored. It is not too late for one last attempt to influence the details of the plan for the better. The consultation documents can be seen here.

It was pointed out to the inspector at the plan hearings in May that the original consultation process was flawed. The hearings were also flawed in that there is no transcript of the discussion of what the council officers said in verbal response to those giving evidence.

The hearings drew attention to a number of new issues on which there is no record of any consideration by the Council afterward.

The consultation documents do not contain an explanation of why each modification is being made

Examples of these include: helping the elderly in large property downsize but staying in their local area, treating registered social landlords differently from private developers so they have more flexibility to develop small sites to help the elderly move and recognizing that the built and natural environments are major determinants of health and well-being.

The consultation documents do not contain an explanation of why each modification is being made, even by simple reference to the discussion documents between the inspector and the council.

There is no introductory explanation as to why the council has not accepted modifications proposed by those giving evidence at the hearings. This makes it difficult to understand the meaning of many of the modifications. It also puts those wishing to take part in the consultation at a disadvantage.

Some modifications may be completely ineffectual

There are several modifications which are welcome and can be supported: MMD9 (vacant building credit), MMD77-78 (protection of pubs), MMD85 to 90-93 (trees) and MMD96 (electrical car charging).

Several proposed modifications may weaken the plan. e.g. MMD63 (publicly accessible areas of tall buildings), MMD70 (heritage assets) and MMD74 (community facilities).

Some modifications may be completely ineffectual. MMD97 (car parking) is unlikely to reduce the growing competition in certain areas for car parking on residential streets because it ignores the fact that many people are now required to keep their work vehicles at home.

The council continues to use phrases such as ‘enhanced sense of space’

The council continues to use meaningless phrases such as ‘enhanced sense of space’. This leaves too much scope for argument and gives developers too much flexibility to justify schemes that may, in the view of residents, harm ‘sense of place’.

MMSI-3 updates the housing target figures and alters the share to be met in different parts of the borough. The target in the Croydon Opportunity Area (COA) is increased from 10,650 to 10,930. The figure elsewhere in the borough is reduced from 7,300 to 6,800. However, the contribution across the whole borough from what the council calls windfall sites is increased from 9,120 to 10,060.

It now aims to bring at least 190 vacant homes back into use by 2026

It now aims to bring at least 190 vacant homes back into use by 2026. This amendment gives effect to its earlier acceptance of Croydon TUC’s (CTUC) proposal which the council overlooked to include modifications that were examined by the inspector.

MMS4 retains the aim to achieve 50% affordable housing. However the council now proposes to add ‘subject to viability’, and the deletion of this being achieved on sites with ten or more units. It is not clear whether this means developers proposing schemes of less than ten units will now have to consider offering an element of affordable housing. Should there be a further modification to clarify this?

MMS6 sets out lower levels of affordable housing if 50% is shown by developers to be not viable. In the COA, the council proposes to expect a minimum level of 15% and 30% elsewhere in the borough. These percentages are very low. It is proposing to require that when developers want to provide ‘affordable’ housing on a different site, they will have to have a prior planning permission. This accepts the suggestion of CTUC.

The council is effectively saying that it cannot control bedroom size provisions

The lowering of the target in MMS7 from 50% to 30% for all new homes to have three or more bedrooms is regrettable. The addition to MMS13 justifies the reduction on the basis that the council has until now failed to achieve its existing policy on family size housing. The council is effectively saying that it cannot control bedroom size provisions. If this is the case, then the same is likely true for other large parts of the plan whether subject to proposed modifications or not.

The recognition in MMS17 of the need for “lower quality floorspace for which there remains a demand” recognizes the evidence by CTUC and others that there was a risk of losing cheaper office accommodation which would prevent new businesses setting up. However, MMS22 only recognizes the need for 10% lower than Grade A offices. Is this sufficient?

The principle of trying to ensure that approved developments involve the provision of 20% job opportunities to Croydon residents is welcome, and recognizes the concerns raised by CTUC, but is it high enough?

The council is also proposing to take into account the potential cumulative impact of a sustainable community

In response to the inspector, the council has had to remove the link between health and hot food takeaways. In MMD17 and MM21 it is proposing to insist on adequate arrangements for dealing with waste.

The Inspector was concerned about the omission of any reference to homes in multiple occupations, which was pointed out in evidence by the Norbury Joint Planning Committee (NJPC) and others. This is addressed in MMD26-28 (design standards). This includes a slight tightening of protection for three bedroom houses from conversion but does not increase the 130 sm size above which they can be converted, even though the NJPC submitted figures showing that there were three bedroom houses larger than this. The council is also proposing to take into account the potential cumulative impact of weakening the existing or preventing the strengthening of a sustainable community involved in conversions.

Note: The author gave evidence at the Hearings for CTUC and NJPC.

Sean Creighton

Sean Creighton

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

More Posts - Website

  • RSDavies

    The Local Plan has been flawed since the day it was first put out in draft form for consultation. My abiding impression that the real driver behind was ensuring that the impact of change and high density development is limited to a few areas and the structure of consultation ensured that these areas were always marginalised.
    There was some moderation of this when Labour took control of the council, but the basic structure did not change.
    In all the years it was being developed the Planning Officers declined to attend any of the community group meeting to explain what was being proposed. This was a massive commission for the areas most affected by the proposed Local Plan.
    Ultimately I felt that the fundamental problem is that Croydon simply doesn’t want to engage in the debate about how the town responds to the drivers for change and sustains itself for the next decades. In too many consultation events it was evident that attendees were in denial about the realities about them and were transfixed by their individual short term interests.