As you will know, the Labour-run council is intent on concreting over our neighbourhood and destroying family homes – and has been passing applications indiscriminately to do this for several years. The key planning document for Croydon is the “Local Plan”. It is set every 5 years or so by the council, and it is used when making decisions about whether to approve or refuse planning applications.
Now Labour in Croydon intends to go even further and change the Local Plan to allow severe across-the-board “intensification” (i.e. knocking down houses and building even larger blocks of flats) across Coulsdon, Purley, Kenley, Sanderstead, Selsdon, South Croydon and Waddon – even more than now. This emphasises why it is so important to elect Conservative Councillors and a Conservative Mayor in the local Croydon elections in May to stop this from happening.
But in the meantime, there is a consultation on the new Local Plan closing at 5pm on Thursday 17th February. I enclose below the points I am making to the consultation. You can email a version of these or your own comments in to email@example.com. The full consultation documents (warning: there are a lot) are available here on the council’s website. I apologise the points below are quite long, but this is important.
I enclose below my comments on the Draft Local Plan. I believe it to be “unsound” on the basis that it lacks justification and fails to enshrine the good design principles required by the NPPF.
I am deeply alarmed by the proposals in SP1.0C and DM10.11 to allow for “focused” and “moderate” intensification – entailing building very dense or larger buildings in place of family homes in many peaceful and green suburban parts of the Borough. This will fundamentally change the character of the area. These policies take no account of cumulative effects, which may see whole streets of family houses destroyed. I note that protections around character, size and cumulative effect that exist in the current policy DM10.1-10.8 are to be deleted or substantially watered down. I am deeply concerned and appalled by this and believe it to be inconsistent with the NPPF’s provisions about good design, and wholly without justification (see supply points below).
I am concerned about this grotesque “intensification” occurring in Coulsdon (DM37), Kenley (DM40), Purley (DM42), Sanderstead (DM43), Selsdon (DM44), South Croydon (DM46), Waddon (DM49), which are all peaceful suburban areas.
I also believe that the housing targets are simply wrong in the way they are allocated across the Borough. Firstly, the table on page 34 appears to take little or even no account of the council’s own 5 year housing land supply (identified in its own most recent monitoring report) of 17,707 dwellings – almost double the 9,153 required.
Secondly, it appears that the Croydon Opportunity Area figure of 14,500 takes inadequate or even no account of the Brighton Mainline or North End Quarter opportunities, which are huge. These would allow the Croydon Town Centre figure (currently 14,500) to be a lot higher.
The target figure for Purley at 5,735 is frankly absurd and would turn a peaceful suburban centre into a small city. This is unnecessary and destructive. The figures for Coulsdon, Kenley, Selsdon and Sanderstead are also inappropriately high as drafted.
Given my foregoing remarks about the fact that Croydon already has around 2x its 5 year land supply and the Brighton Main Line and North End Quarter Opportunity areas are not represented in the figures, both the absurd target for Purely (and other areas) and the shocking wider “intensification” mentioned before are quite simply not justified as necessary to meeting housing targets. There are ample Croydon Town centre and brownfield sites to meet the housing need in Croydon without “intensifying” (i.e. destroying) the suburbs and turning the whole Borough into a highly dense urban area, with no meaningful planning protection.
Moving on, I note that policy DM42.1(b) is left in, for a 16 storey tower in Purley (where most buildings are 3 floors). This is carried over from the previous local plan, and the building is now (sadly) under construction, so this reference should be removed.
There is also a plan for a Gypsy and Traveller site at the local Purley Oaks recycling centre (site 324, page 677). Is this an error? This is a vital local facility and is in a flood zone. The plan itself earlier prohibits a gypsy and traveller site in a flood zone, so is contradictory.
I am also concerned that the Purley Way Transformation proposals have many blocks of flats up to 8 floors. This is therefore a missed opportunity to create streets of liveable houses, not yet more tower blocks.
Finally, in terms of soundness, in addition to those already mentioned, the draft local plan has a number of shortcomings:
- Lack of any evidence of agreements with other neighbouring authorities in terms of unmet need.
- Insufficient reliable evidence raises queries as to how justified it is.
- Unlikely to be effective as the plan as it stands is not deliverable and is not based on sufficiently evidenced effective cross-boundary strategic matters.
- It is not entirely consistent with national policy.
I would like to appear at any public enquiry to make these points and any related ones to the Inspector in person.”
Please do send something in yourself to the consultation if you have time – the number of submissions will be accounted for. In the meantime, I will keep fighting to preserve the character of our local neighbourhoods. And we will have a chance in May to vote out the Croydon Labour Party who have been intent on so vindictively destroying the character of our neighbourhoods for the last 8 years.