In FULL, my objections to the Council’s Local Plan

I have submitted my objections to the Council’s Local Plan – a document that will shape the Borough for years to come.

The document is a long, and by necessity, a complicated one. I have been asking residents to help oppose the Plan, since it contains proposals that will have a serious, lasting impact on the Borough.

In particular, many residents have wanted to know what can be done to stop the Council’s proposal to build a traveller site at the Purley Oaks recycling centre – I encourage anyone opposed to the site to let the Council know your own reasons for opposing the site; you can find my reasons for objecting about 2/3rds of the way through the letter.

We now have less than a week to go until the consultation is closed, so if you haven’t sent your objections yet then please do so. I would also like to thank everyone who has taken the time to help stop the Council’s proposals from causing serious damage to our Borough.

Objections can be sent to and please feel free to use any wording from the letter below.


Dear Sirs

Croydon Local Plan: Strategic Policies – Partial Review (Proposed Submission) and the Croydon Local Plan: Detailed Policies and Proposals (Proposed Submission)

I object to the de-designation of Croham Hurst from Metropolitan Green Belt as detailed in Table 6.1, Amendments to Green Grid Designations, as this would not comply with policies SP7, DM19, DM27, DM28 and DM48 and the protection of the green grid.

This tract of land is instrumental in checking the unrestricted sprawl of the large built up areas around it. Indeed, it was bought by the Council to prevent the landowner developing the site at the turn of the 20th century. The history of attempted development of Croham Hurst Golf Club in recent decades poses a real risk for the character and the setting of the area and the potential impact on this heritage asset. The historical context of Croham Hurst is incredibly important and it should be given the upmost protection, It is also a biological Site of Special Scientific Interest and a site of metropolitan importance for Nature Conservation. The site also contains a Bronze Age round barrow, which is a scheduled Ancient Monument.

I also object to the de-designation of Sanderstead Plantation and Purley Downs from Metropolitan Green Belt as detailed in Table 6.1, Amendments to Green Grid Designations, as this would not comply with policies SP7, DM19, DM27, DM28 and DM48 and the protection of the green grid.

The woodland at Sanderstead Plantation is known by the local RSPB as a site of importance to a number of bird species.  There is plenty of local evidence of owls, bats and deer regularly being seen and heard by local residents along with an abundance of other low profile animals.

This woodland is maintained by a number of volunteers who endeavour to maintain it as an amenity and stock it with indigenous trees whilst preserving native species where possible. It is inhabited by a variety of wildlife and is a wonderful amenity used by all ages, young and old and much appreciated by local residents.  The volunteers regularly plant new trees to sustain the continuance of this woodland, some 2000 over recent years. This includes 60 new oaks planted in a diamond for the Queens Jubilee, as well as Lime, Sweet Chestnut, Oaks, Walnuts and Rowan amongst the many others planted.

Purley Downs hosts a well-managed golf course which is set in a beautiful open landscape with a wonderful abundance of wildlife and vegetation.

In the context of the ‘Review of Metropolitan Green Belt and Metropolitan Open Land’ produced in July 2016, it is clear that this land does meet Metropolitan Green Belt as it does check the unrestricted sprawl of London, does safeguard Croydon’s countryside from encroachment, preserves the setting and special character of the heritage of Croydon and it assists in regeneration by encouraging the recycling of derelict and urban land. The proposal for de-designation has not been positively prepared, is not justified or effective and is not consistent with national policy.

I cannot see any justifiable reason why Croham Hurst, Sanderstead Plantation and Purley Downs are being treated differently to the rest of the green belt within Croydon. It is imperative that they retain their Metropolitan Green Belt status.

I object to Woodcote Valley Road, Woodcote Estate, West Hill and Oakwood Avenue, not being created as Local Heritage Areas, and indeed that many of them are losing their protection as Local Areas of Special Character, as detailed in Local Heritage Area Review, section 3, Assessments of the Areas Proposed as Part of the Consultation on Croydon Local Plan.

Some recent planning decisions have shown that these particular areas are not sufficiently recognised and protected by the general policies in chapter 7 paragraph 58 of the National Planning Policy Framework, policy 7.4 of the London Plan or policy SP4 of the Croydon Local Plan.

All of these roads and estates need additional protection to maintain their historical context and character. They comply with policies SP4.11, SP4.12 and SP4.13 and should be designated as Local Heritage Areas. It would not be justified or effective to exclude these roads from Local Heritage Area protection.

Many roads and communities across Croydon are suffering from the cumulative impact of too many Houses in Multiple Occupation. This is a particular problem in areas where larger houses are easily converted to bedsits and studios. The Council should introduce an additional policy into SP2: Homes, this should recognise the impact that HMOs have on an area and seeks to limit the numbers, so that existing communities are not overwhelmed by an increasing population that puts further strain on highway parking, refuse and recycling collections and street cleansing. As an example, such a policy would have a dramatic, positive, impact in areas such as Blenheim Park Road and Birdhurst Road in South Croydon, Chatsworth Road in Central Croydon and many of the roads around Croydon University Hospital.

I object to the introduction of policy DM44.1, sub-section B, which states that developments in Purley have a ‘potential for a new landmark of up to a maximum of 16 storeys’, when the existing building height ranges from 3-8 storeys. This policy conflicts with policy DM11.1 as such development would not ‘enhance and sensitively respond to the predominant built form’.

Furthermore, it does not comply with policy SP4.6 which states that some areas will be ‘inappropriate for tall buildings’ and that applications should ‘respect and enhance local character and heritage assets, as well as minimising environment impacts and responding sensitively to topography’. As such policy DM44.1B has not been positively prepared and is not justified or effective.

The addition of a swimming pool at Purley Leisure Centre, site 30 Table 11.13, is to be welcomed. However, the language used does not require a ‘like for like’ replacement with a 25m pool with spectator seating to enable competition use, which could result in the replacement pool being inadequate for local demand. As such this site proposal does not currently comply with policy SP5.3, sub section B, ‘protecting existing community facilities that still serve, or have the ability to serve, the needs of the community’.

This site proposal should be amended to allow for the exact replacement of the existing facilities.

I object to the creation of areas of focused intensification proposed for areas off Godstone Road in Kenley, around Brighton Road in South Croydon and in Sanderstead as detailed in Table 11.2.

The policy clearly supports ‘the intensification of areas which are developable, where there is adequate provision of community infrastructure, good accessibility to public transport and open space and schools’. The Plan proposes to allow more intensive development in the residential areas behind All Saints’ Church (Onslow Gardens, Blenheim Gardens, Cranleigh Gardens and Stanley Gardens) in Sanderstead, which is at odds with the Council’s proposal that views of this 13th Century Early English style church be protected.

The proposed areas fail to meet these criteria on many levels. The proposed areas are too large, covering many residential streets behind the major through routes. The proposal will add demand to an already struggling infrastructure that does not have sufficient transport links, schools and community facilities. The proposed level of intensification is above the capacity that the character of the areas can handle and there is no mechanism in the Plan to deliver the improved infrastructure that would be needed. This element of the Plan has not been positively prepared, is not justified or effective and is not consistent with national policy.

Such areas of intensification need to be shrunk within the Plan, so as not to affect the surrounding suburban streets, thereby reducing the impact on the local infrastructure.

I object to the use of site 324, Purley Oaks Depot, 505-600 Brighton Road as a Gypsy and Traveller site, as detailed in policies SP2.9 and DM44.

This site fails to meet many of the specific policies of SP2.9, namely that sites should have access to essential services, not be located in areas of high flood risk and not have an unacceptable adverse impact on the biodiversity of the borough.

The site is also a designated site in the adopted South London Waste Plan, policy WP4, Schedule 2, Area 99. This plan states that the following issues would need to be considered: Protecting the residential amenity of those properties adjacent to, or in the vicinity of the site; Limiting traffic movements so as not to hinder traffic flow on the surrounding roads; Respecting and enhancing the on-site wetlands habitat; Minimising flood risk on and off site; Evaluating and preserving any archaeological remains; Remediating the site of historical contamination. This site is particularly important for this waste designation as only a small number of sites have been designated across the four boroughs for waste expansion.

Purley Oaks Depot sits behind a major borough recycling centre that needs expansion. This proposal would preclude that expansion. The site has been used as a depot for many decades dealing with concrete and road surfacing etc. and is no doubt the subject of contamination. The site also contains the balancing pond that is vital in local flood defence. Other sites have been excluded on the issue of noise, yet this site is next to the very busy Brighton Mainline railway line. The local road network also lacks capacity.

The Council’s original report on the site scored it as low for reasons such as flood zone, ground water source protection zone, surface water management, existing infrastructure, heritage designations and impact on local character.

The Council’s own assessment is subjective with scoring values being disproportionately weighted. Where multiple options apply, the lowest score has been given.

Prior to this consultation there has been no public consultation on this site, putting local residents and businesses at a disadvantage.

This element of the Plan has not been positively prepared, is not justified or effective and it is not consistent with national policy.

As an alternative the Plan should look to use underused industrial sites similar to the existing site at Lathams Way. There are many vacant plots in the environs of the Purley Way and in places such as Commerce Way.

I would like to participate in the oral part of the Examination in Public.

Yours sincerely,


Chris Philp MP