|Public hearings into the Purley Skyscraper have just started. The Government “called in” the Council’s decision to grant planning permission to the skyscraper, which means a public inquiry is now being held by an Independent Planning Inspector – whose decision on the site will be final.
I will be speaking in the inquiry tomorrow (10 January 2017) at 10am at the Purley Baptist Church, making my objections clear. While I agree that the site needs re-development, a 17 storey skyscraper would be completely out of character in a quiet town like Purley. The current plans also lack proper parking provision, which would put a huge strain on existing parking spaces, and is lacking in adequate flood protection. These plans need to be rejected and so that a new application that is in keeping with the area can be put forwards. Five to seven floors would be more suitable.
I have also submitted a formal, written objection to the skyscraper to the inquiry – which details why this proposal is so wrong for Purley. I would also like to thank the 11,000 local residents who signed my petition opposing the skyscraper.
I have included a summary of my written submission below:
Summary of my submission
I fully accept the principle that this site is suitable for residential, mixed use or commercial development. It has a high PTAL rating and is in an area that is already developed, with a suburban character. There is no current amenity value to the site, which has been vacant for a long period, and it would benefit from development.
However, I feel very strongly indeed that the site is not suitable for a 17 floor building of the design proposed, for the five reasons listed below in Section D. My view is that a suitable development of this site which would comply with Planning Policy would be a development which:
a) was 5-7 floors in height, and
b) had suitable flood mitigation measures (such as a raised podium for the ground floor) and
c) had reasonable parking provision relative to its number of residential units
Grounds for Objection
In each section below, I list the relevant planning policy and then explain why I feel that this application does not meet it.
1. Excessive Height which is severely out of keeping and contrary to five Planning Policies
This proposal is for a building of 17 floors. The next tallest building in Purley is 4 to 5 floors (the red brick building opposite Tesco, at the southern end the High Street, at the junction with the Purley Cross gyratory). This proposed building is therefore around 4 times taller than the next tallest building and 5 times taller than most buildings in Purley, which are typically 3 floors. To find another building anywhere close to this high, you have to travel 3 miles north to Croydon town centre. So this proposed building is 4x to 5x taller than any other building for some miles around.
This proposal will fundamentally change the character of Purley as a place. It is currently a peaceful suburban district centre, surrounded by quiet residential housing. The built landscape does not consist of any tall buildings at all. This proposed 17 floor building simply does not fit in with the surrounding area at all, and fundamentally conflicts with it. People have chosen to live in this neighbourhood because it has a peaceful suburban feel to it, and because the built environment is not unduly intrusive. Were a tall building of this substantial height built, the character of Purley would be fundamentally and adversely altered. The building would loom over people, dominate the streetscape and block light. The proposed building is manifestly out of keeping, and I therefore oppose it in the strongest possible terms.
In my view, this issue of excessive height is the main grounds for refusal.
Below are listed 5 Planning Policies which this proposal breaches. I have offered a brief comment below each one, but the common theme is that these Planning Policies require a tall building to fit in with its surroundings. This proposal manifestly does not do so, by virtue of being 4 to 5 times taller than the other buildings in the immediate area – and indeed is 4x to 5x taller than any other building for some miles around.
CLP2 (2017) DM 16
Tall buildings should “Respect and enhance the local character” and (section d) “conserve or enhance the significance and setting of the assets of the wider historic environment” and (section c) “The design should be of exceptional quality and demonstrate that a sensitive approach has been taken in the articulation and composition of the building form which is proportionate to its scale”
This proposal quite clearly does not “respect and enhance the local character” (as required by this new version of Croydon’s own Local Plan) by virtue of its size relative to existing buildings. The design cannot be considered exceptional.
LP (2016) Policy 7.7
7.7 A: “Tall & large buildings should not have an unacceptably harmful impact on their surroundings”
7.7C (b) “tall buildings may only be considered in areas whose character would not be adversely affected by the scale, mass or bulk of a tall or large building”
7.7C (c) “tall buildings must relate well to the form, proportion, composition, scale and character of surrounding buildings, urban grain and public realm, particularly at street level”
Para 7.25 – Defines Tall & Large buildings as being “substantially taller than their surroundings” and says “they should be resisted in areas that will be particularly sensitive to their impacts”
Para 7.27 – “Ideally tall buildings should form part of a cohesive building group that enhances the skyline” [i.e. not a one-off like this one]
These important London Plan policies are blatantly contravened by this proposal as follows:
· 7.7 (A) – This proposal will have a harmful impact on its surroundings by virtue of being 4-5x higher than the surrounding buildings
· 7.7 (C) (b) – The character of this area will be adversely affected by the building, as outlined above
· 7.7 (C) (c) – The building clearly does not relate well to the “composition, scale and character” of the surrounding area given that it is standalone-building 4-5x higher than any other in the area. At street level, this building will loom over people and dominate the street scene and public realm
· Para 7.27 – This building is a standalone building, and does not form part of a “cohesive building group” as clearly required by Policy
In relation specifically to Purley: “As a broad location the main focus of major residential growth will be in and around the District Centre with high quality residential development that will respect the existing residential character and local distinctiveness.”
“The main focus of major residential growth will be the District Centre with high quality residential development that will respect the existing residential character and local distinctiveness.”
The proposed 17 floor building does not “respect the existing local character and local distinctiveness”. The building is fundamentally and profoundly different to the existing character of Purley. This important Croydon Local Plan Policy (both existing from 2013 and current emerging) is quite clearly breached.
CLP1.1 (2017) and CLP1 (2013)
Policy SP4, Clause SP4.6
“Some locations within the areas listed in SP4.5 [which includes Purley District centre] will be sensitive to, or inappropriate for, tall buildings and applications for tall buildings will be required to:
a) Respect and enhance local character and heritage assets;
b) Minimise the environmental impacts and respond sensitively to topography;
c) Make a positive contribution to the skyline and image of Croydon; and
d) Include high quality public realm in their proposals to provide a setting appropriate to the scale and significance of the building and the context of the surrounding area.”
There is no high quality public realm (indeed there is no public realm at all) in this proposal, breaching item (d) above. Again, this 17 floor building does not “respect and enhance local character” as required by item (a) above due to its excessive height relative to other local buildings.
NPPF (2012) Para 58, sub point 4
“Planning policies and decisions should aim to ensure that developments: … respond to local character and history, and reflect the identity of local surroundings and materials”
The scheme as designed quite clearly does not “respond to local character,” principally on the grounds that it is substantially too tall by comparison to surrounding buildings. This point has been made repeatedly above. The NPPF is an important planning document which this proposal contravenes.
We have now seen that five planning policies clearly contradicted by this proposal. It is interesting that Policy at every level is contradicted – National, Regional and Local:
· NPPF (2012), in force
· London Plan (2016), in force
· Croydon Local Plan, both in force (2013) and emerging (August 2017)
I have not analysed the newly published London Plan (November 2017) as this is a first draft published on 29th November 2017 and it has not even had initial consultation responses gathered on it yet.
There is a sixth Policy which the applicants and council may cite in support of the application:
DM44.1(b): Development in Purley should “Complement the existing predominant building heights of 3 to 8 storeys, with a potential for a new landmark of up to a maximum of 16 storeys”.
I would make three points in pre-rebuttal to any such claim, should the applicants make it:
· DM44.1 is the only piece of policy which can be read as supportive of the proposed 17 floor building. The other five Polices cited above all point clearly for rejection of the proposal. So by a margin of 5:1, relevant Planning Policy is against this proposal
· DM44.1 claims that current buildings in Purley are 3 to 8 floors. A glance out of the window shows that this is not the case – there is very little over 4 floors and nothing over 5 floors. The premise of DM44.1 is therefore patently inaccurate which materially undermines its persuasiveness
· The policy only refers to the “potential” for a tall building. “Potential” is an extremely weak formulation. A site may have “potential” for 16 floors, yet that does not mean it has to be developed as such. A weak reference to “potential” is therefore not a compelling point in favour of the application. This is insufficiently strong to overcome the very clear Policy opposition to this proposal which flow from the other 5 Policies quotes above – and which apply at the national, regional and local level.
It is clearly a matter of plain fact that the proposal is 4 to 5 times taller than any other building in Purley, and is therefore not respecting the character of the area and is fundamentally changing it. In confirming this view, it is relevant to consider the opinions of local people who know the area well and live here. It is therefore pertinent to note that this proposal is objected to by:
· 7 local Residents Associations representing approx. 15,000 households or 35,000 people.
· Me as the local MP, re-elected by 33,334 local people in June 2017
· The local Greater London Assembly Member, elected by 70,156 people across Croydon and Sutton in May 2016
· 11,933 local people (almost entirely from local postcodes CR8, CR5 and CR2) who responded to my survey on this topic (up to 14th December 2017), of whom 95.44% were opposed
· At least 15 local councillors (being all or virtually all of those representing broadly affected residents)
· When the original application was heard, the council received 616 formal responses: 551 objecting, 57 supporting and 7 commenting. This is an 89% rate of objection
On the other side, there is only one Residents Association in favour (whose own residents take a dim view of their committee’s support) and one business association. The balance of local opinion is overwhelmingly opposed.
This shows clearly that the objections I have made in this section – namely, that the proposed 17 floor development is fundamentally out of keeping with the local area – commands very widespread local support.
2. Density which exceeds current London Plan Policy
LP (2016) Policy 3.4 & Table 3.2
Habitable Rooms should be 200-700 / Ha. This application is 817 / Ha (note that Croydon Council incorrectly stated 717 / Ha in the original Planning Cttee report). The Island Site on its own is 1,052 Habitable Rooms / Ha
The development as proposed, taken as a whole, exceeds the upper end of the density reference range (700) by 117 habitable rooms per hectare or 17%. It exceeds the lower end of the range (200) by 308% and exceeds the mid-point of the range (450) by 82%. The Island Site taken on its own (and this is important since the Island Site is physically separate to the South Site) has 1,052 habitable rooms per hectare. This is 50% higher than the top end of the policy range (700) and over double the mid-point (450). The proposed scheme is materially denser than the current London Plan allows for in a setting such as this one, especially the Island Site taken on its own. This is clear grounds for refusal.
(Note – the “Island Site” is the part of the site adjacent to the current Baptist Church where the 17 floor tower is proposed)
3. Damage to a protected panorama view
CUDP (2006) Policy UD11
“The Council will ensure that all new development and proposed alterations to existing buildings do not have an adverse impact on the designated panoramas, local views and landmarks”. Para 4.65 goes on to define the view from Farthing Downs (View “CP5”) as a protected Panorama.
LP (2016) 7.7 D (b)
“Tall buildings … should not impact on local or strategic views adversely”
The view from Farthing Down, a protected open space of very considerable beauty, is protected as described above. This proposed building would be very clearly visible from Farthing Down and spoil this protected panorama, contrary to Policy UD11 and LP (2016) 7.7 D (b) as specified above. From the 135m above sea level contour on Ditches Lane (which runs along the top of Farthing Down), the line of sight to the development runs about 30 degrees east of due north. The highest point on this line of sight is along a road called Hartley Down which is 100m above sea level. The base of the tower sits at 65m above sea level, and has a total height of about 60m, so the top of the tower is 125m above sea level. So at least the top 25m of the tower (around 8 floors) will be clearly visible. An illustrative diagram is given below. This development will quite clearly have an adverse impact on the protected panorama from Farthing Down, and as such is contrary to Policy.
4. Flood risk not mitigated
NPPF para 100
“Inappropriate development in areas at risk of flooding should be avoided by directing development away from areas at highest risk”
“The SFRA identifies significant episodes of surface water flooding at Purley Cross”
“The Strategic Flood Risk Assessment (SFRA, 2009) identifies the main risks of fluvial flooding in the vicinity of the Norbury Brook through Thornton Heath and Norbury and through Kenley, Purley and Waddon along the Brighton Road and Godstone Road valleys and around the culverted River Wandle”
The NPPF as referenced above is clear that development should not take place in a flood risk area. CLP1 (2013) and CLP1.1 (2017) both acknowledge that this is a high flood risk area. Purley Cross has severely flooded several times in recent years, as is well documented. As recently as February 2014 the whole underpass at Purley Cross was completely underwater. Any proposed building on this site should therefore have substantial flood mitigation measures in place – such as a raised podium for the main ground level – which this design does not have.
5. Inadequate Parking arrangements, with unacceptable consequences
NPPF (2012) para 29
“The transport system needs to be balanced in favour of sustainable transport modes, giving people a real choice about how they travel.”
This scheme does not give the choice referred to in the policy above. For the 220 flats there are only 37 parking spaces. In the Council’s planning report for Committee, paragraph 8.149 admits that the development needs 165 car spaces, and clause 8.147 of the same report recommends that future residents of the scheme are excluded from residents parking permits. This will cause parking chaos on other roads where there is not a CPZ (Controlled Parking Zone) and on unrestricted parking spaces. Moreover, the very large numbers of pedestrians leaving the building may pose a safety risk at busy times as much larger numbers than now seek to cross the very busy roads surrounding the Island Site.
* * *
This building will fundamentally and detrimentally change the nature of Purley, and is manifestly out of keeping with the place – being 4x to 5x higher than any other building for some miles. For this and the other reasons outlined above, which are fully shared by the vast majority of local residents (95% according to my survey of 11,933 people), I urge the Inspector in the strongest possible terms to reject this application.
Chris Philp MP
14th December, 2017