UPDATE: Purley Skyscraper

In 2016, the Labour Council gave planning consent to a 17 floor skyscraper in Purley. This was completely out of keeping with the character of Purley and would have changed the character of the area. In April 2017 the Government to called this in – which suspended the planning application – and there was a public enquiry in early 2018. In late 2018 the Government refused permission, but the developer successfully challenged this in the High Court in early 2019.

There will now be a new public enquiry in December 2019. I am due to speak at 11am on 3rd December, at Purley Baptist Church, on Purley Cross. Please do attend and watch if you would like to.

In the meantime, do please sign the petition against the skyscraper at: www.surveymonkey.com/r/StopPurleySkyscraper and forward the link to your friends, neighbours and family.

Please also email your views to the Planning Inspector at: tim.salter@planninginspectorate.gov.uk

My full updated objection to the scheme is below:

Purley Baptist Church Site – PINS Ref 3174139; Application Ref: 16/02994/P

18th September 2019

I am writing in my capacity as MP for Croydon South, where the above site is located. I was recently invited by Croydon Council to make additional comments on this matter.

I have four main grounds for objection to the application, which are laid out below.

1. The height of the building is fundamentally out of character and contrary to a number of local and national Policies

This application is for a 17 floor building in a small district centre, Purley, which is surrounded by peaceful residential streets. Almost all buildings in Purley district centre are are 3 floors high. The tallest building in Purley is 4-5 floors (the red brick building at the southern end of the High Street). This proposal is therefore nearly six times higher than most buildings in Purley and over three times higher than the next tallest building. It will fundamentally and adversely alter the character of the town centre, contrary to Policy. It would overshadow and dominate the whole area. It is of a fundamentally different style and design to the area as well.

The table below lists a number of Polices that are violated by this application. These largely flow from the application clearly not respecting the character of the area, by virtue of being so very much taller and more modern in design than anything else in the locality.  The underlining in the tables below are mine.

Policy Reference Policy Quote Comment
Croydon Local Plan 2018 Policy SP4.6 Tall Buildings “Some locations within the areas listed in SP4.5 [which includes this site via DM15 and then DM42.1] 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.” This policy makes clear that even where a tall building is allowed by detailed polices, such a building must also “respect and enhance local character”. This proposal neither respects nor enhances local character – it is six times higher than most buildings in Purley District centre and over three times higher than the next tallest. It is of a fundamentally different design to the rest of the area. It fundamentally and adversely changes the character of this quiet suburban neighbourhood, violating limb (a) of Policy SP4.6   There is no public realm at all in the application, violating limb (d) of Policy SP4.6


Croydon Local Plan 2018 Policy DM15 Tall Buildings Tall buildings defined as “significantly larger than .. predominant surrounding buildings” (6.152) or “in excess of 6 stories” (6.9)   DM15 states that to ensure that tall buildings “respect and enhance local character” it should be ensured that “Building height … conserves or enhances the significance and setting of the assets of the wider historic environment” (section d) The same comments apply here as above – the proposal is six times higher than most existing buildings in Purley – local character and the wider historic environment is fundamentally and adversely affected, contrary to Policy DM15
Croydon Local Plan 2018 Para 11.156 Purley “As a broad location the main focus of major residential growth will be in and around the [Purley] District Centre with high quality residential development that will respect the existing residential character and local distinctiveness.” The existing residential character of Purley in not respected. The residential properties surrounding Purley town centre are generally 1920s & 1930s two floor houses. Blocks of flats, where they exist, are generally no more than four floors high. At 17 floors of modern design this application does not respect the existing character as required by Para 11.156
London Plan 2016 Policy 3.5B “The design of all new housing developments should enhance the quality of local places, taking into account physical context; local character; density…” This proposal does not enhance the quality of the local place or take into account the physical context – being six times higher than most neighbouring buildings
London Plan 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] This is harmful as it fundamentally changes the character of the area and dominates it   This proposal will adversely affect the local area as laid out above       It does not relate well – It is three to six times higher than surrounding buildings       This proposed building meets this definition so Policy 7.7 and associated paragraphs do apply   This building is standalone, and not part of a cohesive building group, as required by Para 7.27 of the London Plan
NPPF 2018 Para 127 Paragraph 127 of the NPPF states: “Planning policies and decisions should ensure that developments … (c) are sympathetic to local character and history, including the surrounding built environment, while not preventing or discouraging appropriate innovation or change” This proposal is not sympathetic to local character and history, or the surrounding built environment. The proposal is six times taller than most of the rest of Purley and three times higher than the next tallest building. It is a wholly modern design. The character of Purley will be fundamentally and adversely affected by this lone very tall building. The paragraph goes on to say that it should not prevent “appropriate” development, but this development is not appropriate for the reasons laid out in the rest of this table
NPPF 2018 Para 131 “In determining applications, great weight should be given to outstanding or innovative designs  … so long as they fit in with the overall form and layout of their surroundings.” The design of this building is clearly innovative in the context of Purley. But it manifestly does not “fit in with the overall form and layout of their surroundings” being three to six times higher and of modern design

A large number of National (NPPF 2018), London (London Plan 2016, which is currently the in-force plan) and Croydon (Local Plan 2018) policies are clearly violated by this application as laid out above.

There is only one policy weakly in support of the application, which is to be found in the Croydon Local Plan (2018) at DM42.1 (b) as laid out below:

Policy Reference Policy Quote Comment
Croydon Local Plan 2018 Policy DM42.1 (b) “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 somewhere in Purley”

This refers weakly only to the “potential” for an unspecified tall building. The policy erroneously states that building heights are up to 8 floors. They are not. They are almost all 3 floors, with one building at 4/5 floors.

This single policy in support of the application refers weakly to the “potential” for tall building of up to 16 (not 17) stories. This contrasts with the raft of very explicit policies listed in the first table above which all suggest that the application should be refused.

DM42.1 is also expressly subject to DM15 – DM15 itself says that the sites identified within it (through section (a), which refers to policies DM34 to DM49, and thus includes DM42.1) should “respect and enhance the local character”. DM15 also says in section (d) that such proposals must “conserve or enhance the significance and setting of the assets of the wider historic environment,” which this application does not. The whole of DM15 and DM42.1 are also subject to SP4.6, which says (see first entry in the first table above) that sites for tall buildings identified under SP4.5 and its consequential Detailed Polices DM15 and (in this case) DM42.1 must still meet the test of respecting local character. This particular proposal does not respect local character by reason of wholly excessive height and modern design. These higher-level policies in the Croydon Local Plan therefore explicitly over-ride the weak reference to the “potential” for a tall building, contained in the Plan’s lower-level detailed policy DM42.1 (b).

It is clearly a matter of plain fact that the proposal is three to six times taller than any other building in Purley and of a wholly different design style. It is therefore not respecting the character of Puley, it is fundamentally and adversely 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

2. The application has inadequate parking, contrary to the requirements of the NPPF (2018)

Policy Reference Policy Quote Comment
NPPF 2018 Para 105 “If setting local parking standards for residential and non-residential development, policies should take into account ….. d) local car ownership levels” For the 220 flats there are only 37 parking spaces. The Council’s planning report for Committee, paragraph 8.149 admits the development needs 165 car spaces, and clause 8.147 recommends that future residents of the scheme are excluded from residents parking permits.

The intentional and admitted material under-provision of car parking (37 parking spaces instead of the 165 required by the council’s own estimates of car ownership levels) breaches the terms of NPPF paragraph 105 above. It will also cause chaos on roads where there is not a CPZ (Controlled Parking Zone) and on unrestricted parking spaces, as the extra car which have no spaces will seek to park there.

3. The application materially breaches the density limits in the London Plan (2016)

Policy Reference Policy Quote Comment
London Plan 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 This proposal breaks the London Plan’s maximum density guidelines by 16.7% when taken as a whole. The Island site on its own (which includes the 17 floor tower) breaks the maximum density by a staggering 50.2%

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.

4. The site is at material risk of flooding, contrary to the NPPF (2018)

Policy Reference Policy Quote Comment
NPPF 2018 Para 155 “Inappropriate development in areas at risk of flooding should be avoided by directing development away from areas at highest risk (whether existing or future)” The Purley Gyratory (which this site is on) regularly floods due to overflow of the river Bourne. There is a wide body of technical evidence listed below confirming this.

The Level 1 Strategic Flood Risk Assessment for Croydon, Merton, Sutton and Wandsworth (2015) is very clear that Purley town centre, and the Purley Gyratory opposite this site in particular, is at high risk, saying (amongst other things):

“London Borough of Croydon has experienced a number of surface water flood events, the most notable of which was the 20th July 2007, where intense periods of rainfall caused flash floods and the capacity of the existing drainage system to be exceeded in numerous locations across the borough. Purley town centre experienced some of the worst flooding with significant flooding to property and the transport network.”

The Croydon Local Plan (2018) also acknowledges this at para 8.5:

“The Surface Water Management Plan (SWMP) identifies parts of the Borough to be particularly susceptible to surface water flooding, including Brighton Road through Purley … The SFRA identifies significant episodes of surface water flooding at Purley Cross”

(the site faces onto Brighton Road / Purley Cross at its eastern boundary)

The map published on the council’s own website highlights especially high risk to this site (marked in dark blue) and the Purley Gyratory opposite, which has flooded several times in recent years:


Paragraph 155 of the new NPPF therefore means that this application should be rejected.

*                             *                             *

This building will fundamentally and detrimentally change the nature of Purley, and is manifestly out of keeping with the place – being 3x to 6x higher than any other building for some miles and of a different design style to the rest of Purley. This view is shared overwhelmingly by local residents (95% according to my survey of 11,933 local people) and 7 local Residents Associations.  The application contravenes a number of local, London and national planning policies and I urge the Inspector in the strongest terms to reject this application.

Chris Philp MP
18th September, 2019