PWRA Challenges the Council’s Local Plan Review Proposals – now it’s your turn

As you will all be aware Croydon Council started a review of the Local Plan last year. Feedback on the Council’s initial proposals must be made by 20^th January.

The PWRA has been preparing a detailed response to the Council’s proposals and this is attached. As currently drafted we do not see the Council’s proposals as being realistic or credible.

Amongst other areas you will see that we take issue with:

• the housing numbers being proposed in total, and in particular the numbers to come from so called ‘Windfall’ developments (which we know is currently being translated in Croydon as the destruction of family houses and the construction of small blocks of flats with inadequate car parking); with Purley being expected to have a new housing target similar to Central Croydon;
• the lack of focus on redeveloping ‘Brownfield’ sites before new;
• the lack of tangible detail on how the infrastructure to support any level of new housing in the Borough will be delivered.

We have found that we are not alone in having concerns about the proposed housing numbers as independent Planning Inspectors who have been reviewing the overall London Plan, which is also up for review, have also recommended a substantial reduction in Croydon’s housing target numbers!

ACTION: Please make your own views on the Council’s proposals known to them by the 20^th January and feel free to use any of our material to do so.

If you wish to make your voice heard, please email your concerns about the Local Plan and its effect on your immediate area to: LDF@croydon.gov.uk

Read PWRA’s challenge to the Council below

Below is the Purley and Woodcote Residents Association’s response to this round of public consultation on the Croydon Local Plan Partial Review. We have commented widely, as well as specifically about Purley, as many Borough wide proposals in the Local Plan Review impact Purley and its residents, and vice versa.

Input on the Proposed Revised Croydon Local Plan as a Whole

·       Housing Numbers and Plan Timescale: As acknowledged by the Council the Planning Inspectors for the London Plan have reduced the 10 year target for the total number of housing units across all London Boroughs from 245,730 to 119,250. For Croydon, they have reduced the 10 year target from ~30,000 to ~21,000, and, even more dramatically, have reduced the number of these new housing units in Croydon to come from so called ‘Windfall’ developments (currently being translated in Croydon as the destruction of family houses and the construction of blocks of 9 flat with inadequate car parking) from 15,110 to 6,410. It is again acknowledged by the Council that the Inspectors have proposed these reductions to make the London Plan housing targets more realistic and deliverable over a 10 year timeframe. Despite this the proposed Croydon Local Plan revision proposes a target of an additional 25,250 new homes over and above the London Plan (making a total of ~46,000) and over a 20 year timeframe. If one compares the level and accelerating pace of change that has taken place across all aspects society, including such things as the ways that we live and work (for example more home / virtual working, and dramatically more online shopping), and the increased knowledge and understanding that we have (for example of climate change) one will see that trying to construct a Local Plan with a 20 year time horizon is both unrealistic, and potentially dangerous, in setting directions that may be difficult to subsequently alter in the face of change. These anomalies, combined with way it is proposed to deliver the proposed housing unit numbers in the three ‘Strategic Options’, and the other points we will be making, immediately and completely undermine the credibility and realism of the proposals made at this stage of this Local Plan Review process. Therefore, and in answer to the question is posed by Paul Scott in the Foreword to the Local Plan Review documents, we strongly advocate that the Croydon Local Plan should adopt both the 10 year planning horizon and the reduced housing unit numbers as recommended by the Panel of Inspectors for the new London Plan. Indeed review of Section 5 of the ‘Sustainability Appraisal for the Croydon Local Plan review’ suggests that the Council themselves have concerns about delivery of the higher housing provision number (30,000) and in fact would support the lower one (21,000) over a ten period. In this regard it is worth quoting at length from the Council’s own submission to the London Plan Examination in Public, as it begs the question why the Council has chosen to put forward the Strategic Options and housing unit numbers it has done when it clearly has concerns about the credibility and delivery of these:

“… the Council [is] concerned about three key aspects of implementation.  Firstly, small and medium sized builders are delivering in Croydon, however it is questionable whether they have the capacity to deliver the Mayor’s ambitious target. Secondly, the Mayor risks a situation of Planning by Appeal across London due to the lack of Five Year Supply of Housing Land and, therefore, not being able to implement Local Plan and London Plan policies in their entirety and with full weight.  Thirdly, the Council are very concerned that the necessary commensurate sustainable transport and social infrastructure will not be delivered to mitigate the impact of the proposed development, especially when considered over a 20 year period as opposed to the 10 year London Plan period.”  

·       It is also noted from the council’s ‘Statement of Common Ground’ that Croydon is not alone in its concern about the originally proposed draft London Plan housing unit growth numbers, and particularly that for so called ‘Windfall sites’, with our next door neighbour LB Sutton also expressing concern and supporting the reductions recommended by the London Plan Inspectors: ‘LB Sutton considers that the housing target in the draft London Plan for small sites is not based on evidence and is undeliverable. LB Sutton welcomes the findings of the draft London Plan Panel Report’ (Statement of Common Ground P 2).

·       To support any level of growth in the Borough we have reached the point at which additional infrastructure, from basic utilities to such things as schools, medical facilities, police, fire, and public transport, are required. The proposals are very light on tangible proposals to provide these, despite the fact that, as the previous bullet point indicates, the council has its own concerns in this area. Whilst the Councils Development Infrastructure Funding Study is at this stage very high level it seems to suggest that the cost of infrastructure to support the Local Plan growth options is a huge sum in excess of £4 Bn. Unfortunately it is not possible to break this down per Strategic Option as the council / their consultants have chosen to combine Strategic Options 1 and 2 into one combined scenario for their initial costing and have used a different division of the Borough into ‘Zones’ rather than the ‘Places’ used in the Local Plan Partial Review key documentation. Nevertheless the sums of money apparently needed for the new or upgraded infrastructure to support the proposed Local Plan Strategic Options again casts doubt on their realism and credibility.

·       Similarly whilst the statements in the proposals about addressing climate change and protecting green space and the environment are laudable, there is a lack of substance or of tangible proposals, and hence credibility in the documents. The lack of credibility in this area is magnified when compared with the current council administration’s actions. The most recent illustration of this is the putting up for sale land in Grangewood Park (over the Christmas / New Year holiday period resulting in a public outcry which has fortunately now resulted in the sale being called off), and others including the sale of open space at Montpelier Road / Kingsdown Avenue, and the granting of planning consent at Quail Gardens next to Selsdon Wood, against the advice of local residents and national bodies such as the National Trust. All this before one comes to Strategic Option 3 and its proposal to remove land from the Green Belt for development! Even smaller proposals, like making Purley Station a larger Cycling Hub are made without any tangible proposals to improve and make cycle lanes safer in the area, or indeed across the Borough as a whole, beyond broad brush statements in the Themes section of the Local Plan review documents.

·       Statements about protecting conservation areas and respecting local character are again laudable however, as with climate change, there is a lack of tangible proposals. This undermines the credibility of the proposals, especially when again compared with the current council administration’s actions in granting planning permissions for developments totally out of keeping with their surroundings. The latest examples of this being the granting of planning permission for the redevelopment of 59-63 Higher Drive, and 8-10 Grovelands Road.

·       Statements about respecting local character are further undermined by comments throughout the Local Plan review documentation that some ‘Places’, and in particular Purley, will see their current character ‘eroded’, especially with Strategic Option 1. The documentation also refers to areas where there will be ‘moderate’ intensification. Use of such wording, without definition, is disingenuous, to say the least, and in the interests of the transparency that the current council administration promised they should ‘come clean’ and spell out that what it meant by such wording and that a complete change in the nature and character of many ‘Places’ is an inevitable consequence of the Local Plan review proposals being adopted in their current form.

·       All the above points also beg the question why more priority is not being put on (re)developing so-called ‘Brownfield’ sites in this Local Plan Review. Whilst acknowledging that ~5,500 new housing units are currently under construction across the Borough, and the listing of a number of ‘Brownfield’ sites in the Proposed Site Allocation sections of the Review documents, the focus of Review seems to be on developing ‘new’ sites, here including the demolition of existing houses and their re-development into blocks of flats as ‘new’. Whilst it has been something of a ‘political football’ in recent years it seems incredible that more focus and effort is not being put into the (re)developing of so-called ‘Brownfield’ sites before ‘new’ development. Focus on this would have many advantages, including taking the pressure off the need for ‘new’ development in Croydon’s suburbs and the need for reliance on so called ‘Windfall sites’ to deliver the required new housing units, as well as giving more credibility to the statements in the Review documents about preserving local character and tackling climate change.

General Comments on the Strategic Options

·       Option 1 puts the burden of development on Central Croydon (~30%), and the Southern ‘suburbs’ of Croydon, especially Purley, where what will largely be so called ‘Windfall sites’ are expected to deliver ~40% of Croydon’s proposed housing target. Along with the London Plan Inspectors it is hard to see this percentage being delivered.

The option refers to some areas of the Borough changing ‘more’ significantly with this option. This is disingenuous as, as illustrated by the maps in the Local Plan Review documentation, to deliver anything like the housing numbers proposed the ‘suburbs’ targeted, like Purley, will entirely change their character.

Furthermore as this ‘Windfall site’ development will be ‘piecemeal’ the ‘suburbs’ targeted will face years of disruption and such things as poor air quality, dust, dirt, and noise from construction traffic and construction works. Given this it is hard to accept the Local Plan Review documentation where it refers to the maintaining of local character.

A similar point can be made with reference to the statement that locations within an 800 meter radius of public transport will be subject to change. From the ‘Windfall’ or ‘Small Sites’ Evidence Base Croydon Local Plan Partial Review 2019’ document it appears as if a radius has been drawn around public transport ‘hubs’, such as railway stations, and a presumption made that everywhere within that radius can be subject to change, including the minimisation of car parking to be provided with so called ‘windfall site’ development. This is too much of a ‘one size fits all’ approach and ignores practicalities that residents will need to address such as the topography of their surrounding area and its road network (ie it is often not easy, or necessarily safe, to cross a busy road to public transportation).

Such piecemeal development will also make the necessary infrastructure improvements required to support the occupants of the proposed new housing units very difficult to deliver in a timely way to support increased housing units, and probably impossible to manage in a co-ordinated way.

Overall this option seems the least likely to achieve the council’s stated objectives of growth which can improve conditions and facilities for existing communities, provide the most environmentally sustainable growth, help to address climate change effectively, and help to address the Borough’s current environmental challenges. Furthermore the Councils ‘Sustainability Appraisal for the Croydon Local Plan review’ seems to agree and ranks this option as the least favourable overall and across most of the individual categories that make up that appraisal, including, Heritage, Housing, Population and Communities, Climate Change, and Air Quality (Sustainability Appraisal for the Croydon Local Plan review – Pages iii and 43).  In particular the Sustainability Appraisal highlights ‘Population and Communities’, here meaning the provision of social infrastructure such as medical and education, and ‘Housing’, as areas of particular concern with Option 1. For ‘Population and Communities’ the Appraisal concludes that in this area: ‘Option 1 stands out as performing relatively poorly, and it is appropriate to flag a risk of significant negative effects’ (Sustainability Appraisal for the Croydon Local Plan review – Page 40). For ‘Housing’ the Appraisal concludes that in this area: ‘it is considered that despite the potential for rapid delivery, Option 1 performs least strongly in relation to housing. This is because the proposed dispersal of growth between non-strategic sites, many of which are likely to be below ten dwellings in yield or below 0.5ha in size, gives rise to a significant risk of under delivery of affordable housing.  Additionally, there could be a risk that each windfall site effectively comes forward in isolation and does not have regard for the wider need to deliver a range of types and tenures of homes’ (Sustainability Appraisal for the Croydon Local Plan review – Page 36). By contrast Option 2, and even Option 3, are both considered to be able to perform well in this ‘Housing’ category.

·       Option 2 proposes between 9,400 and 12,000 homes on the Purley Way. Having a coherent masterplan for the (re)development of the Purley Way is long overdue. Industry, Retail, and Residential have developed ‘organically’ along the Purley Way and with a transport infrastructure that is wholly inadequate versus demand. This has created an environment that is sub-optimal for all and provides an unattractive, and indeed unhealthy, environment to work, shop and, in particular, live. Acknowledging the potential complexity, a masterplan for the redevelopment of the Purley Way has the potential to drive real beneficial change not just for the Purley Way area, but for the Borough as a whole. Indeed, as is already at least partially recognised by the Council (in the Statement of Common Ground), development of a masterplan for the Purley Way both needs the involvement of our Sutton Council neighbours, and presents the opportunity to deliver benefits (housing, employment, retail) to both boroughs and their inhabitants and visitors, through a holistic and cooperative approach.

·       Looking across the entire length and breadth of the Purley Way the proposed number of homes feels unambitious, and particularly so for the currently proposed 20 year timeframe of this Local Plan review.

Overall this option seems the most likely to achieve the council’s stated objectives of growth which can improve conditions and facilities for existing communities, provide the most environmentally sustainable growth, help to address climate change effectively, and help to address the Borough’s current environmental challenges. Indeed the ‘Sustainability Appraisal for the Croydon Local Plan review’ also favours this option, saying that: ‘The appraisal shows Option 2 (Purley Way) to perform well in respect of the greatest number of objectives, and also to result in significant positive effects in respect of the greatest number of objectives’ (Sustainability Appraisal for the Croydon Local Plan review – Pages iii and 43).

·       Option 3 suggests building around 5,000 homes on the green belt, including next to Mitchley Hill and Rectory Park in Sanderstead. Our green spaces are precious and desperately needed for recreation, a relief from the urban environment, to prevent uninhibited urban sprawl, as well as being productive farming land in many cases. Removing areas from the Green Belt would set a very dangerous precedent, and should not be considered. Considering removing land from the Green Belt would also seem to be contrary to the climate change message this Local Plan partial review is giving.

·       All options propose significant development in Central Croydon with 12,400 to 14,000 new homes proposed over 20 years. High rise development, including for housing, is already well accepted in Central Croydon. Central Croydon has been suffering ‘planning blight’ for a number of years, significantly due to the uncertainty surrounding the Westfield Shopping Centre development, although this is not the only site upon which high rise, high density modern housing would be a significant improvement on the current. An example is the former Post Office sorting office adjacent to East Croydon station, and Croydon College Car Park. Consequently there should be more ambition in the amount of housing proposed for Central Croydon. Whilst his should be the case anyway, in the context of this Local Plan review, it would remove some pressure from the rest of the Borough.

·       Whilst it has been something of a ‘political football’ in recent years, it is indeed surprising that more emphasis is not put on developing so-called ‘brownfield’ sites. These exist in Central Croydon, as indicated in the previous bullet point, and across the Borough as a whole. Some, like the ‘Lidl’ site in South Croydon, have been vacant for many years and their redevelopment for housing could act as a catalyst for the regeneration of the area as well as providing the needed new homes.

·       All of the strategic options envisage the continued demolition of family homes to be replaced with what are generally small blocks of flats, under the euphemistic title of ‘Windfall sites’.

o   In Option 1 40% of the total housing need for the Borough is anticipated to come through this route, with the Purley area expected to be the most affected. However both Options 2 and 3, with their current numbers, still envisage 25% of the Borough’s housing need to come through this route. It is wholly unrealistic to base one of the most significant expected contributors to one’s housing targets on so called ‘Windfall sites’, unless there are other, non-planning related, agendas running here and which are driving this proposal. The Planning Inspectors for the London Plan clearly found the proportion of new housing units in Croydon coming from ‘Windfall sites’ so unrealistic that they reduced the number by more than half!

o   Development of ‘Windfall sites’ will not only be driven by the availability of sites, but also by whether the resulting, generally flat based, developments are attractive to purchasers, when located in suburban areas, as opposed to town centres where they are well accepted. The sales pattern and price reductions for the new developments so far constructed in such suburban locations suggests that they are not overwhelmingly popular (For example in Purley only ~20 flats sold last year, ~97 currently on the market, price reductions of ~£50k being offered), and that this a significant risk is acknowledged in the Local Plan review documents (Strategic Options – p14).

o   Furthermore reliance on ‘Windfall sites’ would make infrastructure planning (medical facilities, public transport, and ‘basic’ services like water, gas and electric) extremely difficult, if not impossible, to plan for.

o   Currently the council is granting planning permissions for the redevelopment of ‘Windfall sites’ with woefully inadequate car-parking provision for the number of flats proposed. The council is consistently ignoring PTAL ratings in granting permissions. The intent of this policy to help tackle climate change by reducing car usage and ownership is laudable, can work, and is accepted, in town centre and city centre locations, where other forms of transport such as public transport and bicycles can compensate, and even improve transportation. This approach is not credible for suburban locations, such as Croydon’s ‘suburbs’, which are hilly and generally do not have access to convenient public transport. The net result of this will be a dramatic increase in roadside car parking which in turn will adversely impact road safety, and in some locations adversely affect valued local facilities, such as child day care and scouts at St Barnabas church (with the development of 59-63 Higher Drive), and the many diverse activities that take place at St Swithin’s Church Hall such as Yoga, Pilates, Dog training, and Classical Indian Dance (with the development of 8-10 Grovelands Road), as well as those wanting to attend Sunday church services. That this will be a consequence is acknowledged in the Local Plan review documentation (Themes – p46).

o   It seems both practically and morally reprehensible, and against the purpose of a Local Plan, especially in the case of Option 1, to be putting forward Local Plan proposals where such very important considerations as we state in our bullet points above, whilst vital for the well-being and social cohesion of the Borough’s population, are not more tangibly addressed and only mentioned in ‘broad brush’ statements.

Purley Specifics (over and above points made above)

·       We support the vision for Purley: ‘An increasingly vibrant Town Centre with improved public services, physical and social infrastructure, supported by the evolution, and on occasions change, of suburban character’ (Places of Croydon pt 2 p 2). Our concerns primarily surround the way it is proposed to achieve this vision.

·       Introductory statements, such as that quoted below, setting out how the vision will be achieved in the existing Purley Town Centre contradict what is already receiving planning consent in and adjacent to the Town Centre, and actually seem a step backwards from what is needed to reinvigorate it: ‘High quality residential development around the Town Centre and close to stations will respect the existing residential character and local distinctiveness‘(Places of Croydon pt 2 p 2).

·       Introductory statements, such as that quoted below, are disingenuous and palpably false versus what is currently being granted planning consent, and certainly would not apply if Strategic Option 1, as currently set out was chosen: ‘New development will respect the existing local character and distinctiveness of Purley……The landscape-first principles of the Webb Estate and Upper Woodcote Village will be preserved and enhanced’ (Places of Croydon pt 2 p 2).

·       All the Strategic Options propose that Purley should have 5,500 to 9,500 new housing units. It is not credible that Purley be targeted with nearly as many new housing units as Central Croydon, especially when the vast majority of these new housing units are expected to come from ‘Windfall sites’ to which the concerns raised in the previous bullet points apply, including that there are other, non-planning related, agendas running here and which are driving this proposal.

·       That such a large proportion of new housing is proposed in Purley seems to be driven by a simplistic methodology (in the ‘Windfall or ‘Small Sites’ Evidence Base Croydon Local Plan Partial Review 2019’) resulting in little more than a ‘chase the numbers game’. By apparently identifying the Purley area as one with the largest number of ‘detached houses on large plots’ de facto Purley becomes the target location for a very significant proportion of the Borough’s proposed total housing unit target. We see this as a ‘lazy’ approach to both developing the Local Plan, and when combined with the amount of new housing which is to come from ‘Windfall sites’, a ‘lazy’ or passive way, of managing growth, rather than an opportunity to put forward an integrated, well researched, and engaging, integrated, and inspiring vision for the development of the Borough and Purley specifically that all residents can take pride in. We say this as:

o   the proposals to improve Purley’s infrastructure in the ‘Places’ document are not tangible or specific enough to be realistic or credible. For example broad statements to improve public transport, cycle routes, and even reconfigure the current gyratory are not backed up by any tangible proposals or indications how and when these might be developed. Given the current council administration’s approach to the granting of planning permissions in and around the Purley area the suspicion that such proposals will simply remain broad brush statements whilst the granting of planning consents for so-called ‘Windfall sites’ continues unchecked is very high.

o   There is no reference to how vital social infrastructure, such as enlarged medical services, or schools, to support the proposed growth will be delivered, or indeed indication how and when proposals to do so will be developed.

o   Similarly there is no reference to how growth might be sequenced to ensure that the physical and social infrastructure of Purley can cope with the proposed growth.

o   Finally there does not seen to have been any analysis as to what people might want / expect as accommodation in Purley (or indeed across the Borough). The ‘one size fits all’ classification of ‘new housing units’ to set targets also drives a ‘numbers game’ which could (and indeed in Purley seems to) result in accommodation being built for which there is not a ‘market’. A more nuanced assessment of housing requirements and expectations per ‘Place’ would result in a more credible proposal which might then indeed respect the local character of Purley.

Whilst it can be said that detail on items such as the above is beyond the scope of a draft Local Plan at this stage, we say that without this, and in the light of the current council administration’s approach to the granting of planning permissions in and around the Purley area, any proposal to further increase the population of Purley is irresponsible and lacks credibility unless such detail is forthcoming.

·       It therefore appears to us that the Council will be allowing developers to bring forward proposals in a piecemeal fashion and that such proposals will then be reviewed and assessed on a piecemeal basis, with no doubt the objective of achieving housing unit target numbers being a significant consideration.

·       Furthermore, and again in common with the wider Local Plan Review documents there is no apparent emphasis on (re)developing ‘Brownfield’ sites in Purley, beyond their reference in the ‘Proposed Site Allocations’ section. There should be tangible actions to (re)develop such sites as the former Sainsbury’s in High Street and the Car Park at 54-58 Whytecliffe Road.

·       Finally we note the request for evidence to enable Local Green Spaces to be protected. We have already provided this at the councils request in 2019. We have not received any feedback. Is this request in the Purley section and at the start of the ‘Places of Croydon’ chapter implying that what has been provided so far is insufficient, and if so in what way(s)?

Conclusion

There is much in the Local Plan Review that is laudable and appropriate to enable Croydon to thrive into the future, whilst recognising the challenges of Climate Change and a growing population. However the proposed housing unit numbers, the 20 year timeframe for the plan, and the Strategic Options proposed are not currently correctly balanced for all the reasons we have stated. Fundamentally there is way too much reliance on so called ‘Windfall site’ developments in Croydon’s southern ‘suburbs’ and especially Purley, insufficient detail on infrastructure improvements required to support growth, insufficient ambition in the proposed housing numbers for Central Croydon and the Purley Way, and a lack of focus on (re)developing ‘Brownfield’ sites. In summary we advocate:

·       That a 10 year timescale and the housing unit numbers recommended by the London Plan Inspectors be adopted, especially in regard to so called ‘Windfall’ sites.

·       That a much more ambitious version of Strategic Options 2 is developed.

·       That in constructing this revised Strategic Option much greater ambition is shown for the provision of new housing units in Central Croydon and Purley Way.

·       That in constructing this revised Strategic Option there is a much stronger focus on how ‘Brownfield’ sites across the Borough can be (re)developed with new housing units, before ‘new’ development is permitted (here including the demolition of existing houses and their re-development into blocks of flats as ‘new’).

·       That greater tangibility is provided on how the infrastructures required to support the revised Strategic Option will be delivered.