The closing date for comments on the Croydon Local Plan (CLP) is October 10. The CLP document is extremely long/complex and it has taken an immense amount of work to develop the PWRA response, which has now been submitted to the council.
To make it easier for individual residents to respond the attached may make the process easier. I would strongly urge any resident to provide their views on the local plan. In bold type at the bottom of the suggested response are the council’s parameters and guidelines on how the response can be submitted and the format required (which the PWRA’s suggested response follows).
As a Purley resident I write with my comments on the Council’s closing consultation on the final Croydon Local Plan (CLP) draft. My comments are only on the Main Modifications resulting from the Independent Inspector’s recent CLP review.
I believe that there are four items affecting the Purley area in the Main Modifications in the Detailed Proposals (MMD) which are of concern. These are individually listed below by page number and MMD reference. The references are not comprehensive, given that a particular issue is likely to be mentioned in several contexts, including strategic policies. The PWRA comments concern:-
Page 17: Delete Local Green Space designation across the board [MMD86]
I am entirely in agreement with the need for the appropriate designation to be given to the borough’s green spaces to provide them with optimum protection against future development. However I am concerned that the move to remove the current Local Green Space designation across the board and substitute it with the Metropolitan Open Land designation is the wrong approach.
While the Metropolitan Open Land designation may provide better protection for some of the borough’s open spaces there are other open spaces within the borough which will be better protected by the current Local Green Space or another suitable protective designation.
As such I request that the council individually examines every one of the borough’s open spaces to ensure that they are each appropriately designated to provide the optimum level of protection against future development.
Page 37 Back land/Garden Development Policies has been deleted and replaced by DM11 (p75 etc) plus Place-specific in Appendix 5 [MMD4]: I believe that this will result in a considerable dilution of control of back land/garden development which is provided by the current specific policy. The proposed replacement, with its mass of general statements on character, intensification etc, all would be subject to case by case interpretation – and does not provide anything like the current level of control on back land/garden development.
As such I ask that the council rethinks this proposal which will not provide the current level of control on back land/garden development. This is not the time for lowering standards in this important area.
Page 73 etc: Design & Local Character [MMD 24 – 27]
The council states that, “The need to deliver 32,880 homes does not outweigh the need to respect the local character, and amenity and to protect biodiversity”.
However I am concerned that the entirely sensible sentiments of the above statement could be readily over-ruled by “focussed Intensification” and place-specific policies. This also needs to take account of the fact that the term “local” may, depending upon circumstances, refer to a range of different contexts, from “Place” to individual street. The Association believes that there will be a considerable loss of protection in Local Character with the resulting drive towards consistent character.
As such I ask that the council that any proposed development which is incompatible with or damaging to Local Character should be refused planning permission.
There is no need for a Consistent character across the borough. It is very important that if the London Borough of Croydon is to become an ever more vibrant and individual place to live/work then the local character and diversity of individual areas must be retained and developed, rather than subsumed into a uniform, lowest standard denominator.
Page 92 6.62B Flood Risk [MMD 54]
I believe that it suggests to developers that they need to worry less about flood risk. As developing weather trends have shown the borough is subject to ever more frequent bouts of heavy to torrential rain. Across the borough – particularly in Purley – flooding is now common as Croydon’s antiquated and less than optimally maintained drainage systems are overwhelmed.
In Purley this flooding is often extremely serious with today’s level of housing, without the major increase in housing numbers come as part of the local plan.
As such I ask that the council ensures that proposed developments in areas of high flood risk have to ensure that they are designed to provide the optimum level of flood protection for both their inhabitants and the buildings themselves. And, the adverse effects of any proposed development on sites of high flood risk on neighbouring buildings must also be considered as part of the planning process.
As the current local plan is written there is no such proviso for this.
Please note that you can comment on the Croydon Local Plan as follows:
- Emailing firstname.lastname@example.org
- Completing the representation form (which is available at libraries) and emailing it to email@example.com or posting it to Spatial Planning Service, 6th Floor Zone B, Bernard Weatherill House, 8 Mint Walk, Croydon, CR0 1EA.
To be duly made the comments must:
- Be received by the Council between 29 August and 10 October 2017 (inclusive);
- Include a name and either an e-mail or postal address all of which must be legible;
- Not contain offensive or derogatory language; and
- Be related only to the Main Modifications to the Croydon Local Plan: Strategic Policies – Partial Review (Proposed Submission) or the Main Modifications to the Detailed Policies and Proposals (Proposed Submission).
Croydon Council will acknowledge receipt of your representation(s) as soon as possible. Please note that representations are not confidential, including your name and organisation and will be made publicly available. The addresses and contact details of representations from individuals will not be published on the website or any other public place. You are advised to keep a copy of the representation(s) you submit.