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Spatial Planning Service

6th Floor Zone B,

Bernard Weatherill House

8 Mint Walk

Croydon, CR0 1EA                                                                                                                                               16th October 2016

 

Dear Sir or Madam

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

Please find the joint representation from the 4 Coulsdon Residents’ Associations which represent residents from all parts of Coulsdon and Old Coulsdon.

Representatives from our organisations would be happy to speak on our submission.

General

We are in general support of the changes to the local plan contained within, but would wish to make the following comments about Coulsdon Old Coulsdon and Purley.

 

DM 5 District Centres

We consider that it essential that Croydon has a vibrant and viable town centre consisting of good retail, commercial, entertainment and leisure uses for residents of Croydon, visitor and workers. It must also have vibrant and viable District Centres as well as this where the majority of residents live. It is important that policies and investment reflect this and are directed towards these aims and shared among Croydon town centre and the district centres.

To be viable. District centres require adequate commercial and retail outlets, providing employment opportunities along with community facilities such as libraries, medical centres and other community facilities within the district centre with easy access by all.  To this end is important that district centres have good access by walking, cycling, public transport and car. Therefore each district centre must have adequate public car parking that reflect the needs of and viability of the district centre along with improvements to local public transport. We do not believe that DM5 is clear enough on these requirements.

Many outer district centres have to compete for trade with outer districts in other London Boroughs and those across the border in Surrey that have different policies. It is important to take this into consideration as well as the distance from public transport the geography and topography of local areas. A number of areas of Croydon including Crystal Palace, Upper Norwood, Old Coulsdon and Sanderstead are among some of the highest locations in London making walking difficult. We do not believe that the plan set out in DM 31 does this.

 

4 Homes

Mix of Homes by size

4 4.3 “Analysis of the Strategic Housing Market Assessment suggests that approximately 50% of homes should have three or more bedrooms”. We would agree with analysis. However, each part of the borough may differ from the general requirements. We are also pleased to see that this recognises there is also a need for smaller units. We would contend that in areas such as Coulsdon there is a need for more and smaller 2 bedroom accommodation units to enable young people to get on the housing ladder and for older people to down size to.

Houses in Multiple Occupation :  Many roads and communities across Croydon are suffering from the cumulative impact of too many houses in Multiple Occupation. This also confirms there is a need for smaller as well as larger dwellings.  This is a particular problem in areas where larger houses are easily converted to bedsits and studios which have the added problem that as these properties change within the existing buildings the changes go unrecognised until the effects have taken place and the effects are felt by the local community.

The Council should introduce an additional policy into SP2: Homes: That recognises the impact that multiple occupancy has on an area in an unplanned way. This includes the effects on schools, doctors, council services, transport and road congestion.

The Policy should be introduced to limit the numbers, so that existing communities are not overwhelmed by an unplanned increase in population that puts further strain on highway parking, refuse and recycling collections and street cleansing. A new clause could be added to policy SP2.7. Mix of Homes by Size that restricts multiple Occupancy to 25% of properties in any one area.

Although the plan acknowledges the increase in the population over the age of 55 we believe that the plan fails to take into consideration the needs of this increase in the older population. This applies in some parts of the borough where there are high concentrations of older people, neither does it doesn’t reflect the needs of people with disabilities who are able to live independently. 

Therefore, a new policy should be introduced in SP2 that requires provision in all new developments to include some provision for older and disabled people who are able to live independently in all areas of the borough, This would go a long way to maintaining sustainable communities enabling older and disabled people to remain within their communities.

 

Urban Design 6

House extensions

Although we have nothing against house extensions in general. We do have concerns when house extensions are built up to the property boundary line and leave no room for access to the rear garden other than through the house. This has the effect of changing the street scene and turning residential roads made up of detached and semi-detached properties into rows of virtual terraced houses more suitable to town centres and central London rather than suburban London.  This also has a negative effect on the movement of wildlife in our area which consists of badgers, deer, foxes, hedgehogs and other small mammals.

We are of the view that 6.8   spells out the need for this within the plan

6.8 “Additionally a review of the council’s existing Unitary Development Plan, carried out by the Council’s Development Management and Spatial Planning services, identified a need for policies relating to layout, form and design”.

Therefore the council should introduce a policy of restricting house extensions from building up to the property boundary line. To ensure that the street scene does not change by default and local wild life is not unduly affected by the new extensions.

Waste, Refuse and recycling

DM14.2  To ensure existing and future waste can be sustainably and efficiently managed the Council will require a waste management plan for major developments and for developments that are likely to generate large amounts of refuse and recycling. 

We are of the view with the expanding population of Croydon will require additional waste and recycling capacity. Croydon has a limited number of sites across the borough and expansion of existing sites will be is needed. The ability to expand Purley Oaks recycling site will be crucial in order to handle  more recycling and waste..

Public Realm DM 11.9

6.56  We agree that “Historic street furniture such as traditional red telephone boxes, post boxes, ornamental lamp columns, drinking fountains, cattle troughs, monuments and memorials can make a positive contribution to local character by reinforcing a sense of place. Opportunities to retain, restore and incorporate historic street furniture should be taken”. We believe that this is equally important for District Centres and needs to be combined with pubic art which involves the local community.

Policy DM15 Public Art

We strongly support the policy of providing public art in district centres and working with the public and local communities in its themes, designs and locations.

Policy DM 31 Parking

We agree with promoting cycling walking and use of public transport to improve the local environment and reduce pollution in town centres. However, there is a need to take into consideration the geography and topography of local areas as well as the distance from public transport which effect the need to use a car and the need for somewhere to park.  We do not believe that plan set out in DM 31 does this.

The revised London plan of 2016 allows more flexibility in the outer boroughs to increase parking above the standards the council is setting out in these policies in outer suburban and urban areas. The plan should be amended to take this and the local needs more into consideration. 

DM 31 a :  Reduce the impact of car parking in any development located in areas of good public transport accessibility or areas of existing on-street parking stress”.  Our experience is that restricting the amount of parking space in these areas actually increases the stress by adding to the on street parking, when this happens in controlled parking zones it adds to the number of parking permits which now frequently exceed the number of on street parking places available which in turn leads to stress and conflict between neighbours.

10.14 g. “Provide car parking for affordable homes at an average rate not less than 2/3 that of other tenures”.  We agree that occupiers of affordable housing also require car parking spaces. However our experience in the outer parts of the borough is that they require the same parking as that of owner occupied homes, although on average car ownership is 30-60% less than that of owner occupied homes. This does not take into consideration company vehicles and our experience tells us that occupiers of affordable housing are more likely to drive company cars and vans and want to park them near their home.  This can be alleviated by using the same criteria as with owner occupiers for affordable housing.

Table 10.1 The London plan 6.2 is more flexible in outer suburban and urban areas than the council choses to use and there should be no discrimination between owner occupiers and occupiers of affordable housing. Table 10.1 should be amended to take these points of view into account.

SP8  Transport Facilitating Rail and Tram improvement

We support walking, cycling and the use of public transport, but feel the document does not take into account the topography and geography of certain parts of the borough that are situated in hills and valley around Croydon and the difficulty that this causes.  A number of locations such as Crystal Palace, Upper Norwood, Old Coulsdon and Sanderstead are located in some of the highest geographical points in London.

The document fails to recognise that the Mayor of London wishes to take over suburban and Metro train services in South London including Croydon in 2021. The council should support this as a way of improving rail services in the Borough for it residents.

Add  additional 10.39 : The Council  support the London Mayor’s proposal to take over the Southern Metro services in Croydon  and will ensure that the services at all 15 stations in Croydon served by GTR/Southern are transferred to operation by TfL .

Step Free Access to railway stations. The document should include promotion of step free access to stations within the council. At present the only 4 of the 17 stations have compliant step free Access with lifts. Another 5 have non-compliant step free Access which often requires negotiating steep ramps or a long walk around the public highway to get from the booking Office to platforms.

Add an additional Dm33. c

The council will work with DfT, Network Rail and TfL to improve step free access to stations within the borough.

Add an additional DM33. D

Where developments or highway schemes are adjacent or near to railway stations without compliant step free access the council will work with the developers or highways authority to improve step free access at these locations.

An example of this would be: The council supports the inclusion of step free access to Waddon Station in conjunction with TfL’s Fiveways A23/A232 improvement scheme.

Buses :  Bus transport with over 40 individual routes form a large part of public transport in Croydon and this is missing from the document

Add new 10.41 : Encourage Transport for London to provide new or extended bus routes to areas poorly served by existing routes. This would include areas such Upper Norwood, Norbury and in our area Tollers Lane estate in Old Coulsdon which has no bus service and is over half a mile to the nearest bus stop and has no near direct bus service to Coulsdon town centre or stations.  

The NHS is in the process of reorganising health services in Croydon with a greater concentration of   health services at Croydon University Hospital 

Add new 10.41 To encourage Transport for London to ensure all parts of the council have easy access to bus services serving Croydon University Hospital.

Parking 6.4  Add  : All district centres require a public car park of  suitable size to sustain the economy of that centre and the local community.

 

 

Coulsdon DM 39

 

Industrial Ulswater Crescent

Table 4.1 We support maintaining Ulswater Crescent Coulsdon for industrial and warehouse use and excluding other uses as a general principle. This should only be relaxed if an alternative use was needed for the benefit of the local community within Coulsdon.

Cane Hill Park (Site)  Table 11.8 ref no. 60.

Planning permission has been granted for 654 dwelling on this site along with a small amount of commercial development with access from Marlpit Lane and Portnalls Road. We have no objection to the housing development that is taking place on this site. However, we have continually put the case for an exit direct on to the A23 Coulsdon bypass which at the location just north of footpath 744, this is no more than 7 metres away from the development and is a very cost effective option with no visual impact on the surrounding area and would not infringe on Green Belt.

We believe that without an exit onto the bypass the development will have a negative impact on congestion and pollution in the town centre. The developers own traffic assessment suggests that 60% of traffic to and from Cane Hill Park requires access to the A23 north and southbound and not to the town centre and local Roads. In addition since the granting of the original planning permission based on a traffic assessment that was falling traffic in the local area is now rising again this is confirmed by both TfL and DfT reports.

We are of the view that this development is not consistent with policy DM 30 10.6

10.6  “Some development would result in a severe impact on the local transport networks. A severe impact is one which would detract from the economic and environmental regeneration of the council by making Croydon less accessible and a less attractive location in which to develop. Such development will not be permitted. Transport for London and Network Rail will be consulted on planning applications that could result in such an impact on the council”

Lion Green Car Park  Table 11.8 ref no.372.

Since the publication of this report it has become clear that the proposed supermarket development on this site is unlikely to go ahead. This site as a public town centre car park is important for the district centre parking.  The closure of the car park for 6 months in 2015 clearly showed that the district centre of Coulsdon could not function as a viable district centre without a public car park of at least 120 spaces. During this period trade in Coulsdon dropped by between 30% and 50% and two medium sized businesses moved out of the area and two retail units closed.

We believe that this action was not consistent with policy DM5.1  The Council will ensure that the vitality and viability of Croydon Metropolitan Centre and the council’s District and Local Centres is maintained and increased by not permitting new developments or changes of use which would result in a net loss of ground floor7 Class A uses within Main Retail Frontages (unless it relates to the expansion of an existing community use).

Therefore we believe that Lion Green Car park should now be designated for selective mixed use. This could include Housing, a public car park of at least 120 spaces is a must, but retail should be excluded. The area to the west owned by the GLA known as Sovereign House could be used for community use or commercial and/or light industrial use such as a car workshop.

The housing should consist of a mixture of affordable dwellings that are aimed at young people, older people and people with disabilities who are able to live independently.  We believe this would reduce the traffic in the town centre and would not fall foul of DM 30. 10.6.

DM 30 10.6  Some development would result in a severe impact on the local transport networks. A severe impact is one which would detract from the economic and environmental regeneration of the council by making Croydon less accessible and a less attractive location in which to develop. Such development will not be permitted. Transport for London and Network Rail will be consulted on planning applications that could result in such an impact on the council”

As proposed in the original plan The London Loop footpath should be diverted alongside the Iron Railway Embankment at the rear of the Lion Green car park in order that the public can see and appreciate this designated Ancient Monument.

We believe this would comply with 6.149  The London Plan Policy 7.8G states that boroughs should ‘include appropriate policies in their LDFs for identifying, protecting, enhancing and improving access to the historic environment and heritage assets and their settings where appropriate, and to archaeological assets, memorials and historic and natural landscape character within their area.”

Waitrose Brighton Road

Site no. 945. This site is an important part of the existing retail offer in Coulsdon Town centre providing supermarket shopping for the family and car parking for the northern part of the town. Loss of retail and car parking would have a serious detrimental effect on the retail units in the northern part of the town centre.

We believe that this site must remain at least  a retail site at least on the ground floor and the car park must remain part of any retail use. Medical facilities should be situated in other locations in the town centre such as the Calat Centre in Malcolm Road or in any new development on Lion Green road site.

Community Facilities 7

Calat Centre in Malcolm Road  Coulsdon : We are of the view that the existing building which is of good design and is used for community facilities should be retained and developed as a location for town centre community facilities including meeting rooms, halls for hire and a place where local clubs can meet. A new medical facility and a library could also be incorporated. We are of the view that this is in line with the London plan 3.16 in 7.3 and in DM20.1 and should therefore be included in the Coulsdon section.

7.3  The London Plan Policy 3.16 cites the protection and enhancement of social infrastructure which includes community uses and encourages London boroughs to develop policies to protect these uses”.

DM20.1  “The Council will ensure the provision of a network of community facilities, providing essential public services throughout the council by protecting existing community sites that still serve, or have the ability to serve, the needs of the community”.

Historic areas

Table 5.1 We welcome the inclusion of Stoats Nest Village, Chipstead Valley Road (St Dunstan’s Cottages), The Dutch Village (which should include the similarly designed and built houses in Woodplace Lane) and Station Approach Coulsdon in the list of Local Heritage areas.

Croydon Panoramas, Local Designated Views and Landmark DM 18

Views

We believe that The views listed in Table 5.2  from Coulsdon are views that it is essential to include in protected views. These include the view from Woodcote Grove Road of Cane Hill and St. Andrews Church.

The views from Farthing Downs a SSSI owned and managed by the City of London are particularly important as the view not only includes the surrounding local area, but panoramic views of Central Croydon, Central London and Canary Wharf which can all be seen clearly with the naked eye while with a small pair of binoculars it is possible to clearly see beyond central London to Alexander Palace and Hampstead Heath. All should remain as local Designated Views.

In addition the view from Cane Hill Park to Croydon should also be included.

Policy SP4.13 “in which strengthens the protection of and promote improvements to heritage assets and their settings including Croydon Panoramas and Local Designated Landmarks”.

Land Marks SP4

We also support St Andrew’s Church, Woodmansterne Road, Coulsdon as a Landmark, but also feel that Coulsdon Methodist Church in Brighton Road at the northern end of The A23 Coulsdon Bypass should also be added as a local landmark now that the surrounding properties have been demolished and it can be clearly seen from the A23.

Green Grid designations  DM 27

We welcome including in the list of green spaces at the following locations in Coulsdon set out in table 9.1:  Chaldon Way Gardens; Coulsdon Coppice (Bleakfield Shaw); Coulsdon Coppice (North); Coulsdon Coppice (Stonyfield Shaw); Coulsdon Memorial Ground; Scrub Shaw; Land rear of Hillars Heath Road.

Site no. 764 Secondary School Land to the East of Portnalls Road

In table 11.8 it is proposed to build a secondary school on Metropolitan Green Belt. Whilst it is recognised that there is a need for more school places in the vicinity, especially as Cane Hill Park and other developments become fully occupied, we do have concerns that this will be at the expense of Green Belt. To build a school at this site would not preserve the openness of the Green Belt and its proposed location would destroy some of the views from Farthing Downs This would be would be in direct conflict with paragraph 9.17, page 109, “development will not be permitted if it would harm their visual amenity”.

In addition a considerable part of the land has already been given over to Barratt Homes for the development of Cane Hill Park and any development for a school would require further intrusion into green belt beyond that shown in the council’s plan. We are of the view that this use does not comply with policy SP7.2 which looks to protect and safeguard the extent of the council’s Metropolitan Green Belt. Policy DM27.1, DM27.2 and DM27.3 also protect the openness of the Metropolitan Green Belt. Furthermore, within the policy framework on the green grid there is no mention of building schools within the Metropolitan Green Belt.

This site is not served by any public transport and is over 1 kilometre from the nearest bus stop at the bottom of Portnalls Road in Chipstead Valley Road near Smitham School.

Without an exit from Cane Hill Park on to the A23 Coulsdon Bypass there would not be adequate capacity on local roads to take the increase in traffic that a new secondary school would create. We believe the present proposal conflicts with DM 30 10.6

“Some development would result in a severe impact on the local transport networks. A severe impact is one which would detract from the economic and environmental regeneration of the council by making Croydon less accessible and a less attractive location in which to develop. Such development will not be permitted. Transport for London and Network Rail will be consulted on planning applications that could result in such an impact on the council”.

Therefore, the proposal for this site has not been positively prepared, is not justified or effective and is not consistent with national policy. Alternative sites should be considered. There is room at the southern end of the Cane Hill site for a smaller school or primary school with entry from theA23 or from Cane Hill via the A23 Coulsdon Bypass rather than Portnalls Road.

 

Policy DM 44 Purley

 

Community and Leisure facilities

The addition of a swimming pool at Purley Leisure Centre, site 30 Table 11.13, is to be welcomed as a swimming pool is an essential requirement for the south of the borough.  We would like to see this strengthened so that any replacement pool is both a public pool and of at least the equivalent size to the existing 25metre pool. Without this commitment 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”.

Purley Town Centre

We object to the introduction of policy DM44.1 a :  “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 would not only be out of character and completely alter the landscape of the district centre.  This would also conflict with 1.b “Reinforce the continuous building line which responds to the street layout and include ground floor active frontages ; Reinforce the continuous building line which responds to the street layout and include ground floor active frontages”; It would also seem to conflict with 6 Roofscapes :

6.9  “The existing policy review identified a need for a roofscape policy that acknowledges the visual contribution roof-forms make and the need to provide guidance on the way in which the transition between new and old developments are addressed. Guidance for roof-form (roofscape) has not been included within the National Planning Policy Framework or the Croydon Local Plan: Strategic Policies”.

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.

Travellers Purley Oaks and recycling

We 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 council.

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 recycling and as only a small number of sites have been designated across  Croydon and the other three south London boroughs for waste expansion. This site is need for expansion of recycling facilities to cater for the increase in population in Croydon.

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 is not consistent with national policy or the needs of Croydon.

Please contact us if you require any more information. A Representative from our organisations would be happy to speak and participate in the oral Examination in public.

 

Yours faithfully

 

Charles King                   Rita Barfoot                      Diane Herne                       Janet Stollery

Chair: East Coulsdon RA: Chair: Coulsdon West RA Chair: Hartley& District RA Chair: Old Coulsdon RA

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