Saturday October 31, 2020
  • Site last updated at 1:13am on Thursday 22nd October 2020.

We have discovered that a planning application was submitted on 21 August 2019 which seeks to demolish 8 Coulsdon Road (pictured) and replace it with 6 apartments, facing onto Coulsdon Road, and 2 houses which will face on to Petersfield Crescent.

You will of course be aware of Another planning application to replace 2 Coulsdon Road with 9 apartments.

A local resident has taken a great deal of time to compile the following very comprehensive information concerning the planning application and has given us permission to include their findings below:

It is important to note that although the address of the existing property is on Coulsdon Road, the two 4 storey semi-detached houses in the proposed development front onto Petersfield Crescent, which is a short residential road of only 16 single occupancy dwellings that are much sought-after family homes with (mostly substantial) gardens.

Note: the applicant listed in section 25 is not the owner of the property according to Title Register SY135436 at HM Land Registry.


  1. Planning Policies
  • The Croydon Local Plan 2018 (‘CLP’) emphasizes the need for Croydon to “evolve sustainably”. It refers to suburban areas of “evolution without significant change” (CLP figure 6.4).  The Place-specific policy for Coulsdon is set out in DM37 and sections 11.63 through 11.74 of the CLP. CLP 11.75 asserts that much of Coulsdon’s growth potential “is concentrated in the Cane Hill area”.
  • According to CLP 11.71, under the heading “General character”, Coulsdon’s “predominant residential characters” comprise a mix of detached and semi-detached houses and an estate of ‘compact’ houses. Blocks of flats are not mentioned at all, and are therefore by definition out of character for the area. Since the issue of the 2018 CLP, blocks of flat have been erected on Coulsdon’s “proposal sites” (CLP table 11.5 and Appendix 7) as well as on brownfield sites around Coulsdon Town Station. These major developments around the District Centre are important because they meet new housing targets and provide significant levels of affordable housing in accordance with the strategic plan. Such major developments close to the District Centre do not, however, set a precedent for blocks of flats in Coulsdon’s “residential… tree-lined streets” in areas outside the District Centre (CLP 11.66).
  • Planning applications which seek permission to demolish family homes and build blocks of flats go against DM37. The overarching policy in Coulsdon’s suburban residential roads is “evolution without significant change” (CLP figure 6.4).
  • According to CLP 11.64, Coulsdon is an area of “moderate residential growth” where “residential development will respect the existing character and local distinctiveness”. In the neighbourhood containing the two Coulsdon Road sites in the current proposal and the undecided proposal 19/03003/FUL, more than doubling the number of homes and almost tripling the number of residents is not ‘moderate residential growth’, nor is it ‘evolution without significant change’. Putting 3 and 4 storey buildings where there are currently only one- and two-storey buildings does not constitute ‘respecting the existing character and local distinctiveness’.
  • Suburban Croydon homes are being targeted by developers (who are not even local businesses) because adjoining local authorities do not permit family homes to be demolished and replaced with blocks of flats.
  • In the terms set out in the CLP this application is both a “small / minor residential development” and a “proposed development in a garden”. Applicable strategies are therefore SP6, DM10, DM13, DM16, DM23, DM24, DM25, DM27, DM28, DM29 and DM30.
  • 1 states that “the council will take into account cumulative impact”. This application cannot therefore be viewed in isolation and must be considered alongside application 19/03003/FUL (2 Coulsdon Road). In fact, it should ideally be considered alongside all proposals to demolish homes and replace them with blocks of flats and all proposals for backland developments in the Coulsdon wards.
  • If the planning committee persists with its policy of approving overdevelopment in the south of the borough, the demands on local infrastructure will soon reach breaking point, particularly in the areas of health, transport and education, where the current systems are already under pressure. Cane Hill and other developments around Coulsdon Town rail station have already negatively impacted on amenities in Coulsdon, with a 15% uplift in the number of households without concomitant changes to local infrastructure. Anyone who actually lives in this area would know how difficult it is already to get an appointment with the doctor or dentist, get on a train at peak times, or get your child into a local school.
  • In 2018, applications for the 216 year 7 places at Woodcote High School totalled 1,113, with a furthest distance of 1.6 miles (anyone living in Cane Hill Park falls outside this ‘catchment area’ but families in the developments around Coulsdown Town station will increase these figures). Applications to the other Coulsdon secondary school, Oasis Academy, totalled 581 for 180 places, with a furthest distance of 2.8 miles (these figures will only increase as the families in the almost 700 homes in Cane Hill Park are factored in). In Purley the situation is even worse with only pupils within 1 mile getting a place at Riddlesdown. The school system in the south of the borough, where on average there are more than 5 applicants for every secondary school place, cannot support this level of overdevelopment. Overdevelopment of this nature is therefore in direct contravention of the CLP strategy to “evolve sustainably”.
  • By proposing 8 units, the developer is looking to maximise his own profit without the need to comply with a number of conditions set out in Croydon’s strategic plan, including the need to deliver affordable housing (CLP SP2.4). There is no benefit to the community in this proposed development. It is surprising that the Labour councillors are willing to support such overt capitalist greed.
  • Policy DM10.6 states that “the Council will support proposals for developments that ensure that…they do not result in direct overlooking of private outdoor space… within 10m”. The plans misrepresent the shape, size aspect and location of buildings at 16 Petersfield Crescent, but the tight geometry of the 8 Coulsdon Road site means that there will be significant overlooking within a distance to boundary of less than 2m. The patio of 10 Coulsdon Road will also be overlooked by the block of flats, with a distance to boundary of less than 1.5m (see also section 3).
  • 8 states that “the Council will require proposals to …retain existing trees and vegetation including natural habitats”. This proposal decimates the existing mature garden (see also section 8).
  • DM16 sets out the requirement to “consider health and wellbeing during the design of a development”. Developments with subterranean and roofspace rooms cannot possibly be in the spirit of this policy. The developer needs the buildings to be 4 storeys to make a profit, but has probably been warned in pre-planning meetings that 4 storeys above ground will never get approved in this area, and seeks to resolve this quandary by compromising the health and wellbeing of future occupants. It is not clear how the outdoor spaces will get ‘excellent’ levels of daylight (as claimed in the design and access statement) given the shadow cast by 4 storey buildings.
  • DM25 deals with sustainable drainage. The flood risk assessment concludes that this proposal needs further work (see also section 7).
  • DM27 addresses the importance of protecting and enhancing our biodiversity. Back gardens are included in the list of habitats that provide “important support for the borough’s biodiversity” (CLP 9.22). By overdeveloping existing garden land, this proposal goes against DM27 (see also section 8).
  • Croydon Council declared a climate emergency in July 2019. The continued approval of proposals to build on suburban garden land will impede the achievement of carbon neutrality by 2030. There are plenty of other “suitable sites” that will support growth in the borough (CLP 9.32). The council should adopt a ‘brownfield first’ strategy.
  • DM28 relates to trees and asserts that “the Council will seek to protect and enhance the borough’s woodlands, trees and hedgerows”. The approval of planning proposals that decimate an existing mature garden does not support this objective. The council has been crowing about its plan to plant 3,500 new trees yet its planning committee continues to support the removal of existing mature trees, shrubs and hedges (see also section 8). Perhaps all trees over 30 years old need a TPO in this borough? Planting a sapling doesn’t compensate for the removal of an old tree that supports a multitude of wildlife habitats.
  • DM30 governs the requirements for car and cycle parking and refers to the London Plan Table 6.2. This proposal does not meet those requirements (see also section 6).
  1. Loss of light or overshadowing
  • 4-storey buildings on an elevated position in relation to Petersfield Crescent will inevitably lead to a loss of light for neighbouring properties. The sun rises behind the proposed buildings, so houses on the opposite side of Petersfield Crescent will be in shadow for more of the day than at present, since the shadow created by the existing bungalow does not extend beyond its own garden.
  • Due to the sun’s trajectory in relation to the proposed buildings, the garden at 6 Coulsdon Road in particular will suffer from loss of light. In the winter months the sun will probably not climb high enough to reach this garden at all, even at its apex.
  1. Overlooking or loss of privacy
  • 4-storey buildings on an elevated position will inevitably lead to a loss of privacy for the occupants of neighbouring properties, particularly given that the existing building is a bungalow.
  • Differences in levels between neighbouring properties often create privacy issues, and the proposal to excavate and level off the site at different levels to its neighbours will undoubtedly do so.
  • The 4-storey block of flats will tower over its lower-level neighbour at 6 Coulsdon Road.
  • The two 4-storey semi-detached houses will overlook nearby properties on Petersfield Crescent. In particular, there will be a significant loss of privacy for no. 16, whose size, shape, position and aspect is misrepresented in the CGI street elevations and other plans. The landscape plan needs to correct the misrepresentation and show the separation distances to 16 Petersfield Crescent.
  • The private outdoor spaces of 16 Petersfield Crescent and 10 Coulsdon Road will be substantially overlooked.
  1. Visual appearance
  • There are no blocks of flats or 4-storey houses in the vicinity. This residential neighbourhood consist of one-storey and two-storey homes.
  • The 4 storey block of flats is very large and overbearing, particularly as it is built on an elevated position on Coulsdon Road, which slopes sharply downwards towards Petersfield Crescent.
  • The two 4 storey houses, although planned to be on a lower position on the plot, will still be overbearing and out of scale to the neighbouring properties.
  • Four storeys give the narrow semi-detached properties a townhouse look, which will appear cramped and incongruous with the prevailing streetscape.
  • The predominantly brick buildings do not accord with the “local distinctiveness”; the vast majority of homes in this area are traditional 1930s buildings, often mock Tudor, but always white rendered with pitched terracotta clay roofing. The odd brick building does exist in the neighbourhood, but current developments should not seek to repeat or proliferate the mistakes of past developments.
  1. Layout and density of buildings
  • The application has incorrect data in section 16. The proposal is to replace 1 residential property with 8 residential properties.
  • Replacing a solitary one-storey dwelling with a 6 unit 4-storey block of flats plus a further two 4-storey houses constitutes a massive overdevelopment of this small site, with a significant loss of garden land.
  • The CGI elevations and plans for the two houses fronting Petersfield Crescent do not accurately reflect the size, shape, aspect and layout of the neighbouring property at 16 Petersfield Crescent, nor the boundaries with it. On Petersfield Crescent the street elevation should show an overlap, the neighbouring properties would not sit neatly alongside each other as shown in the CGI elevations submitted (see marked up photo at Appendix 1).
  • The plans do not appear to reflect accurately the irregular shape of the site at 8 Coulsdon Road. There is a note on the design regarding the need to take accurate measurements before work commences. A cursory look at this long and narrow plot of land (in person or using Google Maps satellite data) reveals boundaries that are not straight and a width that varies along the length of the plot. Accurate measurements should be taken before any decision is taken on the planning application since there is a significant doubt as to the feasibility of the current proposal.
  • According to Thames Water, a sewer passes across the middle of the garden of 8 Coulsdon Road; there is a manhole behind the garage at 16 Petersfield Crescent and a manhole in the middle of Petersfield Crescent near the garage to 6 Coulsdon Road – drawing a line between these 2 points cuts diagonally across the footprint of the two semi-detached houses (see Appendix 2). It is not clear how the developer can excavate in order to accommodate the two 4 storey semi-detached houses (especially given the proposed changes to existing ground levels) without disturbing the sewer. The house at 16 Petersfield Crescent had to be re-sited on its plot due to the location of the sewer. There is no evidence of consultation with Thames Water.
  • The proposed development is obtrusive and overbearing due to its elevated position with respect to neighbouring properties (see marked up photo at Appendix 3).
  • Any development in this neighbourhood should respect the domestic scale of the nearby buildings. The block of flats is out of scale in this area of single occupancy homes.  The two 4-storey houses are out of scale in this area of one and two storey homes. The “local distinctiveness” (CLP 11.64) of this neighbourhood is for pairs of semi-detached homes across a wide plot; some have detached garages although many homes have been extended to incorporate the footprint of the garage.
  • The height and bulk of the proposed buildings is totally inappropriate for this neighbourhood. Due to the long and narrow nature of the site, the developer has had no alternative but to increase the height to 4 storeys to accommodate sufficient units of a certain size in order to meet the strategic target set out in CLP 2.7 (30% with 3 or more bedrooms) as well as maximise his own profit. There would be no profit in replacing the existing bungalow with a 4- or 5-bedroomed house with landscaped garden, which would be more appropriate to the local character and would provide a much sought-after large family home.
  • The overdevelopment of the plot leaves very little outdoor space, particularly for the two 8 person family homes. In addition, DM10.8 stipulates that proposals must “provide spaces that are visually attractive… and provide a stimulating environment”. A square of grass with a rectangle of paving for each of the two semis does not appear to meet this requirement.
  • DM4 and Table 6.2 establish the minimum private amenity space for all flatted developments. Flats 3 and 5 in the current proposal do not appear to have any private amenity space.
  • The balconies to flats 2 and 4 are a poor attempt by the developer to meet the minimum requirements for outdoor amenity space without actually providing the requisite “high quality design” specified in DM10. Two small balconies will be particularly cramped for wheelchair users. In addition, the sunken north-east facing courtyard for flat 1 will offer scant daylight to the subterranean bedroom. It will be interesting to see what plants would grow in this environment.
  • 4 states that “all flatted developments… must provide a minimum of 10m2 per child of new play space”. There are no measurements for the proposed play area within the 71m2 communal grassed amenity area but it looks very small. It should be noted that there is no park with greenspace and play facilities within a 20 minute walk (at adult pace!); both of the closest parks would necessitate a steep climb either there or back. Parents with young children would inevitably end up driving, leading to more cars for which there are no parking spaces and a greater traffic flow than estimated in the transport note (see section 6).
  • 5 states that “proposals for new flatted development … will also need to incorporate high quality communal outdoor amenity space that is designed to be flexible, multifunctional, accessible and inclusive.” It is not clear how the wheelchair users would access the communal outdoor space, as level access is only available at the lower ground level (i.e. from flat 1). It appears that any wheelchair-bound occupant of flat 3 will not benefit from the enjoyment of any outdoor space (other than the parking or refuse storage areas).
  • Accessibility for wheelchair users has no doubt been encouraged by the council in pre-planning meetings in order to meet certain targets, but realistically the hilly nature of the area means that on the private market the proposed development is unlikely to appeal to wheelchair users. I have personal experience of wheelchair use in this area and getting around requires something close to a superhuman effort (or a car!).
  • While the 2 one person flats do (just) meet the minimum NDDS GIA requirement, there does not appear to be the requisite 1m2 of built-in storage. There must be serious doubts as to the marketability of these cramped studio flats. They are unlikely to appeal to downsizers from this area who are used to a decent sized house and garden. In addition, a 2019 Civitas study noted “a collapse in single living” among young people. Perhaps the council is hoping that they remain unsold and can be commandeered as affordable housing?
  • The NDSS do not cater for 4-storey buildings (which in itself speaks volumes) but the 30m2 open plan kitchen / living /dining areas of the 2 semi-detached houses look cramped. These are designed as family homes for 8 people but it doesn’t look like the whole family can actually dine or relax together. A much better design would have been for 3 bedroomed properties with separate living and dining areas on 2 floors, but this would not have provided a sop to the council in terms of wheelchair accessibility.
  • Problems with surface water run-off in this hilly area have intensified recently, due to increasingly extreme weather patterns. The flood risk assessment recommends the development of a sustainable drainage strategy; this should be carried out before a planning decision is made rather than set as a planning condition. One of the houses on Petersfield Crescent had to place a line of sand bags along its driveway as a flood barrier – in August!
  • To my certain knowledge there have been 4 sewerage blockages on Petersfield Crescent in the last 6-12 months (the shared drains converge in my garden). I’m not sure why the Thames Water statistics in the flood risk assessment do not reflect this, since Thames Water attended two of these events (the others were resolved privately). Even if the flats on the Coulsdon Road frontage join the sewer on Coulsdon Road, the two 4-bedroomed semis would tee into the sewer that runs through my property. The flood risk assessment states that “climate change is anticipated to increase the potential risk from sewer flooding”. I can only conclude that the current waste management system can cope with the addition of 16 residents, which would contravene the requirements of SP6.6.
  • There is another outstanding planning application for a neighbouring property on Coulsdon Road (19/03003/FUL) which could bring a further 17-31 residents, in addition to the 14-29 possible residents from this application. If both went ahead this would constitute an almost 300% increase in the population of this neighbourhood.
  • The two current applications for properties 3 doors from each other (19/03003/FUL and 19/03965/FUL) must be considered holistically, not as separate applications, so that the council can consider the “cumulative impact” in accordance with DM10.
  • The impact of the proposed developments on the substantially green neighbourhood can be seen in the marked up satellite view in Appendix 4.
  1. Traffic generation, highway safety or adequacy of parking
  • The entry / exit point of the Coulsdon Road plot will have poor visibility on a busy road that is a bus route at a point close to 2 difficult junctions, which raises significant highway safety concerns. Anyone taking advantage of the proposed cycle rack would be at high risk of injury. The visibility at these junctions is already poor due to the local topography of hills and bends. According to existing Coulsdon Road residents, accidents on this stretch are unfortunately a frequent occurrence.
  • DM30 governs the requirements for car and cycle parking and refers to the London Plan Table 6.2. The developer’s assertion that the site has a good PTAL score is misleading; on a scale of 0 to 6b (8 grades), 2 is average at best. A PTAL score of 2 in suburban areas would indicate a need for 1.5 parking spaces per unit (per London Plan) – for the block of flats alone this equates to 9 spaces. There is therefore a shortfall of 7 spaces.
  • In addition, DM30 sets a requirement for all parking spaces to “enable the future provision of electric charging points” with 20% of spaces to have an actual charging point. The shortfall in parking spaces means that this requirement is not being met either.
  • The inadequate parking for the 6 flats (likely occupancy of 10-15 additional residents), and the tight geometry and steady traffic on Coulsdon Road on this stretch is most likely to result in overspill parking on Petersfield Crescent, an important access road for several neighbouring roads.
  • The provision of cycle racks at the block of flats is a token nod to ecological issues and the Mayor of London’s proposed new plan. It is naïve to expect future residents to forgo car ownership just because there’s a cycle rack; there is no safe cycling infrastructure on local roads and the hilly topography precludes cycling by anyone other than the super fit (there are unlikely to be 10 of these among the max. 15 residents).
  • DM30 requires that “cycle parking is designed so that it is secure and can also be used for parking for mobility scooters and motor cycles”. The proposed cycle racks do not meet this requirement. Given the hilly locality, residents are more likely to have mobility scooters or motor cycles than cycles.
  • The key fact is that more than two thirds of Croydon households have at least one car (per RAC Foundation - 2011 statistics!) and logically the incidence of car ownership will be higher further away from Croydon town centre. In the nearby Reigate and Banstead local authority area – arguably a better match for this residential neighbourhood – car ownership was close to 90% in 2011 and will have increased since.  Most of the households in this area appear to have 1 or 2 cars.
  • Off-road parking for 2 cars is unlikely to be sufficient for the two 4-bedroomed houses. Most households occupied by families in this area have 2 or more cars. Larger family homes such as the 4 bedroom semis are more likely to be occupied by young adults, particularly as the incidence of 20-34 year olds living with their parents is steadily increasing, particularly in the London area (per Civitas study of Office of National Statistics data). More young adults = more cars.
  • The transport note puts the 8 Coulsdon Road site in the historic Coulsdon East ward. The Council’s website ( shows that it is now in Old Coulsdon ward. Petersfield Crescent properties are split between Old Coulsdon and Coulsdon Town wards.
  • In terms of schooling, the nearest primary schools are Beaumont, Byron and Woodcote – Smitham (referenced in the transport note) is irrelevant. There’s no direct public transport to Beaumont and Woodcote, reinforcing the likelihood that family homes will be occupied by car drivers.
  • The transport note’s assumption that owners of the Petersfield Crescent semis would reverse into the driveway is flawed. The majority of owners would drive in and reverse out (the cars are even pictured front end to the house on the plans!). Reversing onto Petersfield Crescent is unlikely to be trouble-free if both the proposed applications affecting this short stretch of road (19/03003/FUL and 19/03965/FUL) are approved. The increase in on-street parking caused by the considerable growth in the number of residents will inevitably restrict visibility and compromise highway safety.  Although Petersfield Crescent currently only has 16 houses, it also represents an important thoroughfare for access to neighbouring roads.
  • The shared driveway for the 2 houses could result in friction between the occupants. Will ownership of the parking spaces be clearly defined? Who is responsible for maintenance?
  • If the proposed development of 2 Coulsdon Road (19/03003/FUL) is approved, there will be additional dropped kerbs on Petersfield Crescent which will restrict the available street parking and which have not been taken into account in the transport note. Petersfield Crescent will inevitably become more congested and additional parked cars will hinder the flow of traffic.
  • A parking survey conducted between the hours of 00:30 and 05:30 may be the current industry standard (and would undoubtedly have been relevant in the past) but it is totally inappropriate in our current 24x7 society with its more flexible patterns of working, shopping and socialising. In particular, people who work night shifts (or shifts that start very early or finish very late) are more likely to be car drivers given the poor local transport options at night (when the PTAL would drop to 0). In addition, a night survey does not take into account the increase in daytime parking associated with the nearby rail station. Whatever the statistics disgorged by the parking survey, the reality is that, in this sort of neighbourhood, people expect to be able to park outside their own homes at all times; that’s part of the appeal of such a neighbourhood where most houses have a wide frontage and many of the driveways are too steep for parking.  This is particularly important for those with impaired mobility (4 of the units are wheelchair-friendly), those with young children (5 of the units are aimed at families) and the elderly (it is assumed the 3 one-bedroomed flats are aimed at downsizers). A sudden marked increase in the local population will therefore inevitably affect the parking situation for existing residents. It is disingenuous to provide statistics attempting to prove that it will not, and particularly inaccurate to include in the data a stretch of road that even the consultants acknowledge nobody would park on!
  • Surely statistics from the 2011 Census have to be considered as so out-of-date as to be meaningless to current decision-making given the exponential nature of local population growth.
  • The transport note suggests that there are good amenities within walking distance but does not take into account the topography of the area. Anyone with reduced mobility or young children (the most likely occupants of the proposed properties) would struggle to walk up from the shops with much more than a single light shopping bag. The reality is that most local residents drive to a supermarket or take advantage of home delivery (but there’ll be nowhere for the delivery trucks to stop without causing problems). Additionally, anyone in a wheelchair attempting to turn the corner from Coulsdon Road onto Petersfield Crescent to access the shops has to negotiate a steep camber with no dropped kerbs or tactile paving and would likely find themselves in a heap on the ground.
  1. Noise, smells and disturbance resulting from use
  • Increasing the number of dwellings on both Coulsdon Road and Petersfield Crescent to such a considerable extent will inevitably result in increased noise and disturbance to the neighbouring properties.
  • The proposed 1100 litre recycling bin for the block of flats is insufficient. Croydon has seen a successful and significant increase to its recycling rate following the recent changes to household waste collection (Your Croydon, Sept 2019). There should be a minimum capacity for 2 x 240 litres per unit (requiring three 1100 litre bins). The current waste proposals will either lead to decreased recycling rates or result in unsanitary refuse overspills which will be targeted by foxes and rats.
  • The proposed refuse and recycling storage areas for the 2 large semis is insufficient. There needs to be space for 2 large 240 litre bins for recycling, 1 180 litre bin for general waste and a 23 litre food caddy for each property. There should also be storage for a 240 litre green waste bin unless it is proposed that the management company would maintain the grounds to the houses as well as the flats.
  • 1 specifies the need for “covered facilities…behind the building line” in cases where refuse and recycling facilities cannot be integrated within the building envelope (as here). The proposal does not meet this requirement.
  • As mentioned in section 5, there has already been a marked increase in sewerage problems in this neighbourhood. Hardly any problems in the first 20 years I lived here, but at least 4 in the last 6 to 12 months. The smell of raw sewage is already noticeable on the corner of Coulsdon Road and Petersfield Crescent. Such a significant increase in the homes and residents will exacerbate the existing problems.
  1. Loss of trees and conservation issues
  • The application form states that there are no trees or hedges on the site, but there clearly are. In fact, there were even more trees and hedges until recently – did the developer pay the current occupiers to decimate them?
  • With most of the existing garden being built on or paved, this development will result in a significant loss of trees, shrubs and green garden space. Whilst the proposed use of Grasscrete in parking areas is certainly preferable to tarmac or paving, it will not support the wildlife that is currently in residence.
  • Although most of the proposed properties would be aimed at larger families, the outdoor space is severely limited by the overdevelopment of the site.
  • This suburban area represents an important wildlife habitat. In my garden I have observed a wide range of mammals, reptiles, amphibians, birds and insects, including 5 species of birds on the RSPB’s red list. Overdevelopment of suburban areas, with the concomitant pollution and habitat loss, is a major threat to wildlife. Given the Council’s declaration of a climate emergency in July 2019, the planning committee needs to stop agreeing to backland developments with immediate effect.



- Proposal contravenes CLP 2018 in several material terms, most notably policy for Coulsdon (DM37) and need to “evolve sustainably”.

-  Proposed 8 units avoids planning restrictions, including need to offer affordable housing, benefiting only developer not community.

- Overdevelopment of site is out of scale to surrounding area, particularly Petersfield Cres with its 16 one- or two-storey homes. Cumulative impact of proposed overdevelopment of 2 Coulsdon Road (19/03003/FUL); consider two applications simultaneously.

 - Height, bulk and type of buildings all out of character with area.

- 4 storey buildings cause significant loss of light / privacy (exacerbated by site’s elevated position).

- Inadequate parking.  Highway safety concerns.  Transport note has inherent flows and underestimates impact on existing residents.

- Inadequate drainage, sewerage and refuse arrangements.

- Loss of garden habitat for wildlife. Overdevelopment of this nature will not help Croydon become carbon neutral by 2030.



Planning permission should be DECLINED.

To “respect the existing local character and distinctiveness” (CLP 11.66) of the south of the borough, flatted developments should be restricted to the specific sites listed in the CLP, other brownfield or windfall sites, or land that is adjacent to main A roads or railway lines.  By adopting a policy that permits building companies to overdevelop small plots of land in residential areas, the council is fuelling private greed yet still failing to tackle Croydon’s underlying housing needs. If developers can make money quickly by converting family homes to blocks of flats, they will not put forward proposals for the larger, less profitable and longer term developments on brownfield sites that are urgently required to meet the strategic targets in the CLP. Developers are also being diverted from putting forward proposals for the 1,524 long-term empty properties in Croydon (figures from charity Action on Empty Homes, Sept 2018).


A plan of the latest development is shown below:


The latest plan can be viewed (and comments made) on Croydon Council's website at


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