The following notes produced by Cllr Perry on behalf of the Croydon Conservatives were discussed in some detail at the meeting held with Residents’ Associations from across the borough.
As well as reproducing the text of the documents here, there are downloadable copies at the end of each section.
You can submit comments on the Croydon Local Plan until 17th October 2016.
The entry point for all the documents can be found here:- https://www.croydon.gov.uk/planningandregeneration/framework/localplan
It is important to remember that we are looking at both CLP1.1:- www.croydon.gov.uk/localplanone
and CLP2:- www.croydon.gov.uk/localplantwo
There are now also numerous documents that have been loaded onto the Council website, including lots of evidence documents in readiness for the examination. It will be important to respond to this evidence in any objections to the proposals. The evidence can be found here:
All the consultation documents should also be available at the borough’s libraries, at Bernard Weatherill House (Access Croydon), Mint Walk, Croydon. 9.00am-4.00pm Monday to Friday. Alternative formats of the documents are available on request at email@example.com or 020 8407 1385.
The consultation closes on 17th October 2016, so there is time to digest all the new information that has now been uploaded. It would be unwise to rush into a submission to the consultation in these early days without fully understanding the various new documents that are now available, albeit online.
The Council would prefer that everyone use the representation form, which can be found here:-
The guidance notes for completing the form may be found here:- https://www.croydon.gov.uk/sites/default/files/articles/downloads/clp-representation-form.pdf
However, it is perfectly acceptable to write a letter or send an e-mail detailing concerns. The more specific, the better.
All correspondence should be addressed to:-
Post: Spatial Planning Service, 6th Floor Zone B, Bernard Weatherill House, 8 Mint Walk, Croydon, CR0 1EA.
All correspondence must include a name and either an e-mail or postal address all of which must be legible; not contain offensive or racist language; and be related to either a marked change (in red text) in the Croydon Local Plan: Strategic Policies – Partial Review (Proposed Submission) or Croydon Local Plan: Detailed Policies and Proposals (Proposed Submission) including the draft Policies Map.
All submissions must now be challenging the ‘soundness’ of the plan and challenging the ‘evidence’ that the Council have used to draw up their final proposals.
To say that ‘I do not like it’ will not be accepted.
The Local Plan will be examined by an independent Planning Inspector, whose role is to assess whether the plan has been prepared in accordance with the Duty to Cooperate, legal and procedural requirements, and whether it is sound.
The four tests of soundness are that the plans are:-
- Positively prepared – the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements, including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development;
- Justified – the plan should be the most appropriate strategy, when considered against the reasonable alternatives, based on proportionate evidence;
- Effective – the plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities; and
- Consistent with national policy – the plan should enable the delivery of sustainable development in accordance with the policies in the Framework.
All responses will be collated by officers but in effect are directed to the Inspector at this point. Pro-forma letters will be accepted as individual submissions.
Petitions may be taken as one submission – though this is at the Inspector’s discretion.
Anyone wishing to address the Examination in Public (EIP) must make that intention clear in their submission. It will be at the Inspector’s discretion as to who will be called to address the EIP.
Where possible it would be prudent to offer alternatives to policies that are being challenged. It may well be that the Inspector may agree with a challenge to a particular policy, but if no alternative is offered and the Inspector cannot see an alternative then they may well stick with the status quo.
Cllr. Jason Perry firstname.lastname@example.org
12th September 2016
Download a copy, here: cccg-update-on-the-croydon-local-plan
POSSIBLE AREAS OF CONCERN
The four tests of soundness:
P = Positively prepared – the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements, including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development;
J = Justified – the plan should be the most appropriate strategy, when considered against the reasonable alternatives, based on proportionate evidence;
E = Effective – the plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities; and
C = Consistent with national policy – the plan should enable the delivery of sustainable development in accordance with the policies in the Framework.
Gypsy & Traveller site at Purley Oaks Depot
Road network lacks capacity – J E
Recycling centre needs expansion – this proposal will preclude this – J E
Loss of employment land – if it is OK to lose employment here then it should be OK to lose it elsewhere – J E
Possible contamination of the land – suitability for residential? – E
Other sites excluded on issues of noise, yet this is next to the main railway line – E
The Council’s original report on the site scored it as low for reasons such as – P J E C
- Flood zone
- Ground Water source protection zone
- Surface Water Management
- Existing Infrastructure
- Heritage Designations
- Impact on local character
The Council’s own assessment is subjective with scoring values being disproportionately weighted. Where multiple options apply, the lowest score has been given – P J E
Prior to this consultation there has been no public consultation on this site, putting local residents and businesses at a disadvantage – J
Alternative Sites? Underused industrial sites similar to Lathams Way, eg, vacant plot in Commerce Way.
Loss of MOL at Shirley Oaks
The site needs an element of protection in perpetuity as it is well used amenity land by the local community – P J E C
Loss of significant recreational facility which forms part of the character of the area – P J C
It does meet MOL as it does contribute to the physical structure of London as it forms a major part of the character of Shirley and Shirley Oaks, and these open air facilities do serve a significant part of Croydon and, therefore, London – J E C
It forms part of a much wider green space. Whilst there may not be direct access between all areas, these are seen by the local community as a whole and should be treated as such within the green grid, eg, It would be very simple to create a pedestrian link between Shirley Oaks Hospital and Ashburton Playing Fields – J E C
At the minimum this land should have Local Green Space protection as it meets all the criteria for that designation, namely proximity to the community it serves, local in character, a tranquil area and a site of natural open space – J E C
Question the purpose of the intention of de-designation – why do it? Why a distinction between this area and other areas like it?
Alternative? Maintain as MOL.
Loss of Green Belt at Croham Hurst
This tract of land is instrumental in checking the unrestricted sprawl of the large built up areas around it. Indeed it was bought by the Council to prevent the landowner developing the site at the turn of the 20th century – P J E C
It has historical context – J C
Croham Hurst does check the unrestricted sprawl of London, does safeguard Croydon’s countryside from encroachment, preserves the setting and special character of the heritage of Croydon and assists in the regeneration by encouraging the recycling of derelict and urban land – P J E C
Cannot see any justifiable reason why it is being treated differently to the rest of the green belt within Croydon?
Alternative? Maintain as Green Belt.
These areas should be where there is already existing infrastructure to cope with the increase in development – P J C E
Areas are too large moving into the hinterland of major routes – J E
May not have sufficient transport, schools, GP etc. – J E
Will add demand to struggling infrastructure – J E
Level of intensification is above the capacity that the character of the area can handle – P J E
There is no mechanism in the plan to deliver the improved infrastructure that would be needed – E C
Alternative? Shrink the areas of the intensification zones, so as not to effect the surrounding suburban streets around major roads.
These are just some thoughts that may provide some guidance as to how a letter may be framed in response to the consultation.
Cllr. Jason Perry email@example.com
Download a copy, here: cccg-croydon-local-plan-areas-of-concern