The meetings on 20 and 27 July between the Planners and the Residents Associations could be a useful and productive opportunity to discuss the key new sections of the Local Plan draft documents that will not now be approved by the Cabinet until the autumn.
Share
Draft Documents
The Planners could share for comment the drafts
on:
·
the Purley Master Plan
·
the new chapter on East Croydon
Station
·
the new chapter on North End
It would also help if
the following were published in time for the meetings:
·
a briefing paper explaining what
elements of the Government’s NPPF and the London Plan affects the current Local
Plan
·
the Employment Needs Assessment
·
the lists of green spaces to be given
extra protection
·
an explanation of how the climate
crisis change policy will be integral to the Review documents.
The fact that none of this has been done is a
reflection of how the Planners thinking
is still locked into the formal processes,
and not thinking about how additional ones can be undertaken while views
could still have an influence, which was clear from many of the Spatial
Planning Team leader Steve Dennington’s comments at the Scrutiny Committee on
17 March.
Changing
The Council’s Working Culture
This is a reminder of the challenge facing the Council’s
Labour administration in relation to changing the culture of working within the
Council, and particularly encouraging the importance of challenge.
The Spatial Planning
Team should welcome and encourage challenge because it will help identify
weaknesses in the Team’s arguments, and strengthen the draft to be approved by
the Cabinet for submission for Examination.
If this does not
happen in the next couple of months then the Cabinet will basically be asked to
rubber stamp the draft. Its track record shows that it does not usually amend
officers’ reports.
There will be little
point in residents spending time analysing the draft and submitting comments to
the Cabinet members.
The
Local Plan Review Process
The Scrutiny Committee did not appear to have time
or seem to have decided not to consider the Examination processes. I recommended
to it that:
(a)
a written record be made of the
discussions at the Examination.
(b)
the Spatial Planning Team write to the
relevant witness/es informing them of the points they have accepted.
(c)
the list of additional information the
Spatial Planning Team has promised to supply be published.
(d)
given the short period of the
Examination the Team should answer any letters/emails following up discussions
at the hearings within 48 hours.
(e)
the Inspector be asked to agree that
in the penultimate session he request that any witness who has outstanding
issues in relation to the responses of the Spatial Planning Team should state
what they are, to enable the Team to
report on them at the final session.
(f)
the Spatial Planning Team be requested
to re-consider how it reacts to amendments to the Plan during the statutory
consultation in the spirit of openness, transparency, consultation and
engagement, and being flexible and constructively creative and displaying an understanding of the importance of the culture of challenge
that witnesses contribute.
Matters
For Clarification At The July Meetings
There are a number of issues which could usefully
be clarified at the meetings.
Education
Infrastructure
During the Partial Review inquiry Steve Dennington said that his team was supplied with school
place number projections by the Education Department. It was clear in the Local
Plan Partial Review Examination that the basis of the projections was flawed. I
presented a paper on this to the Inspector.
Has the basis of projections been changed since?
Population
Growth
At Scrutiny Steve Dennington explained that the
reported 700,000 people who have left London this past year is a matter for
consideration in the Local Plan Review that will follow the completion of the
current one. The loss of so many people may alter the school place needs
projections, leading to the Plan over providing for places. Figures from the
Office of National Statistics now show that the population of London had
actually grown to about 9m by March 2020, which will also affect school numbers?
What are the ONS statistics on population
decline/growth in Croydon?
This issue will no doubt be subject to discussion
at the Examination, by which time the analysis of decline/grown will be
clearer, and we may also have the first trace of population by age statistics
from the Census.
Is the date for the publication of the initial
Census statistics known?
Borough
of Culture 2023
At the Scrutiny meeting the Cabinet member seemed
to suggest that there was no proposal to spend CIL money on the Borough of
Culture. While this seems reasonable it ignores the central concept of the year
being rooted at neighbourhood level. This may require money to upgrade existing
community hall facilities, to fund physical heritage activities such as
information boards and plaques, and expenses involved in putting on events,
including equipment hire for open space events, insurance and road closures for
open space events. The Ward Budgets have been used for such purposes in the
past. It should therefore be possible to allocate a special sum for Borough of
Culture activities in the Ward Budgets. Issues relating to the neighbourhood
base is discussed in detail in the paper
I published in April 2020.
Can the draft thinking on the future of CIL be
circulated to RAs prior to enable discussion at the July meetings, so that any
concerns, questions, ideas can influence the final decisions?
Consulting
Neighbouring Local Authorities
It is important to know what discussions the
Spatial Planning Team has with neighbouring Councils. In respect of Merton
there may be cross border issues relating to Beddington Lane and the industrial
areas along it, and on the Norbury border about the ambitious plans the Ruach
Church have for the former Nat West playing fields, which could have major
impact on the areas around the site in both Boroughs. There are also
cross-Borough issues on the Lambeth border around Hermitage Lane and the bottom
end of Streatham High Rd.
Is there a section of the Review draft setting out
how the Council will deal with cross Borough planning issues, including
enduring that relevant Residents Associations are consulted?
Protecting
Pubs
The protection of
pubs given in the Local Plan 2018 was one of the positive outcomes of the
process. However at the discussion at
Scrutiny on made clear that developers
have found ways around it. In Norbury the Edge Pub has been sold. It is
not yet known who the purchaser is. The previous owners did not make it clear
in advance that there were going to sell, so the community could not consider
whether to try and buy it. A planning application will at some stage be
submitted by the new owner. Given that Antic Pubs has confirmed that they are
still on track to open their new build pub in Norbury Crescent later this year,
the applicant for the Edge may seek to justify not including a micro pub
facility in their scheme and seek to build 100% residential.
Does the current pub
policy provide protection against this?
If not has it been
amended in the Partial Review documentation?
There is another
category of drinking establishment that may not be covered by the policy. The
British Legion Hall in Norbury was a club with bars and community halls. This
has also been sold and as yet the Legion has not supplied information as to who
the new owner is.
How do current policies
protect such buildings and does the Planning Review documentation seek to
strengthen policy?
Pre-application
Consultations
Although the Council cannot force applicants to
consult prior to submitting their applications, there may be ways in which the
Development Management system can be altered to try and improve the situation
within the current legal restraints.
(1)
Add to the Planning Register informal
applications which are under discussion with the Planners prior to formal
application to enable residents to contact the applicant.
(2)
Make it a condition that any
pre-applications presented to Committee must have been publicly consulted on.
(3)
Allow residents to take part in
discussions the pre-applications at Committee.
What is the current
thinking in the Council on this?
Small
Shop Parades
It was argued at
Scrutiny that small shopping parades need to be protected. The Government’s
change in class uses has weakened this, and the conversion to residential is
likely to happen. There may be two ways in which parades could be given some
protection.
(1)
Design Guidance on converting shop frontages to residential to prevent
unattractive frontages being built.
(2) Article
4 Determinations on specific parades.
Does the Review
documentation include such measures?
I have written to
Heather Cheesbrough, who heads planning and strategic transport at the
Council, about the above.
