Thursday 15 July 2021

Is Croydon Council Open To Meaningful Dialogue On Next Stage of Local Plan Review With Residents Associations on 20 and 27 July?

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.