Suburban Design Guide Supplementary Planning Document (SPD2) Consultation
Report compiled by Rod Davies, on the behalf of the East Croydon Community Organisation steering group. Submitted to Croydon Council on 15 October 2018.
On Tuesday 2nd October 2018 I attended a London Borough of Croydon (LBC) planning consultation event at Christ Church regarding SPD2.
This consultation follows-on from a meeting held with community organisations, residents associations, various planning officers and the Chair of Planning. The meeting introduced the Suburban Design Guide Supplementary Planning Document.
At this meeting the following was apparent;
- LBC is tasked by government and Greater London Authority (GLA) to facilitate and deliver new housing to meet demand in excess of 25,000 units. There is a threat that should LBC fail to progress this that the government will intervene, take control and impose targets
- Established residents associations (RAs) oppose the proposed developments.
- The RA’s have no alternative proposals that could satisfy the need for more housing, nor was it evident that they understood the consequences of their opposition to new housing development if realised.
LBC has now stated that it aims to enable the construction of 32,890 units by 2036.
Over the last two decades LBC has been tasked to respond to the need for housing in the borough within the context of its overall regeneration strategy. LBC was slow in responding to the early 1990’s recession and the outflow of the employers, and the shifts in the London area market economy.
Consultation by LBC has been generally poor with the planning dept seemingly unwilling to directly engage with affected communities. LBC planning staff had a tendency to schedule consultation sessions around their working hours rather than the availability of community stakeholders. Further the approach tended to be characterised by a “blank sheet” approach that elicited residents’ wishes without consideration of what was achievable or desirable from a borough-wide perspective and the need to sustain the economy.
The initial approach under the former Conservative administration was to structure the planning consultation by “Place”. “Place” is defined as being an area which is contiguous and with which the “community” identified. The consultation fed into the Local Plan and the overall borough Master Plan.
The town centre was separated from these consultations and dealt with in its own planning guidance.
The organisation of the “Places” was such that the “Places” around the town centre included small areas marked for high-density development. However the majority of the “Place” areas were to be protected from medium to high-density development through planning restrictions. As the majority of residents were protected from development, the proposals gained majority support.
As has been seen with Rees House the lack of restriction in the proposed high-density development areas provided LBC with the opportunity to easily respond to demands without any meaningful local consultation. This concentrates public facilities (i.e. schools) into the core areas, which may have undesirable consequences in terms of conflict with the community and an opportunity loss.
In my opinion the “Place” approach fostered an environment where the majority of LBC’s residents believed that that the solutions to LBC housing issues would be addressed elsewhere and that their environment and assets would be protected and preserved.
In parallel to the above there was consultation about the town centre. LBC’s approach has been to promote high-density commercial and residential development up to potential 50 floors, even though as yet this has not been realised. Although the revitalisation of the borough is welcomed by most residents and businesses, there has been considerable opposition to the hi-rise approach from residents individually and through RA’s.
Popular concerns have been centred on;
- Impact upon townscape.
- Impact on public services.
- Impact on transport systems and associated environmental impact on residential areas.
Funding for area improvements, as has been seen in Addiscombe Place, tended to reflect political considerations. The benefits to be obtained from developments in the central areas have been used to fund facilities aimed at the needs of the wider borough community rather than ameliorate the impact upon the directly affected areas. The example of the Cherry Orchard Rd retail area where it has not received the level of investment received by Addiscombe “village” retail area to improve the environment and promote economic activity.
LBC Objectives & Considerations
(abstract from webpage)
Croydon Council plans to introduce a Suburban Design Guide Supplementary Planning Document (SPD2), as well as revising its Statement of Community Involvement (SCI).
The SPD2 supports the policies adopted in the Croydon Local Plan 2018 and, the delivery of around 10,000 of the borough’s target of 32,890 new homes by 2036. The document will provide guidance for suburban residential developments, development in Areas of Focused Intensification and updates to existing guidance on extensions and alterations to homes across the borough.
The SPD2 also includes technical design guidance seeking to limit negative impact and frame opportunities where increased densities can enhance and bring benefit to communities.
The SCI details how the council will engage with stakeholders, both local and statutory, in preparing planning documents and carrying out management functions. It also sets out how the council will provide advice or assistance on the preparation and adoption of neighbourhood plans.
The draft Suburban Design Guide Supplementary Planning Document (SPD2) provides guidance for suburban residential developments, development in Areas of Focussed Intensification and extensions and alterations to existing homes across the borough. It is a Supplementary Planning Document to the Croydon Local Plan 2018 and is intended to assist in the delivery of around 10,000 homes in these locations of the boroughs housing target of 32,890 new homes by 2036.
The document provides technical design guidance that seeks to both limit any negative impact on places, including the amenity of existing residents, and frame opportunities where increased densities can enhance places and bring benefits to communities.
As per the requirements of Town and Country Planning (Local Planning) (England) Regulations 2012, the Council is undertaking formal consultation on SPD2 and will seek representations on the draft document. The Council is consulting on the Draft Suburban Design Guide Supplementary Planning Document from 3 September to 15 October 2018.
Overview of Proposals
The SPD2 provides design guidance is a response to the need to provide more housing in the borough, and recognition that the opportunities in the town centre and peripheral community areas are now largely exhausted.
The SPD2 sets out guidance to developers to utilise space between existing housing units to create sufficient housing to meet needs and to create sustainable communities. It responds to “facts on the ground” where developers are already creating new housing across the borough in areas of low levels of land space utilisation and sets out clear guidelines for developers.
The aim is to secure a better designed properties that are sympathetic to the environment, of good to excellent design and encourage innovation.
While there is no medium to high density development permitted, SPD2 does envisage the construction of small 3 storey flats being developed on sites currently occupied by single dwellings or semi-detached properties. The officers expressed the opinion that the availability of such developments as starter homes would enable young adults to remain close to their families, and potentially progress to larger family homes later on.
In my opinion SPD2 will face considerable organised opposition from RA’s in the outer areas, particularly to the south of the borough, as they appear committed to maintaining the status quo. Were they to be successful, then there is the risk that central government & GLA intervenes and decides to impose development on current public green space.
Quality of Consultation
There is evidence of progressive improvement in the quality of consultation but in my opinion is still lacks explicit statement of the arguments for the need for the volumes of housing proposed to sustain Croydon and more widely London.
The consultation event was well supported by six officers.
In my opinion is was deficient insofar as it:
- Did not provide any positive examples of how this approach to development had delivered benefits to a community and individual residents
- Did not address the rationale for this approach to development
- Did not provide indications of planning for health, education & environment (traffic)
The displays were good, setting out the main themes from SPD2 document and providing some detail, and officers were on hand to discuss the approach.
East Croydon Community Organisation (ECCO) is a community organisation that seeks to represent the interests of the residents and businesses in the area broadly known as “East Croydon”. This area is delineated by a boundary defined by Addiscombe Road, the railway line, Lower Addiscombe Road and the rear of Tunstall Road.
The SPD2 does not really apply to any part of the ECCO area as the Master Plan defines the ECCO area as suitable for medium to high-density development and that there is no spaces left for development.
However, in my opinion ECCO should welcome the SPD2 as evidence that the council now recognises that the burden of regeneration and meeting the need for housing needs to be shared across the borough.
SPD2 works within the development constraints set out in the Master Plan that future developments outside of the central areas will be of low density (not exceeding 3 floors).
SPD2 supports the preservation of publicly accessible green spaces.
It does however diminish privately owned between housing green space and green space adjacent to existing residential areas that provide a “view” to those householders.
With 1,000’s of new housing units being constructed in areas such as Shirley, Sanderstead etc there is a pressing need for the council in conjunction with Transport for London (TfL) to address the potential traffic impacts and set in place a pro-active stance that discourages future residents relying on private vehicles to move about the borough.
I raised the traffic management issue with the officers present and they provided an anodyne response that the council and TfL collaborate. It was not apparent that there is any proactive stance towards traffic management aligned with SPD2. As there is an established car-culture in these areas which generates high volumes of traffic traversing the central areas there is the risk that this is merely augmented.
In my opinion ECCO needs to lobby for a change in stance and demand that the council and TfL collaborate to create a pro-public transport initiative to discourage where possible the use of private vehicles and to plan public transport infrastructure to support these expanded communities prior to these outlined developments occurring.
The officers attending the event expressed the opinion that the increase in population, especially if it is younger than the current demographic for the outer areas, which would help sustain the small shopping parades in those areas. This may also apply to the smaller local libraries.
I was unable to obtain any information regarding health centres etc.
- SPD2 balances the Master Plan whereby the entire borough is required to share the burden of meeting housing targets.
- It will help protect public green space from development by meeting space requirement from land already occupied
- This approach largely precludes any social housing due to low density and inherently high plot cost, and will result in social housing being concentrated into relatively small areas in the town centre. (I feel that this reinforces existing social divisions and may destabilise the central communities)
- It does not include developing schools etc to meet demand and it would suggest that such public resources will be concentrated in the central areas. (In my opinion it is not desirable to have large numbers of young people travelling into the town centre everyday often at distance from their homes & families).
The absence of a more comprehensive approach towards a significant increase in population is a deficiency and without being identified at this stage and planned for could lead to significant problems for the central areas.
ECCO presents its support for SPD2 with caveats regarding planning for transport and health services.