Appendix 10: Consultation Responses on Towards a Preferred Core Strategy for Croydon - Supplement (including Sustainability Appraisal) Section Representation Recommended Response Full Name Paragraph Organisation Nature of Response Officer Recommendation

The improvements are welcome as it is The comment is noted. Mr Bernard Hobbs currently very rundown. My particular concern would be if housing was to be provided that it Observation be a very mixed use. Housing should provide Noted the opportunity for young professionals to afford their own property. Affordable should be affordable! and provide not just a token few apartments. In addition, English Heritage would be grateful The recommendation to include if consideration could be given to the an analysis of the public English Heritage borough's historic school building stock in the heritage building stock in the Observation Learning City Programme in the Infrastructure Infrastructure Delivery Plan is, Noted Delivery Plan . It is English Heritage's unfortunately, beyond the preference that historic school buildings be resource capacity of the retained and refurbished wherever possible. It Council. However policies will would be beneficial for the borough to make it clear that heritage consider generally the issue of assets must be respected and decommissioned public heritage building protected and regarded as stock as part of developing the Infrastructure opportunities to strengthen the Delivery Plan and considering the potential sense of place through their role of such buildings for cultural provision or retention, enhancement and other uses in the Core Strategy . continued use. English Heritage can see that the Character The Character Appraisals are Appraisals have been used to justify the one factor in determining the English Heritage numbers of houses to be located in the locations for growth alongside Observation different Spatial Management Areas around the Strategic Housing Land Noted the borough. There does appear to be an Availability Assessment which implication that the northern part of the takes into account the viability, borough has the most historic value and availability and indicative consequently should not absorb as great a capacity of individual sites. level of new housing as other parts of the Whilst the exercise helps to borough. However, this is perhaps too broad a determine the quantum/type of brush stroke for the historic environment new homes in each Place, it because the same analysis also seems to does not dictate the level of have led to the identification of the need for detail you suggest in the four new residential tall buildings in very close Masterplans. proximity to the Grade I listed St Michaels and All Angels Church in the Croydon Metropolitan Centre in the West Croydon Masterplan . English Heritage is of the view that the need to conserve and enhance the setting of this highly significant heritage asset should instead have led the local authority to consider reducing the pressure in the Core Strategy for housing provision in this part of the Croydon Metropolitan Centre. The Borough Character Appraisal does identify the Croydon Metropolitan Centre as having a number of significant heritage assets. As a Grade I heritage asset, St Michaels is highly significant and the treatment of development within its setting needs very careful attention. More generally, the borough needs to define Agree, the Council will include its approach to tall buildings more clearly. At more detailed policies on tall English Heritage present the treatment of tall buildings in the buildings in the pre-submission Observation East Croydon Masterplan is openly draft of the Core Strategy. It will Noted development driven stating that final form and also set out a definition of ‘tall massing should be determined by occupier building/s’ in the glossary. demand. This has insufficient regard for the need for development to be sustainable and plan-driven in accordance with PPS 1. In accordance with our publication Guidance on Tall Buildings (July 2007) , English Heritage recommends that the borough use the Core Strategy to define what "tall building" means throughout Croydon and indicate where it considers the location of tall buildings to be appropriate, inappropriate and sensitive. The Masterplan documents can then be informed by this. If library in Purley is at risk, incorporate No decision to close Purley Mr Carl Roche additional community facilities (eg. community Library has been taken by the centre, public hall, etc) to make the library a Council Observation central feature. Noted Consequently, English Heritage would be The Council does not consider it grateful if the borough would consider the necessary to include all heritage English Heritage following adjustments to the consultation assets in the ‘Cultural Mapping Observation documents and their supporting evidentiary Study’ nor is in a position to Noted – To be Reviewed documents: inclusion of the borough's undertake this work. It also heritage assets (including archaeological considers that the relationship assets) in the Cultural Mapping Study and between the Places of Croydon Borough Character Appraisals; analysis of and the borough’s heritage public heritage building stock use in the assets has been appreciated. Infrastructure Delivery Plan (particularly historic school buildings); analysis of the The housing numbers will be relationship between borough heritage assets reviewed in the light of and understanding of place identity, capacity comments received ahead of and enhancement in the Core Strategy (with the publication of the pre- supportive reference in the Infrastructure submission draft of the Core Delivery Plan where necessary); adjustments Strategy. to housing supply numbers for each Spatial Management Area in the Core Strategy where Comments relating directly to heritage conservation requirements might the East and West Croydon necessitate it; adjustments to the Core Masterplans will be passed to Strategy and both Masterplans to reflect a the relevant team. plan-driven approach to tall building development; and reconsideration of the West The recommendation to include Croydon Masterplan building development an analysis of the public proposals to demonstrate the conservation heritage building stock in the and enhancement of the Grade I listed St Infrastructure Delivery Plan is, Michaels and All Angels Church and its setting. unfortunately, beyond the resource capacity of the Council. However policies will make it clear that heritage assets must be respected and protected and regarded as opportunities to strengthen the sense of place through their retention, enhancement and continued use. We would be very happy to continue to liaise Apologies for any confusion closely with the borough as this work is created on our part, but the English Heritage undertaken and trust that this will be of Council has made available, on Observation assistance to the process. Â Furthermore, in its website, the latest version of Noted our previous correspondence we noted that the Sustainability Appraisal and we had not been sent a draft sustainability will continue to do so. appraisal report for comment. This is still the case and therefore could you please advise us as to the current status of the sustainability appraisal and send any outstanding version through to us for review. Â Finally it must be noted that this advice is based on the information provided by you and for the avoidance of doubt does not reflect our obligation to advise you on, and potentially object to any specific development proposal which may subsequently arise from this or later versions of the plans that are the subject of this consultation, and which may, despite the sustainability appraisal, have adverse effects on the environment. The current national climate similarly Whilst public expenditure will be Mr Brian Madge challenges the assumptions regarding the constrained over the next 4 Brian Madge Ltd necessary infrastructure provision. The years and concievably foer a Objection strategy is heavily reliant on intense longer period, much Noted development in CMC and its environs and in infrastructure is provided by the the north of the Borough. It is well private sector. Health documented that the forthcoming expenditire has in large Comprehensive Spending Review will impact measure been protected . on virtually all public agencies to the extent Additionally the government has that the required investment will not occur. approved the means for funding Moreover, given current levels of private infrastructure through the development and approaches to funding there Community Infrastructure Levy is doubt that sufficient development with to be deployed by both the Section 106 agreements will come forward to Mayor of london and the met infrastructure requirements. The Council Borough council. Prudential are already re-negotiating existing borrowing on the back of future agreements downward and there is no funding is also being indication of a more favourable climate in the encouraged. The current short to medium term. reduction in development backed funding is not likely to be long term Why has "local distinctiveness" replaced what Local Areas of Special has previously been known as "area of special Character (LASCs) have not character"? Is there some subtle difference? been lost, they are referenced Objection in the Core Strategy and remain Disagree – No Change areas for conservation. The idea of preserving local character and local distinctiveness are in addition to existing designations such as LASCs. 2) Proposing such an ambitous figure for an School planning provision is Amanda Sciberras area that is on the periphery of borough undertaken across the Borough Resident boundaries is highly questionable given that including Crystal Plalace. It Observation the 3 adjoining borughs have yet to present makes allowance for cross Noted their own Core Strategies and new home boundary movement of children. figures and this area is beginning to buckle Liaison with adjoining Boroughs under the increasing demands of an ever is continuing and those expanding populous. Crystal Palace is boroughs are not raising inundated with multiple large new objection to the intended developments that will significantly swell the housing provision in North exisiting population and increase demands on Croydon. social and transport infrastructures. For example local schools are all oversubscribed, like wise GPs, yet the population is about to expand by aproximately 500 new residents. I can only hazzard a guess as to how many new cars this will bring to the already heavily parked roads but it will guarantee further congestion and disruption. Then there's the health and safety issues that come with over abundance of on street parking. More importantly where are all the children going to be schooled? I would urge your team at Croydon to go back to the drawing board and liase with Lambeth, Southwark and Bromley in order to ease this burden. Reigate & Banstead Borough Council have no Support is welcomed. specific comments to make on the 'Towards a preferred Core Strategy for Croydon - Support Supplement'. However, the Council does Noted support the short-term proposals of easing congestion on the A23 and making enhancements to Purley Cross gyratory. The Council also supports the recommendation to increase rail service destinations from East Croydon. Town centre designation The Core Strategy will provide Mr Michael Mulhern more detail on town centres. Greater London Authority 38 In line with London Plan policy 2A.8, the Observation Core Strategy identifies a town centre Noted – To be Reviewed hierarchy, including Metropolitan, District and Local centres. The supporting text may benefit from a further explanation of these centres with details as what type and quantum of development may be appropriate in each centre, or identify what DPD would provide further detail on this issue. 39 In line with London Plan policy 2A.8 and It is understood that a minor Mr Michael Mulhern annex table A1.1 ‘Town centre classifications', alteration to the London Plan Greater London Authority the Core Strategy proposes to designate the identifiesNew Addington as a Objection following centres as District Centres: district centre. Disagree – No Change Addiscombe, Crystal Palace and Upper Norwood, Norbury, South Norwood, Thornton Heath, New Addington, Selsdon, Coulsdon and Purley. 40 The plan also identifies New Addington as a district centre. However, New Addington is not identified as a district centre in either the current London Plan or draft replacement London Plan (2009). Objectives to reclassify town centres should be carried out in line with PPS6 thresholds and the London Plan ‘Town Centre Health Check' process. A further discussion on this issue would be welcomed, and officers at the GLA are happy to provide further assistance if required. Excessive use of acronyms; and the Whilst this supplement is not employment more plain English would be thought to be user unfrienlt the helpful. The introduction of footnotes to most next version of thePlan will be Observation pages adds to the complexity - too small a assessed for Plain English and Noted – To be Reviewed font to be read but many without the aid of a have a fuller glossary magnifier! If these notes contain relevant information then it is suggested that they be incorporated within the main body of text. On most pages there is space to do this. Alternatively us a bibliography. IIn conclusion This document is unfriendly to both members of the public and other stakeholders, and as such it has been difficult to come up with rational appropriate comments. If the powers that be really want the majority of stakeholders to interact and respond, the documents should be written and marketed with that in mind, rather than for other purposes. Less us of acronyms, more plain English and clearer rational presentation of estimates and projections. Â The document should preferably be written from a bottom-up approach rather than a top-down imposition, where the latter may not fully credit local opinion. In view of the mixture of finite and visionary nature of much of the content it is difficult to decide just what sort of comment authors of the document are looking for. Â In view of the fact the document will surely be subject to periodic review in any event, then at this stage, 2013 may be looking far ahead. It is important to have a strong understanding The scope of the ‘Cultural of what heritage assets the borough has; the Mapping Study’ was wide and English Heritage significance of those assets; and the potential the decision was taken not to Observation they have to contribute positively to the map all heritage assets in this Noted – To be Reviewed borough. The Cultural Mapping Study and the document. This was a purely Character Appraisals would be stronger practical, resource-based pieces of evidence if they mapped all heritage decision and does not mean assets, including archaeological ones, and they are not valued. The pre- examined the potential for such assets to submission draft of the Core contribute to the cultural and spatial objectives Strategy will include a map and for the borough - such as the provision of list of heritage assets. There more venue space or the location of were taken into full account significant new infrastructure. when determining the appropriate vision and quantum/type of growth for each of the 16 Places. I expected a proper targeted focussed Whilst more can always be Mr Kevin Lawrence questionnaire, not to be asked to make up my done, the Council has used a SENSE WITH ROADS own comments. I think you have got it badly wide variety of consultation Objection wrong, and it is such a shambles that it is hard techniques across a range of Disagree – No Change to make detaied comments. media, venues and stakeholders to make the consultation process as accesible and effective as possible with the resources available. I understand you are part of talks discussing Comment is noted. Detailed Wendy Vardon the future core strategy for Purley. I would just parking policies shall be dealt like to say something about the multi storey with in the Site Allocations and Observation car park. I hope it will remain a key Development Management Noted requirement - a substantial car park is DPDs. essential in Purley especially for commuters like me. I have lived in Purley for over 25 years because I find it so good for commuting by train to the City where I have worked for over 25 years. I drive to the station every day and park in the multi storey car park and even when I arrive before 8am it is virtually already full by then so you can see how essential others see it as too. That car park is overflowing every day and we would be lost without it. I also use the car park at weekends for shopping too. Please note that we have no comments to Comment is noted Isabel Assaly make with regards to the Preferred Core Natural England Strategy supplement. Observation Noted Coulsdon is a good location for polyclinic-21 The pattern of polyclinic Mr Charles King century premises needed. Coulsdon should provision is likely to be reviewed East Coulsdon also look at the health provision beyond the in the light of the new system of Residents' Association polyclinics. GP commissioning Observation Noted Coulsdon need a large supermarket to keep The comment is noted. Mr Charles King people in the centre Finish work in town Coulsdon is classified as a East Coulsdon centre Shops are life expired redevelop town District Centre, as such a large Residents' Association centre Need more employment in Coulsdon & supermarket would, in theory, Observation people to live there Develop Management be an acceptable use. Noted DPD should set design rules would have worked with A23 corridor Not enough 1+2 bedroom homes in Coulsdon The Local Housing Market Mr Charles King nowhere for people to move to Population Assessment takes the GLA East Coulsdon predominantly over 55 need smaller homes population projections for the Residents' Association Yet in Purley nothing but 1& 2 bed homes borough as a whole and uses Objection Need a different mix think about Lukes's work data on household composition Noted – To be Reviewed to justify and type of homes currently in existence to provide the overall need for homes up to 2031 and the need for new homes by tenure split and home size. Croydon has followed the guidance and methodology of Planning Policy Statement 3: Housing, this sets out how Local Planning Authorities should assess housing need and land availability for new housing. As a Public Relations exercise this overall The public and others have project might well have been better handled. been consulted as the Plan has Unlike its forerunners such as the Croydon been prepared. Many have Observation Plan or UDP and other, this exercise has been found this to be a help rather Disagree – No Change fragmented between four documents over a than a hindrance. It is a process period of time ranging from July 2009 to permitted by Reg 26 procedures. October 2010. 2. Housing- Since publication of the The potential of each of the 16 Andrew Parfitt Supplement, the GLA have subsequently Places to accommodate new Crystal Palace Triangle made alternative population projections at homes will be reviewed and Planning Group ward level to 2031. These are based on: the where necessary the type and (CPTPG) need to accommodate the London-wide quantity will be revised. Observation population projections in the Draft Noted – To be Reviewed Replacement London Plan; and what could be accommodated if all the land identified by boroughs in their Strategic Housing Land Availability Assessment were taken up. The DRLP-based projection has population growing in the five Crystal Palace wards from 65,000 to 71,000 between 2001 and 2031. For Upper Norwood and South Norwood there is a shortfall at 2031 of fewer than 150 persons between housing need as identified in the DRLP and housing supply as identified in Croydon's SHLAA. i) Key on key diagram is confusing proposed The comment is noted. The V Roberts greenlinks look like railway lines. ii) Question greenway network (existing and Resident whether some of the 'proposed' greenlinks proposed) will be refined and Observation aren't actually 'existing') e.g. the London Loop amended. The use of Noted – To be Reviewed or Hamsey Green. iii) New footpath shown landmarks on mapping will be across Purley Downs Gold Course - is this investigated. wise? iv) Non strategic space such as Duppas Hill Recreation is very important and ought to be shown too. v) Is the proposed footpath next to the railway line nr Purley achievable? Think back gardens extend right down to embankment. vi) Wants to see paper copy of GI study when available vii) There aren't enough landmarks to orientate by on key diagram. n.b. all comments relate to the Key Diagram of CS2b. 7.113 - 7.115 Despite a lottery bid for 'My Not an LDF issue. Mr David White Place'. I would like to see the council create a Resident new position of youth centre co-ordinator, Observation speaking to current day faith centres, to make No Action – Not an LDF Iss sure of unused facilities in their halls during both school and holidays. This would use present facilities, at little extra cost, where capital assets exist, and extra income is needed by faith centres to cover operating costs, to get young people off the Streets. They need more facilities, as they are 'bored', but this would need to be matched by more volunteers from the 3rd sector to manage events. The traffic problem at Purley Cross has a Although the Core Strategy will Paul Thompson major fault with there being only one entrance not address site specific issues, to TESCO's and this requires a right hand turn such as this, the council will Observation for most of the traffic as it is only vehicles from continue to work with Transport Noted the Godstone Road that can turn left into the for London to improve transport centre. All other traffic has to turn right across in the borough. the flow causing congestion especially at Christmas time. This could be cured by simply opening up one of the two unused entrance off the Brighton Road (Coulsdon side) This would give two entrances and two exits to the site with ALL TRAFFIC having a single left trun into the store. If there are any major hazard sites and The comment is noted. This Health and Safety pipelines, or associated consultation zones representation shall be Executive within the local development plan area, it reviewed in light of any changes Health and Safety would be helpful to indicate to potential to the proposals map. Executive developers the constraints likely to be Observation imposed by their presence. The attached Noted – To be Reviewed Annex could form the basis of a policy statement for inclusion in the plan, which may subsequently avoid the submissions of planning applcations containing inappropriate proposals. We suggest that the proposals map be marked to show the location and routes of any major hazards- eg. buried pipelines. Need for larger short stay car park at E Comment is noted. Detailed Croydon stn on ward parking not appropriate parking policies shall be dealt with in the Site Allocations and Objection Development Management Noted DPDs. Re: Purley Car Park. I understand that there Comment is noted. Detailed are discussions to close/pull down Purley car parking policies shall be dealt park. I am amazed as to why anybody would with in the Site Allocations and Objection contemplate this. This car park is essential for Development Management Noted the town, for those who work and shop in DPDs. Purley and also for commuters. The present car park serves in excess of 250 customers a day and is essential for the continued vitality of Purley. If the car park no longer existed then where would people park their cars? The West Croydon Masterplan would do well This is a not a matter for the to include more visual (including Core Strategy – comment will English Heritage photographic) modelling of the potential be passed to West Croydon Observation impact of the proposed tall buildings on the Masterplan team. No Action – Not an LDF Iss church and its setting. The only indicative street level drawing included at present on page 63 suggests that the church will be utterly dominated and illustrations such as that on page 20 indicate that the church will be entirely enclosed by the development and the ability to appreciate its distinctive silhouette and its historic relationship to its residential community will be removed. I have a general comment regarding the The proposed numbers of new Cllr George Ayres borough-wide strategy and a further comment homes have been allocated to relating to New Addington. Borough-wide The individual areas based on Observation primary driver of the strategy is the projected increases in Noted requirement to provide 21500 new homes or population, the existing 1:7 to the existing stock. This ambition is infrastructure capacity, the planned within current land usage. I believe ability of areas to accommodate this ambition is unachieveable without new infrastructure and the sites effecting a significant change to the built shown in the Strategic Housing environment to a degree that will Land Availability Assessment. fundamentally change the nature of the Clearly all areas will require community of Croydon. To achieve the additional housing to meet ambition will require a massive public needs, although CMC will be investment in the social and economic expected to accommodate the infrastructure without any certainty that the largest proportion. necessary housing investment will be forthcoming from the private sector. The future The Local Housing Market social housing need identified is probably Assessment takes the GLA understated as a consequence of the changes population projections for the in demand following the recent decision to cap borough as a whole and uses housing benefit allowance (HBA). The mix of data on household composition housing need requires review following and type of homes currently in amendments announced to the HBA. New existence to provide the overall Addington The design of the area meets the need for homes up to 2031 and aspirations of the "Garden City" concepts the need for new homes by associated with Ebenezer Howard and these tenure split and home size. values must be preserved in any future Croydon has followed the development. The high density buildings guidance and methodology of present do not fit well within the wider design Planning Policy Statement 3: nor do they meet with the residents views as Housing, this sets out how identified in the aborted Central Parade Local Planning Authorities development with its emphasis on high should assess housing need density housing. Unmet housing demand is and land availability for new largely made up of young families with a need housing. for three plus family housing with access to outside recreational space in close proximity A key driver for the Core to the home. Mention is made of the retail Strategy is for local character to sector as the future job creator. The reality is be maintained and enhanced the retail sector is not the main source of where possible, using the employment and that situation is unlikely to Borough Character Appraisal change. The New Addington Trading Estate (now incorporating the (NATE) is far more important in terms of both Residential Character employment and economic added value. It's Appraisal). needs are wholly ignored by the Council and as a consequence future private investment is The Council considers the ‘5- in jeopardy. A major need is to examine the tier’ approach to industrial land adequacy of existing transport infrastructure in reflects Croydon’s ‘Restrictive particular road access by way of King Henry's Transfer’ status in the London Drive and access from the M25 which is of Plan yet also introduces a more growing importance. The second most flexible policy stance than that important employment sector is owner- which currently exists. The Core managed Small Business providing skilled Strategy provides Vulcan Way labour across a range of sectors. Much of the (New Addington Trading Estate) employment provided is of relatives or with the highest protection in neighbours. Whilst the owner has appropriate recognition of its status as a technical skills they often lack business skills separated industrial location. such as finance, marketing and employment and will benefit from signposting to supported The Core Strategy propounds business services. Transport needs should be the idea of a network of properly assessed taking into account the enterprise centres to assist physical separation of New Addington from small and medium enterprises the remainder of Croydon. The high in the borough; this is dependancy of residents to public transport envisaged to cover independent because of economic deprivation and working retailers. patterns that include large measures of shift working across London and the SE England It is acknowledge that New region. Young people The need is to provide Addington’s physical separation low cost recreational facilities for young can hinder walking and cycling people in New Addington Ward. Those to other areas within the facilities available such as schools and ACA borough. The pre-submission Community Hall require a significant user fee version of the Core Strategy will that is presently provided by families many of include policy for encouraging whom are economically deprived living at the more cycling and walking in margin with little or no discreationary spending Addington in addition to public capacity. The incidence of low level anti-social transport improvements. The behaviour is cited as the direct result of the council will continue to work lack of facilities. Central Parade The existing with Transport for London to street scene is best described as "brutal" with improve transport in the little to encourage community use once shops borough. have closed. As a consequence the space is occupied by youths engaged in anti social The pre-submission version of behaviour. There is a need to re-design the the Core Strategy will include space to attract family and community use specific policies for community after retail hours. An example is to soften the facilities and recreation. surface area and to provide lighting and sound capabilities that will support community events The pre-submission version of such as music, plays and events. Â George the Core Strategy will include Ayres specific policies for the Public Realm. Â Paragraph 4.43, which forms part of the The employment policies Metropolitan Police Jobs Strategy for Croydon Metropolitan distinquish between surplus Authority Centre and Environs, seeks to safeguard industrial land and that which Metropolitan Police industrial/warehousing premises/sites which needs to be retained such as at Authority fall outside the Separated and Integrated strategic industrial locations. Objection Industrial Locations. As part of the Strategy, Non emplyment uses can more Disagree – No Change limited residential activity and changes to D1 easily be accommodated where uses will be permitted. Â Currently within the the land is surplus. That is not strategy policing is not recognised as an all employment land. Policing is appropriate use on industrial sites. Policy 3B.4 accepted nonetheless as a of the London Plan recognises '... the potential community facility. for surplus industrial land (as defined in assessments) to help meet strategic and local requirements for a mix of other uses such as housing and social infrastructure...'. Mindful of the London Plan definition of social infrastructure which includes policing, the emerging Core Strategy should be amended accordingly to reflect this strategic policy. I understand that you are currently thinking The valuable role of Purley Pool Mr Jon Webb about whether or not have a pool in Purley. As in providing swimming facilities a father of 2 young children (4.5 and 2.5 years and a learning environment for Objection old) I think it is vital that we have a local pool Purley and adjoining areas is Noted (I live in Sanderstead) so would urge you keep understood. The pool needs this facility in place. refurbishment or in the medium term replacement. The pool is to be refurbished in the short term with commitment from the council to keep it open until 2014.

Proposals to meet the needs of the borough, improve the quality in provision, and meet unmet and future demand have arisen from an analysis of both need and the opportunity to develop provision to cater for the unmet demand in the south of the borough.

The Core Strategy will not include policies for site specific facilities unless there are strategic implications. The Core Strategy will set out general policies related to co-located community facilities (including swimming pools and leisure centres). Site specific policies or detailed community facilities policies shall be dealt with by the Site Allocations DPD and Development Management DPD. Detailed car parking policies will be addressed through the forthcoming Development Management and Site Allocations Development Plan Documents. We understand the Council is preparing a The valuable role of Purley Pool Mr Peter Salter Core strategy Document that will shape the in providing swimming facilities future of Croydon and Purley. This will and a learning environment for Objection incorporate Leisure and Sports facilities. Purley and adjoining areas is Noted Purley is the hub of the South of the borough, understood. The pool needs having good transport links serving all wards refurbishment or in the medium and should retain the Pool. We feel that a pool term replacement. The pool is is essential for the people of the area for to be refurbished in the short healthy activity. It is supported by the doctors term with commitment from the and is well used by local schools and by the council to keep it open until disabled. The pool serves 250000 customers 2014. a year, and our young people make good use of the facilities. Â We also feel that the car Proposals to meet the needs of park next to the Pool should be retained as it the borough, improve the quality serves the local community, as well as rail in provision, and meet unmet travellers. There is insufficient car parking and future demand have arisen facilities in Purley at the present time, and with from an analysis of both need the influx of new dwellings, especially and the opportunity to develop apartments, the need for car parking will provision to cater for the unmet increase in the future. demand in the south of the borough.

The Core Strategy will not include policies for site specific facilities unless there are strategic implications. The Core Strategy will set out general policies related to co-located community facilities (including swimming pools and leisure centres). Site specific policies or detailed community facilities policies shall be dealt with by the Site Allocations DPD and Development Management DPD. Detailed car parking policies will be addressed through the forthcoming Development Management and Site Allocations Development Plan Documents. We understand that these documents are to The Council recognises that the be read in the context of the general strategic complexity of the Core Strategy English Heritage approach for the Core Strategy. Indeed there and the large number of Observation is a very significant interrelationship between supporting documents could Noted – To be Reviewed all of the documents being consulted upon. give the impression that the Consequently, we hope you will understand consideration of heritage has we have taken an issues based approach to been light. However, the value our response rather than compartmentalising of the borough’s heritage assets it into a discussion of each document in turn. has not been overlooked during Currently, it is difficult to be confident that the production of the Core Strategy. combined effect of the documents will result in For example, whilst the conservation and enhancement of Conservation Areas and Croydon's historic environment. English Archaeological Priority Zones Heritage appreciates the preparation of the have not been identified on the Borough Character Appraisal, the Residential Character Appraisal maps, the Character Appraisal and the Culture Mapping presence of these features was Study as important pieces of evidence for the taken into full account when borough's approach to its Core Strategy and determining an appropriate other Local Development Framework (LDF) vision and the quantum/type of documents. However, the treatment of growth for each of the 16 heritage in all of these evidence documents is Places. at present very light. It does not yet appear to have been analysed effectively to indicate The pre-submission draft of the appropriate strategies for the historic Core Strategy will include environment within the documents being specific policies on heritage and consulted upon. For example, in the a map and list of heritage Infrastructure Delivery Plan at page 79 it is assets will be included. stated that culture/heritage infrastructure will be confirmed upon completion of the Culture Mapping Study . This does not seem to have occurred and the Draft Final Report for Understanding and Shaping the Cultural Sector in the London Borough of Croydon, Draft Final Report (September 2010) declines to map the majority of heritage assets (Map m). In addition, Conservation and Archaeological Priority Area maps have not been overlaid into any of the maps in the Character appraisals , nor have they been used in any of the maps in the Supplementary Core Strategy document. Consequently, it is not possible to understand the impact of the documents on the borough's historic environment. I write on behalf of our client the Metropolitan Pre- amble. To be checked to Metropolitan Police Police Authority (MPA)/Metropolitan Police see if the Core Strategy takes Authority Service (MPS) with regard to the above sufficiently into account. The Metropolitan Police document. The MPA/MPS provide a vital comment is noted. Many of the Authority community service to the Borough of Croydon ideas put forward are Observation and policing is recognised within the 2008 embedded in the Core Strategy Noted – To be Reviewed London Plan as being an integral part of social (such as planning for healthcare infrastructure. Acknowledging this strategic facilities, improving safety and policy context, the MPA/MPS have a number security etc.) and will continue of representations concerning the Council's to do so. emerging Core Strategy.  The relevant planning policy framework relating to policing at the national and strategic levels has previously been set out in CgMs' representations on behalf of the MPA/MPS in January 2009 (CS Scoping Document), September 2009 (CS Issues & Options) and March 2010 (Towards a Preferred CS). I reiterate this immediately below and then provide an assessment of the Supplement document.  Context to Representations National Policy  PPS1 states that Councils should prepare development plans which promote inclusive, healthy, safe and crime free communities.   Circular 05/05 paragraph B9 advises that developers may be expected to pay for or contribute to the cost of all, or that part of additional infrastructure provision which would not have been necessary but for their development. Strategic Policy  Paragraph 3.99 of the London Plan (Consolidated with Alterations since 2004) states ‘i nitiatives relating to policing and community safety and crime reduction are seen as increasingly important in improving the quality of life of many Londoners'. Policy 3A.17 states that the diverse population needs should be met through the general and specific policies relating to the provision of social infrastructure including ‘policing facilities' . This policy therefore recognises that the provision of police facilities is defined as an element of social infrastructure.  Policy 3A.18 states: ‘ Policies in DPDs should assess the need for social infrastructure and community facilities in their area, and ensure that they are capable of being met wherever possible. These needs include primary healthcare facilities, children's play and recreation facilities, services for young people, older people and disabled people, as well as libraries, sports and leisure facilities, open space, schools, nurseries and other childcare provision, training facilities, fire and policing facilities , community halls, meeting rooms, places of worship, public toilets, facilities for cyclists, convenience shops, banking facilities and post offices (also see Chapter 3D).  Policy 3A.26 also highlights the importance of ‘ ensuring communities benefit from development including through Section 106 agreements' and improving safety and security.  Emerging London Plan (2009) - further reinforces the need for adequate policing facilities across London within Policies 2.6, 2.13, 2.15, 3.17, 4.4, 4.6, 7.3 & 7.13.  The importance of adequate policing facilities and their recognition as a community facility are acknowledged in both national and strategic planning policy. I refer below to relevant sections within the Core Strategy Supplement document and provide comment in order to ensure that the emerging policy documents reflect the strategic development plan in relation to policing. This is considered a strategically important issue regarding the Borough's future sustainable development, thus these documents are required to take account of policing needs.  MPA's Representations to the emerging Core Strategy Supplement  Croydon Metropolitan Centre and Environs Paragraph 4.7 identifies that growth can only be accommodated in Croydon Metropolitan Centre if the necessary infrastructure exists or can be put in place. Waddon and Broad Green are identified as places that will be developed in time, as supporting infrastructure is required to ameliorate flood risk, address transport facilities and provide community facilities. Importantly, the East Croydon Masterplan This is a not a matter for the needs to recognise that a tall building is a Core Strategy – comment will English Heritage public realm intervention contrary to the be passed to East Croydon Observation statements made at paragraph 3.5-4 on page Masterplan team. No Action – Not an LDF Iss 24. Every storey of a building removes open space from the public realm and the height of buildings impacts upon the relationship between existing public realm elements. There is no reference to policing within the Policing Facilities are accepted Metropolitan Police Supplement. In this regard to document is not as being part of Community Authority considered 'sound' as it does not reflect Infrastructure and are treated as Metropolitan Police government guidance the strategic such in the IDP. The Authority development plan, as required by PPS12 and consolidated next version of the Objection GOL Circular 01/2008.  The emerging Core Plan will make that apparent Agree – Propose Changes Strategy is required therefore to reflect Planning Policy Statement 1 (PPS1), which states that Council's should prepare development plans which promote inclusive, healthy, safe and crime free communities and also Paragraph B9 of Circular 05/05 as referred to above.  Further, policing facilities are defined within Policies 3A.17 and 3A.18 of the London Plan as a community facility and therefore represent a key aspect of social infrastructure.  In order to ensure the emerging core strategy can be judged 'sound' it is therefore recommended that policing is included within the definition of community facilities, as set out below and in our previous representations, in order to ensure planning obligations can be secured to mitigate the impact of development upon policing where required and/or appropriate.  Recommendation: the MPA/MPS recommend that the Core Strategy includes policing facilities as a defined community facility in order to ensure that the impact of development upon policing is mitigated through the use of planning obligations.Paragraph 4.14 lists what is needed to attract people to live in Croydon Metropolitan Centre. Community facilities are outlined as part of the strategy, however neither policing or emergency services are specifically listed. This is contrary to Policies 3A.17 and 3A.18 of the London Plan within which policing facilities are recognised as community facilities. It is therefore recommended that policing is included as a community facility within the Core Strategy glossary, as set out below. Number of New Homes to be provided: I The comments are noted. Mr Sean Fitzsimons agree that the Town Centre should provide a Whilst the Warehouse Theatre Resident major part of the new homes Croydon needs is recognised as a much valued Observation to supply and this will relieve pressure from local asset a specific policy has Noted damaging over delelopment. But this housing not been included as it does not needs a higher percentage of affordable and have the same regional family housing than proposed. Residents on significance as the Fairfield lower income do want houses with gardens Halls. but many also appreciate the advantages of Town Centre living, with its lower transport costs, and closeness to services and better employment opportunities. Fairness of where new homes are likely to be provided: I disagree with the protection South East of Croydon. There are a number of comments in the supplement which talks about protecting the character of certain areas. This has translated in the report so that areas that were developed with lower density in the past such as Selsdon and Addington are protected whilst areas with higher density are not. There must be a recongnition of fairness in the report and that less should be done in the north of the borough and much more in South East Croydon. Culture: the reports on places fails to give much weight or space for culture. The town centre report for example does not mention Warehouse Theatre, vital for the regeneration of Town Centre and East Croydon. The Addiscombe part has no mention of culture at all. The places report fail to address the linear strips shopping parades, espcially roads like Cherry Orchard Road, Lower Addiscombe Road from Windmill Bridge to Grant Road. There are a number of these strips across Croydon that are in poor condition and this document doesn't adress how to tackle their decline. Additionally, Policy 2.17 Strategic Industrial The London Replacement Plan Metropolitan Police Locations of the Emerging London Plan in Policy 2.71 and para. 2.71 do Authority defines, inter alia, 'other industrial related not accept policing functions as Metropolitan Police activities' as being acceptable within Preferred an industrial use or industrially Authority Industrial Locations. In order to ensure related use. Outside strategic Objection consistency with the adopted and emerging areas community uses will be Disagree – No Change London Plan, we recommend policing facilities considered. be considered an acceptable use on industrial sites where appropriate.  Recommendation: the MPA/MPS recommend that paragraph 4.43 of the 'Jobs Strategy' be amended to read (additional wording underlined): The Council will continue to safeguard industrial/warehousing premises/sites which fall outside the Separated and Integrated Industrial Locations. However, where it can be shown not to adversely harm the site's business function, limited new residential activity will be permitted. For those sites which have better transport accessibility, The provision of community facilities will also be acceptable. Derby Road development - route to Wandle The Core Strategy will include Anonymous Park. I am concerned that the proposed borough-wide parking policy. Unknown development in Derby Road will increase the The issues set out in the Objection volume of cars/traffic in Clarendon Road representation are too site Disagree – No Change which has benefitted considerably from the specific for the Core Strategy. 'No Entry' provision at the Derby Road These site specific issues shall junction. be dealt with via the West Croydon masterplan and Also will this impact on the availability of Croydon Opportunity Area residents parking in Clarendon Road which is Planning Framework. already in short supply especially on Sundays since Sunday opening was introduced?

I would also be concerned about the impact of increased pedestrian flow through the road if the Wandle Park route is highlighted. We already experience increased noise at times when less considerate groups pass through. I don't object to highlighting the availability of the park and increasing facilities for all age groups but the less savoury element could be a potential problem. In addition there was a strong feeling amongst The proposed numbers of new Revd Charles Trefusis the Steering Group that: The two main issues homes have been allocated to Purley & Kenley and concerns for Purley were: i. Housing individual areas based on Neighbourhood intensification - covered above and in the projected increases in Partnership Annexe. population, the existing Objection infrastructure capacity, the Disagree – No Change ability of areas to accommodate new infrastructure and the sites shown in the SHLAA. Clearly all areas will require additional housing to meet needs, including Purley. .  Reference has also been made to The broader sense of Culture is changes of social, economic and demographic illustrated in the extract from the conditions. It may be beneficial for future Vision document. Purley is Objection design of larger houses 4/5/6, beds to offered as an example of a Disagree – No Change incorporate built-in provision for easy, rapid district centre with a cultural and relatively inexpensive conversion to offer not to suggest it should reduced styles of occupancy.  7.38 p69 dominate Coulsdon Clarification is required as to the definition of ‘Culture'. It appears that the term is being used solely in respect of a ‘business culture' to the exclusion of all other forms. Concern has been expressed as to the offhand manner by which Coulsdon has been summarily ‘dismissed' as having no culture and relegated as a satellite to Purley's creative business sector. Every Town or place is entitled to its own culture and this should be recognised even if this does not align with other guidance. I am writing to express the views of users of Detailed car parking policies will Mr John Freeman Purley Car Park who do not reside in your be addressed through the area. I, like many other train passengers, use forthcoming Development Objection Purley Rail Station, and some are season Management and Site Noted – To be Reviewed ticket holders in the council car park. I have Allocations Development Plan been using this car park since I moved to this Documents. area about 4 years ago. Whilst ever I work in London I will require a car park near this station. The Station car park is too small if your facility was to close or to reduce. So what would be the alternative? I would have to park in in residential streets near Purley Station and walk, it would be more inconvenience for me, but it would not go down very well with your residents. There is is no doubt although my type of commuting attracts more traffic in Purley, with such a strategic station located in your area there is nothing a council could do to dis-courage such travel arrangements. I suggest you maintain the spaces which exist today for long term users and maintain your substantial car parking income and stop me from upsetting your residents. As a business owner in Purley town centre, Detailed car parking policies will we heavily reply on the multi-storey car park. be addressed through the We currently have six annualpermits for staff forthcoming Development Objection and they are required to attend appointments Management and Site Noted – To be Reviewed throughout the day and require a central point Allocations Development Plan to park. If they had to find alternative parking Documents. arrangements then loss of working time will be effected along with employee frustration and we may lose staff as they becomedissatisfied with the parking arrangements available. Additionally we have customers who visit us on a daily basis and we always direct to the car park. I am certain that if Purley loses the car park, not only my business but most businesses will be dramatically effected and we will see the decline of the High Street, just when we were seeing improvements in the recent number of businesses opening over the last couple of years. Indeed if I couldn't find alternative parking arrangements that suited the flexibility of my staff, I would have to consider relocating at sometime in the near future and I am certain my business will decline of which will result in having to make staff redundant, which will lead to increased cost to the government. Our committee felt that in many ways the The next iteration of the Core Mr I Hunter previous document was better set out in that it Strategy will reflect the style of Friends of the County of identified key areas and locations based on the previous document, which Surrey actual communities and Coulsdon and Old as you point out, provided more Observation Coulsdon were identified as one contiguous detail on specific locations. The Noted – To be Reviewed area rather than seperated as in the latest rationale for associating the document. Place of Old Coulsdon with Kenley in the East Spatial Management Area is the similarity in character, constraints, opportunities etc to Places such as Kenley and Sanderstead. Whereas Coulsdon was considered to have more in common with neighbouring Purley. Whilst the 16 Places remain in the Core Strategy, feedback on the concept of Spatial Management Areas suggests it will not feature in the next iteration of the Core Strategy. 1.0 How to use this document Section Representation Recommended Response Full Name Paragraph Organisation Nature of Response Officer Recommendation

1.0 How to use this ii. The need to regenerate and create a The comment is noted. More Revd Charles Trefusis document thriving and vibrant district centre in Purley. explicit policy will be included in 1.9 There is NO heading for this in the Core the pre-submission version of Purley & Kenley Strategy and this is a huge oversight and the Core Strategy regarding Neighbourhood omission. So the following need to be added: retail and the town centre Partnership Shops and businesses: Purley needs the right hierarchy, including more Objection mix and balance of shops and businesses, details of what policy shall Agree – Propose Changes with affordable rent to attract businesses. We mean for each of the 16 Places do NOT want to say that in 20 years time that of Croydon (including Purley). residents are still going to Banstead to do their shopping (which they do at present), and that Purley has a thriving and vibrant district centre. This needs to be incorporated into the Core Strategy. 1.0 How to use this 10 The Core Strategy identifies four The support is welcomed. Mr Michael Mulhern document management areas, which cover the whole of 1.7 the borough. The management areas are Greater London Authority grouped together based on local Support circumstances and future opportunities and Noted aspirations. Within each of the four management areas there are series of connected sub ‘Places'. The Core Strategy proposes quantum's of housing, housing mixes, employment levels and types appropriate for each ‘Place'. These figures are based on local constraints, character and capacity and the Council has prepared detailed appraisals for each ‘Place' to justify the proposed approach, which is welcomed. The Core Strategy Preferred Option reports propose the concentration of development in those ‘Places' with the best capacity for growth and this approach is broadly supported. 1.0 How to use this 11 However, in line with London Plan policy The Core Strategy will be Mr Michael Mulhern document 3A.3 and policy 3.4 of the draft replacement amended to reflect the role of 1.14 London Plan (2009) the Core Strategy should public transport accessibility. Greater London Authority also recognise the role of public transport Objection accessibility and the density matrix in Agree – Propose Changes determining appropriate levels of development for each ‘Place'. 2.0 Executive Summary Section Representation Recommended Response Full Name Paragraph Organisation Nature of Response Officer Recommendation

Cane Hill : Development of this site has The comment is noted. Revd Charles Trefusis suffered due to non action/decision from the Purley & Kenley Council. Hopefully this opportunity to Neighbourhood redevelop Cane Hill is brought forward. Partnership Observation Noted Croydon Metropolitan Croydon as a vibrant retail, business and The comment is noted. Revd Charles Trefusis Centre (CMC) and Environs cultural centre. Spatial Management Area (SMA) 2.9 Purley & Kenley Neighbourhood Partnership Observation Noted Croydon Metropolitan Page 7: 2.10 - last sentence: NOT if The comment is noted Mr I.G.M. Hunter Centre (CMC) and Environs appropriate capacity cannot be found on Spatial Management Area public transport to cater for shoppers and their (SMA) shopping. 2.10 Resident Observation Noted Croydon Metropolitan Page 6: 2.7 - last sentence: Physical work is Disagree. The last sentence of Mr I.G.M. Hunter Centre (CMC) and Environs already under way, without proper public para 2.7 refers to the Spatial Management Area engagement; what is the value of this development of five (SMA) particular look into the future if options are Masterplans not physical work 2.7 already being closed down by the which is 'already under way'. Resident developments now taking place? Objection Disagree – No Change Croydon Metropolitan The document advises that Croydon The comment is noted. Purespace Group Centre (CMC) and Environs Metropolitan Centre ("CMC") has great Limited Spatial Management Area potential for accommodating intensive, but (SMA) positive change. Our client fully supports the 2.7 long-term redevelopment and regeneration of Purespace Group Croydon Metropolitan Centre and its environs. Limited Our client intends to develop the site at Derby Observation Road which is just outside the boundary of the Noted CMC for a mixed use residential scheme, as identified in the West Croydon Masterplan. Overview 2. Executive summary- We are surprised at The comment is noted. The neighbourhood how few ordinary Croydon residents have formulation of the Core Strategy Partnerships Chairs & engaged with the Strategy consultation. Also, (including production of VCs 2.1 our perception is that most of our councillors supporting evidence) has neighbourhood have focused on how the Strategy and Plan followed national policy Partnerships Chairs & will impact their own constituents, but few - guidance in the form of VCs outside of the cabinet and shadow cabinet - Planning Policy Statement 12: Observation have analysed how the borough as a whole Local Spatial Planning. The Noted can make progress in this "age of austerity" content and format of the Core over the Strategy period. Given this Strategy and Infrastructure background, we believe we can play a useful Delivery Plan reflects PPS12 role in providing a challenging independent (and other Planning Policy analysis, by highlighting the "inconvenient Statements), the planning truths" and acting as a "reality check". Our key regulations and other goal is to help our politicians analyse the guidance/best practice e.g. the strategic choices in a rigorous and realistic Department of Communities way in this age of austerity. Although public and Local Government's "Plan engagement to date has been miserable, we Making Manual", CABE's believe that our challenging analysis, "Planning for places: delivering supported by the right publicity, will help in good design through core engaging ordinary Croydon residents. Ideally, strategies" and the Planning we seek to be a catalyst in generating a lively, Inspectorates "Local honest and realistic debate between our Development Frameworks: politicians, the strategy team and residents. Lessons Learnt Examining We support the process of analysing where Development Plan Documents". Croydon is at present, the current Consultation has been delivered opportunities and issues, the 20 year vision in line with the borough's and the actions and infrastructure that's Statement of Community needed to achieve the long term vision. This Involvement and has been process has shone much needed light on the closely aligned with the Local current issues and how we want Croydon to Strateic Partnership's 'Imagine develop over the next 20 years. There are Croydon' project (since some excellent proposals and analysis in the December 2008) which sought Strategy and Plan - the strategy team is to be to establish a long term vision commended for the excellent work that it has for the borough and act as the done to date. However, we have always touchstone and basis for the understood the Strategy to be a Sustainable Community comprehensive long term plan for Croydon Strategy/Core Strategy. In total that encompasses not only spatial planning, over 20,000 people have thus but also economic, cultural, social services far contributed to the above and transport development. The Strategy is mentioned documents very comprehensive on the spatial plan but is (including the Core Strategy). weak in explaining a realistic economic The GLA population projections, development plan - which we believe is vital. Strategic Housing Land We also believe the Strategy has not as yet Availability Assessment (along set out a compelling plan for redressing with local studies) combined Croydon's poor external image. Also, the with various up to date Strategy is currently focused on the renewal of economic evidence base the City Core but is vague as to how the studies have been used to borough's district centres can be revived from formulate the employment and years of slow decay. Executive summary - housing policies in the Core continued Perhaps our most important Strategy. concern is our sense of a major disconnect between the Strategy's ambitious aspirations and the probable economic and funding backdrop of the coming decade. We would urge realistic goals that are achievable, rather than to aim unrealistically high, fail to meet expectations and to suffer the ensuing credibility gap - which is one of the root causes why ordinary Croydon residents have not engaged with the consultation process. In our detailed response, we focus on the following requests and concerns: an honest analysis of why there was so little historic renewal so as we can draw lessons that will help us in the future a much greater focus in the Strategy on job creation and economic growth a detailed assessment of how Croydon can improve its negative image - which we believe is one of the key hurdles in attracting inward investment our belief that Croydon's current and future projected population are much higher than those set out in the Strategy and Plan a Strategy driven by economic/infrastructure development rather than population growth We believe that the current educational, healthcare, transport and cultural infrastructure of Croydon is under real pressure. We are concerned that without a realistic job creation and economic strategy, that there will be a substantial shortfall in local employment opportunities for Croydon's population. why the frontloading of the population growth into the first 10 years of the Strategy period? This initial period is likely to be the most challenging for the funding of social services and transport infrastructure. The job creation and local economic growth prospects for this period are likely to be relatively poor. Surely, we should recognise economic and funding realities and backload any population growth? a restructure of Croydon? Is it right or realistic to assume that the people of Croydon are best served by retaining the borough in its current geographical form over the long term? the need to balance the renewal of the City Core with the regeneration of the borough's district centres - where most residents live Our analysis of the key priorities for Croydon's longterm revival. We believe that there is merit in long term planning. However, many residents would argue that the future is so unpredictable that it's extremely hard to plan even 5 years ahead - let alone 20. To counter this observation, we believe it is vital for Croydon to have a rolling 5 year plan that "talks to" the long term Strategy but that recognises current economic and political realities. There should be a constant benchmarking of progress against the rolling 5 year plan and an overall assessment of how the longer term Strategy is progressing. We believe it would be the height of cynicism if the Strategy was simply a device to squeeze in another 21,510 dwellings with the associated development goals simply gathering dust in a bottom drawer. A key part of our interim response is the detailed actions set out in Appendix I which we believe should underpin a 5 year plan. We have considered how the Neighbourhood Partnerships can contribute to a realistic short term plan and the long-term Strategy. We have a deep knowledge of the "places of Croydon" and will analyse the Strategy for each of these individual places in our final response. We will also set out our analysis of how the district centres can be revived and how a better balance can be achieved in the borough's housing and education provision. Â There are countless examples of poorly thought out and implemented urban regeneration plans that have absorbed a substantial amount of money and time for little tangible benefit. Although Croydon's recent development record is poor and we face a very challenging economic and funding environment, we believe that a realistic and vigorously implemented plan will be of great value to Croydon. Â Executive summary - continued We believe that Croydon has exceptionally dedicated politicians, a talented council executive and many existing strategic assets - excellent public transport links, a well established retail centre, a potential leisure/dining destination and good value office space for smaller companies. We believe that if Croydon can leverage these strengths in a realistic and well implemented plan, significant progress can be made in revitalising the borough. Although there are many examples of failed regeneration attempts, we take heart from what can be achieved by realistic and well implemented strategic planning. We see Glasgow's powerful regeneration during the 1980s as a model for what can be achieved in the face of a low starting point and a challenging economic backdrop. We would welcome a meeting at the earliest opportunity where our Chairman could discuss our interim response with our leading politicians and the strategy team. Population growth and There will have to be a major increase in Comment is noted Mr Charles King housing housing across the borough to accommodate 2.5 the rising and predicted population rise of the East Coulsdon borough . This must be undertaken in way that Residents' Association protects the existing character of all local Observation districts while at the same increasing the Agree - No Change range and types of housing across the whole borough. Â Population growth and 8. A restructure of Croydon? At our meeting The comment is noted. Whilst neighbourhood housing on 14 th October, our consensus was that we the Core Strategy cannot Partnerships Chairs & favour Croydon remaining in its current address non planning matters VCs 2.4 geographical form over the Strategy period. such as the political boundaries neighbourhood We favour measures that will serve to unify of the borough nor make Partnerships Chairs & our diverse borough. In particular, we believe assumptions about planning for VCs that a strong revival of the City Core will serve different boundaries in the Observation to unite the borough. However, as noted in the future, the analysis of the '3 Noted executive summary, we seek to stimulate a distinct areas' detailed in the rigorous thought process by highlighting representation tallies with much realities and promoting an honest assessment of the evidence prepared to of alternative courses of action. Politically, we support the formulation of the perceive that at the central government and Core Strategy including the London government levels, there are a Borough Character Appraisal number of political leaders who are quietly (now incorporating the considering the merits of reducing London's Residential Character current 32 boroughs to a smaller number of Appraisal). The Core Strategy "super-boroughs". Already, in the areas of puts forward the idea of the 16 healthcare and policing, it's evident that Places of Croydon as a means structures are emerging that encompass of ensuring that deprivation is many boroughs. A strong indicator of the way lessened across the borough the "wind is blowing" is the recent decision of while at the same time the local Camden and Islington to appoint a joint Chief characterisitics and unique Executive. We believe that the current budget qualities of the boroughs places constraints will make it even more likely that can be maintained over the plan central government will seek to reduce period. administration costs by introducing super- boroughs. We believe that super-boroughs may generate some cost savings, but that they will damage local democracy. However, as super-boroughs are certainly a possibility in the medium to longterm, then the Strategy should be honest in assessing the impact this may have on Croydon. We believe that a super-borough might have some beneficial economic and development effects for Croydon. It would seem logical that if super- boroughs were to be imposed, then Croydon would be combined with its neighbours Bromley and Sutton. Croydon's City Core is substantially larger than its Bromley and Sutton equivalents - which suggests that any super-borough development funds would be focussed on it. We believe there should be an honest high level analysis of the opportunities and challenges for Croydon arising from super- boroughs. We have listed this analysis as one of our key information requirements in Appendix II. Although we believe that the emergence of super-boroughs is more likely than smaller political structures, the Strategy should be intellectually honest in assessing whether Croydon should be structured into smaller political units given the following facts: in the Strategy evidence base, the "Places of Croydon" highlights the differences between the borough's "suburban" and "urban" wards the income variations in the borough which produces an "unrealistic" average which may lead to a lower level of central government funding Croydon's estimated current population of 341,800 - if correct - is the highest of all of London's 32 boroughs. The average London borough has a population of 235,000 residents. Our neighbouring borough - Sutton - has a population of 188,000. The rapid population growth envisaged by the Strategy indicates a Croydon population of 380,000 within just 21 years (or an even higher 415,000 using our methodology). A restructure of Croydon? - continued The political map shows that Croydon's politics are polarised. There is a widespread perception by ordinary residents that this political polarisation hinders Croydon's development and creates a sense of division within the borough. The updated Strategy goes some way to acknowledging Croydon's lack of homogeneity by recognising 4 spatial management areas. We believe that a more useful and realistic geographic analysis may be obtained by recognising 3 distinct areas of Croydon: Urban Croydon (primarily the north and east) Suburban Croydon (primarily the south but with notable pockets in the north). The transportation, retail and office centre (the "City Core") The circumstances and aspirations of "Urban" and "Suburban" Croydon are very different. These differences find their expression in the political divide. Certainly, there is the perception that Croydon's politics have historically been divisive. It is clear that delivering on the 20 year Strategy will need a unity of political purpose. In assessing the long term vision, it is useful to analyse the key aspirations of residents in the 3 Croydons: Urban Croydon The feedback we receive is that residents are focused on "bread and butter" issues - education, crime and jobs. Both the crime rate and educational attainment compare badly with Croydon's average and with national levels. The development of a vibrant local economy that creates substantial employment is a key long term aspiration. Suburban Croydon Suburban Croydon is relatively prosperous, has low crime rates, high educational attainment and relatively low unemployment - albeit that many of its residents have to commute into central London. A key long-term aspiration of residents is the preservation of the character of their communities - they place great value on its greenness and tranquillity. The prospect of intense urbanisation is anathema to many residents. The transportation, retail and office centre (the "City Core") The City Core is blessed with 3 long-term strategic assets: it has superb public transport links and acts as a travel hub for a large swathe of south London and Surrey - which underpins its retail and employment potential it is an established retail destination that attracts shoppers from well outside the borough it is an established employment centre which contains a number of large public and private sector employers We would note that the City Core acts as a unifying force as many residents from both Suburban and Urban Croydon work there. Also, the great majority of Suburban and Urban residents use the City Core as their primary shopping, dining and leisure centre. If the long term employment, retail and cultural opportunities of the City Core can be maximised, then this will serve to unify the disparate components of the borough. A constant complaint of our Council in recent years has been relative underfunding by central government. In particular, the low level of Croydon's central government funding per head is often compared against the much higher levels of "poorer" boroughs such as Tower Hamlets and Lambeth. Croydon ranks as only the 15th least deprived London borough. However, we are keenly aware of the great differences in deprivation levels within Croydon. Some of the urban wards rank as the most deprived in London, whereas some of the suburban wards are the most prosperous. A restructure of Croydon? - continued We would ask for a careful and honest analysis of the impact of creating separate urban and suburban areas on central government funding. Obviously, if a restructuring would result in a big net increase in overall funding, this might be a significant factor in assessing Croydon's long term strategy. At a public meeting in the run-up to the council elections on 6 th June, reference was made to detailed figures contrasting Croydon's central government funding as against Lambeth and Tower Hamlets. The underlying analysis supporting these comparative figures is one of our key information requirements in Appendix II. South Spatial Management Why do the "improvements" proposed for the Page 72 paragraph 7.51 sets Mr I.G.M. Hunter Area A23 not include Tram? out the proposed long term 2.19 transport strategy for Purley and Resident Coulsdon, this includes Observation reference to developing options Disagree – No Change for tram extensions in the period 2022-2031. South Spatial Management Section 7 South Spatial management Area The comment is noted. Revd Charles Trefusis Area Flood Risk : Pleased to note that "a critical constraint of flood risk in Purley needs Purley & Kenley addressing over the coming period ...... " Neighbourhood Partnership Observation Noted South Spatial Management If the area between South Croydon Bus The area referred to falls within Mr I.G.M. Hunter Area Garage and the Royal Oak Centre (which the CMC and Environs Spatial 2.17 includes Sanderstead Road and Purley Oaks Management Area. The Core Resident Waste Recycling Depot) is not in the South Strategy sets out the indicative Observation Spatial Management Area, and is referred to level of growth within each Agree – Propose Changes in the CMC, South Croydon SMA as Place. It is not appropriate to "environs", it is not surprising that no specific provide details of all potential changes have been recommended and not sites where development can consultation meetings have occurred in its take place. It is the role of the area. I referred to this oversight in the forthcoming Site Allocations previous consultative document tne expected DPD to address this issue. In some reference to be made in this the light of comments received supplement; Why not? There are several the Council will not take forward potential areas capable of development along the concept of spatial the Brighton Road which are NOT referred to management areas into the herein. next iteration of the Core Strategy. 3.0 Housing and Population Growth Section Representation Recommended Response Full Name Paragraph Organisation Nature of Response Officer Recommendation

.39 p21 It is noted that performance or output Corrective action will come will be monitored. However, there appears to through review of the Plan be no reference to procedures for corrective Observation action to be applied, where appropriate. Noted CHAPTER 3: Housing and Population Growth The comment is noted. The CGLP Croydon's Population. The document process of producing a series of CGLP acknowledges that Croydon has a growing masterplans and an Opportunity Observation population with the Metropolitan Centre Area Planning Framework Noted expected to see the most growth. This growth should provide the policy needs to be seen as a potential asset for framework for such Croydon and as such, opportunities need to opportunities to arise. be made available within Croydon Metropolitan Centre ("CMC") to capitalise on this. Housing Need 2009-2031. It is recognised The council considers that it is CGLP that the Local Housing Market Assessment appropriate for CMC to CGLP (LHMA) shows a need for larger units, whilst accommodate more family Objection the majority of housing completions over the housing in order to address the Disagree – No Change past three years have been one and two housing need identified by the bedroom units within the CMC. It should be Local Housing Market noted that this is a result of the function of the Assessment. The Housing CMC which is more appropriate for higher Typologies Study has indicated density housing and flatted developments, that it is possible for Croydon than in the outer suburbs of the Borough. Metropolitan Centre to meet Development sites within the CMC, such as part of this need whilst still Ruskin Square adjacent to East Croydon contributing to the realisation of Station, are not therefore considered a the London Plan aspirations for suitable location for family units. As such, a the Croydon Opportunity Area. greater number of residential units would be proposed and completed within the CMC. In respect of the distribution of new dwellings throughout the Borough, we support the notion in figure 3.7 that the greatest number of dwellings (14,000) will be provided in the ˜CMC & Environs' of which 8,000 dwellings will be in the CMC Proposed Level of Affordable Housing. The The comment is noted. It is CGLP document acknowledges that there is an considered more helpful to CGLP overall need for 35% of new homes to be developers to give an indication Observation affordable and that on average 20% of the likely required provision Noted – To be Reviewed affordable housing has been achieved on of affordable housing on any development sites in Croydon. Although the site in Croydon hence the 20% document advises that consideration will be target and the Dynamic Viability given to the viability of affordable housing on Model have been put forward as the site in question, paragraph 3.23 states that the proposed policy in Croydon "it is economically viable to require affordable for comment. It is housing on any new housing site however acknowledged that there may many new homes are being built". This is not be circumstances when a necessarily true as each development site and development is unable to each residential scheme is subject to provide any affordable housing individual site and economic constraints that or any affordable housing on- will affect the quantum and delivery of site. As stated in paragraph affordable housing. As such, through a 3.22 such schemes will be financial appraisal, it may be proved that a considered on their own merits particular scheme cannot sustain any and whether material affordable housing as a result of other S106 considerations otherwise mean requirements and individual site that fewer affordable homes will circumstances. As such, in terms of the be provided. It is acknowledged provision of affordable housing, the Core that paragraph 3.23 does imply Strategy should note that the London Plan that affordable homes could be seeks the maximum reasonable amount of provided on any development affordable housing from residential and mixed- site. It is meant to say that it is use schemes, having regard to borough viable to set a threshold for affordable housing targets and the need to requiring affordable homes encourage rather than restrain residential below ten units as it is likely that development and the individual circumstances smaller sites would still be of the site (including site costs, availability of viable if they incorporated public subsidy and other scheme affordable homes. This aspect requirements). of the policy will be reviewed in the next consultation draft of the Core Strategy. Population dispersal and related policies are Disagree that the South SMA Mr Barry Atwood severely imbalanced against Purley and the has been unfairly targeted Resident South Spatial Management Area (SMA) in compared to the East SMA. The Objection favour of the East SMA distribution of proposed growth Noted – To be Reviewed is based on a range of factors such as public transport accessibility, supply of development and infrastructure capacity. Feedback from the consultation exercise suggests the concept of the spatial management areas will not be taken forward to the next iteration of the Core Strategy. On behalf of three interested parties- two are Over the lifetime of the plan the Mr Andrew Steen local landowners of adjacent sites in Old Strategic Housing Land White & Sons Coulsdon, which are submitted for Availability Assessment Objection consideration in reviews of the SHLAA. The indicates that there is sufficient Disagree – No Change other is a local housebuilder, responsible for a land in Croydon to achieve the number of small sites within the Borough. We strategic target set out in the consider that the contents should be broadly Draft Replacement London supported. The targets for housing are rightly Plan. The Draft Replacement targetted toward the more sustainable urban London Plan also includes a locations, but perhaps at the expense of presumption against the release promoting more support for the sustainable of Green Belt and Metropolitan development of the smaller urban areas on Open Land across London the edge of the Borough. The document which the Core Strategy should suggests that the Council expects small conform with. windfall sites to come forward and whilst that is probably correct, Planning Policy Statement The projection of the number of 3: Housing states that Councils should identify new homes on small windfall deliverable sites for the first five years. For sites was based on past years 6-10 it states that they should identify development trends which did specific, developable sites and, where have an emphasis on one and possible, for years 11-15 (paragraphs 54-55). two bedroom properties. In Paragraph 59 states that "windfalls should not order to project these figures be included in the first 10 years of land supply forward the location of past unless Local Planning Authorities can provide small windfall developments robust evidence of genuine local was analysed and an circumstances that prevent specific sites assumption made that sites in being identified." It is suggested that there certain locations would in future would need to be very specific unique consist of larger three or more circumstances in the Borough to include bedroom properties. windfall sites within the first 10 years of supply. The reference to windfall development Existing Green Belt, in paragraph 3.9 of the document suggests Metropolitan Open Land and the Council expect to be able to demonstrate Local Open Land designations those circumstances. Experience elsewhere will be maintained and the Core suggests that it is very difficult to demonstrate Strategy is not proposing to a windfall allowance is appropriate. It is remove that protection. The appreciated that circumstances in London are numbers of housing for very different from much of the country - but individual Places are not targets are probably very comparable to neighbouring but projected figures based on districts. If it is possible to demonstrate that past and projected development identified sites would easily meet the borough trends. The only housing targets targets, this will not be a significant issue, but proposed in Core Strategy are should windfall sites be required to meet for the overall number of homes targets, there is a significant risk of the Core in the borough as a whole and Strategy being found unsound. The for the mix of homes in different Inspector's draft report at Reigate and areas of the borough. Any Banstead Core Strategy relates. It is essential proposed development will need that the Core Strategy is sufficiently flexible to to go through the planning deal with any shortfall in anticipated dwelling process for approval and will numbers - particularly if windfalls are required therefore be individually in the first 10-15 years of the strategy. It is assessed for its impact on the understood that the Council is concerned to character of the area including protect residential garden land, but this needs impact on adjacent open space. to be done carefully, to ensure that sustainable sites that might previously have The change to PPS3 removes been gardens are not excluded where the requirement for a minimum development would be in keeping with density of development but surrounding character or gardens are does not remove the particularly large. It is suggested that the requirement for developments Council should be prepared to look at sites to make efficient use of land nor that could assist in meeting requirements, but the requirement for the London are located in areas where development might Plan to have policies regarding not normally be considered satisfactory. For density. The Draft Replacement example, sites in the Green Belt, but London Plan includes a policy surrounded by residential or other and density matrix within it and development, should be considered as having the housing targets in the Core potential and could be kept in reserve for Strategy reflect this matrix. The development should other sites not come Core Strategy is also not reliant forward, or allocated for development if more on the development of private sustainable than alternative sites. gardens to achieve housing targets as an allowance was made for no development on back gardens when preparing the Strategic Housing Land Availability Assessment which informs the Core Strategy housing targets. Proposed Mix of Homes by Size Paragraph The comment is noted. CGLP 3.18 outlines that Croydon has a need for CGLP more 3 and 4 bedroom homes over the next Observation 20 years. In order to meet this need, the Core Noted Strategy proposes to seek larger homes on potential development sites in the Borough and enhance the attractiveness of CMC as a location for families to live. Figure 3.12 outlines that for the CMC, 41% of homes should be 1 and 2 bedroom dwellings and 26% should be 3 or more bedroom dwellings. Figure 3.13 of the document shows that for There is a printing error in CGLP the CMC, the proposed mix of units would Figure 3.13 and the key has CGLP predominantly comprise units of 3 or more been reversed. Figure 7.3 is Observation bedrooms (in excess of 75%). As previously correct. Noted stated, not all development sites within the CMC should be considered appropriate for a high proportion of family units. In order to meet the Mayor's targets for additional housing the CMC will continue to provide the largest proportion of new homes within the Borough. Given the excellent transport links to central London and the potential for growth within the CMC for a range of facilities, the majority of developments will seek to make the best use of land, in accordance with the London Plan, and increase density of development. CGLP therefore consider that it may not be appropriate for the CMC to be transformed for family homes and support facilities for children. 3.38 p21 bullet point 4. Lifetime Homes Consultees are not expected to standards? What is this? What constitutes a resond to all matters. The next lifetime? Is it the normal 60-65 years or version of the plan will have Observation determined according to other criteria? This is afuller glossary to aid Noted – To be Reviewed a prime example of many references to comprehension documents or information, and whilst they may be of relevance to some, they will be absolutely meaningless to the majority of stakeholders - who are being asked to comment. How can they? 3 3.33 p20 bullet point 2. No date is given for The Site Allocations the availability of a Site Allocations Development Plan document Development Plan document (and many together with the Development Observation others). This should contain some of the most Managemnt DPD will follow a Noted relevant information to residents - setting out similar consultation process as the manner in which any development might the Core Strategy .This is likley affect them and / or their lifestyle. commence in Autumn/Winter 2011 Amended Homes Strategy The housing recommendations for Croydon The comment is noted Pauline Dawkins – for consultation seem sound but more 3 bed's in the North where the population is more dense would be CVA good in the South a large elderly population Observation would suggest slightly more 1-2 beds. On Noted areas to increasing housing, in order to increase housing in Central Croydon this would require more flats which are less family friendly. There are still a lot of children born to younger people hence need for larger homes and growing older population should encourage ground/lower floor homes. Yes there are lifts (when they are operating but lower is better for access Amended Homes Strategy CMC & environs (& wider) I was glad to see The support is welcomed. The Joy Prince – for consultation the proposal for 6-15 extra travellers' pitches. Core Strategy is proposing to 3.37 That is not many for a borough the size of set a target of 10 pitches. The Croydon. But now I hear that might be sealed figure quoted in this Support back. If so, it will only lead to unofficial representation is the figure for Noted pitching of the kind we have suffered along need in the borough (as set out the Purley Way and Mill Lane. Keep the in paragrpahs 3.27 and 3.29). pitches. Amended Homes Strategy 5. Croydon's current & projected population. The population projections used neighbourhood – for consultation One of the linchpins of any long term for formulating the Core Partnerships Chairs & development plan is an accurate assessment Strategy are based on the VCs 3.33 of the current population and a robust Greater London Authorities neighbourhood estimate of population growth over the plan (GLA) 2009 Round Population Partnerships Chairs & period. In the case of Croydon, we are Projections (based on housing VCs hampered as the last census was performed data provided by Croydon Objection in 2001 which recorded 330,668 inhabitants. Council). GLA 2009 Round Disagree – No Change However, Croydon does have accurate Ward Level Population information on the level of new housebuilding Projections (with wards during the period since 2001 and its mix assigned to places by Croydon between flats and family homes. This Council based on closest fit) information enables a relatively accurate were used to determine as estimate of population growth arising from accurately as possible the new housebuilding. The average number of different rates of population inhabitants per existing home does change growth for the places of the over time due to societal and demographic borough. The difference trends such as marital breakup and aging. between the population figures Although estimating average inhabitants per in the Infrastructure Delivery existing home is harder, reasonable Plan and the Core Strategy is assumptions can be made. The estimated noted and will be amended in overall population growth utilising this the next drafts. Full details of methodology can be cross verified against the the population figures used in increase in the council tax rolls, GPs patients' the Core Strategy can be found rolls and school enrolment. A robust analysis at takes some time, but a reasonably accurate http://data.london.gov.uk/datafile estimate can be extracted. Given the crucial s/demographics/gla_population_ importance of accurate current population projections_2009rnd_all_wards_ estimates, we are concerned that the Strategy shlaa.xls with an explanation at and Plan variously refer to populations levels http://data.london.gov.uk/docum ranging between 339,000 in 2010 (the ents/DMAG_Update_17- Strategy, page 10) and 341,800 in 2009 (the 2010_2009_Round_Demographi Plan, page 13). We have a suspicion that the c_Projections-shlaa.pdf 341,800 figure is an Office of National Statistics ("ONS") estimate for mid 2008. If this is an ONS estimate, we have concerns. The ONS estimates are relatively high level and can have a large sample error at the borough level - especially when a borough has been experiencing high levels of migration. The lack of consistency on the population figures in the Strategy and Plan extends to the 2031 projections. The Strategy estimates a population of 380,000 (page 10) compared to the Plan's estimate of 375,236 (page 13). Assuming that Croydon's current population is 341,800 as per the Plan, then this implies only 3% population growth from the 330,668 inhabitants recorded in the 2001 census. We have performed our own independent population estimate based on the borough's new home construction and conservative (but realistic) assumptions on average inhabitants per existing household. We have also estimated the population in 2031 based on the Strategy's targeted 21,510 new homes and what we believe are realistic projections of inhabitants per existing household. The comparison of our estimates as against the Strategy/Plan can be summarised as follows: Our Strategy Estimate Estimate Difference Actual 2001 population (per 2001 census) 330,668 330,668 Estimated population 2010 357,000 341,800 15,200 Estimated % growth 2001 to 2010 8.0% 3.4% Estimated population 2031 415,000 380,000 35,000 Estimated % growth 2001 to 2031 25.5% 14.9% The difference of 35,000 between our estimate and the Strategy's for 2031 - the size of a small town - is disturbing. Certainly, our expectation is that the funding of social services, public infrastructure and employment will be under great pressure in Croydon for an extended period. 5. Croydon's current & projected population - continued We would therefore ask for a detailed analysis of Croydon's population - both the 2010 estimate and the 2031 projection. This analysis should be at ward level so as we can use our deep local knowledge to assess whether the estimates and projections make sense. Accurate current and projected population estimates are crucial in the development of a robust Strategy. We have listed this key data as one of our information requirements in Appendix II - which we need for our final response. Amended Homes Strategy A more flexible approach to the provision of The comment is noted. The Cathy Hall – for consultation family housing (three or more bedroom units) LHMA takes the GLA population 3.36 should be adopted. The intention that 100% of projections for the borough as a GL Hearn homes outside District and Local Centres whole and uses data on Observation should have three or more bedrooms does not household composition and Noted – To be Reviewed have regard to the site-specific considerations type of homes currently in including access to playable space and air existence to provide the overall quality that may mean that family housing is need for homes up to 2031 and not appropriate. PPS3 details the key the need for new homes by characteristics of a mixed community. tenure split (i.e. market, social Accordingly, the guidance states that such rented, intermediate) and home communities comprise households such as size (1 bed, 2 bed, 3 bed etc). families with children, single person Croydon has followed the households and older people ' (para. 20). As guidance and methodology of such, three bedroom houses would likely be Planning Policy Statement 3: disproportionately large for a single younger Housing. Family homes are or older person; the need to provide housing defined in footnote 41 of to meet this mixed demand must be taken into paragraph 3.38, which states account. Furthermore, PPS3 states that the that "Family homes in this type of housing should have regard to, inter context are defined as homes alia: Current and future demographic trends meeting minimum design and and profiles; The accommodation amenity standards to be set out requirements of specific groups, in particular, in a Development Management families with older children, older and disabled DPD and providing either 3 or people. more bedrooms or at least 2 double bedrooms." A refined housing policy shall be included in the pre-submission version of the Core Strategy.

The appropiateness of family housing will have regard to site specific considerations and details set out in both the Site Allocations and Development Managemnt DPD Amended Homes Strategy Housing mix The need for homes of different Mr Michael Mulhern – for consultation sizes was identified by the Local 3.36 18 Figure 3.2 of the Core Strategy identifies a Housing Market Assessment Greater London Authority need to provide 62% of new housing as 3 where as the capacity of the Objection bed+ units across the borough by 2031. borough to accommodate new Noted – To be Reviewed However, paragraph 3.36 sets an overall homes was considered by the housing mix requirement of 50% 3 bed+ units. GLA's Strategic Housing Land The Council should clarify why the required Availability Assessment. This mix does not accord with the identified local latter study demonstrated that need. In addition, there is an inconsistency whilst there was an overall need between paragraph 3.36 and figure 3.12. for larger homes in the borough, Figure 3.12 requires that only 48% of new there is insufficient land suitable family homes be provided as 3 bed+ units, for housing and in accordance and this should be addressed. with London Plan policies on which to build larger homes. As the target is based upon the evidence provided by the Strategic Housing Land Availabililty Assessment it is lower than the overall need. Furthermore the percentage in paragraph 3.36 has been rounded to the nearest 5% where as the percentage in Figure 3.12 has been rounded to the nearest 1%. Future drafts of the Core Strategy will use the same rounding methodology to avoid further confusion. Amended Homes Strategy Beyond the CMC the supplement suggests The change to PPS3 removes Mr Brian Madge – for consultation 70% of all homes will be over three bedrooms. the requirement for a minimum 3.36 Given the constraints identified above it is density of development but Brian Madge Ltd hard to see how this can be met within the does not remove the Objection existing urban particularly given the new requirement for developments Disagree – No Change definition of PDL and the removal of minimum to make efficient use of land nor densities. the requirement for the London Plan to have policies regarding These larger houses are thus focused on the density. The Draft Replacement areas where traditionally windfall sites have London Plan includes a policy brought new housing forward but often of a and density matrix within it and smaller size than that now proposed. the housing targets in the Core Frequently such development has involved Strategy reflect this matrix. The garden land. In such areas it is and will Core Strategy is also not reliant continue to be difficult secure redevelopment on the development of private of 3 and 4 bedroom houses alone that will be gardens to achieve housing economically viable. In short any residual targets as an allowance was development appraisal would show that save made for no development on for the rarest of circumstances the back gardens when preparing redevelopment of single houses with two or the Strategic Housing Land three modern 3 and 4 bedroom houses would Availability Assessment which not generate sufficient development value to informs the Core Strategy prompt such redevelopment. As noted above housing targets. the development viability will be further reduced by the Revised Spatial Standards The impact of London Plan and Play area requirements of the Draft requirements on housing Revised London Plan. If the requirement is to delivery has been considered achieve more traditional family houses (a as part of the preparation of the position we share) then more land has to be Draft Replacement London Plan. released otherwise the objective will fail. Over the lifetime of the plan the As this is the key of the strategy we suggest Strategic Housing Land the contingency requires greater detail even at Availability Assessment this stage. We note that past high density indicates that there is sufficient flatted schemes constructed in the Borough land in Croydon to achieve the generally fails to meet family needs. The strategic target set out in the strategy notes that the Borough will not be Draft Replacement London able to meet its future requirements if Plan. The Draft Replacement development is limited to the restricted supply London Plan also includes a of developable land within existing built-up presumption against the release .areas. Accordingly, the Core Strategy will of Green Belt and Metropolitan need to investigate the possibility of some Open Land across London development being accommodated on green which the Core Strategy should belt and metropolitan open land. We stress conform with. that it is critical for the Council to address the implications for growth in these changed times in the Core Strategy and, accordingly, it is essential for the Core Strategy to acknowledge the necessity of utilising a limited amount of land presently in the green belt to address the local growth agenda. Amended Homes Strategy We are supportive of the documents and have The comment is noted. The Susan Sheahan – for consultation minor comments in relation to flood risk points raised shall be 3.38 management and to a lesser extent incorporated into work on the Environment Agency biodiversity. pre-submission draft of the Core Observation Strategy and future DPDs in Noted – To be Reviewed We are generally supportive of this document. Croydon's Local Development We suggest the following amendments and Framework. inclusions:

Page 20, para 3.33 - When preparing the Site Allocations DPD for allocation of 4500 new homes outside CMC, please seek to place these outside Flood Zones 2 and 3

Page 21, para 3.38- Encourage sustainable drainage for new housing developments Page 21, 3.39 - The number of developments where sustainable drainage has been achieved.

The aspirations in Croydon's Core Strategy are very positive and we are hopeful that the changes we have recommended can be incorporated into this document.

Infrastructure Delivery Plan We are supportive of the measures in paragraphs 6.44-6.48 for preventing flooding in at risk areas. We suggest the following amendments and inclusions:

Page Paragraph Comment

49 6.9 & 6.10 We support the definition of green infrastructure from Natural England but would also include floodplains, migration routes and corridors as providing a green link within cities and between villages, towns and cities.

49 6.10 Green roofs should also be included as being part of the green corridor

50 6.12 Floodplains should be included as part of Croydon's blue infrastructure. Floodplains should be protected and managed at a strategic level. They provide valuable areas not only for flood management but also for recreation and biodiversity. Where possible floodplains should be re-established.

84 Biodiversity Action Plan The Environment Agency is a delivery partner for the Wandle Park restoration project

85 Green roofs and walls The Environment Agency is a stakeholder, providing advice and guidance to developers in the form of the Green Roof Toolkit which aims to promote green roofs in new developments and the use of living roofs in smaller developments and extensions where the opportunity arises.

The aspirations in Croydon's Core Strategy are very positive and we are hopeful that the changes we have recommended can be incorporated into this document. Amended Homes Strategy Royal Mail supports the Council's approach in The support is noted. We will Royal Mail Group plc – for consultation aligning their Core Strategy with the Draft notify registered consultees in 3.33 Replacement London Plan (DRLP) and the due course when we have Royal Mail Group plc adoption of the DRLP's target for new homes consultations on the Site Support in the Borough. Further, we support the three Allocations and Development Noted bullet point actions set out under paragraph Management DPDs. 3.3 that identify how 11,900 homes are to be delivered between 2011 and 2021 and a further 7,200 homes between 2021 and 2031. In light of the second and third bullet points, Royal Mail requests to be consulted on the production of the Site Allocations and Development Management Development Plan Documents (DPDs). Amended Homes Strategy Paragraph 3.34 - 3.35 Royal Mail supports the The criteria for determining Royal Mail Group plc – for consultation principle of the Council "Setting an overall planning applications for mixed 3.35 strategic target of 35% of all new homes in the tenure development will be set Royal Mail Group plc Borough up to 2031 to be affordable homes to out in the Development Objection meet the Borough's need" (paragraph 3.34). Management DPD. In line with Disagree – No Change We also support the Council setting an initial paragraph 3.22 of the current 20% target of homes on sites providing ten or consultation the impact of more units to be affordable (paragraph 3.35). providing affordable housing on We consider that the Council's approach to the viability of development will reviewing affordable housing targets annually be considered. The Local (paragraph 3.35) is sensible given the Housing Market Assessment continuing difficult economic climate. As such, indicates that the need in we support the approach proposed in the Croydon for social rented and Amended Homes Strategy. Notwithstanding, intermediate housing is better we seek an amendment as detailed below. met by setting a 70:30 ratio on The Council acknowledges in paragraph 3.22 new developments. The Draft that "when negotiating the percentage of Replacement London Plan affordable homes on a site with a developer target is a pan-London target consideration will be given to the viability of and is not to be applied rigidly in affordable housing on the site in question. The each borough. extent to which providing affordable housing would prejudice other planning objectives of developing the site will also be considered." However, this is not reflected within the Amended Homes Strategy. As such, we request that the Council amend the wording of paragraph 3.35 to read as follows: "3.35 Setting an initial target for the first year of the plan for 20% of homes on sites providing ten or more units to be affordable homes based on the viability of providing affordable homes on mixed tenure developments, whereby each scheme is to be considered on a site by site basis: We consider that this amendment would provide certainty to applicants that in assessing the percentage of affordable homes to be provided on development sites in the Borough, the Council will apply policy flexibly, to ensure housing delivery. Policy 3.12 (Affordable housing targets) in the DRLP identifies that boroughs should seek to maximise affordable housing provision and within this "seek to ensure that 60 per cent is social housing and 40 per cent is intermediate housing." As with the Council's approach to the housing targets in paragraph 3.33, we request that the Council amend their strategy and any related policies to align with the DRLP. Specifically, we request that the Council amend the first bullet point under paragraph 3.35 to read as follows: "These should be at a ratio of 60:40 between social rent/low cost home ownership or intermediate rent; and" Amended Homes Strategy Accommodation for Families- In principle It is recognised that applying a Royal Mail Group plc – for consultation Royal Mail supports the Council setting an blanket target on each scheme 3.36 overall strategic target of 50% of all new could impact on development Royal Mail Group plc homes in the borough to provide suitable viability and it is not the Objection accommodation for families (paragraph 3.36). intention to hinder development Noted We recognise that that the Council considers in this way. Each planning this will address the need for more 3-and 4- application will continue to be bedroom homes across the Borough over the considered on its merits. next 20 years. We support the flexibility built However it is important to set a into this paragraph by the Council's choice of target in order to provide wording including "targets", "seeking" and guidance to developers as to "aspiring". Notwithstanding, Royal Mail the Council's aspirations for request that the text in this paragraph is Croydon, to help in meeting the amended to further recognise that the need for different types of provision of family housing units could homes in Croydon, and against potentially have a significant impact on the which to assess the relative viability of proposed developments. merits of any application for Specifically, we request that explicit reference planning permission. is made to the Council assessing applications on a flexible and site specific basis subject to the viability of the development in question. We recognise the requirement to identify areas in the Borough with potential capacity and need for more family homes (bullet points one and two under paragraph 3.36). However, we reiterate our request that the Council applies their policies flexibly, allowing an assessment of the provision of housing in the Borough on a site specific basis. This accords with Planning Policy Statement: 3 Housing (PPS3), which states that there should be a flexible and responsive supply of land that is managed in a way that makes efficient and effective use of land, including re-use of previously-developed land, where appropriate. Amended Homes Strategy Play Space for Children- Royal Mail recognise It is not necessary to duplicate Royal Mail Group plc – for consultation that children require access to satisfactory guidance on flexibility and 3.36 play space. However, we request that the innovation that is already Royal Mail Group plc Council amend the policy to allow more included within the Mayor's Objection flexibility, by recognising that the provision of Supplementary Planning Disagree – No Change such space should be appropriate to the form, Guidance. The criteria in the scale and type of development proposed. This paragraph 3.36 does so by request accords with the Mayor's adopted default by requiring certain Supplementary Planning Guidance (SPG) developments to provide an "Providing for Children and Young People's adequate amount of play space Play and Informal Recreation", which as set out in the Mayor's SPG. acknowledges that there may be scope for innovative solutions for the provision of play and recreation space outside of the SPG guidelines if they meet the criteria for quantity, quality and access. Amended Homes Strategy We acknowledge the importance of ensuring The objection is noted and the Royal Mail Group plc – for consultation that new homes in the Borough meet the criteria will be amended in line 3.38 needs of residents over a lifetime and with the other elements of Royal Mail Group plc contribute towards sustainable communities. paragraph 3.38 to say "All new Objection However, Royal Mail is concerned regarding homes SHOULD achieve the Agree – Propose Changes the Council's stipulation that "all new homes standards set out in the draft must achieve the standards set out in the draft London Housing Design Guide". London Housing Design Guide" . The draft London Housing Design Guide (DLHDG) identifies within its Introduction that, "the guide is not a statement of planning policy" and that the contents are the Mayor's aspirations for housing in London. The guide goes on to state on page nine that "This guide...does not, in itself, constitute either a statement of planning policy or Supplementary Planning Guidance." We consider that the Council's requirement to achieve the standards set out in the DLHDG is ambiguous, as the DLHDG itself identifies two standards with differing priorities for compliance. The two standards are ˜Priority 1' and ˜Priority 2', of which "˜Priority 1' must be met in full, whilst ˜Priority 2' are strongly recommended as best practice, but are not required." As such, Royal Mail strongly requests that the Council amend the wording within the Core Strategy to read as follows: "All new homes should aim to achieve the standards set out in the draft London Housing Design Guide;" We consider that this amended wording will remove the ambiguity identified above and provide flexibility to ensure housing delivery. Further, this approach also accords with that taken in the bullet points regarding the Code for Sustainable Homes and lifetime homes. (i.e. the bullet points for the same begin "all new homes should ..." (our emphasis) rather than "must". Amended Homes Strategy Page 20: 3.36 What is the situation where 9 or With the current wording Mr I.G.M. Hunter – for consultation less units designed for families are situated developments of nine or less 3.36 adjacent to sites which themselves do not units designed for families Resident justify provision for play space? would not be required to provide Observation any play space for children on Agree – Propose Changes site due to the unviability of doing so. The next draft of the Core Strategy will be amended to ensure these developments are required to contribute through Community Infrastructure Levy or S.106 contributions towards the provision of play space for children in the area of the development. Amended Homes Strategy The true East SMA comprises Selsdon, The decision was taken to Mr Barry Atwood – for consultation Shirley and Addington, which have a relatively include Sanderstead and better infrastructure than Purley and could Kenley & Old Coulsdon within Resident bear a proportionately greater share of the the East SMA because they Objection overspill were the public transport services share topographic and public Noted improved. The extension of Tramlink in this tranpsort characteristics with area and to Sanderstead could spread both the other Places in the East the overspill and the environmental benefits of SMA. Whilst the 16 Places reduced car dependency. remain in the Core Strategy, feedback on the concept of Spatial Management Areas suggests it will not feature in the next iteration of the Core Strategy. Amended Homes Strategy Page 21: 3.38 - Additional Core Strategy This is too detailed for the Core Mr I.G.M. Hunter – for consultation Requirements; All new homes must have Strategy which is a strategic 3.38 provision for off-road parking for cars - if document. Car parking Resident necessary beyond the present 2-car limit per standards will be considered by Objection household, which should be discontinued in the Development Management Noted the interest of Social Cohesion (ie; people will DPD wish to visit relatives at festival times without the inconvenience of carrying gifts etc. on Public Transport, but will want places to park close to their relatives or friends). Amended Homes Strategy Proposed Level of Affordable Housing The comment is noted. It is Purespace Group – for consultation considered more helpful to Limited 3.35 The document acknowledges that there is an developers to give an indication Purespace Group overall need for 35% of new homes to be of the likely required provision Limited affordable and that on average 20% of affordable housing on any Observation affordable housing has been achieved on site in Croydon hence the 20% Noted – To be Reviewed development sites in Croydon. Although the target and the Dynamic Viability document advises that consideration will be Model have been put forward as given to the viability of affordable housing on the proposed policy in Croydon the site in question, paragraph 3.23 states that for comment. It is "it is economically viable to require affordable acknowledged that there may housing on any new housing site however be circumstances when a many new homes are being built". This is not development is unable to necessary true as each development site and provide any affordable housing each residential scheme is subject to or any affordable housing on- individual site and economic constraints that site. As stated in paragraph will affect the quantum and delivery of 3.22 such schemes will be affordable housing. As such, through a considered on their own merits financial appraisal, it may be proved that a and whether material particular scheme cannot sustain any considerations otherwise mean affordable housing as a result of other S106 that fewer affordable homes will requirements and individual site be provided. It is acknowledged circumstances. that paragraph 3.23 does imply that affordable homes could be As such, in terms of the provision of affordable provided on any development housing, the Core Strategy should note that site. It is meant to say that it is the London Plan seeks the maximum viable to set a threshold for reasonable amount of affordable housing from requiring affordable homes residential and mixed-use schemes, having below ten units as it is likely that regard to borough affordable housing targets smaller sites would still be and the need to encourage rather than viable if they incorporated restrain residential development and the affordable homes. This aspect individual circumstances of the site (including of the policy will be reviewed in site costs, availability of public subsidy and the next consultation draft of the other scheme requirements). Core Strategy. Amended Homes Strategy The support is welcomed. Purespace Group – for consultation Amended Homes Strategy Limited 3.35 Purespace Group The document sets out an initial target (for the Limited first year) of 20% of homes on ten or more Support units should be affordable, based on the Agree - No Change viability of providing affordable homes on mixed tenure developments. Our client supports the approach that the provision of affordable housing must be based on financial assessment with individual site and scheme constraints taken into account. Amended Homes Strategy Paragraph 3.36 advises that there is an Development viability is a Purespace Group – for consultation aspiration for "20% of all new homes within material consideration in the Limited 3.36 the CMC to have 3 or more bedroom by determining of planning Purespace Group 2031". As above, the overall mix of units (and applications. However the need Limited therefore the proportion of affordable) should for different homes in Croydon Objection be based on scheme viability. and building a mixed and Noted balanced community in Croydon Metropolitan Centre will also have to be taken into account if it is included within the adopted Core Strategy. Amended Homes Strategy 20 Paragraph 3.36 notes that 100% of all This will be reviewed as it is Mr Michael Mulhern – for consultation homes outside local and district centres agreed that it may be overly 3.36 should be provided as 3 bed+ units. This restrictive and may not meet the Greater London Authority policy may be overly restrictive. In certain need for smaller homes in many Objection circumstances it may not be appropriate, or areas of the borough. Noted – To be Reviewed feasible, to provide a 3 bed+ unit and it is recommended that the policy should allow for some site specific flexibility. Amended Homes Strategy Since the last consultation a number of The change to PPS3 removes Mr Brian Madge – for consultation government changes have occurred that are the requirement for a minimum 3.33 already and will continue to impact on housing density of development but Brian Madge Ltd supply. The revised PPS 3 (June 2010) does not remove the Observation introduced significant changes in policy requirement for developments Disagree – No Change direction. These are; to make efficient use of land nor the requirement for the London A change regarding minimum densities Plan to have policies regarding density. The Draft Replacement A change to the definition of PDL to exclude London Plan includes a policy private gardens and density matrix within it and the housing targets in the Core These changes have already impacted on Strategy reflect this matrix. The housing yield and are not reflected in the new Core Strategy is also not reliant strategy. on the development of private gardens to achieve housing Further changes at the London wide level (the targets as an allowance was draft Replacement London Plan) such as made for no development on those to housing standards, flat sizes, back gardens when preparing playspace and construction standards (such the Strategic Housing Land as ceiling heights) will further have a Availability Assessment which downward effect on housing yields. informs the Core Strategy Independent research has indicated that the housing targets. new space standards will result in fewer homes and the cost of development will rise The impact of London Plan with a consequent affect on price. requirements on housing delivery has been considered as part of the preparation of the Draft Replacement London Plan. Amended Homes Strategy 22 With regards the Housing Design Guide, Croydon would like to adopt the Mr Michael Mulhern – for consultation the Council should be aware that the Mayor's standards of the Mayors' 3.38 Housing Design Guide currently only applies Housing Design Guide for all Greater London Authority to LDA owned land and will only apply to HCA new homes built in Croydon. It Observation funded projects in their next affordable is noted that the Mayor will Noted housing funding round from 2011. However, intially only apply the standards following the current London Plan EiP, the to HCA funded projects until Housing Design Guide will be incorporated they are adopted in the new into a new London Plan Housing SPG, and London Plan but it is not will be adopted following adoption of the new considered that this should London Plan. impact on Croydon's desire to Housing provision use the guide and its standards more widely. Amended Homes Strategy We also note that the Council proposes As stated in paragraph 3.22 the Mr Keith Hearn (Minerva) – for consultation incorporating the ‘dynamic viability model' for extent to which providing 3.35 affordable housing into planning policy. We affordable housing would CBRE are concerned that this rudimentary approach prejudice other planning Objection will not allow for wider considerations to be objectives of developing a site Disagree – No Change taken into account, such as wider benefits will also be considered. The which a scheme delivers (for example Council is committed to improvements to the public realm and quality securing the maximum benefits of retail offer), when deciding how much from each development site affordable housing a development should including the provision of provide. We stress the importance of keeping affordable housing. It is policies flexible to ensure that they can be therefore considered that effective, in accordance with the ‘tests of setting a requirement for 20% soundness' set out in PPS12. affordable homes on sites initially is appropriate and this will be reviewed annually in line with development viability at any given time. If there are material considerations for not achieving the 20% affordable homes requirement then these will be considered on a case by case basis as set out in paragraph 3.22. Amended Homes Strategy Gypsy and traveller sites The comment is noted. Mr Michael Mulhern – for consultation 3.37 31 The Core Strategy identifies a local need to Greater London Authority provide 10 additional Traveller and Gypsy Observation sites within the borough. During the London Noted Plan EiP the Mayor issued an update on London Plan targets, in which he stated "that setting detailed targets is not the most effective or fair way to deliver real improvements in the provision of pitches for gypsies, travellers or travelling show people. He has also expressed detailed concerns about the extremely prescriptive process that was mandated for the drawing up of these targets. Accordingly, he intends to replace the current policy 3.9 and table 3.4 with a different policy approach that will enable boroughs and stakeholders to meet required needs in light of local circumstances." 32 This change is now set out in a minor alteration to the London Plan, which is currently out for public consultation and is due to be examined in December 2010. This minor alteration does not set a pitch target for boroughs. Amended Homes Strategy 29 The identification of broad locations for The support is welcomed. Mr Michael Mulhern – for consultation housing delivery and the commitment to 3.33 preparing the DPD and OAPF are welcomed. Greater London Authority Support Noted Amended Homes Strategy 25 The Core Strategy provides further A technicnal housing supply Mr Michael Mulhern – for consultation guidance as to how and where these units note will be prepared providing 3.33 would be delivered, including: further details on housing Greater London Authority delivery to support these figures. Observation A Site Specific Allocations DPD providing Agree – Propose Changes detail on the delivery of 5,400 new homes in The relationship between the areas outside the Croydon Metropolitan Centre OAPF and the LDF will be made clearer in the pre- An OAPF providing detail on 8,000 new submission draft of the Core homes in the Croydon Town Centre Strategy.

A Development Management DPD providing detail on the remaining units across the borough

26 It is recommended that as part of the Core Strategy submission, Croydon Council should provide further detail on housing delivery to support these figures. The Council should prepare a technical housing supply note providing detail on; housing supply sites/land for years 1 to 5; and for years 5 to 10; and should also identify broader areas for housing delivery for years 10 to 15. This information should also be provided to the GLA for review.

27 In addition, the Core Strategy should provide a clearer explanation as to the role of the OAPF and its relationship to the LDF Development Plan Document process. Amended Homes Strategy The latest version still has an emphasis on The Core Strategy is a 20-year Mr Brian Madge – for consultation significant growth in Croydon as identified in plan. Whilst current conditions 3.33 the earlier consultations. In this respect it still are less favourable to some Brian Madge Ltd refers to a pre-recession world where attitudes development types compared to Objection to development were very different. The previous years they are unlikely Disagree – No Change evidence of the past two years and the to remain as they are now for governments own predictions suggest the the life time of the Core fundamentals of the development industry Strategy. Therefore the Core have significantly changed and conditions are Strategy will plan for growth in unlikely to return to pre 2008 conditions. Croydon up to 2031 including significant development within The key changes of the past two years are; Croydon Metropolitan Centre, whilst recognising that in the That larger flatted schemes are unlikely to be short term past rates of implemented largely as a result of the development may not be changed nature of development economics. realised. Overall the Core Strategy is not reliant on any The financial institutions are now more one type of development to conservative as to lending for development achieve the housing target as it where cash flow is not secured. is proposing a balance between larger and smaller homes in the These changes are evidenced by the number borough. and type of applications received by the Council in the past two years and the current approach to site assembly. These significant changes fundamentally challenge the housing targets and likely delivery. In short these factors alone will impact on future housing types and densities. Amended Homes Strategy 23 PPS3 requires the use of a DPD to set Details of why it is considered Mr Michael Mulhern – for consultation deliverable housing targets for the first ten the housing target contained 3.33 years of the plan, and that broad locations can within the Core Strategy is in Greater London Authority then be used for years 11 to 15. The Core general conformity with the Objection Strategy provides a broad 20-year housing London Plan will be included in Agree – Propose Changes target of 21,500 new homes across the the pre-submission draft of the borough by 2031. As the Core Strategy is a Core Strategy. 20-year planning document the inclusion of a 20-year housing figure is broadly acceptable. The 21,500 new homes are The Council has explained that the housing broken down as follows: supply would be achieved as follows: 2.400 homes under construction 11,900 conventional supplies homes in the as of 31st March 2009 first 10 years of the plan until 2021 11,900 conventional homes in the first ten years of the plan up 2,200 non-self contained/ vacant homes for to 2021 the entire 20 years of the plan until 2031 7,200 conventional homes in the second ten years of the plan 7,200 homes in the second 10 years of the between 2021 and 2031. plan between 2021 and 2031 The Core Strategy is in general 24 For the first ten years of the plan, until conformity with the Draft 2021, this equates to 13,010 new homes. The Replacement London Plan draft replacement London Plan (2009) target of 12,210 conventional proposes a target of 13,300. The identified new homes between 2011 and target in the Core Strategy does fall below the 2021 as it is proposing a target London Plan target. The Council has not of 11,900 new homes, a raised any concerns with the housing targets shortfall of just 310 units. The in the draft replacement London Plan (2009) remaining 1,100 units of the and as such should explain the shortfall draft replacement London Plan between the identified housing target and the target is made up of non-self delivery breakdown. In addition, how the contained units and vacant housing is being provided is not clear from the properties brought back to use. submitted information, and it is recommended These are not referenced in the that this should be more clearly set out within current draft of the Core a submitted plan. Strategy as it would just duplicate the draft replacement London Plan. A reference to them will be included in the pre- submission draft of the Core Strategy for clarity. In line with the draft replacement London Plan no allowance has been made for non-self contained units or returning vacant homes to use after 2021.

Croydon Council did not raise the issue of the shortfall of 310 units when submitting representations on the draft replacement London Plan due to the shortfall only arising following further evidence on the ability of Croydon Metropolitan Centre to provide new homes being provided by the Housing Typologies Study. This study was prepared and published after the start of the Examination in Public for the draft replacement London Plan. Amended Homes Strategy The Office of National Statistics-published It is agreed that the wording in Cathy Hall – for consultation Social Trends (July 2010) identifies an paragraph 3.36 should be 3.36 increasing trend towards smaller household amended as requiring 100% of GL Hearn sizes i.e. 3.1 people per household in 1961 all homes outside of Croydon Objection falling to 2.4 people in 2009. This supports the Metropolitan Centre and district Noted – To be Reviewed figures outlined in the most recent national and local centres is not flexible census (2001), which states that in Croydon enough to meet the need to some 46,069 people lived in single person develop balanced communities households in comparison to 45,002 people in in the borough. However it is married couple households. The need for not appropriate to set a target of flexibility in the application of targets to 70% of all homes in the respond to market demands is important.  borough to have three or more Therefore we would suggest that the policy is bedrooms as there is amended as follows:  ‘3.36 Setting an insufficient land to do so and overall target of 50% of all new homes in the still achieve the Draft borough to provide suitable accommodation Replacement London Plan for families. This will be achieved by: Setting a target up to 2021. target of 70% of all new homes outside CMC to have 3 or more bedrooms and seeking 100% of homes to have 3 or more bedrooms on sites outside of District and Local Centres , subject to site specific considerations .' Amended Homes Strategy Housing standards The support is welcomed. Mr Michael Mulhern – for consultation 3.38 21 The Core Strategy commits to meeting Greater London Authority Lifetime Homes standards; the provision of Support 10% of units as wheelchair accessible units; Agree - No Change and that new residential units would be provided in line with the Mayors emerging Housing Design Guide. These commitments are welcomed. Amended Homes Strategy 19 There is also an inconsistency with regards Paragraph 3.36 does not define Mr Michael Mulhern – for consultation what constitutes a larger family home within family homes as having 3 or 3.36 the Core Strategy. Paragraph 2.5 notes that a more bedrooms. Family homes Greater London Authority family home should be provided as 2-bed, 4- are already defined in footnote Objection person units and larger; however, paragraph 41 of paragraph 3.38 which Disagree – No Change 3.36 identifies a family home as 3 bed+ units. states that "Family homes in A clear definition of family housing should be this context are defined as provided. homes meeting minimum design and amenity standards to be set out in a Development Management DPD and providing either 3 or more bedrooms or at least 2 double bedrooms." Amended Homes Strategy 14 In light of this evidence, the Council is In Blyth Valley Borough Council Mr Michael Mulhern – for consultation proposing to introduce an affordable housing vs Persimmon Homes (North 3.35 target of 20% on all new sites that provide East) Ltd the Court of Appeal Greater London Authority more than 10 residential units for the first year ruled that Blyth Valley Borough Objection of the plan. This 20% target would Council's Core Strategy should Noted – To be Reviewed subsequently be reviewed each year as part not have been found sound as of the Council's ‘Annual Monitoring Review' the policy on affordable housing that would take account of updated viability had not taken into account the assessments. Each year a new affordable economic viability of affordable housing target would be agreed on and housing. In order to consider managed via the Dynamic Viability Toolkit. the economic viability of affordable housing within 15 The approach is broadly understood, but developments in Croydon an we would caution against using its results to Affordable Housing Viability unduly constrain affordable housing provision, Assessment was commissioned which should always come down to delivering which incorporated a Dynamic the maximum reasonable amount on a site- Viability Model. The purpose of specific basis. This model can be this model was to ensure that appropriately applied as a local indicator any policy target included within within the Annual Monitoring Report. the Core Strategy was both economically viable (therefore 16 In addition, it does raise some other meeting the requirements of concerns that need to addressed in greater PPS3) and also didn't unduly detail before it can be supported; restrict the amount of affordable housing developed in Croydon The data used (Halifax house price index and in future years if the viability of BCIS cost index) are not available at local development improves. authority level and might therefore not accurately reflect local viability. The 20% target reflects the viability of residential The Council should confirm what type of site development in Croydon in has been used to determine the figures. For 2009. It is acknowledged that example; using a ‘typical site' might be less this figure needs to be reviewed useful in areas that typically feature a diversity as it may not reflect viability of of sites coming forward for housing, another residential development on the option of looking at dynamic viability across a date the Core Strategy is range of sites and coming to a judgment on a adopted. The figure derives borough-wide target potentially lacks from the Affordable Housing transparency. A further discussion on this Viability Assessment which would be welcomed. looked at the viability of affordable housing on a range How would the initial short fall in affordable of development sites across the housing provision be addressed in the long borough and reflects the most term i.e. ensuring the borough wide need for reasonable target across the 35% affordable housing would be achieved by borough. A higher target may 2031? Could this result in new development be viable on some sites and later in the plan period having to provide more some sites may not achieve than 35% affordable housing. even 20%. However a target that is higher than 20% would How much planning weight can be not have been reasonable in apportioned to an amended affordable early 2009 as the majority of housing figure that is set out in an Annual locations in the borough would Monitoring Report? not be able to support a higher target. Further explanation as to the role of the dynamic viability model in determining the Future targets are and will be level of affordable housing in the future is included within the Core required? Strategy as part of the Dynamic Viability Model matrix to ensure that the target is transparent. The indices that are used to assess whether the target needs to be amended are publically available (subscription only for BCIS data) so it is possible to work out the likely target by refering to the Core Strategy and these indices. As the matrix is included in the Core Strategy itself it is reasonable to report changes to the indices in the Annual Monitoring Report as these are factual rather than making policy.

The Halifax Price Index, BCIS cost index and Valuation Office Industrial Land Value are considered appropriate indicators as they are available to developers, transparent and in the case of the Halifax Price Index, is adjusted to reflect a balance of the mix of properties sold in the borough (Land Registry data may be distorted by high sales of a particular property type in the borough). Amended Homes Strategy Affordable housing The Local Housing Market Mr Michael Mulhern – for consultation Assessment is available to 3.34 12 The Core Strategy proposes an overall download from Croydon Greater London Authority affordable housing target for the borough of Council's website at Observation 35% up until 2031. This affordable housing www.croydon.gov.uk/contents/d Noted figure is based on an assessment of local epartments/planningandregener need and is evidenced in the Council's ‘Local ation/pdf/912686/917223/croydo Housing Market Assessment'. Identifying a nstrathousingmarketassesmodel borough wide affordable housing target based ling and on local evidence is supported, however, this www.croydon.gov.uk/contents/d information should be provided to the GLA for epartments/planningandregener review. ation/pdf/912686/917223/localho usingmarketassessment. Copies will be sent to the GLA for review. Amended Homes Strategy PPS 12 requires a Core Strategy to be flexible The Core Strategy adopts a Mr Brian Madge – for consultation to enable it to deal with changing flexible approach. The targets 3.33 circumstances. We would suggest the Core are borough wide and if one Brian Madge Ltd Strategy now fails to have such flexibility. If place is unable to provide as Objection future housing cannot be achieved at the many homes as anticipated Disagree – No Change required level in CMC and the north there is then the proposed homes no fallback position. strategy is flexible enough to allow development elsewhere in the borough on suitable sites. The total unconstrained capacity of the borough identified by the Strategic Housing Land Availability is 22% higher than allowed for within the Core Strategy to ensure there is flexibility within the borough to accommodate development. Housing Need 2009-2031 s 2031 looking too far ahead in view of the Government Guidance is that trend towards escalating rate of social and the Core Styrategy should look economic change in modern times? 3.33 p20 at least 15 years beyond the Objection bullet point 1. likely date of adoption. This Disagree – No Change takes us well into the 2020's. 2- 31 is a convenient date aligned to current censuses Housing Need 2009-2031 There is a need for more family housing in the The Local Housing Market Mr Charles King 3.4 north of the borough and a greater need for Assessment takes the GLA East Coulsdon both family and smaller two bedroom houses population projections for the Residents' Association and flats in the south to enable young people, borough as a whole and uses Objection first time buyers and older people to downsize data on household composition Noted while staying in the vicinity of their existing and type of homes currently in home existence to provide the overall need for homes up to 2031 and the need for new homes by tenure split and home size. Croydon has followed the guidance and methodology of Planning Policy Statement 3: Housing, this sets out how Local Planning Authorities should assess housing need and land availability for new housing. Housing Need 2009-2031 The most serious problem currently facing Housing needs arising from Ms Rose Freeman 3.4 mankind is not climate change nor the natural change and population The Theatres Trust financial crisis but over-population, a subject movement have been assessed Objection that politicians and councils are reluctant or and need to be addressed if all Disagree – No Change unwilling to confront. The shortage of houses households are to have a and clamours for more are caused simply by decent home which is too many people. Croydon is already over- Government Policy. The populated, with more than its fair share of replacement London Plan immigrants, so that any increase in population requires Croydon to have at density would lead to even further pressure on least 1330 new dwellings on schools, health and social services, with more average per year. This figure is traffic and congestion, and a lower quality of informed by population life. Consequently, I strongly oppose any forecasts. increase in the number of houses in the area - (particularly in Purley with its heavily congested A22 and A23 and where there have been may unwanted in-fillings along Foxley Lane in recent years) - as proposed in the Council's Preferred Core Strategy for Croydon. The Council should firmly resist Government pressure to build more houses in the borough. We should not wish to bequeath a more densely populated town to our children and grand-children. Housing Need 2009-2031 7. Dangers of frontloading the proposed The population projections used neighbourhood population growth We are concerned that the for formulating the Core Partnerships Chairs & proposed population growth is "front-loaded" Strategy are based on the VCs 3.4 in the period up to 2021. There are currently Greater London Authorities neighbourhood 2,400 homes under construction in the (GLA) 2009 Round Population Partnerships Chairs & borough. The Strategy envisages an Projections (based on housing VCs additional 12,000 homes will be built between data provided by Croydon Objection 2011 and 2021. By way of contrast, only 7,200 Council). GLA 2009 Round Disagree – No Change additional homes are envisaged in the period Ward Level Population 2021 to 2031. It is clear that central Projections (with wards government funding is likely to be severely assigned to places by Croydon constrained during the Strategy's initial 10 Council based on closest fit) year period. Also, this period is likely to be a were used to determine as very challenging one for job creation. We accurately as possible the would therefore ask that the population growth different rates of population is "back-ended" to the final 10 years of the growth for the places of the Strategy period, when hopefully the local borough. Croydon has followed economy and government finances are the guidance and methodology staging a recovery. of Planning Policy Statement 3: Housing, this sets out how Local Planning Auhthorities should assess housing need and land availability for new housing. How much land is available If the past development trends (emphasis on The projection of the number of Mr I.G.M. Hunter in Croydon for new homes? 1-bed and 2-bd residences) are changing new homes on small windfall 3.9 because of the urgent need for 3-4 bedroom sites was based on past Resident properties to relight the housing market, surely development trends which did Observation the size of plots will be changed? (ie; large have an emphasis on one and Noted – To be Reviewed house, 25ft garden, garage or off-street two bedroom properties. In parking for more than one (larger sized car). order to project these figures Unless developers are going to be allowed forward the location of past (wrongly) to reduce the size of the properties small windfall developments and ignore modern vehicle sizes when it was analysed and an comes to car spaces, the number of houses assumption made that sites in foreseen to be built up to 2021 will be less that certain locations would in future estimated will it now? Page 13: 3.10 Do these consist of larger three or more finds reflect a reduction in internal house bedroom properties. There is no dimensions (see 3.9 above) and if so why? assumption about reducing the size of new homes, rather that they will be required to meet the minimum standards set out in the Draft London Housing Design Guide. This is is too detailed for the Core Strategy which is a strategic document.The car parking standards will be considered by the Development Management DPD. How much land is available Opposes infill / back land and garden The comment is noted. Para Mr P Kelly in Croydon for new homes? developments within North Shirley and other 3.15 of the Core Strategy 3.9 suburbs of Croydon where multiple units Supplement indicates a Resident (structures) are being squeezed in between strengthening of policy to Observation adjoining private residences on any residential protect back gardens. The GLA Noted land sometimes not even the size of a Tennis Strategic Housing Land Court which Developers and the Planning Availability Assessment (Small Department wrongly categorise as Brownfield site allowances) also estimates sites in order to allow development up on back that outside CMC over 4,000 garden land which is overdeveloped. Not only new homes can be built on does this practice of infill development having smaller sites without building on structural impacts upon adjoining properties back gardens. but it also has the effect of OVERCROWDING MORE people into what is a small suburb where space is already limited and roadways inadequate to cope with the additional volumes of traffic ( vehicles ) which end up using them. The Council are probably already aware of the situation facing Croydon's suburbs and the Council must realise that our established communities have reached saturation levels if not surpassed them. A logical alternative to insinuating these over developed sites into our suburbs would be to use an existing expanse of open land upon which you could build at least 100 or more homes in the same location. How much land is available 3.9 (IDF) Demand has risen (for primary The Core Strategy already Mr Robert Rudman in Croydon for new homes? schools) and will sharply rise. recognises the need to enhance 3.9 infrastructure such as primary Resident schools in line with dwelling Objection growth. The precise quantity of Noted – To be Reviewed expanded forms and schools will be provided in the IDP. How much land is available I have previously commented on the number The comment is noted. Mr Brian Madge in Croydon for new homes? of sites in your Five-Year Supply of Comments made on earlier 3.6 Deliverable Sites for Housing that are unlikely consultations will also be Brian Madge Ltd to come forward. Those comments still apply. considered prior to preparing Observation the pre-submission draft of the Noted Core Strategy. Proposed level of The following comments are submitted on The Croydon Metropolitan Menta affordable housing behalf of Menta who are bringing forward a Centre homes strategy is 3.20 major mixed use development in East designed to be flexible as it is Menta Croydon. These comments are predicated on recognised that not every site Observation the understanding that the Menta sites at East will be able to to deliver the Noted Croydon (land west of Cherry Orchard Road same level of provision of and Cherry Orchard Gardens) are within the affordable homes or homes CMC. The inclusion of the sites within the suitable for families. Off site CMC has been advised by Officers previously, provision of affordable housing but the visuals in the consultation document is not encouraged or the are inconclusive. Amended Homes Strategy. preferred form of development. The 20% affordable homes target for the first It is considered that any case year is noted to be subject to viability. The for such provision is best dealt policy should include the potential for off-site with as a departure to provision in certain circumstances. The development plan policy and overall target of 20% of new homes in the treated on its own merits if there CMC to have 3 bedrooms or more by 2031 is a material consideration as to and 35% of 2 bedroom units to include 4 bed why affordable homes should spaces is noted. The policy as worded is not be provided on site. appropriate in that it does not necessarily require this level of provision on every site. An overall target for the CMC generally is preferred as this will allow flexibility on a site by site basis. [We would note the some of preceding text/figures is unclear on this issue, but have restricted our comments to Strategy only]. Proposed level of 17 Core Strategy paragraph 3.22 notes that The current consultation on the Mr Michael Mulhern affordable housing the overall quantum of affordable housing Core Strategy ran concurrently 3.22 required on any one site would need to be with a consultation on Greater London Authority considered in the light of how it might Croydon's draft Infrastructure Objection prejudice other planning objectives. This Delivery Plan. The Noted – To be Reviewed proposal does raise a concern and is not fully Infrastructure Delivery Plan will in line with London Plan policy 6A.4, which set out broad policy for identifies public transport and affordable infrastructure requirements housing at the top of the Mayor's list for including playspace. section 106 requirements. Any local variations from this would need to be robustly justified based on local need assessments. Proposed level of Page 18: 3.23 This is a developers "loophole" The threshold is in line with that Mr I.G.M. Hunter affordable housing which will allow them NOT TO BUILD any contained within the London 3.23 affordable homes if they restrict their Plan. Whether it is appropriate Resident developments to nine or less properties. No to ask for contributions towards Objection Council approvals of plans should be made in off-site provision of affordable Noted – To be Reviewed such circumstances. homes on developments with less than 10 units will be considered in the next draft of the Core Strategy. Proposed level of 13 The Council has also prepared an The Affordable Housing Viability Mr Michael Mulhern affordable housing ‘Affordable Housing Viability Assessment', Assessment is available to 3.21 which demonstrates that, at present, an download from Croydon Greater London Authority average development site in Croydon could Council's website at Observation only reasonably be expected to accommodate www.croydon.gov.uk/contents/d Noted 20% affordable housing in the current epartments/planningandregener economic climate, which does raise an ation/pdf/912686/917223/afforda affordable housing delivery issue. This viability blehousingviabilityreport. A evidence should be provided to the GLA for copy will be sent to the GLA for review. review. Proposed level of In terms of affordable housing, we recognise The comment is noted. Mr Keith Hearn (Minerva) affordable housing that this is an important priority for both the 3.22 Council and the GLA, but consider this should CBRE be considered on a site by site basis, rather Objection than a ‘blanket approach' to affordable Noted housing (35% as an overall strategic target) being taken. However, we welcome the recognition in paragraph 3.22 that the extent to which providing affordable housing on site would prejudice other planning objectives of developing the site, will also be considered in deciding what proportion of affordable housing units a site should provide. Proposed mix of homes by Fig 3.13 and Fig 7.3: This fig 3.13 on p.17 Figure 7.3 is correct. There is a Revd Charles Trefusis size shows some 60% of proposed housing in printing error in Figure 3.13 Figure 3.13 Purley consisting of 1-2 bedroom houses. which resulted in the key being Purley & Kenley Compare this with fig 7.3 on p. 65 which reversed. The proportions of Neighbourhood shows the same proportion for 3-4 bedroom homes of different types in the Partnership houses - which of the 2 is correct ? Even if borough was determined by the Objection fig 7.3 (p. 65) is correct we still challenge 40% location and availability of sites Noted – To be Reviewed houses in Purley consisting of 1-2 bedroom for development (which was houses. This is going very much against the considered by the Strategic existing character of Purley. Figure 3.15 p. Housing Land Availability 18 - shows that the SOUTH (Purley and Assessment) and past trends of Coulsdon) will supply 4% of the 33% development on smaller sites. affordable houses compared to 1% in the In Purley a number of potential EAST. development sites were either in or in close proximity to Purley district centre and thus were assigned a number of smaller units as well as larger units hence the higher proportion of smaller units compared to neighbouring places. The methodology for determining the size of new homes assumed that new homes away from the district centre would be predominantly larger homes in keeping with the existing character. Proposed mix of homes by Housing Need 2009-2031 The comment is noted. The Purespace Group size majority of new homes in Limited 3.18 It is recognised that the Local Housing Market Croydon built in the last three Purespace Group Assessment (LHMA) shows a need for larger years have been smaller one Limited units, whilst the majority of housing and two bedroom properties Observation completions over the past three years have outside Croydon Metropolitan Noted been one and two bedroom units within the Centre. The Core Strategy is CMC. seeking to promote sustainable communities in Croydon in the It should be noted that this is a result of the future and part of this includes function of the CMC which is more appropriate promoting developments that for higher density housing and flatted include a mixture of larger and developments, that in the outer suburbs of the smaller homes in the Croydon Borough. Development sites within the CMC, Metropolitan Centre. The such as the Derby Road site within close Housing Typologies Study has proximity to West Croydon Station, are not identified that certain areas of therefore considered a suitable location for Croydon Metropolitan Centre predominantly three bedroom (family) units. could accommodate a mixture of homes of different sizes. Proposed mix of homes by Proposed Mix of Homes by Size There is a printing error in Purespace Group size Figure 3.13 and the key has Limited Figure 3.13 Paragraph 3.18 outlines that Croydon has a been reversed. Figure 7.3 is Purespace Group need for more 3 and 4 bedroom homes over correct.The council considers Limited the next 20 years. In order to meet this need, that it is appropriate for CMC to Objection the Core Strategy proposes to seek larger accommodate more family Disagree – No Change homes on potential development sites in the housing in order to address the Borough and enhance the attractiveness of housing need identified by the CMC as a location for families to live. Figure Local Housing Market 3.12 outlines that for the CMC, 41% of homes Assessment. The Housing should be 1 and 2 bedroom dwellings and Typologies Study has indicated 26% should be 3 or more bedroom dwellings. that it is possible for Croydon Metropolitan Centre to meet Figure 3.13 of the document shows that for part of this need whilst still the CMC, the proposed mix of units would contributing to the realisation of predominantly comprise units of 3 or more the London Plan aspirations for bedrooms (in excess of 75%). As previously the Croydon Opportunity Area. stated, not all development sites within or on the edge of the CMC should be considered appropriate for a high proportion of family units. In order to meet the Mayor's targets for additional housing the CMC will continue to provide the largest proportion of new homes within the Borough.

Our client therefore considers that it may not be appropriate for the CMC to be transformed for family homes and support facilities for children. However, our client supports the delivery of residential growth as part of mixed use schemes with increased intensification around West Croydon Station. The document should acknowledge that the type and size of the housing is dictated by the physical and economic constraints and opportunities of a particular site. Therefore, depending on the nature of proposed development and site location and both economic and physical site constraints, it may not be appropriate to include a large percentage of family housing within some developments. Our client considers that the emerging Core Strategy should reflect this constraint whilst still address housing need in the Borough.

Therefore, depending on the nature of proposed development and site location and both economic and physical site constraints, our client considers it is not appropriate to include a large percentage of family housing within or on the edge of the CMC and any figures stated in the Core Strategy should be targets and subject to overall scheme viability. Proposed mix of homes by We question whether Figure 3.13 ‘Proposed The key in Figure 3.13 has Mr Keith Hearn (Minerva) size mix of homes by size' on page 17 of the been reversed by mistake. It Figure 3.13 document shows the correct proportions in should show just over 75% of CBRE terms of CMC Spatial Management Area. The new homes in Croydon Observation diagram currently shows around 75% of new Metropolitan Centre as having Noted – To be Reviewed homes in the area being 3 or more bedrooms, one or two bedrooms. and only 25% as one or 2 bedroom homes. This appears to be an anomaly and does not accord with the rest of the document. Proposed mix of homes by CMC and Environs - Homes Strategy: The Paragraph 3.36 states that it is Menta size increased target is noted and recognising that an aspiration for 20% of all new Figure 3.13 the CMC will provide more than 75% in one homes within Croydon Menta and two bedroom homes is considered Metropolitan Centre to have 3 Observation realistic - although it is apparently not or more bedrooms by 2031. Disagree – No Change consistent with the above strategy. This is not inconsistent with Figures 3.13 and 4.4 which show between 20% and 25% of new homes having 3 or more bedrooms. Proposed mix of homes by b) (fig 3.13 page 17, fig 3.3 page 11& fig 7.3 There is a printing error in Jean Apps size page 65) There seems to be contradictory Figure 3.13 and the key has Figure 3.13 information presented in these figures. Whilst been reversed. Figure 7.3 is Resident the latter two say that 3-bedroom plus homes correct. Observation will be most in demand and will form the major Noted fraction of homes built, the figure on page 17 states that the majority of homes will be 1 and 2-beds. Which is the case? Proposed mix of homes by It is of concern that the strategy relies on high The Core Strategy is a 20-year Mr Brian Madge size density flatted schemes. If these fail to come plan. Whilst current conditions Figure 3.12 forward the Borough will not be able to meet are less favourable to some Brian Madge Ltd its future housing requirements. Moreover the development types compared to Objection ability to meet family needs, particularly of the previous years they are unlikely Disagree – No Change private sector, in central Croydon has to be to remain as they are now for questioned. the life time of the Core Strategy. Therefore the Core Strategy will plan for growth in Croydon up to 2031 including significant development within Croydon Metropolitan Centre, whilst recognising that in the short term past rates of development may not be realised. Overall the Core Strategy is not reliant on any one type of development to achieve the housing target as it is proposing a balance between larger and smaller homes in the borough.

Over the plan period the Core Strategy seeks to create a new community in Croydon Metropolitan Centre including families. The Opportunity Area Planning Framework will set out how this will be achieved including interventions required to make Croydon Metropolitan Centre more attractive to families as a place to live. Proposed mix of homes by A sound spatial strategy will need to ensure The Housing Typologies Study Mr Brian Madge size that sufficient conventional family housing is indicates that it is possible to Figure 3.12 delivered. The emphasis on family housing provide accommodation Brian Madge Ltd has now increased in the draft Strategy and in suitable for families within Objection Government Policy. Families will look for Croydon Metropolitan Centre. Disagree – No Change housing with gardens which will be in limited One policy aim of the Core supply in the CMC. It is interesting to note that Strategy is to increase the the current 5 year supply contains little family supply of homes suitable for housing which questions how 3500 family families within the borough as units would be found in the CMC area. recent supply has focused upon smaller homes. The need for The now acknowledged need for family play space and open space houses of 3 and 4 bedrooms will require more within the borough has been land than the current emphasis upon flatted factored into the Strategic development. Similarly the supporting Housing Land Availability playspace and open space requirements will Assessment which has be a further demand on land. These house informed the amended homes types and their supporting infrastructure will strategy within the Core be hard to achieve in CMC at the required Strategy. densities to reach the overall housing targets. Proposed number of new We would re-iterate earlier comments as to Comment is noted. The Mr Brian Madge homes in Croydon and the desirability of directing development potential of each of the 16 phasing towards areas of known flooding (the South Places to accommodate new Figure 3.7 SMA) in a climate where infrastructure funding homes will be reviewed and Brian Madge Ltd is in a period of retrenchment. where necessary the type and Objection quantity will be revised. Noted – To be Reviewed Proposed number of new 3. Housing and Population Growth: Housing The proposed numbers of Revd Charles Trefusis homes in Croydon and targets up to 2031 as set out are Central 14 homes in each Spatial phasing 400 North 3 600 East 900 South 2 600. The Management Area is based Figure 3.7 vast difference in the number of proposed upon the availability and Purley & Kenley dwelling between EAST (which includes capacity of development sites in Neighbourhood Addington, Kenley, Old Coulsdon, each area and the residential Partnership Sanderstead, Selsdon and Shirley) at 900 and character. Observation SOUTH which includes only Purley and Disagree – No Change Coulsdon at 2600 remain highly questionable. This tends to imply that concentrated growth along the A23 corridor is still promoted by the Council, in spite of our strong earlier comments against that. Whilst we acknowledge that the EAST has more green areas, we do not accept that it offers less opportunity for housing than other areas. Proposed number of new The existing borough was created in 1965 The 'Places' approach adopted Mr Charles King homes in Croydon and with the amalgamation of the County borough in the Core Strategy is a direct phasing of Croydon and Coulsdon and Purley District response to the concern 3.13 Council areas. Over the last forty five years outilned. It is essential that local East Coulsdon this difference has been emphasised and the character is regarded and Residents' Association borough is clearly dived between north and respected alongside the wider, Observation south . Major efforts need to be undertaken to strategic matters. Noted reduce this difference without destroying the existing nature of each of the districts. It is important that Croydon functions as a borough and there also needs to be adequate investment in all the major district centres which includes such centres as Coulsdon, Purley, Selsdon, Norbury or South Norwood. This investments must recognise that these are independent communities as well as suburbs of Croydon. While recognising there are also a number of smaller centres such as Hamsey Green, Old Coulsdon and Shirley that need investment Proposed number of new We note that CMC is the main area in which The comment is noted. Mr Keith Hearn (Minerva) homes in Croydon and new homes are expected to be provided over phasing the CS period. As stated previously, Minerva 3.13 considers this could be beneficial to the town CBRE centre, but agrees with paragraph 3.13 which Support states that new homes will only be built in Noted areas where residential development is appropriate and where the development itself is in keeping with the distinctiveness of the location. We note that sites for housing will be identified in a Site Allocations DPD (if over 0.25 hectares) or a Development Management DPD (for smaller sites). Proposed number of new Given the restraint now upon infrastructure Whilst public expenditure will be Mr Brian Madge homes in Croydon and and future expenditure there must be doubts constrained over the next 4 phasing in also directing housing growth to the north years and concievably foer a Figure 3.7 (3600 units) knowing that resources such as longer period, much Brian Madge Ltd schooling are inadequate and transport is infrastructure is provided by the Objection under stress. The strategy directs the bulk of private sector. Health Disagree – No Change new development to locations that are expenditire has in large precisely those where public transport is measure been protected . subject of current capacity problems. The Additionally the government has forthcoming comprehensive spending review approved the means for funding is likely to indicate that the necessary infrastructure through the development of transport facilities may now be Community Infrastructure Levy challenged. to be deployed by both the Mayor of london and the Borough council. Prudential borrowing on the back of future funding is also being encouraged. The current reduction in development backed funding is not likely to be long term Proposed number of new With regard to the proposal to put 1,000 new The comment is noted. The Jacqueline Hall homes in Croydon and housing units into South Norwood, 8,000 into location of new homes has phasing Selhurst and 100 in Selsdon, I feel this is a been determined through an Figure 3.7 very bad idea. Extra police are currentlybeing analysis of the availability of put into Selhurst, which isa crime hotspot and land for development and the Objection there is an acceptance that the north of the character of each place. There Noted borough suffers from more crime than the is more land available in the South. I feel that housing is too dense already north and centre of the borough in Selhurst and South Norwood and that this and the existing residential proposal should be rebalanced so the majority character lends itself more to of new housing is where housing is less sensitive redevelopment than in dense, in the South of the borough. areas in the south and east. Proposed number of new 28 The 20-year housing figure of 21,500 is The support is welcomed. Mr Michael Mulhern homes in Croydon and broken into four management areas, with phasing each area comprised of a series of smaller Figure 3.7 connected ‘Places'. The Preferred Options Greater London Authority (2b) report provides high level information on Support housing delivery within each management Noted area, which is acceptable. Proposed number of new We would suggest that should the focus on Only 8,000 homes are proposed Mr Brian Madge homes in Croydon and CMC fail which proposed 14400 new homes, in Croydon Metropolitan Centre phasing the spatial strategy will be unable to meet with the remainder of the Figure 3.7 strategic needs and would require re-casting 14,400 provided in neighbouring Brian Madge Ltd in a different manner. We believe as noted in Places. The five year supply is Objection my previous letter that our recent analysis of not related to the homes targets Disagree – No Change housing supply suggests the latest housing set out in the Core Strategy supply figure significantly over estimates the consultation document. The existing 5 year supply, possibly by a factor of Core Strategy is a 20-year plan 250%. A number of the town centre sites upon and over the lifetime of the plan which housing supply is reliant are no longer it can reasonably be expected viable or permissions have expired. The that a significant proportion of recession thus casts doubts on the larger flat Croydon's homes will be orientated town centre schemes. There is provided within Croydon further doubt on the attractiveness of family Metropolitan Centre as the housing without gardens. viability of development in Croydon Metropolitan Centre will improve further between now and 2031. Proposed number of new The unfair imbalance in housing targets . The proposed numbers of new Revd Charles Trefusis homes in Croydon and homes have been allocated to phasing individual areas based on Figure 3.7 projected increases in Purley & Kenley population, the existing Neighbourhood infrastructure capacity, the Partnership ability of areas to accommodate Objection new infrastructure and the sites Disagree – No Change shown in the SHLAA. Clearly all areas will require additional housing to meet needs, although CMC will be expected to accommodate the largest proportion. Proposed number of new Accordingly, the Core Strategy should place The Core Strategy is a 20-year Mr Brian Madge homes in Croydon and greater emphasis on the possibility of some plan. Whilst current conditions phasing development being accommodated on open are less favourable to some 3.12 land (including green belt and metropolitan development types compared to Brian Madge Ltd open land). It is critical for the Council to previous years they are unlikely Objection address the implications for growth in both the to remain as they are now for Disagree – No Change short and long term in the Core Strategy and the life time of the Core to acknowledge the necessity of utilising a Strategy. Therefore the Core limited amount of land that is presently Strategy will plan for growth in described as open to meet these needs. It is Croydon up to 2031 including thus suggested that wider growth locations significant development within could be required to meet development supply Croydon Metropolitan Centre, (particularly housing). whilst recognising that in the short term past rates of development may not be realised. Over the lifetime of the plan the Strategic Housing Land Availability Assessment indicates that there is sufficient land in Croydon to achieve the strategic target set out in the Draft Replacement London Plan. The Draft Replacement London Plan also includes a presumption against the release of Green Belt and Metropolitan Open Land across London which the Core Strategy should conform with. Proposed source of new 8. The distribution of new housing across the The figures presented in the Mr Paul Scott homes borough is un-equitable and unfairly protects consultation are not currently Figure 3.11 some areas at the detriment of others. An targets as the only target for People for Portland Road alternative approach should be taken to new homes is at a borough Objection spread the new housing out across the whole level. They are indicative figures Noted – To be Reviewed borough - There is a huge disparity across the for the potential capacity of borough in the proposed distribution of the each place. If the level of new housing with the south eastern area in development suggested in particular being expected to accommodate South Norwood and Woodside only a few hundred across a very large area. does not or cannot take place The character of the ‘East Spatial then the homes will have to be Management Area' would be protected by only accommodated in other places accommodating a proposed 900 new homes within the borough. Ensuring whilst the character of the South Norwood and that new development is Woodside area is be sacrificed to appropriate and retains local accommodate 1300. This is clearly utterly distinctiveness is integral to the unreasonable and unjustified. Whilst the Core Strategy as set out in character of the ESMA is clearly important it is paragraph 3.33. certainly not any more important than that of any other part of the borough. Why should the gardens and greenery in South Norwood and Woodside be concreted over and our larger homes be demolished whilst those in Selsdon or Sanderstead are protected? South Norwood has an historic Victorian centre whilst Shirley and Kenley are predominantly 20 th century sub-urban sprawl. A comprehensive reconsideration is required of the distribution of the new homes, with all areas having to accept some change. This would allow the character of all areas of the borough to be protected, but with some change. We propose that much of the housing currently targeted at South Norwood and Woodside could be reallocated into the ESMA through the localised intensification of development in the areas immediately around the district and local centres in that area. This would strengthen those centres and make them more sustainable whilst protecting its predominantly sub-urban character and avoiding any encroachment on the Green Belt. Proposed source of new Housing : a) (fig 3.11 page16) Where are the The large sites are identified in Jean Apps homes 'large sites', designated to be the main the Strategic Housing Land Figure 3.11 sourceof new homes in Purley 2011-2021? Availability Assessment which is Resident available on request. At the Observation moment they are sites identified Noted – To be Reviewed as having potential for development. There will be a full consultation on these sites as part of the preparation of the Site Allocations DPD which will follow the Core Strategy. Proposed source of new 30 Determining the 20-year housing figures The support is welcomed. Mr Michael Mulhern homes has been based on; existing residential Further discussion between the Figure 3.10 planning permissions; a housing capacity GLA and Croydon Council Greater London Authority study for the Croydon Metropolitan Town housing officers would also be Support Centre; the GLA Strategic Housing Land welcomed. Noted – To be Reviewed Availability Assessment (SHLAA) for sites over 0.25 hectares; and past trends of development on the SHLAA ‘windfall' sites smaller than 0.25 hectares. This approach is broadly acceptable, and to ensure that the appropriate information on the use of ‘windfall' sites is provided at submission stage a further discussion between GLA and Croydon Council housing officers would be welcomed. What the London Plan says 3.11 Draft Replacement London Plan - Where The Draft Replacement London Mr I.G.M. Hunter should be built in Croydon can it be found? Plan can be found at in Croydon http://www.london.gov.uk/shapin 3.11 g-london/london- Resident plan/strategy/download.jsp. Observation Internal space standards are set Noted out in Table 3.3. What the London Plan says The fact that the London mayor has recently The Mayor of London reviews Revd Charles Trefusis should be built in Croydon increased housing targets by 21% remains the London Plan Housing in Croydon questionable. If these targets keep changing, Target periodically 3.10 then how is it possible to plan for these with (approximately once every four Purley & Kenley any degree of certainty or indeed authority? years) in order to keep the Neighbourhood London Plan up to date. The Partnership London Plan forms part of the Observation Development Plan for Croydon Noted and therefore in itself provides a degree of certainty and authority. The Core Strategy provides the local intepretation of the Mayor's target and will itself be reviewed periodically to reflect changes in circumstances. The Core Strategy sets the direction of development in Croydon for the next 20 years. Where are we now? Croydon's Population The comment is noted and the Purespace Group Opportunity Area Planning Limited 3.3 The document acknowledges that Croydon Framework include CMC and Purespace Group has a growing population with the consider the potential and Limited Metropolitan Centre expected to see the most provide these detailed guidance. Observation growth. This growth needs to be seen as a Noted potential asset for Croydon and as such, opportunities need to be made available within Croydon Metropolitan Centre ("CMC") to capitalise on this. 4.0 Croydon Metropolitan Centre and Environs Spatial Management Area Section Representation Recommended Response Full Name Paragraph Organisation Nature of Response Officer Recommendation Comments on specific places 1: Croydon The comment s are noted. As Mr Lewis White Town Centre. I visited the West and East the comments directly relate to Croydon masterplan exhibition at the NLA the East and West Croydon Observation tower, and talked with a Planning officer, who Masterplans, a council reply is Noted talked through numerous issues with myself incorporated in the East and and some other residents, keeping his cool in West Croydon Masterplans the face of some incredibly negative or initially consultation response. The hostile people, but eventually they calmed issues of design of the East down and we all had a useful discussion.  I Croydon footbridge is adetail filled out the questionnaires, and you should inappropriate for the Core have these.  I would like to state that I Strategy but of relevance to the consider that both of the Master Plans, if station masterplan implemented on these lines, with good quality buildings and attractive, well-designed spaces between buildings will positively transform these derelict (East) and run down (West) areas. I welcome the inclusion of green roofs and trees, and in fact I would ask that all the major buildings should have green roof requirements as part of the planning permissions. My only concern was regarding the new bridge over East Croydon, and the idea of having lifts in the public domain, as these areas would quickly become no-go areas unless they are within the station building "envelope". To build the bridge as an outdoor deck would be a total failure in my opinion, as it would not be "policed". If the bridge were roofed over so that it became a station building, it would be supervised and should be without problems.  With regard to the idea of having decks in these areas in general, I would say that it would be vital to have properly engineered tree pits in the decks. Decks are generally bleak places, so I would always think long and hard about the quality of the resulting environment. Look for example at the Hayward gallery decks on the South bank of the Thames. Generally, people feel better on the ground-what is the matter with having some slopes-it is hardly the north face if the Eiger.! Wheelchair users would not find any problems using paths that follow the land surface. So my request would be to abandon the deck ideas. CMC and its Environs Reference will be made to the Mr Michael Mulhern OAPF. Greater London Authority 43 The Croydon Metropolitan Centre (CMC) Observation and its surrounding environs of Addiscombe, Noted – To be Reviewed Broad Green and Selhurst, South Croydon and Waddon, is the area identified as having the greatest capacity to accommodate growth. The Core Strategy proposes 14,400 new homes, 2,000 new jobs and 50,000 sq.m. of retail floorspace to be provided in the CMC and its Environs by 2031. The Core Strategy also recognises Croydon Town Centres role as a strategic office location, which is acceptable. 44 The GLA and the Council are currently working closely together to prepare an OAPF for the Croydon Town Centre and the GLA has been involved in reviewing the evidence to support these figures for housing, jobs and retail space. However, at submission stage the Council should provide the Inspector with the final evidence to support the proposed figures. In addition, for clarity, the role of the OAPF and its relationship to the LDF process should be more fully explained in this section. Amended Homes Strategy. The document There is a printing error in CGLP sets out an initial target (for the first year) of Figure 3.13 and the key has CGLP 20% of homes on ten or more units should be been reversed. Figure 7.3 is Objection affordable, based on the viability of providing correct. Paragraph 3.36 states Disagree – No Change affordable homes on mixed tenure that it is an aspiration for 20% of developments. CGLP support that the all new homes within Croydon provision of affordable housing must be based Metropolitan Centre to have 3 on financial assessment with individual site or more bedrooms by 2031. and scheme constraints taken into account. This is not inconsistent with Paragraph 3.36 advises that there is an Figures 3.13 and 4.4 which aspiration for "20% of all new homes within show between 20% and 25% of the CMC to have 3 or more bedrooms by new homes having 3 or more 2031". As above, the overall mix of units (and bedrooms. therefore the proportion of affordable) should be based on scheme viability and site suitability. Figure 3.13 does not reflect the proposed aspiration for the mix of units as set out in the ‘Amended Homes Strategy' and should be amended. Homes - Croydon Metropolitan Centre. CGLP The comment is noted. CGLP supports the recognition at paragraph 4.9 that CGLP it is possible to build a substantial amount of Observation new dwellings in the CMC, but to do so would Noted require a number of tall buildings and an intensity of building that would reduce the number of larger dwellings (3 or more bedrooms). As discussed above, it is considered that the CMC may not be an appropriate location for a large number of family homes. CGLP welcomes flexibility in meeting the needs of family housing within the CMC and the recognition that building larger homes would reduce the overall number of units delivered. Furthermore, it is recognised that much of the housing less suited to families will need to be provided in taller buildings in the more central parts of the CMC. As such, homes more suited for families should be located towards the edge of the CMC. CGLP supports this approach. CHAPTER 4: Croydon Metropolitan Centre The support is welcomed. CGLP and Environs Spatial Management Area CGLP Overview. CGLP support the Council's aims Support for CMC to be the focus for growth for a range Noted of facilities and deliver the key objectives of the Core Strategy. CGLP consider that the CMC needs to provide a range of jobs, good quality shopping, leisure and cultural opportunities, in addition to a good housing stock in order to attract investment and growth. An increased range of facilities, such as retail, will attract residents from all over the Borough to visit the CMC. Also, complementary town centre type uses such as leisure and cultural attractions would provide the vibrancy for the CMC and attract a residential population in the CMC. This area has been a disgrace for so many The comment is noted. The years. I am surprised anyone goes there. The West Croydon Masterplanning East London underground extension is now process was initiated following Observation being used as a hook for redevelopment but work ceasing on the Croydon Noted why after the event. Could this not have been Metropolitan Centre Area Action in planning during consultation extending the Plan. line. I don't understand. The upgrade of transport links (Thameslink, The comment is noted. CGLP Tramlink extensions and Crossrail) will assist CGLP to achieve links to central London and make Observation Croydon a place where companies can Noted relocate easily, be connected back to central London, but have lower overheads. Due to its excellent transport links, Croydon and the CMC in particular will need to be considered more of a London centric destination that should compete for employment with central London. CGLP support the delivery of residential The council considers that it is CGLP growth as part of mixed use schemes with appropriate for CMC to CGLP increased intensification around East Croydon accommodate more family Objection Station. However, it should be recognised that housing in order to address the Disagree – No Change whilst residential development should be housing need identified by the encouraged in the town centre, there is a Local Housing Market difficulty of providing family accommodation Assessment. The Housing with good access to schools within the CMC. Typologies Study has indicated The document should acknowledge that the that it is possible for Croydon type and size of the housing is dictated by the Metropolitan Centre to meet constraints and opportunities of a particular part of this need whilst still site. Therefore, depending on the nature of contributing to the realisation of proposed development and site location and the London Plan aspirations for both economic and physical site constraints, it the Croydon Opportunity Area. may not be appropriate to include a large percentage of family housing within some town centre locations. CGLP consider that the emerging Core Strategy should reflect this constraint whilst still address housing need in the Borough. Therefore, depending on the nature of proposed development and site location and both economic and physical site constraints, CGLP consider it is not appropriate to include a large percentage of family housing within the CMC and any figures stated in the Core Strategy should be targets and subject to overall scheme viability. CMC and Environs – 3) No mention of culture for Addiscombe The reason for identifying the Mr Sean Fitzsimons Cultural Planning Strategy should be cultural incubator for creative arts. - need for cultural/creative 4.64 officers very helpful and informative at the industries related Enterprise Resident consultation Centres at Crystal Palace, Observation Purley, Portland Rd and CMC Noted was the clustering of existing cultural/creative activities in these locations. It is considered that residents and businesses in the Addiscombe Place will benefit from their proximity to the proposed Enterprise Centre (which could be seen as a 'cultural incubator for creative arts') in CMC. CMC and Environs – 2) How do you propose to support the The Warehouse Theatre was Mr Sean Fitzsimons Cultural Planning Strategy Warehouse? mentioned in the previous iteration and the Council Resident recognises it is part of the highly Observation valued cultural offer in Croydon No Action – Not an LDF Iss Metropolitan Centre. Discussions are ongoing with the developers of Ruskin Square over possible options for its reprovision. The ongoing day to day support of the Warehouse is not a matter for the Core Strategy. CMC and Environs – Page 32; 4.66 This decision, belated though it The comment is noted Mr I.G.M. Hunter Cultural Planning Strategy is, comes too late for the hanger. 4.66 Resident Observation Noted CMC and Environs – Regeneration of Fairfield Hall- A serious The comment is noted. Willem Buttinger Cultural Planning Strategy obstacle to the success of Fairfield Halls is the 4.65 cost of parking, speaking to many people I know this is a major put off Observation No Action – Not an LDF Iss CMC and Environs – The Theatres Trust is The National Advisory Whilst it is valued the Ms Rose Freeman Cultural Planning Strategy Public Body for Theatres. It currently delivers Warehouse Theatre is not a 4.66 statutory planning advice on theatre buildings regional performance facility in The Theatres Trust and theatre use through The Town and the way that the Fairfield Halls Objection Country Planning (Development Management is. Disagree – No Change Procedure) (England) Order 2010 (DMPO), Articles 16&17, Schedule 5, Para (w), that requires the Trust to be consulted by local authorities on planning applications which include ˜development involving any land on which there is a theatre.' Due to the specific nature of the Trust's remit we are concerned with the protection and promotion of theatres and therefore anticipate policies relating to cultural facilities. - We support the additional cultural issues and are pleased that the Fairfield Halls are valued as a regional performance facility in the Metropolitan Centre. However we are disappointed that the Warehouse Theatre is not mentioned as an important community producing theatre that provides an excellent daytime facility for local people and complements the grander Fairfield Halls. Both types of facility serve diverse audiences and are of equal importance to the cultural offer of the metropolitan centre of Croydon. We request an additional guidance paragraph at 4.66 on page 32 to support the future of the Warehouse Theatre and retain a diverse mix of performance arts in Croydon's centre. The protection of theatres and performance spaces is essential if future generations are to have the opportunity to experience different aspects of drama, dance, music and opera. CMC and Environs – We support para. 4.63 for the temporary Support is welcomed and Ms Rose Freeman Cultural Planning Strategy occupation of empty buildings although their comments regarding reuse and 4.63 use could be made permanent. Refurbishment refurbishment are noted. The Theatres Trust and reuse of existing buildings usually Support requires significantly less energy than building Noted new ones and therefore supports the aims of sustainable development. This option should be seriously considered for permanency particularly where existing buildings makes a positive contribution to local character or where it/they can form the basic building block of a new development. The alterations necessary to continue the use of a building must be balanced against the impact on the historic fabric and character of the building and the Council should ensure that new uses respect the existing features of a building. The new use must adapt to the building not the other way round and involve the least amount of intervention. CMC and Environs – Similarly, we agree that CMC will have the The comment is noted. Mr Keith Hearn (Minerva) Homes Strategy highest potential for new homes over the Figure 4.3 period to 2031 (as set out in Figure 4.3), and CBRE consider that higher density development is Observation appropriate to help deliver this, given the Noted central location and public transport accessibility which central Croydon benefits from. CMC and Environs – Homes Croydon Metropolitan Centre Mr Keith Hearn (Minerva) Homes Strategy has the potential to provide Figure 4.3 We consider that there is a place for housing more new homes than any CBRE within the town centre, and that the other Place within the borough. Observation introduction of residential uses can However it remains the Noted – To be Reviewed complement the primary retail function of the borough's primary location for town centre, adding to its vitality and viability retailing and offices as befits the (particular in terms of the evening economy). largest metropolitan centre in However, any residential units provided in the South London. Therefore it is town centre need to respond to the needs of agreed that the provision of new people who choose to live in this area, and homes needs to be carefully must be capable of providing an acceptable managed through the Site level of residential amenity. The introduction Allocations DPD and the of residential uses to the town centre needs to Opportunity Area Planning be carefully managed to ensure that the Framework to ensure that it required residential amenity for occupiers is does not impact upon the retail not achieved at the risk of curtailing the town and business functions of centre's primary retail and business functions. Croydon Metropolitan Centre. The overall amenity and public realm within Croydon Metropolitan Centre is recognised as a barrier to inward investment therefore improving the amenity for residential occupiers could also improve the amenity for all. CMC and Environs – Page 27: 4.24 The figure shows a far higher The proportion of larger and Mr I.G.M. Hunter Homes Strategy incidence of 1-2 Bed housing in the CMC and smaller dwellings in Croydon 4.24 Waddon when it is evident that these Places Metropolitan Centre was based Resident have, over recent years, seen the construction upon the evidence provided by Observation of 1-2 bed accommodation from which the Housing Typologies Study Noted families now wish to move (not away from which sought how to make the their jobs but into "affordable" 3-4 bed best use of land in the centre for properties). Why aren't such house types different types of new home. In being planned to be built in those Places the case of Waddon the now? It is also significant that although South proportion has been heavily Croydon (local centre?) has a pie chart the influenced by the New South second "local centre" (see page 26-Homes Quarter development which South Croydon) does not appear to have one, includes a high proportion of and thus the proportions of different housing smaller units and is included in types cannot be determined. Since I live in the figures (due to it being Purley Oaks what is built here is of some under construction). The pie interest to me! charts refer to homes in individual places as defined by the Core Strategy and not particular local centres. CMC and Environs – Jobs 6. Is the Strategy population or development The figure of 20,200 homes is neighbourhood Strategy led? We have noted above the substantial judged to be a realistic Partnerships Chairs & population increase sought by the Strategy in assessment of the amount of VCs 4.43 the period to 2010-2031 - an increase of 11% homes that can be delivered neighbourhood in just 21 years based on the Strategy's over the plan period in order to Partnerships Chairs & suspect estimates (341,800 to 380,000). Our meet the boroughs housing VCs independent analysis indicates an even higher need of 28,069 up to 2031 as Observation level of population growth - 16% (357,000 to identified in Croydon's Local Noted 415,000). We are concerned that this Housing Market Assessment substantial population growth appears to be (LHMA). The LHMA takes the driven more by the availability of housing plots GLA population projections for in the borough (as identified by the Greater the borough as a whole and London Authority's Strategic Housing Land uses data on household Availability Assessment) than by a realistic composition and type of homes assessment of the borough's job creation currently in existence to provide potential and its ability to fund the necessary the overall need for homes up social and transport infrastructure. We fear to 2031 and the need for new that Croydon is acquiescing in this substantial homes by tenure split (i.e. population growth as a way of "currying market, social rented, favour" with London and indeed central intermediate) and home size (1 government so as to capitalise on bed, 2 bed, 3 bed etc). Croydon development funds. We understand that has followed the guidance and Croydon is currently pursuing three methodology of Planning Policy development zone opportunities. Although the Statement 3: Housing, this sets aspirations of each of these three out how Local Planning development zones are admirable, we have Authorities should assess real fears as to whether these development housing need and land zones will have sufficient funding to make availability for new housing. The significant progress - especially given central Infrastructure Delivery Plan government's funding constraints. We (IDP) uses the findings from the therefore believe there is a real danger that Strategic Housing Land Croydon will have to absorb this substantial Availability Assessment and the population growth without seeing the Local Housing Market necessary job creation or development of the Assessment to inform the need transport and social infrastructure. Worryingly, for social infrastructure in the the Strategy is especially vague on local job future. Similarly Core Strategy creation to support this proposed population employment and transport growth. The feedback we receive from our policies (and supporting communities is that Croydon's social infrastructure requirements) infrastructure is under real pressure - aimed at jobs growth and throughout the borough. The supporting data improving skills in the borough acknowledges that Croydon's population will have been formulated using up age over the planning period which will put to date evidence base studies additional strain on its already stretched including (but not limited to) an healthcare resources. The supporting data office, industrial and also acknowledges that the capacity of warehousing land/premises Croydon's primary schools is under real market assessment, a borough pressure - and is likely to remain so for a large wide transport strategy, number of years into the foreseeable future. borough wide and town centre The gradual increase in the minimum retail studies, cultural mapping secondary school leaving age will stretch the study and an Economic capacity of Croydon's secondary schools over Development Strategy Refresh. the medium term. Job creation in the borough has ground to a halt in recent years. Indeed, Overall the London Plan sets given the fears over Nestle and the Council's strategic targets for London as workforce, the job situation in Croydon could a whole and seeks to balance deteriorate over the short to medium term. If the need for jobs and homes at Croydon's medium term ability to create jobs a pan-London level. Not every locally is limited, then any population growth borough is able or required to will result in even more commuting - which will contribute the full number of place additional pressure on our strained jobs or homes to meet the transport infrastructure. We commend the needs of its population and quality of the work in the Plan that analyses Croydon is not an exception to the borough's future social infrastructure this. requirements. The Plan's analysis of primary school requirements is especially comprehensive. Although the Strategy seeks additional social resources, our fear is that the central government's funding constraints could result in a significant delay in providing these resources. Indeed, there is a real possibility given the current austerity measures, that funding may simply not be available in the short to medium term for the necessary social infrastructure set out in the Plan. We would plead for a Strategy that is employment, infrastructure and social resources led. If progress can be made on these necessary factors, then the population growth can follow - not the other way around. CMC and Environs – Jobs Page 30: 4.52 No attempt has been made to The Core Strategy sets out the Mr I.G.M. Hunter Strategy define what could be developed between proposed level of growth within 4.52 South Croydon (Swan and Sugarloaf) and the each Place. It is not appropriate Resident Royal Oak centre/ Purley Oaks recycling to provide details of all potential Objection Depot). Why has this area been ignored when sites where development can Disagree – No Change there are potential development sites take place. It is the role of the available? forthcoming Site Allocations DPD to address this issue. CMC and Environs – Jobs Paragraphs 4.43 - 4.46 Royal Mail supports The Core Strategy addresses Royal Mail Group plc Strategy the Council's protection of the broad policy stance in 4.43 industrial/warehousing premises/sites and the relation to Royal Mail Group plc flexibility provided in allowing new residential industrial/warehousing stock. Observation development at these locations, as part of Detailed wording of policy Noted mixed-use development. This approach related to this area will be accords with the following Government considered in the forthcoming Guidance: – Paragraph 21 of Planning Policy Development Management Statement 1 (PPS1): Delivering Sustainable DPD. Development, which states that "the broad aim should be to ensure that outputs are maximised whilst resources used are minimised (for example, by building housing at higher densities on previously developed land, rather than at lower densities on greenfield sites)"; – Paragraph 10 of PPS3, which states that the planning system should deliver "a flexible, responsive supply of land - managed in a way that makes efficient and effective use of land, including re-use of previously- developed land, where appropriate"; – Paragraph 36 of PPS3, which states that "in support of its objective of creating mixed and sustainable communities, the Government's policy is to ensure that housing is developed in suitable locations which offer a range of community facilities and with good access to jobs, key services and infrastructure. This should be achieved by making effective use of land, existing infrastructure and available public and private investment"; – Planning Policy Statement 4 (PPS4): Planning for Sustainable Economic Development which details that Local Planning Authorities (LPAs) should plan positively and proactively to encourage economic development, in line with the principles of sustainable development and in particular, states that LPAs should develop flexible policies which are able to respond to economic change and notes the need for co- ordination with infrastructure and housing provision; and – Policy EC.2 (d) of PPS4, which states that LPAs should "seeks to make the most efficient and effective use of land, prioritising previously developed land which is suitable for re-use" including town centres. Notwithstanding the support expressed above we consider that the wording of the Jobs Strategy is restrictive and request that the wording of paragraphs 4.43-4.44 and any corresponding policies is amended to provide flexibility by reading as follows: "4.43 The Council will continue to safeguard industrial/warehousing premises/sites which fall outside the Separated and Integrated Industrial Locations. However, particularly in relation to vacant and under-utilised industrial/warehousing premises/sites, new residential activity will be permitted where it can be demonstrated that the supply of commercial floorspace within this area of the Borough will not be adversely impacted . For those sites which have better transport accessibility (PTAL rating of 3 and above), changes to D1 uses (clinic, creche, day centre, place of worship etc) will also be permitted. 4.44 The Council will extend protection of industrial/warehousing premises/sites to those that fall within the CMC and District Centres. However, particularly in relation to vacant and under- utilised industrial/warehousing premises/sites new residential development at these locations will be allowed, as part of a mixed- use development, where it can be demonstrated that the supply of commercial floorspace within this area of the Borough will not be adversely impacted ." This request is made with specific regard to the CMC and Environs - Jobs Strategy, however, we further request that this amended wording is included in the identical opening paragraphs of all the Jobs Strategy Sections (i.e. paragraphs 5.30 - 5.31, 6.26 - 6.27, 7.27 - 7.28). We reserve the right to amend or supplement these representations at a later date if necessary. CMC and Environs – Jobs TOWARDS A PREFERRED CORE The Council does not agree Robin Harper Strategy STRATEGY FOR CROYDON with the view put forward that the ‘4-tier’ approach to CONSULTATION RESPONSE employment land is an Objection inappropriate one. It also Disagree – No Change November 2010 refutes the assertion that the ‘4- tier’ approach does not Towards a preferred Core Strategy for integrate with other spatial Croydon objectives.

Consultation Response The Council considers the ‘4- tier’ approach reflects Croydon’s ‘Restrictive Transfer’ status in the London Plan yet ______also introduces a more flexible ______policy stance than that which __ currently exists. For example, the UDP policy position in ______relation to the Gloucester Rd ______Employment Area is that new development must be for Page 2 industrial/warehouse use alone. Whilst this approach has been CONTENT criticised for being too rigid, it has arguably helped the SECTION 1 - INTRODUCTION 3 borough to maintain, across a number of economic cycles, an SECTION 2 - NATIONAL POLICY REVIEW 5 acceptable vacancy rate. South London Business found that SECTION 3 - CHARACTER OF some other boroughs, such as GLOUCESTER ROAD 8 Kingston, found themselves with vacancy rates as low 2% - SECTION 4 - LDF EVIDENCE BASE far from ideal as it gives virtually REVIEW 11 no ‘frictional vacancy’ and can lead to migration of successful SECTION 5 - CORE STRATEGY POLICY businesses who are expanding RESPONSE 15 yet are unable to find suitable premises in their host borough. SECTION 6 - SUMMARY AND The ‘4-tier’ approach seeks to CONCLUSIONS 21 retain the benefits of strong protection for designated REFERENCES 23 employment land, yet introduces a greater degree of Towards a preferred Core Strategy for flexibility. Were redevelopment Croydon of part of the Gloucester Rd Employment Area to be Consultation Response considered under this approach, and assuming it were designed in such a way that the needs of existing and future businesses ______were not undermined, the ______Council would accept an __ element of housing alongside the employment uses. This is ______therefore one example of the ‘4- ______tier’ approach integrating with other spatial objectives. Page 3 The proposed approach to SECTION 1. ‘scattered’ employment sites (those that fall outside of the designated Employment Areas) 1.1 Harper Planning Consultants Ltd has been is another example of greater commissioned to provide a consultation flexibility and improved integration with other aims. The response to ‘LB Croydon Core Strategy - proposal to allow community Towards a Preferred Strategy for Croydon' on uses on those sites enjoying higher public transport behalf of the owners of vacant land and accessibility is a response to buildings at Milton House, 2 Milton Avenue and the difficulties community groups have experienced when No.43 Gloucester Road, Croydon. trying to find affordable premises in the past. 1.2 Our clients' property has been vacant and derelict for a number of years with a The Council has ensured that both the Strategic Housing Land history of rejected planning applications for Availability Assessment and the residential development. Croydon Office, Industrial, Warehousing Land/Premises 1.3 It falls within the Gloucester Road Market Assessment inform the Employment Area, as designated in the growth strategy in a complementary manner. New Croydon Plan Proposals Map but is not homes growth must be as designated as a Preferred Industrial Location sustainable as possible and access to local employment is (PIL) in the London Plan and includes a an important component of what significant proportion of residential properties makes a place sustainable. Therefore, there is a balance to and other non-employment uses. be struck between the land which is bought forward or 1.4 Our clients wish to make representations released for residential on the proposed strategy for delivering development and the land which is bought forward or housing and industrial locations and their safeguarded for employment capability of achieving the relevant Strategic use. The evidence base indicates we should not release Objectives. employment land to meet our housing targets. This makes 1.5 This consultation response considers the sense as the logical conclusion employment land supply and demand of continually replacing local job opportunities with new homes is issues relating to the Gloucester Road residential dormitory status – a Employment Area in the context of relevant situation directly contrary to the borough’s spatial vision to be national and strategic policy considerations as London’s most enterprising well as the LDF Evidence Base. borough.

1.6 The consultation response has been Finally, the Council does not approached in the following way: agree with the view put forward that sites such as the 1.7 Section 2 reviews the approach adopted ‘Gloucester Rd Cluster’ (a by the consultation documents in the reference made in the consultation response), will context of relevant national and strategic need to be released for policy and considers whether the proposed residential development if the target for family homes in the strategy accords with the general approach vicinity of Croydon Metropolitan advocated for managing the delivery of Centre is to be met. As part of the Core Strategy evidence housing and employment needs. base, the Council commissioned a Housing Towards a preferred Core Strategy for Typologies Findings Report July Croydon 2010 which indicated that, depending on the typologies Consultation Response employed, a range of scenarios within Croydon Metropolitan Centre (from 1,247 through to 2,353 family units) could be ______realised and does not require ______the release of designated __ employment land. An Opportunity Area Planning ______Framework for Croydon ______Metropolitan Centre will provide further detail on this matter. Page 4

1.8 Section 3 considers the physical, social and economic factors relating to

Gloucester Road Employment Cluster within the wider context of the Spatial Management Areas as defined by the CS consultation document.

1.9 Section 4 discusses drivers of future requirements for industrial land in Croydon and considers whether the Gloucester Road Employment Area should continue to be designated.

1.10 Section 5 provides detailed comments on the proposed Core Strategy policy approach.

1.11 Section 6 sets out our conclusions, where we put forward the compelling case for release of this area for housing to realise other strategic objectives.

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SECTION 2

2.1 This section reviews the approach adopted by the consultation documents in the context of relevant national policy statements and considers whether the proposed strategy accords with the general approach advocated for managing the delivery of housing and employment needs.

PPS3 - Housing

2.2 PPS3 sets out the national policy framework for delivering the Government's housing objectives. The principle aim of this advice and guidance is to provide the necessary step-change in housing delivery, through a more responsive approach to land supply at local level.

2.3 Government's housing objectives are to provide:

• High quality housing that is well-designed and built to a high standard. • A mix of housing to support a wide variety of households.

• A sufficient quantity of housing taking into account need and demand.

• Housing developments in suitable locations.

• A flexible, responsive supply of land.

2.4 In the context of creating mixed communities, the guidance includes a requirement for Local Planning Authorities to set an overall (i.e. plan-wide) target for the amount of housing, including affordable housing, to be provided to meet the needs of both current and future occupiers.

2.5 Paragraph 44 states that in developing their previously-developed land strategies,

Local Planning Authorities should consider a range of incentives or interventions that could help to ensure that previously developed land is developed in line with the trajectory. This should include:

- Planning to address obstacles to the development of vacant and derelict sites and buildings, for example, use of compulsory purchase powers where that would help resolve land previously-developed ownership or assembly issues.

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- Considering whether sites that are currently allocated for industrial or commercial use could be more appropriately re-allocated for housing development.

- Encouraging innovative housing schemes that make effective use of public sector land.

2.6 PPS3 recommends the use of guidance on reviewing employment land is set out in Employment Land Reviews: Guidance Note, ODPM, 2004.

PPS4 - Planning For Sustainable Economic Growth

2.7 PPS4 emphasises that new economic growth should be focused in existing centres in order to deliver sustainable patterns of economic development and reduce the need to travel. It also identifies the need to locate uses which generate substantial transport movements in locations that are accessible to key distribution networks, avoiding congestion and preserving local amenity.

2.8 It requires local planning authorities to assess the existing and future supply of land available for economic development, ensuring that existing site allocations for economic development are reassessed against the policies in the PPS, particularly if they are for single or restricted uses. Where possible, any reviews of land available for 2.9 It is not apparent whether Croydon's employment land review was undertaken at the same time as the strategic housing land availability assessment but a combined assessment was not undertaken and it is apparent that there is a conflict in approach, particularly relating to the provision of high quality family sized homes to meet future housing need.

2.10 PPS4 states that existing site allocations should not be carried forward from one version of the development plan to the next without evidence of the need and reasonable prospect of their take up during the plan period. If there is no reasonable prospect of a site being used for the allocated economic use, the allocation should not be

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______Page 7 retained, and wider economic uses or alternative uses should be considered. It also encourages new uses for vacant or derelict buildings.

2.11 Based on an assessment of total quantitative need, the consultation document

‘Towards a Preferred Core Strategy for Croydon' proposals that all existing UDP

Employment Area designations are retained. This recommendation contradicts PPS4 policy guidance which advocates that site designations are not taken forward without evidence of the need and reasonable prospect of their take up during the plan period - including a qualitative assessment of existing sites.

Employment Land Reviews: Guidance Note 2004

2.12 This guide was published to help authorities assess the suitability of sites for employment development, safeguard the best sites in the face of competition from other higher value uses and help identify those which are no longer suitable for 2.13 The guidance recognises that circumstances can and do change, and any review of employment land should start from the issues addressed in previous studies, without being unduly influenced by the conclusions of those studies (which may often have been undertaken under differing economic and property market circumstances).

2.14 It also emphasises that planning authorities should undertake the employment land review as far as possible at the same time as they are reviewing housing, with the emerging findings on land availability and suitability informing work capacity on both studies.

2.15 Council's are recommended to adopt consistent assumptions andand take account of both housing and employment requirements as well as the approaches across their housing capacity studies and their employment land reviews, economics of development and landowners' intentions, when assessing the likelihood that existing or allocated employment sites will remain in, or come forward for, employment uses within the plan period. Local planning authorities should also adopt a

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Page 8 systematic approach to assessing the development potential of sites suitable for mixed use development, where these will include either housing or employment. As stated above, there is no evidence that the findings of the Council's employment land availability study had informed the work on housing need.

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SECTION 3

3.1 This section considers the physical and economic characteristics relating to

Gloucester Road (West) Employment Cluster (URS Cluster No.C5a) within the wider context of the Spatial Management Areas (as defined by Croydon's consultation documents), with particular reference to the vacant site at Milton House, 2 Milton Avenue and 43 Gloucester Road. It provides a brief description of the area in terms of its physical characteristics and predominant uses and reviews the LDF evidence base as it relates to this area. It also identifies the physical and economic constraints that have deterred reuse of the Milton House site for employment purposes for over a decade.

Milton House, 2 Milton Avenue and No.43 Gloucester Road

3.2 Milton House, 2 Milton Avenue and No.43 Gloucester Road is a fragmented site comprising 0.79ha, currently occupied by derelict industrial buildings. The site occupies a significant proportion of the Gloucester Road (West) Employment Cluster. These industrial buildings are within a predominantly residential area and have been vacant for a considerable period. Milton House has been vacant since 1996. The former occupiers of No.43 Gloucester Road relocated to a commercial premises in Coulsdon in 2006, with modern facilities and direct access to the arterial road network.

[It should be noted that the site comprises 0.7ha in total and been vacant for over 4 years. The URS Industrial Market Assessment 2010 states that

Gloucester Road (West) employment cluster has 0.4 ha vacant premises - table

5.12]

3.3 The site is situated to the north of the CMC just off St James's Road (A222) and is bound by residential streets on three sides - Milton Road, Milton Avenue and Gloucester

Road - characterised by two and three storey terraced houses. A part 2 part 5 storey

100 bedroom residential care home has recently been constructed to the south of the site, on the corner of Milton Road and St James's Road. Higher density residential development lies to the south west in Gloucester Road/Bridge Place.

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Selhurst Ward Profile

3.4 Gloucester Road Employment Cluster is situated within Selhurst ward. The Ward

Profile identifies significant areas of deprivation in Selhurst, as shown by the Index of

Multiple Deprivation. Deprivation is focused around ‘Income' and ‘Living Environment'.

Areas experiencing the latter form are likely to be in areas where is a higher than average number of road traffic accidents, poorer air quality and a greater proportion of housing not meeting Decent Homes standards.

3.5 The Residential Character Appraisal identifies the predominant house type in this area as cottages, terraced houses and close knit semi-detached houses.

Planning Policy Context

3.6 Milton House, 2 Milton Avenue and No.43 Gloucester Road fall within an

Employment Area, as designated on Croydon UDP Proposals Map. The Gloucester Road

Employment Area is bounded by railway lines to the northwest and northeast, extending to St James's Road to the south. The Area includes a significant number of nonemployment uses including, vehicle hire company, 100 bed residential care home, residential dwellings and public house. The area to the south of Gladstone Road - including the Milton House site - is more fragmented than the larger area to the north of

Gladstone Road and east of Gloucester Road, and has limited road frontage.

3.7 Since 2002, a number of applications for permission to redevelop the site have been rejected by Croydon Council. Reasons for refusal related to the loss of commercial premises with a designated employment area and noise and disturbance to adjoining occupiers. An appeal was also dismissed in 2004 solely on the grounds of loss of the commercial premises.

Site Constraints

3.8 The reuse of the vacant and derelict Milton House site for any employment operation has been hindered for over a decade by the site's physical constraints which include the piecemeal site size and abnormal shape, limited road frontage as well as poor accessibility to public transport and the arterial road network and its location within a predominantly residential area. It also has poor accessibility to local services and facilities.

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SECTION 4

4.1 This section reviews the LDF Evidence Base and other published studies regarding future supply and demand for employment land and floor space in Croydon and considers whether the Milton House site would meet the requirements for employment land.

London Office Policy Review 2009

4.2 This review highlights that the degradation of Central London salary weightings together with the decimating impact of technology on back office functions has led to a massive reduction in the relocation market to Outer London areas. The relocation of companies from Central London to OL has decreased over the years (with the possible exception of the A4 corridor), and many companies that were located in Central London have relocated staff further afield, to the regions and abroad. The office policy review recommends that the office growth in Outer London office centres, in policy. Hence, many Outer London centres are now terms, should become more realistic more heavily reliant on offices that serve local demand, including local government and other public sector administration, although this demand is likely fall dramatically as a result of public sector finance cuts.

4.3 One of the key concerns identified in the office policy review is the role of

"marginal" office centres: those which lack critical mass, and which tend to benefit in hot markets, but which lose favour when demand falls. The review confirms that the office market has been stagnant, and in some cases in decline, for many years now in centres that, in policy terms, are expected to perform as office centres. It shows that economic viability for office development is a major inhibiting factor in Outer London at any time.

Very few locations command rental values that rendered development viable even at the peak of the cycle when investment yields were lower and rental growth was anticipated.

4.4 The on-going change of use of existing office stock and office land to housing has, in many instances, contributed to the regeneration and increased vitality of many areas.

The review regards the traditional blanket protection of offices as a recipe forcommonly in fringe locations, but also in core areas during vacancy and dereliction - market downturns.

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4.5 The report concludes that change from offices to other uses appears not to have damaged the strategic office market and, more positively, has provided significantly wider benefits to London through enhanced diversity. Office activities are constantly changing and the review regards it as increasingly important for planning policy to reflect the structure of demand over and above that for prime institutional space in core markets.

URS LB Croydon Office/Industrial and Warehousing Land/Premises Market

Assessment

4.6 The URS Market Assessment undertook a qualitative survey of employment land clusters in LB Croydon (outside the CMC) - including Gloucester Road (west) using criteria to analyse suitability for office and industrial uses as well as SME workspace.

Gloucester Road (west) performed poorly against the qualitative suitability criteria for all three employment uses.

4.7 Table 5.12: Summary of Site Survey Results for Employment Clusters Outside

CMC confirms that Gloucester Road (west) does not have very good or good PTAL rating or access to facilities and amenities. It does not have very good or good access to the strategic road network and parking is inadequate for industrial uses. The area has no potential to accommodate SME workspace and has a significant presence of Non-B class occupiers in the Employment Area. Finally, the area has vacant developable land.

[We would dispute URS' conclusion that the majority of sites in this

Employment Area are not in a poor or very poor condition. The vast majority of industrial buildings and sites south of Gladstone Road are either derelict, semiderelict or in a poor condition.]

Croydon Strategic Housing Market Assessments (SHMAs)

4.8 The SHMA estimates that the population of Croydon will rise to 361,400 by 2029.

This would represent a 7.5% rise in the period 2004-2029. The projections also show that the population of Croydon is likely to become older in the period up to 2029. In particular, the number of people aged 45 years and above is expected to grow

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Page 13 considerably However, it also shows that the younger population of the borough will decline.

4.9 When considering the migration flows for Croydon and the rest of south west

London, Croydon receives population from Lambeth and Wandsworth. Population flows typically ran from the north of the borough to the south, with population leaving for

Tandridge typically coming from the south of Croydon.

4.10 The data identifies that 78,408 people both live and work in Croydon. This represents around 61% of all those living in the area who have a job, and 50% of all those who work in Croydon. Of this group 13,372 work mainly at or from home, which represents 17% of all residents of Croydon who have a job.

4.11 Figure 28 shows the travel to work patterns for Croydon to and from each London borough. This shows that Croydon receives a net workforce from Bromley, Sutton and

Lewisham but overall there is a 33,455 net loss of workforce to other borough.

4.12 Figure 31 shows the net new VAT registrations in Croydon per annum. In total, since 1997 the number of VAT registered businesses has grown by 1,195. This represents an increase in registered businesses of around 15% since 1997, which is below the average across England as a whole and the London region where the number of businesses has grown by 18% and 23% respectively.

4.13 Croydon residents are disproportionately to be found in lower paying occupations, compared to the rest of London which further highlights the problems affording market housing. When considering the industry of employment of residents, it is apparent that construction, wholesale and retail trade, public administration and defence and health and social work are relatively important to the Croydon economy.

4.14 It is noteworthy that 50% of dwellings in Central Croydon are flats, while over

25% of dwellings in the South and East area are detached. The nature of the dwelling stock has a strong influence on determining the characteristics of the people that live in that area. Owner occupied housing has a higher proportion of detached, semi detached

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Page 14 and terraced houses and a lower proportion of flats. Social rented and private rented housing have more than 50% of the dwelling stock in the form of flats. 4.15 The increasing volume of households suggest that there will be a requirement for the social rented stock to increase by 3,800 units in the period 2001 to 2021. That is an increase from 23,300 dwellings to 27,100 dwellings over the 20 years. This is in the context of an overall increase of 17,700 households suggesting that social rented housing accounts for 20.9% of the additional provision required for the period 2001-

2021.

4.16 Across the whole of Croydon, 22.2% of households are predicted to be unsuitably housed which amounts to over 30,000 households. The SMHA identifies the requirement for social rented housing as 4,400 units of the 13,600 total requirements, equivalent to

32.2% of overall total requirement.

4.17 The proportion of households who are homeowners is projected to fall to 54.7% by 2021 with 9,800 less households being able to afford owner occupation than are to be currently found in this sector.

Croydon Strategic Housing Market Assessment 2010 Update

4.18 The SHMA 2010 update confirms that the number of 1 and 2 bedroom dwellings required will decline to 65% of the total, while 4+ bedrooms rise from 2% to 10% of the requirement. Therefore, there would appear to be a clear justification for providing an increased amount of larger social units.

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SECTION 5 5.1 This section provides specific consultation responses to proposed Core Strategy policy approach as it will apply to the Gloucester Road Employment Cluster and based on an assessment of the LDF Evidence Base as well as the adopted and draft revised

London Plan.

CS 1 - Modified Spatial Strategy

5.2 The Proposed Spatial Strategy envisages an approximate increase of 19,000 new homes and 15,000 new jobs could come to the borough before 2031 with the CMC capable of taking 10,000 homes and 7,500 new jobs. In theory both jobs and homes could be directed should be directed towards the CMC but it is designated as a Strategic

Office Location and Opportunity Area in the Draft Replacement Plan. The Home Strategy identifies the potential for 8000 new homes in the CMC and Environs, indicating a capacity of 1000 new homes in the CMC periphery (figure 4.3). 5.3 The Home Strategy also anticipates that 48% of new homes will be family sized homes (3 or more bedroom homes), of which 26% will be provided within the CMC &

Environs. Given the expectation that new homes within the CMC will be built at high density and the unsuitability of providing a large proportion of family sized homes within high density schemes, the onus will be put on sites surrounding the CMC, to provide a greater proportion of larger units, at lower densities than within the CMC.

5.4 The Respondent questions whether sufficient sites have been identified for housing development within the CMC Environs to meet projected need for larger homes, which equates to 26% of the total or 4,940 new homes by 2031. It is considered that in accordance with the approach recommended in PPS3, additional surplus industrial sites must be identified to meet the potential shortfall in land for family sized homes. These sites should be located on the periphery of the CMC with good accessibility to the Centre. 5.5 The Supplement acknowledges that ‘Places' in and around CMC have the greatest potential for positive change, which is dependant upon creating streets and places of character. The Respondent believes that the UDP designation of Gloucester Road

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5.6 Employment Area has inhibited its regeneration and that unless this designation is removed, future transformation of this area will be put at risk.

CS 2 - Homes 5.7 The Council acknowledges (paragraph 5.9) that almost half of new homes expected to be delivered must be suitable for family occupation and yet the majority of housing sites likely to come forward over the plan period will be in and around the CMC - an area where the majority of recent housing development has been made up of one and two bed flats. The consultation document suggests that over a third of new dwellings, in the region of 3,500 homes in the CMC will need to accommodate families.

5.8 We have serious concerns about the Council's strategy and its ability to deliver this number of family sized homes in the CMC. Given other strategic objectives for providing office, retail and leisure facilities in the CMC, I believe that there is insufficient land or sites available to provide for the necessary facilities - such as schools, health facilities and public open space - to support 3,500 additional families.

5.9 We consider that peripheral sites beyond the CMC boundary offer a greater opportunity to provide a larger proportion of family sized homes as well as associated infrastructure and local open space. Sites within the CMC will have a higher existing use value - reflecting alternative land uses - which will compete with relatively low value community uses.

5.10 We disagree with the Council's assessment of possible proportions of family and non-family housing for the CMC (figure 19). The expectation that a greater proportion of family sized housing could be provided in the CMC than has previously been delivered, is unrealistic and fails to take onboard the personal aspirations and choices of future family occupiers. It also fails to address the qualitative issues that arise in terms of outdoor amenity space and local provision of play space. As such, family sized housing in the

CMC is unlikely to achieve the design quality aspirations of the London Housing Design

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5.11 We also disagree with the suggestion that placing most new housing in areas of high transport accessibility makes good sense. High concentrations of family sized accommodation in high density CMC locations is likely to increase environmental problems as well as social isolation for occupiers. The Council acknowledges that there are no guarantees that an improvement of the scale needed to encourage families to reside in the CMC is deliverable. We believe that given the projected reduction in public funding within the plan period, overreliance on the private sector to deliver ‘liveability' in the CMC is also unrealistic. Sustainable medium density family housing on the periphery of the CMC should be the preferred strategy.

5.12 The Council's own Housing Typology Study confirms the difficulties in relying on high density CMC development to provide such a large number of family sized homes.

This study examines a wide range of typologies, many of them containing a portion of family housing as the scenarios seek to optimize the number of family units. A policy of only placing family housing in its ‘optimal' locations is recommended. Good family housing should have generous, safe, outdoor private amenity space together with an easy relationship to communal or doorstep play space. Preferably it should also have a simple direct access system that does not involve too many family units being accessed through one access core. 5.13 These constraints mean that the majority of family units end up being placed at the top or bottom of buildings where gardens or terraces are easily possible, placing too many family units midway up tall buildings makes the provision of sufficient outdoor amenity space difficult without making the building structure excessively expensive. It will not be possible to meet these design expectations - which reflect the London Design

Guide Standards - and still provide the proportion of family sized homes proposed. It is also evident that housing development within the CMC will not be able to meet the GLA

SPG on provision of play space for children and young people.

CS 3 - Industrial Locations

5.14 We strongly disagree with proposed policy approach for CS3 Industrial Locations.

5.15 The Council's approach is based largely on the recommendations of Croydon's

Office, Industrial, Warehousing Land/ Premises Market Assessment. The Assessment

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Page 18 draws conclusions that cannot be reasonably justified. Therefore, the Council's conclusion that "the latest available studies suggest it is justifiable to continue to strongly protect all industrial and warehousing premises (paragraph 5.19)" is based on a flawed industrial land assessment.

5.16 In particular, the Assessment acknowledges that the decline in demand for industrial land and premises will continue to fall over the plan period. It suggest that anticipated growth in demand for land for large scale wholesale storage and waste transfer facilities could be met by existing designated

5.17 Despite undertaking a qualitative survey of designated employment land, the

Assessment's conclusions and the recommendation to protect all industrial and warehouse premises are based purely on a quantitative balance between total land available and predicted future demand.

5.18 The Industrial Land Assessment confirms that although there are many strongly performing industrial areas such as Purley Way South and Marlpit Lane, some employment areas, such as Gloucester Road, have issues such as poor servicing arrangements, poor quality of premises and environment or are accessed via residential areas, and thus do not perform as well as they might within the strategic context. The

Council's Employment Land Studies and AMRs confirm that size, location and proximity to residential communities are significant factors in determining demand for industrial premises in the borough. Many of these designated employment areas - notably

Gloucester Road EA - are totally unsuitable for the growing employment sectors, such as large scale wholesale storage/distribution activities or waste transfer facilities. The proposed policy CS3 is based on an untested theory that existing employment land will be appropriate for warehouse/distribution or waste transfer uses. Many of these sites, particularly the Gloucester Road EA are totally unsuitable for these uses.

5.19 We would also question the basis of the Councils' subsidiary justification for seeking to retain all industrial and warehousing premises. Although the Industrial Land

Market Assessment acknowledges there are areas of UDP designated industrial employment land which do not meet the needs of warehouse/distribution or waste transfer uses, the Assessment suggests that these areas could benefit from Towards a preferred Core Strategy for Croydon

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Page 19 intensification, in order to provide a supply of new, modern premises (particularly to accommodate SMEs). The report suggests that employment clusters in New Addington and Fieldway are close to areas of deprivation and provide redevelopment and intensification which could stimulate local regeneration.

5.20 However, this proposal fails to take into consideration the existing surplus in relatively low rental office floor space in the borough which would be better suited to accommodate SMEs. The London Office Policy Review 2009 states that Croydon's identified office floor space capacity far exceeds demand both in percentage and absolute terms (paragraph 3.5.4). The supply/demand imbalance between 2007- 31 is predicted to reach 1,531% - greater than any other borough except Greenwich. The

LOPR suggests that "Croydon is so dominant within its own borough that we see little point in continuing to monitor Coulsdon, Purley or Norbury as potential office centre."

5.21 The URS Assessment confirms the LOPR findings. It states "given the relativelyIt should be noted that Gloucester Road Employment Clusters (C5A and static additional demand forecast for office floorspace outside the CMC (0 sqm to 6,500 sqm) and for industry and warehousing land (- 1,.8ha, mid-scenario) over the plan period, the sites listed in tables 10.2 and 10.3 have not been given priority weightings nor has the potential floorspace or land quantum arising from the redevelopment estimated."

C5B) are not included in Table 10.2: ‘Clusters Outside the CMC Best Suited for Office

Redevelopment'. It is concluded that Gloucester Road Employment Cluster (west) is not well suited for office, industrial or SMW uses.

5.22 Setting aside CMC office provision, there is sufficient surplus of office floor space within the borough to accommodate future needs for SMEs, in relatively low rent premises, without intensification of vacant and derelict industrial sites. Consequently, surplus industrial premises which do not meet qualitative criteria for future industrial use, are likely to remain vacant and under- utilised, fostering further urban dereliction not economic growth.

5.23 The Gloucester Road Employment Clusters are on the periphery of the CMC where there is already surplus floor space and which is the preferred location for further office provision. Such locations, which are not well suited for office redevelopment' would not

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Page 20 be able to compete with nearby office accommodation within the CMC. It would be more appropriate for such sites - particularly sites located on the CMC periphery such as the

Gloucester Road Clusters - to be used for residential purpose, thereby bringing beneficial change through regeneration.

5.24 We believe that the ‘five tier' sequential approach is an inappropriate approach that will not deliver the Council's Spatial Objectives. This approach does not accord with the approach advocated in the London Plan Industrial Capacity SPG or PPS3 and PPS4.

It does not provide greater flexibility and relies upon ‘marketing evidence' prior to release of surplus employment land, rather than plan-led release of based on qualitative and quantitative assessments of existing stock. This approach does not integrate with other spatial objectives, such the provision of family sized housing in appropriate locations. The ‘5 tier' sequential approach will perpetuate the ad hoc loss of employment premises to housing irrespective of the Council's spatial objectives or it will perpetuate continued urban decay and dereliction.

5.25 This approach does not accord with the approach advocated in the London Plan

Industrial Capacity SPG or PPS3 and PPS4. These documents recommend an approach based on qualitative as well as quantitative assessments of existing industrial land to identify surplus sites. They advocate the release of such surplus sites through the LDF process for other uses, including the provision of housing.

5.26 The sequential approach should be replaced by a plan-let reallocation of surplus employment land (based on qualitative as well as quantitative assessment of existing stock against requirements of future industrial occupiers) and should not include assumptions about existing Employment Areas previously designated in the UDP, where they are not identified as Preferred Industrial Locations within the London Plan.

Employment Areas on the CMC periphery - such as Gloucester Road -where residential development exists alongside industrial buildings, should be re-designated as preferred family housing locations. All employment sites in the CMC Environs - whether in

Employment Areas or not - should be assessed for their suitability for continued industrial use and alternatively, to provide family sized housing to meet the Spatial Objective for Housing.

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5.27 The proposed monitoring indicator measuring the amount of land and premises in

Industrial/Warehouse use does not monitor delivery of this strategy because it does not take into account qualitative factors, such as age, condition, size or accessibility, nor does it take into account whether available premises are meeting demand i.e. vacancy levels.

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SECTION 6 - SUMMARY AND CONCLUSIONS

The Milton House site occupiers a large area of derelict land in the centre of the

Gloucester Road (West) Employment Cluster. The site has been vacant for many years and there is reasonable prospect of its take up for employment use during the plan period.

Central Government policy statements requires local authorities to identify those sites which are no longer suitable for employment development which should be made available for other uses - using qualitative assessments. Gloucester Road (west) Employment Cluster performs very poorly against qualitative criteria used to assess employment area suitability for office and industrial uses as well as SME workspace.

Government policy statements recommends employment land reviews are undertaken at the same time as local authorities are reviewing housing capacity, with the emerging findings on land availability and suitability informing work on both studies.

The LDF Evidence Base should adopt consistent assumptions and approaches across their housing capacity studies and their employment land reviews and take account of both housing and employment requirements as well as the economics of development and landowners' intentions, when assessing the likelihood that existing or allocated employment sites will remain in, or come forward for, employment uses within the plan period. The London Office Policy Review considers that office growth in Outer London office centres, in policy terms, should become more realistic and traditional blanket protection of offices as a recipe for vacancy and dereliction.

The Proposed Spatial Strategy envisages an approximate increase of 19,000 new homes and 15,000 new jobs could come to the borough before 2031.

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The Home Strategy also anticipates that 48% of new homes will be family sized homes (3 or more bedroom homes), of which 26% will be provided within the

CMC & Environs.

In addition, 22.2% of households are predicted to be unsuitably housed which amounts to over 30,000 households. The SMHA identifies the requirement for social rented housing as 4,400 units of the 13,600 total requirements, equivalent to 32.2% of overall total requirement.

We have serious concerns about the Council's strategy and its ability to deliver this number of family sized homes in the CMC. Given other strategic objectives for providing office, retail and leisure facilities in the CMC, we believe that there is insufficient land or sites available to provide for the necessary facilities - such as schools, health facilities and public open space - to support 3,500 additional families.

We consider that poorly quality peripheral employment sites beyond the CMC boundary offer a greater opportunity to provide a larger proportion of family sized homes as well as associated infrastructure and local open space.

We believe that the ‘five tier' sequential test is an inappropriate approach that will not deliver the Council's Statial Objectives. This approach does not accord with the approach advocated in the London Plan Industrial Capacity SPG or PPS3 and

PPS4. It does not provide greater flexibility and relies upon ‘marketing evidence' prior to release of surplus employment land, rather than plan-led release of based on qualitative and quantitative assessments of existing stock, at the time of policy review.

This approach does not integrate with other spatial objectives, such the provision of family sized housing in appropriate locations. The ‘5 tier' sequential approach will perpetuate the ad hoc loss of employment premises to housing irrespective of the Council's spatial objectives or it will perpetuate continued urban decay and dereliction.

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We believe that the derelict Milton Road site should be reallocated as an appropriate site for housing, including family sized housing. This approach will help to address the shortcomings in the current spatial approach which would involve locating a substantial number of family sized houses in the CMC.

We believe that this approach will help to address the Spatial Objectives in terms of Housing Provision and regeneration of a deprived ward.

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REFERENCES

Planning Policy Statement 3 - Housing (2010)

Planning Policy Statement 4 - Planning for Sustainable Economic Growth (2009)

Employment Land Reviews: Guidance Note

, ODPM, 2004.

London Office Policy Review 2009

London Plan (Consolidated with alterations since 2004) Supplementary Planning Guidance

- Industrial Capacity March 2008

- Providing for Children and Young People's Play and Informal Recreation march

2008

GLA: Rapporteur Review of Overcrowding in London's Social Rented Housing October

2010

GLA Strategic Housing Land Availability Assessment (SHLAA) and Housing Capacity

Study (HCS)

Interim London Housing Design Guide August 2010

London Borough of Croydon Office Industrial and Warehousing Land/Premises Market

Assessment August 2010

London Borough of Croydon Economic Development Strategy

Croydon Office Market Review 2007

London Borough of Croydon Local Housing Land Availability Assessment - draft for consultation January 2009 CMC and Environs – Jobs The proposed leisure facility Cathy Hall Strategy The establishment of a new Local Centre at now under construction at 4.55 Fiveways is not considered appropriate. It is Waddon alters the context and GL Hearn acknowledged that Fiveways Corner is provides an impetus for Objection defined in the UDP (Appendix 1, Schedule 2) providing a Local Centre along Disagree – No Change as constituting a shopping parade (seven with further housing growth units at the junction of Denning Avenue and opportunities at nodal points Purley Way); however, the possible along Purley Way. establishment of a Local Centre must have regard to the definitions set out in PPS4. Local centres are defined as follows:  ‘Local centres include a range of small shops of a local nature, serving a small catchment. Typically, local centres might include, amongst other shops, a small supermarket, a newsagent, a sub-post office and a pharmacy. Other facilities could include a hot-food takeaway and launderette. In rural areas, large villages may perform the role of a local centre.' (Annex B: Definitions, PPS4)  The cluster of existing shops can be seen to fulfil this definition; however, it is not considered that these existing services can be regarded as meeting the PPS4 definition of a Local Centre.  Fiveways represents a disparate collection of retail parks, extending over 400m along Purley Way and dissected by the junction of several strategic roads. Although the draft document does not attempt to define the boundary of the proposed new Local Centre, it is assumed that the Council intend to incorporate a number of the existing retail parks. When consideration is given to the services provided by these retail parks (present occupiers include a Texaco petrol filling station, Homebase, Furniture Village, What!!! Home and Leisure, Porcelain (Ceramic Tiles and Bathrooms), PetsAtHome, McDonalds and Magnet), it is apparent that none can be regarded as fulfilling the PPS4 definition of serving a small, local catchment. Although a number of local facilities, including a newsagent/convenience strore, launderette and hot-food takeaways are provided on Denning Street/Purley Way, these are already included within the designated shopping parade. There is no legitimate land-use planning purpose. in upgrading this location to a Local Centre; indeed, it may result in unwelcome retail expansion at what is effectively an out-of-centre location.  The need to allow easy pedestrian access in the designation of centres is given prominence in PPS4 by Policy EC3. The existing separation issues posed by the strategic road network prevent Fiveways from providing a local and convenient function for local residents. Bearing in mind the strategic importance of the road network in the vicinity, it is unclear how sufficient pedestrian upgrades could be delivered to address these deficiencies and result in the creation of the Local Centre that could effectively serve a catchment as described in the PPS. The proposed designation of Local Centre should not be used as an attempt to regularise existing out- of-centre retail provision. Designation will be taken as a signal that further retail floorspace is acceptable in this location; without addressing the identified deficiencies in the pedestrian environment, it is likely to result in the creation in the consolidation of retail in an area that continues to be dominated by the road network and inevitably access by the private car. Furthermore, PPS4 requires LPAs to maintain a robust evidence base to inform development plans. With reference to Borough-wide Retail Needs Study Update 2008, prepared by Drivers Jonas, it is noted that the Study does not propose any alteration to the status of Fiveways Corner as a shopping parade. The proposed designation is not therefore regarded as complying with the requirements of Policy EC1.3 which sets out that, at a local level, the evidence base should be used to â˜assess the capacity of existing centres to accommodate new town centre development taking into account of the role of centres in the hierarchy'.  It should also be noted that the Figure 7.5 (Key Diagram) appears to designate Fiveways as a ˜Proposed District Centre'. Considering the direction at Paragraph 4.55, this is assumed to be erroneous. Notwithstanding the comments made above on the appropriateness of any designation for Fiveways, this diagram should be corrected to reflect the broader contents of the draft document. CMC and Environs – Jobs Tesco are currently engaged in pre- Prominence is rightly given to Cathy Hall Strategy application discussions with members of your B2 and B8 Class Uses within 4.53 Council's Development Control team in the Strategic Industrial Location GL Hearn relation to proposals for retail-led regeneration because of this London Plan Objection of their site at 330 Purley Way.  designation and Croydon's Disagree – No Change Employment Prominence is given to the 'Restrictive Transfer' status in Purley Way area as a Strategic Industrial relation to Employment Land. Location, and therefore its suitability for B This designation is not only Class Uses.  However, PPS4 is clear in its supported by the evidence definition of economic development as associated with the London incorporating main town centre uses Plan, it is also supported by the (including retail development), as well as Council's own evidence base. development falling into B Uses Class (para. 4). Policy EC2 directs local planning authorities, in preparing their development plan and safeguarding land for specific uses, as follows:  ‘Existing site allocations should not be carried forward from one version of the development plan to the next without evidence of the need and reasonable prospect of their take up during the plan period. If there is no reasonable prospect of a site being used for the allocated economic use, the allocation should not be retained, and wider economic uses or alternative uses should be considered .' (Our emphasis) We therefore consider the approach taken by the draft Core Strategy with regard to Purley Way as unduly restrictive; it does not give sufficient regard to the fact that the majority of the sites have extant A1 Use Class planning permissions. Restricting development to B Class Uses does not have full regard to the role of retail as a generator of employment. CMC and Environs – Jobs This issue will be addressed in Mr Michael Mulhern Strategy the future Development 4.43 Section 4: CMC and Environs - Jobs Strategy Management DPD. Greater London Authority

Observation TfL notes that section 4 and in particular Noted paragraph 4.43 set out circumstances for which applications for change of use from industrial land to community uses would be acceptable. Whilst TfL supports that this will only take place in areas with improved public transport accessibility, the Borough should however consider that where change of use is to a place of worship, this can often introduce substantial additional parking stress to surrounding roads (particularly for larger sites). This would therefore also need to be considered as part of any change of use application. CMC and Environs – Jobs Jobs. The document advises that there is Comment is noted CGLP Strategy expected to be a shortfall in demand for office 4.47 space in Croydon in the short/medium term. CGLP However, in long term (up to 2031) demand is Observation forecast to exceed the current supply with an Noted additional office floor space requirement to accommodate 2,000 more workers. Whilst there may be a demand for some lower grade office space in the Centre, there is a large over-supply of second grade offices in Croydon which could provide affordable accommodation for smaller businesses. CGLP wish to point out that there are a number of developments permitted or proposed in the Centre that comprise a large element of office floorspace, such as the CGLP Ruskin Square scheme, which will deliver Grade A office space. As an evolution of the consented scheme, the emerging scheme for Ruskin Square is intended to provide flexibility in terms of office floorplates to suit the needs of potential office occupiers and meet anticipated economic and social needs. Within the centre, CGLP consider that to assist in the delivery of Grade A office space, the redevelopment of empty or under-used office space should be encouraged by the Council. The Core Strategy should reflect the ‘Strategic Office Location' designation in the draft London Plan which identifies the area for significant growth in office and residential uses. The CGLP Ruskin Square scheme will provide a significant quantum of both office and residential uses. As such, the scheme will meet the aspirations set out in paragraph 4.28 of the document in providing a mixed use development enabling new residential development around East Croydon Station whilst not jeopardising the future delivery of prime office floorspace. CMC and Environs – Jobs Jobs Support is welcomed and the Mr Keith Hearn (Minerva) Strategy other comments are noted. The 4.43 We strongly support the vision for CMC set request for a meeting will be CBRE out on page 28 of the CS supplementary passed onto the project Observation document, which states that Croydon "will manager for the mid-Croydon Noted provide the principal retail and leisure offer in Masterplan. outer south London (including for visitors and workers arriving from Gatwick Airport) and its tree-lined streets will look more attractive than sterile shopping and leisure malls in other parts of London and the immediate south east". We agree with the statement in paragraph 4.27 that a balance needs to be struck between growth in jobs and new homes.

We consider that retail development can help to contribute to the jobs Croydon is required to deliver (pursuant to the London Plan Opportunity Area allocation) over the CS period. Retail development will provide a significant number of jobs, including a range of full and part time jobs, and skilled/ managerial as well as unskilled positions. As such, we consider that jobs provided by retail developments should be given explicit mention and policy support in the CMC and Environs Jobs Strategy (on page 30 of the document).

We note that the Council's latest retail study shows potential retail floorspace capacity of up to 50,000 sqm over the period to 2021. Minerva supports the study's findings in that Croydon needs to improve its qualitative retail offer, and is committed to working with the Council to deliver this. As you are aware from our previous letter to the Council, dated 24th August 2010, Minerva has a number of concerns regarding the Retail Strategy Report for CMC (Drivers Jonas 2009). To date we have not received a response to this letter. As you are aware, in accordance with the ‘tests of soundness' set out in PPS12, to be ‘justified' the CS needs to be founded on a robust and credible evidence base. We would therefore welcome a response to our 24th August 2010 letter, and a meeting to discuss these concerns, so that any issues can be resolved prior to submission of the CS to the Secretary of State and its subsequent Examination in Public.

Turning back to the CS, we also note the comment in the final sentence of paragraph 4.32 which states that the downturn in the economy may provide a window of opportunity to move forward when development in competing centres is being held back. We are therefore pleased to see that Croydon is investing in its planning framework now, as having this is in place means that developers and other stakeholders can maximise the opportunities this provides for long term sustainable regeneration, as soon as market conditions improve.

We note paragraph 4.32 which states that a short-term strategy to make use of empty buildings/ cleared sites is essential. Minerva would be interested to know more about what this might involve, particularly in terms of retail units. CMC and Environs – Jobs We therefore propose the policy is amended Unlike the approach taken with Cathy Hall Strategy as follows: '4.53 The Council will continue 'scattered' Employment Sites, 4.53 strong protection for industrial and the Council does not intend to GL Hearn warehousing activities on the Strategic introduce policy exemption Objection Industrial Location of Purley Way and criteria based on Disagree – No Change Beddington Industrial Area. If appropriate marketing/demand in relation to marketing undertaken on a site-by-site basis designated Employment Areas. shows there is no demand for these activities, The '4-tier' approach to proposals for alternative economic Employment Land set out in the development will be considered subject to consultation draft published in compliance to other policy tests. ' ' The Feb 2010 is supported by the aspiration to establish mixed-use evidence base and considered developments on existing large retail sites to be an appropriate balance along Purley Way, as set out at within the between maintaining a relatively Croydon Metropolitan Centre and Environs - strong position, in line with the Job Strategy (para. 4.55) is supported. borough's 'Restrictive Transfer' However, regard must be given to the role of status in the London Plan, economic viability of such redevelopments. whilst offering a greater degree We would therefore propose the policy is of policy flexibility than currently amended as follows: '4.55 The Council will exists. seek to establish mixed-use developments on Regarding the suggested existing large retail sites along the Purley wording for para 4.55, the Way. In establishing the mix of uses, Council considers that appropriate regard will be given to economic alongside a whole host of other viability'. factors, giving regard to economic viablity is a pre- requisite to virtually all development proposals and therefore does not need to be stated explicitly. CMC and Environs – Jobs Employment The Council accepts that Mr Michael Mulhern Strategy greater clarity is required when 4.43 34 It is recommended that the Council provide expressing the five-tiered Greater London Authority a clear list of industrial categories with clear approach to industrial Objection definitions as to what land uses would be land/premises and will seek to Agree – Propose Changes appropriate within each use i.e. clear achieve this in the next iteration definitions should be provided for ‘Separated of the Core Strategy. and Integrated Industrial Locations'. The Council should also clearly explain how these uses relate to the five tiered approach set out in the Preferred Options report (2a). In addition, a clear reference to London Plan policy 2A.10 on Strategic Industrial Land protection should be included. It would also be of benefit to show these locations and varying industrial areas on a plan or diagram. 35 Where the Core Strategy notes that some residential development could be permitted in industrial/warehousing premises/sites as part of mixed-use development proposals, it should be made clearer what type of industrial locations such a mixed-use approach would be appropriate within. CMC and Environs – Jobs CMC and Environs -Jobs Strategy. It would The comment is noted and will Menta Strategy not be appropriate for the entire "East be reviewed as part of the 4.47 Croydon Masterplan Area (east of station development of the next Menta tracks)" to be promoted for Class B1a space iteration of the Core Strategy. Observation in terms of viability, character or the Noted – To be Reviewed overarching desire for mixed use development. The sites under Menta control are subject to emerging proposals that could provide a limited amount of Class B1a space, but the majority of such floorspace in this area would be most appropriately located to the south, adjacent to the station building. CMC and Environs – Jobs CS3 Industrial Locations The Council does not accept BRB (Residuary) Ltd Strategy the assertion that Proposed 4.43 Although BRB (Residuary) Ltd considers the Industrial Locations Strategy BRB (Residuary) Ltd Proposed Industrial Locations Strategy to be represents a ‘blanket approach' Objection sound in principle, it is also considered that to the loss of industrial land. For Disagree – No Change the strategy as presented in the Towards a example, the wording in para Preferred Core Strategy document is flawed 4.43 identifies that for some by adopting a ‘blanket approach' to the loss of industrial/warehouse premises, industrial land. Consequently, the Strategy a change to D1 Use will be fails to take into account that there may be permitted. The forthcoming sites that are unsuitable for continued Development Management industrial use and where redevelopment for DPD will provide more detail on other uses would be a better alternative. this policy area and will consider the inclusion of Clearly, the location of the site will be a suitable exemption criteria so significant factor in determining whether an that industrial sites falling existing industrial site would be more outside of the designated appropriately used for an alternative use. Industrial Locations, which are Existing industrial sites which are located in no longer suitable for industrial mixed use areas and/or close to the town use, can be released where centre, and/or with currently low utilisation for appropriate. employment purposes, may be well suited and more efficiently used for other purposes. The Proposed Industrial Locations Strategy should therefore be sufficiently flexible to focus industrial use on established industrial estates and larger sites located close to main roads, whilst allowing for the loss of existing industrial uses in those locations where alternative uses would be more appropriate.

BRB (Residuary) Ltd therefore considers that all industrial sites should be considered on their merits, and that flexibility needs to be specifically built into the Strategy. Although I have used the term ‘industrial' here in keeping with the wording used in the Proposed Industrial Locations Strategy, it is considered that this flexibility should apply equally to all employment generating uses.

BRB (Residuary) Ltd also considers that the Proposed Industrial Locations Strategy also conflicts with other objectives in the Core Strategy, particularly the aspirations for the Croydon Metropolitan Centre (CMC). It is noted that the Council envisages a significant proportion of new housing to be located within the CMC and that a significant proportion of this new housing will be family housing. Housing suitable for families is likely to require ground level location, even if smaller units are located in upper storeys. Consequently, it is likely that new sites will be required to accommodate new family housing within the CMC. Even if some of these new dwellings are provided by redeveloping existing residential sites at higher densities, it is likely that sites currently within industrial use will be required if the Council's aspirations for the CMC are to be realised. By adopting a blanket approach to the loss of industrial land, the Proposed Industrial Locations Strategy fails to recognise this requirement and therefore conflicts with the Council's wider aspirations for the Croydon Metropolitan Centre. It is considered that this defect renders the Core Strategy undeliverable in relation to the Croydon Metropolitan Centre, and therefore unsound as currently drafted. CMC and Environs – CGLP supports the general principle of The comment is noted. The CGLP Transport Strategy improving the bus service facilities within the details of new interchange 4.82 CMC. However, the document advises that facilities in Croydon CGLP the Council will seek to ease pressure on Metropolitan Centre will be Objection West Croydon Bus Station by providing new subject to formal consultation Noted – To be Reviewed interchange facilities on Wellesley Road "and through the formulation of Dingwall Road." CGLP strongly consider that masterplans and an Opportunity any proposed interchange facilities must be Area Planning Framework. This the subject of public consultation with adjacent representation shall be passed landowners as an interchange will to the appropriate masterplan detrimentally effect the development and project teams for consideration. hence regeneration of the Ruskin Square site. At this stage, there are no details as to the extent of a possible interchange and how this can be accommodated in Dingwall Road and such a proposal does not appear in any Transport Strategy. Furthermore, it is not clear how an interchange in Dingwall Road would ease pressure around "West Croydon Station". The provision of an interchange in Dingwall Road is not reflected in the East Croydon Masterplan (˜Site EC12 Dingwall Road') which states that one of the objectives for Dingwall Road is for improvements to the public realm and bus stop facilities. For these reasons, the reference to the provision of an interchange in Dingwall Road should be deleted from the Core Strategy. CMC and Environs – CS identifies the following problem areas but The details of the transport Mr Robert Rudman Transport Strategy does not set out solutions, particularly in light impact of housing and of expected population increase in Central employment growth in the CMC Resident Croydon from Berkley, Stanhope & Schroders, and Environs Area is being Observation Menta developments, circa 1,500 dwellings. explored in modelling work. Noted – To be Reviewed 4.72 Streets being heavily parked 4.73 Suffers Appropriate action to mitigate from periods of traffic congestion. The Core transport congestion will be Strategy lacks consideration for car parking considered in the Opportunity and traffic flows around East Croydon and Area Planning Framework and must take into account the traffic and parking with recommendations of the increase that residents and offices in CMC Transport Strategy. developments above will bring, not least visitors and service vehicles. Assuming that the strong transport links alone will attract occupiers or cope with demand is a risk to the regeneration. CMC and Environs – Roman Way is a barrier between Waddon and The comment is noted. Joy Prince Transport Strategy the Centre. East-West crossings are few, Fiveways and Roman Way 4.82 difficult and unpleasant. They should be have been recognised at this improved or replaced and supplemented to stage of the Core Strategy's Observation achieve more, east to use and pleasant formulation, both in 'Towards a Noted crossings by any and all modes of transport. Preferred Core Strategy for In essence, Roman Way should be made Croydon' (February 2010) and permeable. Transport Fiveways is already an 'Towards a Preferred Core accident blackspot. 30+ years of talking about Strategy for Croydon - and nothing achieved. Someone has to bit the Supplement' (September 2010). bullet, spend the money and build an Fiveways is described as a underpass for the A23 traffic. Cycles and significant congested pinch pedestrians to have priority above ground. point junction disrupting buses and vehicle flow in the borough. Both Roman Way and Fiveways are explicitly referenced in the Transport Strategy as requiring junction improvements. Fiveways is also cited in the more general policy for A23 enhancements over the plan period. In addition improvements for pedestrians and cyclists are promoted in the Green Grid policy which illustrates improved linkages between Wandle Park and Croydon Metropolitan Centre. These improvements to Roman Way are being brought forwards through the Connect2 project which will provide a new at grade crossing in this location. CMC and Environs – Page 36: 4.84 - Long Term Bull point 3 The Noted. The viability and Mr I.G.M. Hunter Transport Strategy Tram system should be extended to Purley in technical assessments for 4.83 the medium term. potential tramlink extensions will Resident be tested by TfL as part of the Objection strategic assessment of tramlink Noted extensions. The final policy wording shall be informed by discussions with TfL and other specific consultees in order to ensure the Core Strategy is flexible and deliverable. CMC and Environs – Page 36: 4.83 - Medium Term CMC and Not an LDF issue. Mr I.G.M. Hunter Transport Strategy environs Transport Strategy: Bull-point 5 4.83 should be enhanced by adding "The buses Resident themselves should be made more shopper- Objection friendly with enhanced room for shopping No Action – Not an LDF Iss bags etc. CMC and Environs – Section 4: CMC and Environs - Transport The comment is noted. The Mr Michael Mulhern Transport Strategy Strategy council will continue to work 4.82 closely with TfL on proposed Greater London Authority It should be noted that the review of road transport improvements. Observation junction capacities and easing of congestion Noted on the A23corridor may not have a lasting effect and may result in reassignment to these routes and junctions. Cleaner vehicles and stricter emissions standards are likely to have a longer lasting effect on improving air quality.

TfL suggests the following wording should be added to paragraph 4.82 Short Term (2012/2017):

"The Council shall work with London Tramlink to provide additional trams to address peak crowding between Therapia Lane and Elmers End, relieving congestion through Waddon, the CMC and Addiscombe."

TfL supports the promotion of car free developments under paragraph 4.82 and agrees that it will be important in areas with high Public Transport Accessibility, such as the CMC, to minimise increase in road traffic.

In regards to bullet point 3, TfL feels that whilst the option of a new bus station on Dingwall Road is worth investigating, it should be noted that this conflicts with the emerging East Croydon masterplan proposals at present.

In regards to bullet point 5, the Council should consider that any parking associated with new developments should be minimal within the CMC due to its high PTAL. CMC and Environs – Section 4: CMC and Environs - Transport The definitions will be reviewed. Mr Michael Mulhern Transport Strategy Strategy 4.82 Greater London Authority Paragraph 4.82 (and in a number of other Observation places within the document) refers to the Noted – To be Reviewed ‘Cycle Hub' concept. The glossary, defines this as "A point for collecting or returning bicycles available for hire", however the footnote reference 119 (page 71) uses a different description: "...an area where potential for a shift is greatest". TfL feels these definitions require clarification in order to make them consistent and correct. CMC and Environs – Please read these comments in conjunction The overall direction of the Mr Brian Madge Transport Strategy with my earlier submission and those representation is noted. submitted by the Pegasus Planning Group on Brian Madge Ltd behalf of Devogrove Limited. These further Observation comments relate not only to the generality of Noted the Strategy but also the sustainable development opportunity which can be identified between Kent Gate Way and Lodge Lane at Addington, adjacent to the Addington Village tram stop I bus station. CMC and Environs – Section 4: CMC and Environs - Transport The comment is noted. The Mr Michael Mulhern Transport Strategy Strategy council will continue to work 4.84 closely with TfL on proposed Greater London Authority Paragraph 4.84 refers to the proposed transport improvements. Observation introduction of ‘bus rapid transit along the Noted A235 Brighton Road', however there is no mention of the appraisal into its viability in either the short or medium term sections at paragraphs 4.82 and 4.83. TfL would like to see how and when the assessment of the bus rapid transit is proposed within these sections.

Under paragraph 4.84, TfL suggests the second bullet point should read "The Council will also support and promote tram extensions northwards in the borough and to Bromley, Sutton and Tooting." CMC and Environs – There remains a problem with transport links The comment is noted. Mrs T J Hague Transport Strategy to St. Andrews School. There is no bus Strategic transport policy shall serving the school, there is a stop at the end be refined to address a number of the Flyover, but then you need to cross the of these points on strategic Observation 4 lane flyover and its slip roads. You can get borough-wide basis. Detailed Noted the tram to Church Street but then have to site specific policy will form part negotiate the Subway by the Parish Church of the Site Allocations and (frequently flooded in Autumn & Winter and Development Management not pleasant at other times) or cross 6 lane DPDs. Roman Way using the pedestrian crossing; either way you've still got various residential streets to negotiate to get up to the School. It's even more of a nightmare by bike. Effectively Roman Way and the Flyover isolate the School, forcing parents to drive, which is not desirable for numerous reasons (Parking & traffic, health and air quality. Fitness and obesity). CMC and Environs – TRANSPORT PRICES The comment is noted. Mr Guy Salt Transport Strategy Planning cannot control public 4.82 At present, the Inland Revenue's highest rate transport fare charges. Sanderstead Residents' for reimbursement of business mileage for However, the Core Strategy Association cars is 40p per mile. At present, the Oyster does propound policy that Objection pay as you go fare on London's buses is seeks to restrict car parking Disagree – No Change £1.20 for any single journey. An average bus spaces for development in journey is about three miles long so the casual areas with the highest levels of bus passenger is paying about 40p per mile. public transport accessibility This means that it is economic for many levels and seeks to promote people to own cars and for those who do own policies and development which them to use them for most journeys where reduces reliance on car borne there are no parking charges at their travel. destinations. For many journeys, the car provides travellers with a lower door-to-door The council will continue to journey time than the more sustainable modes work with Transport for London of transport. This means that car use and car to improve transport in the ownership will continue to increase which borough, including reducing means that demand for car parking will also congestion for motor vehicle continue to rise. This is incompatible with a transportation. Transport Planning Strategy that reduces car parking infrastructure will be addressed space per dwelling. more fully in the Infrastructure Delivery Plan. TRANSPORT PROPOSALS Site specific parking issues will Most of the transport proposals are either for be dealt with in the new infrastructure or increasing capacity for Development Management, movement. Potentially, most involve an Development Plan Document, increase in the use of energy. Experience with with strategic policy to be Tramlink and the Coulsdon by-pass shows contained in the pre-submission that new infrastructure providing new capacity version of the Core Strategy. for movement can be successful in increasing travel. There is, however, no good evidence that new infrastructure reduces the overall level of congestion: the demand for travel generally increases to fill (and often overload) available capacity with serious congestion appearing in formerly uncongested locations..

PARKING CHARGES

Parking charges are probably not applicable to the majority of journeys made by car at present but do influence motorist's travel. Travelling to a distant destination can often mean that the parking charge is lower than at a nearby destination. Hence parking charges can result in additional car travel that offsets the cost of additional mileage. Hence, they are not a means of restraining car use.

THE FUTURE

There is no doubt that the cost of fuel for motoring will rise. However, the cost will need to double before the motorist finds that he can save money by choosing public transport and leaving the car in the garage when free parking is available at his destination. Given that tax is a significant element of the petrol price, it will be very difficult politically to double the pump price of petrol.

CONCLUSION

I consider the overall strategy is "Planning for Gridlock" CMC and Environs – Paras 4.82-4.84. We note the Council's The comment is noted. Parking Mr Keith Hearn (Minerva) Transport Strategy aspirations, as set out on pages 35 and 36 of provision for specific sites or 4.82 the CS, to promote car free development in masterplan will be subject to CBRE areas with high PTAL ratings. We agree that separate consultations and will Observation there is a need to review car parking provision be considered in the Noted in CMC to ensure that future car parking Opportunity Area Planning provides a well balanced and convenient Framework, whereas the Core facility that does not weaken the Strategy will set out the attractiveness of public transport or create boroughs strategic direction. barriers to pedestrian and cycle movement. Minerva considers there may be scope for car parks being ‘shared' between different users, for example car parks used by commercial (office) workers during the week being used by shoppers at the weekend.

However, we consider there will continue to be a proportion of the population for whom car parking is required to sustain their use of the town centre as existing and with regard to future developments. As such, while Minerva will not necessarily want to increase the car parking provision on its site beyond the existing level, it will seek to maintain current levels of parking provision (and aspires to improve the quality of this). We seek to ensure that in any future masterplans for the CMC area (particularly Mid-Croydon), the vehicular access to Minerva's site is considered and protected. These comments are made particularly in the context of the CMC Transport Strategy June 2010, which suggests that a bus interchange in the Park Street/ Park Lane area could be delivered through closing Katherine Street to general traffic and making Park Street bus only. Culture- Croydon We do not have any specific comments to Support is welcomed. Mr Keith Hearn (Minerva) Metropolitan Centre make on the CMC Cultural Planning Strategy, but support the CS objective of raising CBRE Croydon's profile through Culture. Observation Noted Culture- Croydon Page 31; 4.59 No mention again of the The comments are noted. Mr I.G.M. Hunter Metropolitan Centre Warehouse Theatre, a point raised by me in Whilst the Warehouse Theatre 4.59 the previous consultation. is recognised as a much valued Resident local asset a specific policy has Objection not been included as it does not Noted have the same regional significance as the Fairfield Halls. Culture- Waddon The entire paragraph is one great dollop of The comment is noted. Ahead Mr I.G.M. Hunter 4.62 hypocrisy. Two years ago the Council wilfully of its demolition as part of the Resident allowed the last remaining hanger on the Old Costco redevelopment, Council Observation Croydon Aerodrome site, to be demolished- officers did seek to persuade Noted not dismantled and stored. In this ruination of English Heritage to list the the Borough's proud history the Council were hangar referrred to. ably abetted by English Heritage who apparently saw no value in the structure. The belated recognition of the "Strategic Significance to Croydon's future of this heritage", is an unwelcome reminder of the Council's jaw-dropping indifference - in the face of Public objection, to the destruction of a building older than the surviving Croydon Airport structures. Culture- Where are we 1) No mention of Warehouse Theatre The comments are noted. Mr Sean Fitzsimons now? Whilst the Warehouse Theatre 4.56 is recognised as a much valued Resident local asset a specific policy has Observation not been included as it does not Noted have the same regional significance as the Fairfield Halls. Homes – South Croydon Page 26: Homes - South Croydon, second The understanding that this is a Mr I.G.M. Hunter sentence ; What is meant by (a) "ensure" that Place where the Core Strategy Resident the Place is largely residential? (note - I does not envisage radical Observation understand from conversations with those change is correct. The Local Noted – To be Reviewed responsible for the Document, that it means Centre referred to is known by that the current status of the Place will not be the Council (in the UDP and radically changed; perhaps this could be related documents) as 'Brighton confirmed?) and (b) If the first "local centre" is Road, South Croydon' and South Croydon - named on the map on page relates to the cluster of activity 37 of the Document, what is the other - which includes the Red Deer "Purley Oaks"? it is nonsensical to call it Public House. The Council "Brighton Road2 since that is the main accepts that to avoid confusion transport corridor through the area is it not? the full title should be given on the Key Diagram. Homes- Croydon Plan for East Croydon looks very good. Glad Support is welcomed. The Anonymous Metropolitan Centre to see housing plan includes provision for borough growth strategy which 4.9 family homes of 3+ bedrooms. There are too has been developed recognises Unknown many flats being built. Building of houses (para 1.12) that any growth or Support needs investment in infrastructure of roads / regeneration as set out in the Noted schools / shops / doctors at same time. policies contained within the Infrastructure is too often left until after Core Strategy, must be housing density is too high for existing underpinned by investment in infrastructure. hard and green infrastructure to ensure that Croydon adheres to its sustainable development principles. In the future, Croydon’s population also needs to be supported by a range of good quality services and facilities through the provision of adequate and high quality social infrastructure. Homes- Croydon Paragraph 4.11 notes that, with regard to The comment is noted Mr Keith Hearn (Minerva) Metropolitan Centre housing, "hard choices, innovation and some 4.11 compromises will be required in terms of CBRE policy and delivery, particularly if the Support residential and commercial markets both Noted revive in Croydon". We agree that flexibility in the application of policies, and acknowledgement of this in the CS, will be key to ensuring viable development can be progressed in CMC. Homes- Croydon We support the suggestion in paragraph 4.13 The support is welcomed. Mr Keith Hearn (Minerva) Metropolitan Centre which states that "much of the housing less 4.13 suited to families will need to be provided in CBRE taller buildings in the more central parts of Support CMC (such as Mid-Croydon) with homes more Noted suitable for families located in areas towards the edge of CMC". Homes- Croydon Page 23: 4.9 - Homes CMC The objections to Paragraph 4.9 is intended to Mr I.G.M. Hunter Metropolitan Centre "high rise" and "over- development" were highlight that it is possible to 4.9 made in my comments on the previous plan for more homes in Croydon Resident Consultative Documents; has no-one learnt Metropolitan Centre than is Objection anything from a) the concerns about residents proposed in the Core Strategy Disagree – No Change of high rise flats and their psychological and but instead a greater number of social problems b) the squeezing-out of larger homes suitable for families will 3-4 bedroom properties in the CMC for be provided and fewer tall families? buildings. A Housing Typologies Study has been prepared which indicates how to accommodate families in Croydon Metropolitan Centre. It also suggests a range of different housing types in a range of buildings suited to the proposed occupants. Homes- Croydon 45 Paragraph 4.8 notes that whilst Wandle The Core Strategy will review Mr Michael Mulhern Metropolitan Centre Park, Queens Gardens, Park Hill Park and the need for further explanation. 4.8 Duppas Hill are neither Metropolitan Open Greater London Authority Land nor Green Belt, they do perform an Observation important function, which is supported. Noted – To be Reviewed However, the Core Strategy may benefit from providing an explanation as to what level of protection these important open spaces would have. Homes- Croydon Who will make the "hard choices", and after This sentence refers to the Mr I.G.M. Hunter Metropolitan Centre what type of public consultation (PP 1 Development Management 4.11 guidelines)? DPD and the development of an Resident Opportunity Area Planning Observation Framework for CMC (both will No Action – Not an LDF Iss be subject to public consultation with the 'type' to be determined). As the Core Strategy is a 20 year plan, it also refers to the development management process by which individual planning applications are determined (and consulted upon). Homes- Croydon We also believe that it is right to provide more Comment is noted. The Council Mr Charles King Metropolitan Centre living accommodation in Croydon town centre agrees that new employment 4.9 as this will make the town centre retail outlet opportunites must be created to East Coulsdon more viable as it will provide more people who ensure homes growth does not Residents' Association regard the town centre as their local shops. lead Croydon towards dormitory Observation However, there must also be new employment town status. Noted opportunities to support these new people or they will simply commute by car or train and the centre will just become a dormitory town Homes- Croydon Page 24: 4.12 Since "high densities" and "tall The potential location of new Mr I.G.M. Hunter Metropolitan Centre buidlings are not publicly desirable for the homes in Croydon Metropolitan 4.12 reasons given in my comments on 4.9 above, Centre is based upon an Resident what sort of "competitive edge" is being analysis of potential Observation referred to?. We have already seen that development sites in the Noted "affordable" accommodation that was planned Housing Typologies Study. This for the 44-storey tower block in Wellesley included some sites with Road, is being delivered elsewhere, with planning permission and some Council agreement, and yet they still seem sites with future development confident that there will be space for 7,300 potential. Elsewhere in the new homes. Are the Council excluding from borough sites with planning the figure of 7,300 the "displaced" affordable permission have been included housing from the Barclay Homes agreement within the overall numbers of and, if not, where are those additional homes in their respective place. "affordable" properties going? Should it not A requirement for off-site also be the case that the affordable housing provision of affordable homes to under these type of viability agreements, be be provided concurrently is a built concurrently with the project which matter that is too detailed for a caused their displacement. If not, vital Core Strategy. residential building will be delayed. Homes- Croydon Page 24: 4.13 What makes the Council think The Housing Typologies Study Mr I.G.M. Hunter Metropolitan Centre (against all the evidence of the 1960's housing provides evidence as to how to 4.13 fiascos) that young, single persons will want to provide accommodation that is Resident live in tall buildings at non-affordable rents; both suitable and attractive to Observation and whey should families be banished to the families in Croydon Metropolitan Disagree – No Change periphery of the area particularly as they too Centre and it highlights that will be in need of access to quality play and much of this accommodation open spaces and community support centres will have to be provided in areas (see 4.14) towards the edge of the centre. It is not proposed to repeat the mistakes of 1960's high rise housing. Modern high rise housing is known to be attractive to particular demographics otherwise developers would not build such properties. In order to ensure that new homes are built to a high standard all new homes will be required to meet the minimum standards set out in the Draft London Housing Design Guide. Homes- Where are we The "East", particularly Selsdon, is pretty well Support is welcomed Mr Roger Hill now? built up, except for Green Belt and Woodland 4.5 areas. Naturally, we support the preservation Selsdon Residents of these facilities and are pleased that the Association Green Belt will not be reviewed in the near Support future Homes- Where are we We agree that in CMC smaller residential The comment is noted. Mr Keith Hearn (Minerva) now? units will predominate, as set out in paragraph 4.7 4.7 of the document. CBRE Observation Noted Jobs – Croydon If population growth of 12% is proposed a The Industrial, Warehousing Mr Brian Madge Metropolitan Centre sustainable community will require protection and Office Market Assessment 4.27 of employment land thereby further restricting prepared for the Core Strategy Brian Madge Ltd opportunities for housing in the urban area advises that the office market Objection and suggest a real need to retain options to within Croydon Metropolitan Disagree – No Change release some open land. This need is Centre currently has an reinforced by the apparent contradiction oversupply of low grade office between the employment and housing accommodation which is objectives for the CMC. Page 28 of the Core deflating rental values. The low Strategy Supplement notes "CMC is the rental values mean that largest economic centre in south London and Croydon Metropolitan Centre is has been designated a 'Strategic Office currently an unattractive Location' in the Draft Replacement London location for investment in new Plan. Its future growth and economic success office stock. Therefore releasing will be the main driver for the improvement some land currently occupied and regeneration of the other Places within by offices for residential this SMA (Spatial Management Area). development would help However paragraph 4.27 notes "if the number stimulate the office market of new dwellings sought in CMC is in the within Croydon Metropolitan region of 8000 (including development under Centre by reducing the stock construction) this is likely to have an impact and increasing rental values. on the number of new jobs, as it would require Later in the plan period the release / conversion of some of the intesification of remaining sites existing office stock. However, should current would allow Croydon trends continue… in the long term (up to Metropolitan Centre to 2031) demand is forecast to exceed the accommodate additional current supply with an additional office floor workers. space requirement to accommodate 2,000 more workers. Most of these jobs will be located within Croydon Metropolitan Centre".

We would suggest that there is; a) a conflict between employment and housing objectives and b) it is unrealistic to assume that once office accommodation is changed to housing that it may revert to employment. Jobs – Croydon We note the caution with which the Core Comment is noted Mr Jonathan Buckwell Metropolitan Centre Strategy Supplement discusses retail 4.30 floorspace requirements but agree that growth dha Planning of the scale anticipated within the CMC is Observation likely to create some surplus of retail Noted expenditure. The Croydon Metropolitan Centre Retail Strategy 2009 notes that parts of the existing retail centre are underused and that the area would benefit from quality aspirational retailers. Emerging policy should therefore continue to support and promote improvements to existing retail elements in the CMC to address these issues. The Retail Strategy recognises the prominent role which the Whitgift Centre plays in the retail offer of the town and therefore we also strongly advocate a strategy of basing any new retail floorspace within or close to the Whitgift and the existing core retail areas which surround it. Jobs – Croydon We agree that it is important to concentrate on Comment is noted Mr Charles King Metropolitan Centre regenerating the centre of Croydon both as an 4.31 improved retail experience and also as a East Coulsdon major place of Employment. We are Residents' Association concerned with the continued development of Observation the Purley Way as a retail centre in competion Noted with the town centre. We also support improving the centre's image as a place to come to for leisure activities. These leisure facilities need to be improved so that they appeal to the whole range of age young and old alike. In the past there has been too much emphasis on the young with too many nightclubs and late night drinking extablishments and not enough encouragement to other forms of culture that can be built on the good reputations of the Clocktower, Fairfield Halls and Warehouse Theatre. Jobs – Croydon 9. Economic strategy A major criticism of the The comment is noted. An neighbourhood Metropolitan Centre Strategy is that the economic development Economic Development Partnerships Chairs & aspects are vague. We note that the Strategy Refresh was prepared VCs 4.26 economic plans for Croydon (which are in the in light of the downturn. This neighbourhood public domain) predate the financial crash. We along with employment Partnerships Chairs & see the renewal of Croydon's local economy evidence studies has informed VCs as being a key element of the Strategy. We Core Strategy policy on Observation would ask for a comprehensive economic plan industrial areas, the creative Noted that addresses what is likely to be a sustained industries, enterpsie locations, period of austerity. This is one of the key retail and town centres. In information requirements listed in Appendix II. Croydon Metropolitan Centre We note that Croydon is currently making bids five masterplans and an for funding from three different development Opportunity Area Planning zones. We are pleased that Croydon is Framework (a good example of making progress in getting recognition of its capitalising on London Mayoral urgent need for renewal investment. The Draft support that the respondent Replacement London Plan classified calls for) are in preparation with Croydon's Metropolitan Centre as a Strategic one of the aims to improve Office Location and an Opportunity Area. It Croydon's economy. also highlighted it as a Strategic Outer London Development Centre, having potential for higher education, strategic office economic development and a night time economy cluster of regional/sub-regional significance. It appears that at the mayoral level, there is political support for the regeneration of Croydon. We should be pro-active in exploiting this support. We fully support the various development zone funding bids. Our concern is that the development zones are long on aspiration, but in this age of austerity, their ability to finance significant investment may be limited. We would ask for an honest assessment of the funding prospects for the development zones and an analysis of how much of this funding Croydon could realistically expect to receive. This is one of the key information requirements listed in Appendix II. Jobs – Croydon 13. Contribution of the 5 year plan to the 20 The comment is noted. Many of neighbourhood Metropolitan Centre year Strategy We feel that Croydon has lost the ideas put forward are Partnerships Chairs & competitive advantage as its office stock ages embedded in the Core Strategy VCs 4.26 and its retail offering has lost its edge against (such as the importance of neighbourhood newer shopping developments. Croydon badly promoting culture, capitalising Partnerships Chairs & needs a new long term strategy that will renew on our proximity to Gatwick, VCs the City Core's economic vigour. Over the strengthening university Observation next 5 years, we believe that through vigorous presence in the borough and Noted marketing, Croydon could attract smaller remodelling the Fairfield Halls) companies. Hopefully, if Croydon can and will also be taken forward in establish a reputation as a new business the Opportunity Area Planning incubator, the smaller company sector will Framework. grow so as to become a significant employer in the City Core. Hopefully, taking a 20 year view, some of these smaller enterprises will grow to become substantial employers and will remain in Croydon. Over the 20 year Strategy time horizon, it is evident that Croydon will need new future engines of growth. We believe that there is real long term potential for the Gatwick Diamond plan whereby Croydon leverages its excellent transport links to Gatwick airport. In the long term, if the necessary investment can be secured, we see two major streams of business: hotel/hospitality revenues from business/leisure travellers who initially arrive in Gatwick and base themselves in Croydon conference facilities. The short journey times from Croydon to both Gatwick and central London make it a great potential base for business travellers and tourists. To secure such visitors, the following actions are needed: Croydon needs to improve its image so as it becomes a desirable accommodation base for visitors. As noted above, a concerted effort in creating a cultural buzz for Croydon would be of enormous help in creating a positive image. The Fairfield Halls should be redeveloped so as to provide top quality dual purpose conference and cultural facilities. As the Strategy notes, the great potential of Fairfield is currently hugely under-utilised. We list the master plan and development strategy that we understand have recently been developed for the Fairfield as one of our key information requirements in Appendix II. The spatial and infrastructure planning process should give preference to the development of top quality hotels. We accept that re-inventing Croydon as a hotel/conference centre will take both time and substantial investment. In the short term, investment in culture is a prerequisite in making Croydon an attractive place to stay. In the vision, we especially support the long term goal that "Croydon's high quality and innovative cultural offer will snap hard on the West End's heels". In the medium term, the provision of excellent dual conference/cultural facilities at Fairfield is necessary. If both the image and conference facilities are right, then top quality hotels will follow. We believe the second pillar of Croydon's long term revival should be the establishment of a university. Given the huge population of its catchment area, it seems extraordinary that Croydon lacks a university. A university would not only fill an urgent unmet demand, but it would serve as a major employer and wealth generator for the borough. Also, if the university has a technology or business focus, it would have the positive business and employment spin-off benefits that have been evidenced elsewhere. Contribution of the 5 year plan to the 20 year Strategy - continued We believe that the third pillar of Croydon's long term revival is the gradual replacement of the very dated office stock by modern developments that are attractive to larger organisations. Unfortunately, the short term willingness of private property companies to undertake such developments is likely to be constrained by the general economic conditions. We believe however that Croydon should continue to aggressively promote its cost and transport benefits and through its investment in culture, be seen as a desirable place to work (and indeed live). Jobs – Croydon 46 In line with London Plan policy 3D.7 The support is welcomed. Mr Michael Mulhern Metropolitan Centre proposals to attract new hotel development to 4.34 the Croydon Town Centre Opportunity Area is Greater London Authority welcomed. Support Noted Jobs – Croydon We stress the need for flexibility in the CS so The comment is noted. The Mr Keith Hearn (Minerva) Metropolitan Centre as not to frustrate future development representation has been 4.30 opportunities, and to ensure that the overall forwarded to the project team CBRE policy approach is ‘Effective' in PPS12 terms. for the Mid Croydon Masterplan. Observation To ensure the CS is founded on a robust and Noted credible evidence base, and is therefore ‘justified', we ask that the Council responds to our previous concerns raised regarding the Retail Strategy Report for CMC (2009). Jobs – Croydon 3. Historical perspective The City Core was a The comment is noted. neighbourhood Metropolitan Centre relatively successful economy up until the end Partnerships Chairs & of the 1980s. It was highly diversified with VCs 4.26 strong public, private (especially financial neighbourhood services) and retail sectors. In particular, up Partnerships Chairs & until that time, the City Core still had a strong VCs private sector and was seen as an attractive Observation base for the back office functions of financial Noted services companies. However, the City Core has badly underperformed the economic and employment performance of the overall London economy since the late 1980s. This relative decline has been most notable in the private sector - particularly in financial services. It is also apparent that the City Core's retail offering has lost its competitive edge against newer retail developments. The most notable feature of the last 20 years has been the extra-ordinary lack of new development in the City Core - especially of modern first class office space. A shocking statistic is that just 6% of the City Core's office space can be classified as "modern" - i.e. constructed between 1990 and 2003. The comparative statistic for Reading is 57% and for Crawley is 60%. The City Core's record of attracting new non-retail inward investment over the last 20 years has been miserable. It is particularly noticeable that despite Croydon's aspiration to be London's "third city", the City Core has had virtually no success in attracting any large company HQs to relocate in it. Unfortunately, the employment decline in historically important large private sector employers has not been offset by new business and employment creation. The borough's rate of new business creation is low by London standards. Disturbingly, the survival rate for new businesses is particularly problematic. Historically, the City Core had a very competitive retail offering focused on the Whitgift Centre (developed in the 1970s), North End and Centrale (which opened in 2004). There has been some investment in the City Core's retail offering - most notably the refurbishment of the Whitgift and the opening of Centrale. However, it's clear that the City Core's retail offering has lost its competitive edge against newer developments. The most notable example is Westfield in Shepherd's Bush which features many upmarket retailers and a completely integrated dining and cinema offering. Westfield will open a new retail development in Stratford in 2012 which could be a real competitor for the City Core given the ease of transport provided by the newly completed East London line. Even more disturbingly, although Bromley's shopping centre is smaller than the City Core, it now offers a superior retail experience - most notably in "The Glades" shopping centre. Although Kingston's retail centre is not a direct competitor to the City Core, its development over the last 20 years has been far superior to the City Core's. Historical perspective - continued We believe that the decline in the City Core's retail competiveness has accelerated in recent years. Although the City Core still features all of the mainstream retailers, it lacks quality retailers at the upper end of the market - especially so in the fashion sector. Also, a notable feature of recent years has been the slow decay of a number of historically important elements of the City Core's retail offering. This is most apparent in the decline of Alders which for decades was the City Core's premier retailer. Also, the failed Park Place development has resulted in the blight of the St George's Walk area. It is clear that Croydon's relative economic and employment importance in the overall London economy has been in steady decline for over two decades. The private sector has suffered the most serious decline with the result that the City Core has become more dependent on the public and retail sectors. Overview Our comments principally focus on Section 4 The comment is noted. Mr Keith Hearn (Minerva) of the document, which updates the Core Representation has been sent CBRE Strategy (CS) preferred options for CMC, in to the Opportunty Area Planning Observation terms of the Council's proposed approach to: Framework team. Noted homes; jobs; culture; and transport in this area. Croydon is designated in the London Plan as an Opportunity Area, a Metropolitan Centre, and a Strategic Office Location. We consider that parts of the CMC have huge potential for growth and will be key to the delivery of the Core Strategy.

We note that the Greater London Authority (GLA) will prepare an Opportunity Area Planning Framework (OAPF) for CMC, and that this will be consistent with the London Plan and other Mayoral strategies. In our previous representations submitted in March 2010, in response to the document ‘Towards a Preferred Core Strategy for Croydon' we queried whether, at the local planning authority level, an Area Action Plan or other form of planning guidance was anticipated specifically for Mid Croydon. We now note that a masterplan is to be prepared for Mid- Croydon. This is welcomed by Minerva, who wishes to be involved in the masterplanning process. We seek clarity from the Council on the likely scope and status of the proposed masterplan document, and on the status of the ‘designation' of growth proposed in CMC. Specifically, we seek clarification on whether this is a ‘Strategic Allocation' in the Core Strategy, as defined in Planning Policy Statement 12, paragraph 4.6.

Early work on progressing the OAPF is critical if coordinated development linked to adequate infrastructure provision, by way of interchange and transport facilities, is to be delivered. Any clarification as to your understanding of the GLA's programme for progressing this would be appreciated. We understand that the Council is in the process of establishing a Major Developers' Forum and we hope that this forum will be instrumental in beginning to consider the scope of the proposed OAPF. The OAPF can then be prepared in a way which is consistent with the various emerging masterplans. We note that National Planning Guidance PPS4 ‘Planning for Sustainable Economic Growth' Policy EC3, ‘Planning for Centres', encourages local planning authorities to "set flexible policies for their centres which are able to respond to changing economic circumstances and encourage, where appropriate, high-density development accessible by public transport, walking and cycling".

We support the overall approach to the distribution of growth in the London Borough of Croydon, and agree that the focus for growth should be a substantially redeveloped CMC, designed to high densities and quality standards. Overview Royal Mail supports the identification that the Support is noted. Royal Mail Group plc 4.1 places in and around Croydon Metropolitan Royal Mail Group plc Centre (CMC) and Environs Spatial Support Management Area (SMA) including Noted Addiscombe, have the greatest potential for positive change. Overview "Purley Oaks" is a generic area of Croydon The Council considers Purley Mr I.G.M. Hunter 4.1 but is not referred to in either "CMC and Oaks to be similar to other parts Resident environ" or the South Spatial Management of the borough such as Monks Observation Areas (Second 7 - page 62 et al). When did a Orchard. It recognises that Noted consultative meeting involving residents of the some people associate area between South Croydon Bus Garage and themselves with these areas the Royal Oak Centre take place? This point rather than say Shirley. was made by me in my previous comments on However, for the purposes of the Core Strategy and yet is NOT reflected the Core Strategy the here; why? identification of all such areas across the borough is not considered neccesary. Overview We support the primary strategy for the CMC Support is welcomed. Mr Jonathan Buckwell 4.2 as the focus for significant growth and renewal dha Planning and the vision from ˜We are Croydon' in Support respect of jobs, with the aim of establishing Noted Croydon as the principal location of retail and leisure offer in outer south London. Overview Appendix I- Proposed 5 year plan. We believe The comment is noted. Non neighbourhood the key elements of Croydon's short term 5 LDF or Core Strategy Partnerships Chairs & year plan for 2011 to 2016 should be: -Secure representations shall be passed VCs 2.1 city status at the earliest opportunity. We the the relevant Council officer, neighbourhood passionately believe that securing city status including the project teams of Partnerships Chairs & would have enormous long term benefits for the Opportunity Area Planning VCs Croydon. A common image for those who are Framework and the five Observation not familiar with the City Core is that it is Croydon Metropolitan Centre Noted representative of the worst of soulless 1960s Masterplans. architecture. Also, the entire borough has a "dull" image. Securing city status would be an enormously important step in changing external perceptions - which would allow us to build on Croydon's many strategic assets. We firmly believe that Croydon should "pull out all the stops" in securing city status. Such an effort needs to be cross party and to fully involve residents. Maybe a public petition signed by a huge number of Croydon residents would underpin the lobbying efforts of our political leaders? Certainly, the CVCG will do everything in its power to support this effort. Prioritise a first rate redevelopment of the East Croydon and West Croydon rail stations. East Croydon station operates as the main gateway to Croydon. However, as the Strategy notes, it suffers poor design, chronic overcrowding and is inadequately linked to the retail district. As noted above, image is a key problem that Croydon needs to address. Certainly, the poor design and overcrowding of East Croydon station makes a very poor impression on all who use it. We appreciate that investment is constrained due to the current economic circumstances but of all the mooted infrastructure projects, this is the one that our council should prioritise. The recently opened East London line is a major strategic asset for Croydon. However, as the Strategy notes, the very shabby and undeveloped West Croydon station is a major let-down. Once again, if Croydon is to address its image problems, prioritising investment in a first class redevelopment of this newly important gateway station would pay huge long term dividends. - Continue to invest in marketing Croydon's business advantages. Over the next 5 years, we believe that the business environment will be very challenging. As the Strategy notes, much of Croydon's office stock dates back to the 1960s and is unattractive to big companies - as illustrated by Nestle's comments. Unfortunately, Croydon failed to capitalise on the development boom of 2002 to 2008 and therefore lacks a substantial stock of top quality modern office space. - Given the difficult business environment, Croydon has to make the best of its "current hand" over the 5 year planning period. Although much of Croydon's office space is very dated, this space is consequently very cheap compared to central London and Canary Wharf. Also, Croydon's superb transport links give fast access to central London, Canary Wharf and to Gatwick Airport. In our opinion, Croydon's dated office stock has limited appeal for big companies but its low cost coupled with the excellent transport links would be of great interest to smaller and/or newer companies. However, as noted above, Croydon suffers an image problem and many potential business tenants are ignorant of Croydon's cost and transport advantages. Given this background, we believe it is crucial that Croydon continues to market its business advantages. We note the recent demise of the Croydon Economic Development Company. We appreciate the huge financial pressures on our council, but we believe that maintaining investment in promoting Croydon's business advantages is crucial - particularly in such a challenging business environment. -Encourage specialist retailers and new markets in the City Core. One of Croydon's key strengths is the extensive shopping facilities in the City Core. However, with the notable exception of the Surrey Street market, most retailers are part of large countrywide chains. We believe the attractiveness of Croydon's retail offering could be further enhanced by attracting "quirky" independent retailers, upmarket retailers and establishing new markets in addition to Surrey Street. - The late lamented "Beanos" is a prime example of the sort of unusual independent store that can give a retail centre true distinctiveness. Also, as Camden Lock, Portobello Road and Brick Lane evidence, vibrant street and indoor markets can be an enormous draw. Surely, there is a huge opportunity as there is currently no equivalent street or indoor market within many miles of the City Core. Also, given the number of vacant office buildings in the City Core and the availability of St Georges Walk, it may be possible to establish interesting and quirky markets by making space available on competitive terms. Counter the "cultural desert" image of Croydon by maximising the potential of the Fairfield Halls, the Clocktower complex and other cultural/entertainment venues. We agree completely with the Strategy's description of Fairfield Halls as being a "lazy asset". Given sufficient investment, Fairfield has the potential to be a wonderful facility. However, given current investment levels, we believe that it operates at only a fraction of its potential. In particular, we believe that many of the acts that are currently being booked have only limited appeal. The decor has become very tired - although the recent investment in the foyer area is welcome and long overdue. If the City Core is to become a true leisure destination, then we believe that Fairfield has a crucial role by booking acts that have widespread appeal. If the dining opportunities in the immediate area and those on South End are properly promoted in tandem with securing an exciting roster of acts, then Croydon is well placed to become a real event destination. In the short term, the local economy benefits as many concert goers will eat and drink at the local pubs and restaurants. In the medium term, Croydon's image will begin to improve as more people are attracted to the City Core and will see at first hand its many advantages - which will boost shopper numbers. We appreciate that in the short term, it will require additional subsidy to bring top name acts to the Fairfield. However, we feel that such a subsidy would be recouped many times over through the spin-off benefits to the local economy from shopping/dining and the intangible benefit of enhancing Croydon's image so as to make it an exciting and talked about destination. Also, as Fairfield's reputation develops for booking top class acts, the level of subsidy will reduce as audience numbers increase. Establish a facility to see "art house" films on the large screen As the Barbican, Ritzy and Screen on the Green cinemas evidence, there is a large market for quirky non-Hollywood type films. The Clocktower does screen an interesting selection of such films but its attraction for potential filmgoers is limited due to its small screen and size. If the City Core is to establish itself as a prime leisure destination, a much larger cinema showing such films would be a great advantage. In the absence of a suitable purpose built venue, maybe it would be possible to come to an arrangement to obtain screen time in a suitable venue? In particular, maybe a modest level of subsidy to Vue Grants would entice it to include such films on its programme. - Integrate the Croydon Summer Festival into the City Core The Croydon Festival is one of the highlights of the borough's leisure calendar. In our opinion, this is an excellent event that is a showcase for Croydon. Traditionally, it has been held in Lloyd Park. Although Lloyd Park offers space, we feel that this venue misses a huge opportunity to promote the benefits of the City Core. We would suggest that future Croydon Festivals are staged in the City Core. This central location with easy accessibility to transport links will maximise the audience - from both within and outside the borough. It will also provide an economic boost as the audience eats at local restaurants, drinks at the local pubs and perhaps combines the event with some shopping. City Core festivals celebrating the borough's ethnic diversity A notable success in central London has been the many festivals staged in Trafalgar Square celebrating London's ethnic diversity. The celebration of the Chinese New Year, St Patrick's Day and Diwali are now well established celebrations that attract huge crowds. Given Croydon's ethnic diversity, it would be well worth attempting to see if it could emulate Trafalgar Square's success by organising similar festivals for the borough's largest ethnic groups. Not only would such festivals underpin the long term vision of Croydon as a creative city, but well organised events could attract substantial number of visitors that would be a boost to the City Core's leisure and retail sectors. Promote the City Core as a dining location and encourage new restaurants to open A distinctive feature of the City Core is the emergence of South End as a diverse and interesting dining location. Recently, a number of more up- market restaurants have begun to emerge in South End which further enhances its appeal. We believe that South End can reinforce the shopping and potential cultural/leisure attractions of the City Core - subject to sufficient publicity. We believe that the Croydon Food Festival has great potential to publicise the many great restaurants throughout the borough. This year's Food Festival had a very interesting series of public cookery demonstrations but it was disappointing that so few of Croydon's restaurants took the opportunity to capitalise on the Festival's publicity by offering meal promotions. We believe that publicity for future Croydon Food Festivals should be stepped up greatly for potential diners outside the borough. The attractiveness of the Festival could be further enhanced by organising a number of food street markets as an integral part of the Festival. The great benefit of promoting Croydon as a gourmet's delight is that a proportion of diners will also be shoppers, cinema and concert goers - which boosts the overall City Core economy. In the case of South End in particular, we believe that with effective publicity, it could become a "destination" much like the curry houses on Brick Lane. Reduced parking charges after 6.00 p.m. We fully support the long term objective of attracting people to shop, dine and concert-go in the City Core by public transport. However, taking a 5 year view, we believe that it would accelerate the City Core's attractiveness as a leisure/dining destination by reducing parking charges - particularly after 6.00 p.m. Perform a feasibility study on what sort and size of university would best serve Croydon The feasibility study would assess key parameters including specialisation if relevant, student numbers, projected demand as evidenced by application numbers, provision of postgraduate degrees, targeted proportion of overseas students, build costs, running costs, expected fee levels, employment benefits, an assessment of any spin-off economic benefits. Overview 4. The historic lessons- One of the reasons The comment is noted. neighbourhood that so many ordinary Croydon residents are Partnerships Chairs & so cynical about the Strategy is the credibility VCs 2.1 gap arising from how little progress was neighbourhood achieved in renewing Croydon during the Partnerships Chairs & good years in the run-up to 2008. It would be VCs really helpful if there was a short and honest Observation analysis of why so little progress on renewal Noted was made in the 10 years to 2008. We understand that this is now history, but if we analyse what went wrong during this period of opportunity in an honest way, then we can apply the necessary lessons to the 20 year Strategy period. Our perception is that two of the major historic factors hindering Croydon's renewal were: the borough's poor external image an emphasis on seeking "optimal" developments as opposed to backing good developments by creditable property companies that could proceed in the short term. We are disappointed that Croydon has made so little progress in improving its external image. We do believe that the negative external perceptions of Croydon are unfair in many ways. However, this external prejudice towards Croydon is a real factor in discouraging much needed inward investment. We note with regret the recent demise of the Croydon Economic Development Company. We appreciate the huge financial pressures on our council, but we believe the promotion of Croydon's business advantages is crucial - particularly in such a challenging business environment. We set out a number of concrete steps in Appendix I on how Croydon's image can be improved over the next 5 years. We would highlight the importance of securing "third city" status - which we believe would be a powerful first step in changing external perceptions. Also, we believe that Croydon currently has an ill defined and poorly communicated inward investment offer. We believe that a realistic image for Croydon as "a place that gets business done" would play to its strengths. Our perception is that Croydon was historically over-ambitious in seeking the very best developments possible at the expense of expediting good developments that could proceed rapidly - the prime example being the Gateway site. Also, Croydon placed too much reliance on weak developers who ran into financial trouble when the recession hit - the prime example being Minerva and the Park Place development. Given the City Core's relative decline, we believe Croydon needs to be realistic about the quality and ambition of potential developments that it can attract. We are concerned that the lessons of the past have not been fully absorbed. A good example is the proposed Schroders/Stanhope redevelopment near East Croydon station - Ruskin Square. We understand that Schroders/Stanhope want to alter the approved development to reflect current economic circumstances and a time lag of 3 years is being mooted. Surely, a key historic lesson is that Croydon needs to be strict with developers so as we don't get "strung along" for years? Transport- Addiscombe Page 33: 4.72 The reason for the traffic The Replacement Unitary Mr I.G.M. Hunter 4.72 congestion is because of the number of large Development Plan (July 2006) Resident Victorian properties converted with Council includes a policy (H7 Observation planning approval, making a rod for their own Conversions) which prevents Noted – To be Reviewed back in so far as density and car-parking inappropriate sub-division of problems are concerned. Unless the Council properties. The success of this change their policy of approving house policy is also monitored in the conversions without insisting on appropriate Annual Monitoring Report. parking for cars "off street" the problems of Whilst the issue of associated blocked streets will continue. off street parking is too specific in detail and nature for a Core Strategy, policy H7 can be reviewed as part of future work on a Development Management DPD. Transport- Where are we Section 4: Transport - Where we are now? The comment is noted. The Mr Michael Mulhern now? council will continue to work 4.69 Under paragraph 4.69, bullet point two, TfL closely with TfL on proposed Greater London Authority wishes to seek clarification as to what transport improvements. Observation highway improvements are envisaged in Noted reference to those outlined for the West and North areas of CMC?

In reference to bullet point 5, TfL welcomes new interchanges for buses as well as improvements at East and West Croydon Stations for bus, tram and train.

In reference to bullet point 7, it is envisaged that pedestrian wayfinding improvements such as Legible London should also be introduced within the CMC area.

In reference to bullet point 8, TfL wishes the Borough to note that Croydon has an extensive night bus network providing a wide range of links. The network is reviewed on a rolling basis and any opportunities to enhance the night bus network will be progressed where worthwhile and where funding permits. Transport- Where are we This issue will be addressed in Mr Michael Mulhern now? Section 4: Transport - Where we are now? the future Development 4.68 Management DPD. Greater London Authority Under paragraph 4.68, the Council should Observation promote car free developments or allow very Noted limited levels of additional car parking necessary to accommodate the level of development envisaged in the CMC.

In planning for the CMC area, travel plans also play an important role for existing schools and businesses. Reducing the number of Single Occupancy Vehicle (SOV) trips from existing buildings would help mitigate the impact of new development in the area. TfL notes that the supplement has taken into consideration current issues and how they need addressing in terms of hard infrastructure. Further detail should be developed in the Borough Development Management Document on how to mitigate impact through the use of travel plans for current and future development. Transport- Where are we Transport The support is welcomed. Mr Keith Hearn (Minerva) now? 4.68 We strongly agree with the recognition in CBRE paragraph 4.68 of the consultation document Support that for CMC to develop successful high Noted quality retail, office and housing spaces it must be readily accessible, and that improved public transport networks and walking/ cycling routes are essential pre-requisites for the delivery of the CS. In particular, we consider works to Wellesley Road to improve pedestrian and public transport movements to assist linkages between East Croydon and Mid-Croydon will be particularly important, and support their inclusion in the CMC and Environs Transport Strategy. Transport- Where are we Section 4: Transport - Where we are now? The comment is noted. The pre- Mr Michael Mulhern now? submission version of the Core 4.69 Section 4.69 lists schemes to support the Strategy shall address issues Greater London Authority development of the CMC. It specifically lists such as capacity on the tram Objection Tramlink extensions to locations such as network.The council will Noted – To be Reviewed Bromley and Sutton which already have continue to work closely with existing rail connections. However TfL notes TfL on proposed transport there is no mention of the need to expand the improvements and policy to be capacity of the existing Tramlink network included in the Core Strategy.. which directly serves the CMC. The network currently experiences very high level of crowding and has no spare capacity to support any growth in the CMC. Given the Strategy is to accommodate growth in homes and jobs, TfL feels the most immediate need in regards to Tramlink is to increase capacity on the existing lines serving the Croydon loop.

TfL therefore suggests the following wording is added to this section:

"The need to firstly enhance capacity of the existing Tramlink branches serving the CMC, secondly extend Tramlink northwards toward Thornton Heath, Streatham and Brixton to serve the Broad Green growth area, and thirdly to strengthen existing South London orbital movement by extending Tramlink towards Sutton, Tooting and Bromley." Transport- Where are we Transport. The document refers to passenger The support is welcomed. CGLP now? capacity issues at East Croydon Station and 4.69 CGLP support and would encourage CGLP improvements to East Croydon Station. The Support station is the main arrival point for passengers Noted into Croydon and needs to reflect this important transport node into the Metropolitan Centre. Currently, the appearance of the station does not live up to its status as a significant transport interchange and does not give the passenger a sense of arrival within the Metropolitan Centre of Croydon. Transport- Where are we The document refers to improved pedestrian The support is welcomed. CGLP now? links between East and West Croydon 4.69 Stations. CGLP support improvements to CGLP public transport, particularly to East Croydon Support Station and any additional linkages over the Noted railway tracks to increase permeability east to west within the CMC. Transport- Where are we Bull point 6 - What is an "enhanced" bus? This is a mistake, the word Mr I.G.M. Hunter now? 'service' is missing and will be 4.69 amended in the pre-submission Resident consultation report. Observation Noted – To be Reviewed Transport- Where are we Page 32: 68 Which comes first (a) Reliable The Core Strategy shall seek to Mr I.G.M. Hunter now? Public Transport (ie; buses which are promote planning policies and 4.68 designed for shoppers and visitors and not development which reduces Resident commuters), or the demise of the car across reliance on car borne travel. Observation the CMC, with the possibility of no"out-of- The design of public transport Noted town" shoppers who would be discouraged for the use of shoppers is not an from visiting Croydon because of the difficulty issue that can be dealt with in carrying their purchases home on public through planning policy. transport. Transport- Where are we Page 33: 4.69 Bull point 3 - is this now being The Wellesley Road Masterplan Mr I.G.M. Hunter now? done by OKRA without public input, contrary is still being developed and shall 4.69 to PP1 rules? be subject to a formal Resident consultation period. Observation Noted Transport- Where are we CGLP agrees that the Council should seek to The support is welcomed. CGLP now? identify the need for public car parking in the 4.69 Metropolitan Centre. The provision of any CGLP additional major car parking facilities for public Support use should be avoided and sustainable forms Noted of transport promoted. 5.0 North Spatial Management Area Section Representation Recommended Response Full Name Paragraph Organisation Nature of Response Officer Recommendation Culture- Crystal Palace and Other points of note: there is a surplus The potential of each of the 16 Andrew Parfitt Upper Norwood capacity of 300 people in Gipsy Hill ward but a Places to accommodate new deficit of 500 people in College ward; Crystal homes will be reviewed and Crystal Palace Triangle Palace ward has a deficit of fewer than 50 where necessary the type and Planning Group people; overall, there is a deficit of about 350 question will be revised. (CPTPG) people in the five ˜Crystal Palace' wards. The Observation CPTPG therefore: ask Croydon to re-examine With regard to greater cross Noted – To be Reviewed its housing need assessment in light of these borough working, the Council revised population projections by the GLA; will continue to engage note that given Croydon's plans for 50% of colleagues in adjoining housing in Upper Norwood to be family boroughs with the Core housing, additional social infrastructure such Strategy process. More detailed as school places was needed to cater for it; matters such as the possibility express our concerns about over- of a joint Area Action Plan, will intensification of the area. In particular, be considered at a later stage. Croydon needed to take into account the housing proposed in neighbouring wards of We can confirm that the other boroughs.  In respect to College ward character of homes within town (Southwark), whilst we recognise the centres was considered as part constraints on additional housing supply in of the Borough Character South Dulwich, there is scope for new Appraisal. developments to go towards East Dulwich rather than towards Gipsy Hill.  Other points The Council shares your we wish to raise:  p.12, para. 3.9: CPTPG recognition of the value of the welcome Croydon's opposition to building new area's independent traders and homes on back gardens.  p.38, para. 5.3: 'cultural essence' and considers greater cross-borough collaboration is this is reflected in the Core welcome, but we would appreciate further Strategy. details of how this is to be achieved, for instance in development control or through an In the short-term, the area action plan.  p.39, para.5.8: town Development Plan Documents centres appear to be excluded from the (DPDs) referred to are the Site assessment of existing residential character. Allocations DPD and the Housing in places such as the centre of the Development Management Triangle, and flats over shops need to also be DPD. considered. 3. Jobs Beginning with a general comment, we value our independent traders. Regular town centre health Most of the chains have not survived in the checks will enable the Council area, whereas people with a local interest to determine the have. The independent traders are often crafts appropriateness of boundaries people, who carry out out activities such as and retail frontage designations. metalwork, glasswork, dressmaking, bookbinding, jewellery making. This adds to The proposal to permit place of the cultural essence of the conservation area. worship activity (and other D1  We would also make a number of specific Uses) on higher PTAL sites is points:  p.42, para. 5.20: please could the not directly relevant to 25 meaning of "subsequent Development Plan Church Rd as it relates to Documents" be clarified? Whilst we welcome alternative uses for existing the principle of not allowing conversion of B1c, B2 and B8 premises not existing workshops in and around the D2 Uses. Triangle, we would note that development control colleagues have not applied this policy Support for extending protection to Victory Place, Westow Street. Any future of industrial premises to those decisions for this key site need to be mindful within town centres is welcomed of the Core Strategy.  p.42, para. 5.21: we and we agree that smaller welcome the proposal to prepare a cross- scale/affordable premises are borough retail policy stance for Crystal Palace appropriate for this area. and the public realm improvements for Church Road. When Croydon carry out the retail With regard to para 5.31, a 'cap' strategic frontage exercise, we would on D1 Uses is provided to a emphasise the need to ensure that the large extent by the proposal to Lambeth and Bromley sides of the triangle are protect the commercial included.  p.42, para. 5.22: we agree that premises fronting Church Rd for any growth of the district centre should come A1 - A4 and B1c Uses. from within, using existing retail premises, not by expansion of boundaries. This should also The recommendation to include take account of the gateways to the Triangle, a reference that it is not for instance on Central Hill, Gipsy Hill and appropriate for hotels to be built Crystal Palace Parade.  p.42, para. 5.23: we on park land is not a matter for would stress that more hotel provision in Croydon's Core Strategy. Whilst Crystal Palace must not be on park land.  we will continue to work closely p.43, para. 5.30: we are very concerned about with our colleagues in Bromley, the policy to allow new places of worship in it will be for them to determine areas of high PTAL rating. In view of this matter. Croydon's vigorous opposition of the change of use of 25 Church Road, we would suggest The Core Strategy supports the that this reference is unhelpful and should be occupation of vacant premises omitted. Otherwise it could be used to the for creative and cultural activity. detriment of cultural regeneration in the town centre.  p.43, para. 5.31: we welcome the We welcome your support for plans to extend protection of business sites in the establishment of a district centres.  p.43, para.5.32: we creative/cultural industries welcome the support for start-up premises for Enterprise Centre in the studios and workshops and would suggest Triangle area. More detail on that the premises provided should be kept possible size/location will small and affordable.  p.43, para. 5.33: we emerge as work progresses on would propose that this should include a a cap the Site Allocations DPD. on D1 premises in Crystal Palace district centre, given that it already contains 17 In terms of the library, whilst the churches. Otherwise the viability of shops and Core Strategy will contain a cafés will be increasingly jeopardised by general policy protecting parking and traffic problems.  p.43, para. premises/sites for community 5.34: we would strongly recommend that this facilities it cannot prescribe the should make clear that it is not appropriate for end user. hotels to be built on park land. 4. Culture There is scope for art in empty shops, on the The Council shares your lines already achieved in Church Road and ambition to improve pedestrian Anerley Hill.  More generally, it would be movement within and around helpful to have a reference to D2 buildings as the Triangle and this will a priority for the town centre, particularly the continue to be reflected in the clear demand for a cinema in the Crystal Core Strategy. Thank you for Palace Triangle. In addition, we would like to your support for the proposal to see a reference to protecting existing D2 extend the Tramlink network to uses, such as the Phoenix Centre and the Crystal Palace. dance floor at the Foresters Hall, and enhancing their potential.  The cinema would be a major attractor: the whole town centre could be potentially a cultural centre. Besides the craft trades, the vintage and antique culture forms a growing cluster.  The library should also be protected: it is an essential element of cultural richness - and we would be keen to see even more use of the space for exhibitions and talks by visiting authors.  Other points:  p.44, para. 5.42: we welcome the reference to an Enterprise Centre, geared towards the creative industries sector. This is an intriguing proposal about which we would like to learn further details about size and location.  p.45, para. 5.47: we agree with the proposal to support the temporary occupation of empty buildings and cleared sites by creative industries and cultural organisations.  5. Transport Although we accept that the One Way System has probably generally improved traffic flows, it has made pedestrian movements more difficult. There are only two pelican crossings in the Triangle and there is no green phase for pedestrians at any of the Triangle's corners.  We would like to see a pelican crossing in Church Road and a green phase for pedestrians at the corners of the Triangle, or perhaps "stop traffic" systems, such as used at Oxford Circus, to permit diagonal as well as lateral crossings. We would also suggest considering the scope for a box junction at the top of Gipsy Hill and greater enforcement of banned turns.  Other points we wish to raise:  p.36, para 4.84: we welcome the Tramlink extensions to Crystal Palace in principle, and are pleased to see Croydon's commitment to support and promote them over the next 10 to 20 years (if not earlier).  p.46, para.5.51: there is a clear need for cross- borough collaboration on railway stations. The nearest stations to the Triangle are Gipsy Hill in Lambeth and Crystal Palace in Bromley.  p.46, para. 5.51: we welcome the proposal to improve the pedestrian crossings at the All Saints junction of Church Road with Beulah Hill and South Norwood Hill. This would lead to more consideration for residents, shoppers and churchgoers. Culture- Where are we Welcome focus on creative industries in Support is noted. Andrew Parfitt now? Crystal Palace. 5.38 Crystal Palace Triangle Planning Group (CPTPG) Support Noted Homes – South Norwood Transport: The capacity at Norwood Junction The comment is noted. Whilst Mr Paul Scott and Woodside is currently inadequate and needs to be network capacity (service 5.13 enhanced by a more regular high speed frequency) at Norwood Junction People for Portland Road service into central London. This service has is amongst the highest in the Observation been severely curtailed by the introduction of borough, the Borough Wide Noted the Overland service as a result of poor Transport Strategy does timetabling - the four fast commuter trains in highlight high track utilisation the morning peak arrive in two pairs a few and significant standing at peak minutes apart with a half hour gap. The times for servies on the access tunnel is in poor condition and does Norwood Junction line. Whilst not provide for disabled access, and the this is not something the Core platforms need lengthening. Strategy can address directly there will be policies that seek to improve accessibility and design which is relevant to the second part of the representation. This representation will be sent to the Strategic Transport Team for consideration. Homes – South Norwood 2. The character of the South Norwood and The numbers of housing for Mr Paul Scott and Woodside Woodside area has either not been correctly individual Places are not targets 5.14 assessed or is undervalued by the Council - but projected figures based on People for Portland Road The town centre area, which predominantly past and projected development Objection comprises the High Street, Station Road and trends. They are there to inform Noted – To be Reviewed much of Portland Road, is largely within an the consultation by giving an existing conservation area or proposed and indication as to the possible existing areas of local area of special level of development in each character. These designations recognise the Place and to assist largely intact Victorian heritage of the area understanding of the resultant and hence should preclude extensive requirements for infrastructure. redevelopment of this part of the local area. The only housing targets Whilst it is accepted that some buildings do proposed in Core Strategy are need replacement, the generally small scale for the overall number of homes buildings of modest height and on small plots in the borough as a whole and will also limit the development potential. The for the mix of homes in different proposed housing targets will however create areas of the borough. The considerable pressure on the town centre Borough Character Appraisal area to accept inappropriate development that (now incorporating the will rapidly erode the existing character. Residential Character Outside of the immediate town centre roads, it Appraisals) recognise the is the combination and variety of the mix of Victorian heritage, identify the high density Victorian and Edwardian terraces main building form and and larger houses on relatively large plots streetscene characteristics and interspersed with a series of open parks and open spaces and their origin. greens that creates the pleasant character of Any development within the area. The lower density and open areas Conservation Area would need relieve the ‘enclosure' of the higher density to comply with the South terraced streets giving an overall relative Norwood Conservation Area sense of space and openness. Given that Management and Appraisal most of the former industrial / business sites Plan. Outside of the have already been redeveloped over recent Conservation Area the impact years, to meet the housing targets proposed on existing character and local by the consultation much of the lower density distinctinveness of any housing in the area will need to be proposed new development redeveloped at considerably high densities. would be assessed as part of This will inevitably lead to the loss of variety the planning approval process. and reduction in vegetation and general The development will need to openness, seriously impacting upon the be appropriate to the area. character of the area. The council recognises the importance of open space and vegetation for the borough and a green infrastructure strategy is being developed and will be incorporated in the next version of the Core Strategy. Open land in South Norwood and Woodside is currently protected and the Core Strategy is not proposing to remove that protection. Homes – South Norwood 3. The housing targets for the South Norwood Open land in South Norwood Mr Paul Scott and Woodside and Woodside area will put at risk some of the and Woodside is currently 5.14 local currently protected open land - As has protected by existing People for Portland Road been seen recently in Bromley failure to Metropolitan Open Land and Objection achieve housing development targets can Local Open Land designations Disagree – No Change result in the loss of protected open land. Sites and the Core Strategy is not such as Love Lane Green, which forms part of proposing to remove that an important open area that includes the protection. The numbers of South Norwood Country Park and Beckenham housing for individual Places Cemetery, are already under pressure from are not targets but projected developers. The lack of identified large sites figures based on past and and the limited capacity to build new housing projected development trends. elsewhere without significant detrimental The only housing targets impact will strengthen the case for releasing proposed in Core Strategy are Metropolitan Open Land for housing. for the overall number of homes Significant increases in density on current in the borough as a whole and housing land will also reduce garden sizes for the mix of homes in different and is likely to push new buildings areas of the borough. Any considerably closer to parks and other open proposed development will need spaces creating a greater sense of enclosure to go through the planning to those open spaces that do remain. Overall process for approval and will the sense of openness and the extent of therefore be individually greenery will be significantly eroded. assessed for its impact on the character of the area including impact on adjacent open space. Homes – South Norwood 4. The proposed scale of new development in The importance of local Mr Paul Scott and Woodside the area will have significant and detrimental distinctiveness and character is 5.14 impact on the character of the area - The recognised and the impact of People for Portland Road provision of 1300 new homes, two thirds of any proposed new development Objection which would be family sized units, would would be assessed as part of Disagree – No Change require considerable redevelopment of South the planning approval process. Norwood and Woodside that would inevitably The development will need to necessitate the loss of the few remaining be appropriate to the area. The employment sites in the area along with public council recognises the amenities such as pubs, venues for importance of open space and community groups and potentially the loss of vegetation for the borough and open space whether it be publicly accessible a green infrastructure strategy or not. A large proportion of the existing larger is being developed and will be scale housing would need to be replaced with incorporated in the next version much higher density development that would of the Core Strategy. Open land destroy an essential aspect of the area that in South Norwood and contributes greatly towards its character. The Woodside is currently protected mix of densities that currently exists would be and the Core Strategy is not lost, creating a purely urban area instead of a proposing to remove that successful mix of high density terraced protection. The number of new housing with interspersed sub-urban areas. homes in South Norwood is not The lack of available brown field sites will a target but rather an indicative force new development to be taller than the figure of the possible number of surrounding clearly established pattern 2 new homes based on past storey development stepping up to three or trends and the availability of four storeys occasionally and in the town large sites identified by the centre. Gardens and the space between and Strategic Housing Land around buildings will be lost destroying the Availability Assessment. relatively verdant feel of the area. The consultation document does not state how many homes there are currently within the roughly defined South Norwood and Woodside area, but a reasonable estimate would be circa 7500. Increasing this by almost 20% will have a huge impact that will transform the area and in our view will destroy its character and concrete over much of what is highly valued by the local community. Homes – South Norwood 5. The consultation document gives no The type of study referred to Mr Paul Scott and Woodside indication of what the impact of this quantum would simply be beyond the 5.14 of new housing would be on the townscape in resources available to the People for Portland Road terms of form, massing or density of the South Council. The approach taken is Objection Norwood and Woodside area, making it in accordance with Disagree – No Change extremely difficult for residents to gauge what Governnment guidance on Core the impact of the proposals would be on their Strategy production and best neighbourhood - Given that the consultation practice guidance from CABE. document proposes significantly altering the Nevertheless, in the next area through massively increasing the number iteration of the Core Strategy, of homes it accommodates, it is extremely the Council will endeavour to vague and totally fails to identify what the make clearer the likely impact of likely impact will be on the townscape, the growth within each of the 16 environment or on the amenities for local Places. residents. We appreciate that the council is unable to identify what developments will actually come forward, but before committing the area to accommodating a huge increase in housing there should be a clear idea of what the result is likely to be. This should be in terms of options for the number of existing properties that would need to be redeveloped, the height, density and form of buildings that are likely to replace them and the extent of provision of amenities such as gardens and car parking that are likely to accompany them. Such a study must be carried out. If the council has not done so then it has failed to properly assess what it is proposing. At present it is impossible for the public to understand what the real implications of the housing targets are for their neighbourhood and their homes. This seriously calls into question the validity of the consultation itself. Before agreeing what that the housing targets for the area are appropriate studies should be carried out and consulted upon. These should identify the possible implications in easy to understand formats. We suggest this clearly indicates the extent of demolition, the height of buildings allowable and areas that are most likely to be affected. For example, would tower blocks that concentrate the new homes in a small area be envisaged or wide spread clearance of larger houses to make way for estates of high density apartments? Homes- Crystal Palace and The Council needs to be more vigilant and Comment is noted. Not an LDF Andrew Parfitt Upper Norwood active in enforcing the Triangle Conservation matter. 5.9 Area, eg. Victory Place car lot and pavement Crystal Palace Triangle obstruction. Planning Group (CPTPG) Observation Noted North – Cultural Planning Culture: We continue to support the principle Support is welcomed and noted. Mr Paul Scott Strategy of establishing the Enterprise Centre on 5.50 Portland Road, but continue to be People for Portland Road disappointed by the lack of progress in Support delivering it. With the economic downturn it is Noted needed now more than ever and yet no firm plans to deliver it yet in place. We also continue to support our proposal for the Enterprise Centre to be used as a hub for a ‘new business village' that would support new and growing businesses accommodated within currently unoccupied or underutilised shop units along Portland Road and the High Street. This would directly support the regeneration of the area. North – Homes Strategy I would also urge the team to spread the The number of homes proposed Amanda Sciberras Figure 5.2 required 800 new homes figure further and in the each place has been Resident wider across the brough and not impose it on based upon the availability of Observation this already highly populated area. Would you large sites for development Noted be so kind as to send me the link to the (sites over 0.25ha), homes Croydon new home target sites in SE19 so I under construction (as at March can look into this further with my planning 2009) and past development group. trends of smaller sites (sites smaller than 0.25ha). In Upper Norwood and elsewhere the 800 homes is not a target but rather an indication of the likely number of homes that could be accommodated in each place. The only target for the number of homes is the borough wide target set out in paragraph 3.33 of the consultation document and the targets for proportions of homes of different types in paragraphs 3.34, 3.35, 3.36 and 3.38 of the consultation document. The details of specific sites will be sent as requested. North – Homes Strategy 7. Poor quality amenities for newly The Core Strategy does not set Mr Paul Scott Figure 5.2 constructed housing - Recent developments out the standards expected of People for Portland Road and planning applications in the area have residential development as it is Objection included minimal car parking provision and not a strategic matter and will Noted – To be Reviewed extremely limited external amenity space for be set out in a Development new residents. This will impact on existing Management DPD instead. residents, especially given the limited parking However the Core Strategy and open space available at present. A does set out in paragraph 3.33 significant increase in housing will exacerbate that new homes will be the situation considerably. The lack of parking expected to meet a set of provision for new developments has been minimum standards and that justified by the council on the grounds of these standards will be set out proximity to good transport links and yet later in the aforementioned Norwood Junction and the trams are at Development Management capacity already in the busy periods. DPD. The provision of car parking and outdoor amenity space are two elements of residential standards that will be considered. North – Homes Strategy Homes: Whilst we recognise the need for The assessment of how the Mr Paul Scott Figure 5.2 additional housing in Croydon we are potential number of new homes People for Portland Road extremely concerned about the proposed in each place was determined is Objection allocation of 1300 new housing units in the correct as is the fact that South Noted – To be Reviewed South Norwood and Woodside area. We note Norwood and Woodside has that this growth in our area is despite the only two sites and a higher predicted overall slight decrease in the future homes figure than surrouding population of the North Spatial Management places because of the higher Area. levels of small sites developed in the last decade. These 1. The housing capacity assessment for the figures however are not area is fundamentally flawed and is currently targets as the only generating an inflated estimate of the quantity target for new homes is at a of new housing the area can accommodate. - borough level. The assessment is largely based upon the Land designated as open land availability of larger sites for re-development in South Norwood and and recent levels of development in the area. Woodside is currently protected Only two large sites identified locally however. and the Core Strategy is not These are a large and presumably sub- proposing to remove that regional electricity substation which is highly protection. Likewise the Core unlikely to be decommissioned due to the Strategy proposes to protect continuing need for electricity distribution homes suitable for families to through the current system, and the car park ensure that there is no net loss serving a large supermarket and football of these homes in any ground, both of which can reasonably be redevelopment. expected to remain. Historically the area developed as predominantly residential accommodation but interspersed with light industrial and service uses. Over recent times the factory, storage and office buildings and sites have fallen out of use. Many of these sites have recently been or are currently in the process of being redeveloped as housing. These sites include for example the former removals company and print works on Portland Road, factories at both ends of Carmichael Road, the former works site and former lock up garages on Harrington Road, a site to the rear of properties on Lincoln and Regina Roads, and former works sites on Albert Road, Manor Road, Woodside Road and Spring Lane. In addition over the same period a number of the larger public house sites in the area have either been redeveloped or converted. These include the Goat House, Gladestone and Greyhound pubs. All of these developments have been granted planning consent over the last five or so years, over what has been a notable period of high levels of housing development. Most of these types of ‘brown field' site in the area have now been redeveloped however leaving very few additional opportunities in South Norwood and Woodside. Hence, assessing the capacity of the area to accommodate further growth based a finite amount of available land for new housing that has been largely exhausted already by the recent high levels of local development makes no sense. As a result the new housing would inevitably have to be built on either currently open land or through the replacement of existing homes with new considerably high density properties. North – Homes Strategy One of the areas that particularly concerned The number of homes already Amanda Sciberras Figure 5.2 me was the number of proposed new homes under construction (as at March Resident for SE19 area as there are two major 2009) in Upper Norwood and Objection stumbling blocks to the current ambitous the other Places of Croydon are Disagree – No Change figure and a number of other anomalies: 1) included in the overall number The current desire to build 800 new homes in of homes in each Place. the Croydone zone of SE19 is unrealistic and has not taken into consideration the number of new homes currently under construction and awaiting construction in the SE19 zoes of 3 adjoining boroughs. So far Bromley are building 17 new homes, Lambeth are building 68 new homes and Croydon have 53. Total 138 new home currently UC but not taken into account. North – Transport Strategy Section 5: North - Transport Strategy The comment is noted. The Mr Michael Mulhern 5.60 council will continue to work Greater London Authority Paragraph 5.60 refers to the Tramlink closely with TfL on proposed Observation extension to Crystal Palace under the transport improvements. Noted subheading of Long Term vision. It should be noted that the extension has not been included in TfL's current business plan and South London Sub-regional Transport Plan. It is currently unfunded and no work is planned to be undertaken on this proposal. As such, the Council should make clear that this is aspirational and at present no funding is available from TfL to take forward for this project. North – Transport Strategy Section 5: North - Transport Strategy The comment is noted. The Mr Michael Mulhern 5.60 council will continue to work Greater London Authority TfL suggests the following change to bullet closely with TfL on proposed Observation point four of paragraph 5.58: "Introduction of transport improvements. Noted Line 4 Tramlink services between Elmers End and Therapia Lane to relieve congestion to access the CMC. Additional trams (4-6 vehicles) will help ease overcrowding on the central sections of the Tramlink network and act as a precursor to increasing the frequency of the service to Wimbledon (to ease congestion between Mitcham to Wimbledon)."

TfL supports proposals under paragraph 5.58 to limit the amount of parking spaces and access from the already congested A23. Overview Hope that the Masterplan idea for Crystal The preparation of a masterplan Andrew Parfitt 5.3 Palace Triangle can be taken forward with for Crystal Palace will be Crystal Palace Triangle neighbouring boroughs. addressed in lower level Planning Group Development Plan Documents (CPTPG) (e.g. Site Allocations and Observation Development Management) and Noted – To be Reviewed future masterplanning exercises. Overview 1. General CPTPG welcome Croydon's Support is noted. Andrew Parfitt 5.3 commitment to cross-borough working. In this Crystal Palace Triangle context, we propose that Croydon should (like Planning Group Bromley) accept comments on planning (CPTPG) applications from residents and traders in Support neighbouring wards in other boroughs. Noted CPTPG will lobby Lambeth, Southwark and Lewisham to do likewise. Overview In future I would suggest that the mass of The suggested proposals would Mr Fred Kille buildings in the centre of Crystal Palace include significant demolition Traffic one way system be removed and the within a Conservation Area, Objection present Housing be kept This would allow including demolition of listed Disagree – No Change modern built shops to be developed and and locally listed buildings, and encourage more modern shopping also then are therefore considered you would be able to bring back the usual 2 inappropriate. way traffic system.  I agree that this would cause problem regarding Housing and shortage of shopping areas while the area was redeveloped.  The main thing is to be careful that the development of the centre does not hold back the smaller centres which could be held back by this concentration on the Centre. So many of the areas are confined by narrow Roads, Bridges, Railway Lines etc. S Norwood is one area. Crystal Palace narrow Roads and Building Lines. Transport- Where are we Provide opportunity to extend tram network Comment is noted. now? Transport- Crystal Palace and Upper Norwood 5.53 Observation Noted 6.0 East Spatial Management Area Section Representation Recommended Response Full Name Paragraph Organisation Nature of Response Officer Recommendation Feedback for Kenley: In the context of The proposed numbers of new Revd Charles Trefusis housing targets, we agree that Kenley should homes have been allocated to Purley & Kenley be included in the East Spatial Management individual areas based on Neighbourhood Area "East SMA" which has a target of 900 projected increases in Partnership new dwellings during the 20 years up to 2031. population, the existing Objection In particular, we are in full agreement with the infrastructure capacity, the Disagree – No Change strategy supplement's comments on the East ability of areas to accommodate SMA (on page 50): "These suburbs will be new infrastructure and the sites protected or enhanced in their present form, shown in the SHLAA. Clearly all but allowing for appropriate development of areas will require additional minimal impact with a strong emphasis on housing to meet identified conservation" We believe that Kenley & Old needs. Coulsdon's share of the 900 dwellings of the East SMA of 300 new dwellings (page 54 of the supplement) is acceptable and will serve to protect Kenley's character. We note that over 90% of these new dwellings will be family oriented - three or more bedroom homes (page 54 of the supplement). This target is again in keeping with Kenley's character We note that the boundaries of the "place" of Kenley used in the strategy don't match Kenley's ward boundaries. In the case of Kenley, it appears that parts of its northern area are included in the Purley "place". Given that the strategy is seeking a much higher level of new housing for Purley, we are concerned that this area of Kenley could suffer an inappropriately intense level of development. We would re-iterate that the wards of Kenley and Old Coulsdon should absorb no more than 300 new dwellings in total so as to preserve their semi-rural character. East management area The comment is noted. Mr Michael Mulhern Greater London Authority 49 The east management area includes Observation Addington, Kenley and Old Coulsdon, Noted Sanderstead, Selsdon and Shirley. The Core Strategy proposes a total of 900 new homes by 2031. This area is afforded the greatest level of protection with a strong conservation feel, but with some minor enhancement led growth. 50 In line with London Plan policy 3D.19, the Core Strategy proposes the provision of a new burial site at Kent Gate Way (East), which is broadly acceptable. However, it is noted that further work is still required and additional discussion on this site would be welcome. We would suggest that the strategy should The Draft Replacement London Mr Brian Madge Figure 6.4 also incorporate a limited release of land from Plan includes a presumption Brian Madge Ltd the green belt, with good public transport against the release of Green Objection accessibility, to accommodate necessary Belt and Metropolitan Open Disagree – No Change development. If this is accepted we propose Land across London which the that the land between Kent Gate Way and Core Strategy should conform Lodge Lane, Addington represents a potential with. It is recognised that centre for family housing with opportunities for Croydon is constrained in terms community facilities leisure and recreation of the supply of land suitable for facilities. The Addington Village bus/tram housing and the targets set out interchange represents a significant public in the Draft Replacement transport focal point around which a new London Plan reflect this. Over sustainable development form can be the lifetime of the plan the realistically achieved. Strategic Housing Land Availability Assessment indicates that there is sufficient land in Croydon to achieve the strategic target set out in the Draft Replacement London Plan without the need to release land from the Green Belt or Metropolitan Open Land. The strategy places a greater emphasis on The Draft Replacement London Mr Brian Madge Figure 6.4 the provision of family units, (3 bedrooms or Plan includes a presumption Brian Madge Ltd more) to the extent that nearly 50% of all new against the release of Green Objection housing will be of this size including a high Belt and Metropolitan Open Disagree – No Change percentage in CMC and its environs. As Land across London which the regards CMC it is suggested that such family Core Strategy should conform housing cannot be supplied at the necessary with. It is recognised that densities in these locations. Accordingly we Croydon is constrained in terms suggest that the options should not discount of the supply of land suitable for greenfield sites at this stage in the process. A housing and the targets set out limited development off Kent Gate Way, in the Draft Replacement related to Croydon Tramlink, can be achieved London Plan reflect this. Over in a manner which will fulfil many of the the lifetime of the plan the Council's objectives regarding sustainable Strategic Housing Land patterns of growth. A development of housing Availability Assessment in this location would assist in upgrading the indicates that there is sufficient tram stop and uses the existing bus and tram land in Croydon to achieve the routes to the maximum benefit. Other strategic target set out in the locations will require new transport investment Draft Replacement London Plan which may now be question in the light of the without the need to release land financial restraints. from the Green Belt or Metropolitan Open Land. There are many green areas, especially in The comment is noted. The Mr Carl Roche Kenley which could be used more especially greenspaces in Kenley are as they are free and times are getting hard. recognised as a valuable Observation community facility. Noted Although some Kenley residents work in the The comment is noted. Revd Charles Trefusis Croydon Metropolitan Centre ("CMC"), the Purley & Kenley majority face long commutes to central Neighbourhood London. Therefore, Kenley residents place Partnership great store on a reliable and frequent train Observation service. Noted Kenley residents fully support the renewal of The support is welcomed. Revd Charles Trefusis the CMC as a vibrant retail, business and Purley & Kenley cultural centre. We fully support the Neighbourhood establishment of a first rate university in the Partnership CMC. Support Agree - No Change As many Kenley residents work in managerial The comment is noted. Revd Charles Trefusis and professional occupations, the Purley & Kenley development of a sizeable "high skills" Neighbourhood economy in the CMC would be highly Partnership desirable. Observation Noted Annexe 3 Croydon core strategy Kenley The comment is noted. Revd Charles Trefusis response Key aspirations of Kenley's Purley & Kenley residents Kenley is leafy suburbia at its best. Neighbourhood Large swathes of Kenley comprise protected Partnership conservation areas and metropolitan green Observation belt. Residents put great store on the Noted preservation of Kenley's semi-rural character. East – Homes Strategy We would re-iterate that the wards of Kenley The comment is noted. Revd Charles Trefusis Figure 6.2 and Old Coulsdon should absorb no more Purley & Kenley than 300 new dwellings in total so as to Neighbourhood preserve their semi-rural character. Partnership Observation Noted East – Jobs Strategy We are not quite sure what benefits will The rationale for redesignating Mr Roger Hill 6.31 accrue from Selsdon being re-designated as a Selsdon as a District Centre is Selsdon Residents District Centre. What we are concerned about to bring the Core Strategy in Association is that it is rapidly becoming a restaurant and line with the London Plan. In the Observation fast food centre. We are given to understand absence of a strong case not to Noted that an area assessment will be undertaken to do so, conformity with the assist with determining further applications of London Plan is a logical step. this ilk. We consider it over supplied already. The area assessment will Sadly, the DIY shop failed but the premises inform the forthcoming are about to become a Chinese takeaway Development Managmement DPD which will address issues such as the balance between shops and restaurant/fast food outlets. East – Transport Strategy Tramlink extensions at Selsdon, Shirley, The Tramlink extensions Mr Barry Atwood Addington and Sanderstead 13. The real proposed in the Core Strategy Resident problem with Selsdon, Shirley and Addington have been arrived at by Observation is accessibility. As the Supplemental Report discussion with TfL. It is Noted admits, they are excessively car dependent. considered that the costs of an For this problem to be ignored makes a extension to Selsdon are not mockery of Croydon's claim to be a "Place justified by the predicted with a Sustainable Future". The obvious need benefits. is for improved public transport, the opportunity for which is already available via Tramlink, which has a proven track record of removing car journeys from the Borough's congested roads. The extension of Tramlink down A23 or A235 might superficially appear an attractive option. But since public authorities have for more than 25 years declined to contemplate any serious work to relieve this arterial route of heavy traffic at Purley, such an extension would simply add to the congestion. Purley and Coulsdon have mainline rail services to Croydon and London: it is Selsdon, Shirley and Addington that have the real public transport need. A short extension of the Tramlink line up Selsdon Park Road to Selsdon would enlarge the possibilities of spreading the overspill and the environmental benefits to that Place. And from there it would be simple matter to increase those possibilities and benefits by continuing the extension up Addington Road to Sanderstead. Addington and Shirley are even better placed, being already located either on or very near the Tramlink line. If this is indeed currently inadequate to bear a proportionate share of the overspill, here too there is the obvious the option of line extensions - for example down the A232 Wickham Road. East – Transport Strategy Paragraph 6.52 - It is considered that the A tramlink extension is unlikely Mr John Phillips 6.52 potential for feasibility studies into extending to be viable, given the lower Tandridge District the Tramlink network to Selsdon, which could level of residential densities in Council benefit residents living in the north eastern this area. Objection parts of Tandridge District should be explored Disagree – No Change as an option. South Spatial Management Area Coulsdon and Purley Homes- Addington East Spatial Management Area Addington, The support is welcome. Mr John Phillips 6.6 Kenley and Old Coulsdon, Sanderstead, Tandridge District Selsdon. Paragraphs 6.6, 6.10, 6.11 & 6.13 - Council Protecting the "strategic greenspace" Support including Metropolitan Green Belt and open Agree - No Change space is supported. Jobs- Addington In order to ensure the creation of a vibrant Support is noted Cathy Hall 6.23 living environment with a range of facilities, we GL Hearn support the proposed allocation of New Support Addington as a District Centre. It is Noted acknowledged that there is an appropriate mix of existing retail and service provision; however, in accordance with PPS4 definition of a District centre which expects the provision of ‘at least one supermarket or superstore', we consider that the provision of superstore/supermarket in this location would consolidate New Addington as a main food shopping destination to the benefit of the wider vitality and viability of the existing uses Overview 3. Response on behalf of Kenley :Key Paragraph 6.1 makes it clear Revd Charles Trefusis 6.1 aspirations of Kenley's residents Preservation that the eastern area will be Purley & Kenley of Kenley's semi-rural character. protected or enhanced in its Neighbourhood present form, but allowing for Partnership appropriate development of Observation minimal impact. Noted Overview Feedback on the strategy outside Kenley: The proposed numbers of new Revd Charles Trefusis 6.1 Future new house building should be very homes have been allocated to Purley & Kenley restricted. individual areas based on Neighbourhood projected increases in Partnership population, the existing Objection infrastructure capacity, the Disagree – No Change ability of areas to accommodate new infrastructure and the sites shown in the SHLAA. Overview Feedback for Kenley We are in full agreement The comment is noted. Revd Charles Trefusis 6.1 with the strategy supplement's comments on Purley & Kenley the East SMA (on page 50). Neighbourhood Partnership Observation Noted Transport- Selsdon Section 6: Transport - Selsdon The comment is noted - Policy Mr Michael Mulhern 6.45 in the next iteration of the Core Greater London Authority Paragraph 6.45 refers to traffic congestion Strategy will be developed to Observation and overcrowded buses at the start and end consider school travel plans and Noted – To be Reviewed of the school day at Selsdon. This indicates encouragement of sustainable that transport for pupils who are not walking or travel. Future location of cycling to their local schools causes difficulty. schools will be considered in The core strategy perhaps needs to address the Site Allocations DPD and the proximity and locations of schools to the the Council's Education Estate catchment population. Strategy. Transport- Selsdon Section 7: Transport - Selsdon The comment is noted. Mr Michael Mulhern 6.47 Greater London Authority TfL wishes to set out that in regards to Observation paragraph 6.47, the bus network is reviewed Noted on a regular basis to ensure that it is providing adequate capacity. Any changes required to enhance capacity will be progressed subject to funding. Other measures such as school travel planning and spreading departures from schools over the course of the day should be encouraged to ensure that travel to and from schools is as sustainable as possible Transport- Selsdon We applaud the analysis of the transport Support is welcomed Mr Roger Hill 6.45 problems and the comments with regards to Selsdon Residents the need to reduce the impact of school trips Association by providing additional bus services, which will Support also reduce car dependency Noted Transport- Where are we Section 6: Transport - Addington The comment is noted. Mr Michael Mulhern now? Transport- Addington 6.38 TfL welcomes opportunities to acquire Greater London Authority additional bus standing space at Addington Observation Village as set out under paragraph 6.38. Noted Transport-Kenley and Old Reliable and frequent train service. The council will continue to Revd Charles Trefusis Cousldon work with Transport for London 6.39 to improve transport services in Purley & Kenley the borough. Neighbourhood Partnership Observation Noted 7.0 South Spatial Management Area Section Representation Recommended Response Full Name Paragraph Organisation Nature of Response Officer Recommendation

7.9 Purley existing residential character : Detailed development Revd Charles Trefusis Good to see that the Council describes its management policies will be set Purley & Kenley character as "detached houses on relatively out in the forhcoming Neighbourhood large plots ...... and ...... " If the Council Development Management Partnership intends to protect this character then the DPD. Objection policies put forward fail to reflect this. Disagree – No Change In particular, we must refer again to our Proposals for the extension of Mr Barry Atwood proposal that the northern limb of Box Ridge particular, existing Local Areas Resident Avenue, together with the surrounding area of Special Character is not a Observation embracing Hill Road, the southern limb of Box matter for the Core Strategy. No Action – Not an LDF Iss Ridge Avenue, Purley Rise and Purley Knoll be included in the West Purley Local Area of Special Character. We understand that a preliminary inspection of these roads has now actually taken place. However, we still have received nothing in writing indicating the planners' views or explaining what they would want from residents by way of evidence to support the proposal. This is an unacceptable delay given that we first raised the matter in our reply of 21 September 2009 to the Croydon Core Strategy Initial Report: Imagine Croydon. You may be assured that we shall not let this matter lie. The extension of Tramlink down A23 or A235 Comment is noted. Mr Barry Atwood would simply add to the congestion on this Resident arterial route while public authorities decline to Objection contemplate any serious work to relieve it of Noted heavy traffic at Purley Coulsdon Town centre - how to energise the The comments on the character Mr Lewis White town centre as a place to shop and live. I have of Coulsdon are noted, With read the recent Economic Assessment study, regards to the suggestion that Observation and agree with many of the findings, but find it the council seeks protection of Noted strangely silent on several key issues, namely the new buildings of Smitham that of the quality of the environment and semi- Station and the Audi car show dereliction of certain areas. These are room, there is not an discussed below in 3 and 4. Having lived in appropriate protective measure Coulsdon for 6 years, having visited since the that the council can take for 1960's to buy timber, have haircuts, and shop, such recently built I have come to a number of simple development. However as a conclusions.  1: Until the recent town centre recent investment it is unlikely improvements, the environment was drab, that they will be albeit that the traffic passing through gave it replaced/demolished in the next the appearance of life. The reality was that it few years. was in decline for decades. Architecturally, With reference to the town Coulsdon town centre had more in common, centre suggestions,the council visually, with an industrial town rather than a has compulsory purchase picturesque Surrey village or town. It was a powers, however in the current low-cost creation of the railway.  The good economic climate it is not likely news is that the town centre road and footway the the council would pursue works, with their real granite kerbs, wider this and with the footways, areas of real stone, central granite Coulsdon/Cane Hill masterplan sett medians, and street trees-have totally underway other options may transformed the appearance and " feel" of the come forward for Coulsdon. town centre. It is now a really pleasant place!. The comments on the detail will  The gateway plantings and open spaces be forwarded to the around the Northern junction-with the very fine Coulsdon/Cane Hill masterplan new flint and brick walls - provide a really project team. The vacancy rate attractive gateway to the town centre, It now in the employment areas of has an open, sunny feel, that is just waiting for Windermere Road, Reddown the right type of development of new shops Road and Coulsdon North is and flats, which I believe must be provided in currently at 17% (and much of the town centre itself. (see 3 below:-)  2: this is due to redevelopment Architecturally, there are a handful of good activity) which is broadly the buildings of architectural merit that rescue the average for the borough and is town centre from mediocrity. These are:- The reasonable in the context of the old Bank building at the visually key junction current recession. It of Brighton Road (The Boulevard) and demonstrates that it is not a Chipstead Valley road. The Post office-a priority, however the traditional building of mottled Surrey, Sussex Coulsdon/Cane Hill masterplan or Kent stock bricks with a pitched clay tiled will consider encouragement of roof, and charming garage behind. The Janes regeneration including new building- a "modern traditional" Surrey-style enterprise. office building of red/orange multi-stock bricks set back with a generous landscaped area in front. The Library- an English "Art-deco" building of brown brick, with a rather sad- looking flower bed and row of concrete posts in front.  Good new additions are :- The new car show room on the bypass- a beautiful modern building of glass The new W.C., of granite and stainless steel. The new Smitham Station building and adjacent bike parks and well-designed fences.  These are buildings which should be protected in some way, if you could do this. Certainly these building s provide guidelines for the future.  3: Flats and shops with green roofs in the town centre. The economic assessment failed to mention the obvious, that the shops on the East side of the Brighton Road from the Smitham railway bridge up to the Red Lion site are backed by under-used sites. The Plumb Center building and yard and the Working men's Club in the side street are now stopping the redevelopment that the town centre desperately needs.  I am of the firm belief that the Council should now compulsorily purchase all the shops, from the bridge to the Red Lion site, and the Plumb Center and its yard, and the Club, and some adjacent houses, and shops next to the club, to create a site for new shops and with green roofs and flats or offices above. The feel would be modern and very green. You could have a linear supermarket with a continuous glazed frontage to the street-- with a green roof above-- and good quality flats for sale or rent with their own roof gardens.  This is a worthwhile and I believe economically viable vision. It would get people working and living- not in out-dated accommodation such as is present at the moment, but in nice surroundings, right in the centre of Coulsdon. This would bring money into the town centre, thus making the town centre viable  If the Pinewood site were developed for "Green Housing" this use might be better for Coulsdon than a strangely wedge-shaped supermarket on this site. I am not convinced about the latter. A wedge is not a good shape for a building like this.  Waitrose, on the West side of the road, could move into the linear supermarket, thus freeing up the Waitrose site for new flats-flats with balconies and set in a green landscape-again, bringing people to live in the town centre.  The Red Lion was in some ways a loss, but I do believe that a design such as that proposed by a local resident, Mr. Maltby, would provide a modern centre to Coulsdon and would set a precedent for high quality architecture and liveable town centre.  My abiding request to you is to set in place a plan for the town entre which creates a beautiful, green place with high quality modern "green buildings", flats and offices, as well as good shops. I really think it would be feasible, if you could find the right developer, and purchase those sites along the East side of the Brighton Road.  I would be interested to know your considered view on the compulsory purchase idea.  4. The industrial area-Windermere and Redlands and Coulsdon North.  The Economic Assessment skirted over the fact that all of these areas, except for the new car showroom, are in equally poor shape and in sore need of redevelopment. How that could come about, I don't know, unless a high quality estate developer could take over, but as that does seem to have happened in the case of the Car showroom, I live in hope. But in my view, it is important to improve these three areas as at present, they are semi- derelict, and fail to fulfil their potential as an employment base, which can't be good for Coulsdon jobs. I think that this should receive priority in place of industrial or similar development on the unique area of rural landscape known as Cane Hill. South management area The Council will no longer be Mr Michael Mulhern proceeding with strategic site Greater London Authority 51 The south management area comprises allocations in the Core Observation Coulsdon and Purley. New development in Strategy. These key sites will Noted – To be Reviewed this area must be sensitive to local needs with be dealt with through Site a strong emphasis on conservation. The Core Allocations DPD and the Strategy identifies a housing target of 2,600 Opportunity Area Planning new homes by 2031. Framework. 52 Cane Hill is identified as a major mixed use opportunity site. The Council should clarify where the detailed policy requirements for this strategic site would be set out. Emerging proposals for these sites will need to be in general conformity with London Plan policy. Cane Hill Redevelopment .! As a Landscape Design comments related to Mr Lewis White architect I have to say from the outset that this Lion Green Rd are noted. The is a precious gem of chalk downland specific policy comments Objection landscape that stands with its woods, beautiful relating to housing Noted – To be Reviewed open fields, and its remaining hospital types/locations are also noted. buildings, proud above the town centre. In fact, it is a landscape that actually flows down into the town centre, to meet Lion Green Road and the Brighton Road. Lion Green Car Park Apart from the trees and grass frontage, the car park is a tarmac and cinder desert. Yet it could so easily be an attractive car park with trees, and behind it could be good quality buildings. Whatever the buildings turn out to be, I ask that you ensure that the grass and mature trees are retained along the frontage at all costs, and that any car parking includes a grid layout of trees. Innovation Centre on Cane Hill. I have to state clearly my total objection to this proposal. Firstly, hi-tech firms all cluster around Cambridge and certain parts of the Thames valley, the UK Silicon Valley. I would question any proposal on the grounds of no real demand existing. Cane Hill is too small to accommodate, in addition to housing, a campus-style development like the Legal and General, and the Pfizer developments in Reigate and Banstead. Thirdly, the type of buildings that are built on Science parks are big, and are radically unsuited to steeply hilly terrain of the type present at Cane Hill. The only way that such buildings can e accommodated is to carve out large terraces, meaning that the beautiful landscape is destroyed. Corporate car parks also take up a lot of space, space which is too precious to waste at Cane Hill. Housing-to serve needs for flats I and many others, including the writers of the Coulsdon Economic assessment, understand the need for places where small families can live. For this reason, I see Cane Hill providing a number of blocks of flats for couples and singles. Imagine a number of well-designed blocks with balconies, growing out of the trees of Cane Hill? They would look fine, and not destroy the landscape. I could easily imagine three such blocks on the wooded site of the existing Coulsdon Area Farm. Keeping the Open fields . Imagine as well, children living in family homes on the hospital site, on the flatter upper areas of the site. They could play in the woods and fields, and see the cattle and horses all around. That would be good for the children! So for this reason I would see the top "hospital footprint" area being for an Eco- Village of family homes, including the water tower for a few high-end flats and the key remaining buildings of the hospital. The East SMA's suitability to accept overspill Whilst the 16 Places remain in Mr Barry Atwood 10. The common feature of the Places the Core Strategy, feedback on Resident collected into the East SMA is evidently the the concept of Spatial Observation presence there of Green Belt land. We have management Areas suggests it Noted already pointed out that this is not an will not feature in the next argument against redevelopment in those iteration of the Core Strategy. Places. If existing viable properties can be replaced in Purley they can be replaced in the East SMA too.  Sanderstead, Kenley and Old Coulsdon suitable to accept overspill as satellites of Purley and Coulsdon 11. Whatever the other virtues of the Spatial Management Approach adopted in Towards a Core Strategy , it certainly distorts the true situation in the south of the Borough. The western part of Sanderstead relies on Purley District Centre. Kenley and Old Coulsdon should in fact properly be brigaded with Purley and Coulsdon towards which they look and on which in large part they rely. In the first case, why else does the Council seek public views from the Purley and Kenley Neighbourhood Forum ? In the second, the name - Coulsdon - speaks for itself. These facts are not, certainly in the case of Purley, given sufficient weight in assessing the Districts that the Centre is expected to serve and the share of overspill it is being expected to bear. And this it should be noted is in the context of a situation where, as things stand, Coulsdon District centre lacks a large supermarket, and its residents are drawn to Purley. So Purley is expected - at least as regards grocery and related shopping - to service a large part of the south of the Borough with an inadequate infrastructure and no promise of relief from excessive traffic. These parts of the Purley hinterland, which mostly have the benefit of easy access to the East Grinstead, Caterham or Tattenham Corner, if not the main Brighton, railway lines, while Sanderstead has still undeveloped land on Mitchley Hill. There seems no reason why they should not bear more of the overspill burden than is proposed. Swimming Pool: Purley expects and needs to Infrastructure provision will be Revd Charles Trefusis retain a swimming pool in Purley town centre . addressed in the IDP. Purley & Kenley This needs to be incorporated into the Core Neighbourhood Strategy. Partnership Objection Disagree – No Change Cinema: Purley would benefit from a new Infrastructure issues will be Revd Charles Trefusis Cinema in the town which would significantly addressed in the IDP. Purley & Kenley contribute to the regeneration of the town Neighbourhood centre and bring in custom for the other Partnership businesses. Many resident either do not like Observation or feel unsafe going to the Cinemas in Valley Noted Park or Croydon town centre (and many chose to go to either Oxted or even Epsom on a regular basis). The town could sustain a Cinema similar to, say, Oxted, and attract families and other local people in the area. There is a significant opportunity here. Purley, with an inadequate infrastructure and The presence of an existing Mr Barry Atwood no promise of relief from excessive traffic, is Tesco store means Purley Resident being expected - at least as regards grocery already services a larger Objection and related shopping - to service the South catchment area. The Core Noted SMA and large parts of the East SMA that are Strategy focusses on the need satellites of Purley and Coulsdon. These to improve the relationship Places should bear a proportionately greater between the store and the rest share of the overspill. of the District Centre. No map on site. Purley Tram to leave route 3 It is not the place of the Core Mr Alan Moody and us rest of Woodside Line to Selsdon Strategy to determine the exact Friends of the County of Station across allotments beside Brighton Line alignment or routing of Tramlink Surrey on dragons teeth tank trap alignment, extensions. Detailed work on Observation continue using Tattenham Corner Lind link it this has to be done by No Action – Not an LDF Iss to Epsom Downs Line to Sutton. Transport for London at a future date. Town Square: There is no mention of the new This is too detailed for a Core Revd Charles Trefusis Purley Town Square and the expectation for Strategy. Purley & Kenley regular French and Farmers markets, and Neighbourhood other similar events, as well as appropriate Partnership entertainment and community gatherings. This Objection needs to be incorporated into the Core No Action – Not an LDF Iss Strategy. 7.23 Jobs -Purley : We need to insure that The comment is noted. Revd Charles Trefusis main retail balances the need of the town, Purley & Kenley particularly in relation to the existing Tesco Neighbourhood Superstore. Empty shops are of no value and Partnership negates civic pride. Observation Noted 7.28 We support mix use developments in the While the comment is noted, the Revd Charles Trefusis town centre. However it appears that the suggested change is too Purley & Kenley Council has not defined exactly what makes a detailed for a Core Strategy. Neighbourhood good and viable vibrant DISTRICT centre. We Partnership believe for it to be sustainable it needs variety Observation of uses- retail, leisure(swimming pool, cinema Noted , gymnasium etc) , library, food , farmers market and of course residential. good parking facilities works of ART and good access. 7.39 Culture : Public Art is mentioned, and yet The Core Strategy will reaffirm Revd Charles Trefusis we see no signs of this in any of the Purley the council's commitment to Purley & Kenley regeneration documents and indeed allocation public realm this encompasses Neighbourhood of any funding allowed for it in the recent public art. The development Partnership £2.25m for High Street improvements. The management DPD will set out Observation 'vision' cannot afford to mislead local the details. Noted – To be Reviewed communities. There is also no provision to add POS into the It is physically difficult to add Revd Charles Trefusis area either. POS to an area. However, the Purley & Kenley council's Green Infrastructure Neighbourhood proposals will seek to enhance Partnership existing open spaces, including Objection the public realm generally, and Disagree – No Change to make them more accessible to the surrounding areas. 7.45 Transport : Improving the junction of The comment is noted. The Revd Charles Trefusis A22/A23 in Purley Town Centre must remain council will continue to work Purley & Kenley a high priority. Dedicated Bus Lane in with Transport for London to Neighbourhood Brighton Road adds to traffic flow due to the improve transport in the Partnership narrow width of the road from Purley to borough. Observation Coulsdon. Tramlink into Purley is welcome Noted but again this should not be at the risk of car use space. Long term public authority inaction in Purley 8. Comment is noted. Mr Barry Atwood It is tedious to have to reiterate that Purley's Resident difficulties essentially derive from the severe Observation traffic congestion at the junction of A22, A23, Noted A2022 and A235. During at least a quarter of a century, public authorities have not only neglected to solve the steadily increasing problems that this is causing for pedestrians, traffic and traders, but have also compounded them, in particular, by permitting the establishment and development of a major traffic lure in the form of a hypermarket on the old waterworks site. Moreover - as the Infrastructure Delivery Plan makes only too clear - there has been an almost complete failure, until very recently, to invest in Purley's infrastructure. For example, redevelopment of the Hospital, after 9 years of delay, has yet to be commenced, the fire station is unfit for purpose and the number of patients per GP principal is well above the Croydon average. [2] In consequence it has become a self fulfilling prophesy that many residential properties along the main roads - particularly to the south of Purley Cross - are fit now only for redevelopment. Kenley residents are also anxious that their The comment is noted. Revd Charles Trefusis district centre - Purley - should receive the Purley & Kenley necessary investment to function as an Neighbourhood attractive leisure and shopping destination. Partnership Observation Noted The environmental importance of Purley's The Council is seeking to Mr Barry Atwood existing homes and gardens 9. But this is not accommodate growth in a Resident still true of most of the district. Away from the sustainable manner. Whilst Observation main roads there are well kept family homes. Conservation Areas and Local Noted Dating from the first half of the 20 th century Areas of Special Character are they have gardens and trees that provide a less likely to see significant vital ‘green lung' for the neighbourhood. change, other areas of Replace the old with new denser development previously developed land in and Purley will be further degraded to the more accessible locations, are disadvantage of all. The absurdity of such a more likely to witness change development is confirmed by para 6.30 of the and intensification of residential Infrastructure Delivery Plan which admits the activity. importance of green infrastructure in mitigating climate change and the existing heat island effect caused by the predominantly hard surfacing in Purley Town Centre. Purley by contrast serves as the district centre The comment is noted. Revd Charles Trefusis for many Kenley residents - both as a Purley & Kenley transport hub and a shopping centre. We Neighbourhood believe that the Purley district centre is in Partnership urgent need of renewal and investment. Observation Noted – To be Reviewed We fully support the strategy's proposed The support is welcomed. Revd Charles Trefusis "Innovation Complex" focusing on the However, whilst the specific Purley & Kenley knowledge and technology sectors on the policy for an innovation complex Neighbourhood Cane Hill site. As many Kenley residents are at Cane Hill is omitted in the Partnership managers and professionals, we fully support next iteration of the Core Support the creation of well paid, high skills Strategy. The aspiration to Noted – To be Reviewed employment within a short distance of Kenley. promote innovation and enterprise across the borough remains. Regarding Purley redevelopment, I would like These are detailed issues Steve Rowland to ask that the following points be considered: regarding Purley that will need Rowland Brothers 1. Car park is extended to provide more to be considered in the site Observation parking facilities in the area. 2. On street allocation DPD No Action – Not an LDF Iss parking facilities are provided to customers. 3. Access is provided to our funeral vehicles at all times. 4. What will happen to our branch should the development of the whole site go ahead As a residential area, Purley is appropriate to Comment is noted Mr Barry Atwood offices, research and light industrial Resident processes. But while the severe congestion Observation continues at Purley Cross Gyratory (see para Noted 7.46), strategic road access is scarcely "very good or good". All other things being equal, employers needing to transport materials in and products out are going to locate in more readily accessible places with better parking facilities Also, this documents should confirm Croydon's decision not to commitment to the protection of Green Belt review Green Belt is noted in land other dedicated open spaces para 7.4 Objection Agree - No Change Purley Town centre One-way system. Having The comments on the road Mr Lewis White known Purley for years, since the 70's, when layout and urban design are the Fountain sat outside the waterworks, noted. These detailed Observation before the current one way system, I would comments are more appropriate Noted like to state a personal view that the problem for a masterplan than a Core with traffic congestion is mainly because of Strategy. It is noted that a the long-standing pinch point at the railway scheme to improve the public bridge in Godstone Road, next to "My Old realm of Purley in the High China" restaurant.  There are in fact two Street is currently underway arches in the railway viaduct, each side of the which addresses some of the current road arch, that could be opened up, concern raised and comments albeit at some cost. If they were, the will be forwarded to the Purley Godstone Road could itself be widened to two project manager. lanes in each direction. This would allow traffic to exit the town centre quickly, particularly in the morning and evening rush hours going towards Godstone, when the traffic backs up to stop movement at the junction of the Godstone raod and the Brighton Road.  The current one way system has worked very well over the years, but is unjustly criticised in my view because for some reason, probably short- term costs- those who look at the traffic never do the logical action of opening up these arches. The loss of the buildings on both sides of the road would be a townscape win rather than loss, as all of the buildings - my Old China, and the builder suppliers opposite, and the poor quality parade and Young's builder's merchant to the East of the bridge, are generally run down, and lack any architectural merit.  I fear that what ever is done to improve the traffic layout for Purley, it will always remain congested unless the bridge is opened up. I am not the only long-term Purley town-centre user to think this.   Improving the appearance of the Purley town centre streetscape The footways in the Brighton Road and the other town centre streets, are the standard Croydon mastic asphalt with a concession to aesthetics, a narrow double band of brick-in spite of which, the paving is grey, tired and dull-looking. The road is a similar colour-hot rolled asphalt, so the overall colour is "grey". There is however, nothing wrong with the Brighton Road as a street, -the buildings are original, unified and are generally still what they were-- attractive mock- Tudor town centre shops with flats above.  What lets the place down is the grey, boring paving and over-large highway lighting.  Rather than continue to wait for the "Holy grail" of redevelopment project designs, would it not be more sensible to merely repave the footways in York stone, and replace the standard highway lights lamp columns with something more exciting or "heritage traditional". This is exactly what was done by Croydon at the Triangle in upper Norwood about 10 years ago. This area looks good still.  The York stone is of a mixed russet, grey and buff colouration, thus giving real warmth and life to the street. It contrasts with the grey asphalt of the road surface, thus reducing the scale of the street, and making it more humane.  I really think that this is what the Brighton Road, and if affordable, the other streets need-an appropriate new "floorscape"- just repaving using natural stone. It would respect the townscape character, and restore the paving materials that were probably there originally when Purley was built.  In addition, real York stone lasts for over 50 years, and retains its natural colour, but even the best concrete products fade after 10, and then look tired.  So I urge you to consider this as a measure that could be done now, for a reasonably low sum, and it would not conflict with any longer term goals for the improvement of the town centre. It would need funding, but not a huge amount.  It is interesting to see how good streetscape leads to people taking more care with their buildings. The Upper Norwood Triangle is full of new shops with good-quality fascias and shop fronts. I am sure that this would also happen in Purley. Culture- Purley Why is Purley expected to settle for The proposal to promote the Mr Barry Atwood "temporary occupation of empty occupation of cleared Resident buildings/cleared sites" to accommodate its sites/vacant buildings by Observation cultural activities?' Is this the "Space for temprary creative/cultural Noted practicing [sic] and performing" promised for activity is regarded as additional District Centres in the Creative City by to existing activity. Purley Towards a Preferred Core Strategy for District Centre is also identified Croydon page 26? What is needed is a public as the location for an Enterprise hall/centre in Purley. It is truly ironic that centre specifically for the the Selsdon - apparently to be isolated from creative/cultural industries proposed growth - has such a hall but, on the sector. The subsequent Site evidence of the Supplemental Report, Allocations Development Plan scarcely any cultural activity! One possibility Document will help to determine for consideration - if the Purley Library is to be the size/location of this facility. moved - is accommodation in the vacated 1930s building. (It is to be noted that a public hall formerly existed nearby on the island site now being redeveloped by the Baptist church.) Such a use of the old Library building would, however, manifestly require further creative thinking about how parking provision could be made. Culture- Purley Culture: a) There is no mention anywhere that Whilst Croydon is fortunate in Jean Apps 7.39 I can see for provision or development of a having a larger venue in the Resident small theatre or performance space in either Fairfield Halls/Ashcroft Theatre Observation Croydon or Purley. Such a venue would and more intimate performance Noted provide for productions by small-scale space such as the Warehouse professional (and possibly non-professional?) Theatre, the Council recognises theatre and dance companies. Fairfield Halls the need to improve this caters for more large-scale, mainly situation further. Therefore, The musical,entertainment. What about the future Core Strategy outlines a of theWarehouse Theatre in Croydon? Will it borough-wide policy to get Council support? encourage the temporary use of vacant buildings/cleared sites by creative industries and cultural organisations and a network of Enterprise Centres also aimed at this sector. The regional importance of the Fairfield Halls is the reason it is mentioned specifically in para 4.56. The strategic nature of the Core Strategy precludes policy references to other smaller venues. Culture- Purley b) What exactly is envisaged by the phrase As part of the evidence base Jean Apps 7.39 'cultural anchor establishment' for Purley? gathering exercise the Council Resident (P.69, Supplement) Is it intended that this commissioned a cultural Observation shouldinvolve a theatre/performance space? mapping study which identified Noted What about a gallery for displaying local a number of clusters in the artists' work? Purley area relating to fashion, music, advertising and software development. Beyond the aspiration to support these clusters through a physical hub (aka cultural anchor establishment) at this stage, no further work has been undertaken to determine its format, funding mechanism etc. If a site/premises does not come forward beforehand, the forthcoming Site Allocations DPD will seek to determine a suitable location for this facility. Culture- Purley There is no community hall in Purley for The Core Strategy proposes Mr Barry Atwood meetings, functions etc. A district centre new community facilities in Resident needs this. Purley also needs PURLEY signs Purley which in addition to Observation on all roads as they enter the district centre. existing facilities close to/in the Noted We are asked by motorists and lorry drivers District Centre may provide ‘Where is Purley'? as we walk around the further opportunties for town.  More detailed comments will follow community uses. The issue of when documents have been digested. signs for Purley is not a matter for the Core Strategy. Feedback from the consultation exercise suggests the concept of the spatial management areas will not be taken forward to the next iteration of the Core Strategy. Culture- Purley Why is Purley expected to settle for The proposal to promote the Mr Barry Atwood "temporary occupation of empty occupation of cleared Resident buildings/cleared sites" to accommodate its sites/vacant buildings by Objection cultural activities? If the Library is to be temprary creative/cultural Disagree – No Change moved, its 1930s building is one possibility for activity is regarded as additional the location of a public hall/centre to existing activity. Purley District Centre is also identified as the location for an Enterprise centre specifically for the the creative/cultural industries sector. The subsequent Site Allocations Development Plan Document will help to determine the size/location of this facility. Culture- Where are we Coulsdon has quite an artistic heritage in its Comment is noted. The Mr Charles King now? own right with a number of art, photographic, importance of cultural activity theatre, dance and choral clubs and societies. has been recognsied by its high East Coulsdon It also has a number of art and craft retail profile within the Core Strategy. Residents' Association outlets along with some excellent art and craft Observation teaching facilities in the Tollers Design Centre Noted and the Adult Education centre. The council should be encouraged to work with these societies and to develop and promote these assets and it should reflect these rich sources of art and crafts by encouraging and supping public art in the town centre, making it an interesting place to be and visit. Homes- Coulsdon We support development along the A23 Paragraph 3.38 of the current Mr Charles King 7.7 corridor for increased housing as this is where consultation sets out the broad East Coulsdon the main public transport and communications criteria against which Residents' Association are. However, this must have proper planning applications for new homes Observation brief that limits the size of new properties and should be assessed and they Noted ensures they are built to a quality standard include achieving the standards with sustainable materials that are set out in the draft London sympathetic to the area. This should not be Housing Design Guide. The extended south of Coulsdon South station Local Housing Market Assessment has identified a need for larger properties in Croydon where as the Strategic Housing Market Assessment has identified that there is insufficient land to meet this need. Therefore it would be inappropriate to limit the size of units along the A23 corridor. However in recognition of the need plan for balanced and sustainable communities the requirement for all new homes outside of district and local centres to have 3 or more bedrooms will be reconsidered in the pre-submission draft of the Core Strategy. Homes- Coulsdon 7.10 p64 The allocation of 1200 dwellings to The presumption against Coulsdon 2009-2031 does not appear development of back gardens is onerous, but here again the allocation is area now government policy Observation rather than site specific - and it is this latter Noted – To be Reviewed criterion that in which most stakeholders will be most interested. Presumably, other buildings for social care purposes, such as older peoples' homes and, respite care will be in addition to the above allocation of dwellings.  In this context, the Supplement should support and reinforce the re- designation of house gardens from brown-field sites, making back-land development impossible in most cases, Homes- Coulsdon the strategy is wrong for both the eastern part The emphasis on larger Mr Charles King 7.6 of Coulsdon and for the town centre and west dwellings will be revised in the East Coulsdon side with the emphasis on family dwellings of pre-submission draft of the Core Residents' Association three or more bedroom houses. We strongly Strategy with one that promotes Objection believe there is room for more high quality two a balanced sustainable Agree – Propose Changes bedroom houses and apartments to enable community in Coulsdon through both young people, first time buyers and older the provision of more smaller people to downsize while staying in the vicinity units alongside the larger of their existing home. This should apply to homes. areas around Coulsdon South station, the town centre and on new developments at Cane Hill. Sited in these locations they would provide easy access to the town centre and to public transport both bus and rail.   The Cane Hill site provides a wonderful opportunity to provide Coulsdon with housing, people and employment opportunities contributing to economic regeneration of the town centre . We strongly support redevelopment of the old Cane Hill site with mixed use including housing and commercial development, but would strongly oppose retail in opposition to the town centre. We are of the view that Cane Hill must be considered in conjunction with the town centre and local business parks and not separately.  There is clearly a need for more people in the Coulsdon area to ensure regeneration and long term viability of the town centre. The Cane Hill site should include a mix of housing to ensure that the population has a good mix of old and young people and ranges of incomes. However, the planning brief must express quality of building not just quantity.  In the town centre we also support redevelopment and more accommodation units bringing people to the town centre. However again we stress that new buildings should be of quality and there should be an agreed planning brief covering both quality and size of dwellings e.g. there should be height limit of 5 stories Homes- Coulsdon Coulsdon has many good schools and these The pattern of new and Mr Charles King schools need to be able to take any increase extended schools willl take into East Coulsdon in population of children that will happen as prt account the future pattern of Residents' Association of the construction of new housing. We are demographic change Observation concerned that the existing schools both Noted primary and secondary on the west side of Coulsdon may have difficulty in accommodating all the new children from development on Cane Hill and in the town centre while the primary schools on the east may still have spare places as these are some distance from where the new population growth may be. This could result in children having to make long or difficult journeys to obtain school places. This is another reason why it is important to get the mix of new housing correct. We believe that there should be more emphasis on smaller 2 bedroom quality accommodation to ensure a better mix of the population. Homes- Purley Homes: discrimination against Purley and the Disagree that the South SMA Mr Barry Atwood South Spatial Management Area 3. It gives us has been unfairly targeted Resident no pleasure to point out once more that the compared to the East SMA. The Objection Borough's population dispersal and related distribution of proposed growth Noted policies are severely imbalanced against is based on a range of factors Purley and the South Spatial Management such as public transport Area (SMA) in favour of the East SMA.  accessibility, supply of Comparison with the East Spatial development and infrastructure Management Area 4. 2600 new homes are capacity. Whilst the 16 Places proposed for the South SMA of which Purley remain in the Core Strategy, is expected accept 1400, while the whole of feedback on the concept of the East SMA is to get only 900 (see Spatial Management Areas Supplemental Report paras 6.3 and 7.4; and suggests it will not feature in the figures 6.2 and 7.2). Unreasonableness of next iteration of the Core radically altering Purley's home structure 5. Strategy. The unreasonableness of expecting Purley thus to accommodate a significantly larger number of new houses than the whole of the East SMA is exacerbated by the proposal that, while the East SMA "suburbs will be protected or enhanced in their present form, but allowing for appropriate development of minimal impact" (Supplemental Report para 6.1 and figure 6.3), the character of Purley is to be radically altered by increasing the proportion of non-family homes to 45% of the total housing stock (Supplemental Report figure 7.3).  Inconsistency of the proposals with the professed objectives 6. The absence of any vacant land in Purley, means that the creation of 1400 new flats there would require demolition of existing family houses. It remains to be demonstrated that there is a need for further flats; but even if the market for them happens to exist, the proposal to substitute them for so many of Purley's houses is, in our submission, manifestly inconsistent with - the Borough's need for family homes (Supplemental Report para 2.5); the objective of resisting the sub-division of existing larger homes (Supplemental Report para 3.18); and the requirement that development be sensitive to "the market town and quality suburban character" of Purley (Supplemental Report para 7.2).  Unreasonableness of a policy for Purley based on dilapidation caused by long term public authority inaction 7. Not believing that the policy could be so obviously perverse, we have tried to probe further into the underlying reasoning. Although regrettably having been unable to obtain an explanation from your Department, we see from paras 6.3 and 7.3 of the Supplemental Report that the figures were - "determined by taking the sum of all housing in the SMA which is under construction and factoring in an assessment of potential capacity carried out as part of the Strategic Housing Land Availability Assessment (SHLAA). As well as an evaluation of the probability of development being implemented, the SHLAA also identifies constraints that might make a particular site unavailable for development; this includes identification of sustainability issues and physical constraints that might make a particular site unavailable and/or unviable for development; this includes identification of sustainability issues and physical constraints that might make a site unsuitable for development eg high flood risk, Site of Nature Conservation Importance, protected Industrial Areas or Green Belt." The existence of the Green Belt certainly appears to have been an important factor in channelling new homes away from the East SMA (see, for example, Supplemental Report paras 6.1 and 6.2). In fact the proximity of Green Belt land would appear to be an ideal location for new homes, but it certainly is not in itself a justification for preserving existing viable homes and district character there, but not in Purley. It may be that, when the survey was undertaken, the sum of housing in Purley under construction was significantly higher than in the East SMA. If that was so, it would, in our submission, have largely been due to the fact that in Purley certain property along the main roads has become dilapidated through long term public authority failure to remedy the severe traffic problems or to invest adequately in the District's infrastructure. It is unreasonable to invoke the fact that some of Purley's housing therefore needs replacement as a ground for permitting still more of it to be replaced. Homes- Purley We also wish to raise the fact that the Council Flooding issues do not extend Revd Charles Trefusis 7.9 on the one hand states that no major across all of the Purley area. Purley & Kenley developments will be permitted until flooding However, the Council accepts Neighbourhood issues are resolved in Purley by the Mid the level of housing indicated Partnership Phase, by which I assume around 2020. And and the proposed phasing will Observation yet Fig. 3.8 (p. 14) shows substantial housing be reviewed. Noted – To be Reviewed in 2011 and 2021!! There seems no logic in this. Homes- Purley Page 65: 7.11 The new housing development Developers do not get a full Mr I.G.M. Hunter 7.11 in Purley and Coulsdon, like that in the East return on affordable housing Resident Spatial Management Area (fig. 6.3-page 54), provided within their Observation while emphasising 3-4 bed properties, has developments as a Housing Disagree – No Change them situated in the more affluent parts of the Association will only pay a Borough. Developers will not wish to build proportion of cost of the home "affordable" properties in these areas because which may not even meet the of the lower return in investment. How does cost of construction. The the Council propose to make at least 25% of creation of mixed communities such properties "affordable" without is an important element of compensating the Developers? Will it be the social cohesion and requiring Council's intention to give planning permission developers to provide affordable subject to the developers building the quota of homes is needed to offset such housing out side the centres identified in against the development of figures 6.3 (page 54) and 7.3 (page 65) on mono-communities in the viability grounds, such as the case of the borough. As such it is accepted Wellesley Road Tower (see my comments to practice for developers not to 4.12). Will this again push such housing into make a profit on any affordable other Places which have already had their homes within a development affordable housing numbers strategy settled? and they will factor this into their costs at an early stage. The Affordable Housing Viability Assessment indicates that the provision of affordable housing in the south of the borough and other more suburban areas is more viable than in more urban locations due to lower value of land in these areas. Homes- Purley There are questions about the average The comment is noted. Revd Charles Trefusis Figure 7.3 number of occupants per household which Purley & Kenley need to be explained. Neighbourhood Partnership Observation Noted – To be Reviewed Homes- Purley Away from the main roads much of Purley is New development will be Mr Barry Atwood still comprised of well kept family homes with expected to address climate Resident gardens which provide a vital green lung for change concerns through a Observation the district and should be preserved, range of measures such as Noted especially given the importance of green green roofs, Sustainable Urban infrastructure in mitigating climate change and Drainage Systems and low the existing heat island effect caused by the carbon heat and power predominantly hard surfacing in Purley Town generation. Centre acknowledged by the Infrastructure Delivery Plan Homes- Purley It is unreasonable that the dilapidation caused The breakdown of family/non- Mr Barry Atwood by long term public authority failure to address family housing set out in fig 7.3 Resident Purley's traffic problems or even to invest in is an indication of the types of Objection its infrastructure should now, in effect, be new homes to be provided and Disagree – No Change used as a justification for the concentration not an aspiration to see this there of a disproportionate amount of ratio reflected in the exiating intensive development (viz. 1400 new homes housing stock. as against 900 for the whole of the East SMA); and, when Croydon's professed need is for family homes, for changing Purley so that 45% of its homes are flats Homes- Purley Selsdon, Shirley and Addington more suitable The comment is noted. Whilst Mr Barry Atwood to accept overspill 12. In fact the ‘true' East the Council considers it has Resident SMA is comprised of Selsdon, Shirley and allocated growth in broadly the Objection Addington . Once again there is no reason right Places, the quantum and Noted – To be Reviewed why, if existing properties can be replaced in type of homes proposed will be Purley, they cannot be replaced here too. reviewed ahead of the Their proximity to Green Belt land would be a publication of the pre- positive advantage for the reception of a submission draft of the Core greater proportion of Croydon's overspill. Strategy. Selsdon in particular is well placed to make a bigger contribution. By contrast with Purley, this District centre has viable and more user friendly shopping facilities into which the latest supermarket has been integrated, together with the library and a public hall. The Infrastructure Delivery Plan (pages 65 and 66) shows that it also has, in particular, a well below average number of patients per GP principal, by contrast with Purley's well above average ratio and above average percentage of nursing and residential home patients. We have already questioned the existence of a need for further flats, but, if this truly does exist in Croydon, there is no reason why some at least could not, for example, advantageously be located in the East SMA. In Selsdon this would be consonant with existing development at Forestdale. Homes- Purley The lack of open space in Purley if housing is It is intended that new Revd Charles Trefusis to be increased that needs to be addressed. development should be Purley & Kenley accompanied by approriate new Neighbourhood infrastructure. Partnership Observation Noted Homes- Purley The need to retain Purley's existing residential Paragraph 7.9 notes that Revd Charles Trefusis 7.9 character (detached houses on relatively large Purley's existing residential Purley & Kenley plots) which is in contrast with the Council's character needs to be taken into Neighbourhood policies and this document. account. Partnership Observation Noted Homes- Purley I understand from looking at your plans for the There are no "Areas protected Mary Taylor 7.10 future of Croydon that our road (Box Ridge from future development" Avenue) is not included in the area to be shown on the plans in the Objection protected from future developments. The road current consultation document. No Action – Not an LDF Iss is very attractive and most of the properties were built over 100 years ago - pre-dating the Webbs Estate! It is a pleasure to walk along this tree lined avenue.The houses are all different and the gardens are well cared for. The road is used by local people who walk with their children,grandchildren and dogs, some jog and others stroll. Although it is near the centre of Purley it is very qiiet and traffic free. As you know we have no parks in this area and this road ia an amenity to be preserved for the future. Homes- Purley The still unresolved issues of flooding . The Core Strategy seeks to Revd Charles Trefusis 7.9 identify broad areas where Purley & Kenley flooding is an issue. The Site Neighbourhood Allocations DPD will address Partnership the issue of flooding in the case Observation of individual sites in more detail. Noted Homes- Where are we Page 63: 7.4 What reasons are given for The basis for not reviewing the Mr I.G.M. Hunter now? Croydon not reviewing its Green Belt ahead of borough's Green Belt and MOL 7.4 submitting the Core Strategy for examination sites is informed by the Draft Resident when to do so would identify places which, Replacement London Plan Observation sensibly, could be identified early for which includes a presumption Noted conversion or medication for more effective against the release of Green use at the appropriate time? Belt and Metropolitan Open Land across London which the Core Strategy should conform with. It is recognised that Croydon is constrained in terms of the supply of land suitable for housing and the targets set out in the Draft Replacement London Plan reflect this. Over the lifetime of the plan the Strategic Housing Land Availability Assessment indicates that there is sufficient land in Croydon to achieve the strategic target set out in the Draft Replacement London Plan without the need to release land from the Green Belt or Metropolitan Open Land or to undertake a full scale review of the Green Belt for other purposes. It is also recognised that other uses compatible with the purpose that the land was designated as Green Belt could be accommodated. Jobs – Where are we now? Page 66: JOBS - extract from "we are The Council recognises the Mr I.G.M. Hunter 7.12 Croydon" the perceived growth of a "high borough requires a wide range Resident skills" Croydon population mainly go to the of jobs across all skill levels to Observation high skilled jobs in the Borough will the meet residents' employment Noted Borough encourage the import of people with needs. However, it also "low skills" to do the basic level work which understands that as an makes the Borough function (utilities, retail, economy of sub-regional waste management)?. Or will it be accepted importance, there will be many that not everyone will "degree" material and people commuting to jobs in instead be provided with a practical skills Croydon and given the education? I raised this point in my main core proximity to central London and comments earlier in 2010 and, once again, it the excellent transport links, has been ignored; why?, since the forward there will be many Croydon planning of the type of educational residents commuting to jobs establishment foreseen in the Borough elsewhere. Practical skills between now and 2021 has to include low- education, such as those tech. Academy-based as well. provided at the Construction Skills Training Centre, will continue to form a valued part of the wider education and skills strategy which includes a multiversity. Jobs- Coulsdon Effort must be made to encourage more Comment is noted. The newly Mr Charles King 7.22 business including small office based formed 'Coast to Capital' Local East Coulsdon employment to the area to provide more local Enterprise Partnership will Residents' Association employment . Encouraging both local people certainly promote the strengths Observation to travel less and work locally, while also identified in this observation. Noted bringing other people to the area. Promotion Council agrees that Cane Hill of the areas for its good transport links with offers possibilities for Central London and Gatwick Airport should be commercial enterprise. stressed. There are a number of opportunities to provided increased employment opportunities it the existing industrial estate and business park, , this includes possibilities on the Cane Hill site for new commercial enterprises, but not retail and of course a mixture of retail and office employment opportunities in the town centre Jobs- Coulsdon Don't want supermarket at Lion Green must Comment is noted. Work on the Mr Charles King be in town center. Something needs to get Coulsdon/Cane Hill Masterplan East Coulsdon going to reduce further decline Smaller shops will consider the Residents' Association leaving after 1-11/2 yrs Need to provide appropriateness of a Observation something different on line shopping has had supermarket on Lion Green Rd. Noted an impact on economy Lack of co-ordinated The Masterplan should act as a development within A23 frm Coulsdon to catalyst for development. Purley. Need to get going - something needs to happen or it will continually decline. Jobs- Purley Unless some radical solution is found to The aim to establish Croydon Mr Barry Atwood enable heavy through traffic to flow along the as the premier business Resident A23 road to and from the south, it cannot location in south London and Observation seriously be regarded as a satisfactory artery the Gatwick Diamond is reliant Noted for the purpose of establishing "Croydon as on many faxctors and not just the premier business location in South London upon the capacity of the A23 at and the Gatwick Diamond": nor will Purley Purley. thrive as a commercial centre while the experience for pedestrian shoppers is generally so disagreeable. Jobs- Purley The draft Core Strategy acknowledges that Support is noted Cathy Hall 7.26 the Tesco store ˜occupies a significant GL Hearn amount of floorspace within the District Support Centre'; it is felt that the role of the store in Agree - No Change underpinning the District Centre should not be understated. On this basis, we support the commitment made in the draft to improving the relationship between the store and the defined shopping frontages. It is felt that, subject to these linkage improvements, the store should form part of the defined frontages. We therefore support the provision at paragraph 7.26 to carry out annual reviews of the defined frontages. Jobs- Purley Inadequacy of A23 through Purley as an The aim to establish Croydon Mr Barry Atwood artery to the Gatwick diamond 18. Paras as the premier business Resident 7.46 - 7.47 : Unless some radical solution is location in south London and Observation found to enable heavy through traffic toflow the Gatwick Diamond is reliant Noted along the A23 road to and from the south, it on many faxctors and not just cannot seriously be regarded as a satisfactory upon the capacity of the A23 at artery for the purpose of establishing Purley. "Croydon as the premier business location in South London and the Gatwick Diamond" (see Towards a Preferred Core Strategy for Croydon Spatial Objective 1).  A23 through Purley inhibiting commercial development. Jobs- Purley Page 67: Jobs-Purley 7.25 The present This is an interesting point and Mr I.G.M. Hunter 7.25 position and accessibility of the TESCO store one that has not been Resident means that it does not cast too great a previously considered. Whilst it Observation shadow over the rest of the smaller retail seems likely that improving Noted – To be Reviewed businesses in the Town centre - an advantage accessibility to the Tesco store in a "sustainable community" example. would benefit both the store Making the store more accessible is bound to itself and the other retailers in affect adversely the future of smaller stores Purley, the potential disbenefits with resulting job losses and diminution of of doing so will also be consumer choice. considered ahead of the next iteration of the Core Strategy. Jobs- Purley While the severe congestion continues at The Council acknowledges this Mr Barry Atwood Purley Cross Gyratory, strategic road access issue and proposes a range of Resident is scarcely "very good or good" for employers short-term measures such as Observation needing to transport materials in and products promoting greater use of more Noted out sustainable modes of travel as well as the possibility of a consolidatiion centre to reduce the amount of heavy vehicle movements. However, in the medium-term the priority remains to improve the Purley Cross Gyratory. Overview At present there is a large number and range Comment is noted. Mr Charles King 7.2 of individual shop units and a small East Coulsdon supermarket and some convenience stores in Residents' Association the town centre and a number of medium and Observation larger sized car dealerships in the centre and Noted just outside the town centre. These do not attract local residents or residents from adjacent catchment areas to the town centre for their weekly shop . Our own research show less than 50% of local residents do their main weekly shop in Coulsdon and the reason given is there is not one of the big four national supermarkets in the town where you can do your weekly shop.  Therefore the town centre must become more attractive to residents and have a better retail mix and this must include one of the four major supermarkets in the town centre and not in a peripheral location such as Lion Green car park where it would detract from the town centre retail experience. We were extremely disappointed that Sainsbury's decided to withdraw from constructing a new store in the centre of the town. We are strongly of the view that the council should do all it can in their power to encourage Sainsbury's back to the town Overview Keep Purley Swimming Pool The valuable role of Purley Pool RMT Phillips in providing swimming facilities Croydon Mobility Forum and a learning environment for Selsdon Purley and adjoining areas is Observation understood. The pool needs Noted refurbishment or in the medium term replacement. The pool is to be refurbished in the short term with commitment from the council to keep it open until 2014.

Proposals to meet the needs of the borough, improve the quality in provision, and meet unmet and future demand have arisen from an analysis of both need and the opportunity to develop provision to cater for the unmet demand in the south of the borough.

The Core Strategy will not include policies for site specific facilities unless there are strategic implications. The Core Strategy will set out general policies related to co-located community facilities (including swimming pools and leisure centres). Site specific policies or detailed community facilities policies shall be dealt with by the Site Allocations DPD and Development Management DPD. Overview Purley LFB intends to redevelop the Brighton The council will engage with the London Fire and Road fire station in Purley to ensure that the LFB over the provision of new Emergency Planning 7.2 station is able to provide an adequate service infrastructure. London Fire and and improve the existing facilities for the local Emergency Planning community in the future. This is being Authority undertaken as part of a PFI project to deliver 9 Observation new fire stations. To ensure its service Noted – To be Reviewed delivery is maintained for the Borough, LFB are seeking to acquire a temporary site during the period of redeveloping the Purley site, and would be keen to enter into discussions with the Council for a suitable location with good access to main roads. South – Jobs Strategy We fully support the strategy's proposed The support is welcomed. This Revd Charles Trefusis 7.33 "Innovation Complex" comment is responded to in Purley & Kenley comment ID 050 Neighbourhood Partnership Support Agree - No Change South – Jobs Strategy Coulsdon is the first part of the London Work is just beginning on a Mr Charles King 7.30 Borough of Croydon that people pass through Masterplan and development East Coulsdon or by after leaving the Motorway or travelling brief for Coulsdon/Cane Hill Residents' Association on the Brighton railway line. It has an which takes a much wider Observation important role to play as the gateway to perspective than simply Noted Croydon and should be recognised as such. It considering Cane Hill/Lion should be clearly recognised as a district Green Rd car park which was centre and town in its own right and be previously the case. The considered as a whole. This must include the Council agrees that proposed town centre, Cane Hill, the industrial estates, homes growth in the Coulsdon all the residential areas of East and West Place offers the possibility to Coulsdon that have a CR5 post code and the improve the local economy. recreational areas of Coulsdon Common, Coulsdon Court, Farthing Downs and Happy Valley.  Coulsdon has lacked investment and has been in gradual and continuous decline as an economic and employment centre for over twenty years since the closure of Cane Hill Hospital at the Southern end of the town and Netherne hospital in Coulsdon, but just over the border in Surrey. The existing mix of housing does not support a proper mix of the population. This is borne out by the majority of the population which is now above the age of 50. As a result they are less likely to spend money in the town centre adding to the problems of economic viability South – Jobs Strategy  Purley could be as rich and pleasant a Comment is noted Paul Thompson place to shop as Banstead. Unfortunately through consistently misguided planning ideas Observation Purley is a mess in which everybody loses. Noted Let's hope something changes and a GLOBAL strategy is employed for the future. South – Transport Strategy Paragraph 7.51 - Extending Tramlink services The long term options for Mr John Phillips 7.51 towards Purley and Coulsdon is supported by tramlink to Purley and Coulsdon Tandridge District the Council as such extensions could benefit will be further explored with TfL. Council residents living in the more western parts of Observation Tandridge District Noted – To be Reviewed South – Transport Strategy In general, would like to see more action & Comment is noted Lisa Downham 7.49 less talk. Parking in Purley (pg. 70-71) We do Get Fired/Purley not wish to see a decrease in our parking Business Assoc. facilities - they should be increased if Purley is Observation to grow. Changing peoples behaviour by Noted taking away parking is not an appropriate solution here. By all mean provide clean, safe and well run alternatives - but leave our parking spaces alone or add more. South – Transport Strategy Transport: Purley: incredible inadequacy of Comment is noted. Mr Barry Atwood proposals for Purley Cross Gyratory 16. Paras Resident 7.49 -7.51: We have already referred above to Observation the long term failure of public authorities to Noted deal with the severe traffic problems at Purley Cross Gyratory. Given the serious and increasing traffic problems at Purley Cross, it is beyond belief that the only remedial measure proposed by the Supplemental Report in the Short Term (2012/2017) is a review of local car parking provision! It is wholly unacceptable that no improvements are contemplated prior to the Medium Term (2017/2022). Even then so-called "enhancements" and, for the Long Term (2022/2031), a vague reference to "improving the A23" would be risible were the situation not so dire. South – Transport Strategy With reference to the Croydon Core Strategy The comment is noted. Parking Mr Gary Varndell 7.48 and in particular to the strategy involving provision for specific sites or Square Foot Design Ltd Purely I would like to state categorically that masterplans will be subject to Objection for Purley to continue to act as a busy and separate consultations, Noted vital hub for the rest of the borough and whereas the Core Strategy will London it is essential that a multi-storey car set out the boroughs strategic park is maintained near the train station. Also, direction. Detailed parking in order that Purley itself has any future as a policies shall be dealt with in the town or transportation hub it is essential that Site Allocations and the road crossing at Purley Cross is simplified Development Management by removing the gyratory that is slowly DPDs. It is recognised in the destroying the town. I believe that recent Supplement that resolving studies by your own external consultants have pedestrian and cycle severance proved that reverting to a simple cross-road issues at the Purley Cross would work if sufficient funds were made gyratory will require more available. fundamental work in the medium to long term. The startegy also includes the prioritisation of improvement to the A23 with enhancements made to the Purley Cross gyratory. The Council will work with partners such as TfL to ensure improvements are programmed and implemented to compliment the Councils priorities for other parts of the road network. South – Transport Strategy Section 7: South - Transport Strategy The comment is noted. Mr Michael Mulhern 7.49 Greater London Authority TfL supports proposals under paragraph 7.49 Observation to promote a construction consolidation centre Noted in Coulsdon / Purley and to carry out a review of parking with the aim of decreasing congestion on the A23. Consideration of the land uses designation and their anticipated trip generation should also be given for new development sites along the corridor. Transport- Purley Yet the Council is continuing to aggravate the The delivery of a cycle hub Mr Barry Atwood problem by permitting replacement of Plough within Purley District Centre is Resident Lane houses with blocks of flats. Small part of a wider aspiration to Observation wonder then that residents use their cars. The reduce reliance on private cars Noted problem is often not, as para 7.46 suggests, (particularly for shorter "due to the topography" of the district, but journeys) as a means to reduce because residents simply feel unsafe on foot. pressure on the road network  Probable failure of a Purley cycle hub 24. alongside a range of other para 7.49: By the same token, "a cycle hub measures. within Purley District Centre", while an estimable objective in itself, is almost certainly doomed to failure while the internal combustion engine takes such priority on Purley roads. Planners will note that the cycle track down Foxley Lane (A2022) is always blocked by stationary cars which have nowhere else to park. It would certainly be wholly unsafe to expect pedestrians to share the pavements with cyclists. Transport- Purley "A cycle hub within Purley District Centre" is The delivery of a cycle hub Mr Barry Atwood almost certainly doomed to failure while the within Purley District Centre is Resident internal combustion engine takes such priority part of a wider aspiration to Observation on Purley roads. reduce reliance on private cars Noted (particularly for shorter journeys) as a means to reduce pressure on the road network alongside a range of other measures. Transport- Purley Moreover, Purley will not thrive as a The Council agrees that the Mr Barry Atwood commercial centre while the experience for pedestrain/cycling environment Resident pedestrian shoppers is generally so in and around Purley needs to Observation disagreeable. A recent non resident's view of be improved and will continue to Noted Purley [3] refers to the "joyless concrete pursue this aim through the gyratory", "the treacherous one way system" Core Strategy and subsequent and expresses the view that "It's no fun for Development Plan Documents. pedestrians round here, nor indeed up much of the rest of the road". Difficulties for West Purley pedestrians going to Purley centre 20. Getting to the shops, post office, railway station etc. from where we live in West Purley (Box Ridge Avenue) is particularly trying due to the increasing difficulties of crossing A23, A22 and A235. This can be an intimidating experience especially for older people such as ourselves.  21. At 8.45am on Wednesday 6 October 2010 we were using the A23 pedestrian crossing immediately to the south of the Purley Cross roundabout in order to reach the shops. The lights were in our favour and cars in the two near side lanes had already stopped. As we stepped out from the pavement two cars coming from the south in the third lane making for A235 drove through the red lights at speed. Fortunately for us we had not yet got to that point of the crossing. And this is not an isolated incident. Particularly in early morning and late at night, accidents have been caused as a result of the tendency of A23 traffic from both directions to shoot the lights. The experience of crossing to Purley centre is such that at least one elderly lady, who lives in Purley Knoll, is accustomed to catch a bus on the south side of the junction and get a taxi back.  The interests of elderly West Purley residents have been disregarded 22. On the evidence of the table on page 66 of the Infrastructure Delivery Plan - Purley has above average numbers of older residents. Yet the continuing failure to bring forward any plan to assist pedestrians in negotiating the Purley Cross Gyratory coupled with the proposal to convert a major proportion of Purley's housing stock into flats suggest that the interests of long term older residents, such as ourselves, have been written off.  Traffic dangers for West Purley pedestrians going to Woodcote Medical Practice 23. Paras 7.46 - 7.47 : The dangers for pedestrians are even greater where the traffic is rushing to or from the junction. Para 7.46 of the Supplemental Report acknowledges that "some north - south roads through residential areas are used as alternatives to avoid delays when Brighton Road is congested". This is an understatement. As we are only too aware when walking regularly from home to our doctors' surgery (the Woodcote Medical Practice) - Woodcote Valley Road, Foxley Lane (A2022) and Plough Lane are now used throughout the day by heavy lorries and commercial traffic. There is no pedestrian refuge to protect those crossing Foxley Lane to the surgery, while Plough Lane with its bend, restricted width and very narrow pavements is particularly hazardous for the elderly, those with young children and others on foot. Unless something is done here to calm vehicular use and to protect pedestrians it will not be long before there is a serious accident. Transport- Purley There is no pedestrian refuge to protect those, Comment is noted Mr Barry Atwood such as ourselves, crossing Foxley Lane to Resident the Woodcote Medical Practice surgery, and Observation Plough Lane with its bend, restricted width Noted and very narrow pavements is particularly hazardous for the elderly, those with young children and others on foot. Unless something is done here to calm vehicular use and to protect pedestrians it will not be long before there is a serious accident. Yet the Council is continuing to aggravate the problem by permitting replacement of Plough Lane houses with blocks of flats. In consequence, residents use their cars because they feel unsafe on foot. Transport- Purley Purley Swimming Pool must be retained for The valuable role of Purley Pool Mrs Valerie Hunter the following reasons: Swimming is not only a in providing swimming facilities Resident healthy exercise, but a life saver! Used by and a learning environment for Observation babies, toddlers, older children, teenagers Purley and adjoining areas is Noted regularly especially during the school understood. The pool needs holidays. The pool is also used by elderly and refurbishment or in the medium disabled people, and those recovering from term replacement. The pool is accidents- swimming is an acticity for all. to be refurbished in the short Buses go directly to Purley from ALL term with commitment from the directions - South Croydon, Sanderstead, council to keep it open until Woodcote, Kenley, Waddon, Coulsdon, as 2014. well as Purley itself. The suggested replacement pool in Coulsdon would require 2 Proposals to meet the needs of buses for many of the above and more petrol the borough, improve the quality and driver time would be taken up. Parents in provision, and meet unmet would not be happy about their children and future demand have arisen travelling a much longer journey especially if it from an analysis of both need involves TWO buses. and the opportunity to develop provision to cater for the unmet demand in the south of the borough.

The Core Strategy will not include policies for site specific facilities unless there are strategic implications. The Core Strategy will set out general policies related to co-located community facilities (including swimming pools and leisure centres). Site specific policies or detailed community facilities policies shall be dealt with by the Site Allocations DPD and Development Management DPD. Transport- Purley 1) ANGER AND ACCIDENTS!! Diabolical lane- The comment is noted. Whilst Paul Thompson 7.45 swapping chicane layout the town centre is full the Core Strategy cannot of angry motorists. Minutes standing on the address some of the Observation corler of Russell Hill by Pizza Express will suggestions above the council Noted attest to this. Coming the other way past the will continue to work with Tesco entrance things are no better with a Transport for London to improve crazy curved island forcing cars to cut across transport in the borough. lanes. Redesign of the road system is badly needed, but as a start large 'GET IN LANE NOW' followed by SOLID white lane lines accompanied by 'NO LANE CHANGING' signs need to be put in at the Godstone Rd and Russell Hill. Also traffic heading south on Brighton Rd coming through the RH Rd lights especially busses consistently jump the lights thereby blocking the main flow of Purley Way traffic making navigation virtually impossible. Transport- Purley Keeping a car park of substantial size is Detailed car parking policies will Mrs Valerie Hunter 7.47 essential to keep Purley shops alive. There be addressed through the Resident are only a limited number of on-street parking forthcoming Development Observation places, and it would be very annoying to drive Management and Site Noted to Purley for shopping (other than Tesco's) or Allocations Development Plan for other purposes, to find these full, and a Documents. reduced car park full also. Many people do not live near a bus stop, and those who continually advocate using public transport do not have mobility problems, or several small children and buggies which they have to manage in rain and cold weather. Transport- Purley Getting to the shops, post office, railway The aim to improve pedestrian Mr Barry Atwood station etc. from West Purley is particularly movement in and around Purley Resident trying due to the increasing difficulties of remains in the Core Strategy. Observation crossing A23, A22 and A235. The continuing Noted failure to bring forward any plan to assist pedestrians in negotiating the Purley Cross Gyratory coupled with the proposal to convert a major proportion of Purley's housing stock into flats suggest that the interests of the substantial number of long term older residents, such as ourselves, have been written off. Transport- Purley Secondly, the current car park adjacent to the The comment is noted. Parking Mr Peter V Gee 7.45 station is a major facility. Many times I have provision for specific sites or had to go to the roof to find a space, but it is masterplans will be subject to Observation normal that there is a vacant parking lot. Any separate consultations, Noted reduction in this space would be a a serious whereas the Core Strategy will loss to the many Purley residents who find it set out the boroughs strategic convenient, especially can I also add senior direction. Detailed parking citizens who find the train service up to policies shall be dealt with in the London ideal to attend many ofthe cultural Site Allocations and attractionsavailable. Purley is a great place for Development Management families and older people. The proposed re- DPDs. building of the Purley Hospital is an example of how PFI type projects seem to be out of favour. Even with the multi-storey car park not faraway, the developers complained insufficient parking was their reason for pulling out of deal.I appreciate that this was entirely a Health Authority issue, butI think that within the Core Strategy the failure to develope the proposed doubling of clinical services should also be addressed. Again, from children to pensioners there is a huge clientele. Loss of the pool and the car park would inflict a significant reduction in the attraction of Purley as ideal location for living, covering single persons, couples, smaller families, larger families, and senior citizens. Transport- Purley -The transport strategy does not identify the As the consultee notes the M Kruppa 7.49 serious overcrowding on the rail network and requirement for longer trains is Resident it's causes. Purley station is probably the noted in para.5.4 of the IDP. Observation second busiest station in the borough. Rail The Council will lobby for longer Noted transport is vital for Purley and it's trains as part of the Thameslink neighbourhood. People frequently have to system but the short term travel in overcrowded trains where there is implementation of longer trains standing room only. One of the reasons for is not feasible because approval this is that the trains are too short to cope with for their purchase has only just the demand. Many years ago the platforms been given by Government and were lengthened to take 12 coach trains, but there are constraints with we seldom have such trains. Considering the platform lengths at other cost of the rail infrastructure - tracks, stations. signalling and stations - and their maintenance, it does not make sense to run short trains when there is a demand for longer ones. Short trains may improve the rail operator's balance sheet but undermines the fundamental principle to make the best use of the extensive railway system. People should be encouraged to change from car to rail travel, but it is not going to happen with overcrowded trains. The 'Infrastructure Delivery Plan', paragraph 5.4, suggests the provision of longer trains only in the medium term, years 6 - 10. Why only then? They are needed now and this should be the top priority. The Council should do everything possible to persuade the train operators to operate longer trains to ensure that people can travel in comfort. In order to improve accessibility and rail service destinations from Purley, some of the Thameslink trains, operated by First Capital Connect, should stop at Purley. I am certain the demand is there and it should be met. Transport- Purley Transport for London's apparent contempt for The Council does not have a Mr Barry Atwood Purley 17. The apparent contempt with which definitive proposal for Purley Resident Purley is treated by Transport for London is Cross Gyratory and will Observation well demonstrated by the fact that this District continue to work with TfL on this Noted centre - unlike Coulsdon and Purley's minor matter. constituent part, Woodcote - has not even been permitted signs on the main roads identifying its presence. It is understood that the control of this arterial route is not within the control of the Borough Council. It should, however, be doing its utmost to press for a solution that will improve matters not only for through traffic, but also for its long suffering Council Tax payers. If a by-pass is not possible, what does the Council propose instead? Transport- Purley From Inglewood need a new pathway to Comment is noted RMT Phillips Figure 6.4 Selsdon Park Road Croydon Mobility Forum Selsdon Observation Noted Transport- Purley Given the severe traffic problems at Purley Comment is noted. The Council Mr Barry Atwood Cross Gyratory, the "improvements" proposed will continue to work with TfL to Resident in the Short, Medium and Long Term are promote improvements to Observation unbelievably inadequate. Purley has not even Purley Cross Gyratory. Noted been permitted signs on the main roads identifying its presence. The Borough should be doing its utmost to press for a solution that will improve matters not only for through traffic, but also for its Council Tax payers. If a by-pass is not possible, what does the Council propose instead? Transport- Where are we Section 7: Transport - Coulsdon The comment is noted. Mr Michael Mulhern now? Transport- Coulsdon 7.44 Paragraph 7.44 sets out a strong dependency Greater London Authority on car trips to access local facilities, the Observation Council may also wish to note there are some Noted park and ride activities for Coulsdon South station (using the Lion Green car park and the nearby industrial estates). Transport- Where are we Today Coulsdon generally has good transport The comment is noted. The Mr Charles King now? Transport- Coulsdon links with the main A23 trunk road linking viability and technical 7.43 directly to the M23 and M25 motorways and assessments for potential East Coulsdon Gatwick. However, the A23 still suffers severe tramlink extensions will be Residents' Association congestion all week. Coulsdon is now tested by TfL as part of the Observation fortunate that this traffic is now diverted away strategic assessment of tramlink Noted for the town centre by the bypass. While the extensions. The final policy Brighton and Tattenham Corner train lines wording shall be informed by also link directly to Croydon, Central London, discussions with TfL and other Gatwick Airport, Redhill and Brighton. On specific consultees in order to Public transport there is a very good train ensure the Core Strategy is service on Monday to Saturday in both the flexible and deliverable. Parking peak and off-peak at both Coulsdon South provision for specific sites or and Smitham (to be renamed Coulsdon Town masterplans will be subject to in 2011) stations. However, the Sunday separate consultations, service at both stations is still poor and at whereas the Core Strategy will Coulsdon South is only hourly and does not set out the boroughs strategic reflect the service level needed to meet direction. Transport will be demand and potential demand compared to addressed more fully in the other stations in the borough or surrounding Infrastructure Delivery Plan. Car area. In fact usage at Coulsdon South is in the parking standards will be top 12% stations in the whole country with considered in more detail by the around 1.5million journeys per year. Today Development Management Coulsdon has a very good bus services Development Plan Document. supplied by TfL with four trunk routes 60, 166, 405 & 466 linking central Croydon three local routes 404, 434 & 463 providing local connecting services to the stations and town centre and there is an all night service N68 linking Central London and Croydon providing a 24hr service in conjunction with route 60. There is still room for some improvements , route 404 only runs hourly and along with route 434 do not run on Sundays and there are needs for improved links to parts of Old Coulsdon such as the Tollers Lane estate across the border to Caterham Valley and Netherne Village in Surrey. In the longer term with the development of Cane Hill consideration should given to extending Tramlink to Coulsdon to replace some of bus routes . There also needs to be adequate and a fair car parking regime in the centre and at stations for shopper, businesses, commuters and leisure users. There also needs to be adequate loading and unloading facilities to reflect the needs of businesses and shops. There is scope to increase the parking at Coulsdon South station and the council should encourage both Network rail and Southern improve these facilities there. Transport- Where are we Transport Generally transport is good The comment is noted. Whilst Mr Charles King now? Transport- Coulsdon however, Sunday trains to Coulsdon Sth not bus and train services have 7.43 so good Bus services on Sunday- some don't been considered by the East Coulsdon run Cane Hill needs to be on the bus route- Borough Wide Transport Residents' Association needs to be designed to be bus friendly. Strategy and the Sub Regional Observation Transport Plan - South. It is Noted unlikely that the Core Strategy will address these issues directly through policies. 9.0 Glossary Section Representation Recommended Response Full Name Paragraph Organisation Nature of Response Officer Recommendation

Chapter 9. Glossary - There is no definition of As per recommmendation Metropolitan Police community facilities within the glossary of the Authority Supplement or within the previous 'Towards a Metropolitan Police Preferred Core Strategy' document. In order Authority to ensure consistency with the London Plan, Objection particularly policy 3A.18, it is essential to Agree – Propose Changes ensure that policing facilities be included within a definition community facilities. Recommendation: the MPA/MPS recommend that the Core Strategy glossary be amended to outline a list of community facilities to include 'Policing'. 9.0 Glossary The supplement has a glossary, but other The Council will add a reference Mr Carl Roche literature does not appear to - eg. see to CMC to the Glossary and summary CS P29 where there are many check to see if there are other Objection initials but no obvious point of reference. abbreviations/terms that need to Noted – To be Reviewed be included. No Specific Chapter Section Representation Recommended Response Full Name Paragraph Organisation Nature of Response Officer Recommendation General Comments The comment is noted. The Mr Michael Mulhern council will continue to work Greater London Authority TfL welcomes the general thrust of the closely with TfL on proposed Observation document and notes that the Council transport improvements. Noted – To be Reviewed recognises that Croydon's growth agenda requires substantial attention to transport infrastructure, services and operations to enable sustainable implementation.

The documents (the Core Strategy Supplement, the Masterplans and the Infrastructure Delivery Plan) appear to draw heavily upon the two draft transport strategies covering the whole borough and the Croydon Metropolitan Centre respectively. They were developed by PBA for Croydon. In both cases TfL has made substantial comments about the drafts and await updated versions plus supporting evidence. Their status as supporting documents has not as yet been agreed with TfL and as such TfL expects to review further versions and outputs from these documents. Where necessary such consultation will possibly lead to revisions to the Core Strategy and Infrastructure Delivery Plan.

TfL notes that very little reference has been made within the above documents to the work carried out with the GLA family (core GLA, LDA and TfL) to produce an OAPF for the town centre. This work is due for completion in September 2011. It should provide a more detailed, agreed and holistic view of the town centre issues and necessary actions to address them. TfL suggests the Borough should refer to the emerging work in future versions of the Core Strategy if timelines permit.

In addition, the Council may wish to consider how the Mid Croydon and College Green work may be able to be integrated into the Borough's LDF documentation.

Finally, in regards to the economic and commercial viability and availability of funding for schemes, TfL will continue to feed into the Councils work to notify as to the levels of funding available for the development of CSR and other transport related schemes/infrastructure. I am very keen to have a swimming pool in The valuable role of Purley Pool Margaret Mowll Purley. I have used the pool for a long time in providing swimming facilities and as I am 75 I still need a facility. I am also and a learning environment for Objection keen to have a car park in Purley so that I can Purley and adjoining areas is Noted easily get to the hospital and optician and the understood. The pool needs URC church when their car park is full. refurbishment or in the medium term replacement. The pool is to be refurbished in the short term with commitment from the council to keep it open until 2014.

Proposals to meet the needs of the borough, improve the quality in provision, and meet unmet and future demand have arisen from an analysis of both need and the opportunity to develop provision to cater for the unmet demand in the south of the borough.

The Core Strategy will not include policies for site specific facilities unless there are strategic implications. The Core Strategy will set out general policies related to co-located community facilities (including swimming pools and leisure centres). Site specific policies or detailed community facilities policies shall be dealt with by the Site Allocations DPD and Development Management DPD. Detailed car parking policies will be addressed through the forthcoming Development Management and Site Allocations Development Plan Documents. Coulsdon with its extensive green belt areas Comment is noted. The value of Mr Charles King of Coulsdon Common, Coulsdon Court, greenspaces and the Green East Coulsdon Farthing Downs, Happy Valley and Cane Hill Belt across the borough is Residents' Association which provide excellent outdoor leisure areas recognised in the draft Core Observation both for people and wildlife not only of Strategy as areas to be Agree - No Change Coulsdon or the borough of Croydon, but for protected and enhanced. This London as well. Coulsdon South station is the applies to the London Loop, one most southern point on the London Loop of the borough's strategic offering good public transport access for access and movement routes. ramblers and walkers to the east and west Work is just beginning on a sections of the London loop and this should Masterplan and development be promoted more. It is important that these brief for Coulsdon/Cane Hill areas are protected and kept in their natural which will be informed by the condition and support should be given to the emerging Core Strategy. It is Corporation of London and Croydon Parks expected to consider the department to continue to provide active connectivity of the site to nearby management of these areas. Any open spaces and opportunities development on Cane Hill should also provide for different users. new opportunities for walking, rambling, cycling and horse riding in the green belt areas. The general comment is that, by and large, Comment is noted. Mr Roger Hill the proposals are still too statistic oriented and Selsdon Residents not sufficiently location explicit to enable Association critical comment. The underlying problem, of Observation course, is the usual one, unless building a Noted New Town, of financial availability and developer profit. There needs to be a clearer investment strategy. Once the Site Allocations Development Plan Document is produced, more cogent comments, of a general nature, might become possible. The general tenor of the document is positive but hopeful rather than determined. We still wait and see Transport and car parking: Only mentioned in Transport infrastructure will be Revd Charles Trefusis passing on pages 44 & 71. The Green addressed more fully in the Purley & Kenley Transport Plan and expectations are Infrastructure Delivery Plan. Neighbourhood unrealistic with regard to Purley . Whilst we all Parking will be dealt with in the Partnership endorsed the need to get people 'out of their Development Management Objection cars': i. The geography of Purley with hills, Development Plan Document. Disagree – No Change and the fact that most public transport is limited to the main roads, means that to get for example to the station (and use public transport from there on), there needs to be appropriate and indeed increased car park capacity in the town centre . If car parking is reduced, more people will travel to Banstead where parking is free - see point above about our vision for 20 years time. ii. Buses do not go on the right routes, up the right hills or to the right destinations (e.g. to the station or the hospital). Residents are not prepared to walk up long and steep hills back to there home. Cycling is in many cases not an option. iii. Transport demands greater thought (including the removal of bus lanes) to ease the through the Purley area. iv. The A235 is not wide enough to accommodate all the traffic and a Tramlink route. v. Car parking is omitted from the Infrastructure Delivery Plan - see above These all need to be incorporated into the Core Strategy and Infrastructure Delivery Plan. That Purley should receive the necessary The comment is noted. Revd Charles Trefusis investment. Purley & Kenley Neighbourhood Partnership Observation Noted Conclusions The comment is noted. Mr Michael Mulhern Greater London Authority 54 The general thrust of the plan is supported, Observation in particular the identification of four Noted management areas that relate to a series of underlying connected places give the plan a clear spatial feel. The process of setting out appropriate development potential and housing figures for each of the management areas and sub places based on local evidence provides clarity. 55 Proposals for the Croydon Town Centre Opportunity Area are fully supported by the Mayor and the continued working between the Croydon Council, the GLA, TfL and the LDA will help set out the detail for the future growth of this key area within Croydon. 56 From this Preferred Options report (2b) there are still areas where further detail is still required to ensure the submission of comprehensive Core Strategy DPD, including; housing, transport and employment and further discussion on these would be welcomed. Minor comments The comment is noted. Mr Michael Mulhern Greater London Authority 53 Within each of the management areas pie Observation charts are used to set out the required mix of Noted – To be Reviewed units within each area and ‘Place'. The use of a pie chart may lead to confusion, and to avoid this, the Core Strategy may benefit from using numbers. Green belt and MOL The comment is noted. Mr Michael Mulhern Greater London Authority 36 Since the previous Core Strategy Preferred Observation Options (2a) report the Council has now Noted clarified that it will not be reviewing its Green Belt or Metropolitan Open Land designations, which is acceptable. Within each of the management areas, Metropolitan Open Land and Green Belt locations are identified, which is welcomed. We would ask that the 20 year strategy is The adoption of the Core Revd Charles Trefusis supplement by a 5 year development plan. Strategy will be followed closely Purley & Kenley Key elements of this 5 year plan should by a Site Allocation DPD which Neighbourhood include the development of the Kenley will provided more detailed Partnership Memorial Hall as a true community centre, development proposals for Observation improved train and bus services, the creation individual sites. Noted of more conservation areas and LASCs, flood prevention measures and the enhancement of Kenley Airfield as a historical and environmental showpiece. We have communicated our detailed suggestions for a 5 year plan to our ward councillors. 41 The proposed area based approach is The format of the Core Strategy Mr Michael Mulhern supported. Detailed character appraisals for will be reviewed. Greater London Authority each ‘Place' have been prepared as evidence, Observation which identify opportunities and constraints Noted – To be Reviewed and provide further explanation as to the character of each area. 42 However, this approach does lead to some repetition within each of the management areas, for example, the Homes section in each management area begins with a repeated explanation as to the methodology used to determine the housing figures for each area, which could be removed. Flood risk The IDP will identify the need Mr Michael Mulhern for infrastructure development Greater London Authority 37 In line with London Plan policy 4A.12, the in the borough. Both the Site Objection Core Strategy notes that there is significant Allocations and the Agree – Propose Changes sewer, ground water and fluvial flooding Development Management issues across the borough. However, in line DPDs will address flooding with London Plan 4A.13 and 4A.14 it is issues, in addition to the recommended that the Core Strategy should strategic policies set out in the set out clearer mitigation measures to address Core Strategy. these flooding concerns, or identify what DPD would provide further detail on this issue. Feedback on the strategy outside Kenley: We The 16 Places and 4 Spatial Revd Charles Trefusis agree completely with the strategy that the Management Areas selected to Purley & Kenley semi-rural character of Kenley should be reflect areas of common Neighbourhood preserved and that any future level of new attributes for which broadly Partnership house building should be very restricted. similar spatial planning Objection However, the strategy includes Kenley with approaches are appropriate. Disagree – No Change Old Coulsdon. This is inappropriate as the Whilst the 16 Places remain in reality is that Kenley residents have very the Core Strategy, feedback on limited contact with Old Coulsdon due to its the concept of Spatial restricted shopping offer and the lack of public Management Areas suggests it transport links. will not feature in the next iteration of the Core Strategy. 10. District centres- The great majority of The comment is noted. neighbourhood Croydon residents live outside the City Core Partnerships Chairs & and hence place great store on having vibrant VCs district centres. Unfortunately, many of the neighbourhood borough's district centres have been in a state Partnerships Chairs & of slow decay for the last two decades. The VCs traditional "parade of shops" (incorporating a Observation butcher, greengrocer and post office as Noted "anchors") that worked so well up to the 1960s is a model that is now in deep trouble. But what has emerged in many of Croydon's district centres as a replacement is unattractive - we now have the domination of charity shops, estate agents and pubs. In many district centres, traffic management, pavement design and street furniture have had very little investment in years. The key is to achieve a balanced development of the City Core and the district centres. Historically, the perception of many residents was that the district centres were starved of investment in favour of the City Core. We believe that what makes a district centre work in the 21st century is very different to even just 20 years ago. A key observation is that it is now usually vital for a district centre to have a reasonably sized supermarket - otherwise residents in its catchment area tend to completely ignore it. However, each of the borough's district centres needs an individually tailored plan that addresses its specific circumstances and needs - any attempt at a generic solution will fail. We believe that for many of the borough's district centres, the way forward is leisure and dining. The revival of Crystal Palace's district centre could be a model for the borough's other district centres. We note with regret the very recent decision to reduce the number of district centre managers. We would highlight this action as being one of the "disconnects" that ordinary residents focus on between the Strategy's ambitious aspirations and what's actually happening in practice. This particular action demonstrates why the Strategy needs to be honest and realistic - otherwise it will lose all credibility with Croydon's residents. Our final response will include our detailed proposals for the revival of the district centres. Croydon Council's Core Strategy Preferred The support is welcomed. Mr Michael Mulhern Options report (2b) was reviewed by the Greater London Authority Mayor today. He has acknowledged that Observation significant work has been carried out since the Noted previous report and that the Council is still working up further detail for the Core Strategy and also for the CMC Opportunity Area, however, there are some areas that still require further work and discussion, in particular around housing and transport (based on report 2b). Add remaining content of letter from Limehouse here.. Town & Country Planning Act 1990 (as amended); Greater London Authority Act 1999; Planning and Compulsory Purchase Act 2004, Planning and Compulsory Purchase Act 2004, Town and Country Planning (Local Development) (England) Regulations 2004

Recommendation

That the Mayor agrees that the comments set out in this report and attached as appendices be submitted to Croydon Council as the GLA response to the Core Strategy Preferred Options report 2b consultation.

Purpose

1 To assist the Mayor in making his representations to Croydon Council's consultation on the Preferred Options report (2b) for the Core Strategy Development Plan Documents (DPDs), which form part of Croydon's Local Development Framework. 2 The Mayor of London's comments on this document will be made available on the GLA website www.london.gov.uk. Background

3 The Planning and Compulsory Purchase Act 2004 ("the Act") introduced a new system of preparing development plans. This requires Boroughs to progressively replace existing Unitary Development Plans with a portfolio of Local Development Documents (LDDs) that will collectively form the Local Development Framework (LDF) for each of the Boroughs. The LDF together with the London Plan provides the essential framework for planning at the Borough level. The "development plan" in London for the purposes of section 38(6) of the Act is: The London Plan (Regional Spatial Strategy), and DPDs produced by the Boroughs (and saved UDP policies in transitional period). 4 There are two types of Local Development Documents: firstly, Development Plan Documents, those spatial planning documents that are subject to a statutory adoption process and Examinations and have development plan status. Examples of DPDs include Core Strategies, Site Allocations, Proposals Map and Development Control Policies, and Area Action Plans. 5 Secondly, there are Supplementary Planning Documents. These provide supplementary guidance on policies and proposals in DPDs. They do not form part of the development plan and are not subject to Examinations. 6 Croydon's Local Development Scheme identifies five DPDs that will be produced; Core Strategy, Proposals Map, South London Joint Waste Management, Site Allocations and Development Management Policies. In addition, a number of Supplementary Planning Documents are proposed covering a range of topics. The Mayor's role

7 All LDDs must be in general conformity with the London Plan, in accordance with Section 24(1)(b) of the Act. This requirement is also a key test of the soundness of the plan. The Mayor welcomes early engagement with boroughs as LDDs progress through production stages and will formally issue his opinion on general conformity at the submission stage in line with Regulation 30(1) of the Town and Country Planning (Local Development) (England) Regulations 2004 ("the Regulations") and Section 24(4)(a) of the Act. 8 Regulation 26 of the Regulations requires consultation at the Preferred Options stage of LDD production. The Mayoral representations made to Croydon Council at this stage will not go forward to the Examination. It is envisaged that the Borough Council and GLA officers will meet to take forward the issues raised by the Mayor before the next formal consultation stage, so that general conformity with the London Plan can be achieved and the DPDs are sound before the Examination commences. General 9 On 3 September 2010 Croydon Council consulted the Mayor on an updated Core Strategy Preferred Options report (2b). This updated Preferred Options (2b) report provides more detail on; the four management areas, homes, jobs, transport and culture, which was not previously included in the earlier Preferred Options (2a) report. As such, the comments in this Mayor's report should be read in conjunction with the comments set out in the previous Mayors report from 26 March 2010. CMC and Environs – At the present time all bus services come The comment refers to a Mr Fred Kille Transport Strategy along London Road to West Croydon Station detailed transport matter that is pass on and take the first left and then go up outside the scope of the Core the Road and then right into Wellesley Road. I Strategy. Strategic options for Observation notice that according to the diagrams this will bus movements in Croydon No Action – Not an LDF Iss not be possible. Is this correct? Metropolitan Centre (CMC) and the detail of bus movements are subject to ongoing review by Transport For London (TfL) and the outputs of the emerging CMC Transport Strategy and the emerging West Croydon Masterplan. No Specific Chapter Interim response of Croydon's Neighbourhood The inerim response is noted neighbourhood Partnerships' Chairs & Vice-Chairs Group and in the absence of a final Partnerships Chairs & ("CVCG") to the Core Strategy supplement response, officers are to provide VCs (the "Strategy") and the associated formal comments on this interim neighbourhood Infrastructure Delivery Plan (the "Plan"). The repsonse. The Interim Partnerships Chairs & members of the CVCG have individually response refers to an Appendix VCs reviewed the Strategy and Plan in detail. Over II as `key additional analysis Observation recent weeks, we have shared our concerns, and information requirements` Noted proposals and our analysis of the key issues that the CVGS believes crucial with each other. At our recent meeting on 14 in developing a robust strategy. th October, each of us in turn outlined what The council has developed the we saw as being the key issues. This interim Core Strategy in line with response attempts to capture our concerns PPS12` Local Spatial Planning` and to summarise our analysis of the way , and the draft Replacement forward. Although we don't unanimously agree London Plan, and has referred on every point in this interim response, as a to the necessary evidence group we can endorse this analysis as base and findings in order to highlighting the key issues that have emerged develop sound policies that will from our discussions. We believe that be justified, effective, flexible important information is missing which is and deliverable. It is not the crucial in developing a robust strategy. We intention to carry out further have detailed this missing information in evidence studies. Appendix II. Also, we believe it would be highly beneficial if our Chairman could discuss this interim response with our leading politicians and the strategy team before we finalise our analysis. Finally, we are anxious to append a detailed response for each of the "places" of Croydon, our analysis of how the district centres can be revived and our analysis of how a better level of housing and educational balance can be achieved in our final response. No Specific Chapter Comments on general concepts 1: Protecting These comments are admirable Mr Lewis White and Improving the landscape of Croydon- and noted. The draft Green landscape corridors to protect Trees along the Infrastructure Report (June Observation main road network. I am very aware that, in 2010) recognises the significant Noted addition to the street trees owned by the value of trees to the landscape Council and TFL, the trees growing on the character of the borough and frontages of private properties along the A 23 their important environmental Brighton Road and along the other main roads function and these comments of Croydon, fulfil a vital function in "Greening" will be considered in reviewing the otherwise hard appearance of the road this paper. The Council is and its corridor. Trees, as we all know, soften currently committed to the the harsh appearance of the road and paved Mayor of London’s scheme to footways, help to reduce the impact of increase tree planting and buildings, they filter the air, and provide plants a number of trees each attractive seasonal colour-much needed green year. Croydon has nearly 2,000 in Spring and Summer, yellow and red in TPOs at present, one of the autumn and bare tracery of branches in largest totals of all London winter. Evergreen like pines and Holm Oak boroughs. The trees team has provide all year foliage. They provide most of been making strides into the life in the landscape, and contribute reviewing and updating the positively to physical and mental well-being of existing orders for some years the beholder, albeit that much of the benefit is now. Unfortunately, such work not fully realised by the individual. I am has now had to cease due to acutely aware that all these trees fronting the financial constraints. main roads of Croydon borough, on private land, in front gardens and landscaped areas, The suggestions with regard to are constantly under threat of removal, and protecting significant trees, over the years I have noticed several good would be an immense quality specimens disappear, felled, for what undertaking and very costly, ever reason, and often merely to allow the both in officer time and paving over of a front garden. For this reason I administrative expense, and would suggest, if it is not already included in may not fall within the true remit the Borough LDF plan, or is not already under of the legislation. The legislation consideration, that a strategy be adopted to in respect of TPOs and trees in protect all existing significant trees along the Conservation Areas provides main roads of Croydon. For starters, please sufficient scope and powers to could you place a TPO on all the significant retain visually important trees, privately-owned trees from Coulsdon to Purley wherever they are located Cross, including the Tesco frontage, then from within the borough, so it is Purley Cross along to South Croydon, difficult to see what benefit including the Whitgift Playing fields, right in to would be gained through Croydon Town Centre. Similarly, could you adopting a specific strategy for please look at the Purley Way, from Purley to ‘main road’ trees within the LDF. the Lombard Roundabout, and TPO all the significant trees along the route, such as those at the Five ways junction (on the Homebase car park perimeter landscaped strip), and do the same from the Streatham border, South to Norbury and Thornton Heath pond, then to Broad Green, and a similar exercise for the road from Thornton Heath Pond to Lombard Roundabout, and also Mitcham road. Whitehorse Road is also a major route, down which thousands of people drive or go through by bus each day. There are very few trees along this road, and every one that does exist is very important. This would be a strategic proposal, in order to protect landscape landscape quality now, in the medium and also the long term of the corridors along all the main roads in the borough. I feel that it would be simple to implement, and it would give long-term protection to the landscape seen by 10's of thousands each day. Today's buzzword is Landscape Infrastructure-this is a proposal to Protect the trees that already make up this infrastructure. - 2: A plan to add trees in the streets and on Council-owned frontages. I know that it is very easy to ask for more tree planting, but what I wish to suggest is that the council carry out a simple survey to highlight the areas of the borough that lack significant numbers of trees, such as areas of Waddon (e.g. Waddon New Road, areas of Thornton Heath and other areas which are "deprived of trees". The residents in such areas must suffer as a result of low air quality, and low levels of amenity, as trees contribute directly to creating both cleaner air and better amenity. Property values reflect this, and health also reflects this. I would ask that you take a strategic view on planting and seek to target areas with few trees in the streets for future planting. In addition, perhaps the council could offer free trees to residents for front gardens. - 3: Retaining space for trees by respecting traditional building lines. As a general rule, areas where the building line is set back to create front gardens or landscaped frontages are much greener, more humane and "liveable" than areas where front gardens are short or non-existent. I am troubled by the current tendency for planning authorities including Croydon, to allow developments to come forward, in front of the original building line, towards the street, thus excluding or diminishing the all-important space for gardens and trees. A typical example is the Shurgard storage building in Stafford Road, Waddon. There was once a wide landscaped area here, between the previous factory and the footway. The Shurgard building was approved about 5 years ago, and built much closer, resulting in a narrow shrub strip with a few trees, but the building is massive and over-bearing. It needed to be set further back to allow tree planting with large-growing trees in keeping with the scale of the building. I am very concerned by the diminution in environmental quality that results from this squeezing process. Big buildings, very close to the street, with a tiny strip of greenery between them and the footway-this is only too familiar across London. A recent example is the former Esso garage in South Norwood hill. The new building is set close up towards the street, but the original building line is much further back, so the landscaped strip is very narrow. Whilst the building is much nicer than the Esso garage, nevertheless the abandonment of building lines is in my view a retrograde step in 9 out 10 cases. Such developments set a clear precedent which is used by the next developer to justify why their building too, should come closer to the street than the old building line, so we get intensification of development over the years on an incremental basis. Gradually, albeit over decades, the long gardens and their trees go, and the new buildings crowd in on the street. This is irrevocable change which once lost can never be re-created. I would be grateful if you would consider this point in the revision of the Local Development framework. No Specific Chapter Infrastructure Development Plan (p36). IDP Not all libraries are Although many other Branch libraries receive mentioned by name. Some are a mention, any reference to Coulsdon Library because of their unfavourable Objection is conspicuous by its absence. Consequently, location. No policy intent should Disagree – No Change readers will be drawing their own conclusions! be interpolated from a lack of specific mention No Specific Chapter We request that we be kept informed of The comment is noted. London Fire and progress with this plus further LDF Emergency Planning documents. In addition we wish to reserve our London Fire and client's position to submit further Emergency Planning representations on subsequent LDF Authority consultations. Observation Noted No Specific Chapter Options for growth: LFB note that paragraph The Council will consult with the London Fire and 5.10 identifies a need to provide LFB on the design of new Emergency Planning approximately 19,000 new homes in the developments as part of the London Fire and borough before 2031. Although the LFB have development management Emergency Planning no objection to this growth, it is important that process. The comment is noted. Authority the Council carries out suitable consultation It refers to CS2a. Observation with the LFB, along with the other emergency Noted services, for any proposed large scale developments. This is important to ensure that emergency access through new developments is carefully designed and the emergency services can monitor future growth in the borough to ensure that the service they provide is sufficient. The LFB should always be included as a statutory consultee for large scale developments within the borough. No Specific Chapter 2. General: As a Partnership we welcome the While the criticism of the Revd Charles Trefusis opportunity to be consulted and to be a part of consultation process is noted, Purley & Kenley the development of the Core Strategy for the council has conformed with Neighbourhood Croydon, and are grateful for the way that our the adopted Statement of Partnership previous comments have been taken into Community Involvement and Objection account. We would suggest that the has received a substantial Disagree – No Change consultation process has regretfully failed due number of representations. to: Lack of engagement by residents. The publicity failed and only a handful of the Partnership members were aware of either of the Purley events, and the Steering Group pointed out that many of us did not receive notifications and saw no other publicity anywhere. If this was genuinely intended as a consultation (as opposed to merely ticking the boxes), questions need to be answered by the Council why more residents did not attend. The actual documents and information are confusing, too great in volume, very difficult to comprehend and in ˜Council' language that is not accessible to ordinary residents. The internet site was not seen to be accessible and easy to use or read. A perceived cynicism. Over the past 10+ years there have been many plans and schemes in Purley and Croydon but we have seen very little real change (other than the Tramlink in Croydon) in Purley, Kenley and Croydon. It is difficult to predict 20 years ahead. The Council needs to deliver change for the better. No Specific Chapter Conclusion - Not enough notice seems to The comment is noted Mr I.G.M. Hunter have been taken of comments offeredto the Resident main Core Consultation documents. This is in Observation conflict with the Public Policy Statement - Noted National Planning Policies article 43, which requires Councils to allow the local community to say what sort of place they want to live in at a stage when this can make a difference. The article continues:- "effective community involvement requires an approach which enables communities to put forward ideas and suggestions and participate in developing proposals and options. It is not sufficient to invite them to simply comment once these have been worked up. Effective community involvement requires an approach which provides and seeks feedback". In my view there is a danger that this Core Strategy process is not going to satisfy the real stakeholders in the community - the residents and ratepayers. No Specific Chapter There is a problem of not enough schools in The issue of schools will be Revd Charles Trefusis the north of the Borough. If the capacity was addressed in the IDP. Purley & Kenley increased it would reduce the pressures on Neighbourhood schooling and transport in the south of the Partnership Borough including Purley. Observation Noted No Specific Chapter Core Strategy Policy 7 LFB support paragraph The comment is noted. London Fire and 6.6 in so much as it states that emergency Emergency Planning services are considered to be a community London Fire and facility, and it recognises that a good Emergency Planning understanding of the future needs of the Authority borough's residents is required. LFB would Observation like to see further clarification of the proposed Noted Community Facilities Strategy, which aims to promote interaction between communities by integrating facilities at one accessible location, such as a town centre. Although this is suitable for a range of community facilities, this approach is not necessarily the most appropriate for emergency services. LFB therefore seek clarification that the LFB would not be required to relocate any element of the existing facilities without prior consultation. Furthermore, we seek clarification that community facility contributions would be divided between uses appropriately. No Specific Chapter The London Fire Brigade has 112 land fire The comment is noted. London Fire and stations located across Greater London. Five Emergency Planning of these stations are located within the London Fire and London Borough of Croydon (Croydon) as Emergency Planning detailed below: 1. Addington: 197-199 Lodge Authority Lane, CR0 0QA 2. Croydon: 90 Old Town, Observation CR0 1AR 3. Norbury: 1321/1325A London Noted Road, SW16 4AU 4. Woodside: 2 Long Lane Addiscombe Road, Croydon, CR0 7AL In addition, the LFB is seeking to improve the following fire station on site: 5. Purley: 128 Brighton Road, CR8 4DB Summary These comments are in regard to the Croydon New Core Planning Strategy, which is at the preferred options stage and currently undergoing consultation. The LFB are generally supportive of this document and the long term vision it sets out for the London Borough of Croydon, but would like to draw attention to the following points. No Specific Chapter Funding: Considering Emergency Services Funding for infrastructure will be London Fire and have been classified as community facilities, addressed in the IDP. The Emergency Planning the LFB understand that they will benefit from comment is noted. It refers to London Fire and section 106 agreements. LFB are also CS2a. Emergency Planning supportive of paragraph 8.8, which outlines Authority future funding sources and identifies Private Observation Finance Initiatives (PFI) as suitable to support Noted the delivery of improved fire-fighting facilities. No Specific Chapter It is noted that Purley and Kenley have in the Kenley is substantially different Revd Charles Trefusis latest document been divided into separate in character from Purley and will Purley & Kenley zones. This is illogical and needs to be require a different spatial Neighbourhood reviewed as in many ways Kenley looks planning approach to its future Partnership towards Purley (and not Coulsdon or development. Objection Addington). Disagree – No Change No Specific Chapter 3. Response on behalf of Purley: Comments The 16 Places and 4 Spatial Revd Charles Trefusis that demand a response and need to be Management Areas to reflect Purley & Kenley addressed include: The need to review the areas of common attributes for Neighbourhood areas or zones. which broadly similar spatial Partnership planning approaches are Objection appropriate. Whilst the 16 Disagree – No Change Places remain in the Core Strategy, feedback on the concept of Spatial Management Areas suggests it will not feature in the next iteration of the Core Strategy. No Specific Chapter Public Art: There are no signs of 'public art' The Core Strategy will Revd Charles Trefusis and there is an expectation for sculptures, incorporate an enabling policy Purley & Kenley statues and the like. This needs to be fleshed for public art elements of which Neighbourhood out, described and incorporated into the Core may be financed through s106 Partnership Strategy. and/or CIL contributions Objection Agree – Propose Changes No Specific Chapter The need to maintain sustainable retail The comment is noted. Revd Charles Trefusis balances - with a balanced and thriving town Purley & Kenley centre. Neighbourhood Partnership Observation Noted No Specific Chapter There are factual errors regarding the number The issue of infrastructure will Revd Charles Trefusis of swimming pools and Purley expects to be addressed in the IDP. Purley & Kenley retain a pool in the Town centre. Neighbourhood Partnership Observation Noted – To be Reviewed No Specific Chapter 15. Next steps- We would stress that this is an The comment is noted. Some of neighbourhood interim response. There are a number of the issues in this representation Partnerships Chairs & important issues that we will research and are not LDF issues. Evidence VCs comment on in our final response. In has been prepared that is neighbourhood particular, our final response will address the suitable for the requirements of Partnerships Chairs & renewal of the district centres and how we can developing a Core Strategy VCs create a balanced housing mix and Development Plan Document Observation educational provision in the borough. We (as prescribed in the regulations Noted believe that in some areas, crucial information and national planning policy is missing. We have detailed this missing guidance). We await your final information in Appendix II - which is a key response. requirement for us to complete our final response. Finally, we are anxious to append a detailed analysis for each of the "places" of Croydon in our final response. We believe it would be highly beneficial if our Chairman could discuss this interim response with our leading politicians and the strategy team so as to obtain feedback that would be invaluable in drafting our final response. Appendix II - Key additional analysis & information requirements. Robust and detailed current population estimate and projections to 2031 (pages 6/7) The estimate for 2010 and projection for 2031 should be broken down by ward and detail new dwellings (by number of bedrooms). The rational for average inhabitants per household should be justified. Corroborating evidence for the 2010 estimate from council tax rolls, GP patients' rolls and school enrolment should be provided - broken down by ward if possible. Analysis of the advantages and disadvantages for Croydon of being included in a super-borough (page 8) Assume that Croydon is combined with Sutton and Bromley - Analysis of the central government funding impact of dividing Croydon into two separate units - urban and suburban (pages 10) At a public meeting in The Ashcroft Hall in the run-up to the council elections on 6th June, reference was made to detailed figures contrasting Croydon's central government funding as against Lambeth and Tower Hamlets. - A detailed up-to-date comprehensive economic strategy (page 10) Funding for the various development zone opportunities (page 10) A realistic assessment of the funding for the various development zone opportunities that Croydon is targeting. An honest and realistic assessment of how much funding Croydon could expect to receive as its share of the available funding - School children travel flows (page 11) An analysis of school children flows both into and out of the borough together with an analysis of intra- borough numbers for children attending a school that's not in their ward of residence. •Fairfield master plan and development strategy (page 12). No Specific Chapter Executive Summary This divides Croydon into The 16 Places and 4 Spatial Revd Charles Trefusis - 4 distinct areas - Central, North, East and Management Areas have been Purley & Kenley South It is noted that " South" only includes selected to reflect areas of Neighbourhood Coulsdon and Purley where as Kenly and Old common attributes for which Partnership Coulsdon which lie south of Purley are broadly similar spatial planning Objection included in the East Section. This is not only approaches are appropriate. Disagree – No Change inaccurate -it gives totally false impression of The description of the areas is the geographical locations. If these are considered to be broadly defined according to the Characteristics of accurate and more informative each area then may I suggest you use the than numerical zoning. Whilst terms 'ZONES' 1 to 4 Alternatively Kenly and the 16 Places remain in the old Coulsdon should be added to the “South” Core Strategy, feedback on the section. concept of Spatial Management Areas suggests it will not feature in the next iteration of the Core Strategy. No Specific Chapter Kenley residents have very limited contact The comment is noted. Revd Charles Trefusis with Old Coulsdon. Purley by contrast serves Purley & Kenley as the district centre for many Kenley Neighbourhood residents - both as a transport hub and a Partnership shopping centre. Observation Noted No Specific Chapter In producing this supplement, some time after The comment is noted Mr I.G.M. Hunter the deadline for the original Core Strategy Resident document, the Council have, disappointingly, Objection not taken the opportunity to address the Noted obvious errors which appeared in the original. No Specific Chapter ################ Note due to error message now Revd Charles Trefusis - recorded as comment #53. Purley & Kenley Neighbourhood Partnership Objection No Specific Chapter I used the Purley pool for the first time today - The valuable role of Purley Pool Mr Tony Wiseman I belatedly realised it on my early morning in providing swimming facilities Resident route to get my grandson to school. I intend to and a learning environment for Observation use it on a regular basis from now on. This Purley and adjoining areas is Noted sort of facility with it's associated parking is understood. The pool needs critical to people like me who need to refurbishment or in the medium undertake some low impact activity to improve term replacement. The pool is fitness and control weight gain following to be refurbished in the short cancer treatment. term with commitment from the council to keep it open until 2014.

Proposals to meet the needs of the borough, improve the quality in provision, and meet unmet and future demand have arisen from an analysis of both need and the opportunity to develop provision to cater for the unmet demand in the south of the borough.

The Core Strategy will not include policies for site specific facilities unless there are strategic implications. The Core Strategy will set out general policies related to co-located community facilities (including swimming pools and leisure centres). Site specific policies or detailed community facilities policies shall be dealt with by the Site Allocations DPD and Development Management DPD. No Specific Chapter Purley is inadequate in Public Open Space The comment is noted. Revd Charles Trefusis provision. It relies largely on the relatively Purley & Kenley large gardens for its recreation and open Neighbourhood space. This needs to be protected. Partnership Observation Noted No Specific Chapter 14. Role of the Neighbourhood Partnerships in Not an LDF issue. neighbourhood the long term vision. We fully support the Partnerships Chairs & "Caring City" long term objective which states: VCs "More people than ever before will take on neighbourhood responsibilities in their neighbourhoods Partnerships Chairs & resulting in some of the highest levels of VCs community involvement in the country". One Observation of the Croydon's most positive features is its No Action – Not an LDF Iss vibrant voluntary, charity and community organisation sector. However, the health of this sector could be greatly damaged by the proposed funding cuts. We understand the huge financial constraints facing our council but we would ask that it adopts a long term approach in assessing funding needs. A very real danger exists that the funding cuts will cause many of these very valuable organisations to close and it will be impossible to resurrect them when better times resume. In the case of "grassroots" engagement, the main vehicle to harness this involvement is via the Neighbourhood Partnerships. As the recent CVCG proposal articulates, one of the obstacles to securing a much greater level of community engagement is that many residents see the Partnerships as being "talking shops" with little evidence of practical outcomes. We were therefore very encouraged to see that the long term vision contains a very clear statement in "We are Croydon" that: "People, young and old, will be motivated to get involved in shaping what happens in Croydon. They will take on responsibility for managing public spaces and community facilities" This long-term objective is absolutely consistent with the CVCG's desire to make the Neighbourhood Partnerships relevant to their communities so as to maximise engagement. Although it is not an immediate request as set out in the CVCG's recent proposal, our medium term objective is to emulate Sutton's practice of giving its Partnerships a modest amount of funding where communities decide how it is best spent. Finally, it is very apparent that the Strategy focuses on the 16 "places of Croydon". Currently, there are just 10 Neighbourhood Partnerships. As outlined in our recent proposal, we are anxious to redesign the Partnership boundaries. We would welcome the opportunity to work with our council to redraw the boundaries so as they best reflect the communities they serve. No Specific Chapter Inconsistencies in facts and figures between The comment is noted. Revd Charles Trefusis different pages (and previous documents). Purley & Kenley Neighbourhood Partnership Observation Noted – To be Reviewed No Specific Chapter General Comments Within our comments on There will need to be an Carmelle Bell the original 'Towards a preferred Core enabling policy on water and Thames Water Property Strategy for Croydon' document we wastewater in addition to Objection highlighted the need for supportive policies for provision in the IDP. Agree – Propose Changes water and wastewater infrastructure to support growth and deliver environmental improvements. Within the supplement there are several references to pluvial flooding and sewer flooding which are referred to in the Strategic Flood Risk Assessment. Such problems highlight the need for any necessary water and wastewater infrastructure to be provided ahead of the occupation of development and reinforce the need for the supportive policies set out in our previous comments. As set out in our comments on the Infrastructure Delivery Plan (IDP) it is not possible to set out within the IDP all of the water and wastewater infrastructure upgrades required due to the complexity of the networks and the need for certainty over the location and scale of developments and the amounts of development in adjoining Boroughs. Consequently, in order to avoid adverse impacts such as low/no water pressure and sewer flooding a policy is required in the Core Strategy to secure the provision of any necessary water and wastewater infrastructure to support development. Â Without a policy in the Core Strategy relating to water and wastewater infrastructure the Core Strategy would not be effective at delivering the infrastructure required to support development and would therefore not be sound. In addition the Core Strategy would not conform with Policy 4A.18 of the London Plan which states: Â " The Mayor expects developers and local planning authorities to work together with water supply and sewerage companies to enable the inspection, repair or replacement of water supply and sewerage infrastructure. Water and wastewater infrastructure requirements should be put in place in tandem with planned growth to avoid adverse environmental impacts." No Specific Chapter North management area The need for further explanation Mr Michael Mulhern will be reviewed. Greater London Authority 47 The north management area includes Observation Crystal Palace and Upper Norwood, Norbury, Noted – To be Reviewed South Norwood and Woodside and Thornton heath. There is scope in this area for a level of growth through heritage led enhancement plans and regeneration and renewal plans. The Core Strategy identifies a housing figure of 3,600 new homes by 2031. 48 The Core Strategy identifies Crystal Palace, Selhurst and Portland Road as areas that could accommodate a creative industries specific Enterprise Centre. Further explanation should be provided as to what this is and how it would be provided should be included. No Specific Chapter SA Objective Item 15 To reduce flood risk and The comment is noted. The Mr Dave King adapt to climate change. y) Flood plain areas previous consultation reports for Monks Orchard areidentified by the Environmental Agency the Core Strategy (July 2009 Residents Association [not the Local Government]; therefore, what and February 2010) have put Observation are Croydon Council's proposals for providing forward for consultation options Noted any preparations for limiting or preventing for ameliorating flood risk. The flood damaged to properties and buildings in LDF cannot put forward the areas likely to be affected - or do they policies/strategies for limiting or think its good enough just to recognise there preventing damage to private is a flood plain? z) What are Croydon Councils dwellings in flood events, this policies to prevent ANY further development information is available in the on any site within currently identified Flood Multi-Agency Flood Plan and Plain areas? e.g. Monks Orchard Primary further guidance for School. aa) What preparations or plans are homeowners can also be found being made or undertaken to improve surface on the Environment Agency water drainage in the identified flood plain website. The Core Strategy and areas to assist in the improved discharge of Infrastructure Delivery Plan surface and flash flood water in the event of have used the Strategic Flood high levels of precipitation. bb) Have all Risk Assessment and emerging culverts and underground water courses in work on the borough's Surface Shirley and Ashburton areas been mapped Water Management Plan to and categorised in relation to the likely propose planning strategies for contribution to flash flooding in these or mitigating flood risk including downstream localities and what preparations site specific sustainable have or will be made to mitigate the effects on construction standards, the use local properties. cc) What action is being of SUDs and promotion of taken or planned, to investigate the deculverting and water storage improvement or flow of surface water schemes in the boroughs green discharge where there are any likely spaces. resistances or blockages of surface water run- off rather than wait for an eventual flood or flash flood to establish where they are. dd) What advice has been or will be given to householders who live within flood plain areas? ee) What flood defences are proposed for those areas identified as flood plains? ff) Could any financial help be given to householders to provide flood defences -e.g. to provide water proof covers for air bricks below dpc's and door thresholds in threatened locations. No Specific Chapter To use the facilities of Coombe Nursery to Comment is noted. The benefits grow food possibly as a social enterprise to of green spaces and associated replace Crossfield sheltered home and tackle activities on mental health and Observation other mental health issues. well-being is recognised. Noted No Specific Chapter If this was intended as a consultation then it The comment is noted. Mr Michael Buckley failed miserably. Nobody to talk to or ask me if Resident I had any views. Observation Noted No Specific Chapter To monitor existing hardsurfaces e.g drives to Comment is noted. The Council create water return to the earth, drainage in identifies as a priority the Council areas too utilisation of sustainable Observation drainage systems to tackle flood Noted risk in the borough. No Specific Chapter I confirm that we have no specific comments Comment is noted. Miss Rachael Bust to make on this document at this stage. Coal Authority Observation Noted No Specific Chapter I write in answer to your invitation to give my Comment is noted. Refer to Mr Mike Metcalfe views on future plans for Croydon. For Purley Infrastructure Delivery Plan for Resident I think the essentials are 1) A new and better comment. Observation road layout for Purley Cross, ideally with a Noted flyover. 2) A better swimming pool or gym facility to include spectacular viewing facilities. 3) Car Parking facilities at least as good as existing in the multi-storey Sainsbury one. 4) Walk-in clinic at Purley Memorial Hospital. These improvements would benefit the health, vitality and well being of Purley residents. No Specific Chapter Since the earlier drafts the CMC is now Providing homes specifically for Mr Brian Madge required to accommodate more land uses students or policies to consider Brian Madge Ltd such as the University thus further restricting applications for Class C4 use Observation housing opportunities and creating its own are not strategic matters for the Noted housing demand. Since the recent changes to Core Strategy to consider. the Use Classes Order the Council can no Furthermore as of the 1st longer assume shared student housing will September 2010 the Town and occur. The requirement for planning Country Planning (General permission places further demands on Permitted Development) housing provision. (Amendment) (No.2) (England) Order 2010 now permit the change of use of Class C3 dwellings to Class C4 use without the need to apply for planning permission thus the new use class is unlikely to become a constraint on development. No Specific Chapter BRB (Residuary) Ltd owns land located at the These comments refer to the BRB (Residuary) Ltd East Croydon Goods Yard, Lansdowne Road, previous consultation on Core BRB (Residuary) Ltd Croydon. The site is situated to the north west Strategy - Towards a Preferred Observation of East Croydon Station and currently sits Core Strategy and have been No Action – Not an LDF Iss outside but close to the Metropolitan Centre responded under that Boundary as defined in the Croydon consultation. Replacement Unitary Development Plan 2006.

CS2 Homes

Whilst recognising that the Core Strategy sets out general Spatial Objectives for the provision of housing within Croydon, it is nonetheless a test of soundness of the Core Strategy that these general objectives are deliverable. In this context, BRB (Residuary) Ltd makes the following comments.

Even at this strategic level, considerations of viability need to be built into the Core Strategy. This is particularly the case in relation to the provision of affordable housing, not least within the Croydon Metropolitan Centre (CMC). Throughout the Borough, and particularly within the CMC, sites coming forward for residential development are likely to be subject to a number of constraints (including, for example, contaminated land). The abnormal costs associated with bringing these sites forward makes the development of such sites challenging, to the extent that the development of such sites could be prejudiced by a requirement to provide affordable housing to the percentages required by the London Plan. It is therefore considered that the Core Strategy should specifically acknowledge, even if only in general terms, that the provision of housing in general, and affordable housing in particular, may be affected by issues of viability. The Core Strategy should also acknowledge that, on a case by case basis, the Council may consider accepting a lower percentage of affordable housing in schemes in order to deliver the level of housing growth envisaged in the Core Strategy. It is considered that for the Spatial Objectives set out in CSS2 to be deliverable, it will be essential to release land currently in industrial use. This point is covered in more detail under comments on policy CS3 but, in relation to CS2, it is considered that the deliverability of the Spatial Objectives in relation to housing, and therefore the soundness of the Core Strategy, will be dependant upon the release of industrial land. No Specific Chapter Drawing the above together we suggest the The Core Strategy is a 20-year Mr Brian Madge Core Strategy should have; plan and over its lifetime the Brian Madge Ltd economic climate is likely to Objection Greater regard on the changed nature of the change signifcantly. It is built Disagree – No Change development industry upon the current national policy guidance taking into account Greater regard to the changed national policy recent changes at both the environment national and regional level. The strategy it presents is flexible Regard to the likely consequences of enough to deal with the current prolonged public expenditure restraint economic situation whilst preparing Croydon for any Both of the above require either that the Core future upturn in the economy. Strategy should be further considered, particularly post the CSR, and there is a need or that it should include provisions that address the changed nature of the economy and possibility that such conditions will continue for at least the medium term.

It is our conclusion that the plan as regard housing and infrastructure in falling to recognise the change development climate is currently unsound.

We wait the next stage of the LDF process and would request an acknowledgement of this representation No Specific Chapter Exhibition and staff very helpful Comment is noted - thank you Mr Brian Madge for the feedback Brian Madge Ltd Observation Noted No Specific Chapter To encourage food growing locally in private Comment is noted. Enabling and community gardens more sustainable local food production is a priority in the Observation emerging Core Strategy. Noted Purley Swimming Pool Section Representation Recommended Response Full Name Paragraph Organisation Nature of Response Officer Recommendation I understand you are involved in preparing a The valuable role of Purley Pool Caroline Hughes Core strategy document on the future of in providing swimming facilities Resident Croydon and Purley and would like to urge and a learning environment for Objection you to keep the Purley Leisure Centre and its Purley and adjoining areas is Noted swimming pool. This pool is used by many understood. The pool needs people - some 250,000 customers a year, I refurbishment or in the medium believe - young and old. It provides an term replacement. The pool is excellent, affordable toall, healthy activity and, to be refurbished in the short for this reason,is supported by the doctors in term with commitment from the this area. It is also used by local schools and council to keep it open until the disabled. Purley has little to offer to its 2014. residents in the way of public amenities and it would be a great shame to get rid of a much- Proposals to meet the needs of enjoyed facility. Purley is at the hub of the the borough, improve the quality south of the borough and has good transport in provision, and meet unmet links, so is reachable by many in the and future demand have arisen surrounding area. from an analysis of both need and the opportunity to develop provision to cater for the unmet demand in the south of the borough.

The Core Strategy will not include policies for site specific facilities unless there are strategic implications. The Core Strategy will set out general policies related to co-located community facilities (including swimming pools and leisure centres). Site specific policies or detailed community facilities policies shall be dealt with by the Site Allocations DPD and Development Management DPD. Â I fully support the retention of the Purley The valuable role of Purley Pool Mr Victor Cole Swimming Pool. It is regularly used by a large in providing swimming facilities cross section of the local population as well as and a learning environment for Objection those from neighbouring areas. In addition, Purley and adjoining areas is Noted with the increased number of housing units understood. The pool needs that are planned for the Purley area, the Pool refurbishment or in the medium represents not only a healthy, but a sporting term replacement. The pool is facility that would be sorely missed. Â to be refurbished in the short term with commitment from the council to keep it open until 2014.

Proposals to meet the needs of the borough, improve the quality in provision, and meet unmet and future demand have arisen from an analysis of both need and the opportunity to develop provision to cater for the unmet demand in the south of the borough.

The Core Strategy will not include policies for site specific facilities unless there are strategic implications. The Core Strategy will set out general policies related to co-located community facilities (including swimming pools and leisure centres). Site specific policies or detailed community facilities policies shall be dealt with by the Site Allocations DPD and Development Management DPD. I disagree with what the council is doing to this The valuable role of Purley Pool Hannah Mitchell swimming pool. The pool is a lovely place and in providing swimming facilities Resident is used by 250,000 customers a year. These and a learning environment for Objection customers include the disabled and 11 local Purley and adjoining areas is Noted schools. The swimming pool is used for fun as understood. The pool needs well as fitness routines and keeps a lot of refurbishment or in the medium young people of the streets, this means many term replacement. The pool is people will be disapointed when this facility to be refurbished in the short disapears. Purley also has great transport term with commitment from the links making it easier to travel to the pool and council to keep it open until the transport is better than all the emitions 2014. from cars. The local councillors support this facility and in the last election it was Proposals to meet the needs of mentioned that there will need to be a pool in the borough, improve the quality purly in the future so why should the plannet in provision, and meet unmet be destroyed more by building a new facility and future demand have arisen when there is already one there. from an analysis of both need and the opportunity to develop provision to cater for the unmet demand in the south of the borough.

The Core Strategy will not include policies for site specific facilities unless there are strategic implications. The Core Strategy will set out general policies related to co-located community facilities (including swimming pools and leisure centres). Site specific policies or detailed community facilities policies shall be dealt with by the Site Allocations DPD and Development Management DPD. First you closed Croydon Swimming Pool then The valuable role of Purley Pool Diane Heeley it was the Purley Way Pool now I understand in providing swimming facilities LBC that there are plans for Purley Swimming Pool and a learning environment for Objection to be closed. Â I live in the South of the Purley and adjoining areas is Noted borough and work in Purley, I like to use the understood. The pool needs pool before I go to work in the morning, as do refurbishment or in the medium numerous other people, bearing in mind that term replacement. The pool is we are encouraged to exercise, why is it that to be refurbished in the short you intend to close down a leisure centre that term with commitment from the is popular especially in an area that offers council to keep it open until very little in the way of leisure activities that 2014. are affordable and accessible. Â I would request that you reconsider the decision to Proposals to meet the needs of close this Swimming Pool the borough, improve the quality in provision, and meet unmet and future demand have arisen from an analysis of both need and the opportunity to develop provision to cater for the unmet demand in the south of the borough.

The Core Strategy will not include policies for site specific facilities unless there are strategic implications. The Core Strategy will set out general policies related to co-located community facilities (including swimming pools and leisure centres). Site specific policies or detailed community facilities policies shall be dealt with by the Site Allocations DPD and Development Management DPD. I received information this morning that you The valuable role of Purley Pool Susan Heeley are looking at closing down the Pool in Purley, in providing swimming facilities l feel that this would be a mistake l use the and a learning environment for Objection pool in the early morning every day and so do Purley and adjoining areas is Noted a lot of other people. One of my many reasons understood. The pool needs for using the pool is from the Physiotherapist refurbishment or in the medium as l have arthritis of the knees and swimming term replacement. The pool is reduces the need for some of the pain to be refurbished in the short medication and increases my mobility. It is term with commitment from the also helpingme to reduce weight. This is the council to keep it open until only amenity of available in the south of the 2014. borough to enable the people in the south of the borough to maintain fitness and enjoy Proposals to meet the needs of exercise in the same place the borough, improve the quality in provision, and meet unmet and future demand have arisen from an analysis of both need and the opportunity to develop provision to cater for the unmet demand in the south of the borough.

The Core Strategy will not include policies for site specific facilities unless there are strategic implications. The Core Strategy will set out general policies related to co-located community facilities (including swimming pools and leisure centres). Site specific policies or detailed community facilities policies shall be dealt with by the Site Allocations DPD and Development Management DPD. I consider a swimming pool essential for the The valuable role of Purley Pool Mr Mark Bernstein people ofthe areafor healthy activity. Purley is in providing swimming facilities the hub of the South of the borough, having and a learning environment for Objection good transport links serving the wards of Purley and adjoining areas is Noted Coulsdon, Kenley, Selsdon and South understood. The pool needs Croydon. The pool serves 250,000 customers refurbishment or in the medium a year, and our young people make good use term replacement. The pool is of the pool. to be refurbished in the short term with commitment from the council to keep it open until 2014.

Proposals to meet the needs of the borough, improve the quality in provision, and meet unmet and future demand have arisen from an analysis of both need and the opportunity to develop provision to cater for the unmet demand in the south of the borough.

The Core Strategy will not include policies for site specific facilities unless there are strategic implications. The Core Strategy will set out general policies related to co-located community facilities (including swimming pools and leisure centres). Site specific policies or detailed community facilities policies shall be dealt with by the Site Allocations DPD and Development Management DPD. Please do your best to support the retention of The valuable role of Purley Pool Mr Roger Munrow this pool which helps users to maintain a in providing swimming facilities Resident healthy life style. and a learning environment for Objection Purley and adjoining areas is Noted understood. The pool needs refurbishment or in the medium term replacement. The pool is to be refurbished in the short term with commitment from the council to keep it open until 2014.

Proposals to meet the needs of the borough, improve the quality in provision, and meet unmet and future demand have arisen from an analysis of both need and the opportunity to develop provision to cater for the unmet demand in the south of the borough.

The Core Strategy will not include policies for site specific facilities unless there are strategic implications. The Core Strategy will set out general policies related to co-located community facilities (including swimming pools and leisure centres). Site specific policies or detailed community facilities policies shall be dealt with by the Site Allocations DPD and Development Management DPD. Core Strategy for Purley - the continued need The valuable role of Purley Pool Mr Barry Kay for a Purley pool I have been an active in providing swimming facilities Resident swimmer in Croydon for some 65 years and and a learning environment for Observation continue to use the Purley Poolmost Purley and adjoining areas is Noted weekdays. When the central baths in understood. The pool needs Scarbrook Hill, Croydonwere demolished in refurbishment or in the medium the 60's there became a real need for new term replacement. The pool is swimming facilities in central Croydon. Today, to be refurbished in the short some 50 years later, there are stillno such term with commitment from the facilities. At that time there were nobaths in council to keep it open until the south of the Borough but your council 2014. recognised this need when initial discussions took place regarding the development of the open Purley Municiple car park. Whilst I had aninvolvementin the development, it failed to Proposals to meet the needs of materialisebut, your Council rightly recognised the borough, improve the quality the development potential resulting in the in provision, and meet unmet Sainsbury/Multi-storey car park and swimming and future demand have arisen complex that is there today. The facility is from an analysis of both need currently enjoyed by many and particularly and the opportunity to develop young persons acquiring theability to swim provision to cater for the unmet and secondly by the old and infirm who need demand in the south of the the facility to keep active.The pool is well borough. positioned for all swimmers being close to public transport facilities, shops and necessary parking. The pool is structually sound and has a lifespan of many years given The Core Strategy will not reasonable annual maintenance. The public, include policies for site specific schools and the medical profession all support facilities unless there are the continuedneed for a pool in central Purley strategic implications. The Core to serve those residents in the southern part Strategy will set out general of the London Borough of Croydon. If no policies related to co-located provision is made in the core strategy for a community facilities (including pool thenI foresee a further downturn in swimming pools and leisure central Purley. Ihave read of your desire to centres). Site specific policies or construct pools at Five Ways, Wadden and in detailed community facilities Coulsdon but a more centralised siting is policies shall be dealt with by required not one that serves the periphery of the Site Allocations DPD and the boroughwhere public transport facilitiesfor Development Management many of us residents would prove impossible. DPD. I am not adverse to the demolition of the Purley pool if, on redevelopment, it can be shown that Purley will benefit and always providedthat another6 lane, 25 metre swimming pool, with spectator seating and adequate car parking is built before any closure of the existing facility and in a central area of the town where similar public transport facilities are available.Why not make Purley the 'hub' of the swimmingworld - it may prove to be the catylstfor its survival and development. In formulating your proposals I trust that you will take fully into account my comments. If you require me to enlarge upon any aspect of this email please let me know. I understand comments are to be sent to you The valuable role of Purley Pool Mr Michael Goddard regarding the future of Purley Pool, which I in providing swimming facilities Resident understand is being considered for closure. Â and a learning environment for Observation If that is the case, could I please make the Purley and adjoining areas is Noted following appeal? - Â As a Purley resident understood. The pool needs and a parent of 2 small children, one of whom refurbishment or in the medium attends a Purley Primary School that utilises term replacement. The pool is the pool (the other being an infant), I would to be refurbished in the short strongly oppose the closure of Purley Pool. Â term with commitment from the Aside from being a statutory requirement of council to keep it open until the national curriculum, I believe it is vital that 2014. children learn to swim at the earliest opportunity. This not only builds their confidence around water but may assist in saving their lives should they get into Proposals to meet the needs of difficulties in water without the presence of an the borough, improve the quality adult to assist them. Â The children at my in provision, and meet unmet sons' primary school are able to walk to and future demand have arisen Purley Pool for their swimming lessons. from an analysis of both need Should they have to travel further afield, this and the opportunity to develop would mean an increase in financial costs to provision to cater for the unmet the school and extend their absence from the demand in the south of the classroom, which would have a negative borough. impact on their other lessons. Â Aside from the school use, I have taken my eldest son to Purley Pool at weekends and on days off on numerous occasions and it is an excellent The Core Strategy will not local resource, not only due to its location but include policies for site specific also due to the quality of the pool staff - and I facilities unless there are say this having been to other pools in the strategic implications. The Core area, such as Westcroft in Carshalton, which Strategy will set out general is not, in my opinion, as good. Â I believe policies related to co-located Purley Pool is an excellent local resource and community facilities (including it would be a great sadness if the local swimming pools and leisure community and borough in general were centres). Site specific policies or deprived of it. detailed community facilities policies shall be dealt with by the Site Allocations DPD and Development Management DPD. I write in regards to a letter I received from The valuable role of Purley Pool Mr Richard Ayetey Christ Church C of E Primary about the in providing swimming facilities Resident closure of the Purley Pool. As it is a statutory and a learning environment for Observation requirement laid out in the National curriculum Purley and adjoining areas is Noted that all primary age children are taught to understood. The pool needs swim, I do have two of my children,Rhys and refurbishment or in the medium Reanne in Christ Church Primary and are term replacement. The pool is enrolled in years three and one respectively. to be refurbished in the short Currently the school walks the children to the term with commitment from the pool in Purley for lessons however if they council to keep it open until have to pay travel costs on top of the cost of 2014. the swimming lessons this additional expense will take away other aspects of children's learning as well as extra cost for all of us. Â Travelling further away will also take more Proposals to meet the needs of time out of the school day when children could the borough, improve the quality be engaged in other learning. Â For these in provision, and meet unmet reasons it will be detrimental to the education and future demand have arisen of the children if there is no pool in Purley. Â I from an analysis of both need therefore suggest that swimming pool in and the opportunity to develop Purley is still kept in the locality as a provision to cater for the unmet contributing factor to the quality of education demand in the south of the for children in our community. borough.

The Core Strategy will not include policies for site specific facilities unless there are strategic implications. The Core Strategy will set out general policies related to co-located community facilities (including swimming pools and leisure centres). Site specific policies or detailed community facilities policies shall be dealt with by the Site Allocations DPD and Development Management DPD. The Purley pool is a very good pool. My The valuable role of Purley Pool Mr Kieran Copson cousins live around the area and i have visited in providing swimming facilities Resident the pool many times. I love the pool and when and a learning environment for Observation my uncle told me they were shutting it down i Purley and adjoining areas is Noted was heart broken. Purley is the middle of the understood. The pool needs Southern Croydon, having good transport refurbishment or in the medium links so the pool serves 250000 customers a term replacement. The pool is year, and our young people make good use of to be refurbished in the short the pool. I was told that it is used by 11 local term with commitment from the schools and the disabled. These schools will council to keep it open until have nowhere else to go and will loose their 2014. right to swimming lessons.

Proposals to meet the needs of the borough, improve the quality in provision, and meet unmet and future demand have arisen from an analysis of both need and the opportunity to develop provision to cater for the unmet demand in the south of the borough.

The Core Strategy will not include policies for site specific facilities unless there are strategic implications. The Core Strategy will set out general policies related to co-located community facilities (including swimming pools and leisure centres). Site specific policies or detailed community facilities policies shall be dealt with by the Site Allocations DPD and Development Management DPD. i think you should keep croydon swimming The valuable role of Purley Pool Mr Charlie Clark pool because it isa very good, fun place to go in providing swimming facilities Resident that keeps people very fit also i think its a bad and a learning environment for Objection idea because there will be nothing for the Purley and adjoining areas is Noted children to do sothey will hang around on the understood. The pool needs streets. the pool serves over250000 people a refurbishment or in the medium year and some of this people are disabled that term replacement. The pool is look foward every week to going swimming to be refurbished in the short with schools is this pool gets shut down lots of term with commitment from the people will have to travel miles to go council to keep it open until swimming. 2014.

Proposals to meet the needs of the borough, improve the quality in provision, and meet unmet and future demand have arisen from an analysis of both need and the opportunity to develop provision to cater for the unmet demand in the south of the borough.

The Core Strategy will not include policies for site specific facilities unless there are strategic implications. The Core Strategy will set out general policies related to co-located community facilities (including swimming pools and leisure centres). Site specific policies or detailed community facilities policies shall be dealt with by the Site Allocations DPD and Development Management DPD. With regard to the Core Strategy for Purleys' The valuable role of Purley Pool Ashley Allen future, I would like to make known my feelings in providing swimming facilities Resident toward the future of the swimming pool. Â I and a learning environment for Objection believe this to be a very important and integral Purley and adjoining areas is Noted part of the community with many positives; understood. The pool needs schools use, health for the community, refurbishment or in the medium training facilities for athletes, fun for families term replacement. The pool is and many more. The pool is currently used by to be refurbished in the short approx 25,000 customers a year, so this tells term with commitment from the us that this is a viable facility for the future. Â council to keep it open until Without starting to ramble aimlessly, I along 2014. with many friends and colleagues, believe that the pool should very much be part of future Proposals to meet the needs of plans for Purley. the borough, improve the quality in provision, and meet unmet and future demand have arisen from an analysis of both need and the opportunity to develop provision to cater for the unmet demand in the south of the borough.

The Core Strategy will not include policies for site specific facilities unless there are strategic implications. The Core Strategy will set out general policies related to co-located community facilities (including swimming pools and leisure centres). Site specific policies or detailed community facilities policies shall be dealt with by the Site Allocations DPD and Development Management DPD. I have been informed of your proposed Core The valuable role of Purley Pool Mr Gary Mundy Strategy document and wish to add my in providing swimming facilities comments regarding the Purley swimming and a learning environment for Observation pool as I personally use the pool 3 times a Purley and adjoining areas is Noted week which I have done for around 10 years. understood. The pool needs  I was informed a while back that the refurbishment or in the medium Council's plan was to retain a pool at Purley term replacement. The pool is until the new pool at Waddon was built, to be refurbished in the short probably around 2013. It is my opinion that a term with commitment from the pool at Waddon cannot be seen as an council to keep it open until adequate replacement for the Purley pool. 2014. Waddon is not close to Purley. The Purley pool is in an easily accessed part of Purley. The Waddon site is difficult to access. I believe many of those using the Purley pool Proposals to meet the needs of would cease to do so if the location was the borough, improve the quality effectively changed to Waddon. There is no in provision, and meet unmet nearby alternative site.  The pool is well and future demand have arisen used and has a car park attached (which also from an analysis of both need needs to be retained). Swimming is a great and the opportunity to develop way for people young and old to keep fit. provision to cater for the unmet Gyms are not appropriate for everyone. demand in the south of the Swimming is suited to a much wider range of borough. people. It would also seem churlish to have promoted activities like swimming leading up to the 2012 Olympics, only to then close a swimming pool the very next year.  I believe The Core Strategy will not the pool is very important for Croydon, include policies for site specific particularly the Purley area and would strongly facilities unless there are urge you not to consider closing it. strategic implications. The Core Strategy will set out general policies related to co-located community facilities (including swimming pools and leisure centres). Site specific policies or detailed community facilities policies shall be dealt with by the Site Allocations DPD and Development Management DPD. As a pensioner, I have been using the Purley The valuable role of Purley Pool Mrs L Hedley Swimming Baths for several years now and in providing swimming facilities Resident have foundswimming a verygood way of and a learning environment for Objection keeping fit. I have just learnt from the staff Purley and adjoining areas is Noted there that you are preparing the above on understood. The pool needs Purley, and that there is a possibility thatthe refurbishment or in the medium baths may be closed. If so, it would indicate a term replacement. The pool is grave lack of foresight, at a time when the to be refurbished in the short NHS is under increasing pressure, and more term with commitment from the not less effort should be being made to help council to keep it open until us all keep fit. Anything that does that should 2014. be welcome and not closed down. I hope you will take my comments on board Proposals to meet the needs of the borough, improve the quality in provision, and meet unmet and future demand have arisen from an analysis of both need and the opportunity to develop provision to cater for the unmet demand in the south of the borough.

The Core Strategy will not include policies for site specific facilities unless there are strategic implications. The Core Strategy will set out general policies related to co-located community facilities (including swimming pools and leisure centres). Site specific policies or detailed community facilities policies shall be dealt with by the Site Allocations DPD and Development Management DPD. My name is Kieran Mac Feely. I am writing to The valuable role of Purley Pool Mr Kieran Mac Feely you regarding Purley Pool, whose future is in providing swimming facilities uncertain I am told. I am a resident of Purley and a learning environment for Observation and have two young children who enjoy the Purley and adjoining areas is Noted use of the pool frequently. If this pool was to understood. The pool needs be demolished we would have to drive a refurbishment or in the medium considerable distance everytime we wish to term replacement. The pool is go swimming. My daughter has asthma and to be refurbished in the short regular swimming is essential for her well term with commitment from the being. We encorporate regular swimming council to keep it open until sessions into our weekly routine. To have to 2014. drive the extra miles to continue to do this would put both financial and time pressures on us as a family. The pool is very important to us. Proposals to meet the needs of the borough, improve the quality in provision, and meet unmet and future demand have arisen from an analysis of both need and the opportunity to develop provision to cater for the unmet demand in the south of the borough.

The Core Strategy will not include policies for site specific facilities unless there are strategic implications. The Core Strategy will set out general policies related to co-located community facilities (including swimming pools and leisure centres). Site specific policies or detailed community facilities policies shall be dealt with by the Site Allocations DPD and Development Management DPD. I wish to add my view regarding a pool in The valuable role of Purley Pool Patricia Underwood Purley. I feel the future of a pool in Purley is a in providing swimming facilities top priority for the people of Purley, Coulsdon, and a learning environment for Objection Kenley, Sanderstead, Selsdon and South Purley and adjoining areas is Noted Croydon. Â I consider a swimming pool understood. The pool needs essential for myself and the people of the area refurbishment or in the medium for healthy activity. As a young senior citizen I term replacement. The pool is find attending two or three swimming sessions to be refurbished in the short a week invaluable as it helps to keep me fit term with commitment from the and mobile without hard impact activity. The council to keep it open until pool serves 250000 customers a year, and is 2014. used by all ages. Â The premises of Purley Pool and Car Park is I believe sound and the Proposals to meet the needs of life of the building could be retained by the borough, improve the quality upgrading and refurbishing the existing main in provision, and meet unmet structure and be cost effective. Â Purley is and future demand have arisen the hub of the South of the borough, having from an analysis of both need good transport links serving the above wards and the opportunity to develop is essential in view of the hills surrounding provision to cater for the unmet Purley which makes walking into the town demand in the south of the centre difficult for a large majority of the local borough. residential. Buses and rail link improvements would reduce the need for cars. The Core Strategy will not include policies for site specific facilities unless there are strategic implications. The Core Strategy will set out general policies related to co-located community facilities (including swimming pools and leisure centres). Site specific policies or detailed community facilities policies shall be dealt with by the Site Allocations DPD and Development Management DPD. We consider Purley pool to be an important The valuable role of Purley Pool Mrs Jennifer Boff part of Purley - we have already lost our in providing swimming facilities cinema and the town has not much to offer. and a learning environment for Observation The pool provides healthy exercise and is Purley and adjoining areas is Noted used by quite a few of the local schools. understood. The pool needs Purley is a very good area to have the pool as refurbishment or in the medium there are numerous bus routes going through term replacement. The pool is Purley and we also have the train station to be refurbished in the short nearby. There are no sports facilities in the term with commitment from the area unless you are able to afford to pay for a council to keep it open until private gym/health club. 2014.

Proposals to meet the needs of the borough, improve the quality in provision, and meet unmet and future demand have arisen from an analysis of both need and the opportunity to develop provision to cater for the unmet demand in the south of the borough.

The Core Strategy will not include policies for site specific facilities unless there are strategic implications. The Core Strategy will set out general policies related to co-located community facilities (including swimming pools and leisure centres). Site specific policies or detailed community facilities policies shall be dealt with by the Site Allocations DPD and Development Management DPD. I am writing as one who strongly supports the The valuable role of Purley Pool Mr Colin MacGregor preservation of Purley Pool. I am a retired in providing swimming facilities clergyman andI had a parish on Purley. I know and a learning environment for Observation how important the Pool is for those who live in Purley and adjoining areas is Noted the area. I am also a member of the Purley understood. The pool needs Rotary Cluband I know that the Swimathon we refurbishment or in the medium organise every year raises well over £20,000 term replacement. The pool is pounds for local charities. to be refurbished in the short term with commitment from the council to keep it open until 2014.

Proposals to meet the needs of the borough, improve the quality in provision, and meet unmet and future demand have arisen from an analysis of both need and the opportunity to develop provision to cater for the unmet demand in the south of the borough.

The Core Strategy will not include policies for site specific facilities unless there are strategic implications. The Core Strategy will set out general policies related to co-located community facilities (including swimming pools and leisure centres). Site specific policies or detailed community facilities policies shall be dealt with by the Site Allocations DPD and Development Management DPD. I am a resident of Purley Oaks. I have often The valuable role of Purley Pool Mr David Brown used Purley Swimming pool and think it is in providing swimming facilities important for those that live or work around and a learning environment for Objection Purley as the nearest alternative very far Purley and adjoining areas is Noted away. It is also used by my children for school understood. The pool needs swimming. To me it makes sense to retain it. refurbishment or in the medium term replacement. The pool is to be refurbished in the short term with commitment from the council to keep it open until 2014.

Proposals to meet the needs of the borough, improve the quality in provision, and meet unmet and future demand have arisen from an analysis of both need and the opportunity to develop provision to cater for the unmet demand in the south of the borough.

The Core Strategy will not include policies for site specific facilities unless there are strategic implications. The Core Strategy will set out general policies related to co-located community facilities (including swimming pools and leisure centres). Site specific policies or detailed community facilities policies shall be dealt with by the Site Allocations DPD and Development Management DPD. My child's school has notified me that you are The valuable role of Purley Pool Stephanie Clackworthy the most appropriate contact to lobby to in providing swimming facilities maintain the availability of this pool. Â At the and a learning environment for Observation moment, there are a number of schools in the Purley and adjoining areas is Noted area that all use Purley Pool for lessons. understood. The pool needs Since it is a statutory obligation for them to refurbishment or in the medium teach all primary schoolchildren how to swim, term replacement. The pool is we would not welcome extra expense being to be refurbished in the short diverted to the exercise, nor the loss of time of term with commitment from the a longer journey that they can currently council to keep it open until undertake on foot. I do not understand and 2014. never have understood how it benefits the south of the borough to lose a swimming pool, especially as the proposal is to close it before the Waddon pool is opened. Purley Pool Proposals to meet the needs of already seems to have been short-changed in the borough, improve the quality relation to the exercise suite downstairs, in provision, and meet unmet which is of no use to children whatsoever. Â I and future demand have arisen swim regularly with my daughter at Purley. from an analysis of both need Bus links to Waddon from South Croydon and and the opportunity to develop Purley are inadequate, leading to increased provision to cater for the unmet road traffic for those with a car during the demand in the south of the week (I don't have one). You are asking for borough. turkeys to vote for Christmas! How can it possibly be a viable use of public funds to build a new pool rather than maintain the existing one? The Core Strategy will not include policies for site specific facilities unless there are strategic implications. The Core Strategy will set out general policies related to co-located community facilities (including swimming pools and leisure centres). Site specific policies or detailed community facilities policies shall be dealt with by the Site Allocations DPD and Development Management DPD. I am writing this email to inform you that I, The valuable role of Purley Pool Georgina Pascoe along with many others, are determined to in providing swimming facilities Resident keep this family fun swimming centre open for and a learning environment for Observation the public. I believe that this swimming pool is Purley and adjoining areas is Noted an essential part of the local community and understood. The pool needs provides fun leisure activities and joy to all! refurbishment or in the medium Obesity has been a major issue in the news term replacement. The pool is lately, and closing this swimming pool would to be refurbished in the short result to more young kids doing less exercise term with commitment from the and not having the healthy lifestyle that they council to keep it open until would, if this centre was kept open. I have 2014. been informed that you provide this pool out for 11 lucky, local primary schools .inc. Proposals to meet the needs of disabled students. Have you thought about the borough, improve the quality the feelings and emotions of these young in provision, and meet unmet kids? Viewing your centre's statistics, it shows and future demand have arisen that you serve over 250 000 customers a from an analysis of both need year, with them all making great use of this and the opportunity to develop centre. Many people, including councillors and provision to cater for the unmet all political parties support this need for a pool demand in the south of the in Purley; and this is the best one around as it borough. has great transport links in and around Croydon. Also, by closing many people's pride The Core Strategy will not and joy, you are destroying a great place for include policies for site specific people to socialise and enjoy their time to facilities unless there are relax and get away from stress that follows strategic implications. The Core them through out their lifestyle! Have you Strategy will set out general considered any of these points? Lastly, you policies related to co-located and your staff of this centre have always community facilities (including encouraged people to come in and have early swimming pools and leisure morning swimming sessions... After all the centres). Site specific policies or hard work you have put in to help others, detailed community facilities would you really like to see that all disappear? policies shall be dealt with by You will also have that problem with the the Site Allocations DPD and children's swimming lessons/sessions... What Development Management will those childrens outcome in life be? And DPD. who will they have to blame? I demand that you take time to read this email carefully and think about how many people you are upsetting and ruining their chances of having a active life! Please take time to consider all of these points and think deeply about what your final decision will be. over the last few years I have represented The valuable role of Purley Pool Mr Richard Evans Great Britain at Triathlon at World in providing swimming facilities Championships around the World, as I am of and a learning environment for Objection a swimming back-ground I find thefacilitiesat Purley and adjoining areas is Noted Purley ideal for my training. I realise that all understood. The pool needs levels of swimmers appreciate the pool and I refurbishment or in the medium have always held the principal that swimming term replacement. The pool is is for 'all'. All shapes, sizes, ages, abilities and to be refurbished in the short isexcellentforrehabilitation, fitness and fun. It term with commitment from the also is a sport which does not cause injuries council to keep it open until as there is no impact on the body and 2014. therefore is great for mental and physical ailments. Â The location of the pool is very Proposals to meet the needs of very important and despite the very poor the borough, improve the quality parking facilities, it is in thecentreof several in provision, and meet unmet surrounding communities with the heart at and future demand have arisen Purley. There are no pools in the locality and from an analysis of both need considering closing it down to me and the opportunity to develop seemsludicrous, especially as I witness the provision to cater for the unmet array of public who attend. The pool invites demand in the south of the community spirit and would be borough. adevastatingloss. The Core Strategy will not include policies for site specific facilities unless there are strategic implications. The Core Strategy will set out general policies related to co-located community facilities (including swimming pools and leisure centres). Site specific policies or detailed community facilities policies shall be dealt with by the Site Allocations DPD and Development Management DPD. It has been brought to my attention that once The valuable role of Purley Pool Lee Rammelt again our local pool is under threat of closure. in providing swimming facilities We are constantly encouraged and and a learning environment for Objection recommended to maintain a healthy life style, Purley and adjoining areas is Noted but the facilities needed to do so are understood. The pool needs becoming more and more scarce. My God refurbishment or in the medium daughter who attends the Chruch of England term replacement. The pool is school in Purley greatly enjoys her swimming to be refurbished in the short lessons there and both her parents and I term with commitment from the enjoy coming along with her. The nearest council to keep it open until swimming pool is in South Norwood... Please 2014. show concern for the health and well being of us, your locals. Proposals to meet the needs of the borough, improve the quality in provision, and meet unmet and future demand have arisen from an analysis of both need and the opportunity to develop provision to cater for the unmet demand in the south of the borough.

The Core Strategy will not include policies for site specific facilities unless there are strategic implications. The Core Strategy will set out general policies related to co-located community facilities (including swimming pools and leisure centres). Site specific policies or detailed community facilities policies shall be dealt with by the Site Allocations DPD and Development Management DPD. The valuable role of Purley Pool in providing swimming facilities and a learning environment for Purley and adjoining areas is understood. The pool needs refurbishment or in the medium term replacement. The pool is to be refurbished in the short term with commitment from the council to keep it open until 2014.

Proposals to meet the needs of the borough, improve the quality in provision, and meet unmet and future demand have arisen from an analysis of both need and the opportunity to develop provision to cater for the unmet demand in the south of the borough.

The Core Strategy will not include policies for site specific facilities unless there are strategic implications. The Core Strategy will set out general policies related to co-located community facilities (including swimming pools and leisure centres). Site specific policies or detailed community facilities policies shall be dealt with by the Site Allocations DPD and Development Management DPD. I am writing to register my view that Purley The valuable role of Purley Pool Mr Gordon Griffin Swimming Pool must be kept open, and must in providing swimming facilities be part of the Council's core strategy for the and a learning environment for Observation foreseeable future. It is the only public Purley and adjoining areas is Noted – To be Reviewed swimming facility in the south of the Borough. understood. The pool needs Were it not for Purley, I would have to travel to refurbishment or in the medium Oxted, into a different council jurisdiction to term replacement. The pool is swim.I am fortunate enough to be able to to be refurbished in the short drive, but anyoneunfortunate enough to be term with commitment from the reliant on public transport would be without council to keep it open until any viably reachable public pool South of 2014. Croydon without Purley Pool. Swimming is a vital part of health and fitness, and Croydon Council need to recognise this and fund it appropriately. Proposals to meet the needs of the borough, improve the quality in provision, and meet unmet and future demand have arisen from an analysis of both need and the opportunity to develop provision to cater for the unmet demand in the south of the borough.

The Core Strategy will not include policies for site specific facilities unless there are strategic implications. The Core Strategy will set out general policies related to co-located community facilities (including swimming pools and leisure centres). Site specific policies or detailed community facilities policies shall be dealt with by the Site Allocations DPD and Development Management DPD. I understand that the Council is preparing a The valuable role of Purley Pool Imogen Smith core strategy document which will include a in providing swimming facilities review of Leisure and Sports facilities in and a learning environment for Objection Croydon. I and my family think that it is Purley and adjoining areas is Noted essential that the swimming pool remains understood. The pool needs open in Purley. Because of it's excellent refurbishment or in the medium transport links with all otherwards in the south term replacement. The pool is of the borough, Purley is the ideal location to to be refurbished in the short suit the greatest number of people easily. I term with commitment from the understand that it serves 250,000 customers council to keep it open until per year and is used by 11 local schools for 2014. swimming lessons, this is aside from all the charities that use it for fundraising purposes. Proposals to meet the needs of In the runup to the London Olympics and the borough, improve the quality when health is so high a priority on the in provision, and meet unmet national agenda, it would seem a false and future demand have arisen economy to cease to provide a facility capable from an analysis of both need of providing health benefits to so many. and the opportunity to develop Personally, my initial decision to live in Purley provision to cater for the unmet was influenced by the presence of the pool demand in the south of the which I use twice a week, as it provides the borough. exercise and strengthening which is necessary for my (physically tiring) job. My The Core Strategy will not family also use it regularly for relaxation and include policies for site specific exercise. facilities unless there are strategic implications. The Core Strategy will set out general policies related to co-located community facilities (including swimming pools and leisure centres). Site specific policies or detailed community facilities policies shall be dealt with by the Site Allocations DPD and Development Management DPD. We urge Croydon Council to retain the The valuable role of Purley Pool Mr Peter Elfer existing Purley Swimming Pool or build a new in providing swimming facilities one. We have lived in Croydon for over 50 and a learning environment for Objection years and our parents, us, our children and Purley and adjoining areas is Noted grandchildren have all used Croydon understood. The pool needs Swimming Pools starting with the Scarbrook refurbishment or in the medium Road one many years ago. Do not let CC cut term replacement. The pool is the pool in Purley - it is a life line for tens of to be refurbished in the short thousands of residents and a life line for the term with commitment from the South Croydon Community. Â council to keep it open until 2014.

Proposals to meet the needs of the borough, improve the quality in provision, and meet unmet and future demand have arisen from an analysis of both need and the opportunity to develop provision to cater for the unmet demand in the south of the borough.

The Core Strategy will not include policies for site specific facilities unless there are strategic implications. The Core Strategy will set out general policies related to co-located community facilities (including swimming pools and leisure centres). Site specific policies or detailed community facilities policies shall be dealt with by the Site Allocations DPD and Development Management DPD. I understand that I should write to you to voice The valuable role of Purley Pool Ian Thomas my wishes with regard to the Core Strategy in providing swimming facilities Document and my particular interest is the and a learning environment for Observation swimming pool in Purley. I use the pool three Purley and adjoining areas is Noted times a week and my family also try to get understood. The pool needs along once a week. It is obvious to any regular refurbishment or in the medium user how important this facility is and I am term replacement. The pool is aware that it is used by at least ten schools to be refurbished in the short and various clubs. There is nothing term with commitment from the fundamentally wrong with the pool at Purley - council to keep it open until it definitely struggles to get enough funding 2014. and consequently might appear a little tired - for instance the lockers have been short of Proposals to meet the needs of keys for months, if not years, but the pool the borough, improve the quality itself works .That's all we need, really. Plans in provision, and meet unmet to close this well used facility are ludicrous. and future demand have arisen Surely a pool if built at the Waddon site should from an analysis of both need be in addition to the pool at Purley to serve a and the opportunity to develop different set of customers (perhaps some of provision to cater for the unmet those who would have used the Scarbrook demand in the south of the Road pool had that not been demolished in borough. favour of flats, instead of the promised re build). The Waddon site is on a busy junction The Core Strategy will not and is not well placed for people living in the include policies for site specific south of the borough, especially those who do facilities unless there are not drive. strategic implications. The Core Strategy will set out general policies related to co-located community facilities (including swimming pools and leisure centres). Site specific policies or detailed community facilities policies shall be dealt with by the Site Allocations DPD and Development Management DPD. As a regular early bird swimmer at the pool, I The valuable role of Purley Pool Francine Gee really believe that this is necessary for the in providing swimming facilities health of so many older people (and younger and a learning environment for Objection ones!) for the pool to be retained in the centre Purley and adjoining areas is Noted of Purley. The pool may not be beautiful, but it understood. The pool needs fulfils a basic need, and is easily accessible - refurbishment or in the medium an integral part of what makes Purley a nice term replacement. The pool is place to live. If there is not a pool near enough to be refurbished in the short to get to it will have a deleterious effect on the term with commitment from the wellbeing of many Purley and Coulson council to keep it open until residents; I consider a swimming pool 2014. essential for the people of the area for healthy activity. Theyalso do not want to add to the Proposals to meet the needs of traffic in the area, or extend their carbon the borough, improve the quality footprints by driving further. Purley is the hub in provision, and meet unmet of the South of the borough, having good and future demand have arisen transport links serving many people, including from an analysis of both need the 250,000 customers a year, consisting of a and the opportunity to develop wide age range who make good use of the provision to cater for the unmet pool. (This includes those children of primary demand in the south of the age, who have to learn to swim to comply with borough. the national curriculum). The local Councillors all support a pool in Purley and all the political The Core Strategy will not parties supported the need for a pool in the include policies for site specific future of Purley. A pool is supported by the facilities unless there are doctors in our area and is well used by local strategic implications. The Core schools and by the disabled. 11 local schools Strategy will set out general use the pool. Personally, swimming helps my policies related to co-located arthritis to remain in abeyance, and enables community facilities (including me not to take medication, thus saving the swimming pools and leisure health service money and time... I should also centres). Site specific policies or like to express my surprise that in this time of detailed community facilities CSR it is not considered economical to retain policies shall be dealt with by a building, including a car park, which adds to the Site Allocations DPD and the viability of our community. Development Management DPD. Detailed car parking policies will be addressed through the forthcoming Development Management and Site Allocations Development Plan Documents. I have heard that Purley Pool may be about to The valuable role of Purley Pool Nicki England close down and wanted to give my reasons in providing swimming facilities Resident why it should remain open.  My children and a learning environment for Observation attend Christ Church C of E Primary School, Purley and adjoining areas is Noted which is situated a stones throw from the pool understood. The pool needs and is used by many of the classes, as part of refurbishment or in the medium the national curriculum. Actually, I believe that term replacement. The pool is it is government policy that every child should to be refurbished in the short be able to swim at least 25 metres, by the term with commitment from the time they reach year 7. Without the pool, this council to keep it open until would not happen for a large number of 2014. children, with their only access to swimming lessons being the ones offered by the school at Purley Pool.  As a local resident, I also take my children ‘leisure' swimming at Proposals to meet the needs of Purley Pool and as we only live a mile away, the borough, improve the quality we cycle there, providing health benefits and in provision, and meet unmet fun to the whole family.  There are few and future demand have arisen enough leisure facilities in Purley, without from an analysis of both need losing the pool - please ensure that it is kept and the opportunity to develop open!! provision to cater for the unmet demand in the south of the borough.

The Core Strategy will not include policies for site specific facilities unless there are strategic implications. The Core Strategy will set out general policies related to co-located community facilities (including swimming pools and leisure centres). Site specific policies or detailed community facilities policies shall be dealt with by the Site Allocations DPD and Development Management DPD. I understand that a 'core strategy' document is The valuable role of Purley Pool Mr John Bailey currently being prepared which will, amongst in providing swimming facilities Resident other things, make a recommendation and a learning environment for Objection concerning the future of Purley Swimming Purley and adjoining areas is Noted Pool. Could I here make the statqement that I understood. The pool needs strongly advise that closure of Purley refurbishment or in the medium Swimming Pool should not be considered as term replacement. The pool is an option. I state this both as a frequent user to be refurbished in the short of the pool myself (several times per week on term with commitment from the average) and also on behalf of the many other council to keep it open until users of the pool in the borough. Although I 2014. live in Waddon ward, the excellent public transport links make it easy for me and others Proposals to meet the needs of to reach the pool quickly without using a car. the borough, improve the quality The pool also has very good transport links in provision, and meet unmet with areas to the south of the borough. I and future demand have arisen should also be grateful if you could let me from an analysis of both need know when the final version of the core and the opportunity to develop strategy document will be released, and provision to cater for the unmet whether it will be available on the Croydon demand in the south of the Council website? borough.

The Core Strategy will not include policies for site specific facilities unless there are strategic implications. The Core Strategy will set out general policies related to co-located community facilities (including swimming pools and leisure centres). Site specific policies or detailed community facilities policies shall be dealt with by the Site Allocations DPD and Development Management DPD. Will you please register my interest in The valuable role of Purley Pool Mr Ken Whittick maintaining a Swimming pool in Purley and for in providing swimming facilities the retention of theMulti Storey Car Park orcar and a learning environment for Objection parking of similar capacity to that which we Purley and adjoining areas is Noted have at the moment. Purley is a major understood. The pool needs transport link for the pool and the car park refurbishment or in the medium serves Purley workers, commuters and term replacement. The pool is shoppers and is very well used as is the pool. to be refurbished in the short Both facilities should be at the centre of the term with commitment from the Purley strategy. council to keep it open until 2014.

Proposals to meet the needs of the borough, improve the quality in provision, and meet unmet and future demand have arisen from an analysis of both need and the opportunity to develop provision to cater for the unmet demand in the south of the borough.

The Core Strategy will not include policies for site specific facilities unless there are strategic implications. The Core Strategy will set out general policies related to co-located community facilities (including swimming pools and leisure centres). Site specific policies or detailed community facilities policies shall be dealt with by the Site Allocations DPD and Development Management DPD. Detailed car parking policies will be addressed through the forthcoming Development Management and Site Allocations Development Plan Documents. I understand that you are considering the core The valuable role of Purley Pool Fiona Corby strategy for Croydon and Purley which will in providing swimming facilities include items such as Purley Pool. I am a and a learning environment for Observation volunteer swimming teacher at Purley Pool Purley and adjoining areas is Noted and help teach local primary school children to understood. The pool needs swim. At present the primary children only refurbishment or in the medium receive three terms of swimming for their term replacement. The pool is entire primary school life. This is not enough to be refurbished in the short and without Purley Pool I doubt whether they term with commitment from the would actually swim at all as the school will council to keep it open until not be able to fund transport. We have an 2014. increasing amount of children in the area who do not attend any form of swimming lessons and indeed some have never been in a pool when they receive their first lesson from the Proposals to meet the needs of school. Obviously this means that we still the borough, improve the quality have children who are unable to swim by the in provision, and meet unmet time they are 11 and the statistics are below and future demand have arisen the national average even with Purley Pool from an analysis of both need within walking distance. It is essential that and the opportunity to develop Purley Pool remains open and that we can, at provision to cater for the unmet least, continue to give some of these children demand in the south of the safety skillsin order that they can be safer borough. around the water. As a borough we ought to be ensuring that all children learn to swim 25m before they leave primary school which isnt happening at the moment. On top of this The Core Strategy will not there are alot of local residents particularly include policies for site specific pensioners who can enjoy Purley Pool's facilities unless there are facilities and without this they would not be strategic implications. The Core able to keep fit. Strategy will set out general policies related to co-located community facilities (including swimming pools and leisure centres). Site specific policies or detailed community facilities policies shall be dealt with by the Site Allocations DPD and Development Management DPD. I totally agree with and support the need for a The valuable role of Purley Pool Mr Trevor Olliver swimming pool in Purley. It is absolutely in providing swimming facilities essential for recreational,medical, and a learning environment for Objection leisure,therapeutic and other activities.It is a Purley and adjoining areas is Noted disgracethat a town the size of Croydon with a understood. The pool needs population of 350,00 plus inhabitants does not refurbishment or in the medium have one.This should be urgently rectified. term replacement. The pool is to be refurbished in the short term with commitment from the council to keep it open until 2014.

Proposals to meet the needs of the borough, improve the quality in provision, and meet unmet and future demand have arisen from an analysis of both need and the opportunity to develop provision to cater for the unmet demand in the south of the borough.

The Core Strategy will not include policies for site specific facilities unless there are strategic implications. The Core Strategy will set out general policies related to co-located community facilities (including swimming pools and leisure centres). Site specific policies or detailed community facilities policies shall be dealt with by the Site Allocations DPD and Development Management DPD. I write to oppose the planned closure of Purley The valuable role of Purley Pool Judith Cosaitis pool due to detrimental effects it will have on in providing swimming facilities Resident myself and my family. Â This pool is the only and a learning environment for Observation local authority provision of its kind in the south Purley and adjoining areas is Noted of the borough and the only one myself and understood. The pool needs my family can use with out having to travel refurbishment or in the medium unacceptable distances, or pay increased out term replacement. The pool is of borough fees to facilities located within to be refurbished in the short another local authority. Aside from the health term with commitment from the and recreational benefits to my family, I council to keep it open until particularly support keeping the pool open 2014. because of the provision of a teaching pool which is instrumental in allowing children to grow and gain confidence in the essential skill of swimming. It is also used by several Proposals to meet the needs of schools in the area to support the needs of the the borough, improve the quality national curriculum. Â I would appreciate in provision, and meet unmet being kept informed of timescales and and future demand have arisen progress in this matter. from an analysis of both need and the opportunity to develop provision to cater for the unmet demand in the south of the borough.

The Core Strategy will not include policies for site specific facilities unless there are strategic implications. The Core Strategy will set out general policies related to co-located community facilities (including swimming pools and leisure centres). Site specific policies or detailed community facilities policies shall be dealt with by the Site Allocations DPD and Development Management DPD. i am writing to you with regards to the future of The valuable role of Purley Pool Mr Howard Marsh the Purley swimming pool. The Purley in providing swimming facilities Resident swimming pool is essential for the local and a learning environment for Objection community and must be protected. I take my Purley and adjoining areas is Noted children there every week, also together understood. The pool needs withmy husband we enjoy our regular refurbishment or in the medium swimming there. The pool serves many term replacement. The pool is people of all ages - babies, youngsters and to be refurbished in the short elderly. Swimming is a great way to keep fit term with commitment from the and unwind after work or during the weekend. council to keep it open until Also I hope that along with the pool the car 2014. park will be preserved as it is quite convinient to have this parking facility right next to the Proposals to meet the needs of pool. I am sure many peope share my view the borough, improve the quality that the preservation of the pool is a top in provision, and meet unmet priority for the people in the local area, I hope and future demand have arisen this will bereflected in the Core Strategy from an analysis of both need document. and the opportunity to develop provision to cater for the unmet demand in the south of the borough.

The Core Strategy will not include policies for site specific facilities unless there are strategic implications. The Core Strategy will set out general policies related to co-located community facilities (including swimming pools and leisure centres). Site specific policies or detailed community facilities policies shall be dealt with by the Site Allocations DPD and Development Management DPD. Detailed car parking policies will be addressed through the forthcoming Development Management and Site Allocations Development Plan Documents. My children and I are active users of purley The valuable role of Purley Pool N Townend pool and consider a swimming pool essential in providing swimming facilities for the people of purley for healthy activity. and a learning environment for Observation Purley is the hub of the South of the borough, Purley and adjoining areas is Noted having good transport links serving the above understood. The pool needs wards. The pool serves 250000 customers a refurbishment or in the medium year, and our young people make good use of term replacement. The pool is the pool. The local Councillors all support a to be refurbished in the short pool in Purley and all the political parties term with commitment from the supported the need for a pool in the future of council to keep it open until Purley. A pool is supported by the doctors in 2014. our area and is well used by local schools and by the disabled. 11 local schools use the pool There is plenty of support to keep this pool open Proposals to meet the needs of the borough, improve the quality in provision, and meet unmet and future demand have arisen from an analysis of both need and the opportunity to develop provision to cater for the unmet demand in the south of the borough.

The Core Strategy will not include policies for site specific facilities unless there are strategic implications. The Core Strategy will set out general policies related to co-located community facilities (including swimming pools and leisure centres). Site specific policies or detailed community facilities policies shall be dealt with by the Site Allocations DPD and Development Management DPD. I consider a swimming pool essential for the The valuable role of Purley Pool Mr Steve Vanstone people of the area for healthy activity. Purley in providing swimming facilities is the hub of the South of the borough, having and a learning environment for Objection good transport links serving South Croydon, Purley and adjoining areas is Noted and beyond. The pool serves 250000 understood. The pool needs customers a year, and our young people, refurbishment or in the medium including my daughter, make good use of the term replacement. The pool is pool. Â Not everyone can afford gym to be refurbished in the short membership to use private pools and the only term with commitment from the gym in Purley with a pool is LA Fitness which council to keep it open until has an inadequate, small pool which is 2014. frequently out of order. Â Loss of this valuable resource would be the final nail in the Proposals to meet the needs of coffin for Purley town centre. the borough, improve the quality in provision, and meet unmet and future demand have arisen from an analysis of both need and the opportunity to develop provision to cater for the unmet demand in the south of the borough.

The Core Strategy will not include policies for site specific facilities unless there are strategic implications. The Core Strategy will set out general policies related to co-located community facilities (including swimming pools and leisure centres). Site specific policies or detailed community facilities policies shall be dealt with by the Site Allocations DPD and Development Management DPD. I am writing to you today with regards to The valuable role of Purley Pool Vicky Geary Purley swimming pool and the importance of in providing swimming facilities keeping it open for the local community. I am and a learning environment for Observation a very regular user of Purley pool and find its Purley and adjoining areas is Noted location fantastic. I live in Kenley, work in understood. The pool needs Croydon and swim twice a week on my way refurbishment or in the medium home. I wouldn't want Purley pool to close term replacement. The pool is because personally I couldn't find another to be refurbished in the short descent length pool in the local area that suits term with commitment from the my needs and fits in with my schedule. Most council to keep it open until private gyms don't supply swimming and if 2014. they do the pool length is far too short to get a proper swim. I also find the car park that forms part of the complex invaluable. Surely, it is these kind of amenities that are required by Proposals to meet the needs of the local people and especially the local the borough, improve the quality schools to make sure people have access to in provision, and meet unmet sports. Swimming in my opinion is one of the and future demand have arisen best sports for all generations and for the from an analysis of both need body. It takes the load bearing strain away and the opportunity to develop from muscles, ligaments and bones and is a provision to cater for the unmet fantastic aerobic workout. I hope this email will demand in the south of the be considered when decided the future of borough. Purley Pool.

The Core Strategy will not include policies for site specific facilities unless there are strategic implications. The Core Strategy will set out general policies related to co-located community facilities (including swimming pools and leisure centres). Site specific policies or detailed community facilities policies shall be dealt with by the Site Allocations DPD and Development Management DPD. I am writing this email because I feel very The valuable role of Purley Pool Anne Davis strongly that a swimming pool in Purley is in providing swimming facilities Resident essential for the residents of both Purley and and a learning environment for Objection surrounding areas. As a back sufferer I know Purley and adjoining areas is Noted the health benefits of swimming, especially understood. The pool needs both for the elderly who in many cases can refurbishment or in the medium not drive and for young people who often don't term replacement. The pool is get enough exercise. If a local facility like that to be refurbished in the short closes, a lot of people will miss out on a term with commitment from the briliant form of exercise. It is also important for council to keep it open until the future of Purley that a varied selection of 2014. facilities is kept and added to, to get people in to the town and using it for shopping etc. Proposals to meet the needs of Parking must be another important factor. It the borough, improve the quality must be easy and cheap, to help bring people in provision, and meet unmet into the town and using both the pool and the and future demand have arisen shopping, which hopefully will get even more from an analysis of both need interesting and varied. I regret the closure of and the opportunity to develop Purley Cinema and wish a small cinema could provision to cater for the unmet be part of the plan, showing interesting and demand in the south of the different films for both children and adults. borough.

The Core Strategy will not include policies for site specific facilities unless there are strategic implications. The Core Strategy will set out general policies related to co-located community facilities (including swimming pools and leisure centres). Site specific policies or detailed community facilities policies shall be dealt with by the Site Allocations DPD and Development Management DPD. Detailed car parking policies will be addressed through the forthcoming Development Management and Site Allocations Development Plan Documents.

In relation to cultural activity, the Council is seeking to establish a creative/cultural industries Enterprise Centre wihtin Purley District Centre to support this sector. I understand a strategy for Purley is being The valuable role of Purley Pool Rachel Garnett developed.Above all please can the swimming in providing swimming facilities pool remain. It is a fantastic resource and my and a learning environment for Objection family use it a great deal. I go there several Purley and adjoining areas is Noted times a week and being able to swim has understood. The pool needs greatly helped my pregnancy asI was advised refurbishment or in the medium to carry on swimming by both my doctor and term replacement. The pool is midwife. My daughter has swimming lessons to be refurbished in the short there too. My mother in law who is in her 80's term with commitment from the regularly goes as well. I wil be taking the baby council to keep it open until there. I know many local schools use it and it 2014. is often very busy which shows how popular it is with locals. Many of us can go there before Proposals to meet the needs of work something that would not be possible if the borough, improve the quality the pool was no longer in Purley as I for one, in provision, and meet unmet can be on a train into London within minutes and future demand have arisen of leaving the pool. Please, please save the from an analysis of both need pool. and the opportunity to develop provision to cater for the unmet demand in the south of the borough.

The Core Strategy will not include policies for site specific facilities unless there are strategic implications. The Core Strategy will set out general policies related to co-located community facilities (including swimming pools and leisure centres). Site specific policies or detailed community facilities policies shall be dealt with by the Site Allocations DPD and Development Management DPD. I urge you to keep Purley pool open. Along The valuable role of Purley Pool Peta Barber with many others I use it regularly, 3 times at in providing swimming facilities least per week, not only for the pleasure of an and a learning environment for Observation early morning swim but also for medical Purley and adjoining areas is Noted reasons. Doctors in the area will of course understood. The pool needs also support the pool remaining open. It is an refurbishment or in the medium essential centre used by people of all ages term replacement. The pool is and abilitiesforhealth, fitness and recreation. It to be refurbished in the short is essential that itremains open. The pool is term with commitment from the also used by many local schools enabling council to keep it open until pupils to have localswimming lessons and 2014. totake part in swimming events. Therefore I urge you please to recommend and give your support for Purley Pool to remain open. I would also like you to recommend that we Proposals to meet the needs of keep the car park adjacent to the pool open. the borough, improve the quality in provision, and meet unmet and future demand have arisen from an analysis of both need and the opportunity to develop provision to cater for the unmet demand in the south of the borough.

The Core Strategy will not include policies for site specific facilities unless there are strategic implications. The Core Strategy will set out general policies related to co-located community facilities (including swimming pools and leisure centres). Site specific policies or detailed community facilities policies shall be dealt with by the Site Allocations DPD and Development Management DPD. As a resident of Purley and as a Parent with The valuable role of Purley Pool Shamini Sathiyathasan children attending Christchurch Primary in providing swimming facilities Resident school I ask that you do not close Purley and a learning environment for Objection Swimming Pool. Travelling further away will Purley and adjoining areas is Noted take more time out of the school day when understood. The pool needs children could be engaged in other learning. refurbishment or in the medium And as a resident why shouldn't purley have a term replacement. The pool is swimming pool, where would parents spent to be refurbished in the short some quality time with their children in this term with commitment from the hard financial times. I honestly belive that LA council to keep it open until should rethink this plan. 2014.

Proposals to meet the needs of the borough, improve the quality in provision, and meet unmet and future demand have arisen from an analysis of both need and the opportunity to develop provision to cater for the unmet demand in the south of the borough.

The Core Strategy will not include policies for site specific facilities unless there are strategic implications. The Core Strategy will set out general policies related to co-located community facilities (including swimming pools and leisure centres). Site specific policies or detailed community facilities policies shall be dealt with by the Site Allocations DPD and Development Management DPD. I am a regular user of the purley pool for The valuable role of Purley Pool Mrs Mukta Bhatia nearly 2 years.I consider a swimming pool in providing swimming facilities essential for the people of the area for healthy and a learning environment for Observation activity.Purley is the hub of the South of the Purley and adjoining areas is Noted borough, having good transport links serving understood. The pool needs the above wards. The pool serves 250000 refurbishment or in the medium customers a year, and our young people term replacement. The pool is make good use of the pool. Â Â The local to be refurbished in the short Councillors all support a pool in Purley and all term with commitment from the the political parties supported the need for a council to keep it open until pool in the future of Purley. A pool is 2014. supported by the doctors in our area and is well used by local schools and by the disabled. 11 local schools use the pool. Â Â It will be a disaster for the community if you Proposals to meet the needs of were considering closing this pool. Â the borough, improve the quality in provision, and meet unmet and future demand have arisen from an analysis of both need and the opportunity to develop provision to cater for the unmet demand in the south of the borough.

The Core Strategy will not include policies for site specific facilities unless there are strategic implications. The Core Strategy will set out general policies related to co-located community facilities (including swimming pools and leisure centres). Site specific policies or detailed community facilities policies shall be dealt with by the Site Allocations DPD and Development Management DPD. I am writing with reference to the Core The valuable role of Purley Pool Rachel Cornish Strategy Document that you are preparing in in providing swimming facilities Resident relation to Croydon and Purley and the and a learning environment for Observation Leisure and Sports facilities. I believe it is Purley and adjoining areas is Noted essential to have swimming and leisure centre understood. The pool needs facilities in the south of the borough. I am an refurbishment or in the medium activemember of thePurley centre and my two term replacement. The pool is children both had swimming lessons at Purley to be refurbished in the short pooland continue to use its facilities. My eldest term with commitment from the daughter is looking forward tojoining the gym council to keep it open until when she is older. For my family and for a 2014. large number of people in the area, both young and old, a swimming pool is essential for healthy activity.As well as teaching young people to swim swimmingis an ideal form of Proposals to meet the needs of exercise for disabled groups and the older the borough, improve the quality generation. It already serves 250,000 in provision, and meet unmet customers a year and if developed could and future demand have arisen become a centre of community activity and from an analysis of both need services, a focal pointfor the people in the and the opportunity to develop southern part of the borough. Purley or provision to cater for the unmet Coulsdon both have excellent public transport demand in the south of the links and I would like to see borough. considerationgiven to both when a decisions need to be made about any new leisure and swimming facility. Coulsdon has been greatly enhanced with a variety of shops and The Core Strategy will not businesses now in place and a new include policies for site specific community swimming pool or leisure centre facilities unless there are would addlife and help supportthe area. strategic implications. The Core Purley is now dominated by Tesco and Strategy will set out general smaller businesses have been squeezed out. policies related to co-located There is very little else to offer the leisure community facilities (including centre customer and I would strongly ask the swimming pools and leisure Council to look at Coulsdon as a viable centres). Site specific policies or alternative location. detailed community facilities policies shall be dealt with by the Site Allocations DPD and Development Management DPD. I understand that a review of the Purley Pool The valuable role of Purley Pool Mr Greg Edwards is currently underway. I want to make it very in providing swimming facilities clear that myself and family are regular users and a learning environment for Observation and that I consider a swimming pool essential Purley and adjoining areas is Noted for the people of the area for healthy activity. I understood. The pool needs am keen to make this view known as you go refurbishment or in the medium through your decision making process. term replacement. The pool is to be refurbished in the short term with commitment from the council to keep it open until 2014.

Proposals to meet the needs of the borough, improve the quality in provision, and meet unmet and future demand have arisen from an analysis of both need and the opportunity to develop provision to cater for the unmet demand in the south of the borough.

The Core Strategy will not include policies for site specific facilities unless there are strategic implications. The Core Strategy will set out general policies related to co-located community facilities (including swimming pools and leisure centres). Site specific policies or detailed community facilities policies shall be dealt with by the Site Allocations DPD and Development Management DPD. I understand you are preparing the above The valuable role of Purley Pool Mr Ray Morriss document on Purley. As you are no doubt in providing swimming facilities Resident aware Purley has been going "downhill", for and a learning environment for Objection want of a better way of putting it, for some Purley and adjoining areas is Noted considerable time now. Ihave nowheard understood. The pool needs thatthe local swimming poolmight beunder refurbishment or in the medium threat of closure and sincerely hope this is not term replacement. The pool is the case. It is well used and therefore an to be refurbished in the short excellent source of leisure and exercisefor term with commitment from the many. Please leave it alone or indeed, council to keep it open until improve it, if at all possible. 2014.

Proposals to meet the needs of the borough, improve the quality in provision, and meet unmet and future demand have arisen from an analysis of both need and the opportunity to develop provision to cater for the unmet demand in the south of the borough.

The Core Strategy will not include policies for site specific facilities unless there are strategic implications. The Core Strategy will set out general policies related to co-located community facilities (including swimming pools and leisure centres). Site specific policies or detailed community facilities policies shall be dealt with by the Site Allocations DPD and Development Management DPD. i am writing to you with regards to the future of The valuable role of Purley Pool Irina Berard the Purley swimming pool. The Purley in providing swimming facilities Resident swimming pool is essential for the local and a learning environment for Objection community and must be protected. I take my Purley and adjoining areas is Noted children there every week, also together understood. The pool needs withmy husband we enjoy our regular refurbishment or in the medium swimming there. The pool serves many term replacement. The pool is people of all ages - babies, youngsters and to be refurbished in the short elderly. Swimming is a great way to keep fit term with commitment from the and unwind after work or during the weekend. council to keep it open until Also I hope that along with the pool the car 2014. park will be preserved as it is quite convinient to have this parking facility right next to the Proposals to meet the needs of pool. I am sure many peope share my view the borough, improve the quality that the preservation of the pool is a top in provision, and meet unmet priority for the people in the local area, I hope and future demand have arisen this will bereflected in the Core Strategy from an analysis of both need document. and the opportunity to develop provision to cater for the unmet demand in the south of the borough.

The Core Strategy will not include policies for site specific facilities unless there are strategic implications. The Core Strategy will set out general policies related to co-located community facilities (including swimming pools and leisure centres). Site specific policies or detailed community facilities policies shall be dealt with by the Site Allocations DPD and Development Management DPD. Detailed car parking policies will be addressed through the forthcoming Development Management and Site Allocations Development Plan Documents. With regard to the Core Strategy for Purleys' The valuable role of Purley Pool Mr Richard Plummer future, I would like to make known my feelings in providing swimming facilities Resident toward the future of the swimming pool. Â I and a learning environment for Objection believe this to be a very important and integral Purley and adjoining areas is Noted part of the community with many positives; understood. The pool needs schools use, health for the community, refurbishment or in the medium training facilities for athletes, fun for families term replacement. The pool is and many more. The pool is currently used by to be refurbished in the short approx 25,000 customers a year, so this tells term with commitment from the us that this is a viable facility for the future. Â council to keep it open until Without starting to ramble aimlessly, I along 2014. with many friends and colleagues, believe that the pool should very much be part of future Proposals to meet the needs of plans for Purley. the borough, improve the quality in provision, and meet unmet and future demand have arisen from an analysis of both need and the opportunity to develop provision to cater for the unmet demand in the south of the borough.

The Core Strategy will not include policies for site specific facilities unless there are strategic implications. The Core Strategy will set out general policies related to co-located community facilities (including swimming pools and leisure centres). Site specific policies or detailed community facilities policies shall be dealt with by the Site Allocations DPD and Development Management DPD. I believe that you are currently undertaking a The valuable role of Purley Pool Jo Moore core strategy review in regard to Croydon and in providing swimming facilities Globe Business Purley, and that this will cover leisure facilities. and a learning environment for Publishing As a resident of Purley I wanted to express Purley and adjoining areas is Objection my view on the need to maintain (and ideally understood. The pool needs Noted improve) Purley Leisure Centre as part of this refurbishment or in the medium strategy.  I have lived in Purley for three term replacement. The pool is years now and find the leisure centre in the to be refurbished in the short middle of the town essential. I use the pool term with commitment from the and gym there regularly as it offers an council to keep it open until affordable and convenient option (much more 2014. so than the two private gym facilities in the area, both of which are out of the centre of Proposals to meet the needs of town and are far more expensive). As a non- the borough, improve the quality driver who works in Central London, having a in provision, and meet unmet leisure centre that is easy to get to is vital. The and future demand have arisen staff are very friendly and the facilities, while from an analysis of both need in need of a bit of refurbishment, are good and and the opportunity to develop provide everything that I need.  In my block provision to cater for the unmet of 40 flats just a short walk away, there are demand in the south of the many families with young children who I know borough. use the pool on a regular basis and who find it invaluable - it is very easy to underestimate The Core Strategy will not how important it is to have a leisure centre include policies for site specific that is easy to get to and does not require facilities unless there are driving or a considerable journey on public strategic implications. The Core transport (as I believe the proposed Strategy will set out general alternatives to the Purley Leisure Centre policies related to co-located would do). community facilities (including swimming pools and leisure centres). Site specific policies or detailed community facilities policies shall be dealt with by the Site Allocations DPD and Development Management DPD. Dear Mr Carlisle I wish to add my voice to the The valuable role of Purley Pool Mr Douglas Conn saving of Purley swimming pool (and in providing swimming facilities associated facilities) The pool, though dated a and a learning environment for Observation little bit, is in very good condition and a Purley and adjoining areas is Noted revamp of the changing facilities is really all it understood. The pool needs needs to last another 30 years Purley is refurbishment or in the medium ideally placed for this facility - it has excellent term replacement. The pool is transport links from all over the area - I travel to be refurbished in the short in from Croydon each day to use its pool, and term with commitment from the my walk back is good for me as well. Whilst in council to keep it open until Purley I sometimes use the shops there 2014. though my primary shopping is done in Croydon. In the early morning I, and many people my age and older, use it to endeavour to stay fit - saving the NHS and council (care Proposals to meet the needs of homes) money. Purley station enables early the borough, improve the quality morning swimming/exercising for some in provision, and meet unmet commuters. The proposal that the pool in and future demand have arisen Waddon, with few transport links (which could from an analysis of both need encourage more vehicles onto the road and and the opportunity to develop there is little parking facilities there either), provision to cater for the unmet should replace Purley pool is ill conceived. I demand in the south of the hope it will attract more people to swim borough. particularly from its own area, but it will only aid the people who travel to Purley from the Waddon direction - the other directions Purley serves will be less facilitated. Waddon station The Core Strategy will not is not so useful a connection as is Purley include policies for site specific station. Also I am told that the pool serves facilities unless there are 250000 customers a year, and our young strategic implications. The Core people make good use of the pool. Further Strategy will set out general that the local Councillors all support a pool in policies related to co-located Purley and all the political parties supported community facilities (including the need for a pool in the future of Purley. A swimming pools and leisure pool is supported by the doctors in our area centres). Site specific policies or and is well used by local schools and by the detailed community facilities disabled. 11 local schools use the pool.  policies shall be dealt with by Yours faithfully Douglas Conn  the Site Allocations DPD and Development Management DPD. I think the swimming pool in your specific area The valuable role of Purley Pool Mr Josh Dunnell is vital since it is the only one around, in providing swimming facilities swimming is a very healthy activity as you and a learning environment for Objection must know, and it would be a shame for all the Purley and adjoining areas is Noted people in the area to not have the facilities understood. The pool needs that could be possible for them to have. The refurbishment or in the medium pool serves over 250000 people a year andt term replacement. The pool is hen if you shut down the pool then all the to be refurbished in the short outcome in money would just disapear for the term with commitment from the staff, and then the staff would have to get council to keep it open until different jobs and then that could lead to 2014. difficulties. The disabled love to use the pool and swimming is one of the only things they Proposals to meet the needs of can do, they cant do many other sports, such the borough, improve the quality as football for instance, swimming is lovely for in provision, and meet unmet the whole public and they would be a bit and future demand have arisen devistated if it could'nt be possible no more. i from an analysis of both need hope this has sent a message through and and the opportunity to develop you will understand the dialema. provision to cater for the unmet demand in the south of the borough.

The Core Strategy will not include policies for site specific facilities unless there are strategic implications. The Core Strategy will set out general policies related to co-located community facilities (including swimming pools and leisure centres). Site specific policies or detailed community facilities policies shall be dealt with by the Site Allocations DPD and Development Management DPD. We are in full support of Purley pool being The valuable role of Purley Pool Mrs Val Baylie kept open as it is the only pool in the in providing swimming facilities immediate area and is essential for both and a learning environment for Observation young and old who in particular use this as an Purley and adjoining areas is Noted excellent form of exercise and of course it is understood. The pool needs so important that young people learn to swim. refurbishment or in the medium Purley has easy access either by road or train term replacement. The pool is and makes it very convenient for people in all to be refurbished in the short parts of the borough to get there. As an term with commitment from the addition the car park provides parking right in council to keep it open until the heart of Purley and that is the only public 2014. car park that we have. PLEASE KEEP THE POOL OPEN.

Proposals to meet the needs of the borough, improve the quality in provision, and meet unmet and future demand have arisen from an analysis of both need and the opportunity to develop provision to cater for the unmet demand in the south of the borough.

The Core Strategy will not include policies for site specific facilities unless there are strategic implications. The Core Strategy will set out general policies related to co-located community facilities (including swimming pools and leisure centres). Site specific policies or detailed community facilities policies shall be dealt with by the Site Allocations DPD and Development Management DPD. Iam in support of swimming facilities The valuable role of Purley Pool Mr Ronald Harding continuing in the development of Purley for in providing swimming facilities the following reasons :-  0 Location - is at and a learning environment for Objection the centre of both the road and public Purley and adjoining areas is Noted transport systems for the southern quarter of understood. The pool needs the borough  0 Existing pool is well used by refurbishment or in the medium schools, youngsters, adults & senior citizens term replacement. The pool is  0 I have used the pool for the past 15 years to be refurbished in the short and was of a great help when recovering from term with commitment from the heart surgery in 2003 and my subsequent council to keep it open until fitness.  0 As the population of Purley 2014. increases it is necessary to maintain, among others, this type of facility for the cohesion and Proposals to meet the needs of balance of the community as a whole  the borough, improve the quality in provision, and meet unmet and future demand have arisen from an analysis of both need and the opportunity to develop provision to cater for the unmet demand in the south of the borough.

The Core Strategy will not include policies for site specific facilities unless there are strategic implications. The Core Strategy will set out general policies related to co-located community facilities (including swimming pools and leisure centres). Site specific policies or detailed community facilities policies shall be dealt with by the Site Allocations DPD and Development Management DPD. I am writing to request that Purley pool The valuable role of Purley Pool Stephanie Belch remains open. As a parent with two children at in providing swimming facilities ChristChurch school the benefits of having a and a learning environment for Observation pool which the children can walk to is Purley and adjoining areas is Noted enormous. It cuts down the cost for parents understood. The pool needs and for many families school swimming refurbishment or in the medium lessons arethe only they have. I believe term replacement. The pool is swimmming is an essential life skill and every to be refurbished in the short child should be given the opportunity as it term with commitment from the could save their life. As a family we often use council to keep it open until purley pool as it is our local pool. In this age of 2014. increasing obesity it is essential that families remain healthy. Please keep this local amenity open. Proposals to meet the needs of the borough, improve the quality in provision, and meet unmet and future demand have arisen from an analysis of both need and the opportunity to develop provision to cater for the unmet demand in the south of the borough.

The Core Strategy will not include policies for site specific facilities unless there are strategic implications. The Core Strategy will set out general policies related to co-located community facilities (including swimming pools and leisure centres). Site specific policies or detailed community facilities policies shall be dealt with by the Site Allocations DPD and Development Management DPD. I am writing with regard to Purley pool, and The valuable role of Purley Pool Jackie Salter the importance of keeping a pool in Purley, for in providing swimming facilities the people in the area to use, in order to keep and a learning environment for Observation healthy. Â Purley is the hub of the South of Purley and adjoining areas is Noted the Borough, with good transport links. The understood. The pool needs local Councillors all support a pool in Purley refurbishment or in the medium and all the political parties supported the need term replacement. The pool is for a pool in the future of Purley. The pool is to be refurbished in the short well used by 11 local schools and by the term with commitment from the disabled. Â I myself swim there four days a council to keep it open until week at 7 a.m.with my 70 year old mother.We 2014. go to keep ourselves fit & healthy. My mother walks with a stick, so finds walking & other exercise difficult. Swimming has been recommended to her by her doctor. My son Proposals to meet the needs of also accesses the gym within the pool building the borough, improve the quality as a young teenager, as it one of a few that in provision, and meet unmet accepts under 16's in the area. Please accept and future demand have arisen my e mail as a record of one local resident, from an analysis of both need that is keen to keep a pool in Purley. and the opportunity to develop provision to cater for the unmet demand in the south of the borough.

The Core Strategy will not include policies for site specific facilities unless there are strategic implications. The Core Strategy will set out general policies related to co-located community facilities (including swimming pools and leisure centres). Site specific policies or detailed community facilities policies shall be dealt with by the Site Allocations DPD and Development Management DPD. I understand the above document is now The valuable role of Purley Pool Dr Harry Reid under consideration. May I urge that the in providing swimming facilities continuation of the Purley swimming pool be and a learning environment for Objection incorporated as an urgent requirement for this Purley and adjoining areas is Noted area of Croydon. I am sure you will be familiar understood. The pool needs with the many reasons to support this: ranging refurbishment or in the medium fromthe pool'scentral location in terms of term replacement. The pool is accessibility either by public or private to be refurbished in the short transport through to its beneficial impact on term with commitment from the community health. A recent survey confirmed council to keep it open until a surprisingly wide level of public support for 2014. the continuation of this facility in this location: neither of the mooted alternatives would be Proposals to meet the needs of equally accessible to less advantaged the borough, improve the quality members of the community. It would seem a in provision, and meet unmet perverse decision to close the pool at the very and future demand have arisen time there is much public concern about from an analysis of both need thelevel of obesity in the population as a and the opportunity to develop whole, and the young in particular. Croydon provision to cater for the unmet should be planning toincreasethe number of demand in the south of the such locations, and to preserve those that borough. already exist. In terms of both cost and the environmental capital cost of creating an The Core Strategy will not alternative pool, there is much to be said for include policies for site specific "making do and mend". I trust you will lend facilities unless there are your support to theincorporation of a strategic implications. The Core continuing facility at Purley into the above Strategy will set out general document, policies related to co-located community facilities (including swimming pools and leisure centres). Site specific policies or detailed community facilities policies shall be dealt with by the Site Allocations DPD and Development Management DPD. Purley Pool essential facility for local The valuable role of Purley Pool Mr Malcolm Cragg people,well used,especially by in providing swimming facilities pensioners,helping to keep them fit and and a learning environment for Observation healthy.I have been swimming there regularly Purley and adjoining areas is Noted since my retirement,and would consider it a understood. The pool needs vital part of the purley center,regards Malcolm refurbishment or in the medium Cragg. term replacement. The pool is to be refurbished in the short term with commitment from the council to keep it open until 2014.

Proposals to meet the needs of the borough, improve the quality in provision, and meet unmet and future demand have arisen from an analysis of both need and the opportunity to develop provision to cater for the unmet demand in the south of the borough.

The Core Strategy will not include policies for site specific facilities unless there are strategic implications. The Core Strategy will set out general policies related to co-located community facilities (including swimming pools and leisure centres). Site specific policies or detailed community facilities policies shall be dealt with by the Site Allocations DPD and Development Management DPD. I am writing to express my support for Purley The valuable role of Purley Pool Mrs Judith Parfitt swimming pool. I feel that it isessential for the in providing swimming facilities people of the local area supplying ahealthy and a learning environment for Objection activity and I need it for physio purposes.It is Purley and adjoining areas is Noted also ideally situated in the south of the understood. The pool needs borough enjoyinggood transport links to other refurbishment or in the medium areas. I believe the pool is used by250,000 term replacement. The pool is customers a year which includes those from to be refurbished in the short across the age spectrum and thatit also has term with commitment from the the support of the local Councillors. Indeedall council to keep it open until the political parties supported the need for a 2014. pool in the future of Purley. A pool is supported by the doctors in our area and is Proposals to meet the needs of well used by local schools (eleven) and by the the borough, improve the quality disabled. I do hope you can take my opinion in provision, and meet unmet into consideration. and future demand have arisen from an analysis of both need and the opportunity to develop provision to cater for the unmet demand in the south of the borough.

The Core Strategy will not include policies for site specific facilities unless there are strategic implications. The Core Strategy will set out general policies related to co-located community facilities (including swimming pools and leisure centres). Site specific policies or detailed community facilities policies shall be dealt with by the Site Allocations DPD and Development Management DPD. I have been concerned for some time at the The valuable role of Purley Pool Kathleen Garner plans of Croydon Council to close down in providing swimming facilities Purley Pool. This is a swimming pool which and a learning environment for Objection caters for a wide area around Purley, Purley and adjoining areas is Noted Coulsdon and South Croydon, as well as local understood. The pool needs schools. It is very popular. And yet the council refurbishment or in the medium seems fixated on closing it down despite the term replacement. The pool is fact that the council tax payers who pay for to be refurbished in the short this facility wish to retain it. Ridiculously large term with commitment from the sums have been quoted to bring the pool up council to keep it open until to standard, but as a regular user I am aware 2014. only of certain cosmetic problems and possibly some repairs to the roof, none of Proposals to meet the needs of which would amount to the figures the council the borough, improve the quality uses. It is also noticeable that the hours when in provision, and meet unmet the pool is open have been reduced. I myself and future demand have arisen have several times arrived at the pool in the from an analysis of both need late afternoon on a weekend only to be and the opportunity to develop refused entry or to find it already closed. This provision to cater for the unmet severely limits the people who are likely to use demand in the south of the the pool and has probably put many off. There borough. have been offers of pools in other areas to replace the Purley Pool. To which the The Core Strategy will not response is, if it isn't broken, don't fix it. Why include policies for site specific should the people of Purley and its surrounds, facilities unless there are who have a perefectly serviceable pool, strategic implications. The Core suddenly have to start going elsewhere? This Strategy will set out general is not progress, it is going backwards. We policies related to co-located have consistently had to put up with the loss community facilities (including of pools in Croydon over many years, starting swimming pools and leisure with the central Croydon pool which we were centres). Site specific policies or promised would be replaced but never was, detailed community facilities then the open air pool on the Purley Way, policies shall be dealt with by then the Water Palace, and now Purley Pool. the Site Allocations DPD and Councils should be looking to improve Development Management facilities, not simply remove them or move DPD. them elsewhere more inconvenient. The money was apparently found to refurbish the pool at New Addington, but not in Purley. The money can be found to provide the leader of the council with an £11,000 a year salary increase plus related pension rights, but not to retain facilities we urgently need. The money can be found for all manner of politically correct and completely unnecessary jobs and support of overtly racist organisations, yet it cannot support the real needs of tax payers whose money goes towards paying for all this. It has long been clear that the council has an agenda in this, namely the desire to knock down the entire site of the pool, the store and the car park in order to build yet more flats to house yet more immigrants whose sole purpose is to change the demography of this country while keeping down the wages of the ordinary people (but not councillors). In this the council is not working for the good of the people who pay their wages but actively against their good. It is about time councils were brought to book about their relationship with the taxpayers who are effectively robbed to pay for services, so-called, that in many cases are against their own interests. There is no valid reason for knocking down Purley Pool and it cannot be justified on any grounds. I wish to write and express my veiw that The valuable role of Purley Pool Mr Clinton Biggle purley pool be kept open and it being an in providing swimming facilities integral part of Purleys future my family use it and a learning environment for Observation regularly and it is essential for the health and Purley and adjoining areas is Noted wellbeing of the community understood. The pool needs refurbishment or in the medium term replacement. The pool is to be refurbished in the short term with commitment from the council to keep it open until 2014.

Proposals to meet the needs of the borough, improve the quality in provision, and meet unmet and future demand have arisen from an analysis of both need and the opportunity to develop provision to cater for the unmet demand in the south of the borough.

The Core Strategy will not include policies for site specific facilities unless there are strategic implications. The Core Strategy will set out general policies related to co-located community facilities (including swimming pools and leisure centres). Site specific policies or detailed community facilities policies shall be dealt with by the Site Allocations DPD and Development Management DPD. I understand the Council is currently reviewing The valuable role of Purley Pool Chris Russell future strategyfor the area. Might I suggest in providing swimming facilities Resident that the retention of the swimming pool at and a learning environment for Objection Purley is a key ingredient, together with the Purley and adjoining areas is Noted local library. Reduction in amenities that are understood. The pool needs well used either adds further pressure to other refurbishment or in the medium sites that can only be warranted if they are term replacement. The pool is under-usedor results in the depravation of to be refurbished in the short current users who must go without. Swimming term with commitment from the isseen as an excellent form of exercise and I council to keep it open until believe the pool in Purley is well used, giving 2014. good local access for people in the surrounding area. I do trust the facilities will be Proposals to meet the needs of retained in use in plans for the future. the borough, improve the quality in provision, and meet unmet and future demand have arisen from an analysis of both need and the opportunity to develop provision to cater for the unmet demand in the south of the borough.

The Core Strategy will not include policies for site specific facilities unless there are strategic implications. The Core Strategy will set out general policies related to co-located community facilities (including swimming pools and leisure centres). Site specific policies or detailed community facilities policies shall be dealt with by the Site Allocations DPD and Development Management DPD. Dear Sir, I believe that the car park and pool The valuable role of Purley Pool Mebs Haji in Purley are vital to the community which is in providing swimming facilities the heart of the South Croydon Borough. It is and a learning environment for Objection essential that these services are maintained. Purley and adjoining areas is Noted understood. The pool needs refurbishment or in the medium term replacement. The pool is to be refurbished in the short term with commitment from the council to keep it open until 2014.

Proposals to meet the needs of the borough, improve the quality in provision, and meet unmet and future demand have arisen from an analysis of both need and the opportunity to develop provision to cater for the unmet demand in the south of the borough.

The Core Strategy will not include policies for site specific facilities unless there are strategic implications. The Core Strategy will set out general policies related to co-located community facilities (including swimming pools and leisure centres). Site specific policies or detailed community facilities policies shall be dealt with by the Site Allocations DPD and Development Management DPD. Detailed parking policies shall be dealt with in the Site Allocations and Development Management DPDs. I sincerely hope that proper consideration will The valuable role of Purley Pool Mrs Lesley Ackerley be given to keeping the Purley Swimming in providing swimming facilities Pool open. The pool is used not only by and a learning environment for Objection Purley residents but by many residents in the Purley and adjoining areas is Noted south of the borough. The pool services a understood. The pool needs quarter of a million customers each year - refurbishment or in the medium local people including the young and the term replacement. The pool is elderly find swimming a really good way to to be refurbished in the short maintain their health and fitness. In an era term with commitment from the when we are encouraged by the government council to keep it open until to take more responsibility for our own health 2014. and fitness a pool at a convenient location in the south of the borough really is essential. I Proposals to meet the needs of also hope that due consideration will be given the borough, improve the quality to the lack of Council funding support for in provision, and meet unmet fitness related adult education classes and future demand have arisen (previously under the banner of "CETS") - the from an analysis of both need number of classes available has deceased and the opportunity to develop dramatically in recent years, whilst the costs provision to cater for the unmet have increased dramatically - not everyone demand in the south of the can afford a gym membership and these borough. classes play a very important role for many people, allowing them to take part in fitness The Core Strategy will not activities at a reasonable price. include policies for site specific facilities unless there are strategic implications. The Core Strategy will set out general policies related to co-located community facilities (including swimming pools and leisure centres). Site specific policies or detailed community facilities policies shall be dealt with by the Site Allocations DPD and Development Management DPD. I consider healthy activity very important and it The valuable role of Purley Pool Ms Ann Elvin is essential that we keep Purley swimming in providing swimming facilities pool for the people of Purley and the and a learning environment for Objection surrounding area. Purley is the hub of the Purley and adjoining areas is Noted South of the borough, having good transport understood. The pool needs links serving not just Purley but Coulsdon, refurbishment or in the medium Kenley, Sanderstead, Selsdon and South term replacement. The pool is Croydon I feel that the future of a pool in to be refurbished in the short Purley is a top priority for the people of Purley term with commitment from the and the above wards. The pool serves council to keep it open until 250,000 customers a year, and our young 2014. people make good use of the pool. The local Councillors all support a pool in Purley and all Proposals to meet the needs of the political parties supported the need for a the borough, improve the quality pool in the future of Purley. A pool is in provision, and meet unmet supported by the doctors in our area and is and future demand have arisen well used by local schools and by the from an analysis of both need disabled. 11 local schools use the pool. and the opportunity to develop provision to cater for the unmet demand in the south of the borough.

The Core Strategy will not include policies for site specific facilities unless there are strategic implications. The Core Strategy will set out general policies related to co-located community facilities (including swimming pools and leisure centres). Site specific policies or detailed community facilities policies shall be dealt with by the Site Allocations DPD and Development Management DPD. There is nothing else in Purley or nothing The valuable role of Purley Pool Mr Frank Zezula better to help maintain the healthy lifestyle in providing swimming facilities then swimming - please do keep our pool and a learning environment for Objection open for Purley citizens of any age. Purley and adjoining areas is Noted understood. The pool needs refurbishment or in the medium term replacement. The pool is to be refurbished in the short term with commitment from the council to keep it open until 2014.

Proposals to meet the needs of the borough, improve the quality in provision, and meet unmet and future demand have arisen from an analysis of both need and the opportunity to develop provision to cater for the unmet demand in the south of the borough.

The Core Strategy will not include policies for site specific facilities unless there are strategic implications. The Core Strategy will set out general policies related to co-located community facilities (including swimming pools and leisure centres). Site specific policies or detailed community facilities policies shall be dealt with by the Site Allocations DPD and Development Management DPD. Dear Mr. Carlisle, This note is sent in support The valuable role of Purley Pool Mr E R C Mouat of others you will have received particularly in providing swimming facilities concerning the swimming pool whose and a learning environment for Objection continuing existence has suffered uncertainty Purley and adjoining areas is Noted for some time. The number of public understood. The pool needs swimming pools in Croydon, which is refurbishment or in the medium equivalent in size to a number of cities in the term replacement. The pool is UK, is limited. Closure of the Purley Pool to be refurbished in the short would remove a facility which is used by a term with commitment from the large number of people in the area. I use it council to keep it open until regularly and it is always busy. I note too that 2014. school partiesmake good use of it and also that parents are able to have their small Proposals to meet the needs of children gain water confidence. There is no the borough, improve the quality other pool within a reasonable distance and, in provision, and meet unmet in particular, the excellent transport facilities and future demand have arisen and car-parking are conducive to encouraging from an analysis of both need its use. On the subject of transport facilities and the opportunity to develop you may wish to include in the equationthe provision to cater for the unmet institution of a bus service from Purley to demand in the south of the Caterham. Running along the spine Higher borough. Drive and Hayes Lane it would offer public transport to a large, and ever-developing area The Core Strategy will not which currently has none. include policies for site specific facilities unless there are strategic implications. The Core Strategy will set out general policies related to co-located community facilities (including swimming pools and leisure centres). Site specific policies or detailed community facilities policies shall be dealt with by the Site Allocations DPD and Development Management DPD. The suggestion to provide a bus service between Purley and Caterham is noted. Dear Mr Carlisle I am writing to say that I think The valuable role of Purley Pool Ms Emma Mascarenhas it is essential for a swimming pool to be in providing swimming facilities written into the strategy for Purley. There is no and a learning environment for Objection other public swimming pool within walking Purley and adjoining areas is Noted distance for a large number of people in understood. The pool needs Purley and the surrounding area. Purley is the refurbishment or in the medium hub of the South of the borough, having good term replacement. The pool is transport links serving the above wards. The to be refurbished in the short pool serves 250000 customers a year, and term with commitment from the our young people make good use of the pool. council to keep it open until The local Councillors all support a pool in 2014. Purley and all the political parties supported the need for a pool in the future of Purley. A Proposals to meet the needs of pool is supported by the doctors in our area the borough, improve the quality and is well used by local schools and by the in provision, and meet unmet disabled. 11 local schools use the pool. I also and future demand have arisen believe that Purley needs a pedestrianised from an analysis of both need shopping area. and the opportunity to develop provision to cater for the unmet demand in the south of the borough.

The Core Strategy will not include policies for site specific facilities unless there are strategic implications. The Core Strategy will set out general policies related to co-located community facilities (including swimming pools and leisure centres). Site specific policies or detailed community facilities policies shall be dealt with by the Site Allocations DPD and Development Management DPD. The suggestion for a pedestrianised shopping area has been considered through the Local Implementation Plan and proved not to be viable at this time. However, other measures to improve connectivity for pedestrians in Purley District Centre will be developed. It is vital that the proposed core strategy The valuable role of Purley Pool Mr Michael Roach meeting on Purley should include the Purley in providing swimming facilities Pool. This well used facility is the only one we and a learning environment for Objection have used by schools and swimmers from all Purley and adjoining areas is Noted over the borough and not forgetting the annual understood. The pool needs Swimathon organised by Purley Roaary. We refurbishment or in the medium are lucky in having excellent bus services term replacement. The pool is through Purley and it is notable how many to be refurbished in the short swimmers I have met who travel to Purley term with commitment from the from other boroughs to use our pool. I have council to keep it open until been using the pool regularly since it was built 2014. and now retired swim twice a week. I have also used the pool through my cancer Proposals to meet the needs of treatment and latterly following a replacement the borough, improve the quality knee cap operation. I am sure this form of in provision, and meet unmet exercise has helped many others in helping and future demand have arisen themselves to get back to good health and we from an analysis of both need all know that doctors and our GPs support and and the opportunity to develop encourage swimming for their patients. To provision to cater for the unmet demolish Purley Pool would do fare more demand in the south of the harm than good and to build further homes borough. and or outlets with Tesco's on our doorstep would not solve the regeneration of Purley The Core Strategy will not problem. You may know that the old Croydon include policies for site specific Pools were demolished many years ago never facilities unless there are to be rebuilt. strategic implications. The Core Strategy will set out general policies related to co-located community facilities (including swimming pools and leisure centres). Site specific policies or detailed community facilities policies shall be dealt with by the Site Allocations DPD and Development Management DPD. I am writing to say that as a family we really The valuable role of Purley Pool Jo Riches value the pool at Purley and the children use it in providing swimming facilities regularly - they love meeting their friends on a and a learning environment for Observation Saturday afternoon at the pool for a couple of Purley and adjoining areas is Noted hours.  My daughter's school (Christchurch) understood. The pool needs also use the pool - it would be very difficult for refurbishment or in the medium them to swim somewhere else without having term replacement. The pool is to use transport which wouldn't be very green. to be refurbished in the short  So many shops and services have closed term with commitment from the in Purley over the last 10 years, and the town council to keep it open until has been in decline, that closing the pool 2014. would send the wrong message about the town, especially as Croydon Council have identified it as an area that needs regenerating.  It's so important that young Proposals to meet the needs of people have something constructive to do that the borough, improve the quality also gives them some exercise within walking in provision, and meet unmet distance of their homes - it would be a shame and future demand have arisen for them to have to bus to Waddon - and then from an analysis of both need how many of them would bother?  I hope and the opportunity to develop you can support the local councillors in provision to cater for the unmet keeping the Purley pool open. demand in the south of the borough.

The Core Strategy will not include policies for site specific facilities unless there are strategic implications. The Core Strategy will set out general policies related to co-located community facilities (including swimming pools and leisure centres). Site specific policies or detailed community facilities policies shall be dealt with by the Site Allocations DPD and Development Management DPD. I am emailing to express my feelings over the The valuable role of Purley Pool Mr Tim Ashton future of the Purley Swimming Pool and in providing swimming facilities Leisure Centre. I am a regular user and and a learning environment for Objection member of said facility and consider it an Purley and adjoining areas is Noted essential service for the people of the area for understood. The pool needs not only health factors, but also social ones refurbishment or in the medium too. I understand the centre services around a term replacement. The pool is quarter of million people every year - that's to be refurbished in the short almost 700 people a day - so it is clearly well term with commitment from the supported, much in demand and very popular. council to keep it open until Please do not deny me and thousands of 2014. others like me the services of this centre when considering the future of the borough. Proposals to meet the needs of the borough, improve the quality in provision, and meet unmet and future demand have arisen from an analysis of both need and the opportunity to develop provision to cater for the unmet demand in the south of the borough.

The Core Strategy will not include policies for site specific facilities unless there are strategic implications. The Core Strategy will set out general policies related to co-located community facilities (including swimming pools and leisure centres). Site specific policies or detailed community facilities policies shall be dealt with by the Site Allocations DPD and Development Management DPD. we would like to ask you purley pool is very The valuable role of Purley Pool Genet Tefera important, for those children to also benefit for in providing swimming facilities thecommunity please keep it open!!! and a learning environment for Observation Purley and adjoining areas is Noted understood. The pool needs refurbishment or in the medium term replacement. The pool is to be refurbished in the short term with commitment from the council to keep it open until 2014.

Proposals to meet the needs of the borough, improve the quality in provision, and meet unmet and future demand have arisen from an analysis of both need and the opportunity to develop provision to cater for the unmet demand in the south of the borough.

The Core Strategy will not include policies for site specific facilities unless there are strategic implications. The Core Strategy will set out general policies related to co-located community facilities (including swimming pools and leisure centres). Site specific policies or detailed community facilities policies shall be dealt with by the Site Allocations DPD and Development Management DPD. I am aware that the future of Purley Pool is The valuable role of Purley Pool Kirsty Archer again in doubt and would like to bring to your in providing swimming facilities attention, as I'm sure many other residents in and a learning environment for Observation the neighbourhood will or have done so Purley and adjoining areas is Noted already, of the detrimental effect the closure understood. The pool needs ofPurley Pool will haveon many members of refurbishment or in the medium the community. As a swimming teacher I am term replacement. The pool is very aware of the health benefits that to be refurbished in the short swimming brings for all ages and as a parent term with commitment from the whose children attend Christ Church CofE council to keep it open until Primary School which uses the pool I would 2014. be doubly disappointed if it is closed. I find it incredible at a time when there is so much discussion on health that such a decision is being contemplated. From our school Proposals to meet the needs of childrens' point of view their education would the borough, improve the quality suffer if it is closed as they would have to find in provision, and meet unmet an alternative venue which would have cost and future demand have arisen and time implications with more time away from an analysis of both need from learning and less money available for the and the opportunity to develop school. I urge you to do your utmost to ensure provision to cater for the unmet that our local pool stays open. demand in the south of the borough.

The Core Strategy will not include policies for site specific facilities unless there are strategic implications. The Core Strategy will set out general policies related to co-located community facilities (including swimming pools and leisure centres). Site specific policies or detailed community facilities policies shall be dealt with by the Site Allocations DPD and Development Management DPD. I am writing thisemail to lobby against the The valuable role of Purley Pool Kate Mortimer proposed closure of Purley pool. We live in in providing swimming facilities the Purley area, have used the pool as a and a learning environment for Observation family with both our children, and in addition, Purley and adjoining areas is Noted my elder son attends ChristChurch Primary understood. The pool needs school, and so also attends with school. I refurbishment or in the medium understand it is a requirement under the term replacement. The pool is national curriculum that primary aged children to be refurbished in the short should be taught to swim. Currently, term with commitment from the Christchurch children will walk to the pool, council to keep it open until with the poolbeing very convenient for the 2014. school. If, going forward, the pool is closed this will result in significant extra expense, both for the school in terms of transport costs, and, more importantly,for the children in terms Proposals to meet the needs of of their time spent travelling to a further the borough, improve the quality location vs. learning, resulting in a poorer in provision, and meet unmet quality of education for our children in the and future demand have arisen area. I am quite frankly appalled that this from an analysis of both need closure could result in precious learning time and the opportunity to develop being taken away from my son. Whilst I do provision to cater for the unmet appreciate, in the current environment in demand in the south of the particular, that costs are under severe borough. pressure and scrutiny, I cannot see the closure of the Purley pool being a sensible option, and only see this as detrimental to the community as a whole. The Core Strategy will not include policies for site specific facilities unless there are strategic implications. The Core Strategy will set out general policies related to co-located community facilities (including swimming pools and leisure centres). Site specific policies or detailed community facilities policies shall be dealt with by the Site Allocations DPD and Development Management DPD. This pool is very important to the people of The valuable role of Purley Pool Mr Peter Holmes Purley. My husband and I are retired and like in providing swimming facilities to use the pool and it is within walking and a learning environment for Objection distance for us which is so convenient. Also, I Purley and adjoining areas is Noted look after my grandchildren in the school understood. The pool needs holidays and often take them swimming which refurbishment or in the medium I feel is very good for them. We would be very term replacement. The pool is upset if this pool were to close. to be refurbished in the short term with commitment from the council to keep it open until 2014.

Proposals to meet the needs of the borough, improve the quality in provision, and meet unmet and future demand have arisen from an analysis of both need and the opportunity to develop provision to cater for the unmet demand in the south of the borough.

The Core Strategy will not include policies for site specific facilities unless there are strategic implications. The Core Strategy will set out general policies related to co-located community facilities (including swimming pools and leisure centres). Site specific policies or detailed community facilities policies shall be dealt with by the Site Allocations DPD and Development Management DPD. This swimming pool gives so much pleasure The valuable role of Purley Pool Swapan Chakraborty and the happiness to the local people and in providing swimming facilities children It will be big loss for all the local and a learning environment for Objection schools children and very sad to see it go. Purley and adjoining areas is Noted understood. The pool needs refurbishment or in the medium term replacement. The pool is to be refurbished in the short term with commitment from the council to keep it open until 2014.

Proposals to meet the needs of the borough, improve the quality in provision, and meet unmet and future demand have arisen from an analysis of both need and the opportunity to develop provision to cater for the unmet demand in the south of the borough.

The Core Strategy will not include policies for site specific facilities unless there are strategic implications. The Core Strategy will set out general policies related to co-located community facilities (including swimming pools and leisure centres). Site specific policies or detailed community facilities policies shall be dealt with by the Site Allocations DPD and Development Management DPD. It has been brought to my attention that there The valuable role of Purley Pool Helen D'Aguiar is a real possibility that Purley swimming pool in providing swimming facilities may close. Why on earth is this even being and a learning environment for Observation considered when we should in fact be Purley and adjoining areas is Noted improving the facilities there, not removing understood. The pool needs them. We should be promoting good health refurbishment or in the medium and general fitness rather than allowing our term replacement. The pool is children to continue to sit at home on their to be refurbished in the short computers...probably virtual swimming, like term with commitment from the they ‘virtual' all other sports. My family and council to keep it open until I feel very strongly about this subject and it 2014. would be absolutely terrible if the pool were to close as we regularly take our son swimming there as it is very close to our house.  My son also attends Christchurch school and they Proposals to meet the needs of are currently able to walk the pupils to Purley the borough, improve the quality pool for swimming lessons. If the pool closes in provision, and meet unmet the swimming lessons may have to stop as and future demand have arisen the school will have to pay travel costs on top from an analysis of both need of the cost of the swimming lessons and this and the opportunity to develop additional expense will take away from other provision to cater for the unmet aspects of children's learning.  Travelling demand in the south of the further away will take more time out of the borough. school day when children could be engaged in other learning.  Shouldn't we in fact be building more swimming pools so that there are more facilities for the local communities to The Core Strategy will not enjoy and promote good health - in some include policies for site specific countries there is a pool in every town. If facilities unless there are Purley pool closes, where is the nearest public strategic implications. The Core pool situated....I certainly don't know.  By Strategy will set out general keeping a swimming pool in the locality you policies related to co-located will also be contributing to the quality of community facilities (including education for children in our community.  I swimming pools and leisure hope this email will go some way into the centres). Site specific policies or reconsideration of the closure of Purley Pool. detailed community facilities policies shall be dealt with by the Site Allocations DPD and Development Management DPD. I am writing with regards to the Core Strategy The valuable role of Purley Pool Linda Triggs Document currently being prepared. As a in providing swimming facilities family we consider a swimming pool essential and a learning environment for Observation for the people of Purley and surrounding area. Purley and adjoining areas is Noted We use the pool frequently. Our 12 year old understood. The pool needs son will regularly meet his friendsand either refurbishment or in the medium walk or catch a bus to Purley and go for a term replacement. The pool is swim in Purley pool on a weekendafternoon. to be refurbished in the short This is an activity that as parents we actively term with commitment from the encourage and would like this to be part of his council to keep it open until routine well into his teenage years for all the 2014. obvious reasons - he is getting healthy activity in a social situation. In addition, our younger daughter, aged 9, regularly uses the pool after school and at weekends. Holiday activities Proposals to meet the needs of held at the pool such as snorkelling lessons the borough, improve the quality and water polo sessions for children are really in provision, and meet unmet fantastic. The pool currently serves 250000 and future demand have arisen customers a years, including 11 schools, the from an analysis of both need disabled, and many of our young people. and the opportunity to develop Where would these local people learn to provision to cater for the unmet swim, get exercise and spend their leisure demand in the south of the time if the pool were to close? The pool is very borough. well sited - close to Purley Rail station, bus routes and with lots of parking. If money were spent in making itmore attractive, even more local people would use the facilities. No The Core Strategy will not money has been invested in the site for a include policies for site specific number of years, and the fact that so many facilities unless there are local people still use the facilities, in spite of strategic implications. The Core this, should show just how necessary it is. In Strategy will set out general the past, we have found ourselves travelling policies related to co-located out of the Borough for most of our leisure community facilities (including activities - Tandridge Pool, Reigate Park, swimming pools and leisure Croydon Park in Beckenham, as our part of centres). Site specific policies or the borough is severely lacking in decent detailed community facilities leisure facilities. The money invested in the policies shall be dealt with by last few years at Higher Drive Recreation the Site Allocations DPD and ground has changed this and our children now Development Management use the facilities here regularly - our son DPD. mainly to play football with friends and our daughter to use the play equipment. This play area and recreation ground has had a new lease of life and isnearly alwaysfull of families andchildren using the facilities. More money could be spent to tidyup "the cage" area used bynumerous children of all ages mainly to playfootball, and thetennis court which is in a very bad state of repair. This would encourage even more children to use this area and become more active. If we want our young people to lead active, healthy lives, beat the obesity problem and give our children places they can go for positive, healthy activity, so that they are not bored hanging around the streets causing trouble, then Purley Pool must remain open. We must increase and invest in the facilities available to them locally, not reduce the facilities and make it more difficult for them to get the exercise they need. I consider healthy activity very important and it The valuable role of Purley Pool Ms Christine Attwood is essential that we keep Purley swimming in providing swimming facilities pool for the people of Purley and the and a learning environment for Objection surrounding area. Purley is the hub of the Purley and adjoining areas is Noted South of the borough, having good transport understood. The pool needs links serving not just Purley but Coulsdon, refurbishment or in the medium Kenley, Sanderstead, Selsdon and South term replacement. The pool is Croydon I feel that the future of a pool in to be refurbished in the short Purley is a top priority for the people of Purley term with commitment from the and the above wards. The pool serves council to keep it open until 250,000 customers a year, and our young 2014. people make good use of the pool. The local Councillors all support a pool in Purley and all Proposals to meet the needs of the political parties supported the need for a the borough, improve the quality pool in the future of Purley. A pool is in provision, and meet unmet supported by the doctors in our area and is and future demand have arisen well used by local schools and by the from an analysis of both need disabled. 11 local schools use the pool. and the opportunity to develop provision to cater for the unmet demand in the south of the borough.

The Core Strategy will not include policies for site specific facilities unless there are strategic implications. The Core Strategy will set out general policies related to co-located community facilities (including swimming pools and leisure centres). Site specific policies or detailed community facilities policies shall be dealt with by the Site Allocations DPD and Development Management DPD. am writing regarding the possible closure of The valuable role of Purley Pool Mrs April Alderton Purley Pool. Swimming is a LIFE SKILL. My 2 in providing swimming facilities children currently swim here regularly and and a learning environment for Observation participate in swimming as part of the national Purley and adjoining areas is Noted curiculum through Christ Chirch School. Our understood. The pool needs school is in close proximity to Purley Pool and refurbishment or in the medium should the pool close the nearest pool is some term replacement. The pool is 25 minute drive away. Obviously this extra to be refurbished in the short travel time would reduce the childrens term with commitment from the learning time in the classroom and council to keep it open until significantly increase the cost of this essential 2014. life skill. Our govenrmentand indeed Croydon Council,put emphasis on keeping children healthy which is why, as well as other sports, I want my children to have swimming lessons. Proposals to meet the needs of The pool and leisure centre serve the greater the borough, improve the quality community too and its loss would be a tragedy in provision, and meet unmet for many, not to mention the loss of an and future demand have arisen importantlocal ammenity for which we pay our from an analysis of both need taxes. I therefore urge you to keep our pool and the opportunity to develop open, provision to cater for the unmet demand in the south of the borough.

The Core Strategy will not include policies for site specific facilities unless there are strategic implications. The Core Strategy will set out general policies related to co-located community facilities (including swimming pools and leisure centres). Site specific policies or detailed community facilities policies shall be dealt with by the Site Allocations DPD and Development Management DPD. I'm e-mailing you today, to inform you it would The valuable role of Purley Pool Amie Stroud be a good idea to keep Purley Pool open. It in providing swimming facilities Resident would be a good idea, to keep Purley pool and a learning environment for Observation open, because it's a good way to get the Purley and adjoining areas is Noted people in the area active. Purley pool is in a understood. The pool needs area, where there is good transport too there, refurbishment or in the medium so lots of people use the pool. The pool is term replacement. The pool is used by 11 different school and also people to be refurbished in the short that are disabled, and is always in good use term with commitment from the for any one that goes there. The people in the council to keep it open until area are supporting for the pool to be stayed 2014. open,and i'm sure other parts of the country are too.

Proposals to meet the needs of the borough, improve the quality in provision, and meet unmet and future demand have arisen from an analysis of both need and the opportunity to develop provision to cater for the unmet demand in the south of the borough.

The Core Strategy will not include policies for site specific facilities unless there are strategic implications. The Core Strategy will set out general policies related to co-located community facilities (including swimming pools and leisure centres). Site specific policies or detailed community facilities policies shall be dealt with by the Site Allocations DPD and Development Management DPD. Hello I am the head coach of the Purley H2Os The valuable role of Purley Pool Evans106 swimming club .We regularly use the pool for in providing swimming facilities our training sessions and our inter club and a learning environment for Objection competitions and it would be terrible to lose Purley and adjoining areas is Noted the pool.As we are approaching London 2012 understood. The pool needs it would be an asset to local swimmers and up refurbishment or in the medium and coming young athletes,we have around term replacement. The pool is 100 swimmers who benefit from this facility to be refurbished in the short and we have in development plans to include term with commitment from the more local disabled athletes at our training council to keep it open until sessions, I urge the powers that be to retain 2014. this facility and have the foresight to appreciate its role in the future. Proposals to meet the needs of the borough, improve the quality in provision, and meet unmet and future demand have arisen from an analysis of both need and the opportunity to develop provision to cater for the unmet demand in the south of the borough.

The Core Strategy will not include policies for site specific facilities unless there are strategic implications. The Core Strategy will set out general policies related to co-located community facilities (including swimming pools and leisure centres). Site specific policies or detailed community facilities policies shall be dealt with by the Site Allocations DPD and Development Management DPD. Ithink that you should not close the swimming The valuable role of Purley Pool Mr Danny Lambert pool down because it is used by many people in providing swimming facilities and if you close it they will all be sad that they and a learning environment for Objection have nothingto do no more. you should also Purley and adjoining areas is Noted keep it because it is excersise for the kids and understood. The pool needs if they dont get excersise they may get fat, refurbishment or in the medium also it gives teenagers something to do rather term replacement. The pool is than roam the streets causing trouble and to be refurbished in the short even turning to drugs. this is some of the term with commitment from the things why the pool is good: Purley is the hub council to keep it open until of the Southern Croydon, having good 2014. transport links (so lots of people can use the pool) The pool serves 250000 customers a Proposals to meet the needs of year, and our young people make good use of the borough, improve the quality the pool. It is well used by 11 local schools in provision, and meet unmet and also by the disabled. The local and future demand have arisen Councillors all support a pool in Purley. In the from an analysis of both need last election, all the political parties supported and the opportunity to develop the need for a pool in the future of Purley. provision to cater for the unmet demand in the south of the borough.

The Core Strategy will not include policies for site specific facilities unless there are strategic implications. The Core Strategy will set out general policies related to co-located community facilities (including swimming pools and leisure centres). Site specific policies or detailed community facilities policies shall be dealt with by the Site Allocations DPD and Development Management DPD. I am writing to try and persuade you to keep The valuable role of Purley Pool Emma Latchem Purley Swimming Pool open. I feel you should in providing swimming facilities keep it open for many reasons. To start with, and a learning environment for Observation swimming is a very healthy activity and as Purley and adjoining areas is Noted there are many people gaining weight in the understood. The pool needs UK, the people in the area need places to refurbishment or in the medium regularly exercise. Also, the pool is easy to term replacement. The pool is access, with a lot of transport links, many to be refurbished in the short people can get to the pool, including schools term with commitment from the which means if Purley Pool is closed down council to keep it open until schools will not have a local pool to go to. 2014. Furthermore, the pool is proved rather popular, with over 250,000 people being served every year and even the political parties are supporting us to keep it open, as Proposals to meet the needs of shown by the last election. the borough, improve the quality in provision, and meet unmet and future demand have arisen from an analysis of both need and the opportunity to develop provision to cater for the unmet demand in the south of the borough.

The Core Strategy will not include policies for site specific facilities unless there are strategic implications. The Core Strategy will set out general policies related to co-located community facilities (including swimming pools and leisure centres). Site specific policies or detailed community facilities policies shall be dealt with by the Site Allocations DPD and Development Management DPD. I would like to express my views regarding the The valuable role of Purley Pool Sue Hunt Pool at Purley, I use this pool 3/4 times a in providing swimming facilities week and feel it is an important part of Purley and a learning environment for Objection life, also the number of schools using it . I Purley and adjoining areas is Noted have lived in Purley for 30 yrs and have seen understood. The pool needs it deteriorate over this time ,from the closer of refurbishment or in the medium the cinema to loosing Sainsbury's , the only term replacement. The pool is place people now go to Purley for is the pool to be refurbished in the short and Tescos. term with commitment from the council to keep it open until 2014.

Proposals to meet the needs of the borough, improve the quality in provision, and meet unmet and future demand have arisen from an analysis of both need and the opportunity to develop provision to cater for the unmet demand in the south of the borough.

The Core Strategy will not include policies for site specific facilities unless there are strategic implications. The Core Strategy will set out general policies related to co-located community facilities (including swimming pools and leisure centres). Site specific policies or detailed community facilities policies shall be dealt with by the Site Allocations DPD and Development Management DPD. I would like to voice my opinions on Purley The valuable role of Purley Pool Barbara Somers Pool and would like you to know that I in providing swimming facilities Resident consider a swimming pool essential for the and a learning environment for Observation people of the area for healthy activity. Purley Purley and adjoining areas is Noted is the hub of the South of the borough, having understood. The pool needs good transport links serving the above wards. refurbishment or in the medium The pool serves 250000 customers a year, term replacement. The pool is and our young people make good use of the to be refurbished in the short pool. The local Councillors all support a pool term with commitment from the in Purley and all the political parties supported council to keep it open until the need for a pool in the future of Purley. A 2014. pool is supported by the doctors in our area and is well used by local schools and by the disabled. 11 local schools use the pool. Please take all these factors into Proposals to meet the needs of consideration when you make your decisions the borough, improve the quality and not let it just be about cost. in provision, and meet unmet and future demand have arisen from an analysis of both need and the opportunity to develop provision to cater for the unmet demand in the south of the borough.

The Core Strategy will not include policies for site specific facilities unless there are strategic implications. The Core Strategy will set out general policies related to co-located community facilities (including swimming pools and leisure centres). Site specific policies or detailed community facilities policies shall be dealt with by the Site Allocations DPD and Development Management DPD. As a resident of Pampisford Road I feel that The valuable role of Purley Pool Mrs Pam Blair the Local Leisure is an important part of in providing swimming facilities Purley as this encourages residents into the and a learning environment for Observation town centre the only down side to this is the Purley and adjoining areas is Noted empty building adjacent to Purley Pool .If this understood. The pool needs was purchased by Croydon Council this could refurbishment or in the medium be used for more Leisure activities for term replacement. The pool is example during the day Indoor Bowls in the to be refurbished in the short evening Basketball , Football, Indoor Cricket term with commitment from the or any court games as well extending the gym council to keep it open until . As for the Multi-storey Car Park if you wish to 2014. park for more then 2 hours after 10.00 a.m the only spaces you can find will be on the eighth (8) floor ,this tell you how well the car park is used bearing in mind that for over 2 hours the Proposals to meet the needs of charge is £3.00 and as the car park is no the borough, improve the quality longer manned revenue must out weight the in provision, and meet unmet expenditure (bearing in mind the lifts and and future demand have arisen landings seem to cleaned about once a month from an analysis of both need )plus where would these cars park ? and the opportunity to develop provision to cater for the unmet demand in the south of the borough.

The Core Strategy will not include policies for site specific facilities unless there are strategic implications. The Core Strategy will set out general policies related to co-located community facilities (including swimming pools and leisure centres). Site specific policies or detailed community facilities policies shall be dealt with by the Site Allocations DPD and Development Management DPD. I am a retired Senior Citizen (63 years of age) The valuable role of Purley Pool Mr Andrew Dunlop I use Purley Pool regularly as I enjoy in providing swimming facilities swimming and it is useful exercise among and a learning environment for Observation others (golf, gym) in trying to keep me fit. I Purley and adjoining areas is Noted think it would be a shame if the pool were understood. The pool needs closed as there would be nothing in the south refurbishment or in the medium of Croydon for all 250000 people who use it term replacement. The pool is every year. There are not many indoor sports to be refurbished in the short facilities in the south of the Croydon and the term with commitment from the health and enjoyment of thousands of adults council to keep it open until and children would be affected if it were to 2014. close.

Proposals to meet the needs of the borough, improve the quality in provision, and meet unmet and future demand have arisen from an analysis of both need and the opportunity to develop provision to cater for the unmet demand in the south of the borough.

The Core Strategy will not include policies for site specific facilities unless there are strategic implications. The Core Strategy will set out general policies related to co-located community facilities (including swimming pools and leisure centres). Site specific policies or detailed community facilities policies shall be dealt with by the Site Allocations DPD and Development Management DPD. I live in Purley and can walk to the pool with The valuable role of Purley Pool Samantha Purser my children to take them swimming at in providing swimming facilities weekends - one of the rare places we can get and a learning environment for Observation to on foot without need to use public transport Purley and adjoining areas is Noted or petrol. The loss of this would undoubtedly understood. The pool needs that we go swimming less due to the time refurbishment or in the medium taken and hassles of going further afield. A term replacement. The pool is shame when the government / NHS / local to be refurbished in the short councils are supposed to be promoting fit and term with commitment from the healthy life styles. My children also attend council to keep it open until Christ Church Primary school - in order to 2014. fulfill the statutory requirement made in the National Curriculum that all primary school children learn to swim, they are able to walk to Purley Pool for swimming lessons. If they Proposals to meet the needs of were no longer able to go to Purley Pool for the borough, improve the quality swimming lessons, the cost of travelling in provision, and meet unmet further afield and the extra time taken out of and future demand have arisen normal lesson time would be detrimental to from an analysis of both need their education. I urge you to keep Purley Pool and the opportunity to develop open for all the reasons above and the fact provision to cater for the unmet that Purley is very accesible to other people in demand in the south of the surrounding areas as it has good transport borough. links. Rather than build a whole new centre in a new area, surely it would make sense to spend less money improving a facility that is well used by local people The Core Strategy will not include policies for site specific facilities unless there are strategic implications. The Core Strategy will set out general policies related to co-located community facilities (including swimming pools and leisure centres). Site specific policies or detailed community facilities policies shall be dealt with by the Site Allocations DPD and Development Management DPD. concerned about the direction Purley is The comments are noted. Road Paul Thompson heading in regard to its global planning layouts and markings are not strategy and as someone who's lived and had dealt with by the Core Strategy, Objection business in Purley for 20 years I'd like to offer nor is the charging schedule for Disagree – No Change you my concerns and observations: the multi storey car park or tenants of the retail units in the Purley is a dismal mess thanks to a number of High Street. things: The valuable role of Purley Pool 1) ANGER AND ACCIDENTS!! Diabolical lane- in providing swimming facilities swapping chicane layout the town centre is full and a learning environment for of angry motorists. Minutes standing on the Purley and adjoining areas is corler of Russell Hill by Pizza Express will understood. The pool needs attest to this. Coming the other way past the refurbishment or in the medium Tesco entrance things are no better with a term replacement. The pool is crazy curved island forcing cars to cut across to be refurbished in the short lanes. Redesign of the road system is badly term with commitment from the needed, but as a start large ‘GET IN LANE council to keep it open until NOW' followed by SOLID white lane lines 2014. accompanied by ‘NO LANE CHANGING' signs need to be put in at the Godstone Rd Proposals to meet the needs of and Russell Hill. Also traffic heading south on the borough, improve the quality Brighton Rd coming through the RH Rd lights in provision, and meet unmet especially busses consistently jump the lights and future demand have arisen thereby blocking the main flow of Purley Way from an analysis of both need traffic making navigation virtually impossible. and the opportunity to develop provision to cater for the unmet 2) IMPROVING PURLEY TOWN CENTRE - demand in the south of the Purley High Street should be pedestrianised borough. and linked directly to Tesco so that patrons of either can either make a choice, or use both. The Core Strategy will not The Multi-Storey is massively under-used and include policies for site specific should be FREE for the first 60 minutes facilities unless there are encouraging shoppers to chose Purley Town strategic implications. The Core Centre to shop and help it thrive instead of Strategy will set out general having every charity shop under the sun policies related to co-located occupy otherwise empty and un-rentable community facilities (including shops. swimming pools and leisure centres). Site specific policies or 3) PURLEY POOL - Purley Pool is an integral detailed community facilities part of the Purley community and the Multi policies shall be dealt with by Storey Car Park is an integral part of Purley the Site Allocations DPD and Pool. Development Management DPD. 4) FLATS - How many more flats can Purley support?! I fail to see the sense of Croydon The Local Housing Market Planning Dept encouraging block after block Assessment takes the GLA of flats when there is no road or transport population projections for the infrastructure to support it. Parking is virtually borough as a whole and uses non-existent and you cannot get on trains to data on household composition London in peak times as they are completely and type of homes currently in full!! existence to provide the overall need for homes up to 2031 and Purley could be as rich and pleasant a place the need for new homes by to shop as Banstead. Unfortunately through tenure split and home size. consistently misguided planning ideas Purley Croydon has followed the is a mess in which everybody loses. Let's guidance and methodology of hope something changes and a GLOBAL Planning Policy Statement 3: strategy is employed for the future. Housing, this sets out how Local Planning Authorities should assess housing need and land availability for new housing. As a regular user of the pool for many years I The valuable role of Purley Pool David Wilkin wish to make known my concern that this in providing swimming facilities useful facility (the only thing the council and a learning environment for Objection provides to me of any use), should be Purley and adjoining areas is Noted maintained and upgraded for the future. understood. The pool needs Purley is obviously located at a key point in refurbishment or in the medium the borough which makes it easy for residents term replacement. The pool is to access the pool. The alternative sites which to be refurbished in the short have been proposed are not in such term with commitment from the accessible locations and will basically only be council to keep it open until available to car users. 2014.

Proposals to meet the needs of the borough, improve the quality in provision, and meet unmet and future demand have arisen from an analysis of both need and the opportunity to develop provision to cater for the unmet demand in the south of the borough.

The Core Strategy will not include policies for site specific facilities unless there are strategic implications. The Core Strategy will set out general policies related to co-located community facilities (including swimming pools and leisure centres). Site specific policies or detailed community facilities policies shall be dealt with by the Site Allocations DPD and Development Management DPD. 3) PURLEY POOL - Purley Pool is an integral The valuable role of Purley Pool Paul Thompson part of the Purley community and the Multi in providing swimming facilities Storey Car Park is an integral part of Purley and a learning environment for Objection Pool. Purley and adjoining areas is Noted understood. The pool needs refurbishment or in the medium term replacement. The pool is to be refurbished in the short term with commitment from the council to keep it open until 2014.

Proposals to meet the needs of the borough, improve the quality in provision, and meet unmet and future demand have arisen from an analysis of both need and the opportunity to develop provision to cater for the unmet demand in the south of the borough.

The Core Strategy will not include policies for site specific facilities unless there are strategic implications. The Core Strategy will set out general policies related to co-located community facilities (including swimming pools and leisure centres). Site specific policies or detailed community facilities policies shall be dealt with by the Site Allocations DPD and Development Management DPD. Detailed parking policies shall be dealt with in the Site Allocations and Development Management DPDs. I am writing to register my extremely strong The valuable role of Purley Pool Kate Richards opposition to any thoughts of closing Purley in providing swimming facilities pool. It is a vital part of our local community and a learning environment for Observation and offers so many benefits - economic, Purley and adjoining areas is Noted social, health. I understand that it serves understood. The pool needs 250000 customers a year, and most refurbishment or in the medium importantly many young people (both through term replacement. The pool is schools and with families) make good use of to be refurbished in the short the pool and the gym. Please let me know term with commitment from the what your intentions are regarding the pool. council to keep it open until 2014.

Proposals to meet the needs of the borough, improve the quality in provision, and meet unmet and future demand have arisen from an analysis of both need and the opportunity to develop provision to cater for the unmet demand in the south of the borough.

The Core Strategy will not include policies for site specific facilities unless there are strategic implications. The Core Strategy will set out general policies related to co-located community facilities (including swimming pools and leisure centres). Site specific policies or detailed community facilities policies shall be dealt with by the Site Allocations DPD and Development Management DPD. I consider a swimming pool essential for the The valuable role of Purley Pool Hilton Lord people of the area for healthy activity. Purley in providing swimming facilities is the hub of the South of the borough, having and a learning environment for Objection good transport links serving the above wards. Purley and adjoining areas is Noted The pool serves 250000 customers a year, understood. The pool needs and our young people make good use of the refurbishment or in the medium pool. Â I trust that we can continue to enjoy term replacement. The pool is the pool in the future. to be refurbished in the short term with commitment from the council to keep it open until 2014.

Proposals to meet the needs of the borough, improve the quality in provision, and meet unmet and future demand have arisen from an analysis of both need and the opportunity to develop provision to cater for the unmet demand in the south of the borough.

The Core Strategy will not include policies for site specific facilities unless there are strategic implications. The Core Strategy will set out general policies related to co-located community facilities (including swimming pools and leisure centres). Site specific policies or detailed community facilities policies shall be dealt with by the Site Allocations DPD and Development Management DPD. I have been keeping upto date on The valuable role of Purley Pool Dr Anjali Chitkara developments on Purley pool. Please bear in in providing swimming facilities mind this is an important facility for people in and a learning environment for Observation the area. (I live in Coulsdon South). And it Purley and adjoining areas is Noted needs to be in a location that is accessible by understood. The pool needs public trasport for ALL. I hope you bear this in refurbishment or in the medium mind before you make decisions that will not term replacement. The pool is be able to be undone. to be refurbished in the short term with commitment from the council to keep it open until 2014.

Proposals to meet the needs of the borough, improve the quality in provision, and meet unmet and future demand have arisen from an analysis of both need and the opportunity to develop provision to cater for the unmet demand in the south of the borough.

The Core Strategy will not include policies for site specific facilities unless there are strategic implications. The Core Strategy will set out general policies related to co-located community facilities (including swimming pools and leisure centres). Site specific policies or detailed community facilities policies shall be dealt with by the Site Allocations DPD and Development Management DPD. I think that it is absolutely imperative that we The valuable role of Purley Pool Mary C FitzGerald retain a pool in Purley. Â The pool is essential in providing swimming facilities for the people of the area for healthy activity. If and a learning environment for Objection we were to lose the pool there is every Purley and adjoining areas is Noted likelihood that many of those who use it will understood. The pool needs find it too difficult to make alternative refurbishment or in the medium arrangements. term replacement. The pool is to be refurbished in the short term with commitment from the council to keep it open until 2014.

Proposals to meet the needs of the borough, improve the quality in provision, and meet unmet and future demand have arisen from an analysis of both need and the opportunity to develop provision to cater for the unmet demand in the south of the borough.

The Core Strategy will not include policies for site specific facilities unless there are strategic implications. The Core Strategy will set out general policies related to co-located community facilities (including swimming pools and leisure centres). Site specific policies or detailed community facilities policies shall be dealt with by the Site Allocations DPD and Development Management DPD. I consider a swimming pool essential for the The valuable role of Purley Pool Sophie Dilley people of the area for healthy activity. Please in providing swimming facilities ensure this can stay open and with leisure and a learning environment for Objection facilities too. Purley and adjoining areas is Noted understood. The pool needs refurbishment or in the medium term replacement. The pool is to be refurbished in the short term with commitment from the council to keep it open until 2014.

Proposals to meet the needs of the borough, improve the quality in provision, and meet unmet and future demand have arisen from an analysis of both need and the opportunity to develop provision to cater for the unmet demand in the south of the borough.

The Core Strategy will not include policies for site specific facilities unless there are strategic implications. The Core Strategy will set out general policies related to co-located community facilities (including swimming pools and leisure centres). Site specific policies or detailed community facilities policies shall be dealt with by the Site Allocations DPD and Development Management DPD. Iam writing with regard to Purley Leisure The valuable role of Purley Pool Mr Jim Clarke Centre which has for some time been under in providing swimming facilities threat of closure. As a resident of and a learning environment for Objection Sanderstead I ama regular visitor to the Gym Purley and adjoining areas is Noted and Swimming Pool. The location of the understood. The pool needs facility is most convenient for people who live refurbishment or in the medium in the south of the boroughas it has good term replacement. The pool is parking provision and also excellent transport to be refurbished in the short links for those without cars On my visits to the term with commitment from the Pool I am always struck by the number of council to keep it open until elderly people who make use of this facility an 2014. option that would not be open to them if it was moved to another part of the Borough. I Proposals to meet the needs of myself also take a handicapped person who the borough, improve the quality lives in Forestdaleto the Centre on a regular in provision, and meet unmet basis to use the gym and he looks forward to and future demand have arisen these outings and Iknow that his sessions from an analysis of both need there have helped him with his mobility. This and the opportunity to develop is a well used and much appreciated facility provision to cater for the unmet within the Borough why close it!!!! demand in the south of the borough.

The Core Strategy will not include policies for site specific facilities unless there are strategic implications. The Core Strategy will set out general policies related to co-located community facilities (including swimming pools and leisure centres). Site specific policies or detailed community facilities policies shall be dealt with by the Site Allocations DPD and Development Management DPD. I understand that a core strategy document is The valuable role of Purley Pool Mr David Klein in development and that this will include detail in providing swimming facilities on the level of support for a local pool. From and a learning environment for Objection the perspective of promoting fitness, the pool Purley and adjoining areas is Noted should definitely stay its regularly used and is understood. The pool needs one of the hubs of the area, aside from the refurbishment or in the medium dreadful Tesco development. Its very term replacement. The pool is important that local people get a say in the to be refurbished in the short development of their area and my wife and I term with commitment from the wholeheartedly believe the pool should stay. council to keep it open until 2014.

Proposals to meet the needs of the borough, improve the quality in provision, and meet unmet and future demand have arisen from an analysis of both need and the opportunity to develop provision to cater for the unmet demand in the south of the borough.

The Core Strategy will not include policies for site specific facilities unless there are strategic implications. The Core Strategy will set out general policies related to co-located community facilities (including swimming pools and leisure centres). Site specific policies or detailed community facilities policies shall be dealt with by the Site Allocations DPD and Development Management DPD. I understand that you are considering a The valuable role of Purley Pool Mr David Donald development programme for Purley. I hope in providing swimming facilities you are including the continued existence of and a learning environment for Observation the Purley Pool. Loss of the pool would result Purley and adjoining areas is Noted in many unfortunate happenings in the areas understood. The pool needs of health and community affairs. Not least it is refurbishment or in the medium the source of funds for local charities term replacement. The pool is amounting to some £25,000 a year raised by to be refurbished in the short Purley Rotary through their annual Swimathon. term with commitment from the council to keep it open until 2014.

Proposals to meet the needs of the borough, improve the quality in provision, and meet unmet and future demand have arisen from an analysis of both need and the opportunity to develop provision to cater for the unmet demand in the south of the borough.

The Core Strategy will not include policies for site specific facilities unless there are strategic implications. The Core Strategy will set out general policies related to co-located community facilities (including swimming pools and leisure centres). Site specific policies or detailed community facilities policies shall be dealt with by the Site Allocations DPD and Development Management DPD. I write concerning your forthcoming strategy The valuable role of Purley Pool Mr David Lewis document for Purley. I am very concerned that in providing swimming facilities the Swimming Pool is retained and if possible and a learning environment for Objection improved. I am one of the many more senior Purley and adjoining areas is Noted residents of the area to whom the pool is very understood. The pool needs important in my battle to remain fit and active. refurbishment or in the medium I swim there regularly twice every week and term replacement. The pool is this is part of my fitness work. Without this I to be refurbished in the short am sure that in time my mobility would be less term with commitment from the and I would eventually cost the council much council to keep it open until more in terms of support needed. I am 2014. certainly not alone in this. Â Of course the pool doesn't only benefit people like me. Proposals to meet the needs of Something approaching a quarter of a million the borough, improve the quality visits are made to the pool and this brings in provision, and meet unmet great benefit to Purley in terms of associated and future demand have arisen trade - I for instance pick up prescriptions at from an analysis of both need the local pharmacy whilst visiting for my swim, and the opportunity to develop and some of the swimmers meet after their provision to cater for the unmet swim for coffee locally. Â Moving the pool to demand in the south of the Coulsdon or worse still Waddon is just not borough. appropriate as it needs to be easily accessible for residents of Purley, for the early morning The Core Strategy will not 7.00 swim. Neither do we want a Water include policies for site specific palace type fiasco, proper swimming is facilities unless there are needed for exercise. strategic implications. The Core Strategy will set out general policies related to co-located community facilities (including swimming pools and leisure centres). Site specific policies or detailed community facilities policies shall be dealt with by the Site Allocations DPD and Development Management DPD. I hear there is another core strategy coming The valuable role of Purley Pool Anne Gasnola up for Purley. I would just like to say please in providing swimming facilities Resident consider how important the pool is in Purley. It and a learning environment for Objection is essential for all people to have access to a Purley and adjoining areas is Noted healthy activy like swimming good for all ages. understood. The pool needs I swim before work every day, I cycle ,but refurbishment or in the medium Purley is easy to get to from anywhere in the term replacement. The pool is borough by bus or train. Purley has not much to be refurbished in the short else going for it, it all arranged for the car, on term with commitment from the foot ar bike is not sogood. Such as if you shop council to keep it open until in Tesco you cannot cross the road to the bus 2014. stop, you have to walk a long way with shopping into Purley because of the rail in the Proposals to meet the needs of Brighton Rd. You cannot get to the bus stop the borough, improve the quality apposite the store. If the pool closed I would in provision, and meet unmet think of moving away from here. and future demand have arisen from an analysis of both need and the opportunity to develop provision to cater for the unmet demand in the south of the borough.

The Core Strategy will not include policies for site specific facilities unless there are strategic implications. The Core Strategy will set out general policies related to co-located community facilities (including swimming pools and leisure centres). Site specific policies or detailed community facilities policies shall be dealt with by the Site Allocations DPD and Development Management DPD. In response to the difficulties currently facing pedestrians in Purley District Centre you mention, measures to improve connectivity will be developed. I would like to take this opportunity to put The valuable role of Purley Pool Mr Malcolm Davidson down in few words why I think Purley needs a in providing swimming facilities pool and leisure centre. Â Purley is town that and a learning environment for Observation serves both young and old, it incorporates Purley and adjoining areas is Noted neighbouring wards of Coulsdon, understood. The pool needs Riddlesdown and Kenley and many more, refurbishment or in the medium because of this Purley is the hub South of the term replacement. The pool is borough. Purley has good transport links It to be refurbished in the short has many buses and a train station that has term with commitment from the just been upgraded. You will know that Purley council to keep it open until is a town for the future with many new projects 2014. earmark too and with this I consider a swimming pool essential for the town that in turn benefits to the community leading healthier lifestyles and an activity that can be Proposals to meet the needs of used and enjoyed by all people all year round the borough, improve the quality no matter what the weather. Â It seems in provision, and meet unmet sorrowing that Purley pool may have to close and future demand have arisen especially with the Olympics coming to from an analysis of both need London and now so many famous peoples and the opportunity to develop encouraging a healthier active lifestyle. Â The provision to cater for the unmet pool serves 250000 customers a year, and the demand in the south of the community makes good use of the pool. Â borough. The local Councillors all support a pool in Purley and all the political parties supported the need for a pool in the future in Purley. A pool is supported by the doctors in our area The Core Strategy will not and is well used by local schools and by the include policies for site specific disabled. 11 local schools use the pool. The facilities unless there are young people see sport as not only as a past strategic implications. The Core time but something of a learning tool it gives Strategy will set out general young people time to develop team and social policies related to co-located skills for the future, confidence and it is where community facilities (including people can come to play, relax get fit and to swimming pools and leisure meet new friends. centres). Site specific policies or detailed community facilities policies shall be dealt with by the Site Allocations DPD and Development Management DPD. I wish to add my support for keeping Purley The valuable role of Purley Pool Mr Gerald White Swimming Pool open. Fromthe facts that have in providing swimming facilities been passed to me concerning the usage and and a learning environment for Objection who uses the pool it is blindingly obvious that Purley and adjoining areas is Noted it would constitute a near criminal act to go understood. The pool needs ahead and close it. refurbishment or in the medium term replacement. The pool is to be refurbished in the short term with commitment from the council to keep it open until 2014.

Proposals to meet the needs of the borough, improve the quality in provision, and meet unmet and future demand have arisen from an analysis of both need and the opportunity to develop provision to cater for the unmet demand in the south of the borough.

The Core Strategy will not include policies for site specific facilities unless there are strategic implications. The Core Strategy will set out general policies related to co-located community facilities (including swimming pools and leisure centres). Site specific policies or detailed community facilities policies shall be dealt with by the Site Allocations DPD and Development Management DPD. My name is Anuja. I am the mum of two, The valuable role of Purley Pool Anuja Joseph Helen (6 years) and Anna(1 year). We are in providing swimming facilities Resident living in South Croydon. My elder one is going and a learning environment for Observation to Christ Church School,Purley and she is Purley and adjoining areas is Noted going for swimming classes in Purley Pool. understood. The pool needs She is enjoying a lot. She is very sad to hear refurbishment or in the medium that there are plans for the closure of the pool. term replacement. The pool is I don't know driving and it is very difficult for to be refurbished in the short me to take her to some other places. And it is term with commitment from the only walking distance from her school. School council to keep it open until will also take them for swimming classes later 2014. in the Year. I believe it is an essential skill, children should know.So please don't go forward with the plan of closing the pool. Proposals to meet the needs of the borough, improve the quality in provision, and meet unmet and future demand have arisen from an analysis of both need and the opportunity to develop provision to cater for the unmet demand in the south of the borough.

The Core Strategy will not include policies for site specific facilities unless there are strategic implications. The Core Strategy will set out general policies related to co-located community facilities (including swimming pools and leisure centres). Site specific policies or detailed community facilities policies shall be dealt with by the Site Allocations DPD and Development Management DPD. I live in Purley and have used the swimming The valuable role of Purley Pool Mr Alastair Davis pool for many years. Â Whilst it is true to say in providing swimming facilities it is not immaculate the point is it is well used and a learning environment for Objection by casual swimmers, some for a splash and to Purley and adjoining areas is Noted enjoy with their family/friends and others to understood. The pool needs lane swim. Â It is one of the best forms of refurbishment or in the medium fitness and is I believe crucial for the future of term replacement. The pool is Purley and nearby areas to have such a to be refurbished in the short facility, after all successive Councils have term with commitment from the managed to kill of the rest of Purley unless council to keep it open until anyone's idea of a thriving place is charity 2014. shops. Whether the existing facility is maintained, or sold for profit to developers, Proposals to meet the needs of another Council policy, any replacement the borough, improve the quality should be in Purley as it is so central. At the in provision, and meet unmet southern end of Croydon it is well placed for and future demand have arisen swimmers in Purley, South Croydon, from an analysis of both need Sanderstead, Coulsdon, Woodcote, and other and the opportunity to develop surrounding areas, indeed there is no reason provision to cater for the unmet why it should not attract out of borough demand in the south of the swimmers. Â For any pool to be placed borough. elsewhere will not prove to be sensible or for the benefit of the majority and that surely The Core Strategy will not should be the plan of any Core strategy. Â As include policies for site specific such I would ask that the current pool be facilities unless there are included in the future plans, or any strategic implications. The Core replacement to also be placed centrally in Strategy will set out general Purley. policies related to co-located community facilities (including swimming pools and leisure centres). Site specific policies or detailed community facilities policies shall be dealt with by the Site Allocations DPD and Development Management DPD. I am another Purley Pool user for many years The valuable role of Purley Pool Conny Viol and would like to urge the council to keep the in providing swimming facilities Resident leisure centre. As you know it is a fantastic and a learning environment for Observation facility (with a good size pool) to keep the Purley and adjoining areas is Noted population all ages fit and healthy. It would be understood. The pool needs a great shame to lose it, wouldn't it??? refurbishment or in the medium term replacement. The pool is to be refurbished in the short term with commitment from the council to keep it open until 2014.

Proposals to meet the needs of the borough, improve the quality in provision, and meet unmet and future demand have arisen from an analysis of both need and the opportunity to develop provision to cater for the unmet demand in the south of the borough.

The Core Strategy will not include policies for site specific facilities unless there are strategic implications. The Core Strategy will set out general policies related to co-located community facilities (including swimming pools and leisure centres). Site specific policies or detailed community facilities policies shall be dealt with by the Site Allocations DPD and Development Management DPD. We need to keep Purley Pool open for the The valuable role of Purley Pool Mr Roger Chapman residents south of the borough. in providing swimming facilities and a learning environment for Observation Purley and adjoining areas is Noted understood. The pool needs refurbishment or in the medium term replacement. The pool is to be refurbished in the short term with commitment from the council to keep it open until 2014.

Proposals to meet the needs of the borough, improve the quality in provision, and meet unmet and future demand have arisen from an analysis of both need and the opportunity to develop provision to cater for the unmet demand in the south of the borough.

The Core Strategy will not include policies for site specific facilities unless there are strategic implications. The Core Strategy will set out general policies related to co-located community facilities (including swimming pools and leisure centres). Site specific policies or detailed community facilities policies shall be dealt with by the Site Allocations DPD and Development Management DPD. My wife and I strongly support Purley The valuable role of Purley Pool Mr Tony Heys swimming pool - we use it regularly with our in providing swimming facilities 9yr old daughter, and very much want to see it and a learning environment for Objection continue, or even be improved over what it Purley and adjoining areas is Noted currently is. understood. The pool needs refurbishment or in the medium term replacement. The pool is to be refurbished in the short term with commitment from the council to keep it open until 2014.

Proposals to meet the needs of the borough, improve the quality in provision, and meet unmet and future demand have arisen from an analysis of both need and the opportunity to develop provision to cater for the unmet demand in the south of the borough.

The Core Strategy will not include policies for site specific facilities unless there are strategic implications. The Core Strategy will set out general policies related to co-located community facilities (including swimming pools and leisure centres). Site specific policies or detailed community facilities policies shall be dealt with by the Site Allocations DPD and Development Management DPD. Sustainability Appraisal Section Representation Recommended Response Full Name Paragraph Organisation Nature of Response Officer Recommendation

SA Objective Item 13 To protect and enhance The comment is noted. There Mr Dave King the borough's cultural and heritage resources. may be oppotunities in areas Monks Orchard MORA are mainly a suburban area and not an such as Monks Orchard for Residents Association urban area and therefore not an area which jobs and cultural activities Observation has significant job opportunities or specific arising from the colocation of Noted cultural requirements. buildings for community facilties SA Objective Item 4 To provide greater choice These sentiments are carried Mr Dave King and an appropriate mix of housing in terms of forward in para 3.13 of the Core Monks Orchard size, type and location. c) Ensure any Strategy Supplement Residents Association additional housing is appropriate to the area Observation and enhances the community and street Agree - No Change scene rather than squeeze more and more small unattractive developments and blocks of flats onto smaller and smaller plots. d) Have a presumption to retain bungalows and single storey accommodation so as to maintain suitable living accommodation for the increasing numbers of elderly population living and cared for at home; rather than allow redevelopment for high density accommodation. e) That Croydon Planning categorise all in-fill and back garden development as not presumed available for development as stated in the Communities and Local Government Planning Policy document Statement 3 (PPS3) Housing - June 2010 at Annex B unless significant reasons to allow such developments are given and endorsed by the LPA. f) To lobby for changes to the Permitted Development rules to prevent inappropriate development in residential areas that do not meet the criteria in the current or future UDP or the London Housing Design Guide. g) Only allow development where the infrastructure and services would cope with the increase in demand - Schools, medical surgeries and utilities services provision. h) We understand that the target for new homes in Shirley and Ashburton is 100 for the period 2012-2031 [i.e. ≈20 years]. The rate of new build in Ashburton and Shirley has been significantly higher than 100/20 = 5 dwellings per year over each of the last few years. What can Croydon LPA do to limit the developers to stay within this limit. i) To lobby for an equality of appeals process. Either lobby for the end of appeals procedures - the LPA and local residents are more aware of local issues than an Inspector from Bristol - or give local residents an opportunity to appeal against an approval. SA Objective Item 5 To ensure equal and fair The Core strategy (Towards a Mr Dave King access to opportunities, services and Preferred Core Strategy for Monks Orchard amenities, focusing on the most deprived Croydon) includes Spatial Residents Association areas. . j) Focussing on the most deprived Objectives 4 which aims to Observation area should not totally exclude other urban or provide well disigned Agree - No Change suburban residential areas of Croydon for the community, education, health provision of services and amenities. All and leisure servicesto meet the council Tax Payers should be given their aspirations and needs of a share of services. k) We suggest that the diverse community.Spatial London Housing Guide requirements on Objective 5 aims to conserve Residential and Housing Density, and and create spaces and minimum room dimensions and storage buildings that foster cohesive allocations etc are embodied into the Local communities. These are Development Framework / UDP.) borough wide objectives.The London Housing Design Guide requirements on Residential and Housing Density, and minimum room dimensions will provide guidance and be developed further as part of the Developmnet Management DPD SA Objective Item 7 To ensure sustainable The infrastructure requirement Mr Dave King economic growth and business development to underpin economic growth Monks Orchard to provide economic well being for all of the are being considered in the Residents Association community. Infrastructure Delivery Plan. Observation Agree - No Change l) Plans are necessary to ensure the infrastructure is in place to support economic growth and business development such as: Mains Services [Electric Gas and Water] distribution is provided to support the loads required by business and dwelling growth rather than allow development without sustainable services distribution so as to avoid retrospective catch-up. m) Ensure communications and fibre optic provision for fast broadband is provided to allow competitive development of new businesses and entrepreneur start-ups to compete with equivalent provision of such services in other competing localities. n) Ensure that the transport infrastructure is enhanced to give full and uninterrupted access to the centres of business and services and ensure all planned works avoid disruption. o) Implement policies to attract business, commerce and retail into the area rather than price them and their customers out of Croydon and into other competing localities. To ensure that a network of diverse, good There is no proposal to use any Mr Dave King quality open spaces is provided. designated Green Belt and Monks Orchard Metropolitan Open Land for Residents Association p) To safeguard all designated Green Belt and development. Observation Metropolitan Open Land from any future Any proposed Travellers site Agree - No Change development. will be identified in Site q) Introduce policy changes to prevent any Allocation DPD and subject to development on green spaces within Shirley further public consultation. and Ashburton Wards r) Introduce policy changes to prevent loss of ANY Metropolitan Open Land in Shirley or Ashburton. s) Implement policies to maintain areas of MOL and Green Spaces to an acceptable condition and enforce the clearing of any fly tipping in such areas. t) Provide identification of all enforcement orders issued on the Croydon Web such that residents are aware of actions taken and the period by which site owners are required to clean-up such sites? u) The SA Objective for Croydon indicates that central government requires that 10 new Travellers Sites are to be designated for Croydon. Please identify the locations of such sites and allow full public consultation before they are authorised. v) What will be the allocated area [in hectares or sq metres] for each site and will any be allocated within Shirley or Ashburton Ward areas. w) What public consultation will there be before these travellers sites are allocated? SA Objective Item 3 To improve health and IDP reference. The approach to Mr Dave King wellbeing for all and reduce Health future health care and provision Monks Orchard inequalities. a) Ensure that Croydon has a is given in the Caring City Residents Association fully equipped and professionally qualified section of the Infrastructure Observation staffed A&E unit to cope with the large Delivery Plan Agree - No Change number of residents within the London Borough of Croydon area and to ensure that ambulance emergency collection times are within or below the agreed target times for the whole area. b) Ensure that adequate provision of GP Surgeries and Dental Surgeries is made available to an appropriate ratio of residential density for each area so preventing inequality of access.