Appendix 6: Towards a Preferred Core Strategy Consultation Summary Report

207 Consultation Report Towards a Preferred Core Strategy for

April 2010

208 Contents

Page Introduction

Representations count

Summary of representations

Workshop and meeting summaries

209 Introduction

Published in February 2010 the second Core Strategy report, Towards a Preferred Core Strategy, incorporated feedback from ’Imagine Croydon: Core Strategy Issues and Options - Initial Report’ and provided more detail on preferred options.

Consultation period: 08/02/10 – 21/03/10

A total of approximately 200 people attended workshops: • Approximately 50 in attendance at each workshop. They were held on four consecutive Saturdays at the following venues: Phoenix Community Centre, Christ Church Hall, Purley, , and Hall. • 11 people made video comments at the weekend workshops, these were uploaded to the Spatial Planning Services’ Youtube channel.

A total of 91 formal representations were received: • 11 representations received online via the consultation portal • 80 representations received by post and email

210 Representations count

1. CS1 Modified Spatial Strategy - Total* 292 2. Transport and Movement 223 3. Homes 196 4. Enterprise Locations+ 188 5. CS1 Modified Spatial Strategy Introduction/Questions/Misc* 121 6. Community Facilities 110 7. Climate Change, CO2 and Water Management 108 8. Spatial Objectives 78 9. CS1 Qualifications to Spatial Strategy (inc. town centres/retail)* 73 10. Green Grid and Rivers 72 11. Delivering the Preferred Strategy 67 12. Education and Skills 66 13. Spatial Vision 62 14. CS1 Croydon Metropolitan Centre* 60 15. Heritage and the Built Environment 47 16. Industrial Locations 43 17. The Places of Croydon/Spatial Management Areas^ =41 18. The Public Realm =41 19. CS1 Possible Strategic Site Allocations* 38 20. Culture 36 21. Waste Reduction and Management =35 21. Community Safety =35 21. Regional Context =35 22. Sustainability Appraisal/Monitoring =11 22. Document format =11 22. Consultation =11 23. Demographic Factors 6 24. Glossary =5 24. Historical Context =5 25. Past Visions/Imagine Croydon 4 26. Borough Character Appraisal 3 27. A Place with a Sustainable Future Introduction/misc =2 27. A Place to Belong Introduction =2 27. A Place of Opportunity Introduction/misc =2 27. Foreword =2 28. Why we need a Spatial Plan =1 28. Croydon's Core Planning Values =1

*CS1 Total – The top commented policy was CS1 ‘Modified Spatial Strategy’. However, there are many discrete issues within this chapter and so these have been included as separate issues in the list e.g. CMC, town centre hierarchy/retail. ^The Places of Croydon/Spatial Management Areas include all the comments received about individual places +Enterprise Locations is high up the list due to the volume of responses received on Park/CPFC

211 Summary of representations

Introduction • Welcome references to Plan and draft replacement London Plan, but clarify that London Plan forms part of the development plan for the borough and is developed in tandem with it. • Welcome the fact that flood risk has been identified as a constraint to be addressed ahead of improvements to transport facilities/homes growth in Purley. • Fully support the long-term redevelopment and regeneration of Croydon Metropolitan Centre and its environs • It would be useful if the four areas (north, south, east and centre) matched those of the areas being used by police, the council through the street based services review and Children's Services. • Meeting the housing, employment and leisure needs of the Borough's residents should be referenced in Fig 1 - Croydon's Core Planning Values. • Not enough weight on the need to provide family homes – a major contributory factor to social sustainability. • A presumption in favour of allowing change and development in which individuals and organisations are prepared to risk investment of their own resources (except where there is a very convincing case to the) should be referenced in Fig 1 - Croydon's Core Planning Values. • Croydon should relinquish City status aspirations and focus on being an Outer London borough. Also a lack of reference to neighbouring Surrey, yet mention of Gatwick and Brighton that are miles away. • Overall the document seeks to give rather more weight to the protection of the interests of 'the haves' (the majority) than to meeting the needs of 'the have nots'. Resulting discontentment from this has implications for crime and increased public spending. • Need clarification on what ‘heritage led renewal’ means for Crystal Palace. Especially given the Council’s poor record on protecting the Conservation Area – now ‘at risk’.

Why We Need a Spatial Plan • Particularly support cross borough working especially in relation to Biggin Hill Airport lies. • Why no mention of key issues being faced by your borough, for example in relation to flooding, employment and housing. Furthermore, whilst the regional context is welcomed, including a reference to cross borough working, there is no information on cross boundary issues, including migration and the “Gatwick Diamond and other growth areas”. • Upgrading of transport links (Thameslink, extensions and Crossrail) will improve accessibility of Croydon and make it more attractive to central London businesses looking to reduce overheads. It should be competing directly with central London for employment. • In general the document is well set out and addresses many of the issues and problems. However the previous iteration was better in that it identified key areas and locations based on actual communities. • Council should add London Sub-Regional Transport Plans to ‘regional context’ list on p.20. • Decision to make Heathrow the London airport (freeing up for development and saving us from relentless airport expansion plans) should be mentioned in the historic context. Also why no mention of the ill-fated Water Palace on Purley Way. • Fail to see what impact short-term sporting events in London (in 2012, 2015 and possibly 2018) have on Croydon’s long-term planning strategy. • Rise in the range of leisure activities undertaken suggests we should sometimes consider releasing Green Belt sites for these purposes. • Figure 10 appears to suggest CMC has been excluded from the residential character appraisal – is this correct? • Figure 3 – Spatial Management Area (opportunities and constraints), the boundaries of the maps overlap (see Croydon and Addiscombe0. Even if the maps are to be printed on a small scale they need to be more accurate. • Need to make sure demographic change is seen as a potential asset which could help the future regeneration of Croydon’s districts. • Suggest the inclusion of a health deprivation map to identify where investment, regeneration and other mechanisms could be focussed. We would stress that the baseline health conditions of the borough should be understood and outlined in the LDF and monitored through the AMR. • Core Strategy should reflect the polysystem approach being taken forward by the NHS (A collection of services, working together to help local people with their healthcare needs). This would also be linked to enhanced GP surgeries, known as GP-led health centres. • The Core Strategy should be flexible and acknowledge the changing pattern of care provision. A flexible policy should allow the PCT to manage its estate is suggested.

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Croydon in 2031 • Vision should include reference to an adequately housed population • There should a Spatial Objective in respect of property and technology resources to promote full employment • Reference to Biggin Hill welcomed –can supplement the services provided by the major airports via nice business transport • Reference to both physical health, mental health and well-being of our population should be made in objectives 5 and 9 i.e. ‘Conserve and create spaces and buildings that foster healthy, cohesive communities’ / ‘Increase access to green space and nature for all Croydon residents...’ • Spatial objective 6 should be reworded for clarity: ‘Ensure that new development and built heritage integrates, protects and enhances biodiversity and keeps ecosystems in good condition.’ • Spatial objective 8 should include reference to improving, restoring enhancing and protecting land and natural resources as well as responsible use. Explicit reference should be made to reducing greenhouse gas emissions, living within environmental limits and reducing consumption of natural resources • Spatial objective 9 should include reference to improving and restoring biodiversity as well as enhancing and protecting it in all ecosystems. Active participation in improving the environment and increasing access to greenspaces in areas of deprivation should also be included • Spatial objective 10 should include reference to minimising flood risk as well as tackling it. Reference needed to prevent inappropriate development in the floodplain alongside inclusion of improvement in flood resilience for new and existing developments including retrofitting existing buildings with SUDs. Objective welcomed but document fails to display how this will be addressed via infrastructure improvements • The use of drawings is a very positive means of expressing the vision, rather than the normal paragraphs of text in Core Strategies. Overall presentation of the vision and maintenance of a short and straightforward list of objectives is very well done. Some not as positive. • A more concise locally distinctive spatial vision is needed, setting out how we aim to achieve the vision, indicating timescales and the quantum of development. The visual representation of the vision is an interesting concept. Suggestion that it is made more succinct, and represents the borough as a whole (appears to be more focus on the CMC) • CMC is identified as an ‘Opportunity Area’ for significant growth, the vision should explicitly include the potential to be a desirable and attractive place to live and work. A further bullet point under “We are Croydon” referring to “A Living and Working City” should be added. Include reference to quality of design as an important element in seeking to meet the objectives of the vision. Becoming an attractive place will create investment opportunities for homes, jobs, retail and leisure uses to aid the overall regeneration of the Borough, this should be recognised • The vision needs to mention the importance of a top level football club and stadium to the community and to Croydon’s city status. • Croydon is not once described as a ‘city’ within the 10 objectives, merely as a ‘place’ or ‘Borough’. This is inconsistent with the vision which describes Croydon as a city throughout. • A spatial objective needs to get to the heart of what it means to be a ‘city’, what facilities and attributes a ‘city’ should have, as opposed to a town or suburb. These facilities should include a community stadium and a top class football club. Within the UK, there are no other cities of Croydon’s scale that lack these attributes. Objective 4 needs to emphasise the importance of protecting existing facilities e.g. Selhurst Park. At present the wording implies the emphasis is on providing new facilities, it also needs to specifically mention ‘sporting’ facilities • The vision attempts to satisfy everybody's dreams, but omits a requirement that development should be on a human scale - the individual should not feel dominated by large buildings and wide roads • The vision puts too much onus on city status and large projects (new Council HQ, University, Arena etc), this is an easy option and diversionary to the difficult tasks that need addressing i.e. improving the town and welfare in practical ways for its people • Key concern is whether the spatial vision and objectives can be fulfilled in the absence of major infrastructure investment, and expensive site assembly • Spatial object 4 omits reference to policing, suggestion to amend: 'Provide well designed community, education, health, policing and leisure facilities to meet the aspirations and needs of a diverse community' • Some spatial objectives relate to elements of social, physical and green infrastructure, the objectives would not necessarily ensure that new development is delivered alongside all the infrastructure that is necessary to support it including water and wastewater infrastructure. Include an objective relating to the provision of infrastructure and in particular the provision of water and sewerage infrastructure required to support growth; necessary to avoid potential impacts if new development is provided ahead infrastructure required to support it e.g. sewer flooding, pollution of watercourses and problems of low/no water pressure. Such impacts could impact on the vision of ‘A Sustainable City’

213 • Propose replacing “we want to be London’s most enterprising borough” (which only applies to certain parts of the borough) with “we want to live in a pleasant place with high quality civic & cultural facilities”. • The 6 ‘city’ themes on p.22 are based on CMC and do not directly relate to the south. • What is a “cohesive community”? (sounds threatening) [pp.32, 43]. • Croydon Council Objective 13 says ‘Mitigate and Adapt to Climate Change’ but later in the document this is Objective 8 on Page 23. Also suggest a new para on ‘sustainable city’. • Spatial Vision should recognise the role and function of the Purley Way corridor as an important retail warehouse location - There are no spatial objectives relating to retail provision. It is an important aim to enhance the existing retail facilities of Croydon, including the retail warehouses at Purley Way. • In general we agree with the spatial objectives identified. However, the spatial objectives fail to address the sense of security within the environment either within residential areas or central Croydon. • Health provision in Croydon is inadequate. • Spatial objective no. 3 – fails to address Central Government’s imposed housing quota’s upon Local Authorities and the resulting pressure to erode the green belt. • I am glad to see that as well as an overall vision the separate parts of the borough are being considered in an individualist way to boost their unique characters, something that I have mentioned before as being I personally consider very important in the scheme of things. • English Heritage welcomes the proposed discrete Historic Environment Strategy but suggests that more explicit links to the historic environment and other strategies within the document are required. Also disappointed that the long term vision up until 2040 (page 22) does not mention the historic environment at all, which given the strong character it imparts is surprising. We therefore suggest that it is added to the vision for “a sustainable city” (bullet point 5) where the natural and historic environment should be seen together. • In general terms English Heritage supports the 10 spatial objectives identified in the document although we have suggested some amendments to the wording to provide the linkages with the historic environment to emphasise the holistic approach. • Spatial objective 6 is slightly ambiguous in that the emphasis appears to be on new development. We suggest that the wording is amended to read “...built heritage is enhanced by high quality new development that respects its character and is therefore well integrated.” • Page 32, 3.12, It is essential that this objective explicitly recognises the heritage value of the Borough’s open spaces. It should be recognised that many of the open spaces in the Borough including those which may have nature conservation value may also be of historic importance. • PPG15 makes reference to need for local planning authorities to consider the heritage value of historic parks and gardens and the wider historic landscape when defining planning policies (para’s 2.24 and 2.26). In addition many of the open spaces identified may have an integral relationship with the significance of other heritage assets, such as the special character and appearance of a conservation area, or setting of a listed building. We suggest therefore that the words “historic interest” are added to the end of the sentence. • Page 23, Paragraphs 3.3 and 3.4, the recognition of the historic legacy is welcomed, as is the commitment to be respectful. However, the role that historic areas such as Surrey Street, and Church Street can play in supporting activities other than shopping should be referred to – for example these are just the sort of areas that provide the distinctive character sought by the creative industries. The quality of the space and public realm in historic areas should also be recognised – not just the buildings. • Page 28, the spatial vision for “A Sustainable City” should make reference to the retention and re-use of existing buildings where appropriate- reducing both consumption of new materials and also waste generation. • Regarding Objective 1, it is not necessary to aim towards being the 'Premier business location in South London' etc. It is better to aim towards being 'a key business location in South London' etc. • Why call Croydon a “City” it’s a shambles. It’s not even a proper borough! • Support the overall principle of ‘A Caring City’ but would value expansion of this to incorporate the need to address health deprivation and inequalities, encourage healthier lifestyles and development that supports healthier lives. • Croydon’s aspirations are rightly ambitious. We are concerned, however, whether these are deliverable by 2031. • While Policy EC2.1 in PPS4 (2009) requires Local Planning Authorities (LPAs) to set out a clear economic vision in development plans, it also stipulates that policies should be flexible enough to accommodate sectors not anticipated in the plan and allow a quick response to changes in economic circumstances. • PPS3 (2006) similarly calls for the planning system to deliver a flexible, responsive supply of land (paragraph 10). It should also be sufficiently flexible to accommodate market change and site-specific characteristics. • Furthermore, PPS12 requires Core Strategies to be effective and therefore deliverable, flexible and able to be monitored (paragraph 4.4).

214 • Given the physical constraints to development, its current and emerging job and housing targets, and Croydon’s ambitious aspirations we ask that the Council seeks to improve accessibility to existing green spaces rather creates new green spaces. • National and regional expectations for Croydon are high. The Government has identified Croydon as a Growth Area, the adopted London Plan (2008) identifies Croydon Metropolitan Centre as an Opportunity Area (Policy 2A.5) and strategic office location (paragraph 5.150), and the draft Replacement London Plan (October 2009) identifies Croydon as an Opportunity Area (Policy 2.13), recognises it as London’s largest ‘Metropolitan’ town centre (Policy 2.15) and identifies it as a potential Outer London Development Centre and strategic office location and possible education location (Policy 2.16). • Although we agree with the objective of fostering an environment where "indigenous, innovative and creative enterprises can prosper", there should be some space for enterprises new to the area as well as those indigenous to it. • Agree whole-heartedly with all 10 Spatial Objectives identified • "Existing office blocks have been...converted into homes..." - this is good; Central Croydon needs people to live there. At the moment, it's just a place people to go to work, shop or spend leisure time, but they all seem to treat the town centre badly and then go back to the outlying suburbs where they live. If some people actually lived in Central Croydon, it should make central Croydon more 'cared for' and treated better by all. • An Enterprising City - shouldn't the Brit School (full of star-struck kids with their pushy parents) be mentioned in "A Creative City" not in ENTERPRISE? And also shouldn't Heathfield be mentioned in "A Sustainable City" not in ENTERPRISE? • A Learning City - Croydon College being upgraded to a university certainly requires a vivid imagination! • A Connected City - This is something Croydon is already good at - public transport links, and the best bit of Croydon is , allowing us to get fast trains away from Croydon! Can you bring the "comprehensive cycle network" forward a bit....I'll be in my 60s by 2031?! • A Sustainable City - Croydon is also already good in this area, with lots of green spaces (esp. in the south of the borough) - just DO NOT build on these valuable green spaces ! • Spatial Objectives - Numbers 6 and 9 are quite similar and could probably be combined. Also 8 and 10 are quite similar too. • Number 7 should specifically mention encouraging cycling, walking and the use of public transport, and not be used to build/widen any more roads for environmentally hostile motorists!

Towards a Preferred Spatial Strategy - Spatial Strategy Approach • Initially surprised to see West linked with Purley & Old Coulsdon with other areas, but see the logic & support this. • Unclear how and Old Coulsdon relate better to Shirley etc than to Coulsdon and Purley – looks very odd. Suggest that /Fieldway justify being the 5th area in their own right • Definition of conservation and enhancement should be expressed more positively to also promote development that can enhance the character of an area. • Support the three spatial strategy approaches set out under paragraph 4.3. • The strategy should take into account the potential upgrade of both West and East Croydon Stations to improve rail services and facilities to support East London line of West Croydon and the feasibility of a greater intensity of building around the station. • Further consideration should be given to dispersed growth involving the release (where fully justified) of previously undeveloped land throughout the borough. • ‘Renewal & Growth’ be expanded to allow for a strategy which ‘Promotes and supports appropriate new development and intensification in areas of high accessibility either within existing settlements or as planned, coordinated extensions to existing built-up areas’ • The 16 Places and Spatial Management Areas are purely politically contrived and won’t stand up to planning inspectorate. • Must have a key diagram. • Need to show scale (numbers) of growth and explain how 4 spatial management areas and 3 spatial strategy approaches relate to places already able to accommodate growth as well as those areas that can following investment (e.g. CMC overlaps with – what does this imply?). Currently doesn’t provide enough detail to inform other DPDs that will follow. • Encourage the Council to consider a wide range of employment uses on existing and new sites to ensure that employment demand within the borough is met. • Concerns that without major infrastructure investment (yet to be identified) longer term growth which is envisaged along A23 will not be acceptable.

215 • Furthermore, TfL suggest that third-party land take will probably be needed to achieve necessary improvement and this may not be achievable or desirable – reducing car use should be the priority. In the meantime, suggest the Council set up a CIL/S106 pot to start gathering funds. • It only makes sense to direct growth to areas where the transport infrastructure already has spare capacity. Wrong to put it there and assume improvements to follow. • Need to make it possible for people to live, work, go to school etc., without needing to use the car. • Directing growth to more accessible areas sounds logical but is it? It could lead to overstretching areas already at full capacity - Need to realise that growth as proposed just might not be feasible and it is not a priority for the people of Croydon. • ‘Conservation and Enhancement’ is a confusing title as these are two distinct approaches. Also suggest associated wording - “An approach where significant change is not envisaged but where it takes place it sustains and enhances the character of an area.” • CMC should not be considered along with its environs as they are very different areas. • It is considered that the wording of conservation and enhancement is negatively worded. Proposed wording to overcome this has been provided by BNP Real Estate. • The application of the proposed three Spatial Strategies should be in accordance with the needs and priorities of each place. • Coulsdon should benefit from supplementary regeneration status • Expand the role of each of the centres further within the document with further text to quantify what is required fro each centre. • If the growth is to be directed to existing town centres an indication of the level of predicted growth needs to be identified in the final document for each centre. • There is no mention of tall buildings within the document. It is proposed that a further spatial objective be added to encourage high quality, high density development including tall buildings. • It would be useful to define what constitutes family housing as it has been ‘identified’ separately from other housing figures.

Towards a Preferred Spatial Strategy - CS1 Proposed Spatial Strategy • Unfair that almost half of the borough is virtually exempt from growth. Both Addington and Selsdon (particularly if served by a Tramlink spur) have capacity and access to open space to accommodate significant growth. It needs to be explained hwy there is a lack of development towards to the eastern side of the borough. • East has education capacity – surely this should be a reason for putting more housing there. • The south of the borough could accommodate far more growth. Flood risk at Purley is a poor excuse as most of Purley is on hills. Makes no sense to squeeze growth into the already highly developed areas of the borough. • Represents a better solution to meeting growth than that proposed in first iteration of the Core Strategy. • Disagree with proposal that CMC should be sole area of growth in homes/jobs over next 10 years. Other areas already well related to existing infrastructure such as should come forward too. • The area around , the subject of a forthcoming Masterplan accommodating much growth should be shown on fig. 14. • Flood risk issues in Purley are considerably underestimated. • Disappointed that so little is said about resolving traffic related issues in Purley – a new north/south bypass for Purley is essential not just for local considerations but also to meet London Plan policies. • Arguably, Purley is already making a disproportionately large contribution to perceived public needs and should not be targeted for further significant growth as it cannot support (in infrastructure terms) the proposed growth. • Proposal to provide 45% of new homes for non-family purposes would prejudice the character of Purley. • Kenley and should both be considered along with Purley in growth terms as they both have stations without the same flood risks. • Increase industrial jobs capacity in Selsdon/New Addington and direct more of the housing growth their too. • It is inevitable that some Greenfield sites will need to be released to meet demand for family homes and the strategy should not discount the idea at this stage. • Certain areas of the borough seem to be given protection whilst others are targeted. This suggests that some areas are considered to be ‘special’ over others.

Towards a Preferred Spatial Strategy - Qualifications to Spatial Strategy • Propose that Whitehorse Shopping Parade be designated a Local Centre as it is comparable in terms of range/scale to Limpsfield Road Local Centre.

216 • Purley Way should be identified on the map as it too is an important part of Croydon’s retail offer. Why has it not been identified as part of the corridor containing new jobs and homes? The existing function of Purley Way needs more recognition within the DPD. • There should be sufficient consideration given to reducing the surface water runoff from development. Some areas identified are located in the areas at risk of surface water flooding such as , and the Wandle Link. • It would be useful to expand Paragraph 4.8 of the emerging Core Strategy to articulate the future roles each Town/District/Local Centre will play in the spatial strategy for Croydon. • Welcome greater cross-borough working but a formal mechanism is needed. Particularly an issue for New Addington, where challenges are high and town is tightly constrained. Concerns have been raised that there is a lack of consideration regarding cross boundary issues/opportunities within the document. • Agree significant development along A23 should only come forward once transport deficiencies are addressed. • Welcome changes to town centre hierarchy to bring it in line with London Plan, yet New Addington remains an anomaly. There is a need to remove all references to town centres, as these are not formally recognised within the London plan, rather they are district centres. This has been repeated throughout the document which makes it confusing. Further clarification to the hierarchy of centres within the borough needs to be made.

Towards a Preferred Spatial Strategy – Croydon Metropolitan Centre • Agree that CMC and environs 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. • Question both CMC and OAPF boundaries as shown in fig.17 as entire West Croydon Masterplan boundary should be encompassed. • Core Strategy should note that The London Plan seeks the maximum reasonable amount of affordable housing from residential and mixed-use schemes, having regard to borough affordable housing targets and the need to encourage rather than restrain residential development and the individual circumstances of the site (including site costs, availability of public subsidy and other scheme requirements). • Strategy is vulnerable as making CMC an attractive place for family homes may not be achievable. • Support strategic direction for the CMC and areas designation as a Strategic Office Location and an Opportunity Area in the London Plan and efforts to establish a ‘major developers forum’ to support this and bring forward the short-term growth identified through the OAPF. • Need some reference to District Energy or improvements to energy efficiency. • Evidence needs to be presented as to how all the extra housing and supporting community facilities can be accommodated in terms of typologies as we remain to be convinced that this strategy is viable. • The ‘contigency plan’ set out in para 4.17 should be developed further as it’s highly likely it will be needed. Especially as there’ll almost certainly be a lack of public money to address the infrastructure limitations identified. This involves identifying what infrastructure is essential for growth and what do we do if it doesn’t materialize. • In relation to the contingency plan, Council needs to clarify at what stage a review of green spaces would be triggered and ensure it takes account of London Plan policies 3D.9 and 3D.10 on Green Belt and Metropolitan Open Land. • Unacceptable to countenance building on Green Belt as a contingency – if growth cannot be accommodated on brown field sites, then reduce the level of growth planned. • Welcome planned growth for CMC which has huge potential for jobs and homes growth. Must not be delayed for sake of too many studies. • Fig. 16 confusion over boundaries and comprehensiveness of information. One respondent has requested that the boundaries be clarified for the Mid Croydon Master plan. • Disagree with aspiration to build family homes in CMC as space is so tight and densities must be maximized to hit targeted growth, only most appropriate type of residential accommodation should be placed there. • Need to balance the impact on surrounding areas against the benefits of CMC intensification and recognise the impacts are likely to be, on balance, positive. • Is the Council not considering changing the Green Belt boundaries? Para 4.2 infers the Council is no longer considering this. Any de-designation would need to be considered through the Core Strategy. • The Council should consider the approach set out in PPS 4 (sequential testing) for edge of centre developments within the CMC to ensure that the proposals do not impact on the vitality and viability of the centre. • The Council need to identify at what stage the loss of Green Belt/MOL land is acceptable to compensate for the failure to meet the CMC targets. • The Core Strategy should recognise that housing will be dictated by site constraints.

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Towards a Preferred Spatial Strategy - Possible Strategic Site Allocations • Want to see Cane Hill come forward as part of wider Coulsdon TC regeneration in short term. Coulsdon should be recognised as a town centre, incorporating further areas surrounding the existing district centre. • Support mixed-use (commercial and housing, but not retail) at Cane Hill which considers the town centre, local industrial estates and nearby residential and recreational areas. • Agree with recognition of Cane Hill having sub-regional importance and designation for ‘essential new jobs and homes’ – accords with HCA responsibilities. However, as per PINS advice, more detail needed, e.g. a clear objective/aim for what is intended to be achieved in the overall development; identification of site constraints; all the different land uses/proposals and their scale that the site is to accommodate; what infrastructure is needed to make that development a viable, attractive, sustainable location; and milestones for the progression of the development. • Given the complex relationship between Cane Hill and surrounding area as well as the shared aspiration to slide development down the hill, suggest the Key Diagram identifies whole of site not just MDS boundary. • Question whether both housing and commercial aspirations for Cane Hill can satisfactorily be met. Most important need is for new homes to support a thriving town centre. • Not enough strategic sites are identified to address transport congestion. How will traffic and congestion be dealt with in the document from developments around strategic sites? • Boundaries of strategic sites need to be shown on a plan. Further information should be provided – see PINS document for specific information on strategic sites. • Not enough detail for either site given – also need to make sure they are ‘strategic’ i.e. not just a large housing or mixed use site, but one that is essential for delivery of Core Strategy objectives. • Essential that the poor PTAL of Cane Hill is improved as part of redevelopment. • The failure to translate Croydon Council and London Mayor press statements of support for CPFC into the wording of the Croydon Core Strategy is a serious contradiction and a serious concern. This is without doubt a strategic issue that needs to be addressed in the Core Strategy and cannot be left to the Site Allocations DPD. • East Croydon Station is the key transport hub of the Metropolitan Centre, therefore new employment with residential opportunities and an overall mix of uses should be promoted in this area. • East Croydon is identified as a possible strategic site in order to “remove capacity constraints key to focusing the majority of growth in Croydon Metropolitan Centre”. This is aspiration is understood, but it should not act as a delay to much needed proposals coming forward in the area that are already being coordinated through the ongoing East Croydon Masterplan process. Clarification required regarding the sites strategic allocation.

A Place of Opportunity General Points • Welcome harmonised hierarchy of Croydon town centres with the London Plan. • Along with welcome sections on education and skills and culture, an additional section on ‘Health and Well Being’ should be added. • The 15,000 new jobs are important for sustainable economic growth but now need to see the where they will be located. • Inward investment/economic success relies upon- o a better reputation – trendy, progressive and with an iconic centre o Improved safety and security (including a more varied night-time economy) o A good workforce to choose to locate in an area – we should work towards providing this. o Improved retail offer in CMC, emphasising the importance of Croydon as a location for major regeneration and the need for quality retail. • Where there is a need for better access to services, facilities and employment by socially excluded groups, promoting new centres is supported. • In line with PPS4 and to encourage sustainable economic growth, Croydon should develop flexible policies able to respond quickly to changing economic circumstances. • Too ambitious for Croydon to be 'the premier business location in South London'. We should focus efforts on micro businesses and not overlook the informal economy. • Don’t overlook locations such as the Purley Way and just rely on town centres to provide economic (including retail) growth opportunities. Yet others point to the danger of peripheral retail detracting from the town centre retail experience. • Given the nature/causes and the depth of the recession it is unlikely that we can rely on the retail sector for growth - It will probably contract/consolidate as a traditional, floor space hungry sector. • Don’t underestimate the opportunity for providing both skilled and non-skilled jobs that Biggin Hill Airport represents for Croydon (particularly New Addington) residents.

218 • Ensure adequate weight is given to increasingly important ‘green’ jobs in the local economy. Britain has the potential to be a leader in green technology but is losing out to places like Germany. • Shopping parades should be re inserted into the hierarchy as they serve an important function. • Whitehorse Shopping Parade should be re-designated as a local centre.

Homes • Number of homes needs to be quantified, • Concern about proportion of family/non-family homes and how they are distributed around borough (balance) – in particular lack of justification of this approach. How does this accord with population and household projections for the borough (both ONS/CLG and GLA)? More sites for family homes need to be found outside of Croydon Metropolitan Centre. The housing figure in CS2 does not meet the Draft Replacement London Plan target or the existing London Plan target. • Affordable Homes approach to be guided by mixture of London Plan evidence base and LHMA. There is a lack of detail on affordable housing in the document. • There should be a requirement for intermediate (shared ownership) homes in new developments included in the Core Strategy • Implementation of London Housing Design Guide does not need to be in Core Strategy if in London Plan. The effect on viability of development in Croydon of this policy is raised. Some comments ask for more reference to standards such as Lifetime Homes. The text should be more flexible and reflective of the viability of development in different locations • The contribution that Croydon Tramlink can make to the achievement of sustainable patterns of growth adjacent to its present alignment should be recognised. • The use of Green Belt and MOL for housing not addressed. The consultation fails to test the contribution of development arising beyond the existing built-up area. The growth agenda and the provision of more family housing cannot be achieved solely by seeking opportunity sites within the built-up areas of the Borough. If the desired choice of housing is to be provided sites with good public transport accessibility beyond existing settlement boundaries will need to be developed. • Suggestion of new settlement at Land at Kent Gateway, Addington. • Suggestion of strategic housing site at Dunmail Drive, Purley • CS is overly reliant on Croydon Metropolitan Centre and the A23 corridor to provide new housing, in particular family housing but does not contain any guarantees that it can deliver the environmental and social infrastructure improvements needed to encourage and enable people (in particular families and older people) to live there. Doubts expressed about the viability of development in Croydon Metropolitan Centre and the ability of sites there to provide the number of new homes at the level contained in CS2, especially family homes. • CS3 needs to have more specific reference to how infrastructure to support new homes will be provided. • CS3 should include an ideal housing density map. • The Core Strategy should include site allocation criteria which are fair, reasonable, realistic and effective in achieving London Plan targets for Gypsy and Travellers pitches. • New indicator on number of new homes built above Level 4. • New indicator on loss of family homes in the Spatial Management Areas • There should be a policy positively encouraging the development of family homes. • There should be reference to the loss of family homes through sub-division into flats. • There is little/no mention of disabled persons within the document.

Industrial Locations • Policy CS3 (set out in figure 21) is confusing and needs clarification – perhaps by providing actual examples. • Support for ‘5 tier approach’ but some concern that it could relax protection for Strategic Industrial Land too far. • Support for retention of industrial space for own sake but also as a way of keeping freight concentrated along Purley Way and not negatively affecting less suitable routes. Sites of strategic importance for transport activity should be identified (in addition to E Croydon Stn), together with alignments or corridors to be safeguarded. • Suggestion for specific policy on safeguarding land for transport functions (bus stations, transport support functions, consolidation centres etc) – a local interpretation of London Plan policy 3C.4 Land for Transport and the ‘Land for Transport’ (March 2007). • Some consultees agree with thrust of CS3 (provision/protection of cleaner light industrial activity in residential areas (with selective release for community use) and heavier industry in more appropriate locations) but call for greater flexibility. Others question the robustness of the evidence base suggesting there needs to be a full 'Industrial Land Survey' which evaluates industrial supply on a site by site basis.

219 • Policy CS3 should be altered to allow more housing on the ‘scattered employment sites’. On the other hand, others point to the need to safeguard employment sites within walking distance of homes. • Police related activities should be seen as appropriate uses for industrial sites where appropriate. • Welcome recognition of importance of sites beyond the borough boundary, such as Biggin Hill, but suggest more is done (e.g. road/transport improvements as well as partnership working) to exploit this situation. • Don't allow green space to be converted to industrial use. Use CPO powers to buy vacant industrial space (e.g. Gloucester Rd) and bring back to industrial use. • Not enough weight given to the principles of sustainable development, such as minimizing energy consumption, reducing pollution risks, cleaning up contaminated land etc. • Performance should be judged against the Strategic Flood Risk Assessment, Surface Water Management Plan, the number of developments permitted against Environment Agency advice and the number of specific measures included in development proposals for mitigation of surface water run-off, for example rainwater harvesting.

Enterprise Locations • Video comment – need a 5 boro forum to co-ordinate activity in Crystal Palace area. • Just 2 responses were received that directly referenced Cane Hill. The first offered very strong support for an Innovation Park element, whilst the second considered it essential that any proposals for “innovation” uses undergo a rigorous process of viability and market testing to demonstrate deliverability. The point was also made that there may be more suitable sites elsewhere within the immediate area for this facility. There was also a call for flexibility regarding the nature of employment uses as demand for an innovation park appears weak. • As with industrial capacity, comments were made concerning the importance of local employment activity (both homeworking and commercial premises in local centres as well as town centres) especially for people who also need to juggle family commitments but also for others involved in the informal economy. • The proposal to locate Enterprise and Opportunity Centres (EOC) in areas playing to their strengths was supported, but numerous respondents flagged up the danger of encouraging town centre uses in out of centre locations. Also given its large over supply of tired office stock (and it’s adaptability for serving small businesses) some concern was raised that it might undermine regeneration activity in CMC. • Conversely, the edge of centre environment (with it’s older, more affordable premises) can be regarded as a good location for fledgling businesses – especially the valued, independents that help combat the ‘clone- town’ syndrome. A problem for CMC as unusual/specialist shops/services can be priced out. Whilst some parts of the borough are more affordable there lack of parking facilities can sometimes make them less attractive/viable. • It was also considered that the Core Strategy should identify the role/sectoral specialism of all the EOCs not just some. Suggestion made that Portland Rd ( as a cluster of small offices) could formally operate as one. The nature of the EOC’s was questioned with some considering it essential that the detail of exactly how they would operate be identified (ie. by who, for who, relation to surrounding area etc) yet others of the opinion that they should be more organic, supportive and avoid temptation to micro-manage. • In relation to out-or-town retail opinion was divided with some commenting that the retail function of Purley Way was now established and should be recognized as such in the Core Strategy. Whilst others considered it should be firmly resisted. In some places there is also concern that shop vacancy has as much to do with unrealistic landlord rental expectations as demand for premises.

Education and Skills • Whilst there was support for a form of university in CMC and/or Cane Hill, there are concerns that with the quantum of new jobs and housing (and associated infrastructure) to be provided, there simply won’t be enough space to accommodate it. Further clarification on how this is to be provided is required. • The emerging partnership between Sussex University and Croydon College is welcomed and recognized for its potential to assist with the aim of being “the premier business location in South London and the Gatwick Diamond”. As was the concept of a multiversity which was seen to be more appropriate to local needs. • However, others argues that measures such as increased training and learning opportunities for young people and entrepreneurial training are a more pressing need suggesting that investment in CALAT centres is not only more realistic but also preferable. • In terms of school place provision the point was made that the Council should not be permitting new homes without ensuring sufficient infrastructure is in place. • The idea of sites such as higher PTAL EM5 sites for educational use was supported as long at it was not be at the expense of other uses, including residential. • Figure 23 is confusing as there are more areas than boxes indicating capacity and references to half a school.

220 • With excess school accommodation shown in the East Spatial Management Area, numerous people ask why isn’t it taking a greater proportion of the Borough’s population growth? Furthermore, without this growth, won’t the schools in this area face funding issues if they are under-utilised? • School planning must take a long-term view as adequate school place provision is of the highest importance. Most parents don’t have the option of taking their children to a school beyond their local area – and nor should they have to. • New sites are needed as building on playing fields is a poor solution. Possible sites may be found in edge of town centre locations, or perhaps where there is no space within the built up area, within the Green Belt. • Don’t forget that for many no matter how much a policy tries to increase people's education levels, there will always be people below those ideal levels. Rather than viewing this as a negative, they should be recognised for the contribution they can make – e.g. find ways to help them engage with the formal economy despite lower academic skills. • Concern is raised over the general lack of spaces for pupils in schools in Croydon. How will this be addressed with the proposed increase in housing numbers within the Core Strategy? • The south is under utilised, whilst the north is strained. Why is there a lack of direction to the south/east of the borough?

Culture • Strong agreement that for it’s size, Croydon is poorly served in this regard - cultural activity and the creative economy should be nurtured and provided with physical spaces to make this happen. Need to move away from the notion that culture is a commercial enterprise that needs to pay its way. However, it must be planned comprehensively with regard to the wider area/context. • Strengthen ties between business community and arts and examine sponsorship potential. Especially as Council does not appear to support private venues that are used for these constructive purposes. Also the important link between cultural activity and the aim of being the ‘premier business location in South London and the Gatwick Diamond’ should be made more explicit. • Welcome proposal for more venues and recognition that a strong cultural sector is key to a vibrant town but need to make sure existing facilities (where appropriate) are protected and new ones strategically located to lessen negative impact of bars /take-aways. But guard against undermining existing ventures by generating too much competition. The emphasis should be on diversification and quality rather than quantity with both young and older people’s activities considered. • There is a failure to mention a number of valued cultural venues/activities such as Ruskin House, Croydon Music Service, Purley Music Week etc. • Small is beautiful – think small scale activities, but a lot of it. Provide ‘micro opportunities’ as creative and innovative ideas and outputs often come from the grass-roots. • On the other hand, there is a need for higher-profile and/or larger venues for a town the size of Croydon. Certainly, both and should be protected. Fairfield indispensible, but tatty and theatre-wise we’re beaten by nearby boroughs. • Consider alternative venues/workshops for this sector such as empty premises above shops, Beulah Road, etc. Also need to make the link with the historic environment – encouraging re-use of historic buildings as quirky and affordable space. Don’t forget importance of public art. • Need considerably more small sports centres, community halls, and other places in the centre and in the rest of the borough too where affordable leisure activities can take place. • Significance of CPFC has been seriously overlooked and is a very disappointing omission. The club must be valued and supported/protected to secure their future at Selhurst Park. Council needs to appreciate just how great an asset CPFC is. • More emphasis should be put on public art and other features within town centres. • The Culture heading should include Strategic Objective 6. • The council should seek to incorporate historic buildings into culture within the borough. • Support and recognition should be given to the Warehouse Theatre within the document. • Smaller venues should be promoted within the document as well as larger ones. • There is a need for quality venues within the borough, not just quantity.

A Place to Belong General Points • The Core strategy has does not recognise the important contribution that football clubs make to the local economy. There is an opportunity for Croydon to play a pivotal role in promoting initiatives such as football in the community and homework clubs which are run by local football clubs. • It is not always necessary to provide new facilities or relocate existing facilities within new areas. To reverse existing decline, consideration should be given to upgrading existing facilities or building on local brownfield sites located within the heart of the community.

221 • The third theme in the introduction [‘Community Safety] should be cross referenced to spatial objectives and include the Public realm and Transport strategy. • The core strategy should identify the need to support communities in terms of community facilities, heritage and the built environment and community safety.

Community Facilities • Co-location of public services should include educational facilities as well as community health facilities, and emphasis should be on proximity to neighbourhoods and local employment. • There should be specific and positive provision within the Core Strategy, for the retention and promotion of places of religious worship in the Croydon Borough. • Additional spatial objectives should be included in this section to cover flood risk (Ensures that development is located in the most appropriate location in terms of risk of flooding and vulnerability classification; Proposals should provide Flood Risk Assessments as required by PPS25). Additional indicators should be added to objective 8 (Number of developments permitted against Environment Agency advice; Net change open space) [Environment Agency] • More modern healthcare provision and leisure facilities in the town centre. • Croydon’s Core Strategy should better reflect the objectives of the London Plan on community facilities. • The social and community role of the Court Service and other delivery partners such as the police in maintaining safe neighbourhoods should be acknowledged. Add “Criminal Justice Facilities” to 6.6. The policy should provide flexibility for court estate. Her Majesty’s Court Service should be included as a delivery partner who may receive planning contributions. • Policing facilities should be recognised as an important community facility and should be referenced in Spatial Objective 4. An additional section should be added to Figure 27 which outlines policing and emergency services and the need for adequate facilities in the borough to ensure effective policing can continue. • “Where necessary, policing facilities will be provided to serve the community and will be provided in accessible locations which meet modern policing requirements.” [CGMS on behalf of PMA] • Community facilities should include more permanent public toilets. • Indicator for loss of existing facilities under 6.14 [English Heritage] • Need to provide and retain leisure and sports facilities. Some industrial buildings could be used for community facilities. This includes policing uses. • The use of Section 106 agreements and the Community Infrastructure Levy to assist toward providing community facilities should be realistic, proportionate and not harm the ability to develop sites. • It is encouraging that the importance of affordable active leisure and sports facilities has been recognised. The National Institute for Health & Clinical Excellence provides guidance on environment, planning, communities and health promotion e.g NICE PH8 ‘Ensure local facilities and services are easily accessible on foot, by bicycle and by other modes of transport involving physical activity.’ [NHS Croydon] • Need to be realistic. Concern on how Croydon will meet community facilities on top of job and housing targets in the town centre. The Council need to prioritise the issues for which it will seek contributions for so that the total contributions for any one development would not make it unviable. • Confusion over how shared community and faith centres would practically work. General belief that faith groups prefer their own dedicated space. • The whole population should be made aware of the availability of community facilities and services especially those groups who can easily be isolated such as those with disabilities. Improvements should be provided in services for the disabled community to prevent them from becoming isolated. More centres for people with learning difficulties are needed. • Investment in the district centres should be increased to achieve a better balance and take pressure off the town centre. This would prevent people from having to travel to the town centre as frequently. • Health needs to be detailed in the Core Strategy as a cross cutting theme. [HUDU] • The Core Strategy needs to link the provision of community facilities with the aim of reducing health inequalities and meeting objectives such as those from Croydon’s Community Strategy. It should not just be PRIMARY health care facilities under 6.6 [HUDU] • Each of the 16 places might have its own “village hall” community centre which hosts a range of activities, leisure learning, fitness and social. • The importance of a stadium and football club to the community and city status should be mentioned. Crystal Palace FC are an important and valued community facility that are not mentioned. • 6.7 Outmoded community facilities may be replaced locally, and where appropriate, the former community use may be redeveloped for alternative uses. This should be concurrent with a relevant Estate Strategy or where the replacement community facility would better meet local population needs. [CGMS on behalf of PMA]

222 • It is recommended that changes be made to bring the chapter in line with the aims and objectives of the London Plan in connection with Policing facilities. • The need for cemeteries and crematoria should be mentioned.

Heritage and the Built Environment • Some detail in CS8 appears to repeat national guidance and may not be needed. • Support the council’s approach to heritage and the built environment but needs to be flexible to allow for growth /high quality /sustainable new development and regeneration. • CS8 should cover broad density and design principles required to meet the proposed strategic targets. • CS8 should be more explicit in referencing the link to creative industries /culture and aspects of community safety. • Further protection should be given to the historic environment of Purley and Kenley by designating additional LASCs. • Concern that demands for more housing in Croydon town centre will place buildings in conservation areas at risk of demolition or unsympathetic alteration. • CS8 should be informed by the Strategic Flood Risk Assessment and Surface Water Management Plan and Objectives 6 and 8 should be expanded to :- - ensure development is located in the most appropriate location in terms of risk of flooding and vulnerability classification. - Proposals should provide Flood Risk Assessments as required by PPS25. • Additional indicators should be added for Number of developments permitted against Environment Agency advice and net change in open space • Development proposals affecting Scheduled Monuments should be notified to the National Amenity Societies in addition to English Heritage. • Residential character appraisal should include housing within conservation areas. (Note:- Version 3 of the Residential Character Appraisal does include Conservation Areas). • A tall buildings policy, informed by the emerging OAPF, is required. This should be based on an understanding of character and context which can be used to identify appropriate and inappropriate locations for tall buildings. • An introductory sentence should be included – “There is a significant legacy of heritage assets across the borough which includes the following designations: Scheduled Monuments, Statutory Listed Buildings, Registered Parks and Gardens, Conservation Areas, Archaeological Priority Zones Local Areas of Special Character, Locally listed buildings and a local list of Historic Parks and Gardens.” • Clarify the approach to managing Scheduled Monuments and APZs. Suggest “There are currently 6 Scheduled Monuments in the borough and Scheduled Monument Consent from the Secretary of State is required for any work- including repairs. There are currently 50 archaeological priority zones across the borough. Development within APZ’s may require evaluation before determination of the application”. • Suggest “A programme for completing Statements for LASCs will be prepared and implemented to ensure that informed change that enhances their character can be delivered” – cross referenced to the development approaches on p34. • Fourth bullet point, p65, is confused – the role of the council in identification of heritage assets for national designation will be in partnership with EH but it also has a role in ensuring that local designations are regularly reviewed and updated. These two roles should be made distinctive. • There are two significant omissions in the strategy (p66) – promoting enjoyment/understanding of the heritage and built environment and identification of its role as a catalyst for regeneration. • There should be a reference to supporting the Greater London Historic Environment Record by submitting information and using it to inform proposals for change. • The management of heritage assets to retain significance and /or contribution to local distinctiveness should be included. • Maintenance and reviews of the Local lists etc could also be an opportunity for fostering community cohesion through engagement with local amenity societies, volunteers and community groups and also build capacity for future management. There should also be an explicit recognition that benefits of protection include contribution to local distinctiveness and character. • The council needs to be pro-active in facilitating public access to and protection of heritage, not just maintaining lists. • Suggestion a more strategic approach by adopting a numeric programme of CA appraisals with targets informed by different development approaches. • Control of shop front design in CAs should be improved, particularly as the CA ( Triangle) is recognised by EH as at risk. • To support the strategy Croydon needs to provide more resources to conservation and enforcement.

223 • Heritage and biodiversity conservation should be integrated where appropriate. Some landscape features that contribute to heritage are not designated, including boundary trees, coppice coups, boundary ditches, etc. • Conservation Area review should include revision of their boundaries. • The Residential Character Appraisal should include identification of areas/roads to be protected from backland development or intensive flatted development. • Protect Queen’s Gardens’ character and avoid introducing cafés etc. • Names of the CAs and LASCs should be included. • Monitoring should include the following review of Archaeological Priority Zones, local list, housing densities, garden area and tree loss. • Heritage at risk indicator could include detailed statistics. • Evidence and research should make reference to the emerging London Regional Landscape Framework.

The Public Realm • There are not enough accessible public toilets. The provision of public toilets is particularly important to women. Provision within new community or publicly accessible developments or within the public realm should be encouraged. • It is recommended that Spatial Objectives 6 and 8 are expanded to include a section that covers flood risk. This should be informed by the Strategic Flood Risk Assessment within the Council’s Surface Water Management Plan. Flood risk and vulnerability classifications should be used to ensure that development occurs within the most appropriate locations as required by PPS25. • The Public realm and Community Safety as they are written appear to be trying to address similar issues. Consideration should be given to combining these two themes to make to help make the published plan more succinct. • Croydon needs to have an attractive public realm in order to become an enterprising, sustainable and connected city where businesses want to be located and where people want to live and work. • Purley has not had any serious proposals to deal with the fundamental problems associated with the public realm or the weight of traffic flowing through the A22/23 junction. • Spatial objective 10 (tackle flood risk and utilising sustainable urban drainage) should include action points and examples showing practical solutions. • The number of poles located along the highway should be minimised and clear signage specifically for pedestrians, cyclists and motorists should be provided whenever appropriate. • Road layouts should be designed so that pedestrian routes through them are safe, direct and obvious. • The strategy outlines the aspiration to create a public realm which is easily accessible to all. However, it would be useful if there were a few more examples of desired improvements, such as the removal of guard railing. • In areas that is predominately car-based out of town retail parks there is potential, at the planning stage, to ensure that linkages are maximised for any future developments through walking and cycling measures and public realm improvements. • Need effective public realm regulation to ensure that private owners cooperate. • The progress of the Public Realm SPD needs to be clarified. • Emphasis should be placed on the importance of providing a high quality public realm within the CMC and improving the pedestrian experience through pavement materials, furniture, lighting, signage, and landscape. • The inclusion of soft landscaping helps meet the natural environment strategy objective as well as contribute towards the climate change mitigation/adaptation objectives. • More ramps DDA compliant ramps should be provided for wheelchair users. Disabled access should be provided to the front of the Town Hall should be provided. • Social landlords should also be involved in the development and implementation of the public Realm Strategy. The strategy should include the spaces in and round housing estates. • London Wildlife Trust’s Natural Estates Project, involves collaborating with a number of social landlords in London to improve the biodiversity of housing estates by using simple interventions and through community engagement • The Council has indicated that a public realm framework and public realm design guide SPD will be created. However, a great deal of design and public realm guidance already exists. • Policy requirements will need to be sufficiently flexible to ensure development are deliverable across the Plan period. • The Council should prioritise the issues for which it intends to seek financial contributions. • Any requirement for developers’ to contribution to public realm maintenance must be considered within the context of any and all other financial contributions. By adopting an impact-based approach any relevant

224 policy should be sufficiently flexible to accommodate market conditions and area or site-specific characteristics. • Are there any other strategy options we should consider? Greenery, especially grass and trees, is always more attractive than hard landscaping with the odd shrub. • Trees are very important to softening the town landscape. They provide ever changing light throughout the year and fresh air on hot polluted summer days. • Community valued public realm needs to be in line with what local people want, not what the Council of the day thinks they should have. • To give the public a sense of ownership, consultation should take place at every stage.

Community Safety • Unfortunately this does not tackle issues with gangs or antisocial behaviour (ASB). Schools should place more emphasis on the importance of good parenting. Parents should be held responsible for their children’s ASB and fined. • Small areas not required for Council use should not be given away to the URV, but used to create activities for young people. • It is important that full public consultation is carried out for all future major projects within the borough. • Additions to paragraph 6.47should include tackling youth crime, safer neighbourhoods, adequate provision of criminal justice facilities, reduction in violent crime, addressing substance misuse and crime, reduction in acquisitive crime, creating a safer town centre, combating hate crime and Improving community cohesion. • Flexible policies are needed to enable the HMCS to adapt its court estate as required ensuring appropriate service delivery, through court extensions, relocation, consolidation, or through the provision of new facilities. • Her Majesty’s Court Service should be referred to in the delivery box within each policy which lists the partners that Croydon Council will be working with to achieve the aims of the Policies. • HMCS should also be recognised in the proposed Core Strategy as a receiver of planning contributions. • Population and economic growth places additional pressure on a range of court services and criminal justice facilities; directly requiring existing services to be enhanced or extended. The cost of these should be met through S106 contributions / CIL payment regimes and recognised in Policies CS7 and CS10. • CS9 (Public Realm) & CS10 (Community Safety) address similar issues. Consider combining to make published plan succinct. • From April 2010, community safety priorities are likely to change, although anti social behaviour, violence, acquisitive, youth crime will still be key, as will an area based approach to engagement and communication through the street based services review. • The future direction of the community safety performance measures will be focused on 'community perception and confidence'. • Town centres, particularly pedestrianised areas, should be vibrant locations with legitimate use of the footway for restaurants and cafes and not just bars and clubs. • People who live alone should have a panic button, or some other emergency help line. • People walking the streets provide a degree of informal security and increase the perception of safety. Encouraging walking in quieter areas should increase community safety. • Include spatial objective 6 (subject to proposed amendment) • The Council and Metropolitan Police are doing their best to deliver the objectives aimed at delivering Community Safety. However, Croydon’s Neighbourhood Watch Crime Briefing for Kenley Sector reveals a continued troubling series of muggings, burglaries and ASB in Purley and the surrounding districts. • Good quality social solutions and design should supplement, not replace, the policing approach, which will continue to be necessary. • Safety is an important issue for women. We are therefore supportive of the proposed community safety strategy, which shows support for longer-term social design approaches to community safety as well as shorter-term enforcement approaches. • The document does not mention the flexible use of vacant commercial properties. Vacant buildings make an area feel unsafe. Consideration should be given to bringing empty shops into temporary use. • Bringing vacant properties back into use can make a place feel safer and increase natural surveillance. This issue is particularly important for women. • An additional paragraph should be added immediately after paragraph 6.44 with specific reference to be made to the Metropolitan Police Authority's Estate Strategy and the Council's support in its delivery. This will ensure that the emerging Core Strategy will reflect the adopted and emerging Strategic Development Plan, in particular policies 3A.18 of the London Plan and Policy 3.17 of the London Plan and relevant policies within the emerging London Plan. • The Metropolitan Police Authority have prepared an Asset Management Plan which sets out how they will improve their operational estate to comprise a move towards more local ‘front counter’ facilities and

225 neighbourhood policing facilities across the borough, providing enhanced accessibility. This will be supported by the centralisation of custody cells, patrol bases and associated operational facilities. The Council will work with the Police to help deliver their planned improvements once they have been agreed. • Preference for policing facilities should be delivered through the traditional section 106 route. This has proven to be the most successful way of delivering the MPA's estate needs and providing police facilities where they are needed. • Community safety is a priority area particularly when encouraging people in the borough to walk and cycle. • The NICE Public health guidance (Preventing unintentional road injuries among under 15s: road design) is due to be published in April 2010. It sets out engineering measures to reduce road injuries among children and young people and recommends measures are part of a broader education and enforcement strategy to reduce such injuries.

A Place with a Sustainable Future General Points • Planning policy should also take into account the impact of the built environment on health and wellbeing and should include a specific policy relating to this • Planning applications should consider the wider impacts of health and wellbeing and developers should be encouraged to speak to the PCT at the pre-application stage • The symbols in figures 32, 33 and 34 are difficult to identify on maps • This chapter should refer to London Plan transport policies

Transport & Movement - Tram • Tram extensions to Purley and Coulsdon were welcomed, particularly orbital links to other boroughs, e.g. Sutton and Bromley, to improve access to fast trains to the south east. Further extensions to Selsdon, Sanderstead, Riddlesdown, Woodcote, Banstead, Sutton, Bromley, Crystal Palace, Hayes and Hooley were also highlighted for consideration • Potential extensions should be progressed alongside solutions for reducing car-borne congestion (e.g. A23) and should include reconfiguration of road lane layouts. New routes should be “off road” where possible. • Sutton extension should be via Tattenham Corner and Epsom Downs railway lines not as per Sutton’s Core Strategy. Likewise a route beside the Brighton Line should be considered for the southern extension to Purley and Coulsdon • Proposals to extend Tramlink south to Purley or north to Crystal Palace should be rethought as trains and buses already serve both routes/destinations • New Mitcham Eastfields Station reduces the need for extensions to Tooting and Streatham • The Core Strategy should make clear that tram extension schemes are not included in TfL’s current business plan and so there is no committed funding at this stage. The Council should aim to collect funds towards these schemes through developer contributions • Good park-and-ride facilities should support any extensions in order to encourage people out of their cars, generate a better integrated transport systems, reducing numbers of vehicles and air pollution in town centres • Allowing cycles on trams (outside peak periods) is essential as it will increase tram revenue and cycling

Transport & Movement - Bus • Overcrowded bus routes reported within the borough, but claim of routes being “at capacity” (Para 7.6) disputed by TfL; unclear what overcrowded bus routes refers to; overcrowded with passengers, roads overcrowded with buses, or the borough overcrowded with numbers of bus routes? Reference to the overcrowding within the CMC and the Masterplans/OAPF process should provide a way of clarifying and resolving these issues • Perceived poor Sunday service and needs for improved links across the border to Caterham Valley and Netherne Village in Surrey • Disparity of choice in certain district centres e.g. Thornton Heath Pond and Tesco side. Situation is exacerbated by new supermarkets and new housing • Shopper bus for the elderly to supermarkets could ease congestion with shopping bags • CMC requires drastic overhaul of current bus strategy (East and West Croydon especially). Buildings over the top of bus stations suggested as land values militate against town centre bus stands as termini • Joint working between the relevant authorities to provide Real Time Passenger Information on cross boundary bus routes should be considered

Transport & Movement - Rail • It is not clear what the potential benefits in land use terms are that the Council is seeking to achieve from the East London Line. There are phased centre improvements shown for South Norwood and Woodside 226 between 2012 -2017, but is not clear how the proposed infrastructure improvements will translate to meeting Spatial Objective 8 (‘…mitigate and adapt to climate change’). Links between Selhurst Park and the East London line should be considered. • Links to other Underground services should be explored. For example, the District Line to West Croydon via Sutton is possible with a link to Wimbledon between District Line and St Hillier Line. The Edgware Road District Line could handle twice as many trains as now and come to Croydon • Train services in the south of the borough at smaller stations in the week are adequate but on weekends the service is only hourly and does not reflect the service level needed to meet demand and future demand • The contribution that improved rail facilities, including the Thameslink Programme, could make should be included in the Core Strategy e.g. East Grinstead Railway Line (which passes through Tandridge District and Croydon) is included in the proposed service pattern for the Thameslink Programme • Improvements to East Croydon Station to remedy capacity issues are welcomed. Improvements to public transport, particularly linkages over the railway tracks to increase permeability east to west within the CMC is supported. The current ticket hall and tram stop require rationalisation, extra platforms should be added and new track space created for through trains • Proposals which come forward for the station should be prepared with full consultation with the Council and adjoining land owners to ensure that the most appropriate scheme is proposed • , Norwood Junction and to a lesser extent West Croydon stations are hardly step-free, and are very wheelchair-hostile. Step-free access provided at stations neighbouring the CMC (e.g. Norwood Junction, Selhurst, West Croydon and South Croydon) could reduce dependence on East Croydon station • It is appalling that integrated public transport at West Croydon is still outstanding; secure integrated public transport without TfL

Transport & Movement - Roads • South of the borough generally has good transport links with trunk roads and train lines, linking Croydon, Central London, Gatwick Airport, Brighton and the M23 and M25 motorways. However, the A23 still suffers severe congestion all week. It is vital to speed up communication from Central Croydon to M25 by improving A23 and A22 corridors. The Purley gyratory needs to be sorted out as soon as possible • Beulah Road area of Thornton Heath is an example of a neglected road harming the ability of businesses to stay open • Phased plans to tackle the congestion around the central part of Thornton Heath (and other district centres) are welcomed • Congestion impacts road safety, the environment, businesses and residential properties e.g. rate of change of retail business in Purley. Residential roads are already used as alternative routes for the overspill from main roads and this presents a significant danger for pedestrians and cyclists, particularly school children. Road injuries amongst under 15’s could be prevented through road design which covers engineering measures • Put cars under Wellesley Road only allowing bus, tram and pedestrian above ground • Most households find it economic to own a car, critical, for journeys where the motorist has free parking at his destination. The fare for travel by public transport frequently exceeds the savings that can be made by leaving the car at home. Moreover, the journey by public transport nearly always takes longer than the journey by car when measured on door-to-door journey time. This is a recipe for gridlock • 7.6 Lombard roundabout and Fairfield gyratory (A232/A212) should be added to the list of busy pinch point junctions • Smoothing traffic flow can only be achieved by reducing the number of vehicles on the road, not by more road-building/widening.

Transport & Movement - Parking • There should be a specific reference to the adoption of maximum car parking standards for new development, in line with the London Plan. Adequate car parking provision should be made for disabled people and the needs of business for delivery and servicing should be taken into account. Parking for motorcyclists should also be considered. The particular needs of coaches and taxis for drop off/collection facilities, particularly at key interchanges, hotels and tourist attractions should also be addressed • Council needs to be realistic; majority of people will own and want to use their cars in the future. If the Council wants Croydon to be a destination for shoppers, businesses, commuters and leisure users, it needs free moving traffic and reasonably priced car parks close to these facilities • Disproportionate parking costs act as barrier to business vitality in local centres and roads in areas of deprivation. Concessions should be made in finely balanced areas where shops are closing and the character of the area is being harmed, influencing profitability • The Council should seek to identify the need for public car parking in the CMC in a strategic manner. The provision of any additional major car parking facilities for public use should be avoided, and sustainable

227 forms of transport promoted. A balance needs to be struck between not encouraging car use, but retaining sufficient car parking provision for important employers in the Borough and especially in the Metropolitan Centre. Any large employers would want to retain as much car parking as possible in order to retain spaces for use by employees and thereby remain in the town centre. • Proposals to review car parking and provide electric vehicle charging points and car clubs, as set out in paragraph 7.9 is welcomed. Provision of electric vehicle charging points should be in line with the Mayor’s Electric Vehicle Delivery Plan for London and a reference to this document should be included. • Core Strategy should recognise link between car parking provision and achieving objectives in relation to active travel, improving viability of developments by increasing available space for developments, public health and congestion relief. Whilst the appropriate level of car parking provision must be based on local circumstances, all developments in areas of good public transport accessibility should aim for significantly less than 1 space per unit. Given the low levels of car ownership in London and high PTALs car-free developments should be promoted in the capital. Demolish Wellesley Road and Dingwall Avenue car parks and create sub surface car parks to free up land above ground for new development • Concept of park and ride facilities generally welcomed, though opposition was raised to any proposals that have the potential to create an adverse impact on the Strategic Road Network. Proposals would need to be in line with DfT's Circular 02/2007 paragraph 41 and in compliance with PPG13 paragraphs 59 to 63 • Unclear that establishing park and ride at the M25/M23 junction would be effective. Most commuters from Surrey/ Sussex use trains. Potential space for a facility in Purley is on the north-west side of the A237/A2022 cross roads. Though others could not see where is would be feasible • Core Strategy should acknowledge that any park and ride proposal affecting the A23/M23, if located close to the Surrey County boundary, would need to be considered in close liaison with the Highways Agency, Surrey County Council, Tandridge and Reigate & Banstead. • 7.12 (p.79) makes insufficient reference to alternative possible locations for Park & Ride Facilities within the borough. Provision should be made within the document to explore other alternative Park & Ride locations where there is existing capacity within the network and or a wide variety and concentration of transport modes

Transport & Movement - Cycling and Walking • Cycling needs safe pathways, physically protected from vehicles – especially if youngsters are to be encouraged. A bit of white paint & green surface is tokenistic, dangerous & a waste of money. • Failure to acknowledge that cycling can also be encouraged through the provision of cycle parking. Expand to clarify that secure, accessible cycle parking should be provided at all new developments, interchanges (particularly East and West Croydon) and key destinations (in line with TfL’s minimum cycle parking standards). This encourages cycling as a feeder mode to rail journeys and improves general interchange across all modes at key transport hubs. Furthermore, it would be useful for the Core Strategy to acknowledge that TfL is implementing a cycle hire scheme in central London and TfL welcomes further discussions on Croydon’s proposals. • 7.9 (item 1e) should include a reference to improving pedestrian crossing provision and should also include the roll out of the Legible London wayfinding system throughout the borough to aid navigation • Paragraph 7.9 (item 2) should include: complete, improve and maintain the Strategic Walk Network (SWN); promote ‘Key Walking Routes’ as route area walking initiatives • Croydon has recently identified a ‘priority’ cycle network, which includes the Connect2 alignments, National Cycle Network Route 21 and a north south corridor in the proximity of the A23. In 2010 Sustrans intends to develop a 5 year programme for the delivery of priority networks across all partner boroughs • The economic case to facilitate and encourage a greater uptake walking and cycling in local plans: road congestion relief, improved retail vitality, improved productivity, reducing costs associated with treating obesity and related conditions, and tourism revenue. • The quality of life case to facilitate and encourage a greater uptake walking and cycling in local plans: obesity has a serious quality of life cost and public cost. Physical inactivity is the primary contributor and that the most effective way to tackle obesity is through helping people to walk or cycle more. Transport policy has an impact on social and community wellbeing as well as individuals health. Roads with high traffic volumes or speeds deter walking and cycling and frequently create barriers to movement, particularly for the elderly, the young or those with mobility impairments. Lower motor traffic levels are associated with significantly higher levels of social interaction, and that in urban areas that are conducive to walking, cycling and outdoor play, people are more likely to know their neighbours, participate politically, trust others and be socially engaged. Cross referencing to health and well being, such as the implications of accessibility to healthcare services, air quality is needed. • The environmental case to facilitate and encourage a greater uptake walking and cycling in local plans: A shift to these walking and cycling from car travel can contribute to delivery of carbon dioxide emission reduction targets. This also helps reduce dependency on fossil fuels and improves energy security and the resilience of local transport systems. A transport system that is more efficient and less dependent on fossil

228 fuels is less exposed to rises and volatility in global oil prices. In this respect a shift to sustainable modes of travel makes the local transport system - and thus local economies – more energy secure and resilient. • Having suitable greenways responds to both peoples’ concerns about the safety of cycling in traffic and the positive perceptions of cycling as a healthy, fun activity they are key in facilitating a greater uptake of cycling. In Outer London particularly, where levels of cycling are currently low, but where there is a wealth of green spaces, greenways could play a central role in encouraging new people onto their bikes. • Better streets through traffic reduction and reallocating road space is needed as per the Manual for Streets (DfT, 2007) and the London Cycling Design Standards (TfL, 2005), which promotes traffic volume reduction measures as the first priority in seeking to facilitate more walking and cycling. Residential areas on strategic active travel routes should use ‘filtered permeability’. This promotes the use of modal traffic gates and ‘point-no-entries’ in appropriate locations to limit permeability for private motorised traffic and thereby reduce traffic levels in target areas, whilst allowing full permeability to active travel modes. • Policies are needed on arterial routes to provide a good quality cycling environment on busier distributor roads. There is frequently no adequate alternative to providing dedicated cycling space. This usually requires the reallocation of road space from motorised vehicles e.g. Blackfriars Bridge. Road space re- allocation measures include: introducing traffic-free transport corridors for cycling and walking; introducing priority lanes for cyclists and public transport; pavement widening; intersection treatments to improve safety for cyclists, as well as pedestrians; parking restrictions and enforcement and raised crossings. Generally, these measures all aim to make access by sustainable and public transport choices simpler and more convenient than access by car • Traffic speed is a key determinant of the appeal of an urban environment for walking and cycling. Local planning and transport policy should reflect this by providing guidance on speed limit policy locally, including promoting the expansion of 20mph speed limits. Could help increase the appeal of walking and cycling and has road safety benefits especially for young people. • Croydon has a wide route network, but with key gaps and significant quality challenges. Noting that there are “key gaps” in the network must followed up by adequate resources to overcome these. Existing routes do not score well against generally recognised quality criteria laid down in publications such as the IHT's Cycle Friendly Infrastructure • Section 7.8 Add: "Improve cycle network linkage with safe, direct cycle access through Croydon town centre in all directions." / "Improve cycle network attractiveness by focusing on motor-traffic reduction or physical segregation on cycle routes." / “Improve cycle network safety by introducing and enforcing 20mph speed limit along all designated cycle routes". • Inability to cycle in North End has precluded an acceptable North / South cycling route through central Croydon. • Cycling to school with young children is hampered by pot holes, riding around them increases fear of injury from high speed traffic. This deters young people from cycling to school. • The Windmill Bridge area, particularly the pedestrian route should be improved providing better links to the Lower Addiscombe Road retail area as it is poorly connected and not mentioned in the Core Strategy. • The 6 lane Pitlake Bridge is a menace to pedestrians. The pedestrian crossing is in wrong place and hasn’t worked for many years. The bridge needs better pedestrian access with lifts beside the railway and tram line; the stairs are not suitable for a lot of old people in the area. Cuthbert Road needs a footpath that extends to the Wandle Park tram stop as it is inaccessible when the park is closed due to private land and network rail land blocking a potential access route to the access bridge path. • The vision for the Wellesley Road and in particular the enhancement of east – west pedestrian links through the Metropolitan Centre is supported. Cycling/pedestrian access west of the centre of Croydon is currently difficult because of the severance caused by the West Croydon railway line, tramline, Roman Way and Purley Way. Wandle Park is completely surrounded by the above, plus an industrial estate to the north, making it very difficult to get to/from the park • Figure 3.2 and Figure 3.3 – questioned as to whether the "proposed extensions" are already complete. As well as appearing isolated and disjointed short sections of route

Transport & Movement - Accessibility • Mixed feelings about the Wellesley Road masterplan –pedestrian and the wheelchair users require good access across the flow of traffic with ample time allowed to pass pedestrian crossings as existing timings are not sufficient for those with mobility or visual impairments. Particularly important given that the population is ageing. There should be double yellow lines in front of all dropped kerbs. Parking restrictions on pavements should be heavily enforced as they present obstacles to those with physical or visual impairment • Developing a good quality network of greenways which are safe, quiet routes connecting to residential areas, to parks and green spaces and interlink with other route networks encourages pedestrians, cyclists, wheelchair users and others who feel vulnerable on or near busy roads, for recreational or practical journeys.

229 • Page 78 – Should also reference car clubs (perhaps point K section 2) • You deal with transport only to the North and South, orbital transport should also be considered. Many people must travel towards (and beyond) Sutton and Bromley and the present public transport arrangements are poor in these directions and need consideration for the future; presently most people going in these directions will normally have to go by car

Transport & Movement - Growth • Figure 31 does not take into account public transport improvements between 2009 -2011 and the implications that this would have on existing public transport capacity. South Norwood shown as having negative population growth between 2009 -2031, but this does not appear to be consistent with South Norwood being a growth area in the period until 2021. It is not clear on what basis this population projection has been made • Cross boundary opportunities should be developed further particularly in light of Redhill/Reigate being a Regional Hub, the Highways Agency's proposals for a new interchange at A23/M23 Hooley and the ongoing ‘Delivering a Sustainable Transport System’ study being led by the South East England Partnership Board. Surrey and Redhill/Reigate Regional Hub transport studies are being undertaken by the authorities; any planned accessibility linkages between Croydon along the A23 corridor involving public transport, traffic management and links with Redhill/Gatwick should be subject to discussions with Surrey County Council • Insufficient infrastructure improvements are mentioned within the Core Strategy to deal with further increases in traffic. While concentrating development along a constrained corridor may bring forward some necessary improvements within Surrey, there are no infrastructure provisions made for this eventuality • Figure 31 shows that the areas identified for the bulk of new development are precisely those where public transport is subject of current capacity problems. Yet the south east of the Borough has capacity but is ignored as a possible development option. A Tramlink extension to Selsdon within the East Spatial Management Area could help absorb more of Croydon’s expected growth • An opportunity may exist to create a small charter business flight airport at Croydon Aerodrome or a helicopter base pad to tie in with all the plans to entice further business to the borough. The existing hotel facilities could be very convenient • Shaping the pattern of development to influence the location, scale, density, design and mix of land uses will reduce the need to travel and the length of journeys, thereby increasing uptake of walking and cycling. • Transport infrastructure should be brought up to the level to serve current needs of the Borough before any further developments are considered that would enlarge Croydon’s population • Due to the quantum of development proposed for the borough, a spreadsheet-based model should be developed to provide a strategic view on the overall cumulative transport impacts of the Core Strategy. This does not appear to have been performed thus far. An evaluation of transport impacts on the local and SRN is necessary to demonstrate that the proposed developments are deliverable in transport terms • Planning for today's increasing level of car ownership requires density of development to be reduced to make space for roads and car parking whereas town planning for a much lower level of car ownership requires a higher density of development in order to facilitate walking, cycling and the use of mass transport which need to be combined with a general reduction of the length of the journey to work

Transport & Movement - Miscellaneous/Delivery • No specific mention of the requirement for planning applications to be accompanied by transport assessments/statements, travel plans and construction logistics plans and delivery & servicing plans; as per the recommendations in DfT Circular 02/2007. Document should be expanded to cover these issues including references to TfL’s Transport assessment best practice guidance document (May 2006) and TfL’s travel planning guidance (Guidance for residential travel planning in London and Guidance for workplace travel planning for development, March 2008). Construction logistics plans and delivery & servicing plans can be co-ordinated with travel plans in order to promote sustainable construction and servicing • Emerging policy should specify that a full Transport Assessment should be produced to support any development likely to have a material impact on the SRN. The threshold requirement for the provision of a Travel Plan should also be outlined within the CS and/or DM DPD. Travel plans should specifically require the consideration of targets, monitoring, incentives for compliance and a funding stream to maximise their potential for success, in accordance with PPG13 • Transport policy indicators have been omitted under Monitoring (paragraph 7.16). Suggestion that LIP mandatory indicators, e.g. buses and also emissions from the LAEI (London Atmospheric Emissions Inventory), and number of new developments with travel plans and number of car free developments should be monitored

230 • Transport provision and measures for new developments should be considered on a site by site basis to enable flexibility. The movement strategy should be sufficiently realistic so as to ensure development is not impeded and that it remains viable and deliverable. • Include and amend spatial objective 6; it is slightly ambiguous in that the emphasis appears to be on new development. Suggest that wording is amended to read “...built heritage is enhanced by high quality new development that respects its character and is therefore well integrated” as transport proposals can have a major impact on existing character. • Investing in transport infrastructure for both public and private transport is not likely to be sustainable. Experience with Croydon Tramlink and the M25 shows that travel expands to fill available capacity • Final policy should be informed by the Strategic Flood Risk Assessment and a Surface Water Management Plan

Climate Change, CO2 and Water Management • Several respondents pointed out that sustainability requirements for new developments should not compromise the financial viability of developments; they should be evidence based and viable and in line with PPS guidelines • Seeking a financial contribution where developments cannot meet on-site CO2 reduction targets may not be acceptable under Government Circular 05/05. The Council should prioritise areas where financial contributions are sought so as not to compromise viability • Change paragraph 7.25 to include test against ‘financial, legal and technical viability tests’. • Wider CSH/BREEAM targets should be sought, rather than just focussing on CO2 emissions • Development proposals should include flood risk assessments in line with PPS25 and SUDS should be installed wherever possible, not just in flood risk areas • The Core Strategy should cover retrofit SUDS projects and S106 funds should be used to retrofit SUDS in existing properties • The Core Strategy should play greater emphasis on the role of the natural environment and green spaces in meeting climate change mitigation and adaptation objectives and should include policies to reflect this • Particular attention should be paid to avoiding increased flood risk by placing restrictions on the creation of new impervious surfaces in development • The Core Strategy should put in place a number of indicators to help monitor the climate change strategy: o Number of developments permitted against Environment Agency Advice o Number of specific flood water management measures put in place o Number of heat and cooling networks o Achievement of 20% renewable energy generation o Number of new waste and recycling facilities • The whole life costs of development should be taken into account and if housing growth cannot be achieved without having significant impacts on the natural environment, then it should not go ahead • The Core Strategy should identify water and sewerage infrastructure and ensure that these can be put in place before development occurs, in line with the SFRA • There is no direct reference to the challenge posed by dwindling fossil energy resources • The Core Strategy refers to a target atmospheric CO2 level of 550 ppm. This is out of date; a target of 350 ppm should be used. Attention is drawn to the abundance of different CO2 reduction targets at the national, regional and local level and some clarity is needed, as well as a specific, challenging target. • Page 83 – The table doesn’t show if the data is in 000 tonnes etc. Para 1 which includes air quality could read better. The District Heat and Power Network Study – we really need to do a Heat mapping exercise for the whole borough (to include cooling). • As soon as possible a specific target should be set for domestic refurbishment and conversion as the term “high standards” will not be sufficient • Several respondent highlighted the importance of renewable energy and wanted to see stronger requirements in this area • Greater clarity is required on when, where and how developments should be “CHP ready” • Developers should be required to submit energy assessments and install renewable technologies in line with the London Plan • The Core Strategy should provide examples of specific energy efficiency measures suitable for Croydon • Gatwick Airport should be consulted on development proposals within a 30km radius of the airport where a wind turbine is included • It may be premature to identify Cane Hill as being suitable for CHP at this stage – any energy policy should be flexible enough to allow for future changes.

Green Grid & Rivers • The inclusion of a section on green grid and rivers is welcome.

231 • The use of financial contributions for green grid improvements must be considered within the context of all other possible financial contributions. To ensure developments remain viable and deliverable an impact- based approach must be adopted and policy requirements should be sufficiently flexible to accommodate market conditions. • To ensure the viability of any development is not adversely affected, the Council should prioritise the issues for which it intends to seek financial contributions. • In line with Nice recommendation references to promoting public access along watercourse and green areas are welcomed • NICE are currently developing a Public Health Guideline on Spatial planning for health. It provides guidance on the stages in the spatial planning process when health issues can be assessed. It also examines how local development frameworks are produced and how health appraisal approaches can be used to help develop sustainable communities and deliver local area agreements (LAAs). • The approach used to appraise health issues and influence planning decisions are based on improving and reducing health inequalities. The approaches to be examined include: strategic environmental assessments, sustainability appraisals, environmental impact assessments and health impact assessments. • Wineham Investments would like the opportunity to meet with officers to help establish the suitability of the land for residential or other development and the issues/requirements relating to Green Belt rollback in the Borough. • The development of a Green Grid within the Borough is welcomed. However, the importance of small and informal local green spaces to women and children have not been recognised within definition of the green grid. • Spatial Objectives 6 and 8 should be expanded to include an additional objective on flood risk. • 7.45 should be informed by the Strategic Flood Risk Assessment and Surface Water Management Plan. • 7.48 pt 6 should include allowance for increased future flood risk. It should also ensure that developments are located in the most appropriate location in terms of risk of flooding and vulnerability classification. • Proposals should provide Flood Risk Assessments as required by PPS25. • 7.45 should be informed by the Strategic Flood Risk Assessment and a Surface Water Management Plan. • 7.57 require further information on how improved flood risk management will be achieved. All development proposals should take flood risk into account and new and historic development should reduce the risk of flooding. For instance working with natural processes such as creating new wetlands and habitats can absorb water and prevent flooding. • Parks, rivers, gardens (including residential gardens), open spaces, trees and living roofs and walls provide habitat for diverse ranges of species, and contribute to townscape and well-being. Private spaces, roof terraces, balconies and green roofs can also make a contribution to green infrastructure. • Additional pressure on open spaces can be mitigated by securing new improved public open space in new developments, deculverting rivers seeking public access to private spaces, securing contributions to improve ecological value, improving the accessibility of local public open spaces and delivering new open spaces from under-used land. • Wandle Park improvements include de-culverting of a section of the River Wandle. The improvements is a good example of a scheme that will reduce flood risk whilst providing increased wetland habitat, educational and recreational opportunities and enhancing development and regeneration. • Strategy options relating to deculverting and river restoration should identify and promote opportunities to restore urban watercourses. This will benefit the local community and environment, particularly where watercourses are in fully-enclosed culverts. For example through: development and regeneration proposals, particularly for brownfield sites. • In accordance with Objective 8 the following additional indicators should be added 1. Net change sites of nature conservation importance 2. Improvements to parks, play areas and other open spaces, including measures to protect or enhance. 3. Ensure the protection and enhancement of open space network and work to develop further connections between open spaces. 4. Public open space deficiencies by protecting all open spaces, and their heritage and ecological value, tranquillity and amenity qualities. 5. Amount of green roofs incorporated into new and existing developments 6. Amount of de-culverting incorporated into new and existing developments. 7. We suggest additional indicators as follows in accordance with the objectives in this section: 8. Amount of flood storage volume provided. 9. Ensure that new developments can stand up to flooding • Natural England was pleased to see the six strands and the Green Infrastructure Plan proposed under this section.

232 • The underlying landscape (also known as natural signatures) can make a direct and powerful contribution to the ‘sense of place’ and local distinctiveness and will help to deliver this objective. • Guidance on Natural Signatures is set out in Natural England’s London Landscape Framework. The Green Grid section of the Core Strategy should be in line this guidance. • In line with the councils aspiration to make the natural environment the “arteries and veins” of the borough, the Council should look at the fragmentation of open spaces and linking of them back to paths and other sites. • Paragraph 7.50 requires subsequent LDF documents to treat the open space network as part of an integrated system providing Green Infrastructure, together with improvements to the Blue Ribbon network is to be encouraged. • Natural England was pleased to see links being made between this document and subsequent strategies and plans. • The report recognises Purley as an “Area of Deficiency in Access to Nature”. It is difficult to see how anything fundamental could be done to change this. Large scale replacement of houses with flats will almost inevitably exacerbate the “Deficiency in Access to Nature” and increase the problem of surface run off. • The plan has aspirations to deal with New Addington’s residents’ deficiency in access to nature. However, it does not recognised that the most convenient location to redress this shortfall would be the open land to the east of the town in Bromley Borough. Prospects for improving the environment for residents of New Addington must be considered in a cross border structure/arrangement. • ROWIPS are supposed to be integral to the planning process and despite carrying out consultation over two years ago; it still has not been produced. • The ROWIP should be published before the Core Strategy. Without the ROWIP the spatial objective does not make sense. • Areas such as Cane Hill are used by riders who require access to Farthing Downs. Stables have always been located here, therefore proposed infrastructure should be suitable for riders to access countryside and retain open space for equestrian and other use. • Whilst the Green Grid is referred to, no reference has been made to the Green Arc which encourages multi user use of linked landscapes around London. The identification of this land is essential before the Core Strategy is published as are the sensitive areas identified on the Croydon Biodiversity Action Plan. • The booklet produced for the Core Strategy is all window dressing and short on detail. • Presumably section 106 funding from the National Grid cable tunnel project from Lloyd Park to New Addington, through Gravel/ is quite considerable. What has the Council done with the section 106 funding from that project? If there's any left, the money could be used for improvements on the existing rarely-used footpath on the south-side of Kent Gate Way between the Addington village interchange tramstop and the roundabout at the bottom of Gravel Hill to be widened or to create a shared (walk, cycle, horse). • Section 7.51 does not mention the Wandle Park Refurbishment Project. Norbury Brook could be smartened up by litter clearance and signposting to make a walking and cycling trail. • Improving and increasing habitat for wildlife in all green space, especially gardens, parks and allotments should be added to Section 7.48. • Paragraph 7.36 does not clarify how the issue of development within the Green Belt and MOL will be addressed. At examination, a clear audit trail will need to be provided showing how policies have been developed and that they are the most realistic and achievable for the borough. • In section 7.49 point 4, for clarity the word conservation should be substituted for the term historic environment. • Section 7.55 should identify EH as a partner. • More greening: green roofs and walls, more tree planting and better protection against trees being cut down and the loss of gardens would make Croydon a nicer place to live. • It is important to invest in reducing the risk of flooding by enhancing existing green areas. Green spaces that are not used for agricultural purposes could incorporate uses such as play areas for children and not solely used for sustainable or aesthetic uses. • Item 7, Figs 32 to 34 needs further clarification. • The Council should encourage cremation. Private facilities should be available for individuals who consider burials important. • In item 7.42, greater efforts to get volunteer groups to deal with the regular long term maintenance of our public open spaces, especially woodlands. In Purley, the Friends of Foxley Woods do a very good job to maintain this public amenity. • The Council should apply pressure to ensure Network Rail maintains its wooded embankments in areas such as Purley. • Should the reference to “Norbury Brook” in section 7.51 be “The River Graveney”?

233 • The promotion of well connected new and enhanced green and blue infrastructure is in line with London Plan policy 3D.11. • Clarity is need on which of planning policy is applied to the spaces shown in Figure 36. Confirmation is also need to ascertain whether Green Belt or Metropolitan Open Land boundaries will be changed. • The Core Strategy notes that there is an overall shortage of allotments in the borough. In line with draft replacement London Plan policy 7.22 the Council should protect existing provision and identify other potential spaces. • The provision of burial space within the borough is limited. In line with London Plan policy 3D.19, DPDs should ensure that sufficient provision is made. • Congratulations on the clear, comprehensive analysis and suggested strategies for the future. However, when planning future developments advice should be sought from a permaculture designer. The designer has a multi-functional, spatial approach to land development and will work with local strategic partners and stakeholders to put together a sustainable development plan for the whole area and/or specific sites. They will look at the environmental, social and economic implications of sites and in line with the Mayor of London’s food initiative, will incorporate perennial edible landscaping into the design, • Planning rules over Green belt as well as urban areas should be flexible enough to allow wind turbines and anaerobic digesters where appropriate. • Effort to promote local food growing will provide security in an uncertain future. • More allotments, community gardens, productive plantings of edible trees and bushes in public places. • The old Coombe Lane Nurseries which is underused could be an excellent resource for food growing and educational facilities to encourage and teach the public about food growing. The crops could be sold providing income and also local, fresh nutritious food. • The document contains very little about recreation areas or playing fields or threats to their existence caused by planning pressures. • Whilst writing it was always the policy of your department to consult with my Association on applications which will affect the continued existence of recreation areas or playing fields or will in any way impinge upon them. Could such a scheme be re-instated? • Difficult to comment on this as we do not know what a “Green Grid” is. It is not explained and does not appear in the glossary. • Are there more than 20 allotments in Croydon? • We would strongly support the encouragement of healthier lifestyles in this policy and links in the supporting text to the health and well being implications of the green grid and rivers. • We also support reference to the s106 funding streams in paragraph 7.46 confirming planning applications will need to include provision for green grid and rivers. • The monitoring targets set out in paragraph 7.56 may benefit from the inclusion of a health and well being indicator, to help confirm if the health and well being objectives set out in the Community Strategy are being met. This should be based on the specific health issues, as set out in the JSNA. • We strongly support this Core Strategy and the relevant Spatial Objectives. Nevertheless, we are concerned that paragraphs 7.36-7) are negative in their reference to Croydon’s natural and green assets, and focuses on the constraints for development rather than the opportunities and benefits. • No reference has been made to the number and quality of the borough’s natural assets (for example Sites of Special Scientific Interest, Local Nature Reserves). • We support the Council’s recognition of the importance of trees, and concur with the issue on tree information outside some key areas. • The GLA’s Right Place Right Tree guidance provides a means of ensuring that increased tree cover actually enhances the sense of place, and does not conflict with biodiversity conservation objectives (for example the borough’s chalk grassland). • Reference should also be made to other strategic evidence and guidance, for example the London Tree & Woodland Framework, and the emerging London Regional Landscape Framework. • We support the proposed Green Grid & Rivers Strategy. However, explicit reference should be made to the protection of key assets of Croydon’s Green Grid (as set out in 7.48). • Green spaces within social housing should be a priority in the Strategy. • Outlined potential for the Downland Regional and Wandle Valley Regional Parks is welcome. Whilst not meriting Regional Park status, additional areas such as wooded parks and other open spaces in the north of the borough, especially Upper Norwood, Biggin Wood, , The Lawns and Long Lane Wood deserve some focus. • London Wildlife Trust is committed to developing a cross-borough project in order to find a means to raise the profile and quality of sites, which could start to address some of the discrepancies in open space provision/access between the south and north of the borough.

234 • We consider ourselves as a partner in helping Croydon deliver the proposed Green Infrastructure Delivery Plan (7.55), through our reserve management, our anticipated Living Landscapes projects and our work with local volunteers to get actively engaged with their local environment. • With the intended increase in new housing in areas such as Purley, what steps will be taken to resolve deficiencies in green space? • London Wildlife Trust’s Natural Estates Project, involves collaborating with a number of social landlords in London to improve the biodiversity of housing estates by using simple interventions and through community engagement. • Trees are very important to softening the town landscape. They provide ever changing light throughout the year and fresh air on hot polluted summer days. • Pressure to develop on MGB, Metropolitan Open Land (MOL) or other green areas will make it increasingly difficult to meet Government targets for new housing provision. • Public open space should be regarded as a precious resource, for the welfare of the community. Therefore the policy to consider developing protected green space is completely unacceptable. This policy should be killed off! • National statistics show that 9 out of 10 people use public open spaces. • Over one third of Croydon has been designated as Green Belt (MGB)" (p.86) but no strategy is proposed for this one third of the borough. • Croydon's own Education Department is proposing to build a school in the Green Belt, at Conduit Lane. Why has no strategy for Croydon's Green Belt been proposed for public consultation?

Waste Reduction and Management • Homes/growth strategy will increase the need for civic facilities for composting and recycling. Commitment to municipal recycling facilities within reasonable travelling distance is needed because they form an important element of community infrastructure • Existing rail heads for the bulk transport of aggregates by rail should be safeguarded. Days Aggregates should be provided with protection in the Core Strategy due to its regional role in recycling aggregates and supplying imported rail-borne crushed limestone and granite • Current figure of 76% of Croydon’s waste going to landfill is unacceptable and explicit reference should be afforded in the Core Strategy to improving this situation, not relying on the JSLWP. London Plan policy 4A.21 identifies the need to exceed recycling and composting levels in municipal waste of 35% by 2010 and 45% by 2015. The Core Strategy identifies a municipal waste target of 32% by 2010. This target falls below London Plan policy. • Intention to investigate new methods and improvements for sustainable waste collection, use of designated employment areas for the location of new facilities, enhancement to facilities for composting and recycling and developing waste management as a green industry is welcomed. The use of legislative controls, including a charging regime, and better education would assist preference for waste hierarchy • Include an additional target to send zero waste to landfill by 2025, exceeds proposed target in the Draft London Plan (zero waste by 2031) but would be consistent with the Mayor’s more recent Vision contained in The Draft Municipal Waste Management Strategy (January 2010) • Encourage the use of sustainable design and construction techniques; promote re-use and recycling of construction, demolition and excavation waste and the use of recycled aggregate in new development. Sufficient space in new development to provide separate storage and collection facilities for segregated waste also needs promotion • Waste hierarchy must be maintained, waste is a resource and disposal should be the last option. Methane from landfill is much more dangerous than CO2. All non-recyclable material should be processed via anaerobic digestion, and by-product of the process sold to energy firms • Future waste processing facilities should not counteract efforts on waste minimisation, reuse and recycling. Facilities should not rely on a continuing high volume of waste to allow it to operate successfully/profitably - the facility should be flexible to cope with different types and smaller volumes of waste as minimisation, reuse and recycling strategies take effect over the plan period • Waste management strategies must acknowledge and understand waste arisings beyond municipal boundaries

Delivering the Preferred Strategy • We request that any financial contributions are sought at a level that ensures that the overall delivery of appropriate development and the viability of a scheme is not compromised. As set out in Circular 05/05. Further we request that this is reflected in the emerging Development Plan Policies

235 • Any approach to Housing Typologies needs to be sufficiently flexible to accommodate market demand and site-specific characteristics. The Council’s strategy therefore needs to be realistic as to the land implications of its challenging job and housing targets and aspirations for competing uses. • Croydon’s aspirations for the CMC are ambitious. While we strongly support ambitious aspirations and recognise the difficulty of long-term planning, achieving job and housing targets and delivering Croydon’s retail and education aspirations will be extremely challenging particularly as land within the CMC is finite and requires the best most appropriate strategy. • In order to ensure that water and wastewater infrastructure is delivered alongside development it is necessary to include policies within the Core Strategy to ensure that water and wastewater infrastructure identified within the IDP or through discussions with developers, is provided ahead of development. • Thames Water are funded in 5 year blocks known as Asset Management Plan (AMP) periods. AMP5 commences on the 1st April 2010 and will run until the 31st March 2015, as such this does not cover the whole of the Core Strategy period. • New and upgraded water and sewerage infrastructure must take into account developments throughout the catchment and not just within one local authority. It is essential that developers demonstrate that adequate capacity exists both on and off site to serve development • Thames Water - In order to ensure that development takes account of the need for water and sewerage infrastructure the Core Strategy should contain robust policy to ensure that growth is supported by the water and wastewater infrastructure it requires and that new development will not exacerbate existing problems of sewer flooding or low water pressure. • Environment Agency - Policy in the CS should be informed by the Strategic Flood Risk Assessment and a Surface Water Management Plan. • There may be a conflict between the development policies and the presence of the notifiable installations. Any proposed developments should take their presence into account. • Strongly advised to consult the listed pipeline operator, to confirm the exact location and route of their pipelines in the area covered by the plan and to ensure that your records are kept up to date. • It would be helpful to potential developers if the constraints likely to be imposed by their presence were indicated in a policy statement in the plan. • The preparation of the IDP is supported, however, a further discussion is required with regards the timing of this plan and what level of infrastructure detail would be included within the Core Strategy. • GLA- Current capacity and projected demand’ for education services, which is welcomed. However, this figure does not include any information for the CMC and its Environs. • It is expected that such a level of new housing would generate significant social infrastructure requirements. This element could be usefully investigated through OAPF process. • TfL welcomes the proposed Infrastructure Delivery Plan referred to in paragraph 8.7. The Plan needs to reflect the current status and funding for strategic transport projects as well as more local aspirations and identify those projects that will require additional funding through the section 106 process, a standard charge mechanism or the Community Infrastructure Levy. • Paragraph 8.8 on funding sources fails to specifically mention transport-related planning obligations, A clear distinction should be made between the Community Infrastructure Levy (CIL) and legally binding planning obligations to avoid limiting the scope for financial contributions and infrastructure associated with new development. • TfL suggests that paragraph 8.8 should also include a reference to LIP funding. (London Plan Policy cross ref. 6A.4, 6A.5 London Plan Alteration 3C.12A Draft London Plan: 6.5) • Highways Agency- We suggest that the following transport related indicators are considered to monitor the proposed strategy: The proportion of trips made by non-car modes; and The level of growth of traffic on key routes within the District • GOL- This section requires more on the who, how, when and where in relation to delivering the plan’s overall strategy. Also, are there any issues/constraints that could prevent development coming forward and how this could be addressed? • Table 8.7 could be made more robust by stating where you expect any funding to come from, how any funding shortfalls will be addressed, whether any of the infrastructure referred to is critical to the delivery of the plan and any contingency plans that are/need to be in place. • London Wildlife Trusts- There should be reference to the following in the Sustainable City Programme: Infrastructure Type ,Delivery Mechanism, Agency Authoriser. Biodiversity Action Plan Parks and green space management LBC, NGOs, land-owners, Friends of groups LBC, Natural England. Sites of Special Scientific Interest BAP, parks & greenspace mgnt, FEP (HLS) LBC, NGOs, land-owners, Friends of groups Natural England Local Nature Reserves BAP, parks management LBC, NGOs, Friends of groups LBC • Cgms Infrastructure Delivery plan provide the basis of identification of the MPA's infrastructure requirements across Croydon Borough. The 'Caring City Program' sub-heading should be updated to reflect this.

236 • HUDU- We welcome reference to the emerging Infrastructure Delivery Plan We would also welcome a specific policy within the document requiring planning obligations to support the needs created by development, and prioritising contributions towards health, in line with the London Plan. Confirmation of commitment to securing funding from development for both capital and revenue funding would also be welcome, as both are legitimate costs to the NHS when new development comes forward. • The reference to CPO within the document as a means to delivering the strategy is misleading. Perhaps a disclaimer could be included • In the absence of major private sector development such infrastructure will not be forthcoming and the strategy will be undermined

North Spatial Management Area • Flood risk should be minimised as well as tackling it and details of the methods to be employed should be provided. • Concerns that infrastructure investment needed to accommodate the longer term growth along A23 will fail to materialise. • Reducing car use should be the priority, not altering the road network to cope with more cars. • Welcome harmonisation with London Plan town centre hierarchy, but need more detail on the role of each of the District Centres. • Impending public spending cuts call into question directing housing to north/west where resources such as schooling are inadequate. • The emphasis of the plan is clearly focused towards protecting certain, favoured areas of the borough at the expense of others.

Crystal Palace & Upper Norwood • support for sympathetic ‘heritage led renewal’, need more coordinated enforcement for the ‘At Risk’ Conservation Area. • effective cross-borough and Mayoral framework should be sought. • need expressed for a master plan with detailed proposals to address issues/maximise opportunities for Church Road area. • Concern that you cannot plan for the area without considering the proposals concerning Crystal Palace Park. • support for creative industries focus for the proposed Enterprise and Opportunity Centre but concern over the apparent lack of specialism’s for the others? • Tramlink extension is needed and the options should consider this, buses aren’t enough to serve the area • commercial edge-of-centre and out-of-town retail development is a risk to the vitality of the Triangle.

Norbury • Norbury Brook could be smartened up by litter clearance and signposting to make a walking and cycling trail. • We support the approaches identified: renewal and growth, managed change and conservation and enhancement. The broad locations of these sites are mostly in Flood zone 1 (which is identified as having a low probability of flooding as defined in Planning Policy Statement 25). However, there should be sufficient consideration given to reducing the surface water runoff from development. Some areas identified are located in the areas at risk of surface water flooding such as Norbury, Thornton Heath and the Wandle Link. • For the strategy to be realistic requires a fuller review of needs, supply and sites. Being heavily reliant on development taking place in Croydon Metro Centre and along the A23 transport corridor, from Norbury in the north, down to Coulsdon in the south there must now be doubt that this corridor alone can meet the required housing levels along with suitable schools, health and community facilities. • Over the last 6 years or so I have noticed the numbers of workers alighting from rush hour trains firstly swelling at Streatham Common, then Norbury, and more recently the same large numbers alighting at Thornton Heath, so I guess there would appear to be a move southwards possibly for the time being anyway being due to more reasonable house prices, whatever the reason the numbers have increased very rapidly I guess you have some figures on that. • 7.51 mentions Norbury brook but having lived in Norbury for over 20 years, I should know this stream and I wonder if you are referring to The River Graveney?

South Norwood & Woodside • Considered that areas such as South Norwood are able to accommodate significant growth in homes/jobs over next 10 years. Increased mainline rail capacity suggests this can happen now.

237 • Significance of CPFC as a great asset for Croydon has been seriously overlooked. Core Strategy should contain an unequivocal positive statement of support for Crystal Palace Football Club and their continued presence in Croydon or nearby area. • Conservation Area boundary needs reconsideration as areas not worthy of preserving are included whilst some nicer areas are not. • No evidence is presented to support the proposal that South Norwood has ‘medium potential for new homes’. • Strongly object to high density social housing being crammed into this area as the social housing provision for ‘posh’ new developments in the town centre. • Portland Rd is a good example of Victorian buildings and should be recognised as such. As an enterprise area it could support small offices e.g. arts, crafts, designers, who would use the local shops and cafes, restaurants, etc. • Woodside is an original, historic and coherent local centre and should be recognised.

Thornton Heath • Look at opportunities such as the site next to Woodville Road on the High Street or the snooker hall opposite to relocate the library to a more central position. Alternatively a car park would be a great boost for the small shops in the area. • More could be done to improve the appearance of the High Street and reduce vacancy such as a shop front grant scheme.

Croydon Metropolitan Centre & Environs Spatial Management Area • The document advises that Croydon Metropolitan Centre (“CMC”) has great potential for accommodating intensive, but positive change. Our clients fully support the long-term redevelopment and regeneration of Croydon Metropolitan Centre and its environs. Our client intends to develop the site at Derby Road which is just outside the boundary of the CMC for a mixed use residential scheme. This will assist in delivering the regeneration objectives and provide significant improvements to the economic and social well being of the CMC. (Purespace) • The document advises that Croydon Metropolitan Centre (“CMC”) has great potential for accommodating intensive, but positive change. CGLP fully support the long-term redevelopment and regeneration of Croydon Metropolitan Centre of which the Ruskin Square scheme will be a key element. Our client intends to develop Ruskin Square which will assist in delivering the regeneration objectives and provide significant improvements to the economic and social well being of the CMC. • Our clients acknowledge that the phasing of development over the 20 year life of the plan is important and that growth and renewal should be focussed in the CMC in the earlier life of the plan. However, this should not hinder the development of sites outside the CMC that are available for redevelopment and are highly accessible to public transport. The hierarchy of location of development should therefore not only include the CMC, but also their “environs”. As such, our clients consider that the plan on p. 37 should also include the area around West Croydon Station, which is the subject of a forthcoming Masterplan that will accommodate a significant quantum of development in the life time of the plan. • The hierarchy of location of development should therefore not only include the CMC, but also their “environs”. As such, our clients consider that the plan on p. 37 should also include the area around West Croydon Station, which is the subject of a forthcoming Masterplan that will accommodate a significant quantum of development in the life time of the plan.

Croydon Metropolitan Centre • Figure 10, page 19. We seek clarification on Figure 10 as it appears that Croydon’s Metropolitan Centre (CMC) has been excluded from the residential character appraisal. We would expect this area to be coloured dark pink to reflect that flats are the predominant housing type in this area. • Figure 3 – Spatial Management Area (opportunities and constraints). We are unclear as to why areas within the ‘Spatial Management Areas’ overlap – there is an overlap between CMC and Addiscombe for instance. We appreciate the plan is at a small scale, but it will be important to be clear about where the boundary between areas lie - the spatial management approach for CMC may be quite different to the spatial management approach for Addiscombe for example. In Menta’s September 2009 representations to the Core Strategy Issues & Options it was made clear that the Menta Cherry Orchard Road sites must be considered within the CMC. We subsequently received written assurance from the Council that the sites are seen as part of the CMC. • 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)

238 • The CMC has a reputation for poor architecture but there are several large development and regeneration schemes that have the potential to offer positive change, but are yet to start. High quality design of buildings and placemaking will assist in making Croydon “a city that fosters ideas and a belonging for all.” The Borough and the CMC in particular will then become and attractive place to live, work, visit and create investment opportunities for homes, jobs, retail and leisure uses to aid the regeneration of the Borough. CGLP consider that this issue should be included as a bullet point under “We are Croydon”. • Paragraph 4.11 advises that the Council will work with the Mayor to prepare an ‘Opportunity Area Planning Framework’ which would be supplementary to the London Plan and show how new homes and jobs could be delivered alongside improvements to facilities and services. The document notes that central to this approach will be transport and public realm improvements. Paragraph 4.13 and Figure 17 on page 39 of the document illustrate the indicative boundary of the OAPF and the CMC boundary in the UDP, in addition to the Masterplan Areas. With regards to the indicative OAPF boundary, this should include the entire boundary of the West Croydon Masterplan. Our clients also question the reference of the CMC boundary on the plan as this relates to the adopted UDP and the emerging West Croydon Masterplan will supercede a number of the principles in the adopted UDP relating to the CMC boundary. • The proposed spatial strategy concentrates growth in Croydon Metropolitan Centre (CMC) and along the A23 ‘transport corridor’. TfL shares the reasoning that ‘growth and renewal earlier in the life of the plan will be focused upon CMC’, concentrating growth in areas of highest public transport accessibility as opposed to the ‘dispersed growth scenario’. • It would be useful to clarify what is meant by family/non-family units, perhaps by reiterating the definition contained within the UDP for clarity. The recognition that the CMC can only provide a smaller proportion of family housing than other areas is realistic. It would be helpful to identify what that proportion is however as Figure 19 is unclear – it appears to suggest approximately 20% family housing in the CMC. The policy will need to recognise that within the CMC some sites and developments will be more suitable for family housing than others in both physical and market terms and the target will be applied with flexibility across the CMC. • The Council should seek to identify the need for public car parking in the Metropolitan Centre. The provision of any additional major car parking facilities for public use should be avoided, and sustainable forms of transport promoted. • Doubts expressed over the deliverability of family housing in Croydon town centre, as making Croydon Metropolitan Centre an attractive place for family living may not be achievable. • Making Croydon Metropolitan Centre an attractive place will create investment opportunities for homes, jobs, retail and leisure uses to aid the regeneration of the whole borough. • The importance of the provision of the right infrastructure to support any planned growth and concern at its impact on heritage and character. particularly of surrounding areas. • It did not always feel safe in Croydon town centre. • Better pedestrian links are needed, particularly between East and West Croydon stations. • Emphasis on the need for high quality public realm. • New housing in the town centre must have education and other facilities to make it liveable. • Support for university facilities, especially if part of a wider offer of significant cultural and leisure provision. • Housing densities, facilities and access opportunities at major transport interchanges should be maximised. • Access to safe open spaces with improved pedestrian and cycle links was supported. • Croydon Metropolitan Centre requires drastic overhaul of current bus strategy. • Concern at restrictions on the levels of car ownership and parking. • Support for a district heat and power network subject to viability tests.

Addiscombe • The Addiscombe area is identified as an area suitable for ‘lower potential for new homes’ with over half of the provision of residential units to be for family housing with the remainder for non family housing (based on Strategic Housing Land Availability Assessment 2009). • The need for and importance of local centres, such as Addiscombe, should be given priority, and they should share in the growth so as to improve them.

Broad Green & Selhurst • I am a local resident and architect living in the Broad Green area (near St. James's Road) and I am particularly interested in the Windmill Bridge area and how the pedestrian route could be improved providing better links to the Lower Addiscombe Road retail area as it is poorly connected plus was not mentioned in the core strategy overview book.

South Croydon

239 • Tram should be extended to Purley, Crystal Palace and South Croydon, so that people do not need to go into the centre to access the tram network. ( This will also generate a better integrated transport system, with the potential for satellite car parks, for cars to be parked on the perimeter of Croydon, hence reducing numbers of vehicles and air pollution in the centre of town. The existing Trams have shown to be a good accessible form of transport for disabled people.) • So please include a lot of cycle route thought and provision and fit the blinking pot holes. You can start with the section of Croham Road from the Whitgift playing fields to South Croydon Station Bridges. There are some wicked holes and sunk metal covers. • South Croydon, Norwood Junction and to a lesser extent West Croydon stations are hardly step-free, and are very wheelchair-hostile.

Waddon • is not a distinctive area, although it has been labelled as one. In spite of other areas having more distinctive identities, they have not been differentiated –this appears to be purely politically motivated and undermines the validity of the distinct place principle. • Support having a Country Music Club near Waddon

East Spatial Management Area • Queries on why the East Spatial Management Area been spared a fair proportion of growth when it is the only Area with the excess school accommodation. • Endorsement of protection of Green Belt as a vital part of the natural environment, but need a specific strategy to make sense of proposals such as Croydon's Education Department’s plan to build a school in the Green Belt at Conduit Lane. • Sustainability - Increase the amount of light industry planned for the East area to reduce the need for residents to make car-borne journeys

Addington • Cross borough cooperation- recognition of the role that Biggin Hill Airport plays is welcomed but need to make more of the employment opportunities along with other assets in Bromley which can help address residential and leisure needs such as the deficiency in access to nature for the residents of New Addington, with improved country roads. • Consider ways of reducing dependency on fossil fuels such as the pilot project ‘Transition Town in New Addington’ and expanding the New Addington industrial estate to reduce car trips.

Kenley & Old Coulsdon • There are several areas in Kenley which would benefit from LASC designation. • Kenley and Sanderstead should both be considered along with Purley in growth terms as they both have stations without the same flood risks.

Sanderstead • Kenley and Sanderstead should both be considered along with Purley in growth terms as they both have stations without the same flood risks.

Selsdon • A Tramlink extension could help absorb Croydon’s expected growth.

Shirley • Forestdale and Spring Park/Shrublands should be included as Local Centres.

South Spatial Management Area • We would prefer no growth, but we welcome appropriate growth in locations with good transport connectivity. • We support the modified strategy compared to previous options, but will the south have more growth if the level of family housing proposed for CMC cannot be delivered? • We are concerned about the viability and ‘offer’ of Purley and Coulsdon. Maintaining and improving the visual quality and character of the area is important for improving offer. • We support proposals for employment and enterprise, and live-work premises • Road congestion and parking are a big issue for retail and business. And it is vital to speed up movement from Croydon south to M25 by improving A23 and A22 corridors, and Purley gyratory. • It is troubling seeing the series of muggings, burglaries and ASB in Purley and the surrounding districts.

240 • Tram extensions to Purley and Coulsdon are welcomed. • Would establishing park and ride at the M25/M23 junction be effective as most commute by train from Surrey/ Sussex? • We agree that schools should provide for the local community and help reduce student travel distances. • We support the promotion of culture wholeheartedly, but can it be delivered?

Coulsdon • Cane Hill should come forward as part of wider Coulsdon town centre regeneration, with mixed-uses which support the town and improved transport access. • We support recognition of Cane Hill as sub-regionally important. • The most important need is for new homes to support a thriving town centre. • We support an Innovation Park element, though any proposals for “innovation” uses should undergo a rigorous process of viability and market testing to demonstrate deliverability. More suitable sites may lie elsewhere within the immediate area.. • With the quantum of new jobs and housing to be provided at Cane Hill, there may not be enough space to accommodate University campus facilities. • It may be premature to identify Cane Hill as suitable for combined heat and Power–any energy policy should be flexible to allow for future changes. • Areas such as Cane Hill are used by riders who require access to Farthing Downs. Proposed infrastructure should be suitable for riders to access countryside and retain open space for equestrian and other recreational uses.

Purley • We welcome that flood risk has been identified as a constraint to be addressed ahead of improvements to transport facilities/homes growth in Purley. Flood risk in Purley is underestimated. • The south could accommodate far more growth. Flood risk at Purley is a poor excuse as most of Purley is on hills. It makes no sense to squeeze growth into already highly developed areas. • The proposal to provide 45% of new homes for non-family purposes would prejudice the character of Purley. • Purley makes disproportionately large contribution to perceived public needs and should not be targeted for further significant growth due insufficient infrastructure • Purley is recognised as an “Area of Deficiency in Access to Nature”, difficult to see how anything fundamental could be done to change this. Large scale replacement of houses with flats will exacerbate this deficiency and increase the problem of surface water run off. • Please apply pressure to ensure Network Rail maintains its wooded embankments in areas such as Purley. • It fails to mention a number of valued cultural venues/activities such as Purley Music Week. • Further protection should be given to the historic environment of Purley by designating additional Local Areas of Special Character (a local designation similar to Conservation Areas). • Purley has not had any serious proposals to deal with the fundamental problems associated with the public realm or the weight of traffic flowing through the A22/23 junction. • Proposals to extend Tramlink south to Purley should be rethought as trains and buses already serve this destination • There is a good case for keeping and improving the Purley swimming pool. • Could there be a bypass for Purley? • A potential park and ride facility in Purley is on the north-west side of the A237/A2022 cross roads. However, is it feasible?

241 Workshop and meeting summaries

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251 Kingston University Consultation Exercise

252 CROYDON CORE STRATEGY SCHOOLS CONSULTATION: SOUTH CROYDON AND THE METROPOLITAN CENTRE

1

Group 1: Claire Buckley Emma Ranken Kathryn Reeves Mark Roberts Lucy Seymour Jeff Sadler

METROPOLITAN CENTRE

-High public transport accessibility -Reputation for crime and anti-social behaviour -Several regeneration sites

SOUTH CROYDON

-Deficiency in community services -Crime related problems with transport

5 and deficient police services -District in need of regeneration -Lower public transport accessibility

253 EVALUATION OF METHODOLOGY

Successes Restrictions

• Familiarity • Time

• Interaction • Group numbers

• Manageable • Venue set-up

• Copying

8

PRIORITISATION TASK: WHAT WOULD YOU MOST LIKE TO SEE IMPROVED IN YOUR AREA?

9

254

PRIORITISATION TASK: WHAT WOULD YOU MOST LIKE TO SEE IMPROVED IN YOUR AREA?

10

255 PRIORITISATION TASK: WHAT WOULD YOU MOST LIKE TO SEE IMPROVED IN YOUR AREA?

Metropolitan Centre South Croydon

11

QUESTIONNAIRE

Q1: DO YOU THINK CROYDON IS A GOOD PLACE TO LIVE? YES/NO? 100% Yes

Q2: WHAT DO YOU THINK THE BEST FEATURES OF CROYDON (SOUTH /METROPOLITAN) ARE?

12

256 Q3: WHAT DO YOU THINK ARE THE WORST FEATURES OF CROYDON (SOUTH /METROPOLITAN) ?

| Traffic | Crime | Dirty Streets

Q4:WHAT WOULD MAKE CROYDON (SOUTH /METROPOLITAN) A BETTER PLACE TO LIVE?

13

257 Q5: WHAT DO YOU THINK OF THE SCHOOLS IN CROYDON? IS THERE ANYWAY IN WHICH YOU THINK THEY COULD BE IMPROVED • High Quality • Good •Could be improved by greater integration between the state and independent schools

Q6:DO YOU SEE YOURSELF WORKING IN CROYDON IN 20 YEARS TIME?

14

Q7: HOW DO YOU THINK THE MAJORITY OF PEOPLE SHOULD TRAVEL AROUND CROYDON IN 20 YEARS TIME?

• Tram • Cycling • Public Transport • Walking

Q8: IF YOU HAD TO SPEND THE NEXT WEEKEND IN CROYDON, WHAT ACTIVITY WOULD YOU CHOOSE TO DO?

15

258

Q9: WHAT ACTIVITES DO YOU THINK WILL DISCOURAGE CRIME AND ANTI-SOCIAL BEHAVIOUR?

• Youth clubs • Sports facilities • More police on patrol

Q10: What would you like to see for the future of Croydon?

• Cleaner • Better reputation/image • Safer

16

259 IMPLICATIONS FOR EMERGING LDF

| Issue of crime: | Assessment of current policy framework shows that there is limited coverage of these issues – UD6 Safety and Security; SPG1 & SPG4 | Croydon Borough Council employs a ‘Crime Prevention Design Advisor’ | Despite this, there is a lack of robust planning policy to support recommendations that seek to design out crime | Danger that opportunities to include policies that address the wider issues of crime will escape incorporation into the LDF process 17

260 IMPLICATIONS FOR EMERGING LDF

| Issue of lack of youth facilities: | Existing policy framework recognises the need to distribute leisure and recreational facilities in accessible locations – LR1; LR2 & LR3 | Leisure facilities are likely to be funded by the private sector – little incentive to subsidise youth group involvement | Difficulty for planning system to introduce measures that relate to existing development | Planning policy supports the ‘dual use of facilities’

18

CONCLUSION

| Crime and the fear of crime is the overriding concern of the secondary school children within the study area | Current Local Plan policies appear not to recognise the significance of these statistics | The pro-active approach that Croydon Borough Council is adopting is the best way of addressing these social issues | Recommendation: Realistic solutions must be found within the context of the Core Strategy to overcome these concerns in accordance with the London Plan

19

261

262 Group 2: Jennifer Sanders, Deborah Renn, Charlie Jarvis, Matthew Harding, Aneta Mantio

Spatial Planning Preferred Option

Addington and Selsdon - Location

263 Addington

• Village • Historical / architectural quality • Saxon origins • Good accessibility • New Addington (garden village) - 1930’s • Fieldway residential area - 1968 • Open space - (partly privatised) • Trams - good public transport links

Selsdon

• Suburban • Predominantly a residential area • Edge of countryside • Poor public transport links • One district and one small shopping centre – Addington Road • Large areas of open space – Selsdon Woods

264 Methodology

Method of consultation: • 15 minute consultation with 7 girls from Croydon High School (age 14-15yrs) • Mindmap with visual guidance Range of topics discussed: •Retail • Residential • Culture and Leisure • Safety •Transport • Open Spaces • Night-time Leisure

Methodology drawbacks

• Limited amount of time. • Interviewees not from Selsdon and Addington. • Difficult to focus on two areas - not Croydon as a whole. • Interviewer bias: leading responses. • Limited sample: gender bias, small number of interviewees.

265 Summary consultation response: Transport

Summary consultation response: Open Spaces

266 Summary consultation response: Culture & Leisure

Summary consultation response: Safety

267 Summary consultation response: Residential

Summary consultation response: Retail

268 SummaryFindings consultation response: Night-time Leisure

Positives Creation of Negatives entertainment • Open spaces facilities • Quality of the built Lack of No • Goodsocial transport links environmentrestaurants (althoughevents infrequent) • Lack/cafés of social cohesion, • Areas of residential interaction and well being character • Limited retail diversity Support CCTV, police creation of •patrols, New street CCTV initiatives • Infrequent transport links A3 lamps currently being trialled (Selsdon)premises • Safety and security • Limited leisure facilities Safety Lack of issues access options More frequent transport links to leisure facilities Preferred Option

Encourage opportunities to improve social cohesion and interaction within the community, by improving quality of space and safety

269 Initiatives

COMMUNITY COHESION

• Development and enhancement of community projects such as neighbourhood planning; community participation; regeneration projects (potentially funded by the Community Infrastructure Levy (CIL)).

• Strengthening links within communities: community centres; neighbourhood watch; and community events.

• Protect, maintain and improve recreation and leisure activities in the public open spaces within Addington and Selsdon.

SAFETY

• Increased police patrols and CCTV provisions.

• Provide a secure, safe and illuminated links between the existing public open spaces.

Initiatives (cont.)

QUALITY OF SPACE

• To enable growth in sustainable locations, while protecting areas of open space and improving areas of deprivation.

• Create opportunities for retail growth and diversity.

• Enhance and improve the areas existing cultural and historic value to create a sense of place and belonging.

270 CroydonCroydon CoreCore Strategy ConsultationConsultation

Group 3 - Hannah Butterfield Chris Peachey Sam Mason Geoffrey Ocen Mel Stride Freya Turtle

The Task z Consultation with particular ‘places’ in Croydon z Complying with the Statement of Community Involvement, early involvement and continuous engagement (SCI, 2007) z School pupils’ vision for the future of Croydon for 2040 z Outputs will feed into the Preferred Strategy (PPS12, 2008) for Croydon’s Core Strategy

271 The study area

School: Norbury Manor Business and Enterprise College for Girls

School: Harris Academy South Norwood z South Norwood z Norbury z Thornton Heath School: Bensham Manor

Task 1 - Statements

z 30 Statements. z Choice of Strongly Agree, Agree, Disagree, Strongly Disagree, Don’t Know. z Extra details Limitations/Assumptions: z Sample bias z Small sample size (n=10-15) z Subjects dictated to children z Assumes answers were honest

272 Task 1 - Statements

Statements Strongly Agree Agree Disagree Strongly Disagree Don't Know

There are plenty of places for me to hang out with my mates The area needs a place that I could have a kick about, skate or hang out with my mates in The area needs more leisure facilities (e,g. swimming pools, cinema, bowling etc There are lots of fun things to do in the area Everything I need and want is within easy travelling distance I find it easy to get around. To get from A to B The area needs more covenience shops (food, post office, newsagents) The area needs more shops that sell clothes, dvds, cds, electronics etc I would like more big branch name shops like H&M, HMV, Boots and Topshop etc I would like more small, local independent shops There are not enough takeaway and restaurants I venture out of Croydon often When I'm really ill, its quick and easy to see a doctor It is a clean and pleasant place I don't think there are enough green areas with grass and trees I don't think there is enough public art I feel safe when walking around the streets in the day I feel safe when walking around the streets at night I know a lot of the people in my neighbourhood I feel attached to Croydon I will probably live around here when I am older I can't wait to leave Croydon! I want to find a job in Croydon when I'm older There needs to be a better night life for when I'm older

Don't Know Strongly Agree

Strongly Disagree Agree

Disagree

273 Safer, stronger and more sustainable communities

Everything I need and want is within easy travelling distance

I know a lot of the people in my neighbourhood

I feel safe when walking around the streets at night “Gun and knife crime”

Promoting economic growth and prosperity

The area needs more shops that sell clothes, dvds, cds, electronics etc

I would like more small, local independent shops “More unique shops”

There are not enough takeaway and restaurants “Lots of restaurants already; Litter”

274 Improving health and wellbeing

There are plenty of places for me to hang out with my mates

The area needs a place that I could have a kick about, skate or hang out with my mates in “Skate park, parks, bowling, leisure centre, ice-skating”

There needs to be a better night life for when I'm older “Too much trouble already”

Improving the environment

It is a clean and pleasant place

“Litter”

There is too much traffic

We need more green areas with grass and trees

I like the look of most of the buildings in the area

275 Delivering high quality public services

We need better internet access and Wi-Fi “Need faster Broadband”(x2)

I find it easy to get around from A to B “Need tube line”

The future

I will probably live around here when I’m older

I can’t wait to leave this place!

276 Task 2 - Maps

Norbury (Norbury Manor)

277 South Norwood (Harris Academy)

Thornton Heath (Bensham Manor)

278 Task 3 - Discussions z Informal and semi-structured z Focused on the future – 20 year timeframe of the Core Strategy z Starting point: Do you think that you will you stay in Croydon when you are older, and why? z And: Would you consider moving to Croydon when you are older, and why?

Harris Academy South Norwood z Negative: z Not enough outside/sports space z Too many fast-food restaurants! z Crime z Positive: z Improving schools – would stay on at sixth-form z Diverse and multi-cultural z Good transport links z Would go away for life experience but return

279 Norbury Manor Norbury z Negative: z Pressure on school places z Crime z Quality of public realm z Positive: z Good shopping – mostly small stores but some chains such as Primark z Sense of community z Likely to move away

Bensham Manor South Norwood z Negative: z Lack of entertainment options z Lack of options for post-16 education z Crime z See it as being firmly in Surrey! z Positive: z Good transport links z Very keen to leave!

280 Key Themes from the Discussion z Some differences in feedback from different areas - Bensham Manor most dissatisfied z Key concerns: z CRIME z Educational opportunities z Better local leisure services z But, happy with: z Transport z Warm and diverse community

Critique – Statement Survey

Pros: z Good general overview of the issues. z Quantitative data. Cons: z Student’s were limited to choice of statements. z Works with the assumption that the student’s can read well. z Worked with the assumption that the student’s lived in the area. z Reliability? sample size, honesty, influence by peers

281 Critique - Maps

Pros: z Issues in spatial terms. z Visual and interactive exercise was good for student engagement. z Encouraged good discussion. Cons: z Assumed the student’s could interpret maps well. z Worked with the assumption that the students lived in the area. z Issue of students’ confidence.

Critique - Discussion

Pros: z More in-depth information. z Qualitative data. z Student’s guided the conversation.

Cons: z Reliant on the children being willing to engage in conversation. z Individuals doing all the talking, others remaining quite.

282 Critique – Overall Approach z Approach from three directions. - improved chances of gathering good data - a variety of data types z Qualitative and quantitative mix. - a horizontal and vertical view - more reliable data z Overall success?

Conclusions 1 Core Strategy options and issues z dealt with future strategic issues (spatial community strategy) z identified broad strategies and sites

Safer, stronger and more sustainable communities z Crime (eg. gun and knife crime) – Tackling crime and perception of crime (eg. safer streets); Thornton Heath (Bensham Manor) z Night time problems - Better management of night life economy z Community engagement – community cohesion

Achieving better outcomes for children and young people z Most feel that schools need better facilities – BSF programme z Supporting education and community services and facilities z More options for post 16 education

283 Conclusions 2 Promoting economic growth and prosperity z Strengthening shopping centres - more high street stores z Strong feelings against takeaways and restaurants - due to litter

Improving health and wellbeing z Boring, nothing to do - more leisure facilities in local area

Environmental improvements z Reducing environmental impact - cleaner and greener, less litter z More green spaces and attractive built environment z Promoting sustainable travel (managed traffic)

Conclusions 3 Delivering high quality public services z Strong demand for improved and better internet access for public services (24/7) z Mixed opinions on transport – better transport and connectivity (eg Tube lines)

The Future z Outward migration – ‘Your Croydon Campaign’ to encourage staying on in the area

What next? z Preferred Strategy Consultations z Pre-submission presentations, Submission, Examination, Inspector’s Report and Adoption (2012)

284 Group 4 – Coulsdon

BY: Ian Thompson Marcus Kinsella Mark Matheson Natasha Williams Adedeji Adenubi Steve Doel Zainab Gulzar

` Southernmost of the 16 ‘Places’ of Croydon

` Edge of countryside: Greenbelt and South Downs

` Bypass: reduced traffic and enabled town centre improvement scheme

` Housing: Victorian terraced cottages, inter-war semi- and detached houses, later development at edges

` Existing facilities include: library, adult education centre, public recreation facilities

` One employment area: Ullswater Crescent

` Six primary and two senior schools

285 ` Community comprehensive school ` Mixed, 11-16 years ` Re-designated specialist sports college 2007 ` Variety of socio-economic backgrounds ` Free school meals lower than national average ` ESL lower than national average ` BME higher than national average ` Learning disabilities higher than national average ` OFSTED ratings of “good” (outstanding-good- satisfactory-inadequate)

` Croydon 2040 An initiative to consult young people in Croydon on strategic planning issues

` Find out from school children what they regard as the key issues for their neighbourhood

` Help them to formulate a vision for the area 15-20 years in the future

286 Semi-structured Interviews/ Discussion

Open and closed questions

What are the advantages/disadvantages within your area?

What would you like to see in the future?

Topics Education Engagement Personal Safety Health Leisure Travel Housing

` Advantages ◦ Able to clarify questions; and

◦ Gave children a chance to express their full views and opinions;

◦ Group discussion sparked ideas.

` Disadvantages ◦ Small sample size (3 children);

◦ Unlikely to be representative of area;

287 ` Transport- roadworks/ congestion - bus timetables - safety issues - Suggestions: bike lanes, pedestrian crossings

` Parks- unclean, unsafe - activities- skate park?

` Urban environment- street lights, seating

` Town Centre - shops, restaurants -entertainment

` Positives- housing - street market/ x-mas fair -community-friends - housing - parks, recreation

288 Group 6: Matthew Conisbee Geoff Finch Chris Gent David Gibson Mike Humphrey Chris Scobie

€ The most populous London borough € South London € Croydon Town Centre – Issues of Deprivation

289 € Identify the main spatial issues and options from the emerging Core Strategy documents.

€ Deciding on an appropriate survey method.

€ Public consultation and data collection.

€ Interpretation of the results and aligning these with the spatial issues and options.

€ The next steps ?

€ St. Mary’s Catholic High School, Woburn Road. € The Archbishop Lanfranc School, Mitchum Road.

€ Focussing on the issues that concern the kids.

€ 16nr statements for consideration. € ‘Satisfied/dissatisfied’, & ‘agree/disagree’. € Open forum “…….if you were Boris Johnson ?” € The Metropolitan Town Centre, and Broad Green.

€ Croydon High School, 9th December 2009.

290 € North / Central Croydon, on A23 € Commercial / Retail / Office-led in character with significant public sector presence € Older Population: Only 13% aged under 15 € Transport: High proportion of public transport users € Fairly ethnically diverse: 30% BAME (about the same as London and Croydon) € 14% of homes are ‘overcrowded’ € Strong skills base: 41% have degree or higher

€ North-west Croydon, borders LB Sutton € Residential/suburban in character with links to Town Centre at SE and Industry in SW € Youthful Population: 23% aged under 15 € Transport: High proportion of car-users € Ethnically diverse: 48% BAME compared to 30% in London and Croydon € 18% of homes are ‘overcrowded’ € Low level of qualification: 28% have no formal qualification € Proportionately large Hindu population: 12% compared to Croydon / London under 5%

291 Results

€ Metropolitan Town Centre:- € 25% of respondants considered the area safe and easy to navigate by bike. € 17% of respondants were satisfied with the parks and open spaces. € 50% of respondants were dissatisfied with the cleanliness of the streets and pavements.

€ Broad Green:- € 67% of respondants were dissatisfied with the leisure facilities. € 100% of respondants were dissatisfied with the cleanliness of the streets and pavements.

Issue 1 – Parks / Open Spaces

€ Generally considered unsatisfactory

€ Conduct a review of green infrastructure

€ Identify areas suitable for opening-up

€ Promote a wider knowledge of existing infrastructure

€ Promote Croydon as a “Champion” borough

292 Issue 2 – Public Places

€ A lack of public meeting spaces and recreation facilities

€ Safeguard and enhance access to existing areas

€ Seek provision of new locations

€ Enhance existing and add new areas for children to play

€ Seek financial contributions

Issue 3 – Transport Links

€ Generally considered unsatisfactory

€ Improve and add new cycle paths

€ Extend the tram service

€ Improve public transport across the sub-region

€ Ensure new development is designed to promote more direct, safer routes for cyclists and pedestrians

€ Create a longer pedestrian networks

293 294 295 296 297 298 299 300