Appendix 8: Consultation Responses on Core Strategy Issues and Options - Initial Report (including Sustainability Appraisal) 1. Setting the Scene Page/Paragraph/ Representation Recommended response Full Name Objective Organisation Nature of Response Officer Recommendation page20/questionAO2 The draft core strategy lacks proposals to The Core Strategy will make Mr Andrew implement the blue ribbon policies in the London specific reference to the blue Steen Plan. Whilst the borough mainly has more minor ribbon networks. White & Sons watercourses these are still important and if Observation development complements and gives space to Agree – Propose Changes them they can restore the sense of place associated with the continuum of the water- space. page20 A place to belong- We support the provision of The support is welcomed. Mr Austin Mackie new housing and the enhancement of existing Austin Mackie Associates residential areas. Ltd Support Agree - No Action n/a We write on behalf of the BRB (Residuary) Ltd. The comment is noted. BRB (Residuary) Ltd owns land located at the BRB (Residuary) Ltd East Croydon Goods Yard, Lansdowne Road, Observation Croydon. The site is situated to the north west of Noted – No Action East Croydon Station and currently sits outside but close to the Metropolitan Centre Boundary as defined in the Croydon Replacement Unitary Development Plan 2006. page20/questionAO2 I am a young adult with learning disabilities and The objection is noted. The Mr Nafi Djemil am very disappointed to see that the disabled Core Strategy seeks to meet seem to have been ignored/forgotten as regards the needs of all residents of Object the provisional aims and objectives the borough and future drafts Noted – Propose Changes of the Core Strategy will include reference to the needs of the disabled residents of the borough. page20/questionA01- We would wish that the objectives in A Place for The first two suggested Mr Andrew A02 Sustainable Living reflected the key concerns of objectives are too detailed for Steen the Environment Agency more directly. We a Core Strategy which is a White & Sons suggest that the following objectives are high-level planning document. Object included in order to tackle the effects of climate A spatial objective refering to Agree – Propose Changes change, flooding, effective waste management, Sustainable Urban Drainage water quality, biodiversity and energy supplies. Systems in the borough will be included within the Core Our suggested objectives are indicated by bullet Strategy. points. Groundwater • Protect surface and groundwater from pollution and enhance and maintain the highest standards of water quality for drinking and recreation wherever possible. • Encourage utilisation of Brownfield sites for development to improve soil and groundwater quality. • Extend the use of SUDS across the district. Require all new developments to consider SUDS as first option (they are not always appropriate). SUDS have huge benefits in terms of improving the quality of water returning to the environment and also helping to recharge the groundwater. This is important as pressures on groundwater for drinking supplies will only increase in the future. page20/questionA01- LB of Croydon is underlain by a Major Aquifer The issue of demand and Mr Andrew A02 which is important in this borough for providing water use will be addressed in Steen water for human consumption. Public water the Infrastructure Delivery White & Sons abstractions in this region include the following: Plan. The protection of Source Observation Protection Zones is noted. Noted – No Action Addington PS, Waddon PS, Purley PS, Woodcote PS, Smitham PS, Kenley PS, West Wickam PS, Stroud Green PS and Woodmansterne PS PS = Pumping Station This list demonstrates that groundwater is a very important drinking water resource in this area. Source Protection Zones are designated for drinking water abstractions. These aim to protect groundwater from surface contamination that could have a detrimental impact on the quality of water being abstracted. The highest risk zones are Inner Source Protection Zones (SPZ 1), where we will object to certain types of high risk activities. Given the sensitive nature of this resource and the increasing demands that will be placed upon it as the population in the district increases, it should be addressed within any spatial policy for Croydon district. page19/para1 “If the DPD is a Core Strategy, the following Infrastructure providers Carmelle Bell documents, amongst other evidence, may be investment programmes and Thames Water Property relevant: ……..infrastructure providers’ strategies and environmental Observation investment programmes and strategies; programmes will be Noted – No Action environmental programmes etc.” considered by the Infrastructure Delivery Plan. page20/questionA01- Land contamination present a risk to the The comment is noted. Mr Andrew A02 groundwater in the Major Chalk Aquifer. Steen Developing Brownfield sites allows the White & Sons opportunity to improve soil and groundwater Observation through remediation if it has been impacted by Noted – No Action historical contamination. page20/questionA02 A further objective should be included; The Core Strategy will include Mr Andrew Waste: a spatial objective ensuring Steen • Minimise waste generated in the borough, the responsible use of land White & Sons increase re-use and recycling. Recover and and natural resources. Object dispose of waste without endangering human Agree – Propose Changes health or harming the environment and ensure that waste is disposed of as near as possible to place of production. page20/questionAO2 A further objective should be included for flood The Core Strategy will include Mr Andrew risk; a spatial objective to tackle Steen flood risk in the borough. White & Sons • Manage and reduce flood risk across the Object borough. Agree – Propose Changes The Wandsworth, Merton, Sutton and Croydon SFRA Level1, Croydon SFRA Level2 and indeed the map on page 18 of this section of the Core Strategy clearly shows that flooding and flood risk is of major concern in the Borough. The SFRA recommends that ‘flood risk considerations are included as part of the LDF process and future strategic planning’ and furthermore that a ‘Surface Water Management Plan should be prepared for the LB Croydon’. page18/figure The map shown on page 18 should show all of The level of detail suggested Mr Andrew the point data contained on figure 5D of The is too detailed for a Core Steen Wandsworth, Merton, Sutton and Croydon Strategy. White & Sons SFRA Level1. This historic data is primarily Object attributable to surface water flooding and should Disagree – No Change be simply referred to as ‘location of historical flooding’ or something similar. n/a Have the infrastructure implications of the The comment is noted. The Carmelle Bell strategy/policies clearly been identified?” infrastructure needs Thames Water Property associated with the Core Observation Strategy will be considered by Noted – No Action the Infrastructure Delivery Plan. page20/questionAO1 Furthermore the MPA recommend that Noted although Secure by additional wording be included within this Design is one of many Metropolitan Police section, as to read (additional wording considerations Authority underlined): Object Noted – No Action • Reduce opportunities for crime and comply with Metropolitan Police ‘Secured by Design’ (or subsequent) accreditation; n/a This probably boils down to the Borough The comment is noted. Mr I.G.M. Hunter business community and the developers of projects having an immediate financial incentive Observation (profit) to actively co-operate with the Council in Noted – No Action schemes that come forward from whatever source. The average resident will see no immediate benefit, financial, ecological or otherwise unless he is presented with the effects of future circumstances that impact directly on his quality of life. page20/para2/bullet3 Biodiversity The Core Strategy will make Mr Andrew specific reference to Steen We support the inclusion of an aim to raise the protecting and enhancing White & Sons quality of green spaces and create a ‘green grid’ biodiversity in the spatial Object across the borough. However this objective objectives. Agree – Propose Changes should refer to biodiversity and the ecological value of these sites or else include an additional objective purely concerned with biodiversity. page20/questionAO1 Recommendation: In response to question AO1, The support is welcomed. the MPA support this statement and are keen for Metropolitan Police its retention within the emerging Core Strategy. Authority Support Agree - No Action page20/questionAO1 A further objective should be included on The Core Strategy will make Mr Andrew Energy; reference mitigating and Steen adapting to climate change in White & Sons • Take account of and reduce the impacts of the spatial objectives. Object climate change. Reduce carbon dioxide Agree – Propose Changes emissions, increase energy efficiency and increase the use of renewable energy sources. Reduce the consumption of non-renewable energy. page20/para1/bullet5 “Work with partners to transform public services Comment is noted. Re. Ms Ann by clustering facilities and services that help to paragraph 2 agree Burroughs regenerate our town and suburban centres.” subsequent documents will try Metropolitan Police to reflect the work of the Safer Object “Together for a Safer Croydon” is the aim of the Croydon Partnership. Re. Noted – Propose Changes