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 Goods Yard, Lansdowne Road, Observation Croydon. The site is situated to the north west of Noted – No Action 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, PS, Purley PS, Woodcote PS, Smitham PS, 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 Safer Croydon Partnership. A greater emphasis paragraph 3 - The manner by of this work should be actively promoted in the which the Police should be LDF Core Policy aims and objectives. involved in pre-application discussions on design will be Working within the Safer Croydon Partnership, considered in the Croydon Borough Police submit that the Development Management Planning Department should also promote and DPD. ensure continuing engagement with Police Crime Prevention Design Advisors (CPDAs) for all major developments during any initial concept discussions, and at the pre-application and application level. page20/para28/bullet2 “Provide the best possible opportunities for our The comment is noted. Ms Ann young people to develop their skills, interests Burroughs and life chances.” Metropolitan Police Observation This is a positive aim that will assist our young. Noted – No Action However, there is a recognised lack of accessible youth amenity space throughout this borough. Croydon Borough Police seek to ensure that the Core Strategy spatial aims and objectives allow for the requirement of more youth facilities and sensibly allocated amenity space to suit their needs. page20/para1/bullet7 Over recent years National Planning Policy The comment is noted. Ms Ann Guidelines have actively endorsed the “Secured Burroughs by Design Scheme” (SBD). This is a nationally Metropolitan Police recognised scheme that is run by the Observation Association of Chief Police Officers; SBD Noted – No Action actively promotes the above principles and encourages developers to apply for accreditation. It has also been included in the ‘Code for Sustainable Homes’ and is a funding requirement of the ‘Homes and Communities Agency’.

In 2004 Home Office funded research by Dr Rachael Armitage showed that ‘Secured by Design’ reduced burglary by over 50%. ACPO CPI recently commissioned further research by Dr. Armitage and Leanne Monchuk of Huddersfield University. This research focussed on the Glasgow Housing Association refurbishment programme of over 2000 dwellings. Preliminary results indicate that there is now a 65% reduction of acquisitive crime and criminal damage experienced in the refurbished developments where ‘Secured by Design’ physical protection standards are incorporated when compared with the same developments prior to the refurbishment.

Research shows that this type of planning intervention would have a clear positive compound effect on community safety and cohesion on this Borough. Croydon Borough Police request that the LDF Core Policy promotes both ‘SBD’ and ‘Counter Terrorism issues’. Planning officers need the necessary strategic statements to enable the introduction of enforceable conditions requiring ‘SBD’ compliance on all new and refurbished developments. Page20 Barratt Homes (Kent) has concerns about the The comment is noted. It is Council’s intention to rely on the creativity in not intended to rely solely on Barratt Homes (kent) Croydon to tackle key issues of climate change, the creativity of the people of Observation accessible jobs, decent homes, and public Croydon to tackle key issues Noted – No Action service provision. Whilst our client recognises of climate change, accessible the importance of public consultation and jobs, decent homes, and involvement in the planning process, PPS1 public service provision. (2005) requires local authorities to take a strong leadership role in the planning system (paragraph 1.6). As set out in paragraph 1.5, the spatial planning system “exists to deliver positive social, economic and environmental outcomes, and requires planners to collaborate actively with the wide range of stakeholders and agencies that help to shape local areas and deliver local services.” The Core Strategy should therefore set out how the Council will tackle these key issues, as well as the appropriate delivery mechanisms. page20/para1/bullet7 Figures published in 2007 on “The economic Noted although Secure by Ms Ann and social costs of crime against individuals and Design is one of many Burroughs households” show that each burglary reported considerations. Metropolitan Police costs £3,268. In the 12 months to August 2009 Object there were 3216 reports of burglary in Croydon. Noted – No Action This long term visioning statement projects building 20,000 new dwellings in Croydon over the next two decades. The enforcement of SBD planning conditions requiring physical protection alone on every new dwelling could reduce the likelihood of those dwellings being burgled by at least 50%. page20/para1/bullet7 Requiring SBD design and physical protection The comment is noted Ms Ann standards in every new build should further although Secure by Design is Burroughs reduce the long-term acquisitive crime figures on one of many considerations Metropolitan Police this borough by addressing the surrounding Object environment and this will in turn enhance Noted – No Action residents’ quality of life and fear of crime. page20/para2/bullet6 The provisional aims and objectives define It is the Council's intention to Ms Ann Croydon as being as Place of Opportunity, A seek the highest possible Burroughs Place to Belong, and A Place for Sustainable quality built environment. Metropolitan Police Living. All of these appear to compliment the Observation visions described. Noted – No Action “We want to raise the standard of design of new buildings, streets and public spaces to equal the best in London.”

This aim will undoubtedly have a positive effect and benefit the built environment. However, I submit that this borough should also aim to deliver the highest quality built environment and raise the standards of physical protection required. This is essential to provide sustainable buildings, streets and public spaces. page20/questionAO2 There is a notable difference in the strength of The principle is embedded in Ms Ann the wording in section 5, Climate change, the emerging Core Strategy. Burroughs Energy, Green Buildings, Flooding & Water. This Metropolitan Police section transmits a definite message to all Object parties about the stance of this Planning Disagree – No Change Authority and how they expect the developments to comply. It is our submission that wording in section 1, Spatial Aims & Objectives should be of a similar strength and clearly transmit a strong message to developers about what “Community Safety” interventions and standards are expected. This then allows developers to allow for any additional costs from the outset and will have a significant positive impact on the regeneration of the borough. page7 Given the importance and long term effects of Residents of Mr I.G.M. Hunter this consultation the Council should have found have not been excluded from the resources and effort to fund Council consultation. The consultation Object organised meetings in all “Places” identified. If has been in accordance with Disagree – No Change they can budget to go to Cannes for the Statement of Community International Kudos they should certainly have Involvement. funded local meetings on the Core Strategy for their own residents. page9 At the end of the day, when the Core Strategy is The comment is noted. Mr I.G.M. Hunter firmed-up it will not be acceptable for the Local Authority to say ”well we did seek consultation Observation but there was a major lack of response from Noted – No Action residents”. page9 In my e-mail to Mr Carlisle, I highlighted the Residents of South Croydon Mr I.G.M. Hunter absence of any consultation meeting about the have not been excluded from “South Croydon Place”. Whether or not any local consultation. The consultation Object association exists, the fact is that thousands of has been in accordance with Disagree – No Change residents living in South Croydon and the Statement of Community specifically along or adjacent to the Brighton Involvement. Road corridor, have been excluded from consultation because the Council did not organise a meeting within the “Place” and, by similar omission may have excluded many other Borough residents, in other “Places”, from the consultative process. page20/questionAO1 Devogrove endorses the objective of the Council The comment is noted. to create “A Place for Sustainable Living.” In that Devgrove context, it is acknowledged that the Council will Observation seek to apply the highest levels of energy saving Noted – No Action standards on new homes and non-domestic properties, whilst endeavouring to raise the standard of design of new buildings, streets and public spaces. We would suggest that the significance of Croydon Tramlink should be recognised not only in its potential extension but also to the contribution that it can make to the achievement of sustainable patterns of growth adjacent to its present alignment. n/a Paragraphs 4.10 of PPS12 place goes on The comment is noted. The Carmelle Bell provide advice on the need for infrastructure to infrastructure needs Thames Water Property support housing growth and states: “The associated with the Core Observation outcome of the infrastructure planning process Strategy will be considered by Noted – No Action should inform the core strategy and should be the Infrastructure Delivery part of a robust evidence base. It will greatly Plan. assist the overall planning process for all participants if the agencies responsible for infrastructure delivery and the local authority producing the core strategy were to align their planning processes. Local authorities should undertake timely, effective and conclusive discussion with key infrastructure providers when preparing a core strategy.” page15 Reference is made throughout the document to Future drafts of the Core Croydon Metropolitan Centre’s identification Strategy will provide more Homes and Communities within the London Plan as an Opportunity Area; detail on the relationship Agency however, it is considered that the Issues and between the Core Strategy Object Options Report should include a greater level of and the London Plan. Agree – Propose Changes detail on the London-wide planning context within which the emerging Core Strategy policies are being formulated. It is a statutory requirement that Croydon’s Core Strategy needs to be in conformity with the policies within the London Plan (albeit recognising that the London Plan is undergoing a review at this time), and therefore it is considered that the inclusion of text setting out a London-wide planning policy context, and explaining how the Core Strategy responds to London Plan policies, is critical within the next iteration of the document, having regard to the tests of “soundness” set out within PPS12. page18/map The flood zones are continuous along the route The comment is noted. The Ms Susan of the Caterham Bourne rather than in isolated map is intended and is Sheahan sections as shown on the map. believed to show that they are Environment Agency continuous. Observation Noted – No Action page18/para1 The CS states that most of the borough’s growth The comment is noted. The opportunities are concentrated in Croydon next iteration will consider a Highways Agency Metropolitan Centre and along the A23 corridor. modified spatial strategy to Observation Intensification of development in areas with a ensure growth is sustainable Agree – Propose Changes low level of public transport assesibility (PTAL), and is likely to feature could result in an increase in car trips which elements of the dispersed could in turn precipitate an increase in growth and concentrated congestion on the SRN if mitigation measures growth options.A Borough- are not in place to reduce the need to travel by wide Transport Strategy will car. However, it is important that the Core be prepared to address Strategy places further emphasis on the reducing the need to travel by provision and improvement of sustainable car. transport infrastructure as a whole and particularly where high trip-generating developments are proposed. In line with the DfT’s Guidance on Transport Assessment (2007) , this emphasis will assist in mitigating potential increases in private vehicle trips and hence help reduce the potential for impacts on the SRN. page15/sub-regional 6. It is acknowledged that Croydon is seeking to The Core Strategy will outline context work actively with other LPAs to deliver specific areas for cross- Highways Agency complimentary policy instruments outlined within borough approaches. Object their respective LDF documents. The HA is Agree – Propose Changes strongly supportive of an integrated approach. We suggest that the CS includes a simple framework which outlines specific areas in which a cross-borough approach will be pursued. The framework should also describe how collaboration will be achieved. The adoption of a co-ordinated approach is particularly important to secure the delivery of cross-borough transport improvements which are often difficult to deliver. page20/para2 In the case of Croydon, this relates to the M25 The observation is noted. The junctions 6-7 and the M23 starting at the junction Core Strategy will seek to Highways Agency with the A23. Although these SRN sections are address existing highway Observation not within the Borough, it should be noted that congestion and reduce Noted – Propose Changes the M25 junctions and M23 junctions are reliance on the private car. currently operating at a high level of stress and any additional traffic would add to the existing congestion. n/a In spatial planning and development control The observation is noted. The terms, we have a duty to safeguard the Core Strategy will seek to Highways Agency operation of the motorway and trunk road address existing highway Observation network as set out in the DfT circular 02/2007 congestion and reduce Noted – Propose Changes (Planning and the Strategic Road Network) . The reliance on the private car. circular encourages the HA to work co- operatively with Local Planning Authorities (LPAs) within the framework of the Government’s policies for planning, growth areas, regeneration, integrated transport and sustainability. We look to your Council’s LDF to promote strategies, policies, and land allocations which would support alternatives to the private car. and Kenley In line with guidance set out in DfT Circular The comment is noted. 02/2007, development proposed within these Highways Agency areas might need to demonstrate how it will Observation mitigate any potential impacts to the SRN. Noted – No Action Furthermore, if development proposals are pursued in these locations then public transport accessibility might need to be enhanced with infrastructure improvements. See paragraph 9 below. page17/para4 Please see below some general comments The Infrastructure Delivery regarding the CS Issues and Options Report, Plan will address funding and Highways Agency which has been assessed from a transport delivery mechanisms. Observation perspective against the soundness requirements Noted – No Action set out in paragraph 4.52 of PPS12. Where development sites are allocated outside town centres, it is essential that sustainable transport improvements are identified to mitigate any adverse impact on the road network. In addition, the proposed improvements should be phased in line with the delivery of new development. Funding and delivery mechanisms of such improvements should be detailed in the CS. page11/para3 Section 1, Croydon’s Historical Context The Borough Character Mr Paul Scott Appraisal will provide more People for Portland Road The 3rd paragraph of the historical context detail on the historic Object describes Woodside as one of a series of places development of Woodside. Agree - No Action that developed in the 18th Century. This is incorrect. The village of Woodside actually dates back to the medieval period and possibly earlier. n/a Growth The comment is noted. Mr David Walker 12. One of the demands driving Croydon’s Crystal Palace Triangle Core Strategy, and the Unitary Development Planning Group Plan before it, is the accommodation of Observation economic and demographic growth allocated to Noted – No Action the borough in the London Plan. The Draft Replacement London Plan [DRLP], currently out to consultation expects that London’s employment and population will continue to grow. n/a 13. The growth is recognised to be created by The comment is noted. Mr David Walker expanding businesses and families, generated Crystal Palace Triangle from within London, and the Mayor wants to see Planning Group that growth accommodated within London. But Observation the pressure is recognised as lower than Noted – No Action previously; the DRLP has published revised housing targets for each borough. page17-18 With regard to the key issues of climate change, The comment is noted. It is accessible jobs, decent homes, and public not intended to rely solely on Homes and Communities service provision, the consultation document the creativity of the people of Agency indicates in the last bullet point on page 20 that Croydon to tackle key issues Observation the Council will rely on the creativity of the of climate change, accessible Noted – No Action people in Croydon to deliver these. The HCA jobs, decent homes, and recognises the role local communities can play public service provision. in tackling these important issues, however is of the view that it is the role of the planning system to seek to implement change in these areas, and that it is issues such as these that the emerging policy framework within the Core Strategy and subsequent DPDs should be capable of addressing. page20 As I have often had reason to state the lovely The comment is noted. The Miss Jean appearance of the quality build of the Sport Core Strategy will seek to Newman England swimming centre in ensure a high standard for high street, I would please urge you to be as new buildings in the borough Observation vigilant in the quality of the building of any new including quality and Noted – No Action developments for Croydon, I'm sure you will and sustainability. the borough will take another huge leap forward in the scheme of things. Just re the eco situation, all of which I'm sure will be welcomed I wonder if there might be any plans to offer mini roof wind generators perhaps to sell any power back to the national grid and reduce electric bills? page19/spatial aims The HCA welcomes the Council’s aim to deliver The support is welcomed. and objectives sufficient new housing, to provide a choice of Homes and Communities residential accommodation and affordable Agency homes, and is supportive of Croydon’s objective Support to extend the range of business activities in the Agree - No Action Borough. page19 A Place of Opportunity - We support proposals Our approach to employment Mr Austin Mackie that seek to develop a more diverse economic / areas will follow that set out in Austin Mackie Associates business base within the Borough. the London Plan. Ltd Observation In doing so we believe that a more flexible Noted – No Action approach should be adopted to long-standing employment / industrial designations, especially where there suitability for future purpose and net economic benefits is likely to be limited.

Such an approach should facilitate more flexible optimisation of land, particularly in existing mixed-use or residential areas and enable commercial as well as environmental and social regeneration.

It is important that existing employment areas are not simply treated as appropriate for retention and are reviewed in full in terms of the qualitative characteristics. page8/para5 Page 8. We welcome confirmation of the The comment is noted. Nikki Honan commitment to see Croydon as ‘a place to HUDU belong’, but this page could note the importance Observation of overall health and well being in addition to Noted – No Action public realm and provision of appropriate services. Drivers for Change page20/questionAO2 In addition, green grid networks normally include The Core Strategy will make Mr Andrew river corridors. A number of important tributaries reference to increasing access Steen of the River Wandle, including the Wandle itself to the natural environment in White & Sons flow through Croydon and the objectives should the spatial objectives and Object reflect this, as river corridors are key in providing make reference to river Noted – Propose Changes access to nature, green infrastructure and corridors in the text. providing corridors for wildlife. We would suggest that this aim is changed to include rivers as follows;

• ‘Raise the quality and ecological value of our open spaces and create a ‘green grid’ across the borough, including river corridors. Restore and enhance watercourses, their banks and the green corridor along their margins to promote recreation, biodiversity and to provide opportunities to reduce flood risk. Protect and enhance biodiversity throughout the borough’. page20/questionAO1 But the aims and objectives are not necessarily A modified growth strategy will Mr Barry Atwood compatible with each other. For example, how be outlined in the next can the Borough “reduce congestion along the iteration of the Core Strategy. Object main A23 corridor” while concentrating in it Agree – Propose Changes “sufficient new housing to provide choice of housing and affordable homes for all local families and single people”? page18/para3 This section highlights the importance of The comment is noted. community cohesion. Ensuring safety and Metropolitan Police security for the community is a priority for the Authority MPA. Observation Noted – No Action n/a Mindful of the requirements set out in the Asset The comment is noted. Management Plan (AMP) and the policy Metropolitan Police framework, the MPA make the following Authority comments and proposed alterations to the Draft Observation Core Strategy. The following representations Noted – No Action consider national and strategic planning policy framework, with particular attention to the policy set out in the London Plan. page19/para2/bullet2 We support the Objective to ‘make Croydon a Note support. Objectives will Ms Rose sub-regional cultural centre and deliver a be numbered in future Freeman stronger range of facilities’. We suggest that the consultation drafts. The Theatres Trust allocation of the Objectives by number or letter Support would facilitate their identification. Agree – Propose Changes page16/figure The diagram on page 16 of the consultation The map was not intended to document “Neighbouring Boroughs” indicates detail the Green Belt outside Homes and Communities the location of specific designations within of Croydon or major Agency adjoining Local Authority areas, including “Green developed sites in Observation Belt” and “Major Housing Sites in the Green neighbouring boroughs. It's Noted – Propose Changes Belt”, however also illustrates the route of purpose was to show existing existing and proposed transport links within and proposed cross-borough Croydon itself. The HCA considers that for working including the Joint consistency purposes, either all the relevant SW London Waste Plan and detail within the key should be illustrated for the Joint Strategic Flood Risk Croydon and its neighbouring Boroughs, or the Assessment. Future drafts of focus should simply be on the neighbouring the Core Strategy will make authorities alone. the distinctions clearer. page18/para3 Community cohesion This section could confirm The comment is noted. Nikki Honan commitment to supporting social well being HUDU (which may include supporting mental health for Observation example), and may be encouraged through the Noted – No Action appropriate design, access and the location of development. page36/para1/bullet1 I agree with your proposal to extend the facilities The comment is noted. Mr Bill Tubb for Leisure activities and swimming Pools. I have been very upset by the recent attitude of the Support present Council regarding their proposal to Noted – No Action demolish the Swimming pool in Purley. page19/Question AO2 Question AO2 Spatial Aims & Objectives- We The comment is noted. Nikki Honan welcome spatial aims and objectives, including Encouraging physical activity HUDU delivering social infrastructure and designing out in the borough will be Observation crime and fear of crime. ‘A Place to Belong’ incorporated in the text of Noted – Propose Changes could include objectives to improve the health future drafts of the Core and well being of the borough, and reduce Strategy. Whilst the spatial health inequalities. Perhaps wording could objectives are not SMART the be:‘Create an environment which supports policies/strategies in future residents to pursue health and wellbeing in the drafts of the Core Strategy will broadest sense, and as described by the WHO: be SMART in order to "a state of complete physical, mental and social measure delivery of the well being and not merely the absence of objectives. Future drafts of the disease or infirmity." ’ Core Strategy will reflect the World Health Organisation. Basic documents. forthcoming vision. 39th ed. Geneva: WHO, 1992.

‘A Place for Sustainable Living’ could include an objective to encourage physical activity in the borough, including recreational activity and increasing walking and cycling.

We would welcome the objectives following a SMART approach.

We presume these aims and objectives will link with the ‘where do we want to be?’ sections within the document to form a vision for the future of Croydon. We would welcome a vision which incorporates improving health and well being and reducing health inequalities. page20/para1/bullet7 Croydon’s Community Strategy 2008-2011 The comment is noted. states that the Council is committed to working Metropolitan Police along side the Metropolitan Police and building a Authority partnership which will focus on reducing crime Observation and improving community safety within this Noted – No Action borough. The MPA support their recognition within this strategy and also wish to work with the Council to improve policing facilities. page20/para1/bullet1 If there is to be growth for housing it must The comment is noted. The Mr Paul Potter supported by an improvement to the infrastructure needs Safer Neighbourhoods infrastructure i.e. schools, health, policing, associated with new homes Team libraries, roads, transport etc will be considered by the Observation Infrastructure Delivery Plan. Noted – No Action page19/para2 I do not agree with the statement – shout for a The comment is noted. It is a Mr Bill Tubb University in Croydon - it is too silly a statement legitimate aspiration to seek a as though Universities are in shop windows and university presence which Object we buy one. Croydon has developed some fine would be in keeping with Noted – No Action schools and we have a fine Technical College Croydon's city status which is still growing and has a good reputation aspirations. which is splendid and it should be able to continue to develop as need requires. page15 Sub-regional context- On behalf of the Homes The comment is noted. and Communities Agency (HCA), we set out Homes and Communities below representations in response to Croydon Agency Council’s Core Strategy Issues and Options Observation Initial Report. By way of background, the HCA is Noted – No Action the landowner of the Cane Hill site in Coulsdon, which under the “saved” policies of the 2006 Croydon UDP is the only Major Developed Site in the Green Belt within the Borough. The representations below therefore focus primarily on those aspects of the Core Strategy Issues and Options Initial Report which are relevant to the redevelopment of the Cane Hill site. page20/questionAO1 Section 1 (Spatial Aims and Objectives) The support is welcomed. identifies under the heading 'A Place to Belong', Metropolitan Police bullet point 7, the need for the design process to Authority address crime and the fear of crime. Support Recommendation: In response to question AO1, Agree - No Action the MPA support this statement and encourage the use of Secured by Design principles within all new developments. page20/questionAO2 The council needs to recognise the needs of all The comment is noted. Mr Ibo Djemil the people of Croydon and not just the wealthy influential and powerful residents living in places Observation such as Purley who seem to want to prevent any Noted – No Action developments of new housing in their large and underused rear gardens. page20/questiona02 A Core Strategy should also contain strategic The Council will ensure that Ms Alison objectives that flow from the document’s vision the Core Strategy sets out Fairhurst and help to guide the development of the spatial spatial objectives that are Government Office for strategy. However, I do not consider that all of appropriate for the Core London the aims and objectives set out within the Strategy. It will be clear how Object document are appropriate for a Core Strategy, the policies will deliver the Agree – Propose Changes for example, the provision of fibre optic and plans objectives. enhanced mobile phone bandwidth. In the published plan, you should be able to identify how policies will deliver the plans objectives. page19/para2/bullet3 We particularly support the aim of attracting a The support is welcomed. Mr Barry Atwood university campus to the Borough. Support Agree - No Action page15 The Council have acknowledged that Croydon The comment is noted. Mr David Metropolitan Centre has been identified as an Hammond opportunity area in the London Plan, but there Natural England are issues over transport capacity, climate Observation change and flood alleviation/amelioration, and Noted – No Action these are acknowledged. page15 Following this Introduction, the remainder of this Future drafts of the Core Mr Andrew response sets out the Airport’s comments on the Strategy will include Biggin Hill Walters draft Core Strategy Issues & Options report, Airport on relevant maps and Biggin Hill Airport Limited under the same headings as the report. in associated text. Object Comments are made only on the sections Agree – Propose Changes relevant to the Airport. The heading ‘The Sub-regional Context’ on page 15 is perhaps incomplete as this section covers both the regional and sub-regional elements. Croydon’s place in the London region and adjacent to the South East of England region is significant and the first part of this section and the map on page 15 describe it. The map should show the location of Biggin Hill Airport both because of its importance to London as a whole and because of its closeness to Croydon, and to match its mention in the adjacent text. The reference to the Outer London Commission in this section is important as a number of their key conclusions are relevant to Croydon and Biggin Hill. page19/para2 Spatial Aims and Objectives The support is welcomed. Croydon Gateway Limited A Place of Opportunity Partnership

Support Chapter 1 of the ‘Core Strategy Initial Report’ Agree - No Action sets out the ‘Spatial Aims and Objectives’ for Croydon.

Croydon Gateway Limited Partnership (“CGLP”) support the provisional draft aims and objectives set out on page 19 of the document, with particular reference to extending the range of business activities and the delivery of sufficient new housing in the Borough. page14/para1 Demographic Factors The comment is noted. Croydon Gateway Limited The document advises that the demographics of Partnership the Borough are changing. The change in Observation demographics needs to be seen as a potential Noted – No Action asset for Croydon and as such, opportunities need to be made available in Croydon to capitalise on this asset in a positive way. There is huge potential to capture the creativity within communities which could help the future regeneration of Croydon’s districts. page17/para2 Drivers for Change The comment is noted. Croydon Gateway Limited The document states that the Croydon economy Partnership is in decline with a loss of 17% of the total Observation number of jobs in the last ten years. This is a Noted – No Action highly significant and alarming loss in the context of the boom that we have been through in the last decade.

The document outlines that the transport capacity of Croydon needs to improve in order to fulfil the growth potential. If Croydon had sufficient infrastructure, the number of jobs should really have grown by some 20% during the last 15 years and not declined to the extent stated in the document. Employment will help the prospects of residents in deprived wards, also brining new investment into the Metropolitan Centre and disposable income which will upgrade the retail and leisure offers.

The excellent transport connection is one of the key benefits of Croydon which is currently focused on East Croydon Station. In terms of prioritising investment, it must follow that this area should be a priority as it is the key decision maker for any employer thinking of locating in Croydon and trying to attract staff.

Once new jobs are attracted then the multiplier effect will be felt throughout the local economy and each commuter to Croydon will be an ambassador which will help to change its image. n/a The places of Croydon – I welcome the inclusion We will seek to relate the Ms Alison of this section, which is in the spirit of spatial thematic options to the places Fairhurst planning. However, as with the place themed of Croydon in future Government Office for sections, how do the options expressed here consultation documents. We London relate to the two strategic options of dispersed will include the scale of new Object growth and concentrated growth? In general, the development in each place Agree – Propose Changes options for change do not give much idea of the and the implications in future implications for the scale of new development in consultations on the Core each place. Also, some of the issues covered Strategy and the Infrastructure within this section does not appear to be Delivery Plan. appropriate for a Core Strategy. page15/para1 The Sub-regional Context The comment is noted. Croydon Gateway Limited One of the main ways to promote the Partnership regeneration of Croydon is to attract jobs and Observation companies. The best way to achieve this is to Noted – No Action support its links to London and be a place where companies can relocate easily, be connected back to central London, but have lower overheads. Due to its excellent transport links, Croydon and the Metropolitan Centre in particular needs to be considered more of a London centric destination that should compete for employment with London villages e.g. Paddington, Canary Wharf, South Bank, Kings Cross.

The document refers to the Borough working with other London Boroughs such as Wandsworth, and Merton and recognising how they will change over the next 15-20 years. CGLP consider that a 15-20 year period to be appropriate in this instance. page15 The sub-regional context – You refer here to Future consultation Ms Alison working with neighbouring boroughs on a documents will provide more Fairhurst number of issues. This section could be detail on major cross- Government Office for strengthened further by setting out any cross- boundary issues. London boundary issues that may arise, for example Observation from any proposed major developments in a Noted – Propose Changes neighbouring borough. page13 Present day context – This sets out a spatial The support is welcomed. It is Ms Alison portrait of the borough and is welcomed. important to set the context for Fairhurst future development in Government Office for Croydon in the Core Strategy. London Support Agree - No Action page11-12 Croydon’s historical context – To make the next It is important to set the Ms Alison consultation document more succinct you may context for future development Fairhurst want to place this section in an annex or in Croydon in the Core Government Office for supporting background document – with the Strategy. We will consider the London appropriate cross-references. most appropriate way of Observation providing this context. Di N Ch page20/questionao2 Given that East Croydon Station is the key The comment is noted. transport hub of the Metropolitan Centre, one of Croydon Gateway Limited the objectives to create ‘A Place of Opportunity’ Partnership should be to attract employment, residential Observation occupiers and a mix of uses. An improvement to Noted – No Action the capacity of the station should be beneficial for the adjoining sites and immediate area such that development comes forward promoting good architecture, mixed uses, public realm, improved streetscapes and pedestrian links. page15/para1 In relation to the Spatial Aims and Objectives, The support is welcomed. Mr Andrew the Airport is particularly supportive of the Walters proposals to develop Croydon as a destination Biggin Hill Airport Limited for business, visitors, conferences, exhibitions Support and hotels, and as a place for developing Agree - No Action opportunities for skills and life chances. We also support the aim of providing new orbital and east-west connections. page20/questionao2 Croydon Metropolitan Centre is identified by the This point will be addressed in Mayor as an ‘Opportunity Area’ for significant the next consultation draft of Croydon Gateway Limited growth for a range of uses, including residential. the Core Strategy but it is not Partnership Therefore, one of the draft aims of the Core considered that this high-level Object Strategy should also be to increase the potential aim is suited for inclusion as a Noted – Propose Changes to make the Metropolitan Centre a desirable and spatial objective. attractive place to live. As such, CGLP consider that the following objective should be added under ‘A Place of Opportunity’:

“Make Croydon an attractive place to live for all sectors of the community.” page16 Page 16 describes the relationship with adjacent Future drafts of the Core Mr Andrew boroughs and, again, the map should show the Strategy will include Biggin Hill Walters location of Biggin Hill Airport as a key facility Airport on relevant maps and Biggin Hill Airport Limited close to Croydon’s boundary. Cross borough in associated text. Object working is particularly supported and reference Agree – Propose Changes can be made back to the Examination in Public of the first London Plan in 2003 where there was a specific recommendation related to the Airport. page20/para1 Spatial Aims and Objectives. We note the The support is welcomed. suggestion that Croydon’s status as an area Devgrove identified for growth creates “A Place of Support Opportunity”. In this context, the Council will Agree - No Action seek to extend the range of business activities, increase the potential for new sectors and develop Croydon as a destination for business. This enhancement in economic activity, added to the demographic profile described at page 14, will inevitably lead to the need to provide more homes. In that context, we support the observation under “A Place to Belong” that a particular objective is to deliver sufficient new housing to provide a choice of accommodation and affordable homes for all local families and single people. page20/questiona01 You acknowledge that as this document is at an The observation is noted. The Ms Alison initial consultation stage, and is ahead of the Core Strategy will provide a Fairhurst publication of your Sustainable Community clear, locally distinctive vision Government Office for Strategy, you have put forward a set of for the borough closely related London provisional aims and objectives for the borough. to the Sustainable Community Observation At the next consultation stage I would expect to Strategy. Noted – Propose Changes see the development of a clear, locally distinctive, vision for the borough covering the plan period, which is at least 15 years from the date of adoption. Planning Policy Statement 12 says that a vision should “be informed by an analysis of the characteristics of the area and its constituent parts and the key issues and challenges facing them. The vision should be in general conformity with the RSS and it should closely relate to any Sustainable Community Strategy for the area.” page20/questionA01- A key sustainability objective for the preparation The comment is noted. The Carmelle Bell A02 of the new Local Development Framework infrastructure needs Thames Water Property should be for new development to be co- associated with the Core Observation ordinated with the infrastructure it demands and Strategy will be considered by Noted – No Action to take into account the capacity of existing the Infrastructure Delivery infrastructure. Paragraph 4.8 of the new PPS12, Plan. 2008 states:

“The core strategy should be supported by evidence of what physical, social and green infrastructure is needed to enable the amount of development proposed for the area, taking account of its type and distribution. This evidence should cover who will provide the infrastructure and when it will be provided. The core strategy should draw on and in parallel influence any strategies and investment plans of the local authority and other organisations.” page15 Biggin Hill Airport plays an important role in The comment is noted. The Mr Andrew serving London as a world city, as well as its importance of Biggin Hill Walters regional, sub regional and local roles. Business Airport to the local economy Biggin Hill Airport Limited aviation is a global industry, providing high will be recognised more Observation quality, discrete and highly focused international explicitly in future drafts of the Noted – No Action transport for business and high wealth Core Strategy. individuals. Biggin Hill is able to provide facilities and services for this market, avoiding the major airports, serving central London and other major centres. Its sub regional roles include providing opportunities for businesses to fly from a nearby airport, facilities for flying training and private flying and providing a range of skilled employment opportunities. Locally it is a key economic asset for the Borough of Bromley and the village of Biggin Hill, and a potential heritage and leisure centre based on its history and current flying activity. page15 Croydon’s views on Biggin Hill Airport were set The comment is noted. Mr Andrew out in its response to the Airport’s draft Master Walters Plan, which was published in May 2005. The Biggin Hill Airport Limited Council supported the proposed long term Observation strategy of the Master Plan, which was to Noted – No Action develop the business aviation activity as well as permitting limited passenger flights to accommodate up to 0.5 million passengers per annum. page15 Regional policy is set out in the London Plan, The comment is noted. Mr Andrew the latest version of which was published in Walters February 2008, which states that national Biggin Hill Airport Limited airports policy applies to all airports in London. Observation The Mayor has begun the process of reviewing Noted – No Action the London Plan, and new versions are likely to be issued for consultation soon. page14/para2 Patterns of Prosperity and Deprivation The comment is noted. Croydon Gateway Limited Historically, in the 1950’s and 1960’s, jobs came Partnership to Croydon because it had contemporary office Observation space, good shopping, good cultural and leisure Noted – No Action facilities and a good stock of housing with a range of affordability.

Today it provides little for those residents of the deprived wards and also the most affluent wards. Croydon Metropolitan Centre therefore needs to provide a focus and opportunity for the entire population of the Borough as an area in which to live, work, shop and visit.

Croydon Metropolitan Centre therefore needs more jobs to address deprivation and better shopping, culture and leisure facilities to attract the wealth from the south of the Borough. At the moment the Centre is failing on both accounts and is generally a place that people do not consider as a place to work or to visit. page15/para1 National airports policy is set out in the 2003 The comment is noted. Mr Andrew White Paper ‘The Future of Air Transport’ and a Walters Progress Report in 2006. For Biggin Hill, Biggin Hill Airport Limited national policy recognises the valuable potential Observation of small airports to serve their local markets and Noted – No Action in particular for business aviation, as well as for flying training and private flying. page15/para1 The Airport is privately owned and operates The comment is noted. Mr Andrew under the terms of a 125 year lease from the Walters London Borough of Bromley. Bromley’s UDP Biggin Hill Airport Limited was adopted in 2006 and its saved policies Observation remain the current statutory local planning Noted – No Action document, although, like Croydon, this will be progressively overtaken by the LDF in the next few years. Bromley’s UDP contains a chapter about Biggin Hill Airport & Environs and seeks to balance the economic benefit and environmental concerns. page15/para1 London Biggin Hill Airport is situated in the The comment is noted. Mr Andrew London Borough of Bromley, but just 2 miles Walters from the boundary of the London Borough of Biggin Hill Airport Limited Croydon at . The Airport is an Observation important facility for the sub region and is Noted – No Action grateful for the opportunity to contribute towards the development of policy of its neighbouring local authority. page20/questionA01 We would also wish to support the proposals for The support is welcomed. Mr Andrew and 2 educational development (Questions ES1 and Walters 2), noting that the Airport is a source of Biggin Hill Airport Limited apprenticeships and skills training, which it is Support looking to enhance. Agree - No Action page20/QuestionA01 Q A01 – Yes, as very general aims and The comment is noted. Mr I.G.M. Hunter objectives. Object Noted – No Action page 18/para2 We agree with page 18 of the Report which A modified growth strategy will states that the community will have to live in a be outlined in the next Devgrove more sustainable manner and deal with issues iteration of the Core Strategy. Support associated with climate change. We have noted Agree – Propose Changes the observation that most of the growth opportunities are concentrated in parts of the Borough, particularly along the A23 corridor, which are most susceptible to flooding. That being the case, we consider that Option for Growth 2 will not deliver the amount of accommodation anticipated pages13-17 Page 14 of the Initial Report refers to the fact The Council will consider that nearly 25% of the Borough’s population is further the arguments for and Devgrove under the age of 18. That age profile suggests against Green Belt and MOL Observation that there will be a considerable local need for amendment in the next Noted – Propose Changes new housing in the period to 2031. We have consultation report for the noted the observation at page 13 of the Report Core Strategy. that over one third of the Borough’s total area is protected green space and is one of the highest proportions in London. The future implications of the Borough’s age profile, in terms of the provision of new housing, are such that part of that protected green space will need to be used to accommodate necessary development. As page 17 of the Report observes, the identification of Croydon as a growth area brings both challenges and opportunities. Developing the homes required for the future population will necessitate land being used more intensively in some parts of the Borough but, in our submission, some limited green belt releases will equally be needed to address that growth agenda. page19/para2/bullet7 School/community facilities – suggested co- The comment is noted. Work Mr Ross Gentry location of facilities and there was a positive is intended to assess the LBC response. It makes sense to allow the interactions between Observation community to utilise existing facilities and to be education and transport Noted – Propose Changes involved in the development of new ones, issues. particularly when they often lay empty on weeknights and at weekends. Existing school facilities should be made more publicly accessible. Those that are accessible to the public should be letting more people know they are. page18/para3 Natural England is pleased to see that The support is welcomed. Mr David Community Cohesion refers to access to parks Hammond and Green spaces and this is welcomed. Natural England Support Agree - No Action Pages19-20 Pages 19 and 20 list the Councils aims and The support is welcomed. Mr David objectives, twenty four in total, which can be Hammond broadly supported by Natural England. Natural Natural England England welcomes and commends schemes Support that promote and encourage sustainable Agree - No Action transport options, including walking and cycling. page20/questionao2 Croydon Metropolitan Centre is identified by the Creating an attractive Mayor as an ‘Opportunity Area’ for significant residential environment is Purespace growth for a range of uses, including residential. important across the borough Object Therefore, one of the draft aims of the Core and not just Croydon Disagree – No Change Strategy should also be to increase the potential Metropolitan Centre. It is to make the Metropolitan Centre a desirable and therefore a spatial objective attractive place to live. As such, Purespace for the whole borough Group consider that an additional objective in including Croydon respect of creating an attractive residential Metropolitan Centre. environment should be included under ‘A Place of Opportunity’: page19/para2 Purespace Group support the provisional draft The support is welcomed. aims and objectives set out on page 19 of the Purespace document, with particular reference to extending Support the range of business activities and the delivery Agree - No Action of sufficient new housing in the Borough. page20/QuestionA02 Q A02 - Not at this time but a Borough-wide The comment is noted. Mr I.G.M. Hunter Environmental Network in expected to come on line in mid-October 2009 which will eventually Observation have the potential to bring even closer Noted – No Action consultation between the Council and residents, using the internet. The organisers of the Croydon Local Development Framework should, I hope, take advantage of the new avenues of dialogue opened up by this Network. page20/para2/bullet6 A Place for Sustainable Living This point will be addressed in the Core Strategy. Croydon Gateway Limited CGLP agree with the objective of raising the Partnership standard of design of new buildings. However, Object there should be emphasis on improving the Agree – Propose Changes pedestrian experience around Croydon through pavement materials, furniture, lighting, signage, and landscape. This can happen regardless of the age of buildings along the streets and not just “new” buildings. page17/para4 The Initial Report understandably contains a The comment is noted. number of references to public transport Devgrove accessibility and Devogrove considers that a Observation highly sustainable development opportunity can Noted – No Action be identified between Kent Gate Way and Lodge Lane at Addington, adjacent to the Addington Village tram stop / bus station. page20/para2/bullet3 Natural England particularly welcome and The support is welcomed. Mr David support the following aims/objectives; -“Raise Hammond the quality of our open spaces and create a Natural England ‘green grid’ across the borough, linked to the Support sub regional framework for walking and cycling Agree - No Action routes”. page14/para1 Devogrove Ltd welcomes the publication of the The comment is noted. Core Strategy Issues and Options Initial Report Devgrove and considers that the consultation document Observation raises a number of important and significant Noted – No Action matters. In particular, the demographic dynamic described at page 14 of the Initial Report will require the formulation of a far-reaching and innovative spatial strategy to implement the growth agenda for the Borough. page20/questionao1 Devogrove agrees with the provisional aims and The comment is noted. Public objectives set out at pages 19 and 20 of the Transport Accessibility Levels Devgrove Initial Report. We would, however, suggest that are one of the considerations Observation the wider implications of Croydon Tramlink underlying the Core Strategy. Noted – No Action should be incorporated, rather than restricting its potential only to its proposed extension. page17/para4 The area is described as having good open The support is welcomed. Mr David space/countryside access but with limited public Hammond transport accessibility. The protection of existing Natural England open spaces is welcomed and supported. Support Natural England also welcomes and commends Agree - No Action schemes that promote and encourage sustainable public transport options, including walking and cycling. page20/para2 CGLP consider that one of the objectives for The comment is noted. sustainable living, should be to encourage the re- Croydon Gateway Limited use of some of the existing buildings for either Partnership less expensive offices or hotels or residential. Observation For example, it is possible that underused older Noted – No Action style buildings of the 1960’s / 70’s architecture could be put in to beneficial use and upgraded to improve the streetscape. page20/para2/bullet6 Natural England particularly welcome and The support is welcomed. Mr David support the following aims/objectives; Hammond “We want to raise the standard of design of new Natural England buildings, streets and public spaces to equal the Support best in London”. Agree - No Action page20/questionAO1 The provisional aims and objectives are worthy. The support is welcomed. Mr Barry Atwood (We particularly support the aim of attracting university facilities to the Metropolitan Centre: Support without this, no serious claim can be made to Agree - No Action Third City status.) page19/para2/bullet3 Education and Skills The support is welcomed. Croydon Gateway Limited CGLP strongly agree that Croydon needs to Partnership invest in education and encourage University Support and other further higher education institutions. Agree - No Action page20/questionAO2 The Council should also include and consider The Core Strategy wording Mr David the provision of new green/open spaces, green will be amended to be more Hammond links corridors and ‘soft landscaping’ as part of proactive. Natural England these aims/objectives – the current wording Object appears reactive and passive. Agree – Propose Changes page7/para4 It is true that “Imagine Croydon” was widely The comment is noted. The Mr I.G.M. Hunter publicised, as the document itself says. formulation of the Core However, there has been little, if any, Strategy (including production Observation subsequent evidence that the Council has pro- of supporting evidence) has Noted – No Action actively encouraged the residents of the followed national policy Borough to pay attention. Apathy and cynicism guidance in the form of towards, not just the current governing regime Planning Policy Statement 12: but its predecessor, has been recognised by Local Spatial Planning. The several Councillors I have spoken to in recent content and format of the Core years. Strategy and Infrastructure Delivery Plan reflects PPS12 (and other Planning Policy Statements), the planning regulations and other guidance/best practice e.g. the Department of Communities and Local Government's "Plan Making Manual", CABE's "Planning for places: delivering good design through core strategies" and the Planning Inspectorates "Local Development Frameworks: Lessons Learnt Examining Development Plan Documents". Consultation has been delivered in line with the borough's Statement of Community Involvement and has been closely aligned with the Local Strateic Partnership's 'Imagine Croydon' project (since December 2008) which sought to establish a long term vision for the borough and act as the touchstone and basis for the Sustainable Community Strategy/Core Strategy. In total over 20,000 people have thus far contributed to the above mentioned documents (including the Core Strategy). page20/para1/bullet2 CGLP consider that in order to encourage The comment is noted. investment in jobs, overall there should be Croydon Gateway Limited increased training and learning opportunities for Partnership young people in the Borough. Observation Noted – No Action page20/para1/bullet2 CGLP agree that the Borough’s residents should The support is welcomed. be highly skilled to provide a local / ‘home Croydon Gateway Limited grown’ workforce. Coupled with the excellent Partnership transport links, currently centred on East Support Croydon Station, this will provide added Agree - No Action incentive for companies to move into the Metropolitan Centre. page20/para2/bullet1 CGLP support and encourage potential station The support is welcomed. improvements and recognise that East Croydon Croydon Gateway Limited Station has the potential to address issues Partnership relating to capacity and improvements to access. Support Agree - No Action 2. Options for Growth Page/Paragraph/ Representation Recommended response Full Name Objective Organisation Nature of Response Officer Recommendation page27/questiong3 Kenley and are essentially The comment is noted. A Mr Barry Atwood adjuncts of Purley to which, for example, many modified development residents look for hypermarket shopping. strategy will be outlined in the Observation Moreover, these districts are close enough to next consultation of the Core Noted – Propose Changes Purley to take advantage of job opportunities Strategy. there if, following traffic improvements, the centre of the town at last begins to thrive. They thus constitute a natural part of the south Croydon corridor and cannot be overlooked in any plan for its growth. Both are served by railway stations affording ready access to London and Central Croydon. Sanderstead is situated away from the flood problems in Purley centre and has available open land along A2022. Kenley is within easy reach of and Caterham thus offering further employment possibilities (eg in businesses on the Godstone Road). page27/questiong3 Additionally, there are of course Kenley, The comment is noted. A Mr Barry Atwood Sanderstead, and Addington. We do modified development not believe that sufficient thought is being given strategy will be outlined in the Observation to their integration into solving the problem of next consultation of the Core Noted – Propose Changes Croydon’s growing population. Strategy. page27/questiong3 Of the southern areas, Coulsdon seems best The comment is noted. Mr Barry Atwood placed to contribute. This district not only has the amenity of the north - south rail and road Observation links, but also enjoys the added advantages of Noted – No Action free land at the old Cane Hill Hospital site adjacent to Coulsdon South Station, a lively shopping centre, employment opportunities on the two existing industrial estates and recent high quality public realm investment in the shape of the by-pass and improvements in the town. page25/para1 I am for dispersed development, expanding and The comment is noted. Jean Apps developing existing communities all over the However a modified borough. This is a more family-friendly option development strategy will be Support than that of concentrating residential housing in outlined in the next Noted – Propose Changes the centres of our major towns. consultation of the Core Strategy. page22/para4 The fourth paragraph on page 22 of the We cannot rely upon the consultation document states that “it makes provision of new infrastructure Homes and Communities sense to concentrate growth in areas of highest in new areas so it is more Agency public transport accessibility”. The HCA sensible to plan for growth in Observation considers that areas which are capable of being areas where infrastructure Noted – No Action made more accessible by public transport already exists. should also be considered for growth. page27/questionG1 The simple choice between a Concentrated A modified development Mr Barry Atwood Growth Corridor and a Dispersed Growth Option strategy will be outlined in the is unhelpful for solving the Borough’s additional next consultation of the Core Object housing needs. Strategy. Agree – Propose Changes page27/questiong3 Situated in the south east of the Borough, The next iteration will consider Mr Barry Atwood Selsdon and Addington are not part of south a modified spatial strategy to Croydon corridor. However, compared with ensure growth is sustainable Observation those districts that are located in it, they are and is likely to feature Noted – Propose Changes better placed to accept new development. They elements of the dispersed still have areas of open land, together with well growth and concentrated established shopping centres, schools and growth options. health facilities. In terms of travel to work, Bromley is accessible by bus, although residents might generally be expected look towards central Croydon. Tramlink directly serves Addington and skirts the edge of the Selsdon. If improvement of the network is to be considered, it would be better directed here and to other areas currently having less good public transport facilities. Given existing train and bus services between Croydon and Purley, a Tramlink extension on the same route is essentially superfluous and would serve only to add to congestion on A235. If the Report’s preference for an unrelieved The next iteration will consider Mr Barry Atwood Concentrated Growth Corridor is realised, Purley a modified spatial strategy to will both lack the advantage of protection from ensure growth is sustainable Observation development promised to other districts (see and is likely to feature Noted – Propose Changes letter: para 21) and could well suffer from the elements of the dispersed disadvantage of a more transient residential gorwth and concentrated character (see letter: para 22). We believe these growth options shortcomings in the proposals support the argument for new family homes to be located at the southern edge of the Borough where there is more room for manoeuvre, that is, there will have to be a much greater resort to Dispersed Growth (see letter: para 25). page24/para1 . I do not see why this has to be more Developers are attracted to Jean Apps "developer-led" than the concentrated growth sites which are easier to option. develop which tend to be Object more dispersed around the Noted – No Action borough hence the Dispersed Growth option is more "developer-led". page27/para2/bullet6 Why could the money that would be spent on The cost of new infrastructure Jean Apps infrastructure and transport in the latter option is high. The level of not be dispersed into various projects over a development in each area in Observation wider area (provided good bus-rail links with the Dispersed Growth option Noted – No Action larger towns was prioritised)? may not be sufficient to fund or support its own infrastructure. The infrastructure needs associated with the Core Strategy will be considered by the Infrastructure Delivery Plan. page22/para2 However, the HCA considers that it would be The designation of specific useful to clarify within this statement the role of sites is not a matter for the Homes and Communities Cane Hill as the only site designated as a Major Core Strategy. It will be Agency Developed Site (MDS) in the Green Belt within considered as part of a future Observation the “saved” Croydon UDP stage of the process. Disagree – No Change page22/para2 The second paragraph on page 22 of the Neither of the growth options consultation document recognises that should presented in this consultation Homes and Communities future growth and development be restricted to restricted development to Agency Town and District Centres alone, this would not town and district centres Observation be sufficient to meet the Council’s housing alone. This paragraph is Noted – No Action targets, and it would be necessary to investigate simply to highlight the the possibility of building on Green Belt land. consequences of doing so. This therefore rightly highlights the importance of planning positively for growth page26/para1 Option 2 is likely to become largely dormitory A modified development Jean Apps housing for young, single commuters and there strategy will be outlined in the is plenty of this type of housing already next consultation of the Core Object Strategy. Agree – Propose Changes Page26 The Option 2 map is not detailed enough to be A Residential Character Peter Williams sure what is really planned for Purley, but my Appraisal and a Borough concern is there is a large red blob covering the Character Appraisal are being Object Centre of Purley and the immediate roads developed to ensure that local Noted – Propose Changes around it. The housing around Purley is sound distinctiveness and the unique and the leafy roads are exactly what gives characteristics of Croydon are Purley its character. Any moves to demolish all considered in future growth these and replace them with blocks of flat would over the plan period. be a detrimental move. One only has to look at Pampesford Road to see how quickly a road full of traditional mixed housing stock can be destroyed and turned into yet another flat alley. Page27/QuestionG2 I also share your current favoured solution for The support is welcomed. Peter Williams providing extra housing, ie Option 2. Support Noted – No Action page27/questiong1 The HCA considers it is important to The comment is noted. acknowledge the guidance within Annex C of Homes and Communities PPG2 in respect of MDSs, which permits the Agency complete or partial redevelopment of MDSs, Observation subject to adherence to certain criteria. It is Noted – No Action therefore important to note that although the Cane Hill site lies within the Green Belt on the Proposals Map that accompanies the “saved” policies of the 2006 UDP, its redevelopment (within certain parameters) is permitted by virtue of the guidance within PPG2 on MDSs, and therefore in the context of reviewing all options for growth, the Cane Hill site represents an important opportunity to significantly contribute to the Borough’s housing targets. Page25/para1/bullet1 On the Negative Features of Dispersed Growth - Concentrated growth would Mr Barry Atwood provide more homes in the • Why should a Dispersed Growth strategy not borough therefore contributing Observation be sufficient to meet housing needs, if minds are more towards meeting the Noted – No Action properly applied to the problem? need for homes. The need for new homes is considered at a borough-wide level rather than in the 16 places. page27/para1/bullet6 • The centre of Purley is of course identified on The comment is noted. The Mr Barry Atwood the Environment Agency map as at risk of infrastructure needs flooding. From long experience, there is indeed associated with the Core Observation every reason to believe that it will in the future Strategy will be considered by Noted – No Action again be inundated by the Bourne and that the Infrastructure Delivery Concentrated Growth will aggravate this risk Plan. unless substantial capital investment is devoted to a solution. page27/para1/bullet3 Why should there be “potential for increased Concentrated housing growth Mr Barry Atwood retail offer” in Purley unless the traffic problems in and around district centres are alleviated? will lead to increased demand Observation for comparison and Noted – No Action convenience goods in those centres whilst reducing the need to travel. The infrastructure needs associated with the Core Strategy will be considered by the Infrastructure Delivery Plan. page27/questionG1 As identified in our comments under growth The comment is noted. A Mr Austin Mackie options above, the role of smaller dispersed modified development Austin Mackie Associates developments can be significant in supporting strategy will be outlined in the Ltd local communities, enhancing the viability of next consultation of the Core Support local centres and mending poor quality urban Strategy. Noted – Propose Changes fabric. In contrast, large scale concentrated growth corridors could threaten the longer-term viability and sustainability of local neighbourhoods and possess significant risk in terms of implementation. page27/para1/bullet2 Given the lack of available land in Purley why is Concentrated growth would Mr Barry Atwood it “more likely that new housing will be sufficient provide more homes in the to meet identified needs”? borough therefore contributing Observation more towards meeting the Noted – No Action need for homes. The need for new homes is considered at a borough-wide level rather than in the 16 places. pages24-27 In the summary of Options for Growth on pages The comment is noted. A Mr Barry Atwood 24 to 27 of the Initial Report, we believe that a modified development superficial, tendentious and inadequate picture strategy will be outlined in the Object is presented by the stark contrast between next consultation of the Core Noted – Propose Changes “Dispersed Growth: Bad” and “Concentrated Strategy. Growth Corridor: Good”. Numerous questions arise that throw doubt on the validity of Report’s unqualified preference for Concentrated Growth. These are set out seriatim in the following paragraphs. page27/para1/bullet4 Even if the traffic problems are ameliorated, will Concentrated growth is more Mr Barry Atwood there really be “increased local job opportunities likely to lead to increased local and a wider range of different jobs” in Purley? job opportunities and a wider Observation Local employment is inevitably in the main range of different jobs in the Noted – No Action limited to the retail sector. There are some borough as a whole than offices but there is no room, such as exists at dispersed growth. Cane Hill, for the sort of employment that is really needed (eg a high quality industrial park). page23/para1 The first paragraph on page 23 of the The comment is noted. The consultation document states, inter alia, that intention was to explain the Homes and Communities “When we take into account the large proportion rationale underlying the two Agency of green space that is protected from growth options presented in Object development (one third of Croydon’s total land this consultation. However as Noted – No Action area) and our desire to protect it, the spatial part of this consultation the options are limited”. This statement is not Council was considering the entirely consistent with later text within the implications of all spatial “Green Belt and MOL” section of the options. consultation document (page 68), which refers to the Council currently considering whether to amend existing Green Belt boundaries, or to de- designate existing sites. page27/para1/bullet6 Why should increased development in Purley Concentrated growth would Mr Barry Atwood lead to a “much improved, quality public realm, provide more opportunity to ... with opportunities for sustainable drainage (to invest in public realm Observation alleviate flooding), wildlife corridors and cycle improvements as there would Noted – No Action highways”? Every indication is that the reverse be more opportunity to will be true. concentrate spending on smaller geographical areas. page26/para1 TfL supports the ‘concentrated growth’ corridor The comment is noted. Mr Michael option, which would enable greater investment However a modified Mulhern in transport infrastructure. development strategy will be Greater London Authority outlined in the next Support consultation of the Core Agree – Propose Changes Strategy. Page25/para2/bullet2 Why should investor interest be weakened by a Dispersed growth will weaken Mr Barry Atwood Dispersed Growth strategy? And what reliable developer interest in Croydon investor interest would there be in Purley Metropolitan Centre, Purley Observation anyway, unless the traffic situation is improved? and Coulsdon as there is not Noted – No Action unlimited developer interest in the borough and sites in easier to develop locations would be developed in preference. Development will only take place if the necessary infrastructure is provided with it. The infrastructure needs associated with the Core Strategy will be considered by the Infrastructure Delivery Plan. page27/para1/bullet1 On the Positive Features of a Concentrated A modified development Mr Barry Atwood Growth Corridor - strategy will be outlined in the next consultation of the Core Observation • What advantage is there to Purley that there Strategy. Noted – Propose Changes should be more protection from development and, possibly, greater enhancement to the character of distinct residential areas “elsewhere in the Borough”? Does this not conflict with your professed vision of Purley as a “Place to Belong”? page27/questiong3 Is not the pressure on ‘backland’ development The comment is noted. A Mr Barry Atwood even more applicable to the Concentrated modified development Growth Option that is proposed for Purley? strategy will be outlined in the Observation next consultation of the Core Noted – Propose Changes Strategy. Page25/para2/bullet5 Is not the increased “pressure on local road Dispersed growth would result Mr Barry Atwood networks and amenities such as parking” even in increased pressure on local more likely to result from the Concentrated road networks and amenities Observation Growth Option that is proposed for Purley? such as parking without being Noted – No Action able to support improvements. Development will only take place if the necessary infrastructure is provided with it. The infrastructure needs associated with the Core Strategy will be considered by the Infrastructure Delivery Plan. page25/para2/bullet5 What “investment in high quality public realm” Dispersed growth would not Mr Barry Atwood would result at Purley from the Concentrated result in an investment in a Growth Option? high quality public realm in Observation Purley as there would not be Noted – No Action enough development to support the level of investment. Concentrated growth would provide more opportunity to do so as there would be more opportunity to concentrate spending on smaller geographical areas. Page25 On the Positive Features of Dispersed Growth - Dispersed growth allows Mr Barry Atwood market forces to drive • Why cannot Dispersed Growth be managed by development. It is presented Observation steering? as the opposite of Noted – No Action concentrated growth where the Council and community set the agenda for development. page27/para2/bullet4 And, on the Negative Features of a The comment is noted. A Mr Barry Atwood Concentrated Growth Corridor - modified development strategy will be outlined in the Observation • Major growth in a Concentrated Growth next consultation of the Core Noted – Propose Changes Corridor could well lead to a more transient Strategy. residential character. Why should Purley aspire to this? Is this not an admission that Purley as a “Place to Belong” envisioned by the Report would in fact finally be destroyed by its designation as a Concentrated Growth area? page26/para2 Even if improved, the traffic problem deriving The issue of car parking will Mr Barry Atwood from the A22/23 junction will still exist in Purley. be addressed through a Unless the amenity of the neighbourhood is to Transport Strategy and Observation be irretrievably damaged, as we have pointed considered as part of Site Noted – No Action out in paragraphs 10 and 16 above, the only Allocations and/or realistic means of increasing accommodation is Development Management to pursue the existing policy of redevelopment Development Plan Documents. along A22, A23 and A2022 and in the centre of the town. Yet this is no easy option because - whether we like it or not - the new residents will aspire to cars and reasonable provision should be made for them if the problem of existing on- street parking is not to be intensified. page22/para4 It is important also to note that the transport The comment is noted. Mr Barry Atwood advantages of the town apply only to north - south travel. There is no east - west rail line and Observation the roads in those directions are crowded at Noted – No Action peak hours. Page27/para2/Questio Therefore, locations for growth ought to be much Your comment is noted. Mr John Escott nG3 more specifically related in a sophisticated Robinson Escott Planning manner to a matrix including the nature and form Observation of development and accessibility levels rather Noted – No Action than the simplistic alternatives that are set out in the consultation paper. I acknowledge that infrastructure considerations are important but there is no reason why these cannot also be factored into a more realistic model. Page27/para2/Questio It is important to understand that the two options The need for family housing Mr John Escott nG3 for growth are not mutually exclusive, nor should will be considered alongside a Robinson Escott Planning they be. A balanced approach needs to be taken modified growth strategy to be Object which matches the type of development for set out in the next iteration of Agree – Propose Changes which there is a need with the appropriate the Core Strategy. location for such development. Thus, whilst it is clearly desirable for development to take place in those areas that are accessible and sustainable, and this would generally speaking favour growth in Croydon Metropolitan Centre and along the A23 transport corridor, it needs also to be recognised that such locations may be inappropriate, for example, for the provision of family housing and that there are other areas around the Borough that have accessibility levels that are perfectly acceptable for such development. page27/questiong1 At first sight the Concentrated Growth Corridor The comment is noted. The Mr Barry Atwood (Option 2) might have appeared the best infrastructure needs solution to accommodating the increase in associated with the Core Object Croydon’s population because of the main rail Strategy will be considered by Noted – No Action and road arteries out of the Borough along the the Infrastructure Delivery “A23 corridor” via Purley. While this must be a Plan. relevant factor and Purley should be expected to contribute, it is not in practice well suited to accept the scale of growth envisaged. Most of the traffic passing through the town is not local. It is on its way to or from other parts of London. To this adverse situation, regrettable Council planning decisions have over the years added (1) heavy lorries rat running on Purley’s suburban roads to and from Day Aggregates’ yard and (2) a hypermarket which naturally attracts customers from a wide area, while at the same time, (3) denying the town necessary public and private car parking. Looked at from this point of view, Purley is already making a disproportionately large contribution to perceived public needs. Nor does it follow from the environmental problems progressively wished on Purley residents that they are complacent about the situation, or that it is reasonable aggravate the problems still further. page26/para1 We do not consider that a strategy that relies There are large Mr Austin Mackie upon large concentrations of housing in growth concentrations of Austin Mackie Associates areas can necessarily generate an immediate development sites in Croydon Ltd and constant supply of housing, nor maintain an Metropolitan Centre and other Object appropriate range of housing types and variety district centres that will help to Disagree – No Change of locations that provides a robust portfolio of maintain a range of housing sites. types in the borough. It is agreed that there are development opportunities outside of the growth corridor so a modified development strategy will be outlined in the next consultation of the Core Strategy. page25/para1 We support measures to decrease travel as a The comment is noted. Mr Austin Mackie whole and consider that dispersed growth is a However a modified Austin Mackie Associates key opportunity to achieve more sustainable development strategy will be Ltd patterns. outlined in the next Support consultation of the Core Noted – Propose Changes Strategy. page27/questiong3 The available sites are also generally suitable The comment is noted. A Mr Barry Atwood only for flats for commuters and - to an extent - modified development retired people. Space for further family homes is strategy will be outlined in the Observation lacking, there being, in any case, a shortage of next consultation of the Core Noted – Propose Changes nearby school accommodation. All in all, this Strategy. suggests that much of Croydon’s need for new housing will realistically have to be met in the districts at the southern edge of the Borough where there is more room for manoeuvre, that is, there will have to be a much greater resort to Dispersed Growth. Croydon Core Strategy: Options for Growth: a compromise

If traffic improvements are made, Purley should stand some chance of playing its part and absorbing some further apartment development. However, dispersal to other southern districts will also be necessary. The historic and architectural character of dwellings in Purley is superior to most of those in these other districts. Moreover, Purley is neither well provided with LEA school accommodation, nor well suited for new family houses. Better to locate them away from its major arterial roads and near the green belt. So far as some of the other southern districts may be relatively isolated, it should evidently be a major priority to extend and improve the public transport links. page27/para1/bullet10 What evidence have you that higher densities of A modified development Mr Barry Atwood living in Purley would reduce reliance on private strategy will be outlined in the cars? Even improvements in the shops would next consultation of the Core Observation provide limited employment opportunities. As Strategy. Public transport in Noted – Propose Changes now, few residents will be able work in the Purley and orbital movements immediate vicinity and the relatively good public will be considered in a future transport facilities will continue to attract only Transport Strategy for the those travelling to Central London and Croydon. borough. Public transport does not afford good east-west travel through Purley (consider, for example, the daily congestion on the road eastwards through Sanderstead and Selsdon) and many will also continue to use their cars to reach their work via M25. page27/para1/bullet9 What “transport improvements” are needed The comment is noted. The Mr Barry Atwood along the A23 corridor? Is not the primary need infrastructure needs for lateral routes across the Borough and associated with the Core Observation between central Croydon and the south eastern Strategy will be considered by Noted – No Action districts? the Infrastructure Delivery Plan. page27/questionG3 Overall we believe that there needs to be a The comment is noted. A Mr Austin Mackie balance between the two growth strategies modified development Austin Mackie Associates suggested. Yes opportunities should be taken to strategy will be outlined in the Ltd optimise town centres and regeneration areas next consultation of the Core Observation for appropriate development, but equally, the Strategy. Agree – Propose Changes ability of dispersed growth to contribute to neighbourhood enhancement should not be denied. Such opportunities clearly exist along public transport routes and in areas in need of environmental enhancement. page27/questionG3 A concentrated growth corridor scenario, without The comment is noted. A Mr Austin Mackie a balanced approach to other locations, risks modified development Austin Mackie Associates denying significant neighbourhood level strategy will be outlined in the Ltd schemes that are capable of making a next consultation of the Core Observation significant contribution to overall borough targets Strategy. Noted – Propose Changes and providing local enhancement opportunities and meeting local needs. page27/questionG1 Permitting appropriate dispersed development The comment is noted. A Mr Austin Mackie will ensure that the best use is made of under- modified development Austin Mackie Associates utilised land, whilst contributing to community strategy will be outlined in the Ltd vitality; for example, by allowing local growth to next consultation of the Core Support support neighbourhood centres and create more Strategy. Noted – Propose Changes sustainable patterns of living. page27/questionG1 The ‘concentrated’ approach risks making The comment is noted. A Mr Austin Mackie delivery targets such as housing vulnerable to modified development Austin Mackie Associates an ‘all eggs in one basket’ scenario that is highly strategy will be outlined in the Ltd vulnerable to volatile market forces. next consultation of the Core Object Strategy. Noted – Propose Changes page26/para2 Where in Purley would it be proposed to locate The comment is noted. The Mr Barry Atwood the additional school places - and indeed infrastructure needs additional medical etc. facilities - that would be associated with the Core Observation needed in response to Concentrated Growth Strategy will be considered by Noted – No Action there? the Infrastructure Delivery Plan. page22/para6 The time required to provide such water and The comment is noted and Carmelle Bell waste water infrastructure should not be this is understood. Thames Water Property underestimated. Where the infrastructure is not Observation available we may require an 18-month to three- Noted – No Action year lead in time for provision of extra water/sewerage capacity. If any large engineering works are needed to upgrade infrastructure the lead in time could be up to five years. Implementing new technologies and the construction of new treatment works could take up to ten years page24/para1 Should Croydon Council decide to follow the The comment is noted. A Mr Michael ‘dispersed growth’ option, a policy should be modified development Mulhern implemented to allow for a cumulating/pooling strategy will be outlined in the Greater London Authority mechanism for contributions in order to support next consultation of the Core Observation necessary investments. Strategy. The Council will Noted – Propose Changes investigate a tariff based approach to pool contributions to support necessary investments. page26/para1 Purespace Group consider that by focussing The comment is noted. development within the Centre and along a However a modified Purespace ‘growth corridor’, gives the potential to meet the development strategy will be Support demand for new homes at appropriate high outlined in the next Noted – Propose Changes densities of living, and also increased retail and consultation of the Core job opportunities within this area. For the above Strategy. reasons, Purespace Group prefer option 2 – ‘A Concentrated Growth Corridor’, so long as this is focussed on areas well served by public transport spreading out from the Metropolitan Centre. page46/QuestionH1 Q H1 – Subject to comments, yes. Comment is noted. Mr I.G.M. Hunter

Observation Noted – No Action page27/questionG3 Q G 3 – Yes, apart from the points made above, A modified development Mr I.G.M. Hunter the solution lies in amalgamating the best and strategy will incorporate most sensible elements of both options thus elements of both dispersed Observation mitigating many, if not all, the perceived and concentrated growth, and Agree – Propose Changes negative elements of both. will be set out in the next iteration of the Core Strategy. n/a The changing urban environment will require The comment is noted. The Ms Ann changes to how the borough will be policed and infrastructure needs Burroughs this should be considered when defining the associated with the Core Metropolitan Police Options for Growth. Strategy will be considered by Observation the Infrastructure Delivery Noted – No Action Plan. n/a All regeneration and development will have an The comment is noted. The Ms Ann impact on community safety. Strategic planning infrastructure needs Burroughs and partnership working to reduce these impacts associated with the Core Metropolitan Police is important. Strategy will be considered by Observation the Infrastructure Delivery Noted – No Action Plan. page24/para1 Option 1 – ‘Dispersed Growth’, is described in The comment is noted. the report as development which is dispersed However a modified Purespace across the whole Borough. This option makes development strategy will be Object the most use of opportunity sites and is a outlined in the next Agree – Propose Changes developer-led, opportunistic approach. The consultation of the Core document considers, however, that this Strategy. approach may weaken investor interest and result in a decline within the Metropolitan Centre and will not be sufficient to meet housing needs in the Borough. Purespace Group agree with this notion and considers that the ‘Dispersed Growth’ option would be detrimental to the objective of focussing growth within the Metropolitan Centre as set out in national, regional and local planning policy. This approach would not meet the guiding principles of development, as set out in PPS1, PPS3 or PPS6 whereby development should be focussed towards areas of high transport accessibility within town centres. page22/para6 Thames Water’s five year business plan ‘Our The comment is noted. The Carmelle Bell Plans for Water’ incorporates plans for water infrastructure needs Thames Water Property and wastewater infrastructure to support growth. associated with the Core Observation We base our investment programmes on Strategy will be considered by Noted – No Action development plan allocations which form the the Infrastructure Delivery clearest picture of the future shape of the Plan which will be developed community. In addition the business plan also alongside the Core Strategy. includes proposals to provide infrastructure in order to comply with new consents and obligations such as environmental quality improvements; enhancing service through the reduction in the number of properties at risk of sewer flooding; and enhancing service through the reduction of odour at sewage treatment works. Some infrastructure improvements can be undertaken under permitted development rights while other improvements require the submission of formal planning applications. page26/para1 However, it should be noted that areas of high The comment is noted. The public accessibility are not only confined to sites designation of sites is not a Purespace within the Metropolitan Centre. Some matter for the Core Strategy. Observation redevelopment sites, such as the site at Derby Noted – No Action Road / Clarendon Road, within close proximity to , whilst technically outside the Metropolitan Centre boundary has excellent access to public transport and so is suitable for high density redevelopment to assist in the growth of the Borough. page27/questiong3 Provision should be made for the housing needs This will be included in the Mr Nafi Djemil of disabled people so that they can live next consultation draft of the independently near their families Core Strategy. Observation Agree – Propose Changes page27/questionG3 Option 3 a combination of both The comment is noted. A Mr Nafi Djemil modified development strategy will be outlined in the Observation next consultation of the Core Noted – Propose Changes Strategy. page27/questionG2 The Issues and Options for ‘growth’ in Croydon The comment is noted. center around two themes – dispersed growth or However a modified BRB (Residuary) Ltd concentrated growth. BRB (Residuary) Ltd development strategy will be Support would support the option for concentrated outlined in the next Noted – Propose Changes growth, especially in and around Croydon consultation of the Core Metropolitan Centre. Strategy. page27/para1 The positive aspects of this concentrated growth The comment is noted. pattern would be more supported by National However a modified BRB (Residuary) Ltd and Regional policy, and it would also be a more development strategy will be Support sustainable option. outlined in the next Noted – Propose Changes consultation of the Core Strategy. page27/questions G1, This section (What is Growth?) outlines that The comment is noted. The 2 & 3 Croydon may need in excess of 19,000 new infrastructure needs Metropolitan Police homes by 2031. This potential large scale associated with the Core Authority development within the Borough may increase Strategy will be considered by Observation pressure on policing facilities in the area. Mindful the Infrastructure Delivery Noted – No Action of London Plan Policy 3A.18 and in order that Plan which will be developed the emerging policy is consistent with this (as alongside the Core Strategy. required by PPS12), it is necessary to ensure that the impact of large-scale development upon policing is mitigated within the revised Core Strategy. Accordingly, and whilst the MPA do not have a preference for either particular growth option, we make the following recommendation. Recommendation: In response to questions G1, 2 & 3 it is requested that the Borough should ensure that proposed development which gives rise to need for additional social infrastructure & community facilities (including Policing) will be mitigated through the use of planning obligations. page26/para1 At the Purley Consultation meeting, between 10 It was not intended to set the Mr I.G.M. Hunter residents and Croydon Corporation options "in stone". representatives on 10th September 2009, much Concentrated growth is Object emphasis was placed upon the desirability of suggested as one possible Agree – Propose Changes “Concentrated Growth” corridor even though the option for development for paper offered two alternatives; one being a consultation. Following this “Dispersed Growth” , the other being whatever consultation a modified the residents decided. The paper itself (page 23) development strategy will be offered “Concentrated Growth” because of outlined in the next constraints made by green belt and capacity of consultation draft of the Core existing transport and other infrastructures. In Strategy. setting such considerations more or less “in stone” the Council is not only limiting its own forward thinking but seeking to focus the ideas and suggestions of residents towards such an end. This is wrong : If the creation of a viable, generally agreed (not just by the Council, TfL, and the business community) Core Strategy, is to be the result of this iteration then flexible, even radical, thinking on the lines espoused by Will Alsopp have to be taken into account. The new Core should not be constrained. Those responsible for the existing transport and other infrastructure, including even the green belt should be expected to provide options for change, in conjunction with Croydon (and all other Boroughs). page22/para6 The water companies’ investment programmes The comment is noted. The Carmelle Bell are based on a 5 year cycle known as the Asset Council will enter into a Thames Water Property Management Plan (AMP) process. We are dialogue with Thames Water Observation currently in the AMP4 period which runs from 1st to ensure that an appropriate Noted – No Action April 2005 to 31st March 2010. AMP5 will cover development strategy is the period from 1st April 2010 to 31st March proposed. Thames Water is 2015 and we have submitted our business plan required to take Croydon's to OFWAT for approval by the end of 2009. development plan into account AMP4 & 5 will not therefore cover the whole LDF when preparing its Asset period and make it difficult to set out Management Plan. infrastructure requirements for the LDF period. page24/para2 Option 1 – ‘Dispersed Growth’, is described in A modified development the report as development which is dispersed strategy will be outlined in the Croydon Gateway Limited across the whole Borough. This option makes next consultation of the Core Partnership the most use of opportunity sites and is a Strategy. Observation developer-led, opportunistic approach. The Agree – Propose Changes document considers, however, that this approach may weaken investor interest and result in a decline within the CMC and will not be sufficient to meet housing needs in the Borough. CGLP agree with this notion and considers that the ‘Dispersed Growth’ option would be detrimental to the objective of focussing growth within the Metropolitan Centre as set out in national, regional and local planning policy. page26/para2 Option 2 - You state here that the scale of Officers have been in Ms Alison growth, particularly in the Croydon Metropolitan discussion with key Fairhurst Centre, is dependent on the provision of key infrastructure providers, Government Office for transport infrastructure. What work have you Network Rail and Transport London undertaken with key infrastructure providers, in for London through the Observation particular, Network Rail and Transport for existing station working group Noted – No Action London, in determining whether this is a realistic and through emerging projects option to take forward in the development of the such as the East Croydon and Core Strategy for your borough? Wellesley Road masterplans page23/para4 I welcome the statement in the final paragraph Proposed phasing of Ms Alison of this section which says that the next iteration development will be included Fairhurst of the Core Strategy will establish the location, within the next consultation Government Office for scale, form and type of development appropriate draft of the Core Strategy. London for the levels of growth expected. To make this Observation more robust you may also want to include Agree – Propose Changes proposed phasing of development. page27/questionG1 It is assumed that the options for growth The comment is noted. A Ms Alison presented in section 2 are options for a spatial modified development Fairhurst strategy for the borough. Is the first option strategy will be outlined in the Government Office for (dispersed growth) realistic in terms of the next consultation of the Core London London Plan, with the policies for Croydon as an Strategy. Observation Opportunity Area and New Addington as an Noted – Propose Changes Area for Regeneration? page23/para1 What is Growth: The study that outlines that Ms Alison the need for new homes in the Fairhurst - The first paragraph on page 23 states that borough is our Local Housing Government Office for studies have indicated that your borough may Market Assessment (2008). London need in excess of 19,000 new homes up to The reference to the joint Observation 2031. I would be interested to hear what these GOL/GLA statement is noted. Noted – No Action studies are. May I also draw your attention to paragraph 6 of the joint statement issued by GOL and the GLA in March 2008 – ‘Addressing PPS3 requirements for a 15-year housing land supply (Interim Approach)’ which states that “for boroughs to demonstrate that they have identified a 15 year land supply in terms of the objectives of PPS3 and in the distinct circumstances of London, they should roll forward their annual London Plan minimum ten year housing targets (2007/8 – 16/17) to cover the required 15 year period”. page23 Minerva would welcome early discussion on the The comment is noted. Retail location, scale, form and type of development for policy will be developed Minerva the levels of growth expected as indicated on further in future iterations of Observation page 23 of the Issues & Options document and the Core Strategy. Noted – Propose Changes would in particular wish to engage with the Council in progressing thoughts as to how an enhanced and improved retail offer might be brought forward in the Metropolitan Centre. page27/questiong3 We further believe that an option that suggests The comment is noted. the provision of new housing sufficient to meet Minerva identified needs and to bring about a much Observation improved quality public realm, is one that must Agree - No Action be right for the town centre. page26/para1 Option 2 - A ‘Concentrated Growth Corridor’ The comment is noted. focuses new housing and commercial However a modified Purespace development within Croydon Metropolitan development strategy will be Support Centre and the transport corridor running north- outlined in the next Noted – Propose Changes south though the Borough. As such, this will consultation of the Core meet the objectives set out in National Planning Strategy. Guidance in PPS1, PPS3 and PPS6 and the London Plan by locating development in town centres and in areas well served by public transport. Again, it should be noted that areas outside the Centre and well served by public transport are suitable for new housing and mixed use development. In this way, a concentrated area of growth within the Centre will also spread to areas immediately and adjoining the Centre. Purespace Group consider that by focussing development within the Centre and along a ‘growth corridor’, gives the potential to meet the demand for new homes at appropriate high densities of living, and also increased retail and job opportunities within this area. For the above reasons, Purespace Group prefer option 2 – ‘A Concentrated Growth Corridor’, so long as this is focussed on areas well served by public transport spreading out from the Metropolitan Centre. page22/para3 'Concentrated Growth’ The comment is noted. However a modified Croydon Gateway Limited This chapter sets out the strategy for development strategy will be Partnership accommodating future growth within Croydon outlined in the next Support and suggests two options – ‘Dispersed Growth’ consultation of the Core Noted – Propose Changes or ‘A Concentrated Growth Corridor’. Strategy.

The draft report highlights that the Mayor has designated Croydon Metropolitan Centre (“CMC”) as an ‘Opportunity Area’ which can accommodate significant growth. As such, CGLP support the notion that future growth should be concentrated in areas of highest public accessibility, with the Metropolitan Centre at its core. page23/para1 LFB note that the Council has identified a need The comment is noted. The to provide approximately 19,000 new homes in design of new developments London Fire and the borough before 2031. Although the LFB is not a matter for the Core Emergency Planning have no objection to this growth, it is important Strategy. Authority that the Council carries out suitable consultation Observation with the LFB, along with the other emergency Noted – No Action services, for any proposed large scale developments. This is important to ensure that emergency access through new developments is carefully designed, and the emergency services can monitor future growth in the borough to ensure that the service they provide is sufficient. In this regard, the LFB should be included as a statutory consultee for large scale developments within the borough. page24/para1 CGLP therefore consider that a ‘dispersed A modified development growth’ approach in the Borough would not meet strategy will be outlined in the Croydon Gateway Limited the guiding principles of development, as set out next consultation of the Core Partnership in PPS1, PPS3 or PPS6 whereby development Strategy. Object should be focussed towards areas of high Agree – Propose Changes transport accessibility within town centres. A ‘Dispersed Growth’ approach will not provide the ‘motor’ for regeneration in the CMC and may mean that the CMC shows no growth and may even decline. For these reasons, CGLP would not support the ‘Dispersed Growth’ option. page26/para1 By focussing development within the CMC and The comment is noted. along a ‘growth corridor’, gives the potential to However a modified Croydon Gateway Limited meet the demand for new homes at appropriate development strategy will be Partnership high densities of living, and also increased retail outlined in the next Observation and job opportunities within this area. consultation of the Core Noted – Propose Changes Strategy. page27/para1 The creation of a ‘Concentrated Growth The comment is noted. Corridor’ will meet the objectives set out in However a modified Croydon Gateway Limited National Planning Guidance in PPS1, PPS3 and development strategy will be Partnership PPS6 and the London Plan by locating outlined in the next Support development in town centres and in areas well consultation of the Core Noted – Propose Changes served by public transport. Strategy. page26/para1 Minerva firmly believes that of the two options The comment is noted. suggested, namely the dispersed option and the However a modified Minerva concentrated option, the positive features of a development strategy will be Support concentrated growth corridor significantly outlined in the next Noted – Propose Changes outweigh the negative implications. Such an consultation of the Core approach would we believe be entirely Strategy. consistent with established planning policy guidance at the national level that seeks to focus major developments in town centre locations that are well served by public transport. This will also provide the opportunity of delivering the strategic aspirations of an integrated approach for the Croydon Opportunity Area as set out in the London Plan. page27/questionG2 Minerva firmly believes that of the two options The comment is noted. suggested, namely the dispersed option and the However a modified Minerva concentrated option, the positive features of a development strategy will be Observation concentrated growth corridor significantly outlined in the next Noted – Propose Changes outweigh the negative implications. We believe consultation of the Core that the concentrated growth corridor option is Strategy. one that offers the potential to effect a step change in bringing about Croydon Council’s long held aspirations for growth in and improvements to the quality of the town centre. page26/para1 This chapter sets out the strategy for The comment is noted. accommodating future growth within Croydon However a modified Purespace and suggests two options – ‘Dispersed Growth’ development strategy will be Support or ‘A Concentrated Growth Corridor’. The draft outlined in the next Noted – Propose Changes report highlights that the Mayor has designated consultation of the Core Croydon Metropolitan Centre as an ‘Opportunity Strategy. Area’ which can accommodate significant growth. As such, Purespace support the notion that future growth should be concentrated in areas of highest public accessibility. page24/para1 A concentrated growth corridor will we believe The comment is noted. also optimise the delivery of development that However a modified Minerva can offer a more sustainable and energy development strategy will be Support efficient future for the Metropolitan Centre and outlined in the next Noted – Propose Changes the wider Croydon area. consultation of the Core Strategy. Page27/QuestionG3 15. The DRLP housing targets are lower than The comment is noted, but the Mr David Walker the current London Plan. However, DRLP obseervation is regarding the Crystal Palace Triangle achievement of housing targets continues to rely Draft Replacement London Planning Group not only on identified sites but also on sites as Plan. Observation yet unidentified, so-called “windfall” sites. It is Noted – No Action these sites, squeezing more accommodation into back gardens, infilling between properties, demolishing large family houses and replacing them with flats, taking sites previously in other uses – school grounds, hospitals, etc – that create housing stress, with more people living in the area but fewer facilities for them. page27/questionG2 Your proposal, Option 2, to plan future The comment is noted. The Mr Bill Tubb development along the A23 corridor appears density and height of sound but I hope these will be sensibly fitted into development suggested in the Observation the right areas with some safeguards on storey Core Strategy and subsequent Noted – No Action height and size of new buildings. DPDs will be influenced by the Residential Character Appraisals. pg 24 7. Concern about Option 1 – dispersed growth – Comment noted. A modified Marie Norfield focuses on the greater opportunity it would allow development strategy will be Scot's Estate Residents for development of industrial buildings in considered for a subsequent Assocaition residential areas. We would not be in favour of iteration of the Core Strategy. Object this. Noted – Propose Changes pg 26 G2 we would on balance favour Option 2: for growth The comment is noted. A Marie Norfield concentrated along the London Road. modified development Scot's Estate Residents strategy will be considered for Assocaition a subsequent iteration of the Support Core Strategy. Noted – Propose Changes page27/questiong3 New Addington in particular is isolated, with no The comment is noted Beverley job opportunities, leisure facilities or choice of although there is evidence to Holdsworth schools. The only people who go there live suggest the contrary. there, there is hardly any other reason to visit. Beverley The area has high numbers of people in the Holdsworth NEET category and there are high levels of Department for adult crime and anti social behaviour. services and housing Observation Disagree – No Change page27/questiong3 I think real investment should be diverted to New The location of new homes Beverley Addington and North borough areas. These are will be informed by a Strategic Holdsworth the 2 areas that are the poorest in terms of Housing Land Availaiblity housing, streetscene and leisure amenity. Assessment. Provision of Beverley leisure facilities in the borough Holdsworth will be informed by an Open Department for adult Space and Indoor and services and housing Outdoor Leisure Study. A Observation Supplementary Planning Noted – No Action Document on Public Realm will be developed to support the Core Strategy. page27/questiong1 I unfortunately don’t agree with either of your 2 A modified development Beverley growth options. strategy will be outlined in the Holdsworth next consultation of the Core Strategy. Beverley Holdsworth Department for adult services and housing Object Agree – Propose Changes page25 Dispersed growth Positive features - Why will The point is a general one, Mr I.G.M. Hunter it be necessary to allow market forces to drive which recognises that going development - particularly now that additional with market forces requires Observation flexibility and powers are available to the Council fewer resources. It is does not Disagree – No Change via the Sustainable Communities Act 2007 and state that it will be necessary the, shortly to be launched, Environmental to do so. Network? Page27/QuestionG3 16. Similarly with employment growth. The The comment is noted. Mr David Walker current economic downturn may last another two Crystal Palace Triangle or three years, and there will be cyclical Planning Group fluctuations, but the longer term forecast is an Observation increase in London’s employment. However, Noted – No Action Croydon, with Lambeth, are the only south London boroughs where employment decline is forecast in the Mayor’s economic strategy. With Croydon the largest metropolitan town centre and one of the capital’s two strategic office centres outside central London, a continued growth in business services and further dwindling of manufacturing, the prospects for employment growth in Croydon is in the borough’s town centres. Page27/QuestionG3 Allow for future residential growth in the Disagree. The council wishes Mr Ibo Djemil suburbia parts of Croydon by actively to protect the open character encouraging the development of residential of large gardens where they Object gardens and back lands. are an important part of the Disagree – No Change character. A borough character appraisal will be prepared in order to assess the important features of the borough's constituents parts. Page27/QuestionG2 14. The Core Strategy sets out options for The comment is noted. Mr David Walker locating this growth, based either on opportunity Crystal Palace Triangle sites for dispersed growth limited by existing Planning Group infrastructure capacity, or on a concentrated Observation growth corridor enabled by investment in new Noted – No Action infrastructure. Neither of these spatial options for growth would direct significant house building or employment sites to : not the opportunity sites for dispersed growth; not the concentrated growth corridor. In reinforcement, DRLP also identifies no opportunity sites (of strategic metropolitan significance) for housing, industry or offices in the Upper Norwood area. Page27/QuestionG3 Surely there are sufficient industrial areas The Council's eviedence Peter Williams around the borough which is currently derelict or bases suggests that there is grossly under used to upgrade with housing not an over supply of industrial Object developments. The WaterColour development in land in the Borough. The land Disagree – No Change Redhill is a classic example of how a derelict referred to off is area can be transformed offering plenty of Metropolitan Open Land and housing and amentities. Alternatively the Old therefore unlikely to be Airport land off the Purley Way could easily developed of housing stand development without losing all the playing purposes in the Plan period. fields. n/a ANNEX A The comment is noted. Mr I.G.M. Hunter Ref: section 2 – Options for Growth, page 3, Detailed negotiations between final point TfL and bus operators are Observation beyond the scope of the Core No Action – Not an LDF Is Example of a “lost opportunity” to enhance a Strategy. Public Transport Service on change of operator

Background

The 468 bus used to run from Elephant and Castle to South Croydon Bus Garage. By the time it enters central Croydon from the North of the Borough, it has become a “short distance bus” and used the Bus stop in Park Street closest to Grants, where it joined five other buses on the stand, Nos. 50, 119, 264, 312 and 412. For the purposes of this Annex, bus 412 can be disregarded as a “short distance” bus in view of its Purley destination. The 119 terminates at The Collonades, the 50 and 264 terminate in central Croydon and the 312 terminates at South Croydon Bus Garage, where the 468 used to terminate.

The other passenger buses going to the South of the Borough stop at a Bus Stop further away from Grants. There are seven; Nos. 60, 166, 197, 405, 407, 455 and 466. With the exception of the 197 which terminates in central Croydon, all the other buses travel at least to Purley, making them “medium/long distance buses”.

There is a logic in separating the buses in this way; short haul customers do not have to take up spaces on longer haul routes making lives uncomfortable for their fellow passengers who have further to commute. Splitting the usage in this way also makes boarding and alighting quicker in the centre of Croydon during the busy rush hours.

Problem

The decision to award the operation of the 468 route to London Central Buses meant that the bus could no longer be garaged at South Croydon Bus Garage, which is an Arriva franchise. The buses, instead, are obliged to park in Nottingham Road, South Croydon at the end of their journey, a half-mile and three bus stops shorter than hitherto. This has meant that passengers wishing to go to the area around South Croydon Bus Garage now have wait, either for a 312, not the most regular service, or join the queue at the other, “medium/long haul” bus stop, in Park Street, thus making their journey a more crowded one and taking up space on the buses intended for medium/long haul passengers, to their discomfort. The need to carry shopping home (because the Council want residents to shop in Croydon) obliges passengers boarding south-bound buses opposite the to use “medium/long haul” buses because the only “short-haul” bus to South Croydon leaves from Park Street, thus making life for a bus passenger more difficult because of increased delays in boarding the buses.

Criticism

I understand that the 468 service, as operated by Arriva, was not an unqualified success. So that when the operating contract came up for renewal, the decision was taken to award it to another operator. This is normal commercial practice and would have been acceptable had the company taking over properly considered the implications both financially for them and the inconvenience of the customers of truncating the service where they did.

The Core Strategy document (page 120) seeks to consider improvements to the bus routes, working in partnership with London Buses but nowhere in the document is a firm undertaking to increase Croydon’s powers to influence the committees which determine what buses go where or whether the service could be extended for the convenience of the residents rather than for the profit of the bus companies.

Proposal

The attached diagram shows three routes for the 468 Bus:

The Red Route represents the original route from Park Street while under Arriva control.

The Blue Route represents the new route under London Central control.

The Green Route is the proposed route which a) would satisfy those customers who hitherto used the bus from central Croydon to South Croydon Garage and b) would provide a slightly extended route which would take some additional customers from the medium/long haul stop in Park Street, plus customers who would otherwise use the medium/long haul buses Northwards from Purley to South Croydon where the route could still terminate.

This extension gains at least four bus stops and additional revenue. The destination board on the bus would read “South Croydon via Royal Oak Centre”.

This proposal does not need to await the promulgation of the core strategy as the present strategy does not limit these sort of changes – indeed, the new Strategy (page 142) Monitoring, continues them. It should be looked at as a matter of urgency with a view to adoption before the Christmas rush occurs this year. page26/figure Having regard to the statement above, the HCA The indicative concentrated is of the view that the boundary of the “indicative growth corridor shown on the Homes and Communities concentrated growth corridor” on the diagram on diagram is indicative only. Agency page 26 of the consultation statement should be Object extended southwards into the Cane Hill site, to Noted – No Action encompass the approximate extent of the site that could become the developable area in the event that the proposal to “slide” the development down the hill to integrate the site with Lion Green Road and Coulsdon Town Centre is pursued. This would be consistent with the “Potential Spatial Options” plan for Coulsdon on page 93 of the consultation document. page23 It is noted that on page 23 of the consultation The indicative concentrated document, reference is made to focusing growth growth corridor shown on the Homes and Communities in a geographically concentrated manner, with diagram is indicative only. Agency most growth in Croydon Metropolitan Centre, but Object also in District Centres, particularly Purley and Noted – No Action Coulsdon. The HCA considers that areas immediately adjacent to these Centres (as currently defined) are also capable of accommodating growth and therefore should be considered for inclusion within the emerging growth corridor concept. Question G1 The HCA considers that the option to focus The comment is noted. development within a concentrated growth However a modified Homes and Communities corridor (Option 2) is a sensible spatial approach. development strategy will be Agency outlined in the next Support consultation of the Core Noted – Propose Changes Strategy. Page27/QuestionG3 17. A combination of employment decline and A modified development Mr David Walker population growth at borough level implies a strategy will be considered for Crystal Palace Triangle reinforcement of Croydon as a dormitory for a subsequent iteration of the Planning Group central London, increasing the need to travel to Core Strategy. It will consider Object work. This increase is clearly unsustainable further the jobs labour supply Agree – Propose Changes without further investment in transport balance in the borough. infrastructure, and in any case undesirable. The Core Strategy should be seeking a more equal balance between workplace jobs and the resident workforce, and Croydon council should work with the Mayor of London to produce harmonised employment and population targets. page26/para2 I support the idea that Croydon metropolitan As is the case in other major Mr I.G.M. Hunter Centre, if it is to accommodate 11,000 new towns and cities, it is homes by 2031 must become a place which is envisaged that many of the Observation far more family-friendly than it is today. But families choosing to live in Noted – No Action family-friendly can imply more parking spaces CMC will not be reliant on for residents (not only parents wish to own private cars and will meet their individual cars but live-in children of driving age travel needs through other also wish to own cars). Such developments also means, such as public have to provide spaces for visitors so as to transport, walking, car clubs, encourage social inter-action (not every-one etc. lives conveniently close to a public transport facility). The parking spaces themselves must be larger to accommodate the current, and possibly future, generation of people carriers. Croydon has to be able to control the amount and type of parking its family developments need - not Central Government. The Sustainable Communities Act will help here. Question G1 It is important that through the Core Strategy The comment is noted. preparation stages, the Council considers all Homes and Communities spatial options, and through the Sustainability Agency Appraisal is able to take informed decisions on Observation which approach(es) to pursue. Agree - No Action page25/para2 Bullet point 4: Not if Central Government laws The comment is noted. Mr I.G.M. Hunter and controls on the number of parking places within developments can be devolved to Observation Croydon (amongst all Boroughs) and Noted – No Action implemented locally with the assistance of the Sustainable Communities Act 2007 –ie: by keeping all appeals against Council/resident agreements, within the Borough. page25/para2/bullet5 Bullet point 5: (a) What is the evidence for this The point is a general one. Mr I.G.M. Hunter and how much compromise (flexibility) should Based on officer experience there be in managing the footprint and (b) to which recognises that it is Observation what extent is this statement currently justified, easier to secure developer Noted – No Action and, given the positive change to waste contributions towards public generation and the environment occasioned by realm improvements when the elements of the South London Waste Plan, dealing with fewer applicants to what extent is this issue likely to pose a major across a more concentrated problem? area than might be the case with dispersed growth. This is a consideration for the South London Waste Plan. page26/para1 The aspiration to focus development on the A modified growth strategy will Mr Michael highly accessible Croydon Metropolitan Town be considered for the next Mulhern Centre and along the A23 transport corridor is iteration of the Core Strategy. Greater London Authority supported. Support Agree – Propose Changes page26/para1 The positives of enforcing the A23 as a A modified growth strategy will Mr Michael concentrated growth corridor are recognised. be considered for the next Mulhern iteration of the Core Strategy. Greater London Authority Support Noted – Propose Changes page27/question G3 However, the proposed approach should not be A modified development Mr Michael at the expense of development opportunities in strategy will be outlined in the Mulhern other centres across the borough. As set out in next consultation of the Core Greater London Authority London Plan policy 3A.3 development proposals Strategy. Object should achieve the maximum intensity of use Agree – Propose Changes compatible with local context, design and public transport capacity. page27/para2/bullet2 Clearly with the change in shopping procedures The number of retail outlets Mr Bill Tubb the public does not need the number of retail and shopping floor spaces will outlets and lots of these were developed from be advised by the retail study. Observation old houses/cottages and need redeveloping. I Noted – No Action assume this plan includes the old Brighton road as well as the brown sites of Purley Way. page26/para1 Congestion is already a problem in the Croydon The support is welcomed. Mr Michael Town Centre and developer contributions from Mulhern the ‘concentrated growth’ scenario would assist Greater London Authority in the delivery of public transport improvements Support and potential future expansion projects Agree - No Action Page 26 Comment: Neither the current Municipal The consultation on the Core Mr I.G.M. Hunter Authority nor its predecessor administration deal Strategy forms part of the well with major planning issues (Arena, Park Council's commitment to early Object Place, Costco), and the present major engagement with the Disagree – No Change developments (Council Hub, Wellesley Road community on major planning Greening, redevelopment and developments. This will be College Green are spectacularly under- followed in due course with whelming the residents. Unless plans for consultation on masterplans development are shown to affected parties when for Croydon Metropolitan they are at the initial proposal stage true Centre. consultation does not happen. For example, just over 400 individuals bothered to see the de- facto plans for the Council Hub and only about 20 attended the feedback session. This is not consultation! Page22/para6 Public Transport, if reorganised to suit the The comment is noted. The Mr I.G.M. Hunter Borough will also help but this requires a greater Council will continue to work influence on TfL committees by the Council (see closely with TfL to meet the Observation Annex A for an example of how borough transport needs of the Noted – No Action residents have lost out on a particular bus borough. service because the Council seemed to have been unable to influence a decision). page27/questionG1 Q G 1 – not necessarily. The comment is noted. A Mr I.G.M. Hunter modified growth strategy will be outlined in the next Observation iteration of the Core Strategy. Agree – Propose Changes page26/para1 Concentrated growth corridor will lead to an A modified development Mr Ibo Djemil oversupply of flats and apartments and force strategy will be outlined in the people to live in small spaces . The young next consultation of the Core Object families of croydon need houses with gardens. Strategy. Disagree – No Change page27/questionG3 Backland development should be actively The policies concerning the Mr Ibo Djemil encouraged for new housing. use of backland for development are not a matter Observation for the Core Strategy. Disagree – No Change page27/QuestionG2 Q G 2 – neither as a whole. The comment is noted. A Mr I.G.M. Hunter modified growth strategy will be outlined in the next Object iteration of the Core Strategy. Agree – Propose Changes Page27/QuestionG3 Croydon has a vast resource of land ripe for Disagree. The council wishes Mr Ibo Djemil development of resendtial homes in the form of to protect the open character little used very large gardens in suburbia. of large gardens where they Object are an important part of the Disagree – No Change character. A borough character appraisal will be prepared in order to assess the important features of the borough's constituents parts. page27/para2/bullet3 Negative features:- Bull point 3; If the transport The comment is noted. Mr I.G.M. Hunter Infrastructure is profit-based and not Public- service based, this might be true. With an aging Observation population Government policy will have to be Noted – No Action directed as much, if not more, to their needs (local buses, trains, shops and leisure), than to the more mobile working population. page27/questionG3 The southern corridor does not afford sufficient A modified growth strategy will Mr Barry Atwood space to accommodate all of these housing be outlined in the next needs and is generally inappropriate for family iteration of the Core Strategy. Observation accommodation. Moreover, the east - west Agree – Propose Changes connections and the A23 road are inadequate for current demands. A compromise between the two Options is therefore required whereby the Borough’s southern districts (relieved, where necessary, by improved transport provision) take on the main responsibility for family housing. page26/para1 We note that the Council intends many of the The support is welcomed. approximately 11,000 new homes in Croydon’s Barratt Homes (kent) Metropolitan Centre to be suitable for families. Support While supportive in principle Agree - No Action page31/para5/bullet3 A review of planning policy to encourage a The comment is noted. The Mr Stephen better mix of retail units Core Strategy will seek to set Leadbetter out general policy for district Central centres. However the precise Residents' Association policies on mix of retail units Observation will be set out in a subsequent Noted – No Action Development Plan Document. page22/para2 CNRA have for the purposes of this response The support is welcomed. Mr Stephen limited comments to the impact of the proposals Leadbetter on Norbury, whose residents we represent. We Central Norbury welcome the Council’s decision to become one Residents' Association of London’s growth areas because of the Support opportunities this will present for current and Agree - No Action future residents. page26/para1 We note that at this point there are 2 options The comment is noted. Mr Stephen being proposed: Leadbetter Central Norbury • Option 1 – Dispersed growth Residents' Association Observation • Option 2 - A concentrated growth corridor Noted – No Action along the A23 and in Croydon town centre. Option 2 would have the most significant impact on Norbury which is essentially a residential suburb with almost all the non residential buildings, except schools, being sited along the A23. page26/para1 We also note the Council’s concern that Option The comment is noted. 2 could be detrimental to those parts of the Barratt Homes (kent) Borough not included in Croydon’s Metropolitan Observation Centre and along the A23. However, the Outer Noted – No Action London Commission’s Interim Report (July 2009) advocates rejuvenation of outer London based on a constellation of town centres, highlighting their importance for both economic activity and community life. page26/para1 The document goes on to recognise the need to A modified development deliver a wide variety of housing choices and we strategy will be outlined in the Barratt Homes (kent) would ask that this is reflected within Option 2. next consultation of the Core Observation Strategy. Agree – Propose Changes page26/para1 We note that the Council intends many of the The Council will consider the approximately 11,000 new homes in Croydon’s site specific circumstances Barratt Homes (kent) Metropolitan Centre to be suitable for families. before determining the mix of Observation While supportive in principle we consider that units on sites in the Croydon Agree – Propose Changes housing mix should be based on several Metropolitan Centre. considerations including up-to-date assessments of need, supply, and demand and, most notably, site-specific circumstances such as whether such provision would be appropriate in this location. page26/para2 We note that the concentrated growth corridor The comment is noted. Mr Stephen proposal is dependent on investment in Leadbetter infrastructure. We have concerns that the Central Norbury current economic climate makes it highly likely Residents' Association that spending on infrastructure and public Observation services will be cut back over the next few years. Ntd N Ati page26/para2 We are not confident that commitments made The comment is noted. The Mr Stephen about improved infrastructure will ultimately be concern is understood. The Leadbetter deliverable to the required standards even if the infrastructure needs Central Norbury desire to do so currently exists. associated with the Core Residents' Association Strategy will be considered by Observation the Infrastructure Delivery Noted – No Action Plan which will be developed alongside the Core Strategy. This will consider the delivery mechanism and funding for essential infrastructure to support growth. Page27/Question G1 PHRA have for the purposes of this response The comment is noted. Ms Brenda limited comments to the impact of the proposals English on Norbury, whose residents we represent Residents Association Observation Noted – No Action page26/para2 Concerned about road traffic on the A23 This will be considered by the Mr Stephen becoming even more congested forthcoming Borough Leadbetter Transport Strategy and this Central Norbury influence the Infrastructure Residents' Association Delivery Plan. The Observation infrastructure needs Noted – No Action associated with the Core Strategy will be considered by the Infrastructure Delivery Plan which will be developed alongside the Core Strategy. page27/para1/bullet6 CNRA’s support for option 2 are therefore The comment is noted. Flood Mr Stephen dependent on the following being delivered for risk and mitigation are taken Leadbetter Norbury: Mitigation of flood risk into account by the Core Central Norbury Strategy. Residents' Association Observation Noted – No Action Page23/para1 1. We support the attempt to think into the future The suppot is welcomed. Norbury and consider future needs shared with local councillors/reside people. We accept the premise of aiming for nts 19,000 new homes over 20 years. There is an Norbury argument for building at a rate more than 1000 councillors/residents per year in next few years in order to stimulate Support the economy and provide jobs. ANAti page26/para1 Option2- It is also in keeping with the allocation The comment is noted. of Croydon Metropolitan Centre as both an However a modified Barratt Homes (kent) Opportunity Area and strategic office location, development strategy will be Support thereby ensuring conformity with the adopted outlined in the next Agree – Propose Changes London Plan as required by PPS12. consultation of the Core Strategy which will retain the emphasis on the Croydon Metropolitan Centre as an Opportunity Area and strategic office location. page26/para1 Furthermore, we believe such an approach The support is welcomed. complements the work already being undertaken Barratt Homes (kent) by the Council to redevelop parts of Croydon’s Support Metropolitan Centre, such as the emerging East Agree - No Action and West Croydon Masterplans, Wellesley Road Masterplan, and Croydon Urban Regeneration Vehicle (CCURV) regeneration plans page27/para1/bullet9 Barratt Homes (Kent) also welcomes the The support is welcomed. recognition of the benefits of higher density Barratt Homes (kent) development. PPS1, PPS3, and the adopted Support London Plan (2008) promote the principle of Agree - No Action maximising densities in order to create sustainable development, and PPS6 promotes the principle of fully exploiting locations through higher density mixed-use development, particularly immediately adjacent to public transport locations. page26/para1 Barratt Homes (Kent) strongly supports Option The next iteration will consider 2, which seeks to concentrate new housing and a modified spatial strategy to Barratt Homes (kent) commercial development in Croydon ensure growth is sustainable Support Metropolitan Centre and along the A23 transport and is likely to feature Noted – Propose Changes corridor. This plan-led approach is an elements of the dispersed opportunity to boost retail, employment, public growth and concentrated realm, cultural, leisure and sports facilities and growth options. sustainable transport infrastructure in the key centres page24/para1 The Council considers Option 1 to be a largely A modified development developer-led, opportunistic approach, strategy will be outlined in the Barratt Homes (kent) however. next consultation of the Core Observation Strategy. Agree – Propose Changes Our client also shares the Council’s concerns that Option 1 could weaken investor interest in Croydon’s Metropolitan Centre, reduce the impetus to invest in rail and other transport infrastructure, and limit investment in high quality public realm. page24/para1 Barratt Homes (Kent) does not support Option 1, A modified development which proposes to disperse growth across the strategy will be outlined in the Barratt Homes (kent) Borough. So doing would not only contravene next consultation of the Core Object national planning guidance which prioritises Strategy. Agree – Propose Changes development in town centres (PPS6, draft PPS4), we would also query the robustness of such an approach. PPS1 (2005) puts a spatial planning approach at the heart of planning for sustainable development and, in paragraph 32, states that Local Planning Authorities (LPAs) should set a clear vision for the future pattern of development in preparing spatial plans. It further adds that planning should lead and focus on outcomes and highlights that it is essential that the Core Strategy makes clear spatial choices about where developments should go in broad terms.. page27/questiong1 One major question is posed in the report – A modified growth strategy will Mr John Ingman whether development should be concentrated in be outlined in the next Park Hill Residents' a corridor along the A235/A23 or dispersed iteration of the Core Strategy. Association through the Borough. The report strongly Observation supports the first option – but we doubt whether Noted – Propose Changes this will provide the sort of homes and communities which people want. page26/para2 The risks of deciding on the concentrated growth The comment is noted. Mr Stephen corridor are Phasing of development over Leadbetter • Concentration of development leading to the plan period will be Central Norbury concentrated disruption during construction. incorporated in the next Residents' Association consultation draft of the Core Observation Strategy to mitigate the Noted – No Action disruption. page22/para6 (In relation to Norbury) Inability to provide The need for leisure facilities Mr Stephen adequate leisure services, which even with the is being considered through a Leadbetter existing population, are completely inadequate Open Space, Indoor and Central Norbury Outdoor Leisure Study which Residents' Association will provide the basis for Observation ensuring that the borough is Noted – No Action adequately served. page27/para2/bullet4 The report recognises that major growth in this A modified growth strategy will Mr John Ingman area could lead to a more transient residential be outlined in the next Park Hill Residents' character (p27) and as other cities have found, iteration of the Core Strategy. Association there is a limited market for high rise high Object density developments. What about houses for Agree – Propose Changes families? In our view this is not an either/or issue. We need both urban renewal in the central corridor and sensitive development across the Borough as a whole, creating balanced communities with a mixture of different types of dwelling which attract a wide range of people – like Park Hill – though even here we need more family houses and fewer flats. page26/para2 Option 2 – A Concentrated Growth Corridor. The The comment is noted. The Mr Robert Core Strategy recognises that there is a need to location requirements for Posselt provide new homes for both small and large family housing will be Martin Robeson Planning households. It is generally accepted that considered alongside the Practice metropolitan centres such as Croydon, because advantages of substantial Observation of their physical nature, are unable to provide development in the Croydon Noted – No Action many of the necessary community facilities that Metropolitan Centre. families require such as recreational and open space. It must also be acknowledged that much of the residential development within Croydon Metropolitan Centre will be high density contained within high rise buildings which are not generally suited to families. Such forms of housing (larger units suitable for families) would generally be better located on the edges of the Metropolitan centre, or within areas where the intensity of development within the centre are lower. Other locations could include district centres and the areas adjoining them. The needs of families and the limited ability for high density development to accommodate for their needs should be recognised within the growth option and reference made to edge of centre or fringe locations within the CMC along with district centre locations being preferable locations for this type of accommodation Mr John Phillips Tandridge District Council page27/questionG3 It remains imperative, however, that the Council The Council will consider the is sufficiently flexible to accommodate up-to-date site specific circumstances Barratt Homes (kent) assessments of need, supply, and demand and before determining the mix of Observation ultimately ensure development is viable and units on sites in the Croydon Noted – No Action deliverable. Metropolitan Centre. A Local Housing Market Assessment is being prepared along with a Strategic Housing Market Assessment. page26/para1 It is our belief that Option 2 is therefore the only The comment is noted. viable, feasible and deliverable development However a modified Barratt Homes (kent) option if these aspirations are to be met. development strategy will be Support outlined in the next Noted – Propose Changes consultation of the Core Strategy. page27/questiong1 So far as the suggestion that growth should be The comment is noted. Mr David Page concentrated in the A23 corridor the panel were Mid Croydon Conservation concerned that many of their conservation areas Area Advisory Panel lie in this strip and as this area is, in the main, Observation already built up, any development would involve Noted – No Action demolition and rebuilding. This is likely to be to the detriment of the conservation areas page27/questiong1 It was also felt that other parts of the borough A modified development Mr David Page might benefit from development and if the policy strategy will be outlined in the Mid Croydon Conservation were too rigid those other parts might miss out. next consultation of the Core Area Advisory Panel Strategy. Object Agree – Propose Changes Page22/para6 Failure of public transport to cope with the This will be considered by the Mr Stephen increase in demand forthcoming Borough Leadbetter Transport Strategy. Central Norbury Residents' Association Support Noted – No Action page45para2/bullet5 High quality sustainable housing and A requirement for Code for Mr Stephen encouragement of innovative design to reduce Sustainable Homes Level 4 Leadbetter carbon output will be considered in future Central Norbury consultation drafts of the Core Residents' Association Strategy. Observation Agree – Propose Changes page22/para6 (In relation to Norbury) Strain on water and The comment is noted. The Mr Stephen sewage services being resolved infrastructure needs Leadbetter associated with the Core Central Norbury Strategy will be considered by Residents' Association the Infrastructure Delivery Observation Plan which will be developed Noted – No Action alongside the Core Strategy. n/a In addition- and despite the aforementioned The comment is noted. concerns- it remains the case that the Council Barratt Homes (kent) has big ambitions for the Borough’s future Observation development. Noted – No Action page22/para6 Flood risk around Norbury station is relatively The comment is noted. Flood Mr Stephen high, and in the event of flooding would be high risk and mitigation are taken Leadbetter impact without work to reduce the risk. into account by the Core Central Norbury Strategy. Residents' Association Observation Noted – No Action page 26/para1 Despite the reservations expressed above, The comment is noted. Mr Stephen CNRA are in favour of a concentration of However a modified Leadbetter development in the Norbury area because it development strategy will be Central Norbury presents the opportunity to improve the physical outlined in the next Residents' Association appearance of our town centre, improve consultation of the Core Support infrastructure, assist local businesses and Strategy. Agree – Propose Changes encourage high quality retailers and employers to move in. Page26 If, however, option 2 is selected it is imperative The comment is noted. A Mr Stephen that there are clear and specific commitments modified development Leadbetter setting out the changes which will be delivered strategy will be outlined in the Central Norbury to support the density of development. next consultation of the Core Residents' Association Strategy. Observation Noted – Propose Changes page27/para2/bullet3 CNRA’s support for option 2 are therefore The comment is noted. Mr Stephen dependent on the following being delivered for Phasing of development over Leadbetter Norbury: the plan period will be Central Norbury incorporated in the next Residents' Association • Strict management of development through the consultation draft of the Core Observation planning and construction phases to minimise Strategy to mitigate the Noted – Propose Changes disruption to existing residents. disruption. Control of construction is also covered by the development management process to further minimise disruption to existing residents. page26/para2 (In relation to Norbury) Improvements to rail and The comment is noted. Rail Mr Stephen bus capacity to serve a growing population and bus capacity will be Leadbetter considered in a future Central Norbury Transport Strategy for the Residents' Association borough which the Council will Support develop. Ntd N Ati page27/questiong2 I believe option 1 is the better choice to ensure The comment is noted. Miss Sevgin less pressure put on one specific areas in the However a modified Djemil borough, which could in turn lead to increased development strategy will be congestion and stress on amenities. Therefore, outlined in the next Support this would enable young people like myself to consultation of the Core Noted – Propose Changes continue to reside in an area I have grown up in. Strategy. page26/para2 CNRA’s support for option 2 are therefore The support for Option 2 with Mr Stephen dependent on the following being delivered for conditions is noted. It is Leadbetter Norbury: Adequate school, health and leisure recognised that adequate Central Norbury provision schools, healthcare and Residents' Association leisure facilities are necessary Observation as part of any growth strategy Noted – No Action to support sustainable communities. page26/para2 CNRA’s support for option 2 are therefore The comment is noted. The Mr Stephen dependent on the following being delivered for infrastructure needs Leadbetter Norbury: An assessment of the capacity of associated with the Core Central Norbury water, sewage, electrical and gas services with Strategy will be considered by Residents' Association improvements where required. the Infrastructure Delivery Observation Plan which will be developed Noted – No Action alongside the Core Strategy. page24/para1 • Option 1 – Dispersed growth- Option 1 would The comment is noted. Ms Brenda be the route which we may be able to defend However a modified English when talking to our members. development strategy will be Pollards Hill Residents outlined in the next Association consultation of the Core Support Strategy. Ntd P Ch page22/para6 Strain on schools and health facilities being The comment is noted. The Mr Stephen resolved impact of growth will be Leadbetter assessed and appropriate Central Norbury policies for infrastructure Residents' Association derived. The infrastructure Observation needs associated with the Noted – No Action Core Strategy will be considered by the Infrastructure Delivery Plan which will be developed alongside the Core Strategy. page27/para1/bullet6 The potential to increase/create public realm The support is welcomed. Mr David including the use of Sustainable Urban Hammond Drainage, Wild Life Corridors and Cycle Natural England Highways are welcomed and to be encouraged. Support Agree - No Action Page27/Question G2 Strict management of development through the A Development Management Ms Brenda planning and construction phases to minimise DPD will consider appropriate English disruption to existing residents. policies.This comment is too Pollards Hill Residents detailed for a Core Strategy. Association Observation Noted – No Action page27/questionG,1,2, Our responses to Questions G1, 2 and 3 are The comment is noted. A Mr Andrew 3 therefore that we recognise the benefits of modified development Walters concentrated growth but note that it also has a strategy will be outlined in the Biggin Hill Airport Limited downside and that, by considering cross- next consultation of the Core Observation borough working, an alternative of concentrated Strategy. Compromise and Noted – Propose Changes growth but not just in the north south corridor growth and cross borough may be more appropriate. relationships will be considered. page27/questionG3 In discussing the options and in particular The next version of the plan Mr Andrew looking at the merits, there should be some will be improved in this regard Walters reference to the cross-borough working referred (ie. connectivity) Biggin Hill Airport Limited to earlier in the document, as there are clear Observation opportunities to relate the growth options to Agree – Propose Changes adjacent boroughs, for example to Biggin Hill and no doubt to other adjacent areas. page27/questionG3 As mentioned above, the Outer London We will consider emphasising Mr Andrew Commission’s interim conclusions include the the links between Biggin Hill, Walters concept of Strategic Outer London Development Croydon and other London Biggin Hill Airport Limited Centres, of which Biggin Hill would be one, development centres. Observation alongside the development of town centres and Agree – Propose Changes the creation of hub and spoke transport networks to support them. The linkage between Croydon town centre, New Addington and Biggin Hill Airport closely matches these concepts. page27/questionG3 A middle ground option might be to concentrate The comment is noted. A Mr Andrew growth on centres, but not just in the main north modified development Walters south corridor. This would enable best use to be strategy will be outlined in the Biggin Hill Airport Limited made of less busy transport corridors and next consultation of the Core Observation enable investments in smaller transport Strategy. This modified Agree – Propose Changes schemes to be made. This comment is made in approach will be further the context of Biggin Hill’s relationship with the explored. eastern parts of Croydon, in particular New Addington and Shirley, which are as close to Biggin Hill as to Croydon town centre. page26/para1 The concentrated growth corridor option The comment is noted. A Mr Andrew possibly puts too much demand on already modified development Walters congested transport networks and also leaves strategy will be outlined in the Biggin Hill Airport Limited centres outside the corridor vulnerable. next consultation of the Core Object Strategy. This suggests the Noted – Propose Changes need for a compromised solution. page24/para1 The dispersed growth option puts town centres The comment is noted. A Mr Andrew at risk and does not make best use of public modified development Walters transport. strategy will be outlined in the Biggin Hill Airport Limited next consultation of the Core Object Strategy. Noted – Propose Changes page27/questionG1 The two options presented are perhaps The comment is noted. A Mr Andrew extremes and each has disadvantages which modified development Walters may be overcome by adopting a middle ground. strategy will be outlined in the Biggin Hill Airport Limited next consultation of the Core Observation Strategy. Noted – Propose Changes Page25/para1/bullet1 10. We recognise the need to build on some The comment is noted. Norbury green field sites. councillors/reside nts Norbury councillors/residents Observation Noted – No Action page22/para3 Also welcomed and encouraged are the The support is welcomed. Mr David potential for the increase in and capacity of the Hammond public transport options, both locally and at Natural England targeted growth points/interchange areas. Support Agree - No Action Page27/Question G2 10) Despite the reservations expressed above, The comment is noted. Ms Brenda PHRA are However a modified English development strategy will be Pollards Hill Residents in favour of Option 1 because outlined in the next Association consultation of the Core Support • The need for development in the Norbury area Strategy. Noted – Propose Changes at presents there must be an opportunity to improve the physical appearance of our town centre, improve infrastructure, assist local businesses and encourage high quality retailers and employers to move in. page27/QuestionG3 People will travel if the good and regular Returning empty homes to transport is there and existing plans to use is integral to the overall Metropolitan Police rejuvenate town centres could still go ahead. development strategy Authority Helping existing residents to move to smaller contained in the London Plan Observation home would bring more people to an areas which forms part of the Noted – No Action (such as Coulsdon) as families move in thus development plan for increasing opportunities for business, as would Croydon. Therefore it is not bringing back into occupation empty homes. I necessary to include it in the think they need a third option ie Core Strategy.

“Concentrated growth in the Centre with a presumption that new homes would be provided along with the redevelopment of such sites as the land around Croydon railway station, the Fairfield Hall, ST. Georges Walk etc combined with polices to bring into use all unoccupied homes in the Borough, to encourage and enable those residents who wish to move to smaller homes to do so and to create/improve existing transport links to all parts of the Borough.” How much of our open land would have to be There is a general lost to ‘assist the development of the necessary presumption in both the Metropolitan Police infrastructure (roads etc) to allow concentrated Dispersed and Concentrated Authority growth to occur? Growth options that there will Observation be no development on open Noted – No Action land within the borough page27/questiong3 However, it may be necessary for the Council to The comment is noted. A Mr David consider a hybrid approach using elements of modified development Hammond both Options. strategy will be outlined in the Natural England next consultation of the Core Observation Strategy. Noted – Propose Changes Page26/map All the ‘Potential areas of Managed Change’ on The comment is noted. Page 26 map are near open space or areas of Metropolitan Police ‘wooded hills’ character. Both options mean Authority more pressure on existing residents, their Observation environment and local facilities. Noted – No Action Page27/para1/bullet Option 2 also has the potential to provide The comment is noted. Mr David increased protection for Green Belt/Metropolitan Hammond Open Land, or at the least, lessen pressure on it. Natural England Observation Noted – No Action Page27/para1/bullet Option 2 provides opportunity to link in and The comment is noted. The Mr David improve existing infrastructure and services, infrastructure needs Hammond which should include Green/Open Spaces associated with the Core Natural England Strategy will be considered by Observation the Infrastructure Delivery Noted – No Action Plan. Page27/questiong1 Either of these Options provides potential for the The comment is noted. Mr David Council to achieve its aims and aspirations Hammond Natural England Observation Noted – No Action page25-27/questionG1 Dispersal versus concentrated growth. - On The comment is noted Nature Conservation Grounds dispersed growth Metropolitan Police would probably have the least effect on our open Authority spaces but could mean more lost back gardens. Observation Concentrated growth would have the most effect Noted – No Action on open spaces particularly in the North of the Borough where there are fewer open spaces for people to use not specified New Addington and Fieldway are not crime hot This reference to crime Cheryll Wright spots – the town centre is statistics will be removed. Safer Croydon Partnership Observation Croydon is the 12th safest borough of all the Agree – Propose Changes London Boroughs – therefore the statement: Rates of crime in Croydon are slightly higher than those in London is incorrect Page27/Question G2 An assessment of the capacity of water, The comment is noted. The Ms Brenda sewage, electrical and gas services with infrastructure needs English improvements where required. Mitigation of associated with the Core Pollards Hill Residents flood risk. Strategy will be considered by Association the Infrastructure Delivery Observation Plan. Ntd N Ati Page27/Negative Norbury’s current infrastructure is under great A Borough-wide Transport Ms Brenda Features of a pressure as follows: Strategy will be prepared to English Concentrated Growth inform the next iteration of the Pollards Hill Residents Corridor Buses are crowded, with only the 109 travelling Core Strategy. Association Observation the whole route via the A23 from Croydon through to Streatham, and slow through Norbury Noted – Propose Changes as bus lanes are limited due to the road being narrow. page26/para1 We note that the concentrated growth corridor The comment is noted. Ms Brenda proposal is dependent on investment in Development will only take English infrastructure. We have concerns that the place if the necessary Pollards Hill Residents current economic climate makes it highly likely infrastructure is provided with Association that spending on infrastructure and public it. Observation services will be cut back over the next few years. Ntd N Ati page26/para2 Street Lighting (in Norbury) has been promised This comment is too detailed Ms Brenda by the council for the last 7 years with no effect. for a Core Strategy. English Pollards Hill Residents Association Observation No Action – Not an LDF Is page26/para2 Side Roads are a hazard and never seem to be This comment is too detailed Ms Brenda repaired. for a Core Strategy. English Pollards Hill Residents Association Observation No Action – Not an LDF Is page26/para2 Building work of new proprieties leave the roads This comment is too detailed Ms Brenda in a damaged state never to be repaired for a Core Strategy. English Pollards Hill Residents Association Observation No Action – Not an LDF Is page26/para2 The council never subject the builders to This comment is too detailed Ms Brenda repairing the roads damaged by the building for a Core Strategy. English lorries & equipment and residents have to suffer Pollards Hill Residents damage to cars and the waste from these sites Association Observation No Action – Not an LDF Is page26/para2 We are not confident that commitments made The comment is noted. Ms Brenda about improved infrastructure will ultimately be English deliverable to the required standards even if the Pollards Hill Residents desire to do so currently exists. See above Association Observation Noted – No Action Page27/Question G2 No more high rise 1 – 2 Bed Apartments along The comment is noted. Ms Brenda A23 English Pollards Hill Residents Association Observation Noted – No Action Page27/Question G2 Considering expansion of the tram link to serve The extension of Tramlink to Ms Brenda the A23 corridor serve the A23 corridor will be English considered in future Pollards Hill Residents consultation drafts of the Core Association Strategy. Observation Noted – Propose Changes Page27/Question G2 Backland developments to be strictly monitored Comment is noted. Backland Ms Brenda and only allowed to be developed when development is monitored as English consultation with the affected area has taken a matter of course. Pollards Hill Residents place Association Observation Noted – No Action Page27/Question G2 12) PHRA’s would only support for option 2 this The comment is noted. The Ms Brenda being dependent on the following being infrastructure needs English delivered for Norbury: associated with the Core Pollards Hill Residents Strategy will be considered by Association • More schools, health and leisure provisions the Infrastructure Delivery Observation Plan. Ntd P Ch Page27/Question G2 Mixed development to include low cost and The next iteration of the Core Ms Brenda family housing with outside space and parking Strategy will set out in more English provision detail the quantum and type of Pollards Hill Residents homes growth expected in the Association area. Space standards Observation provision are matters for a Noted – Propose Changes Development Management DPD. Page22/Para3 We are dubious about the Council’s decision to The London Plan designates Ms Brenda become one of London’s growth areas because Croydon as a Strategic Outer English of the problems this may present for current and London Development Centre. Pollards Hill Residents future residents. Association Object Disagree – No Change Page27/QuestionG3 We note that at this point there are 2 options The comment is noted. Ms Brenda being proposed: English Pollards Hill Residents • Option 1 – Dispersed growth Association Option 2 - A concentrated growth corridor along Observation the A23 and in Croydon town centre. Ntd N Ati Page27/QuestionG2 Option 2 would have the most significant impact A modified growth strategy will Ms Brenda on Norbury which is essentially a residential be considered for the next English suburb with almost all the non residential iteration of the Core Strategy. Pollards Hill Residents buildings, except schools, being sited along the Association A23. Observation Agree – Propose Changes Page27/Negative Norbury’s current infrastructure is under great A Borough-wide Transport Ms Brenda Features of a pressure as follows: Strategy will be prepared to English Concentrated Growth inform the next iteration of the Pollards Hill Residents Corridor • The A23 is narrow and almost always Core Strategy. Association Observation congested with traffic, even outside peak times Noted – Propose Changes Page27/Negative Norbury’s current infrastructure is under great A Borough-wide Transport Ms Brenda Features of a pressure as follows: Strategy will be prepared to English Concentrated Growth inform the next iteration of the Pollards Hill Residents Corridor Train services from Norbury station are regular Core Strategy. Association Observation but not sufficiently frequent and are very crowded at peak times from Norbury onwards on Noted – Propose Changes London bound services. Page27/Negative Norbury’s current infrastructure is under great High quality design will be Ms Brenda Features of a pressure as follows: considered in the next English Concentrated Growth consulatation draft of the Core Pollards Hill Residents Corridor Problems which have been amplified by the Red Strategy. A Residential Association Observation Route and the councils lack of control when Character Appraisal and a businesses seem to be able to do just what they Borough Character Appraisal Noted – No Action want and destroy the local look, and continue to are being developed to ensure make Norbury look tired and dejected. that local distinctiveness and the unique characteristics of Croydon's Places is considered in proposals for growth. Page27/Question G2 We strongly object to option 2 because the risks A modified growth strategy will Ms Brenda of deciding on the concentrated growth corridor be considered for the next English are:- Concentration of development leading to iteration of the Core Strategy. Pollards Hill Residents concentrated disruption during construction, The infrastructure needs Association Strain on schools and health facilities (Norbury), associated with the Core Object Failure of public transport to cope with the Strategy will be considered by Agree – Propose Changes increase in demand, Strain on water and the Infrastructure Delivery sewage services (Norbury), Flood risk around Plan. A Borough-wide Norbury station is relatively high, and in the Transport Strategy will be event of flooding would be high impact without prepared to inform the next work to reduce the risk. Concentration of iteration of the Core Strategy. development leading to concentrated disruption Flood policy will be developed during construction. Road traffic on the A23 in future iterations of the Core becoming even more congested. Inability to Strategy. provide adequate leisure services, which even with the existing population, are completely inadequate. page26/para2 CNRA’s support for option 2 are therefore This will be considered by the Mr Stephen dependent on the following being delivered for forthcoming Borough Leadbetter Norbury: Considering expansion of the tram link Transport Strategy. Central Norbury to serve the A23 corridor Residents' Association Observation Noted – No Action Page27/Question G2 A review of planning policy to encourage a Bullet point 4 on page 24 Ms Brenda better mix of retail units covers this issue. English Pollards Hill Residents Association Observation Noted – No Action page26/para2 The risks of deciding on the concentrated growth The Council will continue to Mr Stephen corridor are -Protection and improvement of protect parks. Leadbetter parks Central Norbury Residents' Association Observation Disagree – No Change page27/questiong3 Instead FAIRVIEW NEW HOMES supports a A modified development N Kwan third option, that growth, in particular new strategy will be outlined in the Fairview New Homes housing for which there is an acute need, should next consultation of the Core Object be linked to sites/ areas with good access to Strategy. Noted – Propose Changes other services, and high public transport accessibility, or with additional public transport capacity committed in the short-medium term, or planned in the medium-long term. page26/para2 Previously, the County Council have highlighted The observation is noted. A Mr Richard concerns over the likely impact of economic and modified development Evans traffic growth on Surrey arising from growth strategy will be outlined in the Surrey County Council within Croydon Borough. In particular, we have next consultation of the Core Observation been concerned at growth affecting the A23 Strategy. Noted – Propose Changes corridor which would increase traffic levels on the highway network in Surrey, and also possibly increase housing pressures within Tandridge District and Reigate and Banstead Borough. page27/questiong1 We note from the current Options document that A modified development Mr Richard the Borough is asking for views on a Dispersed strategy will be outlined in the Evans Option (Option 1) and a Concentrated Growth next consultation of the Core Surrey County Council Option (Option 2). We would be more concerned Strategy. Object over the implications of Option 2 as it involves Agree – Propose Changes concentrating growth along the A23. Whilst accepting the Borough's assumptions concerning the need for improved infrastructure, we do not see how concentrating development along a very tightly constrained corridor will bring forward the necessary improvements. Such improvements would necessarily need to include improvements beyond the Borough in Surrey. page27/questiong1 There is currently no provision made by the A modified development Mr Richard County Council for such an eventuality. We strategy will be outlined in the Evans would also be concerned over the reference to next iteration of the Core Surrey County Council the principle that "development would be Strategy. The forthcoming Object concentrated mainly in the orange areas" Cane Hill Masterplan will Agree – Propose Changes meaning the existing built up areas. We are address infrastructure aware of other opportunities, including the large concerns. Cane Hill hospital, Coulsdon site. We have concerns over the future of this site in terms of housing and employment development and the impact on Surrey's infrastructure and highway network to the south. We have expressed these concerns before in relation to particular proposals at Cane Hill. page27/questiong1 Given the possible ramifications for Surrey, we A modified development Mr Richard therefore OBJECT to Option 2. strategy will be outlined in the Evans next consultation of the Core Surrey County Council Strategy. Object Agree – Propose Changes page27/questiong2 At this time, we can therefore SUPPORT Option The support is welcomed. A Mr Richard 1 concerning Dispersed Growth within the modified development Evans Borough, provided that proposals are for strategy will be outlined in the Surrey County Council sustainable development, and that there is next consultation of the Core Support adequate provision for infrastructure within or Strategy. Agree - No Action adjacent to the Borough in affected areas. n/a With regard to the growth of Croydon over the The comment is noted. Mr Pitts next 20 years, it is most important that there should be a coherent plan. Observation Noted – No Action page27/questiong2 In order to maintain Croydon as a "green The comment is noted. Mr Pitts suburb" it is vital that piecemeal development is However a modified not permitted and that the green belt and open development strategy will be Support spaces are protected. With this in mind, it is outlined in the next Noted – Propose Changes obvious that option 2 is the way forward consultation of the Core Strategy. page27/questiong2 In this respect use can be made of the existing The comment is noted. The Mr Pitts transport infrastructure, avoiding congestion on infrastructure needs minor roads which are already taking more associated with the Core Observation traffic than was forseen when they were Strategy will be considered by Noted – No Action originally built. Good use can be made of the the Infrastructure Delivery existing rail and tram links which can be Plan. developed to provide for the additional traffic which will follow the generated growth around central Croydon and along the A23. page22/para2 We acknowledge the comment that there have The comment is noted. been numerous incidences of high density The Council will consider Devgrove flatted schemes constructed in the Borough and further the arguments for and Object the observation that the Borough will not be able against Green Belt and MOL Noted – Propose Changes to meet its future requirements if development is amendment in the next limited to the restricted supply of developable consultation report for the land within existing built-up areas. Accordingly, Core Strategy. the Core Strategy will need to investigate the possibility of some development being accommodated on green belt and metropolitan open land (page 22 of the Initial Report). page34/para1/bullet6 An idea has just occurred with regard to the The Core Strategy is unable to Miss Jean specialist manual skills training, could a years influence the sylabus of Newman service be offered to a teacher from anywhere in or their the UK who is a specialist in their field with a recruitment policies. Observation good results level at a special rate of pay to take No Action – Not an LDF Is a post in a Croydon college, I think for instance there may be areas that have a tradition of metalwork from the north of England so the students are taught at a high level to increase their competitiveness, and give them a decent chance of competing and avoiding the trap of so called government training courses run for profit by anybody seizing the opportunity to make a business out of the needy (have you seen the benefit busters programmes shown on TV recently, I think that gives a fairly clear view of what is happening to the unemployed). The above post could be for a one year term by arrangement, similar to the idea for instance of a poet or writer in residence scheme such as the had a while back and should benefit all concerned. Page22/para4 Page 22 of the Initial Report rightly declares that The comment is noted. if Croydon is to establish itself as the main driver The Council will consider Devgrove of growth in South London up to 2031, there is further the arguments for and Object merit in seeking to concentrate growth in areas against Green Belt and MOL Noted – Propose Changes of public transport accessibility. Such a strategy amendment in the next does not necessarily preclude some limited consultation report for the development in the green belt as is suggested Core Strategy. by the comment at page 22 of the Report that such an approach “may also afford us greater protection for our Green Belt and suburban areas”. page23/para3 We disagree with the observation at page 23 of The Council will consider the Report that the spatial strategy should further the arguments for and Devgrove protect the green belt and focus growth in a against Green Belt and MOL Object geographically concentrated manner amendment in the next Noted – Propose Changes consultation report for the Core Strategy. page27/questionG3 Land in the vicinity of the Addington Village tram The comment is noted. stop can make a realistic contribution to the Devgrove spatial strategy in an area with good public Observation transport accessibility. Noted – No Action page22/para3 We have taken note of the comment at page 22 The comment is noted. of the Report that Croydon has been identified The Council will consider Devgrove as a key growth area. Furthermore, the Report further the arguments for and Observation states that even without the necessity to address against Green Belt and MOL Noted – Propose Changes wider targets, the Borough must grow to meet amendment in the next local needs. Devogrove agrees that the primary consultation report for the issue is how that growth is managed. If new Core Strategy. development is accommodated in a sensitive manner, with regard to major issues such as climate change, it will afford numerous positive opportunities. A development off Kent Gate Way, related to Croydon Tramlink, can be achieved in a manner which will fulfil many of the Council’s objectives regarding sustainable patterns of growth. Page23/para1 Page 23 of the Report states that “studies The 19,000 is a minimum indicate that we may need in excess of 19,000 number of homes pending Devgrove new homes in Croydon to take us up to 2031.” completion of a Local Housing Observation Over what period does the Council expect those Market Assessment setting Noted – Propose Changes 19,000 dwellings to be built? If the additional out need up to 2031. It will be 19,000 dwellings are to be secured in the period based on the latest available 2009 – 2031, this would represent an average of GLA Population Projections. 865 dwelling completions per annum (19,000 ÷ The assessment will be 22). This is significantly less than the housing prepared in time for the next provision established for the Borough at Table iteration of the Core Strategy. 3A.1 of The London Plan. page25/para1 I feel very much that what we need now is the The comment is noted. Miss Jean dispersed growth option to give people However a modified Newman something very important and I fancy much development strategy will be desired by many, that of feeling more identity outlined in the next Support with their own personal home area, which has consultation of the Core Noted – Propose Changes the big benefit of fostering more community spirit Strategy. and involvement, and generally making people feel safer. A more friendly environment can also deter anyone bent on on criminal activity as they are more likely to be observed by people taking more interest locally. page27/questiong1 London has often been described as a series of The comment is noted. The Miss Jean villages both north and south, and I would Core Strategy is developed Newman personally vote for any schemes that could start around the 16 Places of to put back a sort of village feel, with each area Croydon. Observation concentrating on its own particular flavour, my Noted – No Action own area of Thornton Heath for instance still houses the football ground, now has the very handsome Sport England swimming pool centre, has the Brit school for young musicians and actors and has hatched two famous pop stars, together with what was the famous Lord Napier jazz pub still there in Beulah Road, so an arts and sports theme is already well established Page49 On the sports theme it occurs straightaway that The comment is noted. The Miss Jean there is a crying need for a football club where infrastructure needs Newman young football aspirees could be coached, associated with the Core getting them off the streets and giving them a Strategy including provision of Observation goal. sports facilities will be Noted – No Action considered by the Infrastructure Delivery Plan. page23/para1 Furthermore, such a potential level of growth is The 19,000 is a minimum substantially below the future requirement number of homes pending Devgrove arising from the 2006 – based household completion of a Local Housing Observation projections. Market Assessment setting Noted – Propose Changes out need up to 2031. It will be based on the latest available GLA Population Projections. The assessment will be prepared in time for the next iteration of the Core Strategy. page23/para1 The 2006-based household projections suggest The 19,000 is a minimum an increase of 33,000 households in the number of homes pending Devgrove Borough in the period 2006 – 2031. This is the completion of a Local Housing Object equivalent of an extra 1,320 per year, Market Assessment setting Noted – Propose Changes significantly greater than the suggested change out need up to 2031. It will be described at page 23 of the Initial Report. The based on the latest available household projections themselves are based on GLA Population Projections. future anticipated population change and, given The assessment will be the age profile described at page 14 of the Initial prepared in time for the next Report, Devogrove believes that the future need iteration of the Core Strategy. for housing is considerably greater than the figure of 19,000 new homes presented at page 23 of the Report. page23/para1 In the light of the content of the 2006-based The 19,000 is a minimum household projections, the figure of 19,000 new number of homes pending Devgrove homes might represent only 65% of the completion of a Local Housing Observation projected requirements in the period 2009 – Market Assessment setting Noted – Propose Changes 2031. Such a potential outcome would appear to out need up to 2031. It will be counter the identification of Croydon as a key based on the latest available growth area. Equally, such a consequence GLA Population Projections. would appear to contradict the comment at The assessment will be Policy 3A.1 of The London Plan that the Mayor prepared in time for the next will, and boroughs should, promote policies that iteration of the Core Strategy. seek to achieve and exceed the target for new In addition a Strategic housing to be found at Table 3A.1 of The Housing Land Availability London Plan. Policy 3A.2 of The London Plan Assessment is being prepared appears to propose that the housing figures are which will form the basis of a minimum, yet the Initial Report is apparently new London Plan targets advocating a future housing delivery programme which will be taken forward by that is significantly lower than that to be found in the Core Strategy. The London Plan, a curious net result when compared with the identification of the Borough as key growth area. page25/para1 For all of the above reasons and more I feel the The comment is noted. Miss Jean dispersed growth option is the best way forward However a modified Newman for Croydon and the best way to naturally fuse development strategy will be the area together with the village idea as each outlined in the next Support area becomes more successful it will grow and consultation of the Core Noted – Propose Changes blendinto the whole while retaining its Strategy. uniqueness. page22/para1 We agree that it is critical for the Council to The comment is noted. address the implications for growth through the The Council will consider Devgrove medium of the Core Strategy and, accordingly, it further the arguments for and Object is essential for the Core Strategy to against Green Belt and MOL Noted – Propose Changes acknowledge the necessity of utilising a limited amendment in the next amount of land presently in the green belt to consultation report for the address the local growth agenda. Core Strategy. page26/para2 Devogrove does not consider that Option 2, of The next iteration will consider itself, will deliver the level of growth required in a modified spatial strategy to Devgrove the period to 2031. As noted above, there are ensure growth is sustainable Observation congestion issues affecting the A23 corridor and and is likely to feature Noted – Propose Changes it is highly questionable whether the centre of elements of the dispersed Croydon is able to accommodate approximately growth and concentrated 11,000 new homes by 2031 as suggested at growth options. page 26 of the Initial Report. The Core Strategy needs to address the delivery of family housing and we endorse the suggestion at page 26 of the Report that it will not be possible significantly to increase the number of new dwellings in the centre of Croydon unless it becomes a place “which is far more family-friendly than it is today.” page27/questiong1 My concerns are under the broad heading of The comment is noted. Kathryn Bonds Growth Option 1 and Option 2 - presumably Croydon Council wishes to consider Option 2 Observation whereby more concentration of funding is along Noted – No Action the A23 corridor - I can see why as it builds on existing infrastructure. page27/questiong1 However, whilst I cannot agree with Option 1 The comment is noted. A Kathryn Bonds whereby there would be an obvious dilution of modified development funding which would benefit no-one there needs strategy will be outlined in the Observation to be a balance between both Options next consultation of the Core Agree – Propose Changes Strategy. n/a In the last couple of years there has been This is not a matter the Core Kathryn Bonds criticism of lack of concern for the districts whilst Strategy can deal with. It is a there are DCMs,failure to allow a visitors centre matter for tourism centre Observation to advertise small scale events for the satellite management. No Action – Not an LDF Is district centres and the lack of a tourist central nucleus at the local library has come up for criticism especially when we realised that the visitors centre meant central Croydon only! page27/questiong3 Is there a way in for an Option 3 whereby, all The comment is noted. A Kathryn Bonds areas are looked at and that whilst there is a modified development concentration of central funding to centre of strategy will be outlined in the Observation Croydon; it would back DCMs, that suitable and next consultation of the Core Agree – Propose Changes appropriate and sympathetic development is Strategy- which will explore a considered for the district centres which would compromise pattern of bring in much needed revenue for those centres development. to benefit both businesses and residents alike? page27/questiong1 I fear that Option 2 would add to the boarded up The comment is noted. A Kathryn Bonds local centre. modified development strategy will be outlined in the Object next consultation of the Core Noted – Propose Changes Strategy. page27/questiong1 I was most concerned that this "Hobson's The comment is noted. A Kathryn Bonds Choice" has been presented to us. modified development strategy will be outlined in the Observation next consultation of the Core Noted – Propose Changes Strategy. page27/questiong1 Turning now to the borough that has been The sixteen places of Croydon Kathryn Bonds partitioned off into I think 16 parts to improve the are intended to recognise the lot of the residents - this doesn’t seem to gel well different communities in the Observation with Option 2. borough and their differing Disagree – No Change characters. This is one reason why a concentrated form of development was presented. page27/questiong1 It does tend to look as though its three course The comment is noted. A Kathryn Bonds dinner for the centre of Croydon and crumbs for modified development the rest of us. I do hope you can consider some strategy will be outlined in the Observation middle way. next consultation of the Core Noted – Propose Changes Strategy. page22/para2 If sufficient land is to be identified to The Council will consider accommodate necessary development in the further the arguments for and Devgrove period to 2031, Devogrove believes that land will against Green Belt and MOL Observation inevitably have to be released from the green amendment in the next Noted – Propose Changes belt, particularly in the context of the consultation report for the development of family housing. Core Strategy. page27/questionG1 However, in practice a mix of the two options A modified growth strategy will may be the best approach because whilst be considered for the next B&Q Properties Ltd Croydon Metropolitan Centre and the A23 iteration of the Core Strategy. Observation transport corridor are both important in meeting Agree – Propose Changes the Borough’s retail needs, they are unlikely to be suitable for accommodating the greater part of the Borough’s housing growth. page27/questiong1 FAIRVIEW NEW HOMES does not consider that A modified growth strategy will N Kwan option 2 is the correct option. Option 2 promotes be outlined in the next Fairview New Homes new housing and commercial development iteration of the Core Strategy. Object concentrated on Croydon Metropolitan centre Agree – Propose Changes and along the A23 transport corridor only. This does not promote sustainable development. page24/para1 We object to Option 1 as it will not deliver the The comment is noted. A growth agenda in a sustainable manner. The modified growth strategy will Devgrove dispersed model of growth will lead to a loss of be outlined in the next Object economic competitiveness and will not be interation of the Core Strategy. Noted – Propose Changes sufficient, in itself, to meet future housing requirements. The pressure on the restricted land supply within existing built-up areas will adversely affect residential amenity. page23/para3 The Council’s preferred approach is to focus The comment is noted.The most growth in Croydon Metropolitan Centre and Council will consider further Devgrove in corridors along the A23. The Metropolitan the arguments for and against Object Centre is required to accommodate a range of Green Belt and MOL Noted – Propose Changes land uses, not only housing, whilst the A23 is amendment in the next described within the Initial Report as both consultation report for the congested (page 20) and liable to flooding (page Core Strategy. 18). Furthermore, the problems arising in the A23 corridor will be compounded by land assembly costs and difficulties related to infrastructure provision. Accordingly, we would propose that a sound spatial strategy should also incorporate a limited release of land from the green belt, with good public transport accessibility, to accommodate necessary development. Given our concerns, we would suggest that the next iteration of the Core Strategy, which is to establish the location, scale, form and type of development appropriate for the levels of growth expected, should thoroughly explore the potential of limited green belt releases. page27/questionG3 Option 2 provides the basic framework for a The Council will consider sound spatial strategy but we consider that the further the arguments for and Devgrove DPD must acknowledge the contribution that against Green Belt and MOL Observation limited green belt releases can and will make to amendment in the next Noted – Propose Changes the delivery of new housing and related facilities. consultation report for the The next iteration of the Core Strategy must Core Strategy. confront this pivotal topic. page23/para1 PPS 12 requires a Core Strategy to be flexible to The Core Strategy will take enable it to deal with changing circumstances. If the London Plan targets as its Devgrove Imagine Croydon proceeds on the basis of the basis. Need will be assessed Observation future housing requirement figure given at page by a Local Housing Market Noted – No Action 23 of the Initial Report, the DPD will not be able Assessment. to deal with changing circumstances. Paragraph 33 of PPS 3 states that the determination of the appropriate level of housing provision should take in to account evidence of current and future levels of need for housing and the Government’s latest published household projections page23/para1 As Croydon is a key growth area, Devogrove The Core Strategy is based on would suggest that the Core Strategy should be the latest available GLA Devgrove prepared on the basis, at least, of the housing Population Projections. Observation provision anticipated for the Borough in the 2006 Disagree – No Change – based household projections. page23/para1 Devogrove agrees with the Council that an The support is welcomed. important element of the Core Strategy is to Devgrove identify the best locations to accommodate the Support new housing and complementary facilities. Agree - No Action page27/questionG3 Options. 1. DISPERSED GROWTH. This relies Noted. The additional costs Brian Madge on major infrastructure investment, and arising from dispersed growth Brian Madge Ltd expensive site assembly. The current recession will be considered in a Observation casts doubts on the ability of small sites in modified development Noted – No Action dispersed location to bring forward such strategy which will be outlined investment. It is suggested that larger in the next consultation of the developments may be the only way to achieve Core Strategy. growth which will require a full review of needs, supply and sites. page26/para1-2 Option 2. A CONCENTRATED GROWTH The next iteration will consider Brian Madge CORRIDOR. This relies heavily on development a modified spatial strategy to Brian Madge Ltd taking place in Croydon Metro Centre and along ensure growth is sustainable Observation the A23 transport corridor, from Norbury in the and is likely to feature Noted – Propose Changes north, down to Coulsdon in the south. In the elements of the dispersed absence of the site allocation consideration growth and concentrated there must now be doubt that this corridor alone growth options. The can meet more than half the required housing infrastructure needs (11,000 units), along with suitable schools, associated with the Core health and community facilities. Indeed in Strategy will be considered by response to current planning applications the the Infrastructure Delivery Council suggest this corridor already lacks Plan. The Council recognises essential infrastructure. Many parts of this that there are pressures on corridor are already stretched in terms of along the A23 corridor and infrastructure. Some of the suggested these will be considered in infrastructure issues (such as problems of deciding a balance of flooding, possible road tunnel through Purley) concentrated development in are unlikely to come forward in the forthcoming the borough in the next period of public sector restraint and in a market version. where developer housing schemes may well move away from the higher density flat schemes common in the past 10 years. page27/questionG3 It is thus suggested that wider growth locations The comment is noted. A Brian Madge could be required to meet development supply modified growth strategy will Brian Madge Ltd (particularly housing). Such new locations be outlined in the next Observation should consider the current tramlink corridors. iteration of the Core Strategy. Agree – Propose Changes page23/para1 That being the case, it is somewhat paradoxical The comment is noted. The to state that spatial options are limited on the Council will consider further Devgrove basis of an unsubstantiated aspiration to protect the arguments for and against Observation the totality of the existing extent of the green belt Green Belt and MOL Noted – Propose Changes amendment in the next consultation report for the Core Strategy. page23/para3 PPS 12 requires that alternative spatial options Options 1 and 2 are are evaluated and we would suggest that the alternative spatial options. The Devgrove Core Strategy should look carefully at the Council will consider further Observation potential of limited green belt releases to the arguments for and against Noted – Propose Changes contribute to the achievement of a sustainable Green Belt and MOL pattern of growth. amendment in the next consultation report for the Core Strategy. page23/para2 We acknowledge the fact that, in recent years, The Council will consider new private housing has usually been flatted further the arguments for and Devgrove development on opportunity sites. A sound against Green Belt and MOL Observation spatial strategy will need to ensure that sufficient amendment in the next Noted – Propose Changes conventional family housing is delivered to consultation report for the support the growth agenda. In that context, the Core Strategy. land supply should constitute more than previously developed land within existing built- up areas. page24/para1 After very careful consideration I would actually The comment is noted. Miss Jean like to opt for Option 1 the Dispered growth Plan However a modified Newman for the following reasons. development strategy will be outlined in the next Support consultation of the Core Noted – Propose Changes Strategy. page26/para1 B&Q Properties Ltd support the potential for A modified growth strategy will growth along the A23 (Purley Way) which is be considered for the next B&Q Properties Ltd recognised in Option 2. iteration of the Core Strategy. Support Noted – Propose Changes page23/para2 Where development sites are allocated outside The comment is noted. The town centres, it is essential that sustainable infrastructure needs Highways Agency transport improvements are identified to mitigate associated with the Core Observation any adverse impact on the road network. In Strategy will be considered by Noted – No Action addition, the proposed improvements should be the Infrastructure Delivery phased in line with the delivery of new Plan. development. Funding and delivery mechanisms of such improvements should be detailed in the CS. page27/questiong2 We support Option 1 The support for Option 1 is Miss Wendy welcomed. A modified Wong Chang development strategy will be Berkeley Homes (south outlined in the next East London) Ltd consultation draft of the Core Support Strategy. AP Ch page25/para2/bullet4 Dispersed new housing will reduce the impetus Disagree. Dispersed growth Miss Wendy to invest in rail and other transport infrastructure will lead to more inefficient Wong Chang transport patterns reducing Berkeley Homes (south Again, we believe the contrary. New housing the incentive to invest as no East London) Ltd would cater for increased population and hence single location has enough trip Object increase demand and usage for rail and other generation to warrant Disagree – No Change transport infrastructure, which would in turn investment. increase the impetus to invest in such. page25/para2/bullet3 Residents would increasingly have to seek jobs, Dispersed growth could lead Miss Wendy culture, entertainment and shops elsewhere. We to fewer services in the Wong Chang believe the contrary, more housing available borough as there may be less Berkeley Homes (south within the Borough would encourage people to development of any type in East London) Ltd remain in or move to the Borough. More people district centres leading to Object living in the Borough would increase the vitality residents having to seek jobs, Noted – Propose Changes of town and district centres and hence provide culture, entertainment and more investment opportunities, which would in shops elsewhere. However a turn regenerate run down parts of the Borough. modified growth strategy will be outlined in the next iteration of the Core Strategy. Page22/Para2 Green Belt The Council will consider further the arguments for and Highways Agency 10. The CS states that “If growth was restricted against Green Belt and MOL Object purely to Town and District Centres, under amendment in the next Agree – Propose Changes current planning policies Croydon would not be consultation report for the able to meet its national and regional targets for Core Strategy. housing and it would be necessary to investigate the possibility of building some development on Green Belt and Metropolitan Open Land.” Although the exact land use for the developments is at present unknown, we are concerned that redeveloping Green Belt land could result in development in areas where there is limited access to sustainable transport modes, which could in turn result in higher levels of car usage and subsequent impact on the SRN. Although the HA recognises that new public transport hubs could be developed over time, this process is likely to require very substantial investment. Page27/QuestionG1 One major question is posed in the report – The comment is noted. The Mr John Ingman whether development should be concentrated in next iteration will consider a Park Hill Residents' a corridor along the A235/A23 or dispersed modified spatial strategy to Association through the Borough. The report strongly ensure growth is sustainable Object supports the first option – but we doubt whether and is likely to feature Agree – Propose Changes this will provide the sort of homes and elements of the dispersed communities which people want. The report growth and concentrated recognises that major growth in this area could growth options. lead to a more transient residential character (p27) and as other cities have found, there is a limited market for high rise high density developments. What about houses for families? In our view this is not an either/or issue. We need both urban renewal in the central corridor and sensitive development across the Borough as a whole, creating balanced communities with a mixture of different types of dwelling which attract a wide range of people – like Park Hill – though even here we need more family houses and fewer flats. page22/para2 As recommended by PPG13, development of The comment is noted. travel-intensive uses should be focussed within Highways Agency existing town centre and district centres which Observation are better served by public transport links. This Noted – No Action will minimise the impact of increased trips on the SRN and will also help ensure that the Strategy is in line with PPG13 paragraph 20 , and therefore meets PPS12 soundness requirement to align with national policy. page27/para1 A planned and more concentrated approach is The support for Option 2 is Nikki Honan supported, as set out in Option 2. HUDU fully welcomed. Dialogue with HUDU welcomes further engagement with the Council HUDU is also welcomed to Support to ensure healthcare provision is in the right help develop the policy. Noted – No Action place at the right time to support this growth as well as meet existing requirements. page27/questionsG1-3 Questions G1-3 The options for growth could The comment is noted. The Nikki Honan consider the way healthcare is provided and infrastructure needs HUDU how future provision is planned, as set out in the associated with the Core Observation documents referenced above. In particular, Strategy will be considered by Noted – No Action regard could be had to the ‘hub and spoke’ the Infrastructure Delivery model of provision. Plan which will be developed alongside the Core Strategy. page25/para2/bullet2 - Dispersal would probably weaken investor Dispersed growth will weaken Miss Wendy interest (and the associated opportunities for developer interest in Croydon Wong Chang renwal) in areas such as CMC, Purley and Metropolitan Centre, Purley Berkeley Homes (south Coulsdon. -We consider this to be the contrary and Coulsdon as there is not East London) Ltd as dispersed growth would lead to the unlimited developer interest in Object development of brownfield land in neglected the borough and sites in Disagree – No Change parts of the borough and hence increase the easier to develop locations vitality in these areas and would lead to more would be developed in investment opportunities across the Borough. preference. Rather than weaken investor interest, dispersed growth could retain investor interest within the borough. page25/para2/bullet1 We would disagree with the Council’s argument A modified development Miss Wendy against dispersed growth, these are as follows: strategy will be outlined in the Wong Chang next consultation of the Core Berkeley Homes (south - It seems likely that a dispersed growth strategy Strategy. East London) Ltd will not be sufficient in itself to meet housing Object needs. We disagree with this argument as Noted – Propose Changes dispersed growth strategy would increase the amount of land available or suitable for housing development across the Borough rather than limiting them to those located within designated growth areas. This would create more opportunities for housing development and increase housing provision across the Borough. page27/questiong2 Dispersed Growth as Option 2 would limit the The comment is noted. A Miss Wendy development potential of future sites not within modified development Wong Chang the proposed growth corridor. strategy will be outlined in the Berkeley Homes (south next consultation of the Core East London) Ltd Strategy. Observation Noted – No Action page26/para1 Option 2 – development on this corridor will The comment is noted. The Mr Robert have a negative impact on the road network and latter point is agreed. Hayward cause impacts for those travelling through to/and Reigate & Banstead from Reigate & Banstead. Improving Borough Council infrastructure and promoting rail usage will be an Object important strategy to alleviate congestion on the Noted – No Action A23 and counteract the impact of further growth. page23/para3 The A23 Corridor The next iteration will consider a modified spatial strategy to Highways Agency 7. The CS states that most of the borough’s ensure growth is sustainable Observation growth opportunities are concentrated in and is likely to feature Noted – Propose Changes Croydon Metropolitan Centre and along the A23 elements of the dispersed corridor. Intensification of development in areas growth and concentrated with a low level of public transport assesibility growth options. (PTAL), could result in an increase in car trips which could in turn precipitate an increase in congestion on the SRN if mitigation measures are not in place to reduce the need to travel by car. 3. A Place for Opportunity Page/Paragraph/ Representation Recommended response Full Name Objective Organisation Nature of Response Officer Recommendation page38/para1/bullet8 I am a fan of Croydon’s Libraries in Purley and The comment is noted. Mr Bill Tubb Central Croydon and enjoy the and Old Town Hall cinema and Lean Observation cinema facilities. Noted – No Action page43/questionmc2 With regard to the options for changes, as set The support is welcomed. out on page 40, we would wish to reiterate the Barratt Homes (kent) importance of adopting a flexible approach to Support the Centre’s regeneration to ensure Agree - No Action development is viable, achievable, and deliverable during the Strategy’s lifetime. This is particularly important in respect of aspirations to divide the Centre into functional quarters. However, our client strongly supports the underlying aspiration to encourage growth and a greater mix of commercial, retail, education, leisure, cultural, entertainment and employment uses in the Centre. This is potentially an exciting time for Croydon and our client would ask that the Council capitalises on expectations for the Borough and Outer London to produce a deliverable Core Strategy. This is particularly important given the Council’s past aspirations for change in the Centre as set out in Croydon 2020 Vision (1998) and Croydon Unitary Development Plan (2006), neither of which have yet been implemented. page36/para2/question Reference to the need to consider quality as well The quality of culture and Nikki Honan LC2 as quantity of culture and leisure provision is leisure provision is already HUDU also suggested. considered by the Core Object Strategy. Disagree – No Change page35/para2 We are therefore pleased that the document will The support is welcomed. Ms Rose acknowledge existing cultural facilities and that Freeman policies should include their protection and The Theatres Trust promotion while allowing for future development Support of cultural and leisure venues. Evening and Agree - No Action night-time activities are a fundamental part of urban renaissance because they ensure the vitality of an area beyond normal working hours and the document has noted that this element is essential for the success of a vibrant town centre economy. page 35/para1 Cultural energy and creative activity is the mark The comment is noted. Ms Rose of an innovative community, helping attract and Freeman retain well-qualified people and businesses. The Theatres Trust Theatre and the performing arts are required Observation elements of a sustainable community, providing Noted – No Action social, cultural, environmental and economic benefits. Theatres make a major contribution to the vitality of town centres and are significant elements of any town or city’s cultural infrastructure. People attend arts venues in large numbers for a wide range of arts and entertainment activities, both as paying members of the audience and also as participants in amateur, community and educational arts activities such as dramatic societies, choirs, youth theatres etc. page40/para18/bullet6 Natural England welcomes and commends The support is welcomed. Mr David schemes and initiatives that promote and Hammond encourage the use of sustainable public Natural England transport options, including walking and cycling. Support Agree - No Action page36/questionLC2 The Theatres Trust particularly asks that the The Council's policies Ms Rose document provides sufficient protection to regarding the use of existing Freeman ensure continued theatre use in other venues buildings will be detailed in a The Theatres Trust particularly where buildings providing later LDF document. Observation performance arts may not be covered by listing Noted – No Action or conservation area designations, or may be affected by proposals which come forward for other development sites. This should include performing arts facilities that stand-alone, are part of other facilities, or are contained within educational or community buildings. page46/questionH2 How many empty/derelict homes are there in An allowance for the bringing Croydon which could be put back into back to use of empty homes in Metropolitan Police occupation (compulsorily if necessary) or Croydon is set out in the Authority residents who would like to move to smaller housing target in the London Observation homes to allow some of the target to be met by Plan. Noted – No Action existing housing stock? page43/questionmc3 Barratt Homes (Kent) supports in principle the The support is welcomed. Council’s aspirations for Croydon Metropolitan Barratt Homes (kent) Centre. Our client welcomes the recognition that Support the Centre includes several large development Agree - No Action and regeneration sites that offer potential for positive change and the acknowledgement that the West Croydon area is a gateway location to the town. This is encouraging given that West Croydon’s redevelopment is vital to the success of the overall development and regeneration plans for the town centre and Borough as a whole, as set out in the West Croydon Masterplan Brief (July 2009). Our client supports mixed use development, including residential use, in the Centre and the proposal to establish a partnership framework for its development. Indeed this reflects work that has already begun, such as the emerging West Croydon Masterplan. page36/para2/question Further points under ‘What are the options for These points are addressed Nikki Honan LC2 change?’ could reference green spaces, design elsewhere in this consultation HUDU standards, public realm improvements, document. Object accessibility, encouraging more walking and Disagree – No Change cycling and addressing health and social inequalities. page37/para1/bullet8 Improved and more accessible open spaces and The support is welcomed. We Mr David the de-culverting of rivers, where possible and will review the public realm Hammond appropriate, is also welcomed and supported. strategy to reflect the need to Natural England This could also be linked in with Quality Public adapt to climate change. Support Realm, which can and should consider use of Agree – Propose Changes ‘soft landscaping’, and where appropriate, water features – which can help with climate change adaptation and ‘heat island Affects’. page32/questionBIE2 Question BIE2 We would endorse these The comment is noted. Nikki Honan suggestions but add that further options could HUDU include encouraging developers to recruit local Observation people and use local business, particularly in or Noted – No Action near deprived areas, and encouraging developers to produce an employment and training plan to encourage job opportunities for local people and reduce barriers to work, particularly given the positive impact that employment can have on health. page42/para1/bullet7 With regard to requiring all developments to be A modified approach to the part of a sustainable heating and energy provision of a district heating Barratt Homes (kent) scheme for the Metropolitan Centre (page 42), scheme will outlined in the Object our client supports in principle aspirations to next consultation draft of the Agree – Propose Changes make development environmentally sustainable Core Strategy. but would suggest that such an approach is sufficiently flexible so as not to impede development and regeneration of the Centre and to allow for other factors such as technological advances and viability considerations. page36/para2/question Question LC2 We support the reference to The options for change are all Nikki Honan LC1 promoting healthy lifestyles but suggest this related to addressing the HUDU could be expanded to cover the overall health overall health and social Observation and social implications of appropriately planning implications of culture and Noted – No Action for culture and leisure leisure. page36/para2/question We would also like to see the core strategy Reference to providing for Nikki Honan LC2 provide for equitable access to health facilities. equitable access to health HUDU facilities will be incorporated in Object the next consultation draft of Agree – Propose Changes the Core Strategy. page38/para1/bullet2 In addition to these comments and in view of the The comment is noted. scale and strategic nature of its town centre Minerva landholdings, Minerva would welcome the Observation opportunity of early discussion with Council Noted – No Action Officers in the light of these representations and in advance of the second draft Issues & Options document which we understand will be published in February 2010. page29/para2 Where development sites are allocated outside The comment is noted. The town centres, it is essential that sustainable infrastructure needs Highways Agency transport improvements are identified to mitigate associated with the Core Observation any adverse impact on the road network. In Strategy will be considered by Agree – Propose Changes addition, the proposed improvements should be the Infrastructure Delivery phased in line with the delivery of new Plan which will be developed development. Funding and delivery mechanisms alongside the Core Strategy to of such improvements should be detailed in the ensure that each phase of Core Strategy. development is accompanied by appropriate infrastructure. page42/para1/bullet2 In the meantime however, Minerva welcomes The comment is noted. the opportunity of early engagement with the Minerva Council and other key town centre stakeholders Observation in considering the potential for the future Noted – No Action development of its land holdings as part of a wider strategy for the Croydon Metropolitan Centre. page37/para2/bullet8 The Croydon Metropolitan area is recognised as The comment is noted. Mr David an area deficient/short of quality open space and Hammond the Council has the potential to address this as Natural England developments/applications are submitted or Observation proposed, the use of Section 106 may be Noted – No Action appropriate in certain instances. page43/questionmc3 Croydon Metropolitan Centre The Core Strategy recognises Nikki Honan the role of spatial planning in HUDU Where do we want to be? Health and social supporting the promotion of Support infrastructure could be supported in town centre public health. The Noted – No Action locations as a priority in order to meet Infrastructure Delivery Plan accessibility and sustainability objectives. will address the need for Although health and well being could be a cross health and other infrastructure cutting issue, this could be reiterated in the provision. consideration of the future of the metropolitan centre by referring to social cohesion, a healthy centre, reducing health and social inequalities and access to social infrastructure. page43/questionmc3 The Report also suggests that masterplans will Some masterplans will set be developed for significant development sites massing strategies for the Menta that will provide "massing strategies for tall area, however in other Object buildings". We would question how this will be instances masterplans will set Disagree – No Change achieved. Whilst masterplans may reasonably footprints for development identify certain locations for tall buildings in with only indicative massing. principle, the acceptability or otherwise of a tall Each masterplan will make the building and its ‘massing’ will be judged through level of detail explicit during technical environmental assessments that would future masteplan consultations. be unlikely to take place for the purposes of a 'masterplan' or Core Strategy. page43/questionmc3 Question MC3 - Do you agree with where we Proposals for Croydon want to be? Metropolitan Centre will be Menta developed through an Object The options are stated to be delivered by Opportunity Area Planning Noted – Propose Changes defining "functional quarters establishing the Framework and a series of quantum of development and broadly allocate a masterplans. The Council will balance of use to each quarter, so encouraging work with mixed use development". This is considered to developers/landowners to be overly simplistic approach unlikely to deliver ensure viable development the spatial aspirations. In particular, it appears to proposals come forward. take no account of development viability or feasibility. As noted above, the Cherry Orchard Road area is of particular importance in terms of regeneration but is not identified within a 'quarter'. page41 A 'Greenlink' is shown crossing the railway to The green links will be the north of East Croydon Station in the developed through the Core Menta 'Potential spatial options' plan. It is not clear Strategy and work on the Observation whether this is proposed to be a new vehicular Infrastructure Delivery Plan Noted – Propose Changes and/or pedestrian access. If the link is a (incorporating green proposed access, we are not aware of any infrastructure), masterplans feasibility work that has been undertaken to for Croydon Metropolitan demonstrate whether this could or could not be Centre. achieved. page41 The 'Potential spatial options' plan identifies land Further information on the role to the east of the railway line as 'Intermediate of this area will be developed Menta areas' whereas land to the west is 'Main areas as part of an East Croydon Object for regeneration'. The difference between these masterplan. Noted – No Action two designations is not explained in the Report. Land to east of the railway line is however in significant need of regeneration and is important in terms of successfully achieving improvements to the station. In regeneration terms, the Cherry Orchard Road area is of equal importance to land west of the railway line and it should therefore be designated as 'Main areas for regeneration'. page41 Similarly, the Cherry Orchard Road area is not The areas shown on the recognised in the 'Potential spatial options' plan diagram are for illustrative Menta (p41). The Cherry Orchard Road area is purposes are designed to Object however partly within a 'Project area' that we show exact boundaries. It is Noted – No Action assume relates to the study area being indicative of the East Croydon considered through the East Croydon masterplan area. Masterplan. This 'Project area' does not however coincide with what we understand to be the East Croydon Masterplan study area. Land to the west/south of Cherry Orchard Road should be identified in the 'Potential spatial options' for high density mixed use development, including tall buildings, that maximises the potential of this highly accessible site whilst improving the public realm and permeability. page39 The 'Spatial issues' plan (p39) identifies various The concept of 'quarters' will 'quarters' within the Croydon Metropolitan be discontinued in favour of Menta Centre (CMC). The plan does not however work on masterplans and the Observation identify land to the east of the railway tracks on Opportunity Area Planning Noted – Propose Changes Cherry Orchard Road as a 'quarter'. This area Framework. should be identified as a 'quarter' and should include land to the west of Cherry Orchard as well as the Cherry Orchard Gardens/meatpackers sites to the south of Cherry Orchard Road. We are aware that this area is being considered in the ongoing East Croydon Masterplan work. The 'Spatial issues' for this area are that there is a significant need for regeneration in a key location, immediately adjacent to East Croydon Station, that currently suffers from poor townscape quality, under utilisation, vacancy, dereliction and poor permeability. page33/para2/bullet1 I think Croydon should think more about the This level of detail on Mr Bill Tubb schooling of young people ‘in Care’. As a education provision is not a Trustee of the Reedham Trust, that assists matter for the Core Strategy. Observation children in need by offering education at No Action – Not an LDF Is boarding schools. This type of solution would suit many children currently ‘in care’, plus saving the Council money. Unhappily as with many decisions, politics does not obey reasoned argument? page36/para2/question We would also like to see the core strategy Reference to ensuring that Nikki Honan LC2 ensuring leisure facilities etc are safe and leisure facilities are safe and HUDU accessible for all. accessible for all will be Object incorporated in the next Agree – Propose Changes consultation draft of the Core Strategy. page36/para2/question We would seek to ensure that recreational Whilst the Core Strategy Nikki Honan LC2 facilities are culturally appropriate and respond seeks to address the needs of HUDU to needs of minority communities. Croydon's BME communities, Object the day-to-day management No Action – Not an LDF Is of recreational facilities is not a matter for the Core Strategy. page33/para1 It was interesting to read of all the new The Core Strategy is not able Mrs P Pigram developments in the Croydon Talk leaflet, to influence education policy particularly with regard to education and the new in other boroughs. Observation academies. These are fine but what will happen No Action – Not an LDF Is to Edenham and Shirley High Schools? Will children still be “bussed in” in even greater numbers from the Inner London boroughs? Surely the answer is that their local schools should be improved! page43/questionmc1-4 A comment on Questions MC1 to 4 relating to The support is welcomed. Mr Andrew the Croydon metropolitan centre is to support Walters the objective noted on page 37 (bullet4) to Biggin Hill Airport Limited improve transport connections between the Support centre and rest of Croydon and the sub region. Agree - No Action This is clearly in line with the Outer London Commission’s interim conclusions on transport to create hub and spoke networks. page34/para2/bullet3 A place of opportunity – This section refers to a The Infrastructure Delivery Ms Alison borough wide infrastructure plan. How is work Plan is being developed Fairhurst progressing on this? alongside the Core Strategy. Government Office for London Observation Noted – No Action page43/questionmc3 We support the reference to community The support is welcomed. Nikki Honan infrastructure, and welcome continued HUDU partnership working between the Council, PCT Support and other partners to plan and deliver this. Agree - No Action page30/para1/bullet2 The document advises that Croydon lacks The support is welcomed. A sufficient space for new business growth and review of the Office Market Croydon Gateway Limited some existing space within the Metropolitan Assessment will inform the Partnership Centre does not meet current commercial next consultation draft of the Support demands. CGLP support the option that the Core Strategy on the need Agree - No Action Council will encourage the development of new, and location of new offices in replacement Grade A modern offices on existing Croydon Metropolitan Centre. office sites in the CMC. page43/questionmc4 The fifth bullet under ‘Where do we want to be?’ The relationship between Nikki Honan notes the need to ensure quality design and public realm and health will be HUDU public realm to enhance the image of the addressed in the next Object borough. We would note that such interventions consultation draft of the Core Agree – Propose Changes may have positive impacts on social well being Strategy. and mental health. page43/questionmc2 What are the Options for change? We support The support is welcomed. Nikki Honan the introduction of new pedestrian, cycling and HUDU public transport and connections between Support spaces, which encourages more activity, Agree - No Action accessibility to services and contributes to the overall well being of the community. page32/questionsBIE1- In response to Questions BIE1 and 2, we would The support is welcomed. Mr Andrew 2 wish in particular to support the development of Walters Croydon town centre and the promotion of Biggin Hill Airport Limited Croydon as a business location for specific Support sectors. In addition, the Outer London Agree - No Action Commission’s proposals to make Biggin Hill Airport a Strategic Outer London Development Centre could add around 500 jobs which would be accessible by residents of Croydon, particularly from nearby New Addington. With cross borough working and improved transport links these jobs could be of great value to Croydon and should therefore be considered as options for business, industry and employment page34/QuestionES1 Generally yes, but others could emerge during The comment is noted. Mr I.G.M. Hunter consultation. Support Noted – No Action page34/QuestionES2 There may be, but see QES 1 above. The comment is noted. Mr I.G.M. Hunter

Observation Noted – No Action page35/para1 A specific comment is relevant under the The comment is noted. Mr Andrew heading of ‘Culture & Leisure’ related to the Consideration will be given as Walters 2012 Olympics. The Airport is involved in the to how to build upon Biggin Hill Airport Limited planning of transport for this through the Croydon's links to Biggin Hill Observation Olympic Delivery Authority and the Department and other nearby airports. Noted – No Action for Transport. For major events such as the Olympics, the demand for aviation facilities is significant and Biggin Hill Airport will play a major role in serving specific sectors. This gives a major opportunity to Croydon as a gateway for the Olympics. page22-23 For the reasons outlined in paragraphs 7-9 Although Croydon (below), new employment development should Metropolitan Centre has a Highways Agency be mainly focussed in Croydon Metropolitan high level of public transport Observation Centre. This area currently has a high level of accessibility it is a not a Disagree – No Change public transport accessibility sufficient to support suitable location for all types additional employment trip movements. of employment development. page36/Questions The Airport also provides two other key activities The comment is noted. Mr Andrew LC1-LC2 under the Culture & Leisure heading (Questions Walters LC1 and 2). Flying training and private flying are Biggin Hill Airport Limited leisure pursuits undertaken by significant Observation numbers, both as training towards qualifications Noted – No Action and for straightforward leisure, perhaps associated with other sports (eg. golf). Secondly, people like to visit airports to watch the flying activity and to discover some of the history. The Airport’s new hotel, for which planning permission has now been granted, will partly meet this demand in its coffee shop. Planning permission has also been granted for a heritage centre at Biggin Hill. This will be operated by Biggin Hill Trust and funded by S106 contributions from the adjacent Leavesden Housing Development. These activities are unique to the sub region and provided just across the borough boundary, so are clearly an area for cross-borough co-operation (Questions HC1 and 2). page38/para1/bullet2 This review is ongoing. While the exercise has The comment is noted. yet to be concluded, it appears unlikely that Minerva Minerva will be bringing forward a new Observation application to extend the life of the Noted – No Action scheme in the form that was approved in 2004. Page40/Para2/Bullet1 The potential to improve biodiversity and the The support is welcomed. Mr David ecology of the Metropolitan Area (page 41), Hammond together with the enhancement of existing Natural England open/green spaces, provision of new Support green/open spaces and improvements to the Agree - No Action links between and to open/green spaces within the Metropolitan area are both welcomed and supported. page40/para1/bullet2 In delivering options for change within the CMC, A modified approach towards CGLP do not consider that defined ‘functional future development of Croydon Gateway Limited quarters’ that establish the quantum of Croydon Metropolitan Centre Partnership development and balance of uses is appropriate will be considered within Object for the CMC. Redevelopment proposals that future consultation drafts of Agree – Propose Changes come forward for individual sites within the CMC the Core Strategy and also an should be considered on their merits in terms of Opportunity Area Planning its design and appearance, quantum of Framework. Both will be development and mix of uses and should not be based upon a series of constrained by a pre-determined balance of masterplans for different parts uses for each quarter. The Council should take of Croydon Metropolitan into account the major regeneration schemes in Centre. the CMC and look to encourage their evolution so that these can adapt to meet economic and social needs and assist in the regeneration of the CMC. page43/questionmc1 Functional quarters need careful planning, The comment is noted. Ms Ann designation and design and this can be difficult Burroughs in a developer led environment. Multiple uses in Metropolitan Police the same space such as residential above cafes, Object bars or restaurants need careful planning to Noted – No Action avoid negative impacts on a particular group. page38/para1/bullet2 You are no doubt aware that Minerva is the The comment is noted. sponsor of a major retail-led town centre Minerva regeneration scheme known as Park Place Observation which includes all of the above sites, for which Noted – No Action planning permission was granted by your Council in May 2004 (Council Ref: 99/2350/P). page33/para2/bullet1 In my opinion Croydon also has also done well The comment is noted. Mr Bill Tubb in providing schools for special needs, there is one nearby me in Old Lodge Lane that has Observation recently built an extension. Noted – No Action page38/para1/bullet3 Within the Croydon Metropolitan Centre section The comment is noted. concerns are raised about anti-social behaviour Metropolitan Police within the Metropolitan Centre. Policy 3A.18 of Authority the London Plan states that policies in DPDs Observation should assess the need for social infrastructure Noted – No Action and community facilities in their area, and ensure that they are capable of being met wherever possible, this includes policing facilities. page42/para1/bullet9 Our client also has concerns over including the The comment is noted. intention to investigate the feasibility of building Barratt Homes (kent) over the railway tracks by East and West Object Croydon stations within the Core Strategy and Noted – No Action asks that the Council clarifies that this is part of Network Rails’ business plan. The Council and Network Rail would have to demonstrate that this is deliverable within the Plan period, and such proposals should not unnecessarily delay development of adjoining sites. page42/para1/bullet8 The consideration and provision of “living roofs” The support is welcomed. Mr David and more street planting within the Centre is Hammond also welcomed and supported and would link in Natural England with the comments in respect of PPS 9 above. Support The only consideration that Natural England Agree - No Action would ask the Council to be aware of is the use of native and indigenous species in all new planting schemes. page40/para1/bullet8 The potential to improve biodiversity and the The support is welcomed. Mr David ecology of the Metropolitan Area (page 41), Hammond together with the enhancement of existing Natural England open/green spaces, provision of new Support green/open spaces and improvements to the Agree - No Action links between and to open/green spaces within the Metropolitan area are both welcomed and supported. page40/para1/bullet8 As stated in London Plan Policy 3D.14, “The The comment is noted. This Mr David planning of new development and regeneration will be taken in account when Hammond should have regard to nature conservation and preparing the next Natural England biodiversity, and opportunities should be taken consultation draft of the Core Observation to achieve positive gains for conservation Strategy. Noted – Propose Changes through the form and design of development. Where appropriate, measures may include creating, enhancing and managing wildlife habitat and natural landscape and improving access to nature.” page40/para1/bullet6,8 Page 40 refers to the potential for new build to We will investigate requiring Mr David introduce new sustainable transport options and all new homes to meet Code Hammond green infrastructure which is welcomed and for Sustainable Homes Level Natural England supported and the following information may be 4 and other developments to Support of use to the Council in considering new meet BREAM "Excellent" Agree – Propose Changes applications; Biodiversity- Paragraph 14 of standard. PPS9: Biodiversity and Geological Conservation states that “Development proposals provide many opportunities for building-in beneficial biodiversity or geological features as part of good design. When considering proposals, local planning authorities should maximise such opportunities in and around developments, using planning obligations where appropriate.” page40/para1/bullet9 “Encourage the highest quality built environment This is not a matter for the Ms Ann with improvements to the Metropolitan Centre’s Core Strategy. It will be taken Burroughs public realm, making it feel safer, with better forward later in the Local Metropolitan Police connections between spaces, facilities and Development Framework Observation public transport, and creating a town centre that process. Agree - No Action is designed for people rather than vehicles.” This is an important aim recognising the importance of the “feeling of safety”. Croydon Borough Police submit that the Planning Department should actively promote partnership working and ensure continuing engagement with Police Crime Prevention Design Advisors (CPDAs) when considering regeneration projects such as the Croydon Metropolitan Centre Area Action Plan, Building schools for the Future applications and other Borough investment programmes affecting housing, commerce, culture & leisure. page34/para1/bullet2 I do not agree with the statement –shout for a The Council seeks to attract a Mr Bill Tubb University in Croydon- it is too silly a statement university to the borough as as though Universities are in shop windows and part of its strategy to be Object we buy one. Croydon has developed some fine London's third city. Disagree – No Change schools and we have a fine Technical College which is still growing and has a good reputation which is splendid and it should be able to continue to develop as need requires. page40/para1/bullet6 “Enhance and develop sustainable transport, The support is welcomed. The Ms Ann services and community infrastructures to allow infrastructure needs Burroughs for the future residential intensification and associated with the Core Metropolitan Police economic growth.” Strategy will be considered by Support the Infrastructure Delivery Agree - No Action This is very important and continuing Plan which will be developed engagement with partners and infrastructure alongside the Core Strategy. providers is essential as is the ability to negotiate section 106 agreements to enhance community safety. page31/bullet10 We very much support the aim to attract The support is welcomed. Mr Barry Atwood knowledge based industries, particularly on the Cane Hill site. Support Noted – No Action page43/questionmc2 “Plan the Metropolitan Centre into functional The comment is noted. Ms Ann quarters which provide facilities not only for Burroughs shoppers, workers and those visiting the town Metropolitan Police centre in the evening, but for all sectors Object including children and younger people as well as Noted – No Action older.”

It is important that the public realm is designed well to welcome and integrate all groups to the Metropolitan Town Centre. This should encourage diversity, cohesion and usage within the community. page51/para5/bullet2 “Together for a Safer Croydon” is the aim of the This is already included in the Ms Ann Safer Croydon Partnership. A greater emphasis Core Strategy. However it is Burroughs of this work should be actively promoted in the more appropriate to consider Metropolitan Police LDF Core Policy particularly aims and objectives community safety under A Object addressing a Place of Opportunity. Place to Belong. Agree - No Action page36/para1/bullet5 Multiple uses need careful planning, designation The comment is noted. Ms Ann and design giving consideration for conflicting Burroughs needs through the day & night. For example; Metropolitan Police residents living above cafes, bars or restaurants Observation may suffer from nuisance during evenings. Agree - No Action page36/para1/bullet5 “To redirect the growth and encourage the The comment is noted. Ms Ann dispersal of evening activities, to produce a Burroughs more diverse entertainment offer all ages.” Metropolitan Police Observation It is important that the public realm is designed Agree - No Action well to welcome and integrate all groups to the Metropolitan Town Centre. This should encourage diversity, cohesion and usage within the community. page31/para1/bullet10 The HCA notes that the last bullet point on page The Core Strategy does not 31 of the consultation document refers to seek a full science park at Homes and Communities “continue to push for a significant innovation and Cane Hill. However it is Agency knowledge based employment element to the considered that a significant Object proposed Cane Hill mixed-use development” as innovation and knowledge- Disagree – No Change an option for change. The potential for a full based employment element science park at Cane Hill has already been as part of a mixed use explored, and the resultant science park study development would be an prepared by Roger Tym and Partners jointly for appropriate option for Cane the HCA and Croydon Council concluded that Hill. this was not a feasible proposal. In the light of the requirement in PPS12 for the Core Strategy to be founded upon a “robust and credible” evidence base, it is entirely inappropriate for the Council to “continue to push” for a form of development which is demonstrably undeliverable. Furthermore, officers are well aware that the masterplanning work for Cane Hill, undertaken over the last two years, has not included any form of “science park”, precisely because of the outcome of the Roger Tym study. The HCA therefore strongly objects to the option for change that seeks a “significant” innovation and knowledge based employment element within the redevelopment proposals for the Cane Hill site. The HCA considers it would be more appropriate for market testing to assist in defining the mix and quantum of any employment uses on the site, which may include some business start-up/incubation units. page36/para1/bullet1 The HCA considers the “key locations” within the An Open Space and first bullet point on page 36 should be defined Indoor/Outdoor Leisure Study Homes and Communities within the Core Strategy, in order to provide is being prepared which will Agency clarity with regard to the proposed future inform the location of new Object locations of new swimming pools and indoor swimming pools and indoor Noted – No Action leisure facilities. leisure facilities. page35/para1/bullet3 We support the objectives, including in particular The support is welcomed. Mr Barry Atwood the refurbishment of the , the Whilst the Warehouse Theatre retention of the Warehouse Theatre and the is also a much valued local Support movement generally in the Metropolitan Centre asset a specific policy has not Noted – No Action to a more diverse entertainment culture. The been included as it does not Purley swimming pool should be upgraded (see have the same regional letter: para 15). significance as the Faifield Halls. An Open Space, Indoor and Outdoor Leisure Study is being prepared. This study will advise on the need for leisure facilities in the borough. page40/para1/bullet4,5, We generally support the objectives, including in The support is welcomed. Mr Barry Atwood 8 particular the preservation and enhancement of the historic character of the Metropolitan Centre, Support the provision of better and more accessible open Agree - No Action spaces (including the reinstatement of culverted rivers) and the creation of an improved pedestrian environment etc. in Wellesley Road. page43/question MC3 Recommendation: In response to question MC3 The comment is noted. The and in order to ensure the emerging Core infrastructure needs Metropolitan Police Strategy is consistent with the Statutory associated with the Core Authority Development Plan it is recommended that an Strategy will be considered by Object additional bullet point under the Section 'How do the Infrastructure Delivery Noted – No Action we deliver these options?' should be added Plan which will be developed which reads (additional wording underlined): alongside the Core Strategy.

• Working with the Metropolitan Police to provide adequate policing facilities within the borough. page40/para1/bullet6 As recommended by PPG13, development of The comment is noted. travel-intensive uses should be focussed within Highways Agency existing town centre and district centres which Observation are better served by public transport links. This Noted – No Action will minimise the impact of increased trips on the SRN and will also help ensure that the Strategy is in line with PPG13 paragraph 20 , and therefore meets PPS12 soundness requirement to align with national policy page40/para1/bullet9 The Crime reduction strategy refers to the large The comment is noted. Ms Ann number of children and young people who travel Burroughs through Croydon to get to and from school. Safe Metropolitan Police transport services are essential to encourage Observation sustainability. Agree - No Action page42/para1/bullet2 Minerva would wish to engage in early dialogue It is intended that detailed with the Council in respect of massing strategies design considerations will be Minerva particularly in the context of the suggestion in considered through a Observation the Potential Spatial Options, of the suitability of masterplanning exercise. Noted – No Action the South Central Area for ‘slender towers’. page38/para1/bullet2 Minerva is reviewing its strategy for its Croydon The comment is noted. town centre landholdings in view of market Minerva conditions and the changed physical, economic Observation & social context within which the Park Place site Noted – No Action is located. The planning policy background to this review is that Park Place is cited as a specific proposal in the current Development Plan. In the Croydon Unitary Development Plan (The Croydon Plan), as adopted on 13 July 2006, Park Place is identified as Proposal CMC3, for which the preferred uses are Shopping/Retail. page38/para1/bullet2 The Park Place planning permission granted in The comment is noted. May 2004 was subject to a condition that Minerva required a start on site within five years. Observation Subsequently, for a number of reasons, Minerva Noted – No Action did not commence the scheme on site and this permission has now lapsed. page29/para2 As recommended by PPG13, development of The comment is noted. travel-intensive uses should be focussed within Highways Agency existing town centre and district centres which Observation are better served by public transport links. This Noted – No Action will minimise the impact of increased trips on the SRN and will also help ensure that the Strategy is in line with PPG13 paragraph 20 , and therefore meets PPS12 soundness requirement to align with national policy. page 33 Bull point 3: If too many Academies emphasise The specialisations of Mr I.G.M. Hunter sporting specialisations the pathway mentioned academies in the borough is will not exist. Even now some Academies within not a matter for the Core Observation the Borough are discontinuing foreign languages Strategy. No Action – Not an LDF Is and lowering the standard of exams in subjects such as Science. Academies seem to be allowed to dictate what they want to emphasise and yet not be held accountable for their results (the Freedom of Information Act does not currently extend to Academies and this, unless changed, will prevent proper public scrutiny of the Academy’s direction and efficiency). It should be noted that such educational establishments will soon account for 25% of the Borough’s schools, a disturbingly large number of non-accountable institutions! page38/para1/bullet2 Minerva Plc own significant freehold and long The comment is noted. leasehold interests in a number of town centre Minerva sites. These extend from the southern side of Observation the Whitgift Centre in the north to Katharine Noted – No Action Street in the south. These interests include a significant part of the St. George’s Walk shopping centre, Katharine House, Ellis House and Segas House including the listed Segas House (East) at the junction of Katharine Street and Park Lane. Minerva’s holdings also include freehold and long leaseholds interest in the store on North End. page43/questionmc1 The Core Strategy states that most of the The Croydon Metropolitan borough’s growth opportunities are concentrated Centre and the A23 corridor Highways Agency in Croydon Metropolitan Centre and along the are not areas of low public Observation A23 corridor. Intensification of development in transport accessibility. A Noted – Propose Changes areas with a low level of public transport Borough-wide Transport assesibility (PTAL), could result in an increase in Strategy will be prepared to car trips which could in turn precipitate an address reducing the need to increase in congestion on the SRN if mitigation travel by car. measures are not in place to reduce the need to travel by car. page35/para2/bullet5 I sincerely hope Croydon never gives up on Comment is noted. Mr Bill Tubb Fairfield Halls. It is a good venue, in the right place, with car park and public transport all Observation about it. Its management team might be Noted – No Action improved with a little more expertise? But less interference from Croydon Council might be part of the solution? page29 On page 29, for example, the Council defines The comment is noted. Croydon as “a place of huge potential for new Barratt Homes (kent) business, industry and employment, potential for Observation world class education facilities, potential for a Noted – No Action wide variety of housing choices in high quality environments, and potential for new sports, culture and leisure facilities that will transform…residents’ opportunities to enjoy their borough”. It wants its town centre to provide a wide variety of retail, cultural and entertainment facilities (page 29) and for Croydon Metropolitan Centre to be a vibrant, appealing, world class metropolis (page 35-37). page35/para2/bullet5 The shortage of maintenance to the fabric is The management and Mr Bill Tubb typically evident in its ventilation. On those hot maitenance of the Fairfield summer nights, the enclosed auditoriums both in Halls are not a matter for the Observation Concert hall and Ashcroft get very sticky, Core Strategy. No Action – Not an LDF Is especially for those in the upper circles. Presently stewards cannot even open the fanlight windows! They are jammed or stuck. Not much money is needed to make some minor improvements. It is my feeling that the Council appear to rule and interfere too much. Any private business I think would set targets and see that these were met by regular meetings with a professionally qualified management team. Your report talks about the full range of cultural experiences yet presently the programmes include items from Women Wrestling to Ballet and Kids theatre to Grand Opera, Witches Festivals to Christian Sermons and Sri Lanka language comedy plays. page32/questionBIE2 Recommendation: In response to question BIE In this context the 2, the MPA support this statement, however Metropolitan Police are Metropolitan Police recommend that the wording be altered to read: considered a public service Authority rather than a community Observation • Widen the scope of permitted uses of the organisation. Disagree – No Change borough's 'scattered' industrial sites (the 1,000+ sites falling outside of designated Industrial Areas) and designated employment areas, where appropriate to allow for their reuse/redevelopment by faith organisations and other community organisations including the police). page35/para1/bullet3 Some of the comments regarding Fairfield Halls The management and Mr Bill Tubb are made without consideration of the facts and maitenance of the Fairfield as a volunteer Steward for several years I know Halls are not a matter for the Observation a little about the place. It is a very fine venue Core Strategy. No Action – Not an LDF Is and one Croydon should be proud and it deserves more regular building maintenance. Unhappily Croydon Council have in recent years (both Labour and Conservatives) run the place down, verbally and practically. The building includes two auditoriums, spacious corridors, several meeting rooms etc and a very large kitchen providing meals for delivery all over Croydon. It also gives a most flexible theatre and business centre. Several activities can be programmed to take place simultaneously in different parts of the building. However its size and flexibility require a good team to manage it all and this is I am sure its major challenge. page38/para1/bullet2 In paragraph 5.143 of the London Plan The comment is noted. Consolidated with Alterations adopted in Minerva February 2008, Park Place is considered as one Observation of a number of strategically important sites in the Noted – No Action Croydon town centre Opportunity Area for which an integrated approach needs to be taken. page42/para1 Perhaps the most significant part of the Issues & The comment is noted. Options Report is that within Section 3, entitled Minerva How do we Deliver These Options? We believe Observation that the development of a partnership framework Noted – No Action for the Metropolitan Centre, as suggested in this section of the report, brings together developers, infrastructure providers and representatives to address the issue of each quarter or significant development site. page40/1/bullet7 Minerva would strongly support the Council’s The support is welcomed. desire to encourage growth in and a greater mix Minerva with commercial, retail and other uses and to Support encourage the highest quality built environment Agree - No Action with associated improvements to the public realm of the Metropolitan Centre. page 41 Whilst the Park Place scheme, with its multi- The comment is noted. A level links across George Street, effectively masterplan will be prepared Minerva linked significant parts of these two areas, for this area. Observation Minerva is considering as one of a number of Noted – No Action options, the potential benefits of the separate development of the two sites looking at the sites separately. This could mean that the site to the north of George Street is considered in terms of the potential for the Central Area, whilst to the south of George Street would be suitable for major mixed use development, including residential and retail uses as anticipated by the Potential Spatial Options set out on page 41. page39 The plan entitled Spatial Issues on page 39 The comment is noted. identifies a number of problems of which (2) the Minerva Central Area and (6) the South central area are Observation of particular relevance to Minerva. Noted – No Action page38 As an Opportunity Area and a Strategic Office The comment is noted. Location in the London Plan, the town centre is Minerva clearly recognised as one that has significant Observation potential in the metropolitan context. Under the Noted – No Action Where are we now? heading on page 38 the Council clearly recognises a range of issues that need to be addressed, not least of which are the quality of the public realm and the fact that much of the town centre’s office stock is now outdated and its retail offer has lost ground to other centres. page37 The Council’s aspirations for the Metropolitan The comment is noted. Centre, as set out on page 37 of the document, Minerva are to be welcomed and Minerva intends to play Support its part in delivering these objectives. Noted – No Action page36/para2/question Minerva would support the Council’s aspirations The comment is noted. LC1 to develop a more varied cultural and night time Minerva economy in the Metropolitan Centre and would Support expect to play its part in delivering this objective Noted – No Action through the development of its own site(s). The creation of a better quality offer was a key component of the Park Place scheme and will continue to be an important objective for Minerva in connection with any new proposals. page36/para2/question Question LC 1. The comment is noted. LC1 Minerva The overriding theme of the culture and leisure Observation section of the Issues & Options document is of a Noted – No Action vibrant metropolitan centre with a range of facilities for the whole of the population. page32/para6/bullet6 Minerva would support the Council’s objective of The support is welcomed. progressing these economic development Minerva objectives by bringing forward a co-ordinated Support framework for the Metropolitan Centre through Agree - No Action an Area Action Plan/Opportunity Area Planning Framework page32/questionBIE1 Question BIE 1. The support is welcomed. Minerva Minerva would reiterate its support for an Support approach that focuses office and retail activity in Agree - No Action the town centres, encourages more intensive and mixed use development in selected areas and particularly in the Metropolitan Centre where new replacement modern retail and office development are best located. page31/para1/bullet4 Within the heading, 'Business, Industry & The London Plan designates Employment- What are the Options for Change', Croydon as a 'Restricted Metropolitan Police bullet point 4 suggests widening the scope of Transfer Borough'. An Authority permitted uses of the borough's 'scattered' Employment Land Review will Object industrial sites. This statement complies with be prepared to inform the Disagree – No Change London Plan Policy 3B.4 (Industrial Locations) need to release sites. which highlights the potential for surplus industrial land to help meet the strategic and local requirements for a mix of other uses such as housing and social infrastructure where appropriate. It is therefore considered that the emerging Core Strategy is amended slightly in order to fully reflect the Strategic Development Plan. page43/questionmc3 London Plan policy 5E.2 and table 5E.1 identify The comment is noted. Mr Michael Croydon Town Centre as an Opportunity Area Mulhern with the capacity to accommodate approximately Greater London Authority 5,500 new jobs and a minimum of 2,700 new Observation homes by 2016. Proposals to prepare a Croydon Agree - No Action Town Centre Area Action Plan / Opportunity Area Planning Framework to examine the opportunities and potential quantum of development are supported, and discussions are currently under way with the Greater London Authority and Transport for London. The need to identify potential capacity, infrastructure requirements (including transport) and mechanisms for delivery are key to this. page43/questionmc3 We are concerned with the potential of The retail study for Croydon Mr Robert Croydon’s retail capacity. It would benefit Metropolitan Centre will be Hayward Reigate & Banstead if your quantums of retail updated and will inform the Reigate & Banstead floor space complement the capacity planned for next consultation draft of the Borough Council other parts of the region, with particular Core Strategy and the Object reference to Redhill – our primary regeneration Opportunity Area Planning Noted – Propose Changes area; as well as those centres surrounding Framework for Croydon Croydon. Metropolitan Centre. page43/questionMC1 Whilst we are in agreement with majority of the A district heating scheme is Miss Wendy strategic options proposed under Croydon considered to be important to Wong Chang Metropolitan Centre we do not agree with the reducing carbon emissions in Berkeley Homes (south following option: the borough. Further work will East London) Ltd be carried out to assess the Object - Provide a sustainable heating and energy viability of the scheme. Disagree – No Change scheme for the Metropolitan Centre and require all developments to be part of this scheme

The Council need to provide more details on the sustainable heating and energy scheme before inviting further comments. However, we are of the opinion that the Council should not require all new developments to be part of this scheme if the Croydon Plan already requires all new development to achieve Code for Sustainable Homes Level 4. page43/questionmc1 The document also highlights issues and options The comment is noted. for Croydon Metropolitan Town Centre. BRB BRB (Residuary) Ltd (Residuary) Ltd would support improvements to Observation the town centre, and in particular consider that Noted – No Action sites, such as the BRB (Residuary) Ltd Lansdowne Road site would contribute towards the wider objectives, if they were not constrained and allowed to come forward for development. This is particularly relevant for the BRB (Residuary) Ltd Lansdowne Road site as the area around East Croydon station is potentially identified in the document as being a ‘project area’ and is also partially within the main regeneration area of Croydon Town Centre. page32/questionBIE1 BRB (Residuary) Ltd would consider the It is not inappropriate for Borough’s aspiration for the economy in industrial sites to be located BRB (Residuary) Ltd Croydon, employment and Town Centres to be within a town centre. The Object positive. However there is one aspect of the intention of this option is to Disagree – No Change options for employment land that is considered consider carefully any to hinder growth and achieving many of the proposal to change the use of other aims and objectives in the plan. An option industrial sites within the identified of industrial land is to widen the borough. application of an existing policy which protects ‘scattered’ industrial sites to cover all industrial sites in town centre. BRB (Residuary) Ltd considers that all industrial sites should be considered on their merits. The location of such sites should be a contributing factor as to whether they should remain in use as industrial land, as industrial activities should be located on appropriate sites. page32/questionBIE1 The BRB (Residuary) Ltd site at Lansdowne There is no proposal to bring Road is in an area where there is an existing forward a 'blanket' policy BRB (Residuary) Ltd residential use, and proposed future applying to all industrial land. Observation intensification of residential use, and it is Noted – No Action considered that a site such as this should not be precluded from coming forward for development by applying a ‘blanket’ policy on all industrial land, as this would hinder future development opportunities. page36/para2/question Consider providing a covered market area, The comment is noted. Mr Norman LC2 perhaps as part of the Park Place development Cooper to replace or enhance the current . Observation Noted – No Action page34/para1/bullet6 A blacksmiths foundry would be nice for people The comment is noted. Miss Jean interested in metalwork as currently most Newman substantial courses are a long way off in the countryside and very expensive, mainly Observation operated by people as a business concern. Noted – No Action page35-36 no mention of the implications of a large youth Consideration will be given in Cheryll Wright population – given that most crime is committed the next iteration of the Core Safer Croydon Partnership by young people aged 16 to 24 and that Strategy to education and the Observation Croydon has one of the largest youth implications of population Agree – Propose Changes populations of all the London boroughs, plus it growth. has 2 central transport hubs with some 50,000 school children travelling through Croydon during term time – the links with implications for crime and asb and our youth population are not strong enough Page33/para7/bullet5 Provision must be specifically made and The objection is noted. The Mr Nafi Djemil identified in black and white for the needs of Core Strategy seeks to meet disabled people , as well. the needs of all residents of Observation 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. page35/para2/bullet6 New Bullet point 6: We should also emphasise The Warehouse Theatre is Mr I.G.M. Hunter the importance of the Warehouse Theatre referenced within the Core functions and be prepared to subsidise this Strategy, but it is not the role Object venue as a valuable cultural asset to the of the Core Strategy to Disagree – No Change Metropolitan Centre, as the Fairfield Halls are. determine the subsidy of cultural venues. page43/questionmc1 Core Strategy proposals for the Croydon Reference to a circular bus Mr Michael Metropolitan Town Centre currently make route will be removed and Mulhern reference to the provision of a circular bus route. replaced with an emphasis on Greater London Authority This specific proposal should be replaced by a improving bus routes and Object more general reference to improving bus routes supporting infrastructure. Agree – Propose Changes that serve the metropolitan centre to provide greater flexibility in devising appropriate solutions. A reference should also be made here to enhanced bus priority and infrastructure including stands that will be needed to support future bus service improvements. page42/para1/bullet9 The exciting change for Croydon will be the The comment is noted. Miss Jean arrival of the tube to WEST CROYDON next Newman year 2010 contributing in a major way to enhancing the transport situation and must Observation inevitably contribute to boosting the economy of Noted – No Action the town and I am sure additional rail station capacity will naturally follow on from this, as most certainly will additional housebuilding in the area as has always traditionally been the case when a new tube station arises page38/para1/bullet8 Cultural facilities within the centre of Croydon The maintanence of the Mr Pitts must be maintained to a high standard in order Fairfield Halls is not a matter to make them attractive to the resident for the Core Strategy. A Observation population. In particular, the Fairfield Halls and Masterplan will be prepared Noted – No Action the adjacent car park have not been maintained for the area surrounding as they should be and so give an unwelcoming Fairfield Halls. The need for impression. Facilities such as swimming pools swimming pools will be are also sadly lacking within the centre. assessed as part of an Open Spaces and Indoor and Outdoor Leisure Study. page36 Specifically there should be a link between the The Infrastructure Delivery Mr Norman approval of planning application and the Plan will look at setting a tariff- Cooper provision of new leisure facilities . based system on new development to ensure Observation contributions towards any Noted – No Action required infrastructure based on a needs assessment. page30/bullet5 We consider that the draft Core Strategy is This will be considered in a Mr Ed Kemsley currently deficient in this respect and should be future iteration of the Core Peacock & Smith Limited founded on robust and credible evidence (key Strategy. Object test of soundness – paragraph 4.52 of PPS12). Noted – Propose Changes In light of this we would suggest that that the Core Strategy should include the forecast capacity as set out within the 2008 Retail Needs Update. The Retail Needs Update is intended to form part of the evidence base for the emerging LDF. However, we note that the draft Core Strategy does not make any specific reference to this identified need. Government guidance contained in PPS6 clearly states that through Local Development Documents, Local Planning Authorities should assess the need for further main town centre uses and ensure that there is capacity to accommodate them. The Core Strategy should contain a realistic assessment of need for retail development in Croydon for both comparison and convenience retailing. We consider that the draft Core Strategy is currently deficient in this respect and should be founded on robust and credible evidence (key test of soundness – paragraph 4.52 of PPS12). In light of this we would suggest that that the Core Strategy should include the forecast capacity as set out within the 2008 Retail Needs Update. page38/para1/bullet3 The image of the Whitgift centre needs to be The comment is noted. Mr Pitts improved. At present it is no longer regarded as a safe shopping centre and people are turning Observation their allegiances to other centres such as Noted – No Action Bromley, Blue Water and Oxted where they feel safer and where the service is personalised. page37/para2 Development of this central area can be The support is welcomed. Mr Pitts addressed by providing new additional housing and community facilities Support Agree - No Action page34/para1/bullet6 In the present climate of unemployment really The Core Strategy is unable to Miss Jean there should be specialist training via a local influence the sylabus or Newman college for youth who would be much better courses offered by local suited to craft skill training and for older people. colleges. Observation Practical skills such as bricklaying, carpentry, Noted – Propose Changes electrical, plumbing etc should be available to people locally e.g. there is virtually nothing in Thornton Heath and people often have to travel to neighbouring boroughs to acquire these skills and in the case of people looking for a work change the time and cost involved could be prohibitive. page36/para2/question Q LC 1 – All seem workable with amendments The comment is noted. Mr I.G.M. Hunter LC1 derived from the above comments. Observation Noted – No Action page31/para1 The Council supports the general direction of the The comment is noted. Mr Robert proposed Options for Change but seeks clarify Hayward on the scale in future policies. Reigate & Banstead Borough Council Support Noted – No Action page31/para5/bullet5 A significant increase in employment Croydon's Core Strategy is Mr Robert development would be in direct competition with required to be in conformity Hayward the Regional Hub Redhill – Reigate, which is with the London Plan which Reigate & Banstead identified in the South East Plan as an area for designates Croydon Borough Council economic growth and is located less than 10 Metropolitan Centre as an Object miles away. Opportnuity Area, a Strategic No Action – Not an LDF Is Outer London Development Centre and a Strategic Office location of greater than subregional importance. page42/para1/Bullet5 Bull point 5: No residential growth should be Disagree. There is no reason Mr I.G.M. Hunter planned in what can only be considered Cultural why new residential Zones, eg: around Queens Gardens which is development could not Object generally recognised as the centre of the Town, complement other town centre Disagree – No Change The assumption that the Metropolitan Centre uses. It is accepted that it will should contain more than half the new homes to be a significant challenge to be provided in Croydon should be challenged as deliver the necessary unworkable in view of their associated infrastructure to enable half of infrastructure (provision of utilities etc). Consider all new homes to be built in this as new option. CMC but considers it to be achievable. page42/para1/Bullet2 Bull point 2: It is critical that, at all stages of this All masterplans will be subject Mr I.G.M. Hunter activity, particularly at the outset, the views of to full consultation with residents, as well as stakeholders, are sought; it residents. Observation is not acceptable to present any proposal that Noted – No Action does not have residents endorsement. Consider this as new option. page40 What are the options for change. Development of the core Mr I.G.M. Hunter strategy is influenced by past Comment: Nearly two years ago the Council visioning exercises. However, Object undertook an exercise, very similar the “Imagine their influence needs to be Disagree – No Change Croydon” but confined to an assessment of what balanced against the "Imagine Croydon residents and other stakeholders would Croydon" exercise. This is the like to see developed over the next 20 years in most extensive consultation the Croydon Metropolitan Centre. All options for ever undertaken by the change shown on page 40, including the special council and has been used to issues reported on page 39 were identified and develop the Sustainable what became the “Issues and Options” exercise Community Strategy. As the was contributed to by over 1000 detailed Core Strategy is the spatial proposals. No mention at all of this major interpretation of the initiative , which received much support from Sustainable Community interested residents has been made in this Strategy, it has to be directly present document. It is as if the work and all the related to it, rather than earlier effort put into it, has disappeared. This is a visioning exercises. disgrace; more so since many proposals have been overtaken/supplanted by Council/developer projects that have not been universally popular –eg: the new Urban Hub, and the Greening of Wellesley Road (see also my responses to the Bull points on Page 42). No mention at all of this major initiative, which received uch support from interested residents, has been made in this present document. It is as if the work and all the effort put into it, has disappeared. This is a disgrace; mores so since many proposals have been overtaken/supplanted by Council/developer projects that have not been universally popular - e.g. the new urban hub, and the greening of Wellesley Road (see also my responses to the bull points on page 42). It is accepted that “Imagine Croydon” represents a future look at what the Borough (including the Metropolitan Centre) might look like in 20 years but the document should have indicated, where relevant, that some options had already been closed down and commitments already made. If the response is that such projects have been progressed under the previous Core Plan this should have been mentioned. It was a deception not to have done so and devalues the initiatives sought by this exercise. page39/spatialissue11 Spatial issues Area 11. This purports to describe A future iteration of the core Mr I.G.M. Hunter “East of Centre”, but no reference is made to the strategy will recognise existing proposed Park and new theatre activity in this area. Object Warehouse Theatre or that the existing theatre Agree – Propose Changes provides a cultural focus that indicates not all the area is “dead at night”. This should have been mentioned. page38/para1/Bullet8 Bull point 8: Why is there no reference to the The list of facilities is not Mr I.G.M. Hunter Warehouse Theatre which, according to the intended to be exhaustive. Council (page 35-where are we now Bull point Object 6), has some degree of significance. Noted – No Action n/a As indicated above the formulation of policy The comment is noted. does not exist in isolation and there are Detailed planning policies will Mobile Operators numerous documents which will affect the be developed later in the Assocaition formulation of any telecommunications policy, Local Development Observation the most important of these being PPG8. On this Framework process. Agree - No Action basis we would suggest that within the Local Development Framework there should be a concise and flexible telecommunications policy contained within one of the Council’s statutory Local Development Document. We recognise that this is likely to be contained in a Development Control/Management DPD rather than the Core Strategy which is of a strategic nature. Such a policy should give all stakeholders a clear indication of the issues which development will be assessed against. We would suggest a policy which reads; Proposals for telecommunications development will be permitted provided that the following criteria are met: - (i) the siting and appearance of the proposed apparatus and associated structures should seek to minimise impact on the visual amenity, character or appearance of the surrounding area; (ii) if on a building, apparatus and associated structures should be sited and designed in order to seek to minimise impact to the external appearance of the host building; (iii) if proposing a new mast, it should be demonstrated that the applicant has explored the possibility of erecting apparatus on existing buildings, masts or other structures. Such evidence should accompany any application made to the (local) planning authority. page36/para2/question Q LC 2 – Yes; the Fairfields halls study should The Council will consider the Mr I.G.M. Hunter LC2 be expanded to include consideration of other need for and location of forms of auditoria where cultural and leisure cultural facilities in the Object activities take place eg: Cinemas, sports arenas borough as part of a Cultural Disagree – No Change etc. Mapping Study. page31/para5/bullet2 The Council should not impose a blanket policy The comment is noted. N Kwan to protect industrial sites, but treat the potential Fairview New Homes redevelopment of in particular 'scattered' Object employment sites, which are disused or Noted – No Action underutilised, on a flexible, realistic and viable case by case basis. page43/questionmc3 Question MC3 Yes – Generally yes, however The comment is noted. Mr Robert whilst it is agreed that CMC should have a Posselt greater residential function and that this Martin Robeson Planning contributes to a vibrant centre, a majority of new, Practice larger homes, more suited to families should be Observation developed in suburban locations or those within Noted – No Action district centres and adjoining the metropolitan centre. Potentially lower density parts of the CMC may also be suitable. These locations are better able to provide the type of accommodation better suited to families i.e. not high density high rise where private amenity space can more readily be provided and are closer to essential community facilities such as recreational and open space. This should be recognised within the text of the strategy for the CMC. page27/questionG1 The Council has concerns about the potential More details on the quantum Mr Robert scale of development proposed in the options. of development will be Hayward The range of options proposed is not quantified, included in the next Reigate & Banstead and suggest a significant increase in the scale of consultation draft of the Core Borough Council employment, particularly office development. Strategy. Object Noted – Propose Changes Page36/para1/bullet4 Bull point 4 should recognise therein that a It is not necessary for the core Mr I.G.M. Hunter review of Cultural strategy is important. strategy to set out the review timetable for the sub- Object strategies by which it is Disagree – No Change informed. page35/para1 Bull point 4: The worrying phrase here is The phrase "commercially Mr I.G.M. Hunter “commercially sustainable cultural offer”. sustainable cultural offer" Although the working lives of our population are recognises the difficulty of Object to be extended there will still be an increasing securing medium/long term Disagree – No Change number of elderly, healthy, relatively active funding for cultural activity. It adults who would wish to enjoy a wide and is not the role of the Core varied cultural and leisure lifestyle within the Strategy to determine the Borough. In 10-20 years time the principle of subsidy of cultural venues. free travel cards may well have been extended to cultural and leisure activities, which in some instances already now provide discounted charges, subsidised by full-fee paying individuals. Ultimately, the cost of such subsidies could be borne by local and national taxation. If this proposed Core Strategy is already to be constrained by such phrases as “commercially sustainable cultural offer” – ie: if the service cannot make a profit it should be allowed to fail as a business (something this Council has already said about the Warehouse Theatre) then the Cultural/Leisure and Sporting choices of Croydon residents will become progressively more limited, inevitably leading to no culture except that which makes a profit, and that not for the residents. This is not the way a civilised society should conduct itself in the twenty-first Century. Even though the Warehouse Theatre, for example, will be re-built by the developer of the Gateway site, its running costs, beyond a certain time, will have to be found by the Theatre itself. Positive consideration will, again, need to be given to the matter of subsidy in the same way as for Fairfield Halls. page35/para2/bullet1 Bull point 1: Purley Pool is at a key location, it The comment is noted. The Mr I.G.M. Hunter should not be closed but refitted as more such infrastructure needs facilities are needed for population growth and associated with the Core Observation public health. It is a well-sited pool at a major Strategy will be considered by Noted – Propose Changes transport confluence and would easily attract the Infrastructure Delivery greater numbers of residents. Plan which will be developed alongside the Core Strategy. An Open Space, Indoor and Outdoor Leisure Study is being prepared. This study will advise on the need for leisure facilities in the borough. page35/para2/bullet6 Bull point 6; This point should be expanded to While the council Mr I.G.M. Hunter include the fact that it is also a young peoples acknowledges the value of the theatre and used to have a subsidy which Warehouse Theatre, it is not Object should be reinstated; given its cultural the place of the Core Strategy No Action – Not an LDF Is importance to the Core Plan. to determine the subsidy of cultural venues. page35/para2/bullet2 Bull point 2: If more spaces are required why The comment is noted. The Mr I.G.M. Hunter seek to close Purley Pool in favour of new pools infrastructure needs further along the A23 corridor. Purley is a main associated with the Core Object transport hub and is likely to be for the Strategy will be considered by Noted – Propose Changes foreseeable future. If the pool were to be the Infrastructure Delivery upgraded and refurbished it would form part of Plan which will be developed an increasing number of such facilities and, alongside the Core Strategy. because of its position would attract even more An Open Space, Indoor and people. Moreover, instead of destroying Outdoor Leisure Study is Taberner House to make way for housing being prepared. This study will development (in what is manifestly Croydon’s advise on the need for leisure cultural centre), the building should be modified facilities in the borough. for use as a swimming pool, Gymnasium and Borough Museum. page38/para1/Bullet5 Bull point 5: Reference should have been made This is a subjective view that Mr I.G.M. Hunter to poor planning approvals which failed to the council does not share. ensure adequate “off-street parking”. Object Disagree – No Change page38/para1/bullet1 The document notes that the Centre has a The comment is noted. reputation for poor architecture but there are Croydon Gateway Limited several large development and regeneration Partnership schemes that have the potential to offer positive Observation change, but are yet to start. The CGLP scheme Noted – No Action adjacent to East Croydon Station is one such a major scheme that will provide a positive change to the CMC and is acknowledged as a landmark development with world class quality and function. page30/para1/bullet4 Purley Way is an established retail location Whilst Purley Way is an which forms part of the Croydon shopping established retail location, it is B&Q Properties Ltd hierarchy and it is important that the role and part of the retail hierarchy as Observation function of Purley Way is recognised in the Core defined by the London Plan. Disagree – No Change Strategy. page31/para1/bullet2 Purley Way is an important arterial route for The support is welcomed. Mr Michael distribution, warehousing, wholesale and other Mulhern retail businesses/facilities. The strategy to Greater London Authority protect land for industrial / warehousing/ Support environmentally sensitive uses in this area, Agree - No Action which will help to prevent freight vehicle related congestion from negatively affecting other routes with less capacity, is supported. page26/para2 CNRA’s support for option 2 are therefore This will be considered by the Mr Stephen dependent on the following being delivered for forthcoming Borough Leadbetter Norbury: Consideration of how the A23 can best Transport Strategy. Central Norbury be improved, or supported by other routes, to Residents' Association deal with the increase in road traffic Support Noted – No Action page34/questionES2 . Those that are accessible to the public should The comment is noted. Mr Ross Gentry be letting more people know they are. LBC Observation Noted – No Action page34/questionES2 Existing school facilities should be made more Reference to the co-location Mr Ross Gentry publicly accessible. of facilities will be included in LBC the next consultation draft of Observation the Core Strategy. Agree – Propose Changes n/a When considering applications for The comment is noted. telecommunications development, the (local) Mobile Operators planning authority will have regard to the Assocaition operational requirements of telecommunications Observation networks and the technical limitations of the Agree - No Action technology. n/a If proposing development in a sensitive area The comment is noted. (with respect to telecommunications), the Mobile Operators development should not have an unacceptable Assocaition effect on areas of ecological interest, areas of Observation landscape importance, archaeological sites, Agree - No Action conservation areas or buildings of architectural or historic interest. page37/para2 The centre of Croydon needs to be maintained The comment is noted. Mr Pitts as a commercial and business town as well as for retail shopping. Support Agree - No Action page30/para1 There is a need to avoid sterilising large areas of An Employment Land Review Mr Austin Mackie land, much of which is outworn and not suited to will assess our employment Austin Mackie Associates modern purposes, in particular where such designations and the findings Ltd locations adjoin residential areas and have an will inform the next Observation adverse impact upon the quality of the consultation draft of the Core Noted – No Action residential environment. Strategy. page30/para1/bullet4 It is important that the Core Strategy seeks to The Core Strategy will enhance the Purley Way corridor, not work promote policies that are in B&Q Properties Ltd against it, and the role of its retail function conformity with PPS6 and the Object should be fully recognised in the Core Strategy. draft PPS4. Disagree – No Change A positive statement needs to made in regard to vacant retail warehouses. page31/para1 CGLP wish to point out that there are a number A review of the Office Market of developments permitted or proposed in the Assessment will inform the Croydon Gateway Limited Centre that comprise a large element of office next consultation draft of the Partnership floorspace, such as the CGLP Ruskin Square Core Strategy on the need Observation scheme, which will deliver Grade A office space. and location of new offices in Noted – No Action Croydon Metropolitan Centre. Within the centre, CGLP consider that to assist in the delivery of Grade A office space, the redevelopment of empty or under-used office space should be encouraged by the Council. The Core Strategy should reflect the ‘Opportunity Area’ designation in the London Plan which identifies the area for significant growth in office and residential uses. The CGLP Ruskin Square scheme provides a significant quantum of both office and residential uses. CGLP consider that the Council should look to encourage the further evolution of key redevelopment schemes such as the Ruskin Square scheme to ensure that these are readily capable of meeting anticipated economic and social needs. page29/para2 We support measures to diversify the local The comment is noted. Mr Austin Mackie economy, to create new business generation Austin Mackie Associates opportunities; but importantly, this requires a Ltd quality environment for business investment Observation Agree - No Action pg 42 para1 bullet 5 3. We are dismayed at the developments of The Core Strategy is not Norbury more flats in the centre of Croydon. proposing that all councillors/reside Developments need supportive services in the developments in the centre of nts vicinity. Croydon should be flats. A Norbury mixture of housing types will councillors/residents be required to meet the need Object for new homes. It is Noted – No Action acknowledged that Croydon Metropolitan Centre is a challenging location for family homes but given the level of need innovative solutions will need to be sought. The need for supporting facilities will be considered in an Infrastructure Delivery Plan. Page322/Question As detailed above, we consider that some Policies for the Borough's Mr Austin Mackie BIE1 traditional industrial areas need to be reviewed emoployment areas will be Austin Mackie Associates Lodge Lane and Huntingfield, Addington. This developed as the evidence Ltd document is being produced to assist in the next base is compiled and will be Object iteration of the Core Strategy referred to at page set out in the next version of Agree – Propose Changes 23 of the Initial Report. in the context of their the Core Strategy. adjacency to residential areas and their suitability in terms of traffic and accessibility. Page27/Question G1 11) If , however, option 2 is selected it is A modified growth strategy will Ms Brenda imperative that there are clear and specific be considered for the next English commitment setting out the changes which will iteration of the Core Strategy. Pollards Hill Residents be delivered to support the density of The infrastructure needs Association development. Consideration of how the A23 can associated with the Core Observation best be improved, or supported by other routes, Strategy will be considered by Noted – Propose Changes to deal with the increase in road traffic. the Infrastructure Delivery Protection and improvement of parks. Plan. Improvements to rail and bus capacity to serve a growing population. High quality sustainable housing and encouragement of innovative design to reduce carbon output. page30 We consider that established SIL’s should not An Employment Land Review Mr Austin Mackie simply be considered as a single entity, but their will assess our employment Austin Mackie Associates overall character reviewed, particularly fringe designations and the findings Ltd locations where a more appropriate transition of will inform the next Object land uses will be required; thus requiring a consultation draft of the Core Disagree – No Change review of detailed boundaries. We consider that Strategy. Strategic Industrial such transition locations offer the opportunity for Locations are designated by higher quality employment opportunities within the London Plan and Croydon mixed-use schemes, that will not detract from is categorised as a "restricted overall employment land and economic growth transfer borough". targets. n/a The Mobile Operators Association (MOA) The comment is noted. represents the five UK mobile network operators Detailed planning policies will Mobile Operators – 3, O2, Orange, T-Mobile and Vodafone – on be developed later in the Assocaition radio frequency health and safety and Local Development Observation associated town planning issues. We have no Framework process. Noted – No Action comments to make in respect specific issues & options for the Core Strategy as we understand that this is a strategic document. We would take this opportunity however to comment that we consider it important that there remains in place a telecommunications policy within the emerging Local Development Framework. It is recognised that telecommunications plays a vital role in both the economic and social fabric of communities. National guidance recognises this through PPG8, which provides clear guidance as to the main issues surrounding telecommunications development. These include the legislative framework, siting and design issues, levels of consultation and issues surrounding electromagnetic fields (EMFs). Clear guidance is also given regarding what should be included within local plan (now LDD) policy. This guidance states that local plans (LDDs) should set out criteria based policies to guide telecommunications development and that whilst regard should be had to siting and design considerations, operational efficiency should not be inhibited. PPG8 also makes clear that “Criteria should be flexible enough to allow for the efficient development of the network and the demands imposed by the technology”. Since the revision of PPG8 in 2001, the Office of the Deputy Prime Minister (ODPM) has produced, in conjunction with the industry, a Code of Best Practice. This builds on the Ten Commitments to ensure that the industry is alive to the concerns of local communities and consultation is built into the development process. page29 We consider that it is not appropriate to rely An Employment Land Review Mr Austin Mackie upon ‘static’ historical employment designations will assess our employment Austin Mackie Associates that promote poor quality setting for new designations and the findings Ltd investment, low grade employment and low will inform the next Object employment densities. consultation draft of the Core Disagree – No Change Strategy. page30/para5 The draft Core Strategy provides some general Reference will be made to the Mr Ed Kemsley commentary on retailing and the need to retail evidence base in the Peacock & Smith Limited encourage growth in this sector. In terms of next consultation draft of the Observation future ‘need’ for retail floorspace, we note that Core Strategy. Noted – Propose Changes the Council published the ‘Boroughwide Retail Needs Study Update’ in December 2008. This forecast significant capacity in both convenience and comparison retailing. The table below summarises the forecast convenience capacity.

2005 2010 2015 2020 2025

Norbury £12.58m £13.37m £13.82m £14.34m £14.94m

Upper Norwood £0m £0.13m £0.24m £0.39m £0.57m

Thornton Heath £28.89 £30.88m £32.31m £34.17m £20.48m

South Norwood -£8.11m -£7.40m -£7.08m - £6.64m -£6.07m

Central Croydon West £52.45m £58.24m £63.15m £68.55m £74.46m

Central Croydon East £19.08m £19.99m £20.67m £21.50m £22.48m

Coulsdon £0 £0.14m £0.33m £0.48m £0.61m

Purley £35.83m £39.33m £42.48m £45.44m £48.34m

Selsdon £6.72m £7.28m £7.73m £8.46m £9.42m

New Addington £2.85m £2.92m £3.01m £3.16m £3.35m

TOTAL £150.29m £164.88 £176.66 £189.85 £188.58 page33/para1/bullet6 Bull point 6: There are, within the population of The Core Strategy seeks to Mr I.G.M. Hunter the Borough, adults and children who, reduce the proportion of intellectually – despite being given the young people in the borough Observation opportunity - cannot absorb information to who are not in education, Noted – Propose Changes enable them to achieve high level skills employment or training. The (computers, business management, accounting next consultation draft of the etc.). Nevertheless it behoves the Borough, Core Strategy will seek to set through its alternative education prospectuses, out our proposed strategy for to provide those persons with the type of achieving this. education and training at low skill level which will make them feel a productive source in such areas as building, leisure activities, including sport and utilities support. These people must neither be overlooked nor be branded as educational and therefore social failures. page31/para5/bullet2 FAIRVIEW NEW HOMES agrees in principle The comment is noted. N Kwan that the Borough's overall stock of industrial Fairview New Homes premises for essential, often environmentally Support sensitive activities, should be protected, but with Noted – No Action the recognition that not all existing industrial sites are needed nor ideally located for noisy or bad neighbour uses. page43/questionmc2 Accordingly we suggest that the options should The comment is noted. A Brian Madge not discount Greenfield sites at this stage in the Strategic Housing Land Brian Madge Ltd process. The Core Strategy and Site Allocations Availability Assessment is Observation DPD will need to demonstrate that supply can currently being prepared Noted – No Action be achieved having regard to the bias in need which will inform the next towards family houses. consultation draft of the Core Strategy. page43/questionmc3 The Issues and Options paper places a greater The comment is noted. A Brian Madge emphasis on the provision of family units, (3 Strategic Housing Land Brian Madge Ltd bedrooms or more) and 80% of the land supply Availability Assessment is Observation is in Central Croydon. It is suggested that such currently being prepared Noted – No Action family housing cannot be supplied at the which will inform the next necessary densities in these locations. consultation draft of the Core Strategy. page43/questionmc3 Our recent analysis of housing supply suggests This is a comment on the Brian Madge the latest AMR thus significantly over estimates Annual Monitoring Report. Brian Madge Ltd supple possibly by a factor of 300%. A number The Annual Monitoring Report Observation of the town centre sites upon which housing monitors the implementation Noted – No Action supply is reliant are no longer viable or of Unitary Development Plan permissions have expired. The recession thus policies and highlights areas casts doubts on the larger flat orientated town where intervention is required centre schemes. in the future. The Core Strategy will set out new housing targets and broad areas for development in order to meet the need for new homes in the borough up to 2031. page43/questionmc3 The current five year supply of large sites (25+ This is a comment on the Brian Madge units as detailed on page 129 of 2007-2008 Annual Monitoring Report. Brian Madge Ltd AMR) shows 2412 units supply in the next five The Annual Monitoring Report Observation years. Our review involving discussions with monitors the implementation Noted – No Action developers show that as a result of the of Unitary Development Plan recession the supply is likely to be 751 units. policies and highlights areas where intervention is required in the future. The Core Strategy will set out new housing targets and broad areas for development in order to meet the need for new homes in the borough up to 2031. page43/questionmc3 The 2007-2008 AMR notes “ However in the This is a comment on the Brian Madge second five year period (from 2014/15 to Annual Monitoring Report. Brian Madge Ltd 2018/19, the borough is particularly reliant on The Annual Monitoring Report Observation several large UDP allocations in central Croydon monitors the implementation Noted – No Action for housing land. Should development of any of Unitary Development Plan one of these sites not be developed then it is policies and highlights areas possible that the Council will not meet its where intervention is required minimum housing targets by the end of this in the future. The Core period …” This shows supply is sensitive to the Strategy will set out new loss of any one of these sites. housing targets and broad areas for development in order to meet the need for new homes in the borough up to 2031. page32/Question BIE2 The varying types and roles of industrial land An Employment Land Review Mr Michael across the borough should be further explored will be prepared and the Mulhern within the Core Strategy. In particular, London findings incorporated into the Greater London Authority Plan policies 2A.10 and 3B.4 identify the need to next consultation draft of the Observation promote, manage and where necessary protect Core Strategy. Noted – Propose Changes Strategic Industrial Land. In addition, the London Plan SPG on Industrial Capacity identifies Croydon as a restricted industrial land transfer borough…. ‘there is a low level of industrial land relative to demand (particularly for waste management or land for logistics) and/or low proportions of industrial land within the SIL framework. Boroughs are encouraged to adopt a more restrictive approach to the transfer of industrial sites to other uses. This does not preclude the possibility of smaller scale release where boroughs have made adequate provision of industrial land in their DPDs in particular for waste management and logistics uses.’ page30/bullet5 The Retail Needs Update is intended to form Reference will be made to the Mr Ed Kemsley part of the evidence base for the emerging LDF. retail evidence base in the Peacock & Smith Limited However, we note that the draft Core Strategy next consultation draft of the Object does not make any specific reference to this Core Strategy. Noted – Propose Changes identified need. Government guidance contained in PPS6 clearly states that through Local Development Documents, Local Planning Authorities should assess the need for further main town centre uses and ensure that there is capacity to accommodate them. The Core Strategy should contain a realistic assessment of need for retail development in Croydon for both comparison and convenience retailing. page32/Question BIE1- Question BIE 1 – Do you think these are the The Core Strategy will BIE2 right options? promote policies that are in B&Q Properties Ltd conformity with PPS6 and the Object Question BIE 2 – Are there any other options draft PPS4. Disagree – No Change that we should consider?

The Business, Industry and Employment section of the Core Strategy Issues and Options document refers to the preponderance of retail warehousing, especially along the Purley Way and assert that this can be damaging to Croydon’s town centres, and, that vacant retail warehouses are a wasted resource. In our view, the Core Strategy should aim to build on Croydon’s current resources, not only the town centre, but also other uses which do, and will, benefit Croydon residents. n/a In summary, we recognise the early stage of The comment is noted. LDFs and the early stage of the consultation Mobile Operators process at which we are being asked for Assocaition comment. We are suggesting that a clear and Observation flexible telecommunications policy be introduced Noted – No Action in one of the main LDDs. This should be introduced by a short paragraph outlining the development pressures and the Councils policy aims. We have suggested text for both above. In keeping with the aims and objectives of the new legislation any background information should be contained within a separate LDD which would not need to go through the same consultation process. page31/para1/bullet1 PPS6, draft PPS4 and London Plan policy 2A.8 The comment is noted. Mr Michael identify the key function of town centres and Mulhern seek to ensure that ‘business, industry and Greater London Authority employment’ town centre uses are not Observation encouraged in out of centre locations Agree - No Action page31/para1/bullet7 Proposals to regenerate and renovate existing The support is welcomed. Mr Michael office space within the Croydon Metropolitan Mulhern Town Centre are supported. As set out in Greater London Authority London Plan policy 3B.3 and paragraph 3.148 Support development in the Croydon Town Centre (and Agree - No Action other town centres that have concentrations of office based development) should seek a mix of uses, which should be recognised. n/a It will of course depend on your Local The comment is noted. Development Scheme as to which documents Detailed planning policies will Mobile Operators are produced, which documents have a statutory be developed later in the Assocaition role in development control and which would be Local Development Observation considered as material considerations. We Framework process. Noted – No Action would suggest that this policy be a stand alone policy within one of the main LDDs, with any back ground information, such as electromagnetic fields (EMFs) and public health, being contained within a separate LDD or what is currently termed Supplementary Planning Guidance (SPG). This could then be read with PPG8, the Code of Best Practice to give a comprehensive background to any proposed development. We would consider it appropriate to introduce the policy and we would suggest the following; Modern telecommunications systems have grown rapidly in recent years with more than two thirds of the population now owning a mobile phone. Mobile communications are now considered an integral part of the success of most business operations and individual lifestyles. With new services such as the advanced third generation (3G) services, demand for new telecommunications infrastructure is continuing to grow. The Council are keen to facilitate this expansion whilst at the same time minimising any environmental impacts. It is our policy to reduce the proliferation of new masts by encouraging mast sharing and location on existing tall structures and buildings. Further information on telecommunications can be found in Local Development Document. page43/questionmc3 The 2006-2007 AMR notes “The housing This is a comment on the Brian Madge trajectory shows that in the short-term Croydon Annual Monitoring Report. Brian Madge Ltd has enough new housing in the pipeline to meet The Annual Monitoring Report Observation its targets However in the second five-year monitors the implementation Noted – No Action period (from 2012/13 to 2016/17), the borough is of Unitary Development Plan reliant on several large UDP allocations in policies and highlights areas central Croydon for housing land. Should where intervention is required development of any one of these sites not be in the future. The Core developed then it would increase the likelihood Strategy will set out new of the borough failing to meet its housing housing targets and broad targets. • By 2016/17 (the end date of the areas for development in current London Plan) Croydon will have a order to meet the need for shortfall of 259 dwellings based on current new homes in the borough up predicted completions. If the undersupply from to 2031. the RPG3 period (pre-London Plan) is taken into account then this shortfall is actually over 4,300 units.” page43/questionmc3 The AMR reports of the past two years indicate This is a comment on the Brian Madge that the 5 year supply of housing units is in Annual Monitoring Report. Brian Madge Ltd doubt in later years. Moreover an update The Annual Monitoring Report Observation analysis suggests current short comings. monitors the implementation Noted – No Action of Unitary Development Plan policies and highlights areas where intervention is required in the future. The Core Strategy will set out new housing targets and broad areas for development in order to meet the need for new homes in the borough up to 2031. n/a We write on behalf of B&Q Properties Ltd who The comment is noted. own land at 500 Purley Way, Croydon, which is B&Q Properties Ltd currently occupied by retail warehouse units and Observation which will be redeveloped in the future to Noted – No Action provide a high quality retail warehousing development. By way of background, planning permission was granted at 500 Purley Way in June 2008 for the erection of a two storey retail warehouse with outdoor garden centre, builders yard, entrance and exit atrium and an integrated non food retail unit including internal mezzanine; provision of associated parking and servicing (07/02350/P). B&Q Properties Ltd also obtained outline planning permission at appeal for a development of the same description, but without a condition concerning BREEAM, and with a revised sub-division condition (07/02351/P - APP/L5240/A/07/2058947). When implemented, this retail development will provide significant environmental improvements, including improving the site and the area visually, as well as improving the retail offer. The scheme will provide benefits for local residents, and the wider catchment area. page32/para6/bullet2 FAIRVIEW NEW HOMES considers that an up The Council undertakes a N Kwan to date Industrial Land Supply Survey should survey for all employment land Fairview New Homes form part of the evidence base for the core in the borough every year as Object strategy, to inform the overall growth strategy for part of its Annual Monitoring Noted – No Action the Borough and give justification of the Report. It form a part of the Council's approach towards industrial land. (The evidence base that informs Council proposes that this should be prepared to the Core Strategy. inform the Site Allocations DPD only). In the absence of such document, the 'robustness' of any approach is questioned. page30/para5 We consider that the draft Core Strategy is Reference will be made to the Mr Ed Kemsley currently deficient in this respect and should be retail evidence base in the Peacock & Smith Limited founded on robust and credible evidence (key next consultation draft of the Object test of soundness – paragraph 4.52 of PPS12). Core Strategy. Noted – Propose Changes In light of this we would suggest that that the Core Strategy should include the forecast capacity as set out within the 2008 Retail Needs Update. page42/para1/bullet2 CGLP support the notion of developing a The support is welcomed. A partnership framework for the CMC, especially masterplan for the East Croydon Gateway Limited for East Croydon Station, to address the issues Croydon station area will be Partnership of significant development sites within the CMC. developed with key Support statkeholders. Agree - No Action page42/para1/bullet5,9 Purespace Group strongly support the delivery The support is welcomed. of change around West Croydon Station and Purespace residential growth as part of mixed use schemes Support around West Croydon Station. Also, the Agree - No Action document considers the of West Croydon Station to improve rail services and facilities to support the East London line to West Croydon and also the feasibility of building over the railway tracks. Purespace Group support the principle of improvements to West Croydon Station as part of the emerging masterplan for this area. page35/para1/bullet6 CGLP support the reference in the document The support is welcomed. that ‘The Warehouse Theatre’ to the west of Croydon Gateway Limited East Croydon Station provides a significantly Partnership improved opportunity for education and Support community outreach programmes. Agree - No Action page43/questionmc4 3. The framework for the CMC must not be The comment is noted. Mr Robert overly prescriptive. Posselt Martin Robeson Planning Practice Observation Agree - No Action page43/questionmc4 In order to ensure flexibility the framework The comment is noted. Mr Robert should not be overly prescriptive. It should Posselt contain guidance with respect to possible uses Martin Robeson Planning and building forms but should not be explicit. It Practice needs to be sufficiently flexible to accommodate Observation the varying needs of business, residents and Agree - No Action visitors to the CMC. page40/para1/bullet3 The Strategy for the CMC should clearly explain It is not intended that Mr Robert that change will also need to occur on sites that development will take place Posselt are not specifically allocated. As currently only on specifically allocated Martin Robeson Planning drafted the wording appears to refer to new sites. The consultation offers a Practice development taking place only on ‘specifically wide-ranging prescription for Observation allocated sites’. change of which specifically Disagree – No Change allocated sites are only a part. page43/questionmc1 Question MC1 Yes – Generally there is The comment is noted. Mr Robert agreement with the vision expressed on page Posselt 37. With respect to delivering the change Martin Robeson Planning described, it is considered that if the Council is Practice to seek to direct new development to Observation ‘specifically allocated sites’ via an OAPF or Agree - No Action Masterplan, there will need to be significant input from relevant landowners and private stakeholders in order that the document provides a viable framework from which development can occur. This consultation needs to take in not only the landowners of ‘specific sites’ but also other stakeholders in order to ensure that the OAPF is deliverable. page43/questionmc2 Question MC2 Yes – consider an alternative Spatial option 1 (Dispersed Mr Robert option where the market is left to dictate how Growth) already considers a Posselt residential, commercial, cultural and retail more market led approach. Martin Robeson Planning floorspace comes forward and in what form. Practice Object Disagree – No Change page43/bullet10 We support the proposals to improve transport The support is welcomed. Mr Robert interchanges/connections with the sub-region, in Hayward particular East Croydon Station. In addition, as Reigate & Banstead recognised in the spatial options diagram, a Borough Council clearer link between East Croydon and West Support Croydon Stations should be emphasised. Agree - No Action Making best use of both stations could help to ease commuter congestion. page52/para4 Please note: At this stage of the Core Strategy’s A Borough Character Ms Claire Craig development, English Heritage considers it Appraisal and a Residential English Heritage important that local authorities give Character Appraisal will form Observation consideration to the way in which they intend to part of the evidence base for Noted – Propose Changes evidence their approach to tall buildings. Our the Core Strategy. joint publication with CABE Guidance on Tall Buildings (July, 2007) recommends, as a matter of best practice, that an authority carry out a detailed urban design study to establish their approach to this matter. page36/para1 In delivering the options for change, CGLP The location of new cultural suggest that the Croydon Metropolitan Centre and leisure facilities will be Croydon Gateway Limited Area Action Plan should provide the framework considered by a Cultural Partnership to include a number of general locations, zones Mapping Study and an Open Object or quarters where the provision and Space and Indoor/Outdoor Noted – No Action development of cultural and leisure facilities Leisure Study. The findings could be promoted. This network or quarter will be considered as part of could start at the Ruskin Square site and the series of masterplans in progress in an arc taking into account the Croydon Metropolitan Centre possible redevelopment of Fairfield Halls, and in the Opportunity Area through to the old town. Planning Framework. (the Area Action Plan will not be taken forward at this stage) page37/para2/bullet2 CGLP support the Council’s objective to build The support is welcomed. the image of the Metropolitan Centre as a Croydon Gateway Limited vibrant location with cafés, restaurants and Partnership culture and entertainment facilities. CGLP Support consider that the provision of a high quality Agree - No Action culture and leisure offer within the Centre will support Croydon’s primary function as an opportunity area for business and residential development. page43/questionmc1 Owing to the inherent lack of essential It is acknowledged that Mr Robert community facilities for children (recreational Croydon Metropolitan Centre Posselt and open space etc) within CMC and the nature is a challenging location for Martin Robeson Planning of future residential development i.e. high family homes but given the Practice density in high rise buildings, it is considered level of need innovative Object that generally the CMC is not an appropriate solutions will need to be Noted – No Action location to accommodate a significant proportion sought. of family dwellings that the Council has identified a need for. Suburban, district centres and locations on the edge of and perhaps within the lower density parts of the CMC are better suited to accommodate a majority of this housing need. page42/para1/bullet1 In delivering options for change within the A modified approach towards Centre, Purespace Group do not consider that future development of Purespace defined ‘functional quarters’ that establish the Croydon Metropolitan Centre Object quantum of development and balance of uses is will be considered within Agree – Propose Changes appropriate for the Centre. Redevelopment future consultation drafts of proposals that come forward for individual sites, the Core Strategy and also an whether inside or outside the CMC, should be Opportunity Area Planning considered on their merits in terms of its design Framework. Both will be and appearance, quantum of development and based upon a series of mix of uses and should not be constrained by a masterplans for different parts pre-determined balance of uses for each quarter. of Croydon Metropolitan Centre. page37/para2/bullet2-3 Purespace Group support the Council’s aims for The support is welcomed. Centre to provide a good range of facilities and Purespace an increased residential population, bringing Support vitality to the Centre. Agree - No Action Page36/Question LC2 The decline in leisure facilities – notably the The comment is noted. The Mr John Ingman failure to invest in the Fairfield Halls and the text on page 38 acknowledges Park Hill Residents' over-development of pubs and clubs which have this point. Association discouraged most people over 25 from venturing Observation into Croydon at night and contribute to a Noted – No Action widespread fear of crime; page31/para5 Whilst there may be a demand for some lower A review of the Office Market grade office space in the Centre, there is a large Assessment will be Croydon Gateway Limited over-supply of second grade offices in Croydon undertaken to inform the Core Partnership which could provide affordable accommodation Strategy including the need Observation for smaller businesses. In order to meet the and location of new office Noted – No Action ‘Opportunity Area’ designation, the Council development. should seek to maximise the provision of Grade A office space within the Centre which will attract major occupiers, who will in turn help the regeneration of Croydon. page32/para1/bullet3 The document suggests that Croydon Economic The comment is noted. Development Company could promote Croydon Croydon Gateway Limited as a business location for specific sectors. If this Partnership becomes policy, there is a danger that this could Observation deter significant investment. It is likely that Noted – No Action Croydon will appeal to organisations from a certain sector that are then likely to cluster with other similar organisations. page33/para7/bullet3 CGLP consider that in order to encourage The comment is noted. This is investment in jobs, overall there should be included within the Core Croydon Gateway Limited increased training and learning opportunities for Strategy. Partnership young people in the Borough. Observation Agree - No Action page33/para1 CGLP strongly agree that Croydon needs to The support is welcomed. invest in education and encourage University Croydon Gateway Limited and other further higher education institutions. Partnership Support Agree - No Action page33/para1/bullet1 CGLP agree that the Borough’s residents should The support is welcomed. be highly skilled to provide a local / ‘home Croydon Gateway Limited grown’ workforce. Coupled with the excellent Partnership transport links, currently centred on East Support Croydon Station, this will provide added Agree - No Action incentive for companies to move into the Metropolitan Centre. page43/questionmc4 Yes – see comments below in relation to: It is acknowledged that Mr Robert Croydon Metropolitan Centre Posselt 1. the type of housing and occupiers conducive is a challenging location for Martin Robeson Planning to the physical environment i.e. high density, family homes but given the Practice high rise. level of need innovative Object solutions will need to be Noted – No Action sought. page43/questionmc4 2. the need for significant input from all The comment is noted. Mr Robert landowners and stakeholders with respect to Posselt developing the OAPF (not just the owners of Martin Robeson Planning ‘specifically allocated sites’) in order to ensure Practice that the planning framework is viable and Observation deliverable. ANAti page52/para4 Paragraph 2.7 of this guidance (CABE Guidance A Borough Character Ms Claire Craig on Tall Buildings (July, 2007)) outlines that such Appraisal and a Residential English Heritage a study involve a character appraisal identifying Character Appraisal will form Observation those elements that create local character and part of the evidence base for Noted – Propose Changes other important features including: the Core Strategy.

• Natural topography;

• Urban grain;

• Significant views of skylines;

• Scale and height;

• Streetscape; and

• Landmark buildings and areas and their settings. Both we and CABE are of the view that this should not necessitate a lengthy and complicated report and that, if sufficient time is allowed, it should be possible to put this together using in-house expertise. The key consideration is that it should provide a borough-wide analysis of character and context from which to determine what constitutes a tall building in different parts of the borough and the best locations for taller buildings. We note that the only explicit mention of tall buildings in the Initial Report is the expression of a preference to see them located in Croydon’s Metropolitan Centre but that there are various expressions of interest in growth throughout the places’ analysis. We are of the view that evidence of the nature discussed will be an important component of developing a strong, sound Core Strategy for growth in the London Borough of Croydon. page36/questionlc2 Where do we want to be Section – No mention This is considered in chapter Mr M Jennings of residents having access to open spaces and 4 - A Place for Sustainable Association of Croydon nature reserves for health and recreation. The Living. Conservation Societies Cultural Strategy includes this. Should this be Observation another option for them to consider at this high Noted – No Action level? page42/para1/bullet9 We support the focus on East Croydon/West The support is welcomed. Mr Robert Croydon stations; and the focus on improving Hayward the capacity and flow of the A23 Reigate & Banstead Borough Council Support Agree - No Action page42/para1/Bullet9 Bull point 9: The feasibility of building a raft over Disagree. The suggestion to Mr I.G.M. Hunter Wellesley Road, thus avoiding major build a raft over Wellesley disturbance to the current transport links and yet Road has been discussed at Object provide a safe, pollution-free link between length and is an option the Disagree – No Change Central Croydon and the Railway was proposed council has decided not to under the 2008 Issues and Options exercise. It pursue. has been ignored! Consider this as new option. n/a More generally, we do not think that this report is This consultation is designed Mr John Ingman a sufficient response to the urgent problems to seek people's views on the Park Hill Residents' facing Croydon:- issues facing Croydon and Association ideas as to how to tackle them. Object Noted – No Action page42/para1/Bullet12 Bull point 12: If the encouragement of a greater The Warehouse Theatre is Mr I.G.M. Hunter mix of ages and cultures to use the Metropolitan referenced within the Core Centre is essential to the Core Strategy then the Strategy. It is not the place of Observation Council should be prepared to subsidise the the Core Strategy to No Action – Not an LDF Is Warehouse Theatre to the same extent it does determine subsidy of cultural for both the Fairfield Halls and the Clock-tower, venues. and be willing to compromise on “Commercial Sustainability (page 36-What are the options for change – Bull point 4). Consider this as new option. page43/questionmc1 Q MC 1 – We have seen already the demise in The comment is noted. Mr I.G.M. Hunter Croydon of small unique or specialist trading Detailed planning policies will entities in favour of large, cloned West-End style be developed later in the Object stores. Major stores bring major rents which Local Development Disagree – No Change drive out small businesses. Unless the strategic Framework process. view includes realistic rates etc., much of the theoretical business offer will be unaffordable. page43/questionMC2 Q MC 2 – The comments I have made to the The comment is noted. Mr I.G.M. Hunter various Bull points can be treated as other options. Observation Noted – No Action page43/questionmc3 Q MC 3 – Bull point three is confusing. What Croydon is designated is a Mr I.G.M. Hunter world-class Metropolis is being referred to? Is it Metropolitan Centre in the supposed to be London, and if so is the London Plan. It performs the Observation document saying that Croydon (Town) will role of a sub-regional centre Noted – No Action remain just that and not aspire to being a city in within Greater London. its own right?- not that Croydon has earned the privilege to be called a city at present anyway. page43/questionmc4 Q MC 4 - See Q MC 2 above. Q MC 2 – The The comment is noted. Mr I.G.M. Hunter comments I have made to the various Bull points can be treated as other options. Observation Noted – No Action page30 The decline in employment with the loss of The comment is noted. Mr John Ingman nearly 20% of jobs in the last ten years; Park Hill Residents' Association Observation Noted – No Action page30 The failure to attract good quality retailing and This consultation is designed Mr John Ingman offices in the Town Centre and to develop key to seek people's views on the Park Hill Residents' sites such as Park Place and the Gateway Site – issues facing Croydon and Association in the latter case due to the Council’s misplaced ideas as to how to tackle them. Observation ambitions for an arena; Noted – No Action page37/para2/bullet5 Please let us stop deferring to third rate The comment is noted. Mr K Pope architects and the vested interests and allow ourselves to have an urban landscape in Observation Croydon which is attractive and human in scale, Noted – No Action has quality and merit and will last the tests of time. Funny how the Town Hall is still standing still functional and looking great while other old buildings have been left to moulder. The Croydon way has been to demolish anything decent and replace it with yet another concrete and glass monstrosity that nobody really likes because it needs the moeny not because it fulfils any long term visionary plan. As a consequence we have precious little heritage to worry about and what there is is often neglected because there's no money to maintain it. The landgrab of backgardens for high density flats is particuarly nasty and encouraging developers to get away with almost whatever they like is a mistake which has contributed to the urban decay of Croydon. A few street trees put in as an after thought is no substitute for mature green spaces where people and wildlife can breathe. Global warming is unstoppable if we carry on like this. page36/para1/bullet5 The decline in leisure facilities – notably the The comment is noted. A Mr John Ingman failure to invest in the Fairfield Halls and the Cultural Mapping Study will be Park Hill Residents' over-development of pubs and clubs which have prepared to inform later Association discouraged most people over 25 from venturing consultation drafts of the Core Observation into Croydon at night and contribute to a Strategy. Noted – No Action widespread fear of crime; Page33/Where are we The poor skill levels of people in Croydon and Strategic and local indicators Mr John Ingman now the proportion of young people not in education, will be considered in greater Park Hill Residents' employment or training; detail in the next Core Association Strategy consultation report. Observation Noted – Propose Changes page41 The ‘Spatial Issues’ diagram identifies the area The support is welcomed. around East Croydon Station as ‘East of Centre’. Croydon Gateway Limited The diagram shows that this area currently Partnership comprises a poor environment for pedestrians. Support CGLP therefore support the annotation Agree - No Action illustrated on the ‘Potential Spatial Options’ diagram as an opportunity for regeneration through the intensification of mixed uses, tall buildings and public realm improvements. The CGLP scheme adjacent to East Croydon Station for Ruskin Square will act as a catalyst for further high quality development and regeneration in this part of the CMC. pg 38 The failure to attract good quality retailing and The comment is noted. Mr John Ingman offices in the Town Centre and to develop key Park Hill Residents' sites such as Park Place and the Gateway Site – Association in the latter case due to the Council’s misplaced Observation ambitions for an arena; Noted – No Action page37/para2 CGLP consider that the CMC needs to provide a The comment is noted. range of jobs, good quality shopping, leisure and Croydon Gateway Limited cultural opportunities, in addition to a good Partnership housing stock in order to attract investment and Observation growth. Agree - No Action Page30/Where are we The decline in employment with the loss of The comment is noted. Mr John Ingman now nearly 20% of jobs in the last ten years; Evidence base will be Park Hill Residents' developed to provide policy Association direction for a future version of Observation the Core Strategy. Noted – No Action page33/para2/bullet6 More generally, we do not think that this report is This consultation is designed Mr John Ingman a sufficient response to the urgent problems to seek people's views on the Park Hill Residents' facing Croydon:- issues facing Croydon and Association ideas as to how to tackle them. Object The poor skill levels of people in Croydon and Noted – No Action the proportion of young people not in education, employment or training; page37/para2/bullet2 CGLP support the council’s aims for CMC to be The Core Strategy recognises a vibrant town centre with a good range of the importance of the public Croydon Gateway Limited facilities and an increased residential population realm and the need to plan for Partnership bringing vitality to the Centre. An increased a mix of uses in Croydon Observation range of facilities, such as retail, will attract Metropolitan Centre. Agree - No Action residents from all over the Borough to visit the CMC. However, any increase in the retail offer needs to be provided within the context of improvements to the public realm and streetscape of the CMC. Also, complementary town centre type uses such as leisure and cultural attractions would provide the vibrancy for the CMC and attract a residential population in the CMC. page36/para2 This situation cannot wait on the leisurely This consultation is designed Mr John Ingman approach envisaged in Imagine Croydon. The to seek people's views on the Park Hill Residents' Core Strategy will apparently not be approved - issues facing Croydon and Association let alone acted upon - until the end of 2011(see ideas as to how to tackle Object p1). We have looked in vain in the document for them. It does not preclude Noted – No Action any priorities in the major tasks which face other decisions/proposals as Croydon or any short term targets. For instance, specific sites such as the the proposed responses on business and Fairfield Halls. employment (p32) and culture and leisure (p36) - both key areas - have no specific proposals or timescales at all. They rely too much on vague strategies and planning frameworks. The proposal to have yet another study of the Fairfield Halls is woeful. page43/questionmc4 Under the heading “A Place for Opportunity”, the Details on retailing in Croydon document does not fully consider the potential Metropolitan Centre will be Croydon Gateway Limited for an improvement in the quality of retail in the included in future consultation Partnership CMC. As referred to earlier, an improved retail drafts of the Core Strategy Observation offer would attract visitors from both inside and and as part of the Opportunity Noted – Propose Changes outside the Borough and provide the impetus for Area Planning Framework for future investment and regeneration, creating a Croydon Metropolitan Centre. vibrant town centre with a mix of uses. CGLP consider that given the importance of Croydon as a location for major regeneration, the importance of quality retail within the CMC should be emphasised. Indeed, the document states that one of the aims is for the CMC to be “the primary shopping area between the West End and the South Coast” (p.37). CGLP strongly agrees with this aim, however, the document should be explicit in how this is to be achieved. CGLP consider that the quality of retail provision within the CMC needs to be improved in order to capture expenditure from both within and outside the Borough in order to meet the aim of the CMC becoming a retail destination in its own right. page42/para1/bullet9 However, it should be recognised that whilst The comment is noted. The residential should be encouraged in the town infrastructure needs Croydon Gateway Limited centre, there is a difficulty of providing family associated with the Core Partnership accommodation with good access to schools Strategy will be considered by Observation within the CMC. the Infrastructure Delivery Noted – No Action Plan which will be developed alongside the Core Strategy. page42/para1/bullet5 CGLP support the delivery of residential growth The support is welcomed. as part of mixed use schemes with increased Croydon Gateway Limited intensification around East Croydon Station. Partnership Support Agree - No Action page31/para1 CGLP consider that delivery of new office An Opportunity Area Planning floorspace in the Centre could be provided by Framework will be prepared Croydon Gateway Limited the framework provided by the Croydon for Croydon Metropolitan Partnership Metropolitan Centre Area Action Plan. CGLP Centre. Observation consider that this document should set out that Noted – Propose Changes the delivery of high density office and residential development is encouraged around East Croydon Station which has excellent transport links. 4. A Place to Belong Page/Paragraph/ Representation Recommended response Full Name Objective Organisation Nature of Response Officer Recommendation page54/para22 The impact of the built environment on people’s The comment is noted. Nikki Honan mental health is important. Research by Guite et HUDU al (2006) on London council estates shows how Observation the built environment affects people’s mental Noted – No Action health. Particular aspects of the built environment include damp, noise, ‘liking the look of the place’ and places to stop and chat. Reference below.

Guite HF, Clark C, Ackrill G. (2006). The impact of the physical and urban environment on mental well-being. Public Health. 120(12):1117- 26. page45/para2 Mixed development to include low cost and In the future iteration of the Mr Stephen family housing with outside space and parking Core Strategy we will put Leadbetter provision forward more detailed policies Central Norbury relating to affordable housing Residents' Association and the mix of large and small Observation homes for each Place. Noted – Propose Changes Parking provision will be addressed through the masterplans and the Development Management DPD. Outside space will be considered as part of a stategic policy on green space. Private amenity space will be dealt with as part of the Developent Management DPD page51/Question PR2 Quality Public Realm This level of detail will be dealt Nikki Honan page51/Question PR2 with through a public realm HUDU Question PR2 We welcome the creation of area SPD. Observation specific design codes, masterplans and Local Noted – No Action Development Orders to raise design standards. This could refer to the need to ensure physical, mental and social requirements are met, such as standards to ensure adequate internal space, access to open space and facilities etc, which may be detailed in the forthcoming Public Realm DPD / Action Plan. n/a Enforcement of the penalty for litter This is not a matter that can Derrick East be considered by the Core Strategy. Observation No Action – Not an LDF Is n/a Policy should be drafted to be sufficiently flexible In the future iteration of the Mr Robert to allow for a realistic assessment of what is Core Strategy we will put Posselt achievable in a particular location forward more detailed policies Martin Robeson Planning relating to affordable housing. Practice Observation Noted – Propose Changes page45/para3 We consider that as we enter a period of Comment is noted. The Mr Austin Mackie economic recovery, but with relatively flat forecast period is 2007 - 2031 Austin Mackie Associates growth, net housing targets and resulting need so encompasses the period of Ltd will be greater than past forecasts have recession and subsequent Observation suggested. recovery. Noted – No Action page55/Question HE1 On a general note, the Council is encouraged to The comment is noted and the Nikki Honan ensure the core strategy remains locally Infrastructure Delivery Plan HUDU distinctive. We welcome the assessments set will consider delivery of health Observation out in section 6 ‘The Places of Croydon’, which infrastucture. Noted – No Action include the current spatial issues as well as future options, and would support the Council continuing to work with the PCT to ensure plans match up and delivery mechanisms are secured. page54-55/Health & HUDU’s ‘Delivering Healthier Communities in The comment is noted. Nikki Honan Wellbeing London’ may be helpful for identifying health HUDU evidence for LDFs and developing generic Observation health policies. Noted – No Action Other helpful guidance includes:

• World Health Organisation: ‘Promoting physical activity and active living in urban environments – ‘The role of local governments’ (2006)

• Department of Health: ‘Healthy Weight, Healthy Lives’ (2008)

• Department of Health – ‘Guidance on Joint Strategic Needs Assessment’ (2007)

• Sport England: ‘Active Design’

• NICE guidance PH8 ‘Physical Activity and the Environment’ (2008)

• Mayor of London: draft Health Inequalities Strategy ‘Living Well in London’ (2008). page49 Croydon is getting more crowded and we need The comment is noted. Andonetta Mansi open space to play in. Observation Noted – No Action page54-55 We support the Report’s Health and Wellbeing The comment is welcomed. Mr Barry Atwood objectives Support Comment is noted page53/QuestionHC1 We very much support the aim of protecting and The support is welcome. Mr Barry Atwood enhancing the historic assets of the Borough - hence our application for the inclusion of Box Support Ridge Avenue and neighbouring roads in the Noted – No Action adjacent Local Area of Special Character (see letter: para 9). page45/para1 We agree that “a sense of belonging is very Noted. The matter of traffic Mr Barry Atwood important to the quality of life” but, as pointed congestion and its impact on out in paragraph 11 of the letter, there is no way the public realm will be Observation that this will be fostered in Purley unless the considered in subsequent Noted – No Action traffic flow through its centre is reduced. The versions of the LDF Core Initial Report makes no proposals to achieve this. Strategy. page54-55/Health & Health evidence is available from a variety of The comment is noted. Nikki Honan Wellbeing sources such as the PCT’s public health report HUDU and the London Health Observatory. Developed Observation by the PCT and the Council, the Joint Strategic Noted – No Action Needs Assessment (JSNA) describes the current and future healthcare and well-being needs of the population and the strategic direction of service delivery to meet those needs. When assessing the health impacts of projected demographic change, the JSNA 2008/9 confirms:

‘The demographic projections indicate that the population will become older and more ethnically diverse. Increasing age and certain ethnic backgrounds are major risk factors for a number of key diseases, particularly cardiovascular disease. Advances continue to be made with regard to the effectiveness of medical interventions, meaning that people diagnosed with many diseases live longer. Prevalence is therefore expected to increase. It is anticipated that in Croydon, by 2013, there will be 4,700 more people with hypertension; 3,400 more with diagnosed type II diabetes; 680 more people with chronic obstructive pulmonary disease and 680 more cases of coronary heart disease.’ n/a We also have the situations that: This is not a matter that can Derrick East be considered by the Core People are not generally aware of the penalty for Strategy. Observation dropping litter No Action – Not an LDF Is n/a Pupils and students do not like the This is not a matter that can Derrick East Government's healthy eating policy be considered by the Core Strategy. Observation No Action – Not an LDF Is page55/Question HE2 London Plan The comment is noted. Nikki Honan HUDU The context for Croydon’s LDF is ‘The London Observation Plan Spatial Development Strategy for Greater Noted – No Action London: Consolidated with Alterations since 2004’ (2008). The Plan makes it clear that the policies and programmes of the NHS should be reflected to assess the need for health services and where necessary provision should be made for enhancing services through planning obligations. Key policies relevant to health include:

• Policy 2A.1 Sustainability criteria

• Policy 3A.1 Borough housing targets

• Policy 3A.7 Large residential developments

• Policy 3A.18 Protection and enhancement of social infrastructure and community facilities

• Policy 3A.20 Health objectives

• Policy 3A.21 Locations for health care

• Policy 3A.22 Medical excellence

• Policy 3A.23 Health impacts

• Policy 3A.26 Community strategies

• Policy 3A.27 Meeting floor targets

• Policy 3D.3 Maintaining and improving retail facilities • Policy 3D.6 The Olympic and Paralympic Games and sports facilities

• Policy 3D.8 Realising the value of open space and green infrastructure

• Policy 4A.1 Tackling climate change

• Policy 4B.3 Enhancing the quality of the public realm

• Policy 5E.1:The strategic priorities for South West London

• Policy 6A.4 Priorities in planning obligations page55/Question HE2 4. Evidence The comment is noted. Nikki Honan HUDU In developing the evidence base and the Observation emerging policy options, the Council is Noted – No Action encouraged to focus on the following questions:

• What are the health issues facing the Borough (and where relevant adjacent boroughs) what is the evidence?

• What is the spatial distribution of the key aspects of ill health?

• Which issues are most susceptible to planning interventions?

• What are the key influencers (or impactors) of health in the borough (the determinants perhaps)? (Focus on the environmental as distinct from the purely social/economic but not exclusively.)

• How are these distributed?

• What precisely do we want to achieve - the objectives?

• What range of spatial planning interventions would be most effective in addressing the health issues?

• How does the pattern of supply of health services match the pattern of demand?

• How will supply and demand change over the plan period? • What investments or reconfiguration changes are needed to ensure supply and demand is in balance spatially and over time?

• What are the spatial options for pursuing these interventions (in health and well being and service configuration)

• Which option(s) are likely to be most effective?

• Is that option deliverable? If so, who and how and where will the resources come from?

• What would the policies look like? (this may be premature but it’s very important to get beyond vague statements and to pin down some specific interventions that can then go into the plan)

• How does the core strategy measure and monitor the policies? page46/para1/bullet3 To provide affordable housing for the younger Noted. Miss Sevgin generation who already reside in Croydon. This Djemil needs to include houses as well as flats to be dispersed evenly around the Borough to ensure Observation there is less pressure on amenities in any one Noted – No Action town. page45/para3 Many existing permissions may require Applications for renewals of Mr Austin Mackie adaptation to meet future housing standards, extant planning permissions Austin Mackie Associates policy requirements and potentially changing will be considered in the policy Ltd housing market requirements. context existing at the time. Observation Disagree – No Change page55/Question HE2 Conformity matrix The next iterationof the Core Nikki Honan Strategy will consider HUDU It would be useful to have a matrix or table inclusion of a Core Strategy Observation setting out the policy context – the national, policy matrix to show how Noted – Propose Changes London Plan and the Sustainable Community policies address the prioirites Strategy. It would then be possible to trace the within the emerging Vision conformity of core strategy policies and also from the Sustainable identify gaps. An example is attached as Community Strategy. appendix 1. page55/para2 Sustainable Community Strategy Future iterations of the Core Nikki Honan Strategy will treat the topics HUDU One of the priorities of the Croydon’s of health and climate change Observation Community Strategy 2008-2011 is to improve as underlying themes whist Noted – Propose Changes the health of local people. The core strategy not explicitly referencing them should give spatial expression to and deliver the in each policy. health aims and objectives of the Community Strategy. Ideally, the implementation of the core strategy should reflect the health targets and outcomes of Croydon’s New Local Area Agreement 2008-2011.

The Council is encouraged to treat health and wellbeing as a cross-cutting theme in the core strategy, but to ensure that the health implications of each policy are explicitly addressed. n/a Applying a stiff punishment for those who This is not a matter that can Derrick East assault public servants. be considered by the Core Strategy. Observation No Action – Not an LDF Is page46/para2/bullet6 Mayors house space standards – Croydon The next iteration of the Core Mr Ross Gentry (particularly the south of the borough) is not Strategy will consider impacts LBC comparable to central London. Blanket of viability on new housing. Observation standards across London would not work. Noted – No Action page45/para3/bullet1 19,000 new homes – driven internally (growth No action. Mr Ross Gentry status) and organic growth- Essentially it’s all LBC about money, but has to be done in the right way Observation Noted – No Action page54/para2 Health & Well Being Support is welcomed Nikki Honan HUDU Where are we now? We welcome reference to Support the specific health needs of Croydon and would Noted – No Action support PCT documentation as outlined above to be addressed spatially through the LDF process. page54/para2 Health Plans and Strategies Comment is noted. Officers Nikki Honan working on the Infrasturcture HUDU We suggest the core strategy could refer to the Delivery Plan will be in Observation following health plans and strategies: discussion on this with PCT Noted – No Action colleagues. • Department of Health ‘Choosing Health: Making healthy choices easier’ (2004)

• Department of Health ‘Our Health, Our Care, Our Say: a new direction for community services’ (2006)

• NHS London, ‘Healthcare for London: A framework for Action’

• Croydon Primary Care Trust’s Commissioning Strategy Plan 2008/2009 – 2012/2013

• Croydon Primary Care Trust Operating Plan 2008/09

• Croydon Primary Care Trust Annual Report 07/08

• Croydon Primary Care Trust Governance Annual Report 2007/08

• Croydon Council, Croydon NHS Primary Care Trust and Croydon LINk: ‘A Joint Strategic Needs Assessment for Croydon 2008/09’ (JSNA)

• NHS London HUDU ‘Integrating health into the core strategy’ (2009) (which contains a checklist to ensure core strategies fully address health and well being) The Council is encouraged to explore with the PCT and the NHS trusts the spatial implications of these plans and strategies. page19/para2/bullet7 School/community facilities – suggested co- The next iteration of the Core Mr Ross Gentry location of facilities and there was a positive Strategy will consider this. LBC response. It makes sense to allow the Observation community to utilise existing facilities and to be Agree – Propose Changes involved in the development of new ones, particularly when they often lay empty on weeknights and at weekends. n/a I suggest that what is needed is: This is not a matter that can Derrick East be considered by the Core To publisise the litter law making people aware Strategy. Observation of the associated penalty No Action – Not an LDF Is Page46/para1/bullet3 6. We note the need for more family homes with The comment is noted. Norbury gardens rather than flats. councillors/reside nts Norbury councillors/residents Observation Noted – No Action page46/questionH2 Developers should identify how the site has Comment is noted. Matter for Ms Susan been allocated in the Site Allocations DPD. The the Site allocation DPD. Sheahan SFRA can provide guidance on the application Environment Agency of the sequential and exception tests (PPS25) Observation for allocated sites. Noted – No Action Page53/Question HC1 However, it considers that the Council’s Protection and enhancement approach should be sufficiently flexible to ensure of the historic assets of the Barratt Homes (kent) development is deliverable. Retention of historic borough is a vital strand in the Observation buildings should be assessed on merit. Core Strategy. Noted – No Action page46/para2/bullet3 Whilst we are in support of the Council The text does not suggest that Miss Wendy identifying key housing locations in the Site only sites with planning Wong Chang Allocations DPD, we would suggest that the permission will be taken into Berkeley Homes (south Council take into account sites that are account in assessing housing East London) Ltd considered to have the potential to capacity. Observation accommodate housing development rather than Agree - No Action just those with planning permission. page52-53 In terms of design PPG15 highlights the need for The comment is noted. The high quality design and acknowledges that boroughs heritage Barratt Homes (kent) modern design can sit alongside historic designations are in accord Observation buildings and this can- subject to design- form a with PPG15 and draft PPG15. Noted – No Action harmonious group. Draft PPS15 (July 2009) similarly advocates the conservation of England’s heritage assets in a manner appropriate to their significance highlighting the need to establish an asset’s significance and to integrate the conservation of historic assets into the wider planning context. Paragraph 1.10 calls for a focus on “what is significant in heritage terms about a place and not just protect all of it for its own sake.” page55/questionHE1 Barratt Homes (Kent) recognises- and supports- The comment is noted. The the need to improve general health and well- viability of development will be Barratt Homes (kent) being. However, it would ask that the Council’s considered when preparing Observation approach is sufficiently flexible to ensure the Core Strategy and Noted – No Action development is viable and deliverable. This is Infrastructure Delivery Plan. particularly important with regard to the proposal to develop broad Borough-wide development principles in relation to influences such as the urban heat island effect and pollution. page51/para1 Public realm improvement contributions sourced The comment is noted. through S106 Agreements should be Barratt Homes (kent) reasonable, based on up-to-date assessments Observation of need, supply, and demand, and relate in scale Noted – No Action and kind to development. page46/table With respect to affordable housing targets, In the future iteration of the Mr Robert policy must be clear that the figures identified Core Strategy we will put Posselt are targets and should not be applied forward more detailed policies Martin Robeson Planning prescriptively hence the importance of including relating to affordable housing. Practice reference to an assessment process within the Observation relevant policy. Ntd P Ch page51/QuestionPR2 In addition it is important that design seeks to Agreed. High quality public Ms Susan enhance open space for its amenity value and realm referred to in objective Sheahan also for its biodiversity value. 1. on page 49 covers these Environment Agency aspects. We will develop the Observation concept further. Agree - No Action page46/questionH2 With respect to the affordable housing In the future iteration of the Mr Robert component of schemes, sufficient flexibility Core Strategy we will put Posselt needs to be written into policy to allow an forward more detailed policies Martin Robeson Planning assessment of the particular circumstances and relating to affordable housing. Practice form of development being brought forward i.e. Observation viability (the ability of a scheme to deliver Noted – Propose Changes affordable housing) suitability (is off-site provision preferable). page46/para2/bullet2 Finally, we assume that any changes to the The next iteration will consider N Kwan housing target published as part of the London a modified spatial strategy to Fairview New Homes Plan review in October 2009 will be included in ensure growth is sustainable Observation the further Regulation 25 Core Strategy and is likely to feature Agree – Propose Changes consultation document, to be published by the elements of the dispersed Council early in 2010, and will inform the growth and concentrated Council's Growth Strategy outlined in that growth options. document. pages46 and 4.0 Homes and community facilities: Questions: Comment is noted Ms Susan 49/QuestionsH1 and H1 and H2 and CF1 and CF2 Sheahan H2 and CF1 and CF2 Environment Agency In terms of delivery mechanisms for housing and Observation community facilities (and all other development) Agree - No Action it is essential that development should be subject to assessment against the Strategic Flood Risk Assessment (SFRA). The SFRA assesses flood risk district wide in accordance with Planning Policy Statement 25 (PPS25 Development and Flood Risk). n/a Children drop their "breakfasts" litter as they get This is not a matter that can Derrick East off the 60 bus. Then later in the day we have be considered by the Core their litter from their lunches and after school Strategy. Observation snacks. We also have some college students No Action – Not an LDF Is doing the same thing but why they get off the bus here is a puzzle. The motorists leave litter from drinks and snacks, also dump large items of rubbish. We regularly get beer cans in our garden, hedge, on the pavement or in the gutter, probably from people getting off the bus or having bought cans at the Tudor Parade. page46,49/Questions: Homes and community facilities: Questions: H1 Comment is noted. Ms Susan H1 and H2 and CF1 and H2 and CF1 and CF2 Sheahan and CF2 Environment Agency In terms of delivery mechanisms for housing and Observation community facilities (and all other development) Noted – No Action it is essential that development should be subject to assessment against the Strategic Flood Risk Assessment (SFRA). The SFRA assesses flood risk district wide in accordance with Planning Policy Statement 25 (PPS25 Development and Flood Risk). It is also agreed that, generally, it is important to Noted Mr Robert provide affordable housing in the CMC. Key Posselt workers and other smaller households requiring Martin Robeson Planning an affordable home are better suited to the type Practice of accommodation that is likely to be available in Observation locations such as the CMC. Ntd N Ati page51/para1/bullet3 The Council’s aspiration to ensure a consistent, Support is welcomed Mr Michael best practice approach to streetscape design Mulhern and public realm improvements is welcomed. Greater London Authority Support Noted – No Action n/a I have written to Councillor Fisher about the This is not a matter that can Derrick East problem and received a schedule about road be considered by the Core cleaning but, although The Crossways is a bus Strategy. Observation route, I question whether it is cleaned as No Action – Not an LDF Is regularly as suggested. I also appreciate that parked cars prevent the street cleaners doing their job effectively Question HE2 Question HE2 This is not a matter for the Nikki Honan Core Strategy, the need for HUDU We would like to see all developments being requiring heath impacts will be Observation required to assess health impacts and more considered by the Noted – No Action detail as to how this would be achieved. For Development Management example the local authority and the PCT could DPD. work together to develop a screening tool, which aims to identify those developments of sufficient scale / nature to have potential positive or negative health impacts, or impacts on health service planning. This could also account for the potential of several smaller developments / regional work to have cumulative / incremental impacts. page47/para7 This particular case was not a community centre Comment is noted. Not a Cllr George Filby under threat but a local Public House which has matter for Core Strategy it is a London Borough of closed and is under threat of demolishion. Ken matter of detail. Croydon Coates has come up with the idea (he lives Observation nearby in the Lawns) that the pub could be Noted – No Action leased or bought as a freehold* for the locals comprising The Lawns, Spa Hill, Northwood Rd Beulah Hill and others immediately surrounding the building which is on the left as you go down spa Hill before The Lawns. No doubt the owners of the land (approached thro Estate Egents Fleurets) will ask a silly price but in the light of this recession wll probably come down to something less if the Council or other authority wanted to buy it. There are no community centres anywhere around the area so such one would be most welcome. I have not had time yet but I will be sending some pictures both of the building and the surrounds which include the Lawns Park. (SE19) Page55/para1 Health Impact Assessment (HIA) is a tool that The impacts of the Core Nikki Honan seeks to measure the impact on people’s health Strategy on health will be HUDU of any kind of intervention. In the local considered through the Observation government context, it is used in particular to Sustainability Appraisal Noted – No Action assess the impact on people’s health of specific process. spatial developments (e.g. impact on safety, mental health and wellbeing, opportunities for physical activity etc). Therefore this section could describe how the LDF will use HIA to assess spatial planning decisions for their impact on people’s health such as providing opportunities for physical activity, and not just the impact on health care needs. n/a making parents responsible for paying the fine if This is not a matter that can Derrick East their children are caught dropping litter be considered by the Core Strategy. Observation No Action – Not an LDF Is page46/table Yes – consideration should be given to dividing The next iteration of the Core Mr Robert the two tables which illustrate ‘Croydon’s Strategy will set out in more Posselt Housing Need’ to be area specific – e.g. ‘CMC detail the quantum and type of Martin Robeson Planning and district centres’ and ‘Rest of the Borough’, in homes growth expected in Practice order to address the concern that the CMC is each of the 16 Places. Observation not generally a suitable location for family Agree – Propose Changes housing. page51/Questions 4.0 Public Realm: Questions and Quality of the Green issues are an Ms Susan PR1 and PR2 Public Realm Questions PR1 and PR2 underlying theme for all the Sheahan topics that the Core Strategy Environment Agency We support the inclusion of these sections and is going to address. Observation note that the issue of ‘green buildings’ is also Disagree – No Change located within Section 5. It would be useful to combine ‘green buildings within the ‘homes’ and ‘public realm’ sections of this document because of the relationship between the design of homes and public spaces. page55/Question HE1 Question HE1 Support is welcomed Nikki Honan HUDU How do we deliver these options? We welcome Support the fact that the Council will seek to secure Noted – No Action planning contributions for health facilities. page49/para2/bullet1 Quality Public Realm Links could be made to the The next iteration of the Core Nikki Honan quality of public realm and health well being, Strategy will consider this HUDU including physical, mental and social suggestion. Observation implications. Agree – Propose Changes Question CF2 Community Facilities The next iteration of the Core Nikki Honan Strategy will consider this HUDU Question CF2 Under ‘How do we deliver these suggestion. Observation options?’ reference could be made to the JSNA Agree – Propose Changes to deliver health and well being facilities and improvements. page47/para2 Community Facilities The Core Strategy must Nikki Honan consider social infrastructure HUDU We would encourage review of the JSNA (Joint provision over the Plan Observation Strategic Needs Assessment), as well as the period. This will be Noted – No Action emerging Estates Strategy and other key considered in the documentation referenced above. Ongoing Infrastructure Delivery Plan. liaison with the PCT is again welcomed as this will inform the planning process to ensure health provision is in place at the right time, in the right place to support the existing community and the growth of the borough. page46/table The AMR reports of the past two years indicate This is a comment on the Brian Madge that the 5 year supply of housing units is in Annual Monitoring Report. Brian Madge Ltd doubt in later years. Moreover an update The Annual Monitoring Report Observation analysis suggests current short comings. The monitors the implementation Noted – No Action 2006-2007 AMR notes “The housing trajectory of Unitary Development Plan shows that in the short-term Croydon has policies and highlights areas enough new housing in the pipeline to meet its where intervention is required targets However in the second five-year period in the future. The Core (from 2012/13 to 2016/17), the borough is reliant Strategy will set out new on several large UDP allocations in central housing targets and broad Croydon for housing land. Should development areas for development in of any one of these sites not be developed then order to meet the need for it would increase the likelihood of the borough new homes in the borough up failing to meet its housing targets. • By 2016/17 to 2031. (the end date of the current London Plan) Croydon will have a shortfall of 259 dwellings based on current predicted completions. If the undersupply from the RPG3 period (pre-London Plan) is taken into account then this shortfall is actually over 4,300 units.” The 2007-2008 AMR notes “ However in the second five year period (from 2014/15 to 2018/19, the borough is particularly reliant on several large UDP allocations in central Croydon for housing land. Should development of any one of these sites not be develop then it is possible that the Council will not meet its minimum housing targets by the end of this period …”

This shows supply is sensitive to the loss of any one of these sites. n/a Please do something about the people who This is not a matter that can Derrick East insist on dropping litter in the street, throwing it be considered by the Core into gardens and stuffing it in hedges, also those Strategy. Observation who park their cars and dump litter in the gutter. No Action – Not an LDF Is page45/para3/bullet1 Barratt Homes (Kent) asks for clarification as to The Core Strategy is a 20 the basis for which the Council has calculated year plan and has to look Barratt Homes (kent) that of the 19,000 new homes needed in the beyond the current London Observation Borough to 2031, given that London Plan Policy Plan period. The 19,000 figure Noted – Propose Changes 3A.2 sets minimum housing targets only to is the minimum need figure for 2016/17. Our client also queries the basis on homes not a target. Targets which the Council has calculated that 45% of for homes will be included in this 19,000 provision needs to be family sized the next consultation draft of and at least 28% needs to be socially rented. the Core Strategy and will be Housing mix and tenure type should be based based on the targets included on several considerations including up-to-date in the revision of the London assessments of need, supply, and demand and Plan, a Strategic Housing site-specific circumstances such as whether Land Availability Assessment such provision would be appropriate in any and a Local Housing Market particular location. Assessment. Generally yes - Whilst mixed tenure Further details regarding the Mr Robert developments may work in certain locations, CMC will be contained in the Posselt they may be less suitable in the CMC. A large next consultation draft of the Martin Robeson Planning proportion of affordable housing for example Core Strategy. The Council Practice needs to be appropriately sized for family notes the concern but intends Observation households, however the CMC is generally an to assit and promote CMC as Noted – Propose Changes inappropriate location for children due to the an attractive place for families. nature of the housing and its inability to provide sufficient amenity space i.e. high rise, the physical environment within metropolitan centres such as Croydon and the lack of appropriate community facilities. It is agreed that a proportion of the larger affordable requirement should be provided centrally but a majority should be located in locations discussed in response to the questions above. page54/para1-2 Health & Well Being Noted. The next iteration of Nikki Honan the Core Strategy will consider HUDU Where do we want to be? / Where are we now? policies that promote health Observation We welcome this well considered section on and well being including Noted – Propose Changes health and well being, and support the interation with the public consideration of the wider determinants of realm, which incorporates the health, including air quality and noise pollution built environment. but suggest this could be expanded to reference the built form. It would be good to add some text around importance of built environment for mental health and well-being and the role of the built environment in ensuring access to safe, healthy, affordable food supply. Possible wording may include:

“An individual’s health and wellbeing is determined by a range of factors, a principal one being the built environment in which they live, work, learn or play...” page54/para2 Where are we now? We note the promotion of Support is welcomed. Nikki Honan equality and inclusion and would support HUDU reference to tackling health inequalities through Support the LDF process. Support is welcomed Page46/QuestionH2 We would support an approach whereby Comment is noted. The level housing densities are dependent on the existing of existing public transport Highways Agency public transport accessibility level. See accessibility will be an Observation paragraphs 7-8 (below). Furthermore, in an important factor in considering Noted – No Action effort to support a reduction in the need to travel, the location as well as the it is also recommended that the CS seeks to density of housing in future deliver a balanced level of jobs, housing and housing typology work. services. This approach would help to reduce Regarding jobs housing the need to travel in line with the objectives of balance the Council strategy PPG13, paragraph 30 , and would help ensure is to stimulate both an exact the plan meets with the soundness requirement matching of the two will not be of PPS12 . possible in a complex Borough within a major connurbation. The need to stimulate more jobs in the borough as part of the Enterprising City is central to the Vision. page55/Question HE1 Question HE1 We support improving access to The Core Strategy must Nikki Honan leisure facilities and healthcare facilities, but it consider social infrastructure HUDU would be helpful if the core strategy could provision over the Plan Observation confirm how this will be achieved, and whether period. This will be Noted – No Action there are any resource commitments (time and considered in the funding) into working with the PCT and other Infrastructure Delivery Plan partners to deliver this. and include delivery mechanisms. page52-53 With regard to heritage and conservation, Support is welcomed Barratt Homes (Kent) supports in principle the Barratt Homes (kent) preservation of the Borough’s heritage assets. Support Agree - No Action page55/Question HE1 Question HE1 Support is welcomed Nikki Honan HUDU How do we deliver these options? We welcome Support the idea of pooling of developer contributions Noted – No Action towards infrastructure requirements. This would enable contributions to be made and used strategically rather than provided on a piecemeal basis. This could also help to ensure the PCT is able to respond to the collective impact of smaller developments. n/a Parents are too weak in giving their children This is not a matter that can Derrick East pocket money to buy junk food. be considered by the Core Strategy. Observation No Action – Not an LDF Is page46/para1/bullet1 Our client supports in principle the aspiration to The comment is noted. The improve the design quality standards for new improvement of design quality Barratt Homes (kent) homes, particularly given the recent findings of in Croydon is an important Observation the Design for London-commissioned Seven element of the Core Strategy. Noted – No Action Study (Urhahn Urban Design, September 2009). The viability of development Although this did not specifically look at will be considered when Croydon, its conclusion that good quality preparing the Core Strategy. housing intensification is key to revitalising South London’s town centres is nevertheless informative. However, it is imperative that the Council adopts a sufficiently flexible approach to ensure development is viable and deliverable. page51/QuestionPR2 More generally, we do not think that this report is We want to achieve high Mr John Ingman a sufficient response to the urgent problems quality Public Realm Park Hill Residents' facing Croydon:- The decline in the throughout the Borough and Association infrastructure – patched roads, poor street we want places that we take Object lighting, neglected open areas and litter. pride in. It is considered that Disagree – No Change these two objectives seek to address the decline in infrastructure that is raised in this comment. n/a The law enforced with regard to the drinking of This is not a matter that can Derrick East alcohol in the street be considered by the Core Strategy. Observation No Action – Not an LDF Is page46/para2 Barratt Homes (Kent) asks that the use of The comment is noted. The planning gain and, potentially, the Community viability of development will be Barratt Homes (kent) Infrastructure Levy appropriately considers both considered when preparing Observation Government legislation and the current the Core Strategy and Noted – No Action economic climate. We would wish to avoid Infrastructure Delivery Plan. unnecessarily stifling development in the Borough by placing overly onerous financial demands on developers. page46/para2 In this respect it is also important that any S106 The comment is noted. contributions are reasonable, based on up-to- Barratt Homes (kent) date assessments of need, supply, and demand, Observation and relate in scale and kind to development. Noted – No Action Page50/para2/bullet5 With regard to the Council’s intention to produce The comment is noted. The a public realm strategy and area specific design improvement of the public Barratt Homes (kent) codes, our clients supports this in principle but realm in Croydon is an Observation would again ask that the Council is sufficiently important element of the Core Noted – No Action flexible in its approach to ensure development is Strategy. The viability of viable, achievable, and deliverable. development will be considered when preparing the Core Strategy. page46/para1 Furthermore, older people moving into The comment is noted. specialised accommodation usually do so by Mccarthy & Stone moving from bigger under occupied properties Retirement Lifestyles Ltd that could be reintroduced to the market to be Observation better occupied by families for example. In other Noted – No Action words, specialised accommodation for older people free's up under occupied properties making a better use of the existing housing stock and helping ease identified housing need. page55/Question HE1 What are the Options for Change? The Core Strategy is a Nikki Honan strategic document. It will HUDU Question HE1 We welcome the options for include policies that promote Observation improving health and community well-being set helath and well being. The Noted – No Action out in the options for change. We would further level of detail outlined in the support this section detailing how this will be comment will be addressed achieved. It may be useful to map causal through work on the relationships, such as health care provision, Infrastructure Delivery Plan. deficiencies and capacity; and likely growth and future demand. It may then be possible to address how the Council, PCT and other partners can work together the confirm how the health and well being requirements of Croydon can be met, taking into account the changing nature of supply, such as the ‘hub and spoke’ model of healthcare provision. page49/para12 Community safety aims & objectives should be The comment is noted. Ms Ann set out with the same strength of purpose (ie. Secure by Design will be Burroughs The wording is strong, clear and concise using referred to in the evidence Metropolitan Police such words as ‘require’ and ‘resist’ and all base and future versions of Object parties are immediately aware of the strong the Core Strategy ,however Disagree – No Change emphasis). Secured by design does in fact form there needs to be a balanced part of the security element section 8 in the approach between Secure by Code for Sustainable Homes and as such Design and other urban compliments sustainability. design pricinciples. page49/para2/bullet1 Purespace Group recognise the importance of Support is welcomed providing high quality public realm to improve Purespace the appearance of the Centre. In delivering the Support highest standards of public realm, Agree - No Action page51/para15/bullet2 Police Counter Terrorism Security Advisors Comment is noted. This will Ms Ann (CTSAs) should also be actively included in the be considered in the Burroughs planning process when considering large major Development Management Metropolitan Police developments or regeneration projects. DPD. Object Noted – No Action page51/para15/bullet2 Consideration should also be given to ensure Comment is noted. Not Ms Ann that this LDF Core Policy allows for the inclusion agreed. The arrangements for Burroughs of a Crime Prevention and Community Safety the detailed application of Metropolitan Police element in the Section 106 or new CILP Section 106 and CIL will be Object process. These are matters that affect the considered subsequently in Noted – No Action Boroughs infrastructure and as such should be arrangements for CIL included in future planning applications. implementation and future use of S106. page45/para2/bullet5 Improve the design quality standards required Comment is noted. Support Ms Ann for new homes and enforce this through welcomed. Burroughs planning standards. Metropolitan Police Support Noted – No Action page45/para2/bullet5 This is a welcome opportunity to raise the Comment is noted. Support Ms Ann existing standards of physical protection in all welcomed. Burroughs new housing when implementing the” The Metropolitan Police standards & Requirements for new Housing Support SPD”, together with more assertive marketing of Noted – No Action SPD3 “Designing for community safety”. page49/para11/bullet4 Croydon Council state “we want a safe and Comment is noted. Support Ms Ann secure environment for all the community” and welcomed. Burroughs “high quality public realm throughout the Metropolitan Police borough”. These are positive regeneration Support objectives and as part of the Safer Croydon Noted – No Action Partnership, CPDAs welcome the opportunity to work with Planning and project managers to improve the safety of the public realm. page49/para12 Crime Prevention, Community Safety and Comment is noted no Ms Ann cohesion are essential components necessary change. The text is specifying Burroughs to achieve a sustainable community. They are important objectives not the Metropolitan Police mentioned in ‘A Place to belong’ but stronger means of implementation and Object wording such as ‘require’ would give a greater the level of discretion in such Noted – No Action emphasis on these issues. This is necessary to implementation. ensure that they are given sufficient credence at an early stage and places the onus on the developer to conform. page51/para15/bullet12 This strategic policy needs to make provision for Comment is noted. Not Ms Ann a Crime Prevention and Community Safety agreed. The arrangements for Burroughs element in the Section 106 (planning gain) or the detailed application of Metropolitan Police new Community Infrastructure Levy Process Section 106 and CIL will be Object (CILP). These are matters that affect the considered subsequently in Noted – No Action Boroughs infrastructure and as such should be arrangements for CIL included in future planning applications. implementation and future use of S106. page50/para2 The key issue to reduce crime is to invest in In the future iteration of the Cheryll Wright crime prevention both from a social and Core Strategy we will put Safer Croydon Partnership environmental perspective forward policies relating to Observation community safety. Agree – Propose Changes page47/para2/bullet5 Where we want to be. There will be many instances Mr I.G.M. Hunter (for example on sites with high Bull point 5: This section should include public transport accessibility) Object reference to off-street parking adequate to where car parking provision Disagree – No Change accommodate residents and visitors cars. will not be required. page45/para3 Where are we now. Comment is noted. The Mr I.G.M. Hunter council intends to undertake a Bull point 2: Space for building homes is one Housing Typology Study for Observation thing, but is there the space to build the number Croydon Metropolitan Centre. Noted – No Action of homes proposed without resorting to tall blocks of apartments and the local infrastructure to support them eg: schools, community centres, sports facilities and utilities? page46/para1 What are the Options for change. There will be many instances Mr I.G.M. Hunter (for example on sites with high New Bull point 5: Ensure, through the devolved public transport accessibility) Object powers from Central Government, that sufficient where car parking provision Disagree – No Change off-street parking for all car-owning residents will not be required. and their visitors is provided in every future planning application. page46/QuestionH2 Q H2 – Yes; include a policy for off-road parking There will be many instances Mr I.G.M. Hunter for residents and visitors. (for example on sites with high public transport accessibility) Object where car parking provision Disagree – No Change will not be required. page46/para1/bullet3 Successful schemes to date have included Comment is noted. A matter to Mr Stephen setting up a fund for use in securing appropriate be considered once an Staines land for site provision. The sites will be made appropriate site has been Friends, Families & available to appropriately organised Gypsy and chosen in the Site Allocations Travellers Traveller groups on a non-profit making basis for DPD. Observation them to develop and manage. Funds from the Noted – No Action sale of land will be recycled into purchasing other suitable sites. They have also included grants for the purchase of sites and provision of basic infrastructure. The families moving onto the site will be self-builders, providing their own amenities and manage their site. They will also be offered the opportunity to buy stakes in the site, the income from which will be recycled to provide further sites. Such schemes could assist in meeting demand from Gypsies and Travellers to own their own home, where the cost of achieving this aspiration is prohibitive, as well as potentially utilising the building skills of some members of the Gypsy and Traveller community, and providing better value for money than social rented provision.” page46/questionh2 This section of the document highlights the It is not inappropriate for future housing needs in the Borough, as well as industrial sites to be located BRB (Residuary) Ltd community facilities. There is both a special and within a town centre. Croydon Observation rare opportunity to build new housing in the is recognised as a restrictive Noted – No Action Croydon Area, and the designation of Croydon transfer borough in the Town Centre as an ‘Opportunity Area’ in the London Plan. The need for London Plan is testament to this. BRB industrial land will be (Residuary) Ltd would support the overarching assessed by an industrial land objective of the Council to ensure provision of review. This will be considered additional housing in Croydon, especially given alongside the Strategic the housing need identified of 19, 000 homes by Housing Land Availability 2031. Consequently residential development Assessment and the Local needs to be encouraged on sites like Housing Market Assessment Lansdowne Road, which itself is already in an currently being prepared. area that is predominantly in residential use. As such the plan should recognise that a change of use of industrial sites may be acceptable in order to achieve the required housing growth, as outlined in the Mayor’s Industrial Capacity SPG, and to some extent in PPS3. page51/para15/bullet4 CPDAs welcome the opportunity to liase with Comment is noted. Support Ms Ann officers developing the proposed Supplementary welcomed. Burroughs Planning Document “Public realm design guide” Metropolitan Police and if appropriate the shaping of new places Support masterplans. Noted – No Action page46/para5 There is no mention of preparation of Strategic Note - both the SHLAA and Mr Andrew Housing Market Assessment and Strategic Strategic Housing Marketing Steen Housing Land Availability Assessment, both of Assessment will be an White & Sons which will be essential to justify the submission important part of the evidence Observation Core Strategy. base for the next version of Noted – No Action the plan. page45/para1 Provision should be made for the needs of the Agree no change. Included Mr Nafi Djemil disabled so that they can have a place to belong under bullet point one, page 45 as to `where do we want to Observation be`. Agree - No Action page46/para1/bullet3 We would encourage the Council to work with Comment is noted Mr Stephen RSLs and the Gypsy and Traveller community to Staines obtain the best outcome for the community. This Friends, Families & would be a positive approach giving best value Travellers for money and would help avoid ills of the past Observation and contribute to community cohesion. Ntd N Ati page51/para1/bullet3 TfL would welcome involvement in emerging Noted. Mr Michael streetscape design proposals Mulhern Greater London Authority Observation Noted – No Action page49/question CF2 The following section under 'Where do we want This is already included in the to be', highlights what is desired within the Core Strategy under the Metropolitan Police borough, again policing facilities should be reference to public service Authority included within this section. facilities meeting all of the Observation needs of the community. The Noted – No Action Recommendation: In response to question CF2, Core Strategy must consider the MPA recommend that an additional bullet social infrastructure provision point under the heading 'Where do we want to over the Plan period. This will be' which states (additional wording underlined): be considered in the • We want adequate policing facilities that will Infrastructure Delivery Plan. ensure continued effective policing continues within the Borough and resident and visitor safety is improved. This can be achieved through the successful delivery of the MPA's Estate Strategy by seeking S106 obligations from developers where appropriate. page49/question CF1-2 Furthermore, under the heading 'What are the The use of employment land Options for Change?', it is highlighted that for policing faciltiies will be Metropolitan Police provision for a more flexible approach to considered on their own Authority changing the use of employment sites for multi- merits in line with policy Object faith and community groups other than in core promoting employment Disagree – No Change employment growth zones should be adopted. generating uses in The principle of this approach is supported, employment areas. The however in order to reflect Policy 3B.4 (Industrial reference to multi-faith and Locations) of the London Plan, as referred to community groups reflects the within Section 3 above, the following is difficulty these groups have in recommended. finding suitable sites in the borough. The startegy Recommendation: In response to questions CF1 identifying potential & CF2, the MPA supports this statement employment areas will be however believe that policing facilities should be identified in the next considered as an appropriate alternative use on consultation draft of the Core employment sites. This includes within Core Strategy. Employment Growth Zones. We would however note that there is no clear definition of 'Core Employment Growth Zones' within this document. page49/question CF2 Under the heading 'How do we deliver these The use of both S106 options', the MPA acknowledge the principle of agreements (referred to as Metropolitan Police the Community Infrastructure Levy (CIL) Planning Gain) and the use of Authority however it is prudent to emphasise the necessity CIL are already referred to in Observation for securing planning obligations under Section the Core Strategy. Disagree – No Change 106 (Town and Country Planning Act 1990) to run parallel with the CIL. CIL Guidance published by the Communities and Local Government Department supports this. Section 64 states that planning obligations sought through Section 106 will complement CIL. It notes in some cases planning obligations may be the only suitable tool to secure site specific benefits in particular. For example CIL will rely upon future forecasting of infrastructure requirements (potentially including policing) however policing requirements can be influenced by geographic location, demographics, accessibility and the economy; all of which are factors outside of the MPA's control. Accordingly, and in order to reflect CIL guidance, it is therefore appropriate that the emerging Core Strategy is updated to refer to both planning obligations being secured through the traditional Section 106 route and the use of the CIL where appropriate. page20/para2/bullet4 “Ensure that the design process addresses the Comment is noted. Agree Ms Ann issue of crime and fear of crime” reference to Secure by Design Burroughs will be woven into subsequent Metropolitan Police It is important to ensure design processes but it documents. Object is also crucial to Deliver Safe, Secure and Agree – Propose Changes Sustainable Developments.

To do this it is essential for Croydon to introduce objectives that raise acceptable standards of physical security and protection on all new developments. The SBD (Secured by Design) scheme is a nationally accepted scheme that sets specific, measurable, achievable physical standards to be applied, thus allowing enforcement of planning conditions. page49/questions CF1 Recommendation: In response to questions CF1 The use of both S106 & CF2 & CF2, whilst the MPA acknowledge this CIL agreements (referred to as Metropolitan Police approach, the MPA recommends that reference Planning Gain) and the use of Authority is made to the parallel need for both planning CIL are already referred to in Object obligations sought through S106 agreements the Core Strategy. Disagree – No Change and CIL. We recommend that following bullet point be added under 'How do we deliver these options' (additional wording underlined): • Use planning obligations under Section 106 of the TCPA to secure site specific benefits where required or appropriate. page45/para2/bullet1 The London Plan seeks the maximum A target figure for the reasonable amount of affordable housing from provision of affordable homes Purespace residential and mixed-use schemes, having will be considered in the next Object regard to borough affordable housing targets consultation draft of the Core Agree – Propose Changes and the need to encourage rather than restrain Strategy. residential development and the individual circumstances of the site (including site costs, availability of public subsidy and other scheme requirements). As such, in terms of the references to the number of affordable homes ‘required’, the Core Strategy should express the provision of affordable homes as a target figure and subject to individual site circumstances and constraints. Page47/Para1/Bullet7 Under the heading Community Facilities, bullet The comment is noted. point 7 makes reference to 'Emergency Metropolitan Police services, Council and other public service front Authority offices'. This complies with Policy 3A.18 of the Observation London Plan, which outlines 'policing facilities' Noted – No Action as a community facility. Page47/Where do we The following section under 'Where do we want The comment is noted. Police want to be to be', highlights what is desired within the facilities are included in the Metropolitan Police borough, again policing facilities should be general term public service Authority included within this section. facilities. Object Noted – No Action Page47/Where do we Recommendation: In response to question CF2, Thhis level of detail is want to be the MPA recommend that an additional bullet anappropriate at this stage in Metropolitan Police point under the heading 'Where do we want to the plan making process. Authority be' which states (additional wording underlined): Object Disagree – No Change • We want adequate policing facilities that will ensure continued effective policing continues within the Borough and resident and visitor safety is improved. This can be achieved through the successful delivery of the MPA's Estate Strategy by seeking S106 obligations from developers where appropriate. Page48/Para2/Bullet3 Furthermore, under the heading 'What are the An Employment Land Review Options for Change?', it is highlighted that will assess our employment Metropolitan Police provision for a more flexible approach to designations and the findings Authority changing the use of employment sites for multi- will inform the next Observation faith and community groups other than in core consultation draft of the Core Noted – Propose Changes employment growth zones should be adopted. Strategy. The details of The principle of this approach is supported, Employment Land protection however in order to reflect Policy 3B.4 (Industrial policy will be provided in Locations) of the London Plan, as referred to future version s of the Core within Section 3 above, the following is Strategy. A hierarchical recommended.Recommendation: In response to approach is likely to be questions CF1 & CF2, the MPA supports this adopted. statement however believe that policing facilities should be considered as an appropriate alternative use on employment sites. This includes within Core Employment Growth Zones. We would however note that there is no clear definition of 'Core Employment Growth Zones' within this document. Page49/Para1/Bullet5 Under the heading 'How do we deliver these The comment is noted. options', the MPA acknowledge the principle of Metropolitan Police the Community Infrastructure Levy (CIL) Authority however it is prudent to emphasise the necessity Object for securing planning obligations under Section Noted – No Action 106 (Town and Country Planning Act 1990) to run parallel with the CIL. CIL Guidance published by the Communities and Local Government Department supports this. Section 64 states that planning obligations sought through Section 106 will complement CIL. It notes in some cases planning obligations may be the only suitable tool to secure site specific benefits in particular. For example CIL will rely upon future forecasting of infrastructure requirements (potentially including policing) however policing requirements can be influenced by geographic location, demographics, accessibility and the economy; all of which are factors outside of the MPA's control.Accordingly, and in order to reflect CIL guidance, it is therefore appropriate that the emerging Core Strategy is updated to refer to both planning obligations being secured through the traditional Section 106 route and the use of the CIL where appropriate.

Planning Policy Statement 1 (PPS1) states that Council’s should prepare development plans which promote inclusive, healthy, safe and crime free communities and Circular 05/05 states that developers may be expected to contribute towards the cost of infrastructure provision, which would not have been necessary, but for their development. Page49/How do we Recommendation: In response to questions CF1 The Core Strategy in future deliver these options & CF2, whilst the MPA acknowledge this CIL will refeer to both Section 106 Metropolitan Police approach, the MPA recommends that reference and CIL as means of Authority is made to the parallel need for both planning achieving infrastructure Object obligations sought through S106 agreements provision. Agree – Propose Changes and CIL. We recommend that following bullet point be added under 'How do we deliver these options' (additional wording underlined):

• Use planning obligations under Section 106 of the TCPA to secure site specific benefits where required or appropriate page49/para1 Planning Policy Statement 1 (PPS1) states that The comment is noted. Council’s should prepare development plans Metropolitan Police which promote inclusive, healthy, safe and crime Authority free communities and Circular 05/05 states that Observation developers may be expected to contribute Noted – No Action towards the cost of infrastructure provision, which would not have been necessary, but for their development. n/a Thank you for the invitation to comment on the Comment is noted Ms Claire Craig Core Strategy Issues and Options Initial Report. English Heritage English Heritage is the government’s advisor on Observation all matters relating to the historic environment Noted – No Action and a statutory consultee in respect of the Strategic Environmental Assessment (SEA) of plans. We are keen to ensure that the protection of the historic environment is fully taken into account at all stages and levels of the Local Development Framework process. page51/para1 Purespace Group recommend that the Council An open spaces and prepares a strategy for the provision of open indoor/outdoor leisure study is Purespace space in the Borough as it should not be a pre- being prepared and will in Observation requisite for all development to provide a small form the next consultation Noted – No Action public space. Open spaces should also be report of the Core Strategy. carefully monitored to ensure that they remain fit The Core Strategy seeks to for purpose and inviting to all members of the ensure that people have community access to good quality housing choices that suit lifetime needs, which includes homes to a high standard of design incorporating some amenity space. page51/QuestionPR2 Natural England believes that local authorities Comment is noted. The Mr David should consider the provision of natural areas as standards advocated will be Hammond part of a balanced policy to ensure that local considered for inclusion in Natural England communities have access to an appropriate mix subsequent DPD's. Observation of green-spaces providing for a range of Noted – No Action recreational needs, of at least 2 hectares of accessible natural green-space per 1,000 population. This can be broken down by the following system:

• No person should live more than 300 metres from their nearest area of natural green-space; There should be at least one accessible 20 hectare site within 2 kilometres; There should be one accessible 100 hectares site within 5 kilometres; There should be one accessible 500 hectares site within 10 kilometres. This is recommended as a starting point for consideration by local authorities and can be used to assist with the identification of local targets and standards. Whilst this may be more difficult for some urban areas/authorities than other, Natural England would encourage local authorities to identify the most appropriate policy and response applicable to their Borough. page45/para2/bullet5 Natural England is pleased to see inclusion of The comment is noted. Mr David access to outside amenity space under the Hammond section on homes, and the following may be of Natural England use/interest in these considerations: Observation Noted – No Action page46/para1/bullet3 In relation to need for provision we Gypsies and Comment is noted. Support Mr Stephen Travellers FFT and TLRP welcome the welcomed. Staines commitment to deliver sites via key housing Friends, Families & locations to be identified in a Site Allocations Travellers DPD. Support Noted – No Action Page48/questionCF1 It was interesting to read of all the new The Core Strategy is not able developments in the Croydon Talk leaflet, to influence education policy particularly with regard to education and the new in other boroughs. Observation academies. No Action – Not an LDF Is These are fine but what will happen to Edenham and Shirley High Schools? Will children still be “ bussed in” in even greater numbers from the Inner London boroughs? Surely the answer is that their local schools should be improved! page45/para3/bullet1 A place to belong: Homes: Comment is noted. Ms Alison Fairhurst - This states that at least 28% of the new homes Government Office for needed in Croydon up to 2031 need to be London affordable. London Plan Policy 3A.9 says that Observation “In setting targets boroughs should take account Noted – No Action of regional and local assessments of need, the Mayor’s strategic target for affordable housing provision that 50 percent of provision should be affordable and, within that, the Londonwide objective of 70 percent social housing and 30 percent intermediate provision”. Should you take this forward as policy in your published plan, at examination you will need to provide a robust evidence base to justify that this is the most realistic and achievable policy for your borough. Page48/para1/bullet5 A study of Open Spaces, indoor leisure and Comment is noted Mr David playing pitches will be completed by June 2009; Hammond Natural England would be interested in seeing a Natural England copy of this report when it is ready. Observation Noted – No Action page45/para3 Is the figure of 19,000 new homes by 2031 The figure of 19,000 homes by correct? 2031 represents the current Metropolitan Police known need for new homes in Authority the borough up to 2031 Observation Noted – No Action page50/para2/bullet2 Natural England is pleased to see and supports Comment is noted. Support Mr David the consideration of ‘Greening’ and soft welcomed. Hammond landscaping of the public realm, as mentioned Natural England previously. Support Noted – No Action page52 English Heritage once again welcomes the Comment is noted. The Ms Claire Craig quality of this report, particularly its strong willingness of English Heritage English Heritage acknowledgement of heritage issues and to remain involved in the Observation resources, and the character based approach preparation in the LDF is Noted – No Action taken in the places section of the document. As welcome. the Core Strategy develops, English Heritage anticipates that the ‘Options for Change’ for Heritage & Conservation will be elaborated on as the character of the plan’s focal places is analysed collectively to give a borough-wide picture. For example, we have highlighted the significance of the Heritage at Risk Register in a related sustainability appraisal response and we would encourage the borough to consider the implications of its entries on this Register for their broader strategic objectives such as regeneration. page52 English Heritage would strongly advise that the Comment is noted. The Ms Claire Craig Council’s own conservation staff be closely Council recognise the English Heritage involved throughout the preparation of the LDF. importance of involving Observation They are often best placed to provide advice on: Conservation staff in the Noted – No Action local historic environment issues and priorities, preparation of the Core sources of data; interpretation of policies which Strategy. reflect the needs of the local historic environment; and the contribution of the historic environment. They are also best placed to suggest opportunities for securing wider benefits for the future conservation and management of historic assets; this advice is based on the information provided by you and for the avoidance of doubt does not affect our obligation to advise you on, and potentially object to any specific development proposal which may subsequently arise from this or later versions of the plans, and which may, despite the sustainability appraisal, have adverse effects on the environment. page45/para1 Quality of life must take precedence in the "new" Comment is noted Mr K Pope Croydon in order to keep the middle classes here. I moved to Sutton from Thornton Heath Observation where I had lived for most of my life because my Noted – No Action quality of life needs were simply not being met by livng in that place and watching it go downhill. Thornton Heath has declined so much in my view it almost feels squalid and dangerous in parts and for owner occupiers who wish to live in a clean, decent,crime free environment this is unacceptable especially given the amount of council tax we have to pay. I voted with my feet and got out. n/a Short termism, penny pinching, a complete Comment is noted Mr K Pope disregard for the past, a failure to enforce the rules and the revolving door of politics at the Observation town hall has helped to make Croydon in to the Noted – No Action kind of grim place it is today. Croydon doesn't do vision because Croydon has no imagination and the council has preferred grandiose projects which look good on paper but rip the guts out of communities and ruin the urban landscape. (Who decided Surrey St needs a huge block of flats in it? Who wants to take responsibility for the Park Place fiasco which would be tragic if it wasn't so laughable. Sky scrapers on Cherry Orchard Road-no,no no!!!) page46/para1 To the list of options it is requested that Meeting the lifetime needs of specialised accommodation for older people is the boroughs residents and Mccarthy & Stone added. PPS3 and the Government's National delivering a range of housing Retirement Lifestyles Ltd Strategy for Housing in an Ageing Society types is already included in Observation explicitly require local planning authorities the Core Strategy. Disagree – No Change through the LDF system to plan for current and future demographic change which will include an increase in the number of older people in the Borough in the plan period and in the need for specialised accommodation for older people. page46/Question H1 Question H1 - Are these the right options? Comment is noted. The proportion of housing to be 3 Menta There appears to be an inconsistency between or more bedroom by area will Object 'Where we are now' (p45) and the 'Croydon be considered in detail in Agree – Propose Changes Housing Need 2008' table (p46). Page 45 states Housing Typology studies and that 45% of new homes need to be family sized, will be set out in subsequent whereas the table on page 46 states that 59.3% versions of the Core Strategy. of new homes should be 3 bedrooms or more. These figures do not appear to be consistent. In any event, any future policy should apply to borough-wide targets and not necessarily individual sites where the characteristics and potential of the site should inform mix. page45/para3/bullet5 In relation to Gypsies and Travellers you say Comment is noted. Agree the Ms Alison that the GLA has identified a need within the criteria for location of gypsy Fairhurst borough for the provision of additional pitches. and travellers sites will be Government Office for Paragraph 31 of Circular 01/2006 ‘Planning for incorporated in the next London Gypsy and traveller Caravan Sites’ says that a consultation draft. Observation Core Strategy should set out the criteria for the Agree – Propose Changes location of gypsy and traveller sites which will be used to guide the allocation of sites in the relevant DPD; these criteria will also be used to meet unexpected demand. page45/para3/bullet1 CGLP support the notion that 80% of the Comment is noted. available land supply for new homes is located Croydon Gateway Limited in the CMC. In respect of the delivery of housing Partnership (including affordable housing), CGLP consider Support that the following factors should be taken into Noted – No Action account. page45/para3/bullet1 The document advises that of the 19,000 new The type and size of housing homes required up to 2031, 45% need to be is determined by future Purespace family sized units. The type and size of the policies in the Core Strategy Observation housing is dictated by the economic and which are based on an Disagree – No Change physical constraints and opportunities of a assessment of need contained particular site. Purespace Group consider that in the Local Housing Market the emerging Core Strategy should reflect this Assssment and the availability constraint whilst still address housing need in of land identified in a Strategic the Borough. Housing Land Availability Assessment. page45/para3/bullet2 Purespace Group support the notion that 80% of The comment is noted. the available land supply for new homes is Purespace located in the CMC. However, previously Observation developed sites with good accessibility to public Noted – No Action transport should also be suitable for residential development to assist in the delivery of housing (including affordable housing).,. page46/para1/bullet3 This could encompass a wide range of Comment is noted. Mr Stephen schemes, including: Staines Friends, Families & new, improved designs that can be replicated Travellers elsewhere, radical approaches to procurement Observation and delivery, and using public funding to Noted – No Action facilitate the development of self-build and low cost owner occupied sites, providing investment was protected or recycled. Bids can only be submitted by local authorities, ALMOs or RSLs. However, these organisations are encouraged to be proactive, and work with the Gypsy and Traveller community to develop innovative schemes. page50/para2/bullet2 Open spaces should also be carefully monitored Comment is noted. No to ensure that they remain fit for purpose and change necessary Croydon Gateway Limited inviting to all members of the community. Partnership Observation Noted – No Action page51/para1 In delivering the highest standards of public Comment is noted. The text of realm, CGLP recommend that the Council page 51 does not suggest that Croydon Gateway Limited prepares a strategy for the provision of open all developments however Partnership space in the Borough as it should not be a pre- small should require onsite Observation requisite for all development to provide a small provision of public space. Noted – No Action public space. page49/para2/bullet1 CGLP recognises the importance of providing Comment is noted. high quality public realm to improve the Croydon Gateway Limited appearance of the Centre. The permitted Partnership scheme for Ruskin Square provides an area of Observation good quality public realm. Noted – No Action Page51/QuestionPR2 No formal comment, other than the Council may Comment is noted Mr David wish to include/reference the provision of Hammond Green/Open Spaces, Parks in this section which Natural England can then be linked to the Quality Public Realm Observation section, strengthening the document further. Noted – No Action page45/para3/bullet1 The document advises that of the 19,000 new Comment is noted. The homes required up to 2031, 45% need to be proportion of housing to be 3 Croydon Gateway Limited family sized units. The type and size of the or more bedroom by area will Partnership housing is dictated by the constraints and be considered in detail in Observation opportunities of a particular site. Depending on Housing Typology studies Noted – No Action the nature of proposed development and site location and both economic and physical site constraints, it may not be appropriate to include a large percentage of family housing within some town centre locations. CGLP consider that the emerging Core Strategy should reflect this constraint whilst still address housing need in the Borough. page55/QuestionHE2 The health and well being of the disabled should The comment is noted. The Mr Nafi Djemil also be separately identified as an option Council shall address this issue in a future consultation Observation report for the Core Strategy. Noted – Propose Changes page46/para1/bullet3 We are keen to encourage the development of Comment is noted. Mr Stephen innovative solutions for site accommodation Staines provision that could help: Friends, Families & Travellers speed up delivery, improve standards and value Observation for money, and give better outcomes. Ntd N Ati page46/para1/bullet3 We would also like to take this opportunity to Comment is noted Mr Stephen draw the council’s attention to part of the Site Staines Grant Guidance (Homes and Community Friends, Families & Agency, Jan 2009) which encourages innovative Travellers approaches in section 8: Observation Noted – No Action Page62/para2/bullet9 P.62 Clarification needed on what a 1:50 rainfall Agreed. Further clarification Mr M Jennings event is. will be made in a future Association of Croydon iteration. Conservation Societies Observation Agree – Propose Changes page34/QuestionES1- We would also wish to support the proposals for upport is welcomedupport is Mr Andrew ES2 educational development (Questions ES1 and welcomed Walters 2), noting that the Airport is a source of Biggin Hill Airport Limited apprenticeships and skills training, which it is Support looking to enhance. Noted – No Action page46/para1/bullet3 The Core Strategy will also need to set out Comment is noted. Agree the Mr Stephen criteria as required in para 31 of Circular 1/2006 criteria for location of gypsy Staines to aid allocation of sites and also meet and travellers sites will be Friends, Families & unexpected demand. incorporated in the next Travellers consultation draft. Observation Noted – No Action Page50/para2/bullet3 The potential for an ‘urban forest’, linking the Comment is noted. Support Mr David Green Belt’ in the South of the Borough with the welcomed. Hammond Wandle Regional Park and other ‘Green Links’ is Natural England to be commended, encouraged and supported. Support Noted – No Action page46/table The London Plan seeks the maximum Comment is noted. The table reasonable amount of affordable housing from on Page 46 gives an estimate Croydon Gateway Limited residential and mixed-use schemes, having of the number of units Partnership regard to borough affordable housing targets required. It does therefore Observation and the need to encourage rather than restrain provide an initial target. The Noted – No Action residential development and the individual wording of the policy circumstances of the site (including site costs, regarding the target will be availability of public subsidy and other scheme made more explicit in requirements). As such, in terms of the subsequent documents. references to the number of affordable homes ‘required’, the Core Strategy should express the provision of affordable homes as a target figure and subject to individual site circumstances and constraints. Page49/Question CF1 Q CF 1 - No; the co-location of health facilities is Disagree. Co-location of Mr I.G.M. Hunter contentious and needs more consideration. The health facilities is a detailed assumption that it is viable needs to be matter for healthcare Object questioned and qualified in this document and providers to address. Disagree – No Change its successor. page45 The HCA also welcomes the recognition within Noted, the Core Strategy is the second bullet point of the “Where are we not designating sites for Homes and Communities now?” section on page 45 of the consultation particular uses. Agency document that available land supply Object opportunities for new homes exist within Noted – No Action Coulsdon. The HCA is of the view that it should be explicitly acknowledged within this statement that the Cane Hill site in Coulsdon is one such opportunity to deliver new housing. page45 The HCA is fully supportive of all the Council’s Support is welcomed objectives within the “Where do we want to be?” Homes and Communities section on page 45 of the consultation Agency document, which sets out aims such as Support providing sufficient housing; ensuring people Agree - No Action have access to good quality housing choices that suit lifetime needs; and providing a greater mix of types, sizes and locations of housing. Page 47/Bullet point 7 Bull point 7: These facilities must be “stand- The council accepts that a Mr I.G.M. Hunter alone”, that is, not shared with community range of facilities (some with centres; for example, specialised floors for specialist provision) will be Object Gymnastics cannot be used for general needed, but consider that this Disagree – No Change purposes. This point should recognise the issue. is implicit in the statement. page45/para3/bullet1 The Core Strategy includes a target to deliver The location and numbers of Mr Michael 19,000 new homes by 2031, which is new homes will be informed Mulhern questioned. PPS3 on Housing states that by a Strategic Housing Land Greater London Authority housing targets should be set for up to 15 years. Availaiblity Assessment. More Observation Local Development Documents should identify a detail will come in subsequent Noted – Propose Changes supply of specific, developable sites for years 6 versions of the Core Strategy. to 10 and, where possible, for years 11 to 15. General support is welcome. Where it is not possible to identify specific sites for years 11-15, broad locations for future growth should be indicated. page46/table The Core Strategy identifies the delivery of Support is welcomed Mr Michael 13,277 new homes by 2021, which accords with Mulhern emerging figures in the London Plan Greater London Authority consultation draft 2009 and is acceptable. Support Noted – No Action page46/table The Core Strategy also sets borough wide General support is welcome. Mr Michael targets for house sizes, levels of affordable Mulhern housing and tenure split. This approach is Greater London Authority supported, however, proposals should be Support strongly justified with a local housing capacity Noted – No Action study. page45/para3/bullet2 The Core Strategy indicates that 80% of housing The location of new homes Mr Michael need would be provided within the Croydon will be informed by a Strategic Mulhern Metropolitan Town Centre with some Housing Land Availaiblity Greater London Authority opportunities for residential development Assessment. More detail will Observation available along the A23 growth corridor. Whilst it come in subsequent versions Noted – Propose Changes is understood that more detailed proposals for of the Core Strategy. General the Croydon Town Centre will be established support is welcome. within the emerging Area Action Plan / Opportunity Area Planning Framework, the Core Strategy should broadly demonstrate that this housing target for the Town Centre is realistic and achievable. As stated above, the concentrated approach to development is largely supported. page45/para3 The Council’s strategy must seek to encourage Comment is noted. The Mr Austin Mackie a proportion of supply from small and medium Councils Strategy for housing Austin Mackie Associates sized ‘dispersed’ schemes that are capable of land supply will include an Ltd being integrated into the existing urban fabric element of small sites Observation without requiring major infrastructure provision which will not call for Noted – No Action enhancements. major infrastructure enhancements. page46/para2/bullet6 However, in order to ensure that sufficient The design of new homes in housing is delivered the Council needs to be Croydon needs to be BRB (Residuary) Ltd mindful of being overly prescriptive regarding sufficiently flexible to meet the Observation design and space standards and types of changing needs of Croydon's Noted – No Action dwellings. BRB (Residuary) Ltd considers that population over the next 20 sites in the town centre that are highly years. The type of homes to accessible are better suited to delivering high be developed in the borough density schemes. will be informed by a Strategic Housing Land Availability Assessment and a Local Housing Market Assessment. page55/para2 We would also welcome health targets and The next iteration of the Core Nikki Honan outcomes in the core strategy, that reflect the Strategy will propose potential HUDU targets set out in the Local Development monitoring indicators. Object Agreement, and can be monitored through the Noted – Propose Changes Annual Monitoring Report. page49/question CF1 Under the heading Community Facilities, bullet Support is welcomed. point 7 makes reference to 'Emergency Metropolitan Police services, Council and other public service front Authority offices'. This complies with Policy 3A.18 of the Support London Plan, which outlines 'policing facilities' Agree - No Action as a community facility.

Recommendation: In response to question CF1, the MPA support this section, particularly the reference to emergency services as a community facility. page46/para1/bullet4 The references to joint working between The comment is noted. Croydon Council and the HCA (particularly with Homes and Communities regard to the Borough Investment Plan) Agency throughout the consultation document are Observation acknowledged, in the context of the HCA’s Noted – No Action commitment to the delivery of homes within the Borough. Page 48 Bull point 7: The Environment Network web site The comment is noted. Mr I.G.M. Hunter comes on line this month (Oct) and will be an important adjunct to the Local Strategic Observation Partnership. This should be recognised in this Noted – No Action point. page51/questionPR2 This aspiration should, however, be expanded to This will be considered in the Mr Michael ensure that all new development not only next iteration of the Core Mulhern contributes to the public realm improvement but Strategy. Greater London Authority that they themselves also achieve a high quality Observation design. Agree - No Action Page51/Question PR2 Q PR 2 – Yes; this point should have made it Disagree. It is unrealistic to Mr I.G.M. Hunter clear that the general public were entitled to float expect the council to fund a ideas and to have them professionally costed. If professional costing of all Object the design competitions seek only professional suggestions made by the Disagree – No Change designers the Core Strategy will fail the very public. It will, however, ensure people it is devised to help, the residents of the that all Masterplans are Borough. subject to extensive public consultation. Q PR 1 Q PR 1 – Broadly, yes, but see comments. The comment is noted. Mr I.G.M. Hunter

Observation Noted – No Action page52/para3 Comment The destruction of the last remaining The comment is noted. Mr I.G.M. Hunter hanger at the former was bad example of destroying a heritage asset and Observation could have been avoided. It should have been Noted – No Action listed by the Council, never mind National Heritage. An opportunity to create a living Aviation museum complex on the site of the first International Airport has been lost. Page52/Para1/Bullet7 Comment Bull point 5: I am sure that those who The comment is noted. Mr I.G.M. Hunter know the type of “quality” that should be Members of the public are statutorily listed can be assured that Croydon’s always welcome to submit Observation historical heritage will be protected within the candidates for local listing to Noted – No Action bounds of the Core Strategy but the general the council's Conservation public should be presented with a periodic Officer for consideration. invitation by the Council to review a list of potentially historic entities. Buildings alone aren’t the only objects worthy of preservation/protection. This point should be more embracing. page55/QuestionHE 2 Q HE 2 - A pollution-free raised park above Disagree. The suggestion to Mr I.G.M. Hunter Wellesley Road (See Page 42-How do we build a raft over Wellesley deliver the options - Bull point 9). Road has been discussed at Object length and is an option the Disagree – No Change council has decided not to pursue. page54/para2/Bull Where do we want to be. The comment is noted. Mr I.G.M. Hunter point 5 Bull point 5: This point is in danger of being in opposition to the desire to co-locate health Observation facilities (see page 48-What are the options for Noted – No Action change – Bull point 2). Page 55/What are the What are the options for change Disagree. The suggestion to Mr I.G.M. Hunter options for change build a raft over Wellesley Bull point 6: The consideration of an Road has been discussed at Object environmentally friendly raft above Wellesley length and is an option the Disagree – No Change Road should form part of this implementation. council has decided not to pursue. Question HE1 Q HE 1 - Yes The support is welcomed. Mr I.G.M. Hunter

Support Noted – No Action page45/para2/bullet1 Devogrove agrees with page 45 of the Report The comment is noted. The which refers to the need to provide family Council will consider further Devgrove housing and ensure the people have access to the arguments for and against Object good quality housing choices. The achievement Green Belt and MOL Noted – Propose Changes of these objectives will be assisted if some of the amendment in the next future housing requirement is provided on land consultation report for the presently within the extent of the green belt. Core Strategy. Land released from the green belt, well related to public transport provision, would enable the construction of family homes, providing attractive affordable accommodation for local people. page46/questionh2 The provision of new housing between Kent The Council will consider Gate Way, Lodge Lane and Huntingfield at further the arguments for and Devgrove Addington could produce an exemplar scheme, against Green Belt and MOL Observation displaying high design quality standards, in a amendment in the next Noted – Propose Changes critical strategic location. Our response to consultation report for the Question H2 is to suggest that a limited green Core Strategy. belt release be promoted at Addington for an exemplar scheme demonstrating the highest design quality standards. page46/questionh2 Land between Kent Gate Way and Lodge Lane, The Council will consider Addington occupies a strategic location within further the arguments for and Devgrove the Borough and would also represent a against Green Belt and MOL Observation potential hub, accommodating new community / amendment in the next Noted – Propose Changes health / leisure / recreation facilities adjacent to consultation report for the the Addington Village tram stop. The Addington Core Strategy. Village tram stop represents a significant public transport focal point around which a new sustainable development form can be realistically achieved. page50and55/question If a limited green belt release is undertaken off The Council will consider he2 Kent Gate Way, Addington, a high quality public further the arguments for and Devgrove realm can be achieved as proposed at page 50 against Green Belt and MOL Observation of the Initial Report. Equally, the opportunity amendment in the next Noted – Propose Changes could be taken in conjunction with such a consultation report for the sustainable development to improve access to Core Strategy. leisure, health care and other necessary community facilities. Our response to Question HE2 is to draw attention to the potential of new development off Kent Gate Way, Addington to contribute to the delivery of necessary facilities supporting the local community. The Airport also provides two other key activities In the next iteration of the Mr Andrew under the Culture & Leisure heading (Questions Core Strategy the Council will Walters LC1 and 2). Flying training and private flying are identify Biggin Hill as a key Biggin Hill Airport Limited leisure pursuits undertaken by significant location adjoining the Borough. Observation numbers, both as training towards qualifications Noted – Propose Changes and for straightforward leisure, perhaps associated with other sports (eg. golf). Secondly, people like to visit airports to watch the flying activity and to discover some of the history. The Airport’s new hotel, for which planning permission has now been granted, will partly meet this demand in its coffee shop. Planning permission has also been granted for a heritage centre at Biggin Hill. This will be operated by Biggin Hill Trust and funded by S106 contributions from the adjacent Leavesden Housing Development.These activities are unique to the sub region and provided just across the borough boundary, so are clearly an area for cross-borough co-operation (Questions HC1 and 2). page53/questionHC2 In this plan Croydon should carefully examine Whilst it may not be Mr Bill Tubb the architectural and historical quality of existing appropriate to save every buildings while considering new heritage assest the next Observation redevelopments. Croydon has so little left by iteration of the Core Strategy Noted – Propose Changes way of fine buildings with architectural or historic will proposes strategies for merit and we cannot afford to loose any more. the heritage of the Borough. Page46/QuestionH2 Housing provision for the disabled should not be The Core Strategy will need to Mr Nafi Djemil identified as an inappropriate development , and be in conformity with National should in fact be encouraged , in such areas as policy and will follow Object backland development , back garden recommendations on the Noted – Propose Changes development and also in LASCs. provision of wheelchair accessible and adaptable homes. Development of LASCs, backland and gardens will be in line with National and regional policy. Character and local distinctiveness wil be considered and a Borough character appraisal will be prepared to inform the dierction of policy for the Core Strategy. page45/para2/bullet1 The housing needs of disabled people. I am It will be consdered in the Mr Nafi Djemil disabled and would like my housing needs to be subsequent consultation drafts. identified in the options Object Agree – Propose Changes Page 49 Q CF 2: - Yes; under "how do we deliver these The comment is noted. Mr I.G.M. Hunter options" should be added new bullet point 7. - The Croydon Environment Network will enable Observation residents to communicate betweeen Noted – No Action themselves, various local advice organisations and the council, to move programmes of community benefit forward. page45/para2 Housing provision in the form of one to two The location for special needs Mr Nafi Djemil bedroom flats/bungalows should be made for housing for those with learning the people with learning and other disabilities in and other diabilities will need Observation area near their immediate families. to be considered in the Noted – No Action econtext of site characteristics and the special needs of the potential occupant through the development control process. page52/para3 The temptation for designating areas as either Comment is noted. Mr Ibo Djemil Conservation Areas or LASCs should be Conservation and LASCs resisted if such designation has been have been designated in order Observation encouraged by local wealthy and influential to prevent detrimental Noted – No Action residents and Councillors as a tool to prevent development. They are not a much needed new housing. prescription against well designed new housing. page45/para3/bullet3 The housing needs of Croydon means that A Strategic Housing Land Mr Ibo Djemil backland development and infilling with quality Availability Assessment is homes must be encouraged. being prepared. Generally Observation backland development will not Disagree – No Change be encouraged as it potentially undermines the character of the area. heritage & conservation The erosion of the suburban character should be The council intends to have Mr Ibo Djemil encouraged on the grounds that it no longer policy that protects the meets multi - cultural , multi-- ethnic residential character of the Object and multiwealth charcter . various parts of the Borough. Disagree – No Change n/a Croydon is getting dirtier every day and it would Noted. Andonetta Mansi be nice if it where cleaner Observation No Action – Not an LDF Is page51/para1/bullet4 The proposal to produce a Supplementary Support is welcomed. Mr Michael Planning Document (SPD) on Public Realm Mulhern Design Guide is supported, and TfL seek to Greater London Authority work collaboratively with the Council on Support developing this guidance. The document should Noted – No Action cross refer to TfL’s Streetscape Design Guidance document which can be viewed at the below link: http://www.tfl.gov.uk/businessandpartners/public ations/4858.aspx page46/QuestionH2 Backland development should be viewed as an Disagree. The council wishes Mr Ibo Djemil excellent way to provide well built detached to protect the open character family houses. of large gardens where they Observation are an important part of the Disagree – No Change character. A borough character appraisal will be prepared in order to assess the important features of the borough's constituents parts. page 52 On page 52 of the consultation document, it is Not a matter for the Core noted that Croydon Council currently has 1,066 Strategy. Homes and Communities buildings that are locally listed. Two of these Agency buildings (the Cane Hill Hospital Chapel and Observation Administration Block) are located on the Cane Noted – No Action Hill site, on top of the hill where the hospital complex was sited. In respect of delivering options for heritage and conservation, it is considered that the incorporation of these two locally listed buildings into the redevelopment scheme for the Cane Hill site would be best done through a masterplanning exercise. page46/para2/Question Provision of bungalows and flats should be Comment is noted. Mr Ibo Djemil H2 made for the disabled in Purley , Shirley and Coulsdon . The existing provision is Observation inappropriate and in the wrong locations. Noted – No Action page46/questionh2 The development of new detached house on The comment is noted. The Mr Ibo Djemil backland plots should be actively encouraged in broad locations for new the south of of the Borough. homes will be reviewed in Observation future drafts of the Core Disagree – No Change Strategy. page45/para2/bullet1,3 Provision of new bungalow type housing should Comment is noted. Mr Ibo Djemil be made for disabled people in the wealthy areas of the borough , such as Purley. Much of Observation the existing provision is either inappropriate or in Noted – No Action wrong locations. Page 53 Q HC 1 - Yes The support is welcomed. Mr I.G.M. Hunter

Support Agree - No Action page50/para1/bullet1 Your comments on improving the public realm Support is welcomed. Mr Bill Tubb are sound, Croydon Council is certainly in need of education on this matter. There are several Support developments over recent years that stand as Noted – No Action examples of poor planning and hopefully some can be redeemed. The examples that come to mind include:- Reedham estate Purley, Rutherfield and Deepfield, Coulsdon, and Forestdale, Oswald estates Selsdon. Driving to or through these estates with very narrow roads and insufficient parking is a nightmare. page49/questionhcf1 Similarly with places of worship, these develop The Core Strategy must Mr Bill Tubb as required. It is certainly not necessary for consider social infrastructure Councils to worry about them, they will manage provision over the Plan Observation themselves. Grant aid can usually be found by period. This will be Noted – No Action those who are determined to have/need places considered in the for worship. Infrastructure Delivery Plan. page49/questionCF1 I do not understand why we should worry about The Core Strategy must Mr Bill Tubb developing the Community services provided by consider social infrastructure local council. These have normally grown to suit provision over the Plan Observation demand many by private provision, period. This will be Noted – No Action dentist/doctors practices etc, they just need considered in the some government encouragement. Typically the Infrastructure Delivery Plan. Woodcote practice in Purley is planning development along modern thinking, extending working hours and incorporating a pharmacy. page50/para1/bullet1 In this respect Croydon should provide This is not a Core Strategy Mr Bill Tubb permission to allow car parking to overlap onto issue, and parking will be pavements in many more areas than at present. considered in masterplanning Observation There are many streets throughout Croydon processes and the No Action – Not an LDF Is where common sense tells you it is wise to park Development Management your car partly over the pavement, but without DPD. authority underlining the action anyone parking on the pavement is risking a fine. Examples local to me include Higher Drive, Valley Road, The Reedham estate (Reedham Drive and Aveling Close) and Rutherwick Rise. I believe it is necessary for public safety to either ban parking or allow parking to overlap pavements and on many roads parking is necessary. page49/questionhcf1 It is disappointing that redevelopment in Not relevant to the Core Mr Bill Tubb Croydon often takes so long, those nearest to Strategy. me are the old Purley Council Offices, Purley Observation Hospital modernisation and the old Sainsbury No Action – Not an LDF Is sites and others might include the old Croydon General Hospital Site and the saga of the arena development alongside East Croydon station. Croydon Council are very poor at communication about these problems, time passes year on year and no real explanations/actions happen. However recently out of the blue we hear that there are plans to build new Council offices in central Croydon and actions seem to follow rapidly. Nothing of course is explained to the general public but it is clear that when the politicians are gaining for themselves action is fast and the budget is available. page45/para2 We need good housing but there are so many The comment is noted. Empty Andonetta Mansi houses that are long term vacant or empty which homes brought back into use could be revamped and updated. will be factored into the Observation preparation of the Strategic Noted – No Action Housing Land Availability Assessment. Page45/para2 Deliver affordable new housing in the very The Council intends to protect Mr Ibo Djemil pleasant tree lined south of the borough for the character of the area young people and the disabled by actively whilst providing for affordable Observation encouraging developments on large rear gardens housing through more Disagree – No Change appropriate development. Page 53 Q HC 2 - I cannot think of any at this time. The comment is noted. Mr I.G.M. Hunter

Observation Noted – No Action Page33/para7/bullet5 Adults with learning disabilities should be Comment is noted. Mr Ibo Djemil provided with far more opportunities to develop their skills… Observation Noted – No Action page47/para2/bullet2 Bull point 2: Croydon Primary Care Trust has, The Core Strategy recognises Mr I.G.M. Hunter over recent years, persistently sought to obtain the need for "a new general public consensus on the co-location of generation of health facilities" Observation the various health facilities, Doctors, Dentists and supports the principle of Noted – No Action and Opticians. Their main thrust is that several co-location, but due to its high health facilities could be seen during one visit to level status will not address such a site thus saving public time. Such a the detail of the approach proposal will not work for many and various healthcare providers pursue. reasons, not least being the difficulty of pre- booking such visits with more than one component. As the local population ages, most residents will not wish to travel far from their health care facilities so siting these co-located facilities will be difficult without inconveniencing the part of the population they purport to serve. 5. A Place for Sustainable Living Page/Paragraph/ Representation Recommended response Full Name Objective Organisation Nature of Response Officer Recommendation Page73/How do we The Council has identified a number of delivery The support is welcomed. Mr David deliver these options options which are welcomed and supported. Hammond Natural England Support Agree - No Action n/a To encourage residents to keep their front and This is not a matter that can Derrick East adjacent pavements clear of litter. Yes it will be considered by the Core continually need to be cleared but we do not Strategy. Observation leave the floor unswept because it will get dirty No Action – Not an LDF Is again! Page67/What are the Safeguarding existing open spaces together with The support is welcomed. Mr David options for change ameliorating areas of deficiencies is welcomed Hammond and supported, as is the enhancement of Natural England existing open spaces and improvements to the Support links between them. Agree - No Action Page67/Para1/Bullet4 The consideration of linking Croydon’s Parks The support is welcomed. Mr David and Open Spaces through the provision of a Hammond Green/Wildlife Corridor is welcomed, Natural England commended and supported. Support Agree - No Action Urban Agriculture Natural England commends the Council for The support is welcomed. Mr David considering this approach but offers no formal Hammond comment Natural England Support Agree - No Action Page63/What are the Development that helps to mitigate and adapt to The support is welcomed. Mr David options for change Climate Change and promotes responsible Hammond consumption of natural resources, together with Natural England enhancement of biodiversity and amenity of Support brown-field sites is welcomed and supported. Agree - No Action Page73/What are the The safeguarding and enhancement of the The comment is noted. Mr David options for change Borough’s biodiversity is to be commended, Hammond encouraged and supported and links in with Natural England Natural England’s earlier comments in respect of Support PPS 9. Paragraph 14 of PPS9: Biodiversity and Noted – No Action Geological Conservation states that “Development proposals provide many opportunities for building-in beneficial biodiversity or geological features as part of good design. When considering proposals, local planning authorities should maximise such opportunities in and around developments, using planning obligations where appropriate.” page 57 para 2 bullet 6 Natural England welcomes and commends The support is welcomed. Mr David initiatives that promote and encourage the use Hammond of sustainable transport options, including Natural England walking and cycling. Support Agree - No Action page 61 page 65 Development that helps to mitigate and adapt to The Council does not dispute Mr David Climate Change and promotes responsible that these factors are Hammond consumption of natural resources, together with intrinsically linked. Natural England enhancement of biodiversity and amenity of Observation brown-field sites is welcomed and supported. Noted – Propose Changes This should also be linked to consideration of enhancement of the biodiversity and amenity of ‘Green/Open’ spaces as well; this can then also be linked to the Parks and Open Spaces - A Green Grid section. Page73/What are the As stated in London Plan Policy 3D.14, “The The comment is noted. Mr David options for change planning of new development and regeneration Hammond should have regard to nature conservation and Natural England biodiversity, and opportunities should be taken Observation to achieve positive gains for conservation Noted – No Action through the form and design of development. Where appropriate, measures may include creating, enhancing and managing wildlife habitat and natural landscape and improving access to nature.” n/a We also have the situations that: This is not a matter that can Derrick East be considered by the Core People are not generally aware of the penalty for Strategy. Observation dropping litter. I suggest that what is needed is: No Action – Not an LDF Is To publisise the litter law making people aware of the associated penalty Question GB2 Linking the Green Belt and Metropolitan Open The support is welcomed. Mr David Land with the wider ‘Green Grid’ network is Hammond welcomed and supported, and will assist in Natural England providing the wildlife corridors/green chains Support mentioned earlier. Agree - No Action n/a Sending children off to school without any This is not a matter that can Derrick East breakfast to be treated as child abuse be considered by the Core Strategy. Observation No Action – Not an LDF Is n/a Parking meters being installed where motorists This is not a matter that can Derrick East insist on leaving litter, and an explanation given be considered by the Core why the meters have been installed Strategy. Observation No Action – Not an LDF Is Page67/How do we The enhancement of existing open spaces and The support is welcomed. Mr David deliver these options improvements to the links between them is Hammond welcomed and supported. Natural England Support Agree - No Action Page69/Para1/Bullet2 Natural England also supports the protection The support is welcomed. Mr David and enhancement of Green Belt/Metropolitan Hammond Open Land, and the linking of these to the wider Natural England ‘Green Grid’ networks. Also fully supported is Support the designation and delivery of the Wandle Agree - No Action Valley Regional Park – Natural England is prepared to offer any support, guidance or advice that the Council may wish to access. n/a There is a 60 bus stop used by pupils at the This is not a matter that can Derrick East nearby academy and for access to Coulsdon be considered by the Core South railway station by people using the Strategy. Observation Crossways as a car park. No Action – Not an LDF Is n/a Closure, or at least limited hours for fast food This is not a matter that can Derrick East outlets near schools and colleges be considered by the Core Strategy. Observation No Action – Not an LDF Is n/a Giving children pocket money to buy junk food to This is not a matter that can Derrick East be treated as a form of child abuse be considered by the Core Strategy. Observation No Action – Not an LDF Is Page63/Para2/Bullet1 The consideration and provision of “living roofs” The comment is noted. Mr David and more street planting within the Centre is Hammond also welcomed and supported and would link in Natural England with the comments in respect of PPS 9 above. Observation The only consideration that Natural England Noted – No Action would ask the Council to be aware of is the use of native and indigenous species in all new planting schemes. Page67/Para1/Bullet2 The protection of open spaces is welcomed and The support is welcomed. Mr David supported as are the proposals to improve Hammond access and links between them, also Natural Natural England England also welcomes and commends Support schemes that promote and encourage Noted – No Action sustainable public transport options, including walking and cycling. n/a Presumably we have the problems because This is not a matter that can Derrick East police & NEOs are being assaulted for enforcing be considered by the Core the law. Strategy. Observation No Action – Not an LDF Is page61/para1/bullet1-2 Adaptation to climate really matters in this case The next iteration will consider Muhammad Ali considering the fact that one of the options, a modified spatial strategy to environmental and option 2: a concentrated growth corridor which ensure growth is sustainable sustainability team includes A23 transport corridor is in a flood risk and is likely to feature Observation area? elements of the dispersed Agree – Propose Changes growth and concentrated growth options. n/a Please remember to consult National Grid on The comment is noted. Leslie Morris any Development Plan Document (DPD) or site- National Grid specific proposals that could affect our Observation infrastructure. We would be grateful if you could Noted – No Action add our details shown below to your consultation database: page63/para2/bullet3 How do we deliver these options (Climate A more extensive Glossary Mr I.G.M. Hunter change, energy, green buildings, flooding & will be provided in the next water) consultation report. Object Agree – Propose Changes Bull point 6: Unless there is a glossary attached to this document which explains what a “a Code for Sustainable Homes Level 4 rating” is (which there is not), these words are meaningless to the majority of residents. If it is important for the Core Strategy to embrace the requirement a subsequent iteration must explain it page63/para1/bullet2 Page 63 – Bull point 2: What about local Evidence to support the next Mr I.G.M. Hunter biomass power? consultation report on the Core Strategy will assess the Observation potential of renewables/low Noted – No Action carbon energy generation in the borough as well local requirements for sustainable buildings. page62/para1/bullet3 Page 62 – Bull point 3: How many households in Since the publication of the Mr I.G.M. Hunter Croydon are in this category? Surely this is what Core Strategy, more up to the Core Strategy is about? date fuel poverty figures have Object been released. The estimated Agree – Propose Changes figure for London is 81,300, of which 7,700 are estimated to be in Croydon. These figures will be reflected in future iterations of the Core Strategy. page63/para2 Suggest new Bull point 7: Include “Building on PPS25 sequential test has a Mr I.G.M. Hunter stilts above flood level”. presumption against sensitive developments in high flood Object risk areas prior to developing Disagree – No Change engineering solutions. Page 70 Bull point 4: Such spaces must also be The comment is noted. Mr I.G.M. Hunter affordable. An allotment is for personal Access to allotments is consumption, a Market Garden is for commercial subject to a wide variety of Observation production. Market forces, unless controlled by arrangements and not Noted – No Action law will dictate food costs and such legislation necessarily market price. will probably be beyond the powers of the Council. A “grow your own” culture will not be cheap. Page60/Question TM 2 Q TM 2 - Yes. There is, I believe, sufficient Transport policy will be Mr I.G.M. Hunter public land between Croydon and Lewisham to informed by the forthcoming consider linking the DLR into West Croydon or Borough-wide transport Object extending the Tramlink north to Lewisham, using strategy. Noted – No Action if necessary, compulsory purchase powers. page63/para4/bullet8 Bullet 8 may be alternatively stated: Agree proposal to widen the Mr Andrew measures for flood reduction Steen • Deculvert and otherwise enhance the and biodiversity and amenity White & Sons borough’s rivers (where feasible) to help reduce improvement. Object flood risk and improve biodiversity and amenity. Agree – Propose Changes Notes on revised wording

‘and otherwise’ has been added to capture a number of measures such as improving flow controls and bank improvements that would have benefits on flood risk, biodiversity and amenity. Page 71 Q UA 2 - I cannot think of any at present. The comment is noted. Mr I.G.M. Hunter

Observation Noted – No Action Page67/Para1/Bullet3 The option to safeguard back lands and gardens A Strategic Housing Land Mr Ibo Djemil from over development is wrong . Most of these Availability Assessment is properties are owned by elderly wealthy being prepared. Generally Object individuals who allow their gardens to be wasted backland development will not Disagree – No Change on rarely used large lawn areas and in view of be encouraged as it potentially their age and wealth will not take any notice of undermines the character of the Councils promotions on food growing. the area. page64/QuestionCC2 Q CC 2 - Yes The support is welcomed. Mr I.G.M. Hunter

Support Agree - No Action Page67/Question GG1 Many of the large gardens are in the outer A Strategic Housing Land Mr Ibo Djemil suburbs of croydon are underused and are a Availability Assessment is hugely wasted resource which could be used to being prepared. Generally Object provide valuable detached houses. backland development will not Disagree – No Change be encouraged as it potentially undermines the character of the area. page64/QuestionCC3 Q CC 3 - Yes; the use of Biomass power and Evidence to support the next Mr I.G.M. Hunter the use of Wind-farms ( these options need to consultation report on the be considered in conjunction with others Core Strategy is being Observation proposed in the South London Waste Plan, now prepared that will assess the Noted – No Action under evaluation. potential of renewables in the borough as well local requirements for sustainable buildings. The Joint South London Waste Plan DPD does not consider technologies, rather it seeks to identify appropriate waste sites within the four boroughs. page61 I understand that the core strategy is a high level The next iteration of the Core Muhammad Ali planning policy documents but I think it will be Strategy will set out in more environmental and really useful if we can specifically mention our detail. sustainability team key policy response to climate change in terms Observation of adaptation, mitigation and a mix of Agree – Propose Changes adaptation/mitigation in the core strategy. page69/questiongb2 The association also supports the document's The support is welcomed. Mr Brian aim to improvement of footpaths and cycle Longman routes to allow people greater access to the Riddlesdown Conservation countryside. Committee/Sanderstead, Croham, Selsdon & Ballards Neighbourhood Partnership Support Agree - No Action page69/para2/bullet2 Maintaining the green belt is essential if Croydon The Council will consider Mr Brian is to remain an attractive place to live. The further the arguments for and Longman association agrees that implementation of against Green Belt and MOL Riddlesdown Conservation planning policy to ensure the protection of green amendment in the next Committee/Sanderstead, belt is essential. consultation report for the Croham, Selsdon & Core Strategy. Ballards Neighbourhood Partnership Support Noted – Propose Changes Page69/QuestionGB1 Riddlesdown residents association recently The Council will consider Mr Brian meet to discuss Croydon's new Core Strategy. further the arguments for and Longman The meeting was unanimous in that Croydon's against Green Belt and MOL Riddlesdown Conservation highest priority should be the defence of open amendment in the next Committee/Sanderstead, spaces and green belt land. consultation report for the Croham, Selsdon & Core Strategy. Ballards Neighbourhood Partnership Observation Noted – Propose Changes Page 73 Q EDG 2 - None that I can think of now. The comment is noted. Mr I.G.M. Hunter

Observation Noted – No Action page75/questionw2 My point is that the council needs to make it Not an LDF matter. Carol Kellas easier, rather than harder, for builders to get rid of their stuff at a local dump. Observation No Action – Not an LDF Is page70- Green Belt The comment is noted. Suzanne 71/urbanagriculture London Borough of Croydon has land which is Natelson designated Metropolitan Green Belt. Food Sustain growing can be encouraged for both local Observation residents and for commercial use on Green Belt Noted – No Action land. Many consumer surveys have showed that Londoners want to buy more local produce. Growing locally is an important step to tackle climate change, stimulate the local economy and reconnect consumers with their food. Local authorities can help more commercial food production in their areas by developing a strategy on this issue, and working with economic development and other teams to encourage more food production. Page60/Para1/Bullet5 Bull point 5: As of mid-September 2009, this The role of the LDF is to Mr I.G.M. Hunter study had still not been completed and issued establish the overall strategy for public comment. Before the next iteration of for the borough, whilst some Observation this Consultative document, the Study must detailed studies will be Noted – No Action have been issued otherwise the Core Strategy available in advance of the will be compromised. Core Strategy preparation, others will necessarily follow. Page50/Para1/Bullet5 Bull point 5: The design competition failed to Disagree. It is unrealistic to Mr I.G.M. Hunter look introspectively and as a result options for expect all development development lodged within the Council were not proposals to wait until the Object examined. If current development proposals, ie: adoption of the core strategy Disagree – No Change the new Council Hub, Wellesley Road Greening before being progressed. have been initiated using the current approved Core Strategy, how will valid proposals for the new Strategy be interfaced with the existing one to give the residents belief that their ideas are important and worth consideration? Page 59/para1/bullet1 Page 59 of the Initial Report states that the The comment is noted. A Croydon Tramlink “has been an enormous borough transport strategy will Devgrove success.” Devogrove considers that a sound be prepared as evidence base Observation spatial strategy for the Borough would maximise for proposed policy on trams Noted – Propose Changes the potential of that success. Accordingly, the and tramlink for future Core Strategy should acknowledge Kent Gate versions of the Core Strategy. Way, Addington as a strategic transport hub The need for a new around which a new neighbourhood can be neighbourhood will be provided in the land between Kent Gate Way assessed in relation to the and Huntingfield. A new development in this Strategic Housing Land vicinity could provide the opportunity to enhance Avaialbility Assessment. the potential / capacity of the interchange between Croydon Tramlink and other forms of transport, particularly the private car. Page60/para1/Questio Our response to Question TM2 is to propose The comment is noted. A nTM2 that a new sustainable neighbourhood be borough transport strategy will Devgrove constructed in the area between Kent Gate Way be prepared as evidence base Observation and Huntingfield, Addington to provide the for proposed policy on trams Noted – Propose Changes improvement to the Addington Village tram stop and tramlink for future as anticipated at page 81 of the Initial Report. A versions of the Core Strategy. sustainable new development off Kent Gate The need for a new Way would provide the opportunity to achieve neighbourhood will be improvements to the tram stop / bus station assessed in relation to the interchange to enable more efficient use and Strategic Housing Land enhance the public realm. New bus routes and Avaialbility Assessment. bus service penetration into New Addington could equally arise should such a development form be promoted. Page67/Question GG2 Residential gardens that are not being used to A Strategic Housing Land Mr Ibo Djemil grow food should be open to development of Availability Assessment is much needed housing. being prepared. Generally Object backland development will not Disagree – No Change be encouraged as it potentially undermines the character of the area. page69/QuestionGB2 Q GB 2 - Yes – see my proposal in Bull point 3, The continued protection of Mr I.G.M. Hunter page 68 MOL is a requirement of the London Plan. Observation Noted – No Action Page66/Para2/Bullet6 Bull point 11: The aspiration reflected in this Disagree. It is not a core Mr I.G.M. Hunter point may conflict with the desire to ensure that srategy aspiration to ensure all new residential and commercial that all new residential and Object developments should contain “off-road” parking commercial development Disagree – No Change facilities as well as green areas for urban includes off-road parking. agriculture. Page67/Question GG1 Q GG 1 - Yes, as a general baseline. The support is welcomed. Mr I.G.M. Hunter

Support Agree - No Action Page57/Para2/Bullet2 Bull point 2: This point should be modified to Further work on potential Mr I.G.M. Hunter include “other connections to other major civic tramlink extensions is to be centres”. conducted by TfL and this Object may include the examination Noted – No Action of links to other major civic centres. Page57/Para2/Bullets3 Bull points 3 and 4: These offer a dichotomy. If The Croydon Metropolitan Mr I.G.M. Hunter &4 residents travel out of Centre to work, why are Centre area offers very they offered houses in the Centre? What, significant potential for Observation indeed, is the need of housing in the Centre residential development. A Noted – No Action anyway under these points? proportion of the residents in this area will choose to be employed elsewhere. Page 59/para2/bullet2 Page 59 – Where are we now The core strategy and Mr I.G.M. Hunter associated Infrastructure Bull point 2: Since Croydon does not run the Delivery Plan are the spatial Observation transport systems which traverse the Borough interpretation of the Noted – No Action why is the Core Strategy accepting responsibility Sustainable Community when the Council has very little influence on how Strategy - a document which they operate? (see Annex A as an example of goes beyond the council and the Borough’s inadequacy). is owned by major stakeholders, such as transport providers, too. Page59/para2/bullet7 Bull point 7: This could have been more general At this time it is not proposed Mr I.G.M. Hunter and have included reference to other to extend the tram network connections to other major civic centres. beyond the scope set out. Object However, a future borough- Disagree – No Change wide transport study will consider this issue. Page 73/para2 Page 73 – How do we deliver these options. The council agrees. Mr I.G.M. Hunter

Bull point 5: Sustaining a woodland environment Observation should not mean the widespread planting of fir Agree - No Action trees at the expense of the naturally occurring, if un-commercial, tree varieties. page73/QuestionBDG Q BDG 1 - Yes but see Bull point 5 (page 73). The comment is noted. Mr I.G.M. Hunter 1 Observation Noted – No Action page74 Comment: I am concurrently preparing a The comment is noted. Mr I.G.M. Hunter response to the South London Waste Plan –2nd Consultation. Observation Noted – No Action page75/QuestionW1 Q W1 – Yes, but see my Comment above. The comment is noted. Mr I.G.M. Hunter

Observation Noted – No Action page64/QuestionCC1 Q CC 1 – Are there any areas of the Borough Evidence to support the next Mr I.G.M. Hunter where it would be feasible to erect wind-farms. consultation report on the Core Strategy is being Observation prepared that will assess the Noted – No Action potential of renewables in the borough as well as local requirements for sustainable buildings. page63/para2/bullet3 SUDS are not always appropriate, particularly Page 63 recognises the Ms Susan where contamination in soil can constrain the appropriateness if SUDS wil Sheahan use of infiltration. This is a particular risk in Inner be determined by local Environment Agency Source Protection Zones. Inner Source geology and soil conditions. Observation Protection Zones also have the additional Agree - No Action protection from our policies in Groundwater Protection: Policy & Practice (GP3, 2008), where we will object to the infiltration to ground other than clean roof water in an Inner Source Protection Zone. This is to protect the groundwater from diffuse pollution. Page68/Para1 Given the growth agenda for Croydon, The Council will consider Devogrove questions the proposition at page 68 further the arguments for and Devgrove of the Initial Report to the effect that the green against Green Belt and MOL Object belt and MOL will be protected “as a permanent amendment in the next Noted – Propose Changes feature” in the Borough. Such an approach, at consultation report for the the outset, unnecessarily limits potential spatial Core Strategy. alternatives. Page 60 Q TM 1 - Yes, subject to modification. The comment is noted. Mr I.G.M. Hunter

Observation Noted – No Action Page66/Para1/Bullet4 Page 66 - Where are we now. The comment is noted. Mr I.G.M. Hunter

Bull point 4: Aside from existing views and Object landmarks, there is no reason why new viewing Noted – No Action prospects could not be created. page68- Where are we now. The continued protection of Mr I.G.M. Hunter 69/para3/bullet3 MOL is a requirement of the Bull point 3: The over-zealous protection of MOL London Plan. Observation is to be avoided, particularly if leisure or cultural Noted – No Action facilities could be planned for such acreage. For example on the land adjacent to the Arena Tramlink Stop, a sports Arena could be built to satisfy the desires of those who were frustrated by the refusal to build an Arena on the Gateway site. Such a development could be associated with the refurbishment of the nearby athletics stadium and possibly the construction of an Olympic-size Diving Hall, thus combining cultural and leisure activities.

Page 69 - What are the Options for Change.

Bull point 1: My proposals on Bull point 3 (page 68) are relevant here. Page69/Question GB1 Q GB1 – Yes, subject to comments. The comment is noted. Mr I.G.M. Hunter

Observation Agree - No Action Page70/Para1/Bullet3 Where do we want to be The comment is noted. Mr I.G.M. Hunter Affordability/financial viability Bull point 3: The patterns of consumption must is a factor of "sustainable Observation also be affordable. patterns of consumption". Noted – No Action Page 71/para2/bullet1 Page 71 – What are the Options for Changes The intent is to get an Mr I.G.M. Hunter appropriate balance between Bull point 1: This point seems inconsistent. If the urban agriculture in parks and Object intention is to go green there will not be any in Green Belt/MOL whilst Disagree – No Change surplus park land. Either it will be dedicated for providing sufficient open land Park purposes or for agricultural purposes for other purposes including unless you are defining urban agriculture as a recreation. recreational activity. page70/para2/bullet4 Q UA 1 – Yes, subject to comments. The comment is noted. Mr I.G.M. Hunter

Observation Noted – No Action Page65/Bullet4 Bull point 4: There is no reason why the play This section is dealing with Mr I.G.M. Hunter and sports facilities need only to be in the open open spaces; references to air. Use should be made of buildings on “brown built facilities can be found on Object field” sites for such purposes. The point should page 47. Disagree – No Change reflect this. Page65/Bullet3 Where do we want to be The River Wandle in Croydon Mr I.G.M. Hunter is not suitable as a Bull point 3: If the Wandle can be made commercial waterway Observation navigable consideration should be given to because of its low flow. Noted – No Action making it a commercial waterway through to the Thames on which waste and other bulky material might be carried. This point should therefore be expanded to include reference to the possible “commercialisation” of the river. Page67/QuestionGG1 Appropriate safeguards will have to be put in Disagree. It is not a core Mr I.G.M. Hunter place to safeguard urban land but this should srategy aspiration to ensure not be allowed conflict with the need for “off- that all new residential and Object road” parking facilities in new developments. commercial development Disagree – No Change includes off-road parking. Q GG2 Q GG2 – Yes; a) A tall building in the centre of The comment is noted. Mr I.G.M. Hunter the Town, which might be a hotel to attract visitors, with a viewing platform at its top, would Observation provide excellent views of the entire Borough. It Noted – No Action would have other uses including apartments. Q W 2 Q W 2 - See W1 above. The comment is noted. Mr I.G.M. Hunter

Observation Noted – No Action page60/QuestionTM2 In order to ensure that any potential transport The comment is noted. These impacts are assessed robustly, the HA would matters are considered Highways Agency also expect the Core Strategy and/or the appropriate for the Observation emerging Development Management (DM) DPD Development Management Noted – No Action to set out the requirement for Transport DPD. Assessments or Transport Statements to be undertaken as part of any development proposal. In line with the recommendations in DfT Circular 02/2007, 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. page61 Electricity Transmission The comment is noted. Leslie Morris National Grid National Grid, as the holder of a licence to Observation transmit electricity under the Electricity Act 1989, Noted – No Action has a statutory duty to develop and maintain an efficient, co-ordinated and economical transmission system of electricity and to facilitate competition in the supply and generation of electricity. page60/questiontm2 It is considered that the potential for feasibility The comment is noted. TfL John Phillips studies into extending the Tramlink network to with the borough will consider Tandridge District Council Selsdon, which could benefit residents living in the most appropriate tramlink Observation the north eastern parts of Tandridge District extensions in a future study. Noted – No Action should be examined as an option. page61-73 Devogrove acknowledges and supports the The comment is noted. Council’s observations in that section of the Devgrove Initial Report that deals with climate change, Observation energy, green buildings, flooding and water. We Noted – No Action consider that a new neighbourhood off Kent Gate Way will provide new development to help mitigate against climate change and be adaptable to the effects of such change. New buildings off Kent Gate Way will meet the highest possible standards of sustainable design and construction, taking full account of flood risk, water use, energy, materials, air quality, health and well-being, land use, ecology and green infrastructure Question CC2 As noted in our observation with regard to The comment is noted. Question H2, a new neighbourhood off Kent Devgrove Gate Way would represent an exemplar Support scheme, implementing many of the Noted – No Action considerations described at pages 61 – 64 of the Initial Report. Devogrove, in response to Question CC2, considers that the appropriate options are outlined in the Initial Report. Page69/Question GB2 Should the land off Kent Gate Way be released The Council will consider from the green belt, Devogrove is committed to further the arguments for and Devgrove ensuring that it forms part of the required green against Green Belt and MOL Observation grid. Development in this location would address amendment in the next Noted – Propose Changes any local deficiencies in open space provision. consultation report for the Core Strategy. page60/questiontm1 The option to promote Tramlink extensions The support is welcomed. John Phillips south to Purley and Gatwick is supported by the Tandridge District Council Council as such extensions could benefit Support residents living in the more western parts of Agree - No Action Tandridge District. Page59/Para2/Bullet7 The CS states that both growth options (the The support is welcomed. dispersed option and the concentrated option) Highways Agency will be constrained by the capacity of existing Support transport and other infrastructure. The HA is Agree - No Action supportive of proposals to extend the existing Croydon Tram Link to areas of new growth in the borough and beyond. page60/questiontm2 The scope for joint working between the relevant Not an LDF matter. John Phillips authorities to provide Real Time Passenger Tandridge District Council Information on cross boundary bus routes, Observation including the 403, 407, 409, 434, and 466 No Action – Not an LDF Is services. page60/questiontm1 The contribution that improved rail facilities, The comment is noted. The John Phillips including Thameslink 2000, could make bearing borough-wide transport Tandridge District Council in mind that the East Grinstead Railway Line, strategy will assess all Object which passes through the District and Borough, services passing through the Noted – No Action is included in the proposed service pattern for borough to the south. Thameslink 2000; and Page59/What are the As recommended by PPG13, development of The comment is noted. A options for change travel-intensive uses should be focussed within modified development Highways Agency existing town centre and district centres which strategy will be outlined in the Observation are better served by public transport links. This next consultation of the Core Noted – No Action will minimise the impact of increased trips on the Strategy. SRN and will also help ensure that the Strategy is in line with PPG13 paragraph 20 , and therefore meets PPS12 soundness requirement to align with national policy. page70- Local authority examples Examples are noted. Suzanne 71/urbanagriculture Some local authorities are putting policies on Natelson urban agriculture in their new core strategies: Sustain •Brighton & Hove City Council “Recognise, Observation safeguard and encourage the role of allotments; Noted – No Action garden plots within developments; small scale agriculture and farmers markets in providing access to healthy, affordable locally produced food options” and also “to promote food growing initiatives where a shortfall in terms of quantity, quality and safety has been identified” •London Borough of Camden has pledged to set up and support 60 new community food growing sites in the borough by 2012; ensure a more coordinated approach to food growing in the borough; improve the mental and physical health of Camden residents through food growing and attract sponsorship and funding from other sources to support more food growing in the borough •London Borough of Islington has budgeted £1million to be spent on urban agriculture which will involve creating two new allotment sites and supporting other community growing spaces •London Borough of Lewisham has signed up to the Capital Growth project to create 60 new community growing spaces by 2012. •London Borough of Tower Hamlets wants to support healthier and active lifestyles through promoting and supporting local food growing and urban agriculture . page59/para2/bullet4 The introduction of Park and Ride facilities could The comment is noted. If this encourage an increase in car traffic along the proposition is taken further the Highways Agency southern section of the A23 which could in turn Council agrees that a full Observation effect operations on the M23 and M25. Further assessment will be required. Noted – No Action assessment to identify the most appropriate locations for park and ride sides should be carried out before this is taken forward. n/a Gas Transmission The comment is noted. Of Leslie Morris relevance to future work on National Grid National Grid owns and operates the high Infrastructure Delivery Plan. Observation pressure gas transmission system in England, Noted – No Action Scotland and Wales that consists of approximately 4,300 miles of pipelines and 26 compressor stations connecting to 8 distribution networks. National Grid has a duty to develop and maintain an efficient co-ordinated and economical transmission system for the conveyance of gas and respond to requests for new gas supplies in certain circumstances.

New gas transmission infrastructure developments (pipelines and associated installations) are periodically required to meet increases in demand and changes in patterns of supply. Developments to our network are as a result of specific connection requests e.g. power stations, and requests for additional capacity on our network from gas shippers. Generally network developments to provide supplies to the local gas distribution network are as a result of overall demand growth in a region rather than site specific developments. page59/para4/bullet4 Account needs to be made in the options for The comment is noted. The John Phillips change to the possible cross boundary impact of any strategic park Tandridge District Council transportation implications on places such as and ride scheme on cross Object Tandridge District adjoining the London Borough boundary traffic flows will Noted – No Action of Croydon. It is considered that there are a need to be assessed. number of implications, for instance:The impact of any commuter car parking and park and ride scheme on roads in the District leading to and from the London Borough of Croydon; page60/QuestionTM2 The HA expects that any development The next consultation report producing a full Transport Assessment should for the Core Strategy will Highways Agency also produce a Travel Plan. The threshold include greater reference to Object requirement for the provision of a Travel Plan travel planning. Noted – Propose Changes 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. page60/QuestionTM2 Restrictive car parking standards are an The Development effective demand management measure helping Management DPD and OAPF Highways Agency to limit the level of car trips generated by new will address this issue in Object development. The council should therefore seek greater detail. Noted – No Action to adopt maximum car parking standards in line with car parking policies laid out in Annex D of the London Plan. The HA would also recommend that maximum parking standards should be reduced in areas with good access to public transport. It may also be appropriate to encourage a level of car free and permit free development in areas with the best access to public transport, such as Croydon Metropolitan Centre. This would be consistent with the recommendations of PPG13, paragraph 49 . Page60/Question TM1 Where development sites are allocated outside The forthcoming Infrastructure town centres, it is essential that sustainable Delivery Plan will set out the Highways Agency transport improvements are identified to mitigate infrastructure requirements Observation any adverse impact on the road network. In and their delivery mechanism. Noted – Propose Changes addition, the proposed improvements should be phased in line with the delivery of new development. Funding and delivery mechanisms of such improvements should be detailed in the CS. Page68/Para2/Bullet2 The Planning Inspectorate’s latest LDF guidance The need to fully jusify future document: Examining DPD: Learning from Green Belt changes is noted. Highways Agency Experience (September 2009), states that; “In Observation the absence of a requirement in the RSS to Noted – No Action review the Green Belt boundary, any change must be justified by exceptional circumstances.” Although it is acknowledged that Croydon has been identified as a growth area by the Secretary of State for Communities and Local Government, the evidence base for the CS would be expected to demonstrate that this level of housing cannot be sufficiently accommodated within the town and district centres. We recommend that the results of the Strategic Housing Land Availability Assessment (SHLAA) are used to identify the most suitable locations for new housing development and to justify any requirement for a review of the Green Belt boundary. page60/questiontm2 Question Greater explicit reference will Nikki Honan be made to cycling and HUDU TM2 Cycling and walking also can help to slow walking will be contained in Object the rise in levels of obesity. The core strategy the next cosultation report for Agree – Propose Changes could include greater reference to improved the Core Strategy. walking and cycling and confirmation of how this can be delivered, perhaps linking to the Green Grid policy. Delivery mechanisms may include development standards, developer contributions and funding bids. Q CG2/parks and GG2 Clearly there needs to be a balance The comment is noted. The Nikki Honan open spaces between the need for green space and the first bullet point on page 67 HUDU positive effect it has on health and the need for incorporates this suggestion. Observation homes. We would also want to see green space Noted – No Action protected across the borough. page 65 As outlined above, we would support emphasis The support is welcomed. Nikki Honan on enhancing the links between sites and other HUDU community facilities, to encourage use, enhance Support health and well being and reduce health Agree - No Action inequalities. page72 Biodiversity & Geology We welcome the The support is welcomed. Nikki Honan protection and enhancement of biodiversity and HUDU geology. Support Agree - No Action Page57/Where do we Transport & movement The comment is noted. This Nikki Honan want to be will be considered in the next HUDU Where do we want to be? We would support consultation report of the Core Observation reference to the need for the whole community Strategy. Agree – Propose Changes to access health facilities, as well as the need to encourage activity (to reduce obesity and heart disease for example) so suggest accessibility to sports facilities is also key for the borough moving forward. Question GB1 Green Belt The support is welcomed. Nikki Honan HUDU Question GB1 We support linking the Green Belt Support / MOL with the wider green grid network, Agree - No Action including the Green Arc South West. We also support the continued designation of the Green Belt / MOD and appropriate uses on this land, including agriculture and sporting activities such as equestrian activities. page57/para2/bullet1 The CS has identified potential options to The comment is noted. improve the capacity and flow on the A23. If Junction improvements on the Highways Agency additional capacity is provided, this capacity A23 are likely to include Observation should be utilised to enhance public transport enhancements for public Agree – Propose Changes links along this corridor, especially bus services transport. to / from Croydon Metropolitan Centre. It is our view that improvement measures should be focussed towards enhancing public transport accessibility at development sites poorly served by public transport. n/a Continued from comment 1... re. background The comment is noted. The material - Wind Turbines. All wind turbine Council will continue to carry Civil Aviation Authority proposals, whether prior to, or at, formal out its Telecommunications Observation planning application stage, should be notified to duties in accordance with Noted – No Action both the CAA's Directorate of Airspace Policy formal consultation processes and to Ministry of Defence (Defence estates). - as guided by central government (GDO). Question UA1 Urban Agriculture The support is welcomed. Nikki Honan HUDU questionUA1 Question UA1 We support further allotments Support being established in the borough, and the associated benefits on health and well being, Agree - No Action and reducing health inequalities. Page69/Question GB2 We have noted the observation of page 68 that The Council will consider the green belt boundary is currently being further the arguments for and Devgrove considered “which may assist in identifying land against Green Belt and MOL Object that could potentially be released” from the amendment in the next Noted – Propose Changes green belt to accommodate necessary consultation report for the development. We would endorse such an Core Strategy. approach and consider that the Core Strategy should seek to identify sustainable locations to accommodate new housing, even though some sites may presently be within the green belt. Whilst the broad extent of the green belt in the Borough would be maintained, a careful review of existing green belt boundaries in key locations is needed to enable the growth agenda to be implemented at the most sustainable locations. Page69/Question GB2 Tightly drawn green belt boundaries, whilst The Council will consider hypothetically assisting urban concentration, further the arguments for and Devgrove have made it increasingly difficult to meet against Green Belt and MOL Object development needs, particularly for housing, amendment in the next Noted – Propose Changes resulting in increased pressure on residential consultation report for the amenity within existing built-up areas. Whilst Core Strategy. readjustments of the green belt boundary may result in significant change locally, such amendments can be made / achieved without eroding the principles and overall functioning of the green belt. Where green belt boundaries are being reviewed the aim of the Core Strategy should be to release sufficient land to avoid further review before 2031. page70- Planning policies that support urban food Content of London Plan noted. Suzanne 71/urbanagriculture growing Natelson The London Plan Sustain Policy 7.22: Land for food Observation “The Mayor will seek to encourage and support Noted – No Action thriving farming and land-based sectors in London, particularly in the Green Belt. Use of land for growing food will be encouraged nearer to urban communities via such mechanisms as ‘Capital Growth’. Boroughs should protect existing allotments and identify other potential spaces that could be used for community gardening. Particularly in Inner London innovative approaches to the provision of spaces may need to be followed, these could include the use of green roofs.” This is supported in other places in the London Plan through Urban Greening policies 5.10,Green roofs 5.11, Building London’s neighbourhoods and communities 7.1, Addressing health inequalities 3.2, Quality and design of housing developments 3.5, and Planning obligations for climate change mitigation, learning and skills, health facilities and services 8.2. Page69/Question GB2 In response to Questions GB1 and GB2, The Council will consider Devogrove would observe that it is crucial for the further the arguments for and Devgrove Core Strategy to initiate a review of the existing against Green Belt and MOL Observation green belt boundaries to ensure that a full range amendment in the next Noted – Propose Changes of spatial options is considered. We consider consultation report for the that it is essential for the Core Strategy to Core Strategy. undertake a review of existing green belt boundaries in order to identify sustainable sites which can deliver many of the Council’s principal planning objectives. page70- London and food growing The comment is noted. Suzanne 71/urbanagriculture In London an estimated 30,000 people rent Natelson allotments to grow vegetables and fruit, and Sustain 14% of households grow vegetables in their Observation garden . There are more and more community Noted – No Action growing sites springing up and this phenomenon is supported by the Greater London Authority and the Mayor via the London Food Strategy and Capital Growth, a London-wide initiative to create 2,012 community growing spaces by 2012. Popularity is shown by ever-increasing allotment waiting lists and more and more growing projects initiated by councils, health professionals and community organisations. page70- Research has shown that urban food growing The comment is noted. Suzanne 71/urbanagriculture contributes to: Natelson •Social cohesion. Allotments and community Sustain growing spaces are places to exchange plant Observation growing techniques, recipes and other Noted – No Action information, enrich cultural diversity, counter social isolation and create a sense of community. •Health. Regular outdoor physical activity, contact with nature, the sense of achievement, and a healthier diet all contribute to wellbeing. Food growing has also been used in therapeutic services for people with physical or mental illness. •Environmental improvement. Food growing increases green space, improves biodiversity and can enhance flood resilience. •Economic regeneration. In the long-term there can be income generation opportunities for regular growers, and potentially for more local commercial activity. page70- Urban agriculture is increasingly recognised as The support is welcome. Suzanne 71/urbanagriculture having a range of benefits for peoples’ health, as Natelson well as contributing to social cohesion and Sustain greening the urban environment. Planning Support policies can ensure that existing space for food Agree - No Action growing is retained, and new spaces are allocated by planners and developers. Planning policy on urban agriculture is also a way to provide a range of other social and environmental benefits. page70- Statement in support of food growing in the The support is welcome. Suzanne 71/urbanagriculture London Borough of Croydon from Sustain: the Natelson alliance of better food and farming – December Sustain 2009 Support Noted – No Action Sustain: the alliance for better food and farming advocates food and agriculture policies and practices that enhance the health and welfare of people and animals, improve the living and working environment, enrich society and culture and promote equity. We represent around 100 national public interest organisations working at international, national, regional and local level (listed on our website www.sustainweb.org). This paper has been produced to support and encourage local authorities to include urban agriculture in their planning and policy. Sustain encourages local authorities to: •support existing urban growing spaces; •create and support new spaces (taking the opportunity of linking up with the Capital Growth Project http://www.capitalgrowth.org/); •ensure that food growing is a feature of planning policy, and is mentioned in the local authority core strategy with supplementary guidance if required. page 70/para2/bullet4 I am in receipt of your excellent magazine and Support is welcomed. Steve Lloyd am delighted to read about all that you intend to achieve. It was, therefore, most gratifying to Support read one line that is very much in the forefront of Noted – No Action my thoughts at this time. I refer to the line on page 70 where it states "Consider more allotments for the community", having recently decided that an allotment is what I would like, I then learnt that the waiting lists are longer than my arm!, so the sooner you have more sites to offer, the better. page70/para2/bullet4 Whilst there is a need for increased allotment The comment is noted. Mr Ian space with in croydon there should also be Specific design of allotment Leadbetter some thought given to the provision of "city and food growing space is a plots" these would be growing beds deep dug detailed matter not for the Observation measuring just 12ft x 5ft these srrounded by a Core Strategy. Noted – No Action path would be the most productive sized plots to grow food on in an intensive way especialy if the hight dimention was used . The traditional plot was designed with traditional crops and staples in mind however the new vegatables can be grown more intensivly and in shallower containers . in addition a city plot can be made using a raised bed system so would be suitable for a disabled person and as it is not walked on only requires a trowel and hand fork to manage . The other side to growing more food is to use less and perhaps there should be a collection service from all the major supermarkets of unsold food that can be re entered into the food chain or composted via a methane plant into valuable energy the waste heat into hot houses and the waste then back to the land . There is a section of MOL land at love lane se25 that the council sold off this should now be brought back into public ownership and again food production . There should also be available the provision of "panier" markets for local grown food say produced in croydon or surrounding 25 miles The site next to summerfield in may be used and it would be just local people selling there own or allotment produced food with pitches at a nominal fee ! page61 National Grid operates the national electricity The comment is noted. Leslie Morris transmission network across Great Britain and National Grid owns and maintains the network in England and Observation Wales, providing electricity supplies from Noted – No Action generating stations to local distribution companies. We do not distribute electricity to individual premises ourselves, but our role in the wholesale market is key to ensuring a reliable and quality supply to all. National Grid’s high voltage electricity system, which operates at 400,000 and 275,000 volts, is made up of approximately 22,000 pylons with an overhead line route length of 4,500 miles, 420 miles of underground cable and 337 substations. Separate regional companies own and operate the electricity distribution networks that comprise overhead lines and cables at 132,000 volts and below. It is the role of these local distribution companies to distribute electricity to homes and businesses. Please see the enclosed leaflet for more information on who to contact regarding electricity distribution issues in your area. n/a Continued from comment 1 re. background The comment is noted. The material... -Additionally, to cater for the need to Council will continue to carry Civil Aviation Authority record in aviation documents and charts at out its Telecommunications Observation structures extending 91.4m (300ft) above duties in accordance with Noted – No Action ground level, local planning authorities are formal consultation processes asked to inform the CAA/ DAP about as guided by central developments that might breach this level. government (GDO). page61 To facilitate competition in the supply and The comment is noted. Of Leslie Morris generation of electricity, National Grid must offer relevance to future work on National Grid a connection to any proposed generator, major Infrastructure Delivery Plan. Observation industry or distribution network operator who Noted – No Action wishes to generate electricity or requires a high voltage electricity supply. Often proposals for new electricity projects involve transmission reinforcements remote from the generating site, such as new overhead lines or new development at substations. If there are significant demand increases across a local distribution electricity network area then the local network distribution operator may seek reinforcements at an existing substation or a new grid supply point. In addition National Grid may undertake development works at its existing substations to meet changing patterns of generation and supply. n/a Continued from comment 1 re. background The comment is noted. The material...- 'Other Civil Aerodromes. Operators/ offer to assist in preparing Civil Aviation Authority licensees of civil aerodromes other thanthose 'non official' safeguarding Observation that are officially safeguarded are advised to maps is welcomed. Noted – No Action take steps to protect their locations from the effects of possible adverse development. To this end local authorities might agree to accept a 'non official' safeguarding map from any local aeronautical site. If the council has agreed to hold such maps, it should approach the site operator directly for comment on planning matters. Local planning authorities are asked to respond sympathetically to requests for non- official safeguarding. The CAA is prepared to offer advice on the preparation of a non-official safeguarding map at the request of any aerodrome operator or local planning authority. ODPM circular 1/2003 (annex 2, paragaph 13) refers n/a Continued from comment 1 re. background The comment is noted. The material:... - 'High Structures. Notwithstanding Council will continue to carry Civil Aviation Authority the requirements of local aerodrome operators out its Telecommunications Observation to consider the impact of structures within their duties in accordance with Noted – No Action (officially or unofficially) safeguarded area, away formal consultation processes from the immediate vicinity of an aerodrome, tall as guided by central structures might nevertheless constitute an government (GDO).See aviation hazard. In view of this, there is a repsonse to comment 1. mandatory lighting requirement for structures of a height of 150m or more. Moreover, away fro aerodromes, even structures less than 150m high may need to be lit if by virtue of their nature or location they constitute a significant hazard to air navigation. It is recommended that all proposed developments over 90m in height should be notified to the Directorate of Airspace Policy (DAP) and comment sought relating to the need or otherwise for aviation obstruction lights. n/a Whilst the CAA would not wish to comment on The comment is noted. The local development plans, where officially Council will continue to carry Civil Aviation Authority safeguarded aerodromes lie within the council's out its Telecommunications Observation area of jurisdiction,we recommend that the duties in accordance with Noted – No Action council considers the need of such formal consultation processes aerodrome(s) within your development plan and as guided by central consult with the aerodrome operator(s)/ government (GDO). licensee(s) directly.

Notwithstanding the comments above, the following, whilst by no means a comprehensive list of all development/ aviation related issues, might provide useful background material: - Telecom installations. Whilst it is noted that the General Development Order states that applications for masts within 3 km of an aerodrome should contain evidence of notification to the CAA or aerodrome operator, the appropriate contact is the aerodrome operator. Notification to the CAA will result in advice to contact the aerodrome operator. n/a Further Advice The comment is noted. Of Leslie Morris relevance to Development National Grid National Grid is happy to provide advice and Management DPD. Observation guidance to the Council concerning our No Action – Not an LDF Is networks. If we can be of any assistance to you in providing informal comments in confidence during your policy development, please do not hesitate to contact us. In addition the following publications are available from our web site or by contacting the team below:

National Grid Electricity Transmission plc, Electricity Act 1989 – Schedule 9 Statement, preservation of amenity

Specification for Safe Working in the Vicinity of National Grid High Pressure Gas Pipelines and Associated Installations – Requirements for Third Parties

A sense of place – Design guidelines for development near high voltage overhead lines n/a If a landscaping scheme is proposed as part of Not an LDF matter. Leslie Morris the works, we request that no trees and shrubs National Grid are planted either directly above or within 3 Observation metres of the existing underground cable, as No Action – Not an LDF Is ultimately the roots may grow to cause damage to the cable. The relocation of existing underground cables is not normally feasible on grounds of cost, operation and maintenance and environmental impact and we believe that successful development can take place in their vicinity. n/a Gas Transmission The comment is noted. Leslie Morris National Grid National Grid has no gas transmission assets Observation located within the administrative area of Noted – No Action Croydon Council.

Gas Distribution

Southern Gas Networks owns and operates the local gas distribution network in Croydon Council’s administrative area. Contact details for Southern Gas Networks can be found on the Energy Networks website. www.energynetworks.org page64/QuestionCC1 National Grid infrastructure within Croydon This information will be Leslie Morris Council’s administrative area relevant in the development of National Grid the Infrastructure Delivery Observation Electricity Transmission Plan. Noted – No Action National Grid’s high voltage electricity overhead transmission lines / underground cables within Croydon Council’s administrative area that form an essential part of the electricity transmission network in England and Wales include the following:

Several underground 275kV cables within the Croydon Council area which run from Rowdown substation in Bromley to substation in Sutton National Grid has provided information in relation to electricity transmission assets via the following internet link:

http://www.nationalgrid.com/uk/LandandDevelop ment/DDC/GasElectricNW n/a Our gas and electricity infrastructure is sited The comment is noted. Of Leslie Morris across the country and many stakeholders and relevance to future work on National Grid communities have an interest in our activities. Infrastructure Delivery Plan Observation We believe our long-term success is based on and subsequent DPDs. Noted – No Action having a constructive and sustainable relationship with our stakeholders. Our transmission pipelines and overhead lines were originally routed in consultation with local planning authorities and designed to avoid major development areas but since installation much development may have taken place near our routes. We therefore wish to be involved in the preparation, alteration and review of Development Plan Documents (DPDs) which may affect our assets including policies and plans relating to the following issues:

Any policies relating to overhead transmission lines, underground cables or gas pipeline installations

Site specific allocations/land use policies affecting sites crossed by overhead lines, underground cables or gas transmission pipelines

Land use policies/development proposed adjacent to existing high voltage electricity substation sites and gas above ground installations

Any policies relating to the diverting or undergrounding of overhead transmission lines

Other policies relating to infrastructure or utility provision Policies relating to development in the countryside

Landscape policies

Waste and mineral plans We also want to be consulted by developers and local authorities on planning applications, which may affect our assets and are happy to provide pre-application advice. Our aim in this is to ensure that the safe and secure transportation of electricity and gas is not compromised. page64/QuestionCC1 National Grid and Local Development Plan The comment is noted. Of Leslie Morris Documents relevance to future work on National Grid Infrastructure Delivery Plan. Observation The Energy White Paper makes clear that UK Noted – No Action energy systems will undergo a significant change over the next 20 years. To meet the goals of the white paper it will be necessary to revise and update much of the UK’s energy infrastructure during this period. There will be a requirement for:

An expansion of national infrastructure (e.g. overhead power lines, underground cables, extending substations, new gas pipelines and associated installations).

New forms of infrastructure (e.g. smaller scale distributed generation, gas storage sites). n/a Gas Distribution The comment is noted. Of Leslie Morris relevance to future work on National Grid National Grid also owns and operates Infrastructure Delivery Plan. Observation approximately 82,000 miles of lower-pressure Noted – No Action distribution gas mains in the north west of England, the west Midlands, east of England and north London – almost half of Britain's gas distribution network, delivering gas to around 11 million homes, offices and factories. National Grid does not supply gas, but provides the networks through which it flows. Reinforcements and developments of our local distribution network generally are as a result of overall demand growth in a region rather than site specific developments. A competitive market operates for the connection of new developments. page70- National planning The content of PPSs are Suzanne 71/urbanagriculture There is both direct and indirect support for noted. Natelson urban agriculture in PPS1 on implementing Sustain sustainable development, PPS3 on housing and Observation ensuring access to green spaces, and in PPG Noted – No Action 17 Planning for Open Space, Sport and Recreation. n/a Continued from comment 1 re. background The comment is noted.This is material... DfT/ ODPM Circular 1/2003 (annex not a matter for the Core Civil Aviation Authority 2, paragraph 30-32) refers. Strategy , but would be for a Observation Development Mangement Noted – No Action Venting and Flaring. Venting and flaring of gas DPD. should be anticipated with mineral extraction. This might have a potential impact upon the safe operation of aircraft in the immediate vicinity. With this in mind, should planning permission be granted, it would be essential to establish whether such releases of gas would constitute a potential danger to overflying aircraft. If there were such a danger, the site would need to be promulgated to the aviation community along with advisory avoidance criteria. page75/para1/bullet1 Croydon Council are currently working in Support is welcomed. Mr Michael partnership with the London boroughs of Sutton, Mulhern Kingston and Merton to prepare a South London Greater London Authority Joint Waste Development Plan Document, Support which is due to be submitted for examination in Noted – No Action July 2010. This approach is supported. page75/table It should be noted that the table in the waste The comment is noted. Mr Michael section has the incorrect apportionment figures Mulhern for the London Boroughs of Sutton and Merton, Greater London Authority which should be corrected. Object Agree – Propose Changes N/A All new development provides an opportunity to A Development Management Ms Susan implement best practice environmentally aware DPD will consider appropriate Sheahan design, which can help reduce energy and detailed policies, the next Environment Agency resource consumption during construction and Core Strategy consultation Observation throughout the life of the development and can report will explore further Noted – No Action enhance the local environment. The Local requirements under the Code Authority should encourage best practice for Sustainable Homes and environmental design for major developments. BREEAM. In regard to the options that should be considered we would wish that the following matters relating to sustainable design are included within these sections. Page63/Para1/Bullet7 In regard to the use of brownfield land the local The comment is noted. Ms Susan authority should seek to encourage remediation Sheahan where appropriate, prior to development, to Environment Agency improve the quality of soil and groundwater. Observation Noted – No Action Page63/How do we It is important to encourage the use of The next consultation report of Ms Susan deliver these options Sustainable Drainage Systems (SUDS) in new the Core Strategy will continue Sheahan developments, where appropriate. As well as to support promotion of SUDS. Environment Agency providing ‘flood risk management’ benefits Observation SUDS also have important multifunctional Noted – No Action benefits. For instance, in the creation of sustainable design policies, there is an opportunity to enhance local biodiversity, for example, through the implementation of green roof systems and in landscaping plans. Page63/How do we Green roofs should feature as a key component Green roofs will be referred to Ms Susan deliver these options of sustainable design and construction. The in the next version of the Core Sheahan Environment Agency encourages developers to Strategy. Environment Agency consider enhancing the biodiversity value of Object their development through the use of green Agree – Propose Changes roofs and green walls where appropriate. Green roofs can deliver benefits by creating new outdoor spaces, enhancing biodiversity, reducing flood risk (by absorbing heavy rainfall), providing insulation and improving the appearance of our cityscape. page 67 para 1 bullet 3 The dearth of parks and open spaces in Purley A Strategic Housing Land Mr Barry Atwood emphasises the need to safeguard its “back Availability Assessment is lands and residential gardens from being prepared. Generally Observation overdevelopment” (see letter: para 7). backland development will not Noted – No Action be encouraged as it potentially undermines the character of the area. Page57/Where do we The objective of improved Transport is of course The support is welcomed. Mr Barry Atwood want to be commendable. Support Agree - No Action page59/para2/bullet7 the main need for an improved Tramlink is not in The comment is noted. TfL Mr Barry Atwood Purley but in the south east of the Borough (see with the borough will consider letter: para 30); the most appropriate tramlink Object extensions in a future study. Noted – No Action Page63/QuestionCC3 We encourage sustainable energy schemes. The comment is noted. This of Ms Susan However, use of penetrative GSHPs will require relevance to future work on Sheahan an assessment of the potential environmental Development Management Environment Agency impacts. We will require these systems to be DPD. Observation operated sustainably i.e. no overall changes in Noted – No Action temperature over the course of a year. There may also be risks associated with drilling of boreholes for the GSHP on contaminated sites and appropriate level of risk assessment will be required. This issue is applicable to all sites. Page59/Para2/Bullet9 the option for a tunnel under Purley centre was The comment is noted. The Mr Barry Atwood set aside 20 years ago. The cost would be appropriate engineering enormous, the project would be complicated by solution to traffic congestion in Observation the lie of the land and the Bourne stream, while Purley will need to be the Noted – Propose Changes there would still be congestion beyond the subject of future study. The tunnel towards Coulsdon. complications with water levels and the Bourne are acknowledged. Page59/para1 The document should also more clearly The comment is noted. The Mr Michael acknowledge the constraints of the existing next consulation draft Core Mulhern public transport and highway networks in greater Strategy will illustrate points of Greater London Authority detail. There is the risk that additional travel congestion in more detail. Object demand and increased congestion may Noted – Propose Changes discourage development. page74/para1/bullet1 The Council’s objective to meet London Plan The comment is noted and Mr Michael waste apportionment target is supported. agreed. Next consultation Mulhern However, as set out in London Plan policy 4A.24 draft Core Strategy will refer to Greater London Authority the Core Strategy should make clear reference this. Object to safeguarding all existing waste management Agree – Propose Changes sites. page63/para2/bullet2 The reference to the generation of renewable We will develop our policies Mr Michael energy is welcomed, however, it should be through an appropriate Mulhern made clear that new developments should evidence base to assess the Greater London Authority maximise the opportunities to reduce carbon feasibility of policy Observation dioxide emissions through the use of on-site requirements and will consider Noted – Propose Changes renewable energy systems in the context of the different policy options. The energy hierarchy. Council understands the importance of the energy hierarchy and policy will reflect the importance of energy efficiency and decentralised energy as well as renewables. page64/questioncc3 It is recommended that the Council state its The comment is noted. The Mr Michael intention, to play a leading role in identifying concept of energy networks Mulhern opportunities for expanding existing networks will be furthered in the next Greater London Authority and establishing new networks by undertaking consulation draft Core Observation energy master plans for specific decentralised Strategy. Agree – Propose Changes energy opportunities. page64/questioncc1 It is recommended that specific reference is The comment is noted. Mr Michael included to the opportunities that could exist for Changes will be made to Mulhern reducing carbon emissions associated with reflect this observation in the Greater London Authority existing building stock; whether it is via the next consulation draft Core Observation retrofitting of energy efficiency measures and/or Strategy. Agree – Propose Changes the deployment of low carbon district heating networks to link not only new developments but also the existing building stock and in particular council owned buildings, and if suitable to use council owned land for the installation of energy centres to supply the heat networks. page64/questionCC3 The Core Strategy should require new The comment is noted. Mr Michael development to submit an energy assessment in Mulhern line with the above energy hierarchy. The Core Greater London Authority Strategy should require new development to Object apply to the highest standards of energy Noted – No Action efficiency including passive building design with the aim of minimising heating and cooling loads, suitable access to natural day lighting and the use of energy efficient lighting and equipment, whilst minimising the need for comfort cooling. page62/para1 The Core Strategy includes references to the The comment is noted. Mr Michael London Plan energy hierarchy of energy efficient Mulhern building design, decentralized energy supply Greater London Authority and renewable energy, which is supported. Support Noted – No Action Page64/Question CC3 PPS12 requires that in preparing Local The comment is noted. Of Carmelle Bell Development Documents, authorities should relevance to future work on Thames Water Property consider both the requirements of the utilities for Development Management Observation land to enable them to meet the demands that DPD. Noted – No Action will be placed upon them and the environmental effects of such additional uses. In addition, as detailed above, sewerage undertakers can be required to undertake development in order to provide environmental quality improvements and enhanced services. As such a policy should be provided to support sewerage infrastructure development as follows:

“PROPOSED POLICY – WATER AND SEWERAGE INFRASTRUCTURE DEVELOPMENT: The development or expansion of water and waste water facilities will normally be permitted, either where needed to serve existing or proposed development in accordance with the provisions of the Development Plan, or in the interests of long term water supply and waste water management, provided that the need for such facilities outweighs any adverse land use or environmental impact that any such adverse impact is minimised.” Page64/Question CC3 Given the potential implications of development The precise wording of any Carmelle Bell being provided ahead of any necessary policy will be considered in Thames Water Property infrastructure upgrades it is essential that the future versions of the Core Object Core Strategy makes reference to the provision Strategy.The comment is Noted – Propose Changes of adequate water and sewerage infrastructure noted and is of relevance to to service development. Therefore, if the Core future work on Infrastructure Strategy is to meet the “soundness” test, then it Delivery Plan. should include the following policies and sub- text:

“PROPOSED POLICY – WATER AND SEWERAGE INFRASTRUCTURE CAPACITY:Planning permission will only be granted for developments which increase the demand for off-site service infrastructure where:

1. sufficient capacity already exists or

2. extra capacity can be provided in time to serve the development which will ensure that the environment and the amenities of local residents are not adversely affected.

When there is a capacity problem and improvements in off-site infrastructure are not programmed, planning permission will only be granted where the developer funds appropriate improvements which will be completed prior to occupation of the development.” Text along the following lines should be added to the Core Strategy to support the above proposed Policy :

“PROPOSED SUPPORTING TEXT - The Council will seek to ensure that there is adequate water, surface water, foul drainage and sewerage treatment capacity to serve all new developments. Developers will be required to demonstrate that there is adequate capacity both on and off the site to serve the development and that it would not lead to problems for existing users. In some circumstances this may make it necessary for developers to carry out appropriate studies to ascertain whether the proposed development will lead to overloading of existing infrastructure. Where there is a capacity problem and no improvements are programmed by Thames Water, the Council will require the developer to fund appropriate improvements which must be completed prior to occupation of the development.” Page59/Para2/Bullet4 it is difficult to see how park and ride facilities The issue of car parking will Mr Barry Atwood can be accommodated in Purley. The town lacks be addressed through a adequate parking for its current needs, the Dale Transport Strategy and Observation Road car park has now been sacrificed and the considered as part of Site Noted – No Action only other open space is at the top of Foxley Allocations and/or Lane (see letter: para 17); Development Management Development Plan Documents. page64/questioncc3 However, no delivery method has been provided A Development Management Ms Susan (relating to the identification of brownfield sites DPD will consider appropriate Sheahan as a potential risk to groundwater quality). We policies. Environment Agency suggest the inclusion of the following delivery Observation options: Noted – No Action • Require all new developments on brownfield sites to identify the potential risks to controlled waters (ground and surface water) through historical contamination at early stages in development process if located in an Inner Source Protection Zone. page60/questionTM2 American style buses – with more schools and The comment is noted. Mr Ross Gentry more housing how will the road network cope? LBC Would American style school buses be a way to Observation get cars off the road? Perhaps better cycling Noted – No Action facilities is another option. page59/para2/bullet7 There were proposal to extend tramlink – could The comment is noted.. The Mr Ross Gentry this happen to reduce car dependency? Strategy principle of extending the tram LBC needs to ensure this possibility is factored in. network is made as the Observation second bullet point on page Noted – No Action 57 of the document. page60/QuestionTM2 In addition to enhancement of the capacity of Agree the text on page 59 Mr Austin Mackie major transport interchanges, the Borough under 'What are the Options Austin Mackie Associates should seek to promote, together with its for Change?' already Ltd strategic transport partners, enhancements and considers extensions for Observation extensions to local bus and tram routes to tramlink. Gaps in the bus Agree - No Action enhance the connectivity of and between local network will be considered in neighbourhoods. the transport strategy as a basis for further versions of the Core Strategy. Page60/Question TM2 We would welcome measures to reduce the The comment is noted. Bullet Mr Austin Mackie environmental and economic impacts of point 6 at the foot of page 57 Austin Mackie Associates congestion on residential and other areas. covers this sentiment. Ltd Observation Noted – No Action page75/QuestionW2 As identified above (The impact of waste The comment is noted. The Mr Austin Mackie locations on both economic investment and economic and environmental Austin Mackie Associates general environmental, but in particular impacts of proposed waste Ltd residential amenity needs to be considered facilities will be considered as Observation carefully), we consider that the location and part of the Joint South West Noted – No Action impact of waste / energy facilities need to be London Waste Plan DPD. carefully considered. We support measures to enhance pedestrian The support is welcomed. Mr Austin Mackie accessibility to tram stations and feel that this Bullet point 6 at the foot of Austin Mackie Associates should be extended to enhancing the overall page 57 endorses this Ltd pedestrian environment of the area. aspiration. Support Agree - No Action page71/questionua2 We support the principle of urban agriculture The support is welcomed. Ms Susan and the encouragement given to producing local Sheahan food. Green roofs provide a good opportunity of Environment Agency utilising underused space for the provision of Support gardens and agriculture. Please see above in Noted – No Action 4.0. Page60/Question TM2 The document should refer specifically to taxis The comment is noted. The Mr Michael and the role they play in alleviating pressures on role of the taxi in Croydon Mulhern other services, as can be seen at East Croydon both presently and in the Greater London Authority Station /interchange. There is also a well-used future will be considerd in the Object taxi rank on the High Street and a smaller, but transport strategy. Any Noted – Propose Changes also well-used rank in Poplar Walk. The lessons of a straetgic nature document should consider where future taxi rank will feature in future Core facilities could be provided. Strategy consultation reports. Page69/Para1/Bullet1 In carrying out a review of Green Belt and The comment is noted. Mr Michael identifying uses that are considered to be Mulhern compatible with Green Belt and Metropolitan Greater London Authority Open Land designations, any proposals uses Observation must be compatible with policy set out in PPG2 Noted – No Action and the London Plan. page60/QuestionTM1 There is no reference in the document to Travel The comment is noted. This Mr Michael Planning or ‘smarter travel’ measures, which can will be progressed in later Mulhern be used to aid the reduction in trips and versions of the Core Strategy. Greater London Authority congestion. Smarter travel initiatives, especially Observation those linked to new developments and planning Agree – Propose Changes applications can assist in managing the impact of growth/development on the transport network, whilst also contribute towards improving accessibility and assist in achieving Croydon’s air quality targets. The Core Strategy should clearly identify the role Travel Plans and ‘smarter travel’ initiatives can play in delivering sustainable transport. Page59/para2 The plan should generally include protection for The comment is noted. This Mr Michael all transport related land uses including bus issue will be addressed in the Mulhern garages, stands and drivers’ facilities, rail next Core Strategy Greater London Authority facilities including stations and depots and consultation report. Observation safeguarding of land required for future Noted – Propose Changes expansion of the network including new route alignments or interchanges. Page75/Para2/Bullet4 Such areas, including fringe SIL and other Waste facilities are acceptable Mr Austin Mackie industrial areas should not be considered for uses for Strategic Industrial Austin Mackie Associates waste related activity. Locations within the borough. Ltd Object Disagree – No Change page75/questionW2 The impact of waste locations on both economic The comment is noted. The Mr Austin Mackie investment and general environmental, but in economic and environmental Austin Mackie Associates particular residential amenity needs to be impacts of proposed waste Ltd considered carefully. facilities will be considered as Observation part of the Joint South West Noted – No Action London Waste Plan DPD. page 63 para 1 bullet 4 We also support measures to reduce the impact The support is welcomed. Mr Austin Mackie of and reduce activities that adversely affect air Austin Mackie Associates quality. Ltd Support Agree - No Action Pg 61 para 1 bullet 5 We welcome measures to promote district-wide The support is welcomed. Mr Austin Mackie heating schemes, although their location in the Austin Mackie Associates context of residential amenity and wider Ltd environmental quality, traffic generation etc Support needs to be considered carefully. Agree - No Action page57 We support measures to decrease travel as a The comment is noted. A Mr Austin Mackie whole and consider that dispersed growth modified development Austin Mackie Associates represents a key opportunity to achieving more strategy will be outlined in the Ltd sustainable patterns of travel. next consultation of the Core Observation Strategy. Noted – Propose Changes page59/para2/bullet7 The plan makes reference to a possible Disagree. The Council Mr Michael extension of the Croydon Tramlink to Crystal considers it appropriate to Mulhern Palace. Whilst TfL has been progressing this identify possible extensions on Greater London Authority project, there is no committed funding for the a specific basis. Object scheme. The document should therefore state a Disagree – No Change ‘non-destination specific’ intention to explore and support the feasibility of increasing the capacity of the existing Tramlink network, in order to support the Borough’s growth aspirations. In the instance that funding for expansion becomes available, TfL would welcome discussions with the borough to determine practicable options. page60/QuestionTM2 Businesses are reliant on servicing and freight, The comment is noted. It is Mr Michael therefore ensuring new developments are intended that the Borough will Mulhern accompanied by construction logistics plans and investigate the issue of Greater London Authority delivery and servicing plans will be key to construction logistics through Observation ensuring that future growth is supported by the development of a Borough Noted – No Action sustainable transport practices that complement wide Transport Strategy. the arrangement of the public realm. page 71/questionua1 With reference to groundwater and urban The comment is noted. Ms Susan agriculture we would like to highlight the Sheahan potential impact on water quality, which can be Environment Agency significant. Observation Noted – Propose Changes Page64/Question CC3 Furthermore, development should not increase The comment is noted. More Carmelle Bell the risk of flooding off-site further down the detailed policy for flooding will Thames Water Property catchment and should only be permitted where be developed for the next Object infrastructure is available or it can be provided Core Strategy consultation Noted – No Action ahead of development. report. page 71/questionua1 However, we would not support the use of The comment is noted and will Ms Susan riverbanks for urban agriculture (page 71, be developed as the Core Sheahan Options for Change). Even in rural areas we Strategy progresses. Environment Agency seek a buffer strip to act as a riparian wildlife Object corridor along the margins of rivers. Any Agree – Propose Changes development, including agriculture/allotments, should provide a 5 metre buffer zone for non- main rivers and an 8 metre buffer zone for main rivers, to be measured from the top of the bank/wetland edge. This buffer zone should be free of all build development and planted with locally native species only. page59/para2/bullet5 The Council should seek to identify the need for Agree in principle. public car parking in the Metropolitan Centre. Croydon Gateway Limited The provision of any additional major car parking Partnership facilities for public use should be avoided, and Object sustainable forms of transport promoted. Agree - No Action Page64/Question CC3 It is essential that developers demonstrate that The comment is noted. Of Carmelle Bell adequate capacity exists both on and off site to relevance to future work on Thames Water Property serve development and that it would not lead to Infrastructure Delivery Plan Observation problems for existing users. In some and Development Noted – No Action circumstances this may make it necessary for Management DPD. developers to carry out appropriate studies to ascertain whether the proposed development will lead to overloading of existing sewerage infrastructure. Where there is a capacity problem and no improvements are programmed by the water company, then the developer needs to contact the water authority to agree what improvements are required and how they will be funded prior to any occupation of the development. Page60/para1/bullet5 Purespace Group support the notion that West The support is welcomed. Croydon Station needs to cope effectively with Purespace the growth in passenger number as a result of Support more residential units and jobs in the Centre. Noted – No Action Purespace Group agrees that the most appropriate method to deliver this option is through the West Croydon Masterplan and Site Allocations Development Plan Document. Page63/Para1/Bullet8 CGLP consider that Croydon requires a strategic The support is welcomed. overview with regard to the provision of energy Croydon Gateway Limited efficient measures within development schemes. Partnership With regard to an overall energy strategy for Support Croydon, CGLP welcome the notion that the Agree - No Action potential for district-wide energy networks should be investigated. page61/para1/bullet1 In this section the Council clearly sets out its The support is welcomed. Ms Ann vision over climate change and related areas. Burroughs The wording is strong, clear and concise using Metropolitan Police such words as ‘require’ and ‘resist’ and all Support parties are immediately aware of the strong Agree - No Action emphasis. page64/questioncc1 This is a long term visioning strategic document The comment is noted. Details Ms Ann and it is important that it is equipped to deal with of secured by design to be Burroughs impending developing initiatives such as the considered through Metropolitan Police environmental costs of crime. With this in mind, consultation on the Observation we draw your attention to the recent “preliminary Development Management Noted – No Action findings” from Profs. Pease and Farrell of the DPD. University of Huddersfield into “The Impact of Crime on the Environment and CO2 Emissions”. In addition to the social and economic costs, preliminary figures from Prof. Ken Pease indicates that a single burglary creates 2.5 tons of carbon generated by the many strands of activity that the responses of the victim, police and community create in consequence of an offence. One tree growing for 100 years equates to 1 Ton of CO2. page64/questioncc1 The study as yet unpublished, shows how many The comment is noted. Details Ms Ann tonnes of CO2 each offence generates, on of secured by design to be Burroughs average. These include: considered through Metropolitan Police consultation on the Observation CRIME CO2 per offence Development Management Noted – No Action DPD. Robbery 3.71

Burglary of homes 2.50

Other burglary 2.50

Theft of vehicle 2.75

Theft from vehicle 0.47

Attempt vehicle theft 0.26

Criminal damage 0.39 pages 62- On a borough basis last year there were 2316 The comment is noted. Details Ms Ann 64/questioncc1 reports of domestic burglary equating to 5790 of secured by design to be Burroughs tonnes of CO2 emitted. Using the research considered through Metropolitan Police figures previously quoted, by implementing consultation on the Observation planning conditions that require SBD physical Development Management Noted – No Action protection this borough could enable at least 50 DPD. % long term reduction of CO2 emissions caused by instances of domestic burglary alone. Using the more conservative figure of a 50% reduction of last year’s figures that would equate to 2895 tonnes of CO2! page64/questioncc1 Dr Rachael Armitage’s research has shown that The comment is noted. Details Ms Ann the inclusion of SBD standards have made a of secured by design to be Burroughs significant reduction in acquisitive crimes considered through Metropolitan Police reported such as theft, burglary, robbery as well consultation on the Observation as criminal damage. All of these offences have a Development Management Noted – No Action carbon cost, each theft of a vehicle costs 2.75 DPD. tonnes of CO2 and there were 4325 reports of vehicle crime made in Croydon during the twelve months to Aug 2009. It is accepted that the research into this subject is at an early stage however these preliminary figures show that crime and sustainability are intrinsically linked. Page63/Para1/Bullet9 The document advises that in order to increase The Draft Replacement the proportion of the Borough’s energy London Plan is referred to. Purespace generated from renewable energy and low Observation carbon sources, that major new developments Noted – No Action will be “required” to offset 50% of their Co² emissions and at least 20% through renewable energy technologies. The London Plan advises that the Mayor will work towards the long-term reduction of Co² emissions and that local planning authorities “should seek to achieve the following minimum reduction targets’:15% by 2010; 20% by 2015; 25% by 2020; 30% by 2025”. page60/para1 In respect of the delivery of the options for The comment is noted. The change, CGLP considers that the above support is welcomed. Croydon Gateway Limited measures should form part of the emerging Partnership Masterplan for East (and West) Croydon Observation Stations. CGLP support the vision for the Noted – No Action Wellesley Road and in particular the enhancement of east – west pedestrian links through the Metropolitan Centre. pg 61 para 1 bullet 3 The figures set out in the London Plan for the The comment is noted, but the use of renewable energy and the relocation of Council believes the Purespace carbon emissions are target figures. As such, statement is clear as phrased. Object major new developments are not “required” to Disagree – No Change meet the figures set out in the draft report. The Core Strategy should therefore express the delivery of the options as “targets”. page59/para2/bullet5 With regard to considering new car parking The comment is noted. provision in town centres, CGLP considers that Croydon Gateway Limited a strategic overview of the provision of car Partnership parking within Croydon Metropolitan Centre Observation should be undertaken. Clearly, a balance needs Noted – No Action 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. page59/para2/bullet3 In respect of the option to improve the The support is welcomed. movement of buses to the Centre, CGLP Croydon Gateway Limited supports the general principle of improving the Partnership bus service facilities in Croydon and the Support development of masterplans for East Croydon Agree - No Action as West Croydon Stations to improve and expand their capacity and facilities, by making them part of a fully integrated public transport interchange. page59/para2/bullet1 The document refers to the option of securing The comment is noted. investment in East Croydon Station to improve Croydon Gateway Limited access and passenger flow and passenger Partnership capacity in the medium to long term. It is Observation recognised that the station has potential to Noted – No Action address issues relating to passenger capacity particularly with the amount of new development proposed in the area. Any proposals for improvements to the station which come forward should be prepared with full consultation with the Council and adjoining land owners to ensure that the most appropriate scheme is proposed. page59/para2/bullets1- CGLP support and would encourage The support is welcomed. 2 improvements to East Croydon Station. East Croydon Gateway Limited Croydon Station is the 3rd busiest in London Partnership with over 22m people passing through its Support barriers in 2007/08, which represents an Noted – No Action increase on 16% from the previous year. As such, the station is the main arrival point for passengers into Croydon and needs to reflect this important transport node into the Metropolitan Centre. Currently, the appearance of the station does not live up to its status as a significant transport interchange and does not give the passenger a sense of arrival within the Metropolitan Centre of Croydon. Page 75/Question W1 A place for sustainable living: Waste – You are Consideration will be given to Ms Alison producing a joint waste development plan the need to plan for waste Fairhurst document with the neighbouring boroughs of after 2021. Government Office for Merton, Sutton and Kingston. The joint waste London DPD only covers the period up to 2021. In view Observation of this how will you be taking forward waste Noted – Propose Changes issues within the borough from 2021 until the end of the Core Strategy, that is, at least 15 years from the date of adoption? Page62/Where are we In relation to flooding, it would have be useful to Flood maps are presented on Ms Alison now identify the general areas at high risk of flooding page 18 and 65 Fairhurst and any implications this may have for the Government Office for potential areas of growth. London Object Noted – No Action Page68/Para2/Bullet2 You also state that you are currently looking at The need to fully jusify future Ms Alison the Green Belt boundary and designated sites Green Belt changes is noted. Fairhurst which may identify land that could be potentially The Council will consider Government Office for released, whether there is a case for new further the arguments for and London inclusions, exclusions or alterations to identified against Green Belt and MOL Object boundaries, or whether any sites should be de- amendment in the next Noted – Propose Changes designated or designated as Metropolitan Open consultation report for the Land. Planning Policy Guidance 2 ‘Green Belts’ Core Strategy. (paragraph 2.7) states that “Once the general extent of a Green Belt has been approved it should be altered only in exceptional circumstances. If such an alteration is proposed the Secretary of State will wish to be satisfied that the authority has considered opportunities for development within the urban areas contained by and beyond the Green Belt. Similarly, detailed Green Belt boundaries defined in adopted local plans or earlier approved development plans should be altered only exceptionally. Detailed boundaries should not be altered or development allowed merely because the land has become derelict”. As with the above point, should these proposals be part of your published plan, you will have to provide a robust evidence base to justify why you consider they are the most appropriate and achievable policies for your borough. Page63/Para2/Bullet4 A place for sustainable living: Climate change, Evidence to support the next Ms Alison energy, green buildings, flooding and water: consultation report on the Fairhurst Core Strategy is being Government Office for - This proposes that all residential sites should prepared that will assess the London achieve Code for Sustainable Homes Level 4 potential of renewables in the Observation prior to 2013. As this is in advance of national borough as well local Noted – No Action guidance you will need to provide a robust requirements for sustainable evidence base to justify that this is the most buildings. realistic and achievable option for your borough. Page64/Para1/Bullet2 In relation to Green Belt you propose that The policies developed in the Ms Alison surplus areas of such land are designated for Core Strategy will need to Fairhurst the deployment of major renewables and low adhere to the requirements of Government Office for carbon energy production. Planning Policy PPG2. London Guidance 2 ‘Green Belts’ (paragraph 2.7) states Object that “Once the general extent of a Green Belt Noted – Propose Changes has been approved it should be altered only in exceptional circumstances. If such an alteration is proposed the Secretary of State will wish to be satisfied that the authority has considered opportunities for development within the urban areas contained by and beyond the Green Belt. Similarly, detailed Green Belt boundaries defined in adopted local plans or earlier approved development plans should be altered only exceptionally. Detailed boundaries should not be altered or development allowed merely because the land has become derelict”. As with the above point, should these proposals be part of your published plan, you will have to provide a robust evidence base to justify why you consider they are the most appropriate and achievable policies for your borough. Page63/Para1/Bullet9 The document advises that in order to increase The London Plan is clear that the proportion of the Borough’s energy 20% renewable energy is a Croydon Gateway Limited generated from renewable energy and low target, it follows that this must Partnership carbon sources, that major new developments be the minimum average for Object will be “required” to offset 50% of their carbon new major developments to Noted – No Action emissions and at least 20% through renewable achieve the overall target. energy technologies. The London Plan advises Theprecise policy wording to that the Mayor will work towards the long-term schieve this target will be reduction of carbon emissions and that local developed in subsequent planning authorities, “should seek to achieve the versions of the plan. following minimum reduction targets’:15% by 2010; 20% by 2015; 25% by 2020; 30% by 2025”.

The figures set out in the London Plan for the use of renewable energy and the relocation of carbon emissions are target figures. As such, major new developments are not “required” to meet the figures set out in the draft report. The Core Strategy should therefore express the delivery of the options as “targets”. page71/questionua2 In general terms, the HCA is of the view that the The level of detail on urban options and proposed delivery solutions within agriculatural issues will be Homes and Communities the Urban Agriculture section of the consultation reviewed. Agency document include an inappropriate level of detail Object for the Core Strategy, which should deal Agree – Propose Changes primarily with strategic spatial policies. page 71/questionua1 The application of fertilisers/pesticides can have The comment is noted. Ms Susan a detrimental impact on both surface and Sheahan groundwater quality. These compounds are Environment Agency often highly resistant to degradation and can Observation build up in the environment. Given the sensitive Noted – No Action nature of the groundwater as highlighted earlier, it is important to direct this kind of development away from more sensitive SPZ 1’s unless the risks can be adequately managed. In addition, the southern part of the district is located in a Surface Water Nitrate Vulnerability Zone, which means that the area has been highlighted as sensitive to diffuse inputs of nitrate (from fertiliser) that can enter streams and rivers through surface water run-off. page63 In relation to the questions raised on page 63 of The support is welcomed. The Carmelle Bell the document, all new development should be Council intends to require Thames Water Property required as a minimum to meet the water Level 4 for the Code for Support requirements as set out for level 3 in the Code Sustainable Homes. Evidence Agree - No Action for Sustainable Homes. to support the next consultation report on the Core Strategy is being prepared that will assess the potential of renewables in the borough as well local requirements for sustainable buildings. page62 On page 62 of the document it is stated that the The comment is noted. Carmelle Bell sewerage network can handle waste water and Thames Water Property a 1:50 rainfall event. Thames Waters design Object solutions for sewer networks are designed to a Noted – No Action 1:30 rainfall event and not a 1:50 event. page62/para1 To meet the test of “soundness” as set out in The comment is noted. Carmelle Bell PPS 12 it is essential that the Core Strategy Thames Water Property does consider such water and sewerage Observation infrastructure. In July 2008 The Planning Noted – No Action Inspectorate published “Examination of Development Plan Documents: Soundness Guidance”. The Guide sets out a series of ‘key questions’ that should be convincingly answered which aim to provide a framework for the assessment of soundness of DPDs. page71/QuestionUA1 Proposals within the urban agriculture section of Noted the need to conserve Carmelle Bell the issues and options document would result in water supply is recognised on Thames Water Property an increased demand for water for irrigation. bullet point 5 on page 63 Observation Any policies promoting urban agriculture should "promote responsible Noted – No Action emphasise the need for sustainable water consumption of natural resources such as rainwater harvesting. resources…potable water" pg 64/ Qestion CC1-3 The need to avoid major subterranean The comment is noted. Mr Barry Atwood engineering and the existence of the Bourne stream seems likely to preclude a tunnel Observation beneath Purley centre and probably an Noted – No Action underground car park on the site adjacent to the railway. page65/greengrid The HCA notes that the Cane Hill site, together The comment is noted and a with the majority of other open spaces within the change to text and the Homes and Communities Borough, are shown to be “Potential Downland proposals map will be Agency Regional Park” on the legend that accompanies considered. Object the “Green Grid” diagram on page 65 of the Agree – Propose Changes consultation document. The HCA would welcome clarification as to the status of this proposed Regional Park, and how this might work in practice.Furthermore, the boundaries of any proposed park should have regard to the future redevelopment proposals for the Cane Hill site. page 67/para1/bullet2 The second bullet point on page 67 of the The Council will consider consultation document refers to, inter alia, further the arguments for and Homes and Communities “safeguarding all open spaces”. In the context of against Green Belt and MOL Agency the text on page 68 which confirms that the amendment in the next Object Council is currently reviewing existing Green consultation report for the Noted – Propose Changes Belt boundaries, it is considered that for Core Strategy. consistency this text should be revised to refer to the work currently being undertaken in respect of Green Belt land. page59/para2/bullet2 Purespace Group supports the general principle The support is welcomed. of improving the passenger interchange at West Purespace Croydon Station and the pedestrian links around Support the station through the development to improve No Action – Not an LDF Is and expand capacity and facilities, as part of a fully integrated public transport interchange. page71/para1/bullet2 The HCA is also concerned by the reference to The paragraph in question protecting publicly owned brownfield sites from refers to unconventional Homes and Communities development, as this appears to be contrary to underused spaces i.e. sites Agency guidance within PPS3 that encourages not capable of accomodating Object consideration of the opportunity for housing other forms of development Noted – No Action provision on surplus public sector land. including housing. Page64/Question CC3 It is our understanding that Section 106 The comment is noted. The Carmelle Bell agreements cannot be used to secure water or mechanisms to secure water Thames Water Property waste water treatment upgrades. Furthermore, and waste water infrastructure Observation water and sewerage undertakers have limited enhancements are a matter Noted – No Action powers under the water industry act to prevent for the Infrastructure Delivery connection ahead of infrastructure upgrades. Plan and the Development However, it is essential that any required water Management DPD. and sewerage infrastructure is in place ahead of the occupation of development in order to avoid problems such as sewer flooding and pollution or low/no water pressure. Water and sewerage undertakers therefore rely heavily on the planning system to ensure infrastructure is provided ahead of development either through phasing or the use of Grampian style conditions. page72/para2/bullet5 The HCA notes reference on page 72 of the This is a matter for a Site consultation document to Croydon’s transport Allocations DPD. Homes and Communities corridors and development opportunities being Agency constrained by natural geology (the valleys and Object slopes in the south of the Borough) which also Noted – No Action provide opportunities for long views and strategic open space; and threat one of the consequent options for change on page 73 is to seek to safeguard specific sites and corridors from development. The HCA notes that it is possible to provide development on slopes, however it will be in instances such as this (where build costs will be higher as a direct consequence of the topography) where viability considerations will be crucial. In terms of safeguarding specific sites and corridors from development, the HCA considers it might be more appropriate to adopt a criteria based approach to the development of these sites, where appropriate. page59/para2/bullet2 The document should make specific reference to The comment is noted. The Mr Michael the need for improvements to public transport role of traffic management Mulhern facilities such as bus stopping and standing measures in tacling strategic Greater London Authority facilities at West Croydon, this will play a key trasnport issues will need to Observation part in achieving the desired growth for the be assessed in later versions Agree – Propose Changes borough. of the consultation draft Core Strategy. Page60/Para1/Bullet2 The plan refers to the borough-wide transport The comment is noted. The Mr Michael strategy, some greater detail on how this will tie borough-wide transport Mulhern in with the Core Strategy should be provided, strategy and that for the town Greater London Authority with reference also given to the Croydon Town centre are informal studies Observation Centre Transport Strategy. providing evidence base and Noted – No Action suggested policy for the LDF. page68 The HCA notes the reference to the farm The Council will consider complex at Cane Hill on page 68 of the further the arguments for and Homes and Communities consultation document, but also notes that no against Green Belt and MOL Agency mention is made of the wider Cane Hill site, in amendment in the next Object the context of its MDS status. The HCA would consultation report for the Noted – Propose Changes welcome clarification on the Council’s intentions Core Strategy. for the designation of Cane Hill in Green Belt/MOL terms within future iterations of the Core Strategy, having regard to the statement within the second bullet point of the “Where are we now?” section on page 68 of the consultation document which confirms that “the Green Belt boundary and designated sites are currently being considered which may assist in identifying land that could be potentially released from the Green Belt…” The HCA welcomes and supports the text within this second bullet point, and considers that it is wholly appropriate for the Council to be undertaking this work as it plans for sustainable growth. In procedural terms, it is also recognised that it is appropriate to review Green Belt boundaries through the LDF process, in line with London Plan Policy 3D.9. page69 In light of the comments above, the HCA The Council will consider supports the Council’s delivery option of further the arguments for and Homes and Communities reviewing boundaries and designated sites against Green Belt and MOL Agency within the Green Belt to inform its Core Strategy amendment in the next Observation and Site Allocations DPDs, as set out on page consultation report for the Noted – Propose Changes 69 of the consultation document. In this context, Core Strategy. the HCA also considers that the heading and legend of the diagram on page 69 of the consultation document should be amended to refer to “existing” green spaces. page61 The HCA notes the Council’s aim for all major The comment is noted. The developments and growth areas to incorporate viability of development will be Homes and Communities district-wide energy networks (page 61), and is considered when preparing Agency supportive in principle providing the viability of the Core Strategy. Observation major schemes is not adversely affected, to the Noted – No Action detriment of their delivery. page63 Page 63 of the consultation document refers to It is recognised that it is not an option of requiring major new developments always possible for on-site Homes and Communities to offset 50% of their CO2 emissions and at generation. As an alternative, Agency least 20% through renewable energy it may be suitable for a Observation technologies. The HCA notes that the PPS1 financial contribution to be Noted – No Action Supplement, Planning and Climate Change, sought and used to reduce 2007 requires local authorities to have an CO2 emissions elsewhere. evidence-based understanding of the local We will develop our policies feasibility and potential for renewable and low through an appropriate carbon technologies to supply new development evidence base to assess the in their area (paragraph 26). However, this feasibility of policy paragraph also acknowledges that any target requirements and will consider percentage should draw from the evidence other policy options, such as base, be consistent with housing and economic setting a CO2 reduction target objectives and demonstrate it is viable. The HCA with no specific renewables would support the inclusion of targets where requirement. they accord with PPS1 Supplement requirements. page63 In the context of ensuring high standards of Support is welcomed sustainability and design within future Homes and Communities developments, the HCA is supportive of the Agency option (on page 63 of the consultation Support document) to require all major residential sites to Agree - No Action achieve a Code for Sustainable Homes Level 4 rating prior to 2013, with a suitable timetable for requiring higher standards to be determined at a later stage. page64/bullet3 The HCA considers that the Council’s option to The Council will consider deploy major renewables and low carbon energy further the arguments for and Homes and Communities production on, inter alia, “surplus areas of Green against Green Belt and MOL Agency Belt” is one that will have to be considered very amendment in the next Observation carefully in the context of the guidance set out in consultation report for the Noted – Propose Changes PPG2, in terms of what is deemed Core Strategy. (in)appropriate development in the Green Belt. page71/para1/bullet2 The HCA notes that one of the options for The comment is noted. The change set out on page 71 of the consultation Council will consider a Homes and Communities document is to protect “unconventional balanced approach for the Agency underused spaces” (including publicly owned promotion of urban agriculture. Object brownfield sites) from development in order for Noted – No Action them to be used for urban agriculture. The HCA is wary of such a blanket approach, particularly having regard to the scale of growth Croydon is required to accommodate over the Core Strategy Plan period. page63/para1/bullet3 With reference to Options for Change in Section The comment is noted. Ms Susan 5 (page 63) it should be noted that pumping, as Sheahan a solution to reducing flood risk, should be Environment Agency avoided wherever possible due to CO2 impact. Observation Noted – No Action Page 64/questioncc2 Extra option The next consultation report of Mr M Jennings the Core Strategy will Association of Croydon “Provision of more trees in streets and open recognise the vital role of Conservation Societies areas coupled with areas for cultivation trees for addressing the Observation (gardens/allotments) in large developments.” causes and affects of climate Noted – Propose Changes change. page63/para2/bullet6 In addition, we also note that the policy requires The comment is noted. This Mr Ed Kemsley new commercial development to achieve document and subsequent Peacock & Smith Limited BREEAM standard ‘Excellent’. The Council has versions of the Core Strategy Object not consulted with all sectors of industry to are part of the consultation Noted – No Action confirm whether the BREEAM standard process. The suitability of ‘Excellent’ is achievable or realistic. It is crucial particular standards will be that the Council allows some flexibility to ensure assessed through an that it does not represent an unreasonable appropriate study to develop burden on companies, which could jeopardise policy options and the need investment, regeneration and employment for some flexibility on creation in Croydon. Accordingly, WM. Morrison standards will be assessed as requests that the requirement for all commercial and when detailed policy developments to meet the BREEAM standard comes forward. ‘Excellent’ will be subject to tests of viability and suitability. Page 63/bullet7 Page 63/64 – Climate Change ------Water. - Pages 63 includes references Mr M Jennings Point 7 ‘Options for Change’ - they talk about to achieving Code for Association of Croydon enhance biodiversity and amenity value ------SustainableHomes Level 4 Conservation Societies brownfield sites ----- water abstraction points’ but and BREEAM Excellent, to Observation there is no matching How do we deliver. What achieve these standards Disagree – No Change do they mean by this reference to brownfield developments would have to sties – it could be positive if they were to stay as improve the ecological value they are. They need to consider how they are of brownfield sites. Page 64 going to achieve this. references development in Source Protection Zones in line with Environment Agency guidelines, with the intention of protecting abstraction points and areas susceptible to groundwater pollution. page61/para6/bullet9 We support the safeguarding of groundwater. Support is welcomed. Ms Susan Sheahan Environment Agency Support Noted – No Action page64/questioncc2 We welcome and very much support the The support is welcomed. Ms Susan inclusion of the aspiration to de-culvert and Sheahan restore rivers within the borough. Environment Agency Support Noted – No Action page60/questioncc2 We support the options for change in section 5, The support is welcomed. Ms Susan for instance the requirement for green roofs and Sheahan other sustainable drainage systems. This is in Environment Agency line with the requirements and objectives of the Support Environment Agency. Noted – No Action page64/questioncc1 However, in relation to flood risk it is not only in The comment is noted and will Ms Susan areas at risk of flooding where surface water be developed as the Core Sheahan needs to be controlled by best management Strategy progresses. Environment Agency practices. Most of the water that causes flooding Observation runs from areas that are not themselves at risk. Agree – Propose Changes Surface water storage should not normally be sited in area of floodplain or flood risk (page 61). This is because in a flood the storage feature can be drowned and lose its value. The principle is to prevent too much water getting to the food risk areas. page61/para6/bullet7 We suggest that the aim relating to flooding in The comment is noted and will Ms Susan Section 5, bullet point 7, is therefore amended to be developed as the Core Sheahan the following: Strategy progresses, through Environment Agency a range of policy measures Object • We want to reduce the existing and future risk including open surface water Agree – Propose Changes of flooding from all sources and adapt to climate management systems. change through a risk based approach to development by implementing the best practical sustainable drainage at the masterplanning stage. Within growth corridors we want development to implement strategic initiatives preferably open surface water management systems with their additional amenity, biodiversity and water quality benefits. page60/QuestionTM2 TfL would also welcome further discussions with The comment is noted. Mr Michael Croydon Council as to their plans to implement Mulhern the Legible London way-finding system. Greater London Authority Observation Noted – No Action page61/para1/bullet4 Barratt Homes (Kent) supports in principle the Support is welcomed. aspiration to ensure new development meets the Barratt Homes (kent) highest possible standards of sustainable design Support and construction Noted – No Action Page60/Question TM2 There should be a reference to the application of The comment is noted. The Mr Michael maximum car parking standards, as set out in issue of detailed parking Mulhern policy 3C.23 and Annex 4 of the London Plan. standards will be tackled in Greater London Authority London Plan Policy 3C.23 ‘Parking strategy’ the Development Object states that Development Plan Documents Management DPD. Noted – No Action (DPDs) should: 1) adopt on- and off-street parking policies that encourage access by sustainable means of transport, assist in limiting the use of the car and contribute to minimising road traffic – 2) Adopt the maximum parking standards set out in the annex on parking standards (Annex 4) where appropriate, taking account of local circumstance and allowing for reduced car parking provision in areas of good transport accessibility. The policy also specifies that DPDs should recognise the needs of disabled people and provide adequate parking for them. Provision of electric vehicle charging points in line with the Mayor’s Electric Vehicle Delivery Plan for London and encouraging provision of spaces for car clubs should also be included. page63/para2 The examples (suggested in Comment ID 13) The comment is noted. Ms Susan are perhaps better placed under ‘How do we Sheahan deliver these options?’ Environment Agency Observation Noted – No Action page63/para1/bullet3 We suggest that Bullet 3 is reworded as follows: The comment is noted and at Ms Susan policy wording stage will be Sheahan • Reduce flood risk through a sequential considered. Environment Agency approach to development control decisions and Object adoption of flood risk management measures, Noted – Propose Changes strategic planning of growth and borough wide infrastructure initiatives, and adoption of retrospective measures. Reasons: No need to state the various flooding sources at this level of the strategy or repeat wording in the ‘where do we want to be themes’. The words derive five distinct options from the ‘where do we want to be themes’. page63/para1/bullet3 How do we deliver these options? (page 63) The comment is noted. The Ms Susan policy shall be amended to Sheahan Bullet 3 needs to be expanded to adequately reflect the points made. It is Environment Agency cover the ‘What are the options for change?’ accepted that a combination Object section. Bullets 3 and 4 could possibly be of actions is required to Noted – Propose Changes combined but the tone of the original wording mitigate and adapt to future suggests that this is a more strategic proposal flood risk. rather than one that would be implemented through a site specific proposal. Suggested rewording: Ensure development control decisions are based on a sequential approach to the allocation of development; Require new development to implement design standards to reduce the risk of flooding to and from development; Require new development to adopt appropriate sustainable drainage systems based on a hierarchy to maximise flood reduction, pollution reduction and ecological benefits e.g. green roofs, permeable paving and soft landscaping (including living walls and open natural drainage systems); Establish swales or other similar open source water management systems along river courses or areas of high surface water flooding. Notes on revised wording:

Implementing the sequential approach is the most fundamental way of reducing flood risk and the cornerstone of PPS25; Development that has to be sited in flood risk areas must meet certain standards to justify its less than ideal situation as outlined in PPS25; The appropriateness of SUDS has been generalised to include other constraints but to play down the often over emphasised matter of soil conditions; The concept of a SUDS hierarchy as required by PPS25 and the London Plan (and many other documents has been included); The detailed examples from ‘Where do we want to be?’ are perhaps better placed here. Page 64/bullet2 2nd point on Page 64 – surplus areas of Green Evidence to support the next Mr M Jennings Belt could be near our open spaces – what consultation report on the Association of Croydon effect would say lots of wind turbines have on Core Strategy is being Conservation Societies wildlife in a local area eg birds? We should ask if prepared that will assess the Observation they have existing polices in place to add a potential of large-scale Noted – No Action presumption that the effect on local wildlife will renewables in the borough as be considered when such Green Belt or other well local requirements for sites impinge on areas of open space used by sustainable buildings. people and wildlife page71/para1/bullet2 Allow conventional underused spaces (such as The comment is noted. We Miss Wendy river and railway banks; schools, hospitals, acknowledge that some land Wong Chang social housing grounds; publicly owned will not be appropriate for Berkeley Homes (south brownfield sites; Council-owned road verges and urban agriculture. However, in East London) Ltd other underused areas of green) to be used for some instances urban Observation urban agriculture uses and to protect these agriculture can improve the Noted – No Action spaces from development- We are in support of biodiversity value of sites. The the Council’s aspiration to increase urban next Core Strategy agriculture plots within the Borough. However, consultation report will we would urge the Council, when formulating consider the role of urban future policies, to take into consideration agriculture as part of a wider whether the introduction of such use would be green grid policy. the most efficient and effective use of valuable urban land that could otherwise be used to accommodate additional housing developments to meet the Borough’s rising housing needs. page63/para2/bullet3 Require new developments to improve on-site The comment is noted. The Miss Wendy drainage by designing in sustainable drainage viability of development will be Wong Chang systems (appropriate for local soil and geology considered when preparing Berkeley Homes (south condition), green roofs, permeable paving and the Core Strategy. However, East London) Ltd soft landscaping (including living walls and open mitigation of flood risk in Observation natural drainage systems)- We would urge the Croydon is an important Noted – No Action Council to introduce some flexibility in the element of the Core Strategy. wording of future policies relating to on-site drainage especially taking into consideration site constraints and scheme viability. page64/questioncc3 Groundwater :Question CC3 (page 64) The support is welcomed. Ms Susan Sheahan We support the identification of brownfield sites Environment Agency as a potential risk to groundwater quality Support Noted – No Action page63/para2/bullet3 We would not recommend that SUDS be This is disagreed. The Ms Susan required on all developments (page 63). Instead, wording says `whwere it is Sheahan developers should be required to consider them appropriate for local soil and Environment Agency as a first option but use alternatives where they geology conditions.` Object can be justified. Disagree – No Change page64/questioncc1 We want development both strategically and The comment is noted. Ms Susan within sites to be located in the lowest flood risk Sheahan areas giving consideration to the development Environment Agency type. Observation Noted – No Action Page64/para1/Questio Yes – Ensure appropriate levels of consultation The procedures for Mr Robert n CC3 with landowners stakeholders to ensure the masterplans, the OAPF and Posselt materplans, OAPF and subsequent AAP are subsequent DPDs (not AAP), Martin Robeson Planning deliverable. will ensure the opportunity for Practice consultation, including with Observation landowners and stakeholders. ANAti page 59 para 1 bullets Barratt Homes (Kent) acknowledges that East The comment is noted. The 3 & 4 and West Croydon stations need to cope detailed means by which Barratt Homes (kent) effectively with the growth in passenger develeopment is brought Support numbers that will result from housing and forard around Croydon's major Noted – No Action employment growth in the Metropolitan Centre. stations will be subject to It also notes that West Croydon station is masterplanning and detailed presently ill-equipped to handle the increased negotiation with landwoners. passenger traffic from the East London line extension when it opens. Our client therefore recognises and supports aspirations to work with strategic transport partners and, more widely, to redevelop West Croydon. However, it would also note that the area comprises a complex set of land ownerships and its regeneration should not be delayed on those sites which are capable of early delivery. page63/para2 However, it would caution against an overly The Council will consider onerous approach which risks impeding various different policy options Barratt Homes (kent) development’s viability and deliverability. It is and their feasibility through Observation therefore imperative that the Council adopts a the appropriate evidence Noted – No Action sufficiently flexible approach to issues such as base. The Council is aware of district-wide energy networks, local electricity the requirements in Policy production, and flood risk mitigation measures. Planning Statement 1 to Any requirements, including percentages for ensure that policies are CO2 emissions and use of renewable energy evidence based and viable technologies as well as in respect of BREEAM and is keen to ensure that and the Code for Sustainable Homes, should be requirements are not too similarly flexible and allow for other factors such onerous. as technological advances and viability considerations. page 59 para 1 bullets Barratt Homes (Kent) acknowledges that East The support is welcome. The 3 & 4 and West Croydon stations need to cope phasing of development in Barratt Homes (kent) effectively with the growth in passenger detail is not an LDF matter. Support numbers that will result from housing and Noted – No Action employment growth in the Metropolitan Centre. It also notes that West Croydon station is presently ill-equipped to handle the increased passenger traffic from the East London line extension when it opens. Our client therefore recognises and supports aspirations to work with strategic transport partners and, more widely, to redevelop West Croydon. However, it would also note that the area comprises a complex set of land ownerships and its regeneration should not be delayed on those sites which are capable of early delivery. Page71/Question UA1 Barratt Homes (Kent) does not consider the The comment is noted. The Council’s approach to urban agriculture to be level of detail provided in the Barratt Homes (kent) realistic, and has concerns that it does not next document will be Object conform to national guidance. While we support reviewed. Noted – Propose Changes in principle aspirations to improve food security, we do not consider the level of detail to be appropriate to the Core Strategy. As outlined in PPS12 (2008), the Core Strategy should, amongst other things, set an overall vision for development and strategic objectives. Page 71/Para1/Bullet3 Furthermore, our client considers proposals to Disagree. The principle of the convert surplus park land to urban agriculture policy is to make beneficial Barratt Homes (kent) plots in areas of close proximity to urban use of underused land to Object settlements could place unfair demands on new assist urban agriculture. It is Disagree – No Change development in Croydon to provide useable agreed that there does need recreational/public spaces as a compensatory to be a balance between this measure for the loss of park land. Similarly the use and the use of this land intention to allow unconventional underused for building. In all probability it spaces for urban agricultural uses and will only be a minority of land safeguard such sites from development could will be used for urban unnecessarily constrain future development in agriculture. the Borough. We would wish to highlight that national guidance seeks to focus development on urban brownfield locations and Croydon has a challenging growth agenda to deliver. Page71/Para2/Bullet5 Our client also asks that the use of S106 The comment is noted. The contributions and, potentially, the Community Council's evolving policy on Barratt Homes (kent) Infrastructure Levy appropriately considers both s106 and CIL will conform to Object Government legislation and the current National guidance. Noted – No Action economic climate. Our client would wish to avoid unnecessarily stifling development in the Borough by placing overly onerous financial demands on developers. In this respect it is also important that any S106 contributions are reasonable, based on up-to-date assessments of need, supply, and demand, and relate in scale and kind to development proposals. Page60/Question TM2 Perhaps most surprising in this section is the The comment is noted. Mr Andrew fact that, while the inadequacy of orbital routes Walters and links to neighbouring boroughs is Biggin Hill Airport Limited recognised on page 59, there is no option for Observation change to this fact. Our view is that there should Noted – Propose Changes be such an option, to improve the east west road routes for buses, cyclists and cars. This would then be our main response to Questions TM1 and 2. page57/para1 The plan acknowledges that sustainable public Agree. C Mr Michael transport options and an improved pedestrian Mulhern and cycle environment are essential if people Greater London Authority are to switch to more sustainable patterns of Observation movement, which is welcomed. The plan should Agree – Propose Changes include further detail as to how this would be achieved. page63/para2 The draft Core Strategy puts forward potential It is recognised that it is not Mr Ed Kemsley options for dealing with these issues and we always possible for on-site Peacock & Smith Limited note that page 63 includes a section entitled generation. As an alternative, Observation ‘how do we deliver these options?’. This it may be suitable for a Noted – No Action suggests that new major developments may financial contribution to be have to offset 50% of their CO² emission, 20% sought and used to reduce of which is to be met through renewable energy CO2 emissions elsewhere. technologies. It also suggests that BREEAM We will develop our policies 'Excellent' will be sought for major through an appropriate developments.In principle our client supports evidence base to assess the such this approach. However, we would feasibility of policy comment that paragraph 8 of PPS22 states that requirements and will consider local planning authorities may include policies in other policy options, such as Local Development Documents that require a setting a CO2 reduction target percentage of energy requirements to come with no specific renewables from onsite renewable energy generation, requirement however this guidance is subject to the caveat that such policies: should ensure that a requirement to generate on-site renewable energy is only applied to developments where the installation of renewable energy generation equipment is viable given the type of development proposed, its location and design;should not be framed in a way as to place an undue burden on developers, for example, by specifying that all energy to be used in a development should come from on-site renewable generation.Accordingly, Wm. Morrison requests that any such policies on renewable energy includes text to confirm that the this will be subject to the tests of viability and suitability Page63/para1/bullet9 Yes – However the second bullet point under the The London Plan is clear that Mr Robert ‘How do we deliver these options?’ heading is the 20% renewable energy is Posselt ambiguous. It is considered that this statement a target, it follows that this Martin Robeson Planning should be clarified in subsequent documents. It must be the minimum average Practice is assumed that this should read “Require major for new major developments Observation new developments to produce 50% less CO2 to achieve the overall target. Agree – Propose Changes when compared to that which would be The precise policy wording to produced if the development was in compliance achieve this target will be with Part L of Building Regulations. At least 20% developed in the next of energy consumed will be provided on site consultation report of the Core through ‘renewable’ or ‘low carbon’ energy Strategy. sources”. page63/para9 We suggest that the following delivery The comment is noted and will Ms Susan mechanism is included in Section 5: be developed in future Sheahan iterations of the Core Strategy . Environment Agency • Develop river corridor strategies and require Observation development to focus on, and enhance, the Noted – Propose Changes borough’s river and its margins. This should include the establishment of a naturalised buffer strips for biodiversity, amenity and operational access. Notes on revised wording:

The alteration of wording in the first line better embodies both risks from and to development. The mention of ‘climate change’ addresses the title of this section. The reference to ‘risk based approach’ encompasses the sequential approach and reducing flood risk requirements of PPS25. Page60/Question TM2 No specific mention of coaches has been made The comment is noted. The Mr Michael within the Core Strategy. TfL recommends that role of coaches in the Mulhern consideration be given to the needs of coaches transport system of Croydon Greater London Authority and their passengers, particularly in relation to will be assessed in the Object development proposals for hotels, theatres and transport strategy, however at Noted – No Action leisure venues, which would require adequate this stage it is not thought to facilities for coaches to pick up and set down have raised any strategic groups. Major venues are also likely to require issues. coach parking in addition to the pick up and set down facilities. Coach provision for both current and future developments reduces the impact of coaches on local residents and businesses. Page71/What are the Finally, the section on Urban Agriculture (pp70- The comment is noted. We Mr John Ingman options for change 71) is unrealistic. Are the Council seriously acknowledge that some land Park Hill Residents' suggesting that road verges could be used to will not be appropriate for Association grow crops? An urban area like Croydon could urban agriculture. However, in Object not contribute significant food supplies in a way some instances urban Noted – Propose Changes which would make either environmental or agriculture can improve the economical sense – and it is misleading to biodiversity value of sites. The suggest otherwise. next Core Strategy consultation report will consider the role of urban agriculture as part of a wider green grid policy. page59/para2/bullet2 The Core Strategy should set minimum Disgree. Standards for cycle Mr Michael requirements for cycle parking at new provision are a matter for the Mulhern developments in line with TfL’s Cycle Parking Devlopment management Greater London Authority Standards. In addition to this, secure cycle DPD. Observation parking should be provided at key interchanges, Disagree – No Change particularly the East and West Croydon Rail stations. This would encourage cycling as a feeder mode to rail journeys and improve general interchange across all modes at key transport hubs. page60/QuestionTM2 TfL shares the borough’s aspirations to enhance The comment is noted. The Mr Michael public transport, however, measures such as role of traffic management Mulhern implementation of, or extension to, existing measures in tackling strategic Greater London Authority controlled parking zones (CPZ’s) should be transport issues will need to Observation investigated to assist this process as well as be assessed in later versions Agree – Propose Changes consolidation of under-used car parking of the consultation draft Core facilities. Other measures including waiting and Strategy. loading restrictions, one way streets and prohibited left/right turns could also be implemented as a means to reduce unnecessary traffic circulation and on street parking where this causes delays and worsens bus service reliability, particularly in the vicinity of rail stations, Croydon Metropolitan Centre and other town centres in the borough. page63/para9 All developments must take into account A Development Management Ms Susan contamination and water issues in order to DPD will consider appropriate Sheahan minimise adverse impacts on the environment policies. Environment Agency Observation Agree - No Action page64/questioncc1 As part of a wider imperative to improve The comment is noted and will Ms Susan sustainability all development should seek to be developed as the Core Sheahan reduce consumption of, and minimize the use of, Strategy progresses. Environment Agency non-renewable resources. More efficient use of Observation existing resources and renewable resources Agree – Propose Changes should be promoted and encouraged. pages56-75 The aspirations in this section are very positive Support is welcomed. Ms Susan and we commend Croydon for including these Sheahan proactive measures which the Environment Environment Agency Agency strongly promotes. Support Noted – No Action page61/para6/bullet4 We support the aim that buildings meet the Support is welcomed. Ms Susan highest possible standards of sustainable design Sheahan and construction, taking into account flood risk, Environment Agency water use, energy, materials, air quality, health Support and land use and ecology. Noted – No Action Page60/para1 The plan should generally include protection for The comment is noted. Agree Mr Michael all transport related land uses including bus The change to refer to both CIL Mulhern document suggests that higher densities of living and s106 as delivery Greater London Authority and working would support the financial case for mechanisms and to include a Observation transport improvements. The document also reference to 'why the growth Agree – Propose Changes recognises that new development, being locations'. implemented prior to provision of new infrastructure, would increase pressure on the existing facilities, which is accepted. Any major infrastructure improvements would likely take a long time to develop and would be subject to substantial funding availability. It is therefore essential that a section 106 or Community Infrastructure Levy be included to secure improvements along the identified growth corridor. pages 58 & 60 This section of the document could be better Agree greater explicit Mr Andrew formulated by the inclusion of more information reference will be made to sub- Walters on sub-regional and local movement. The map regional movement and Biggin Hill Airport Limited on page 58 shows Croydon’s transport adjoining transport Observation connections with the rest of the London region infrastructure. Agree – Propose Changes and the adjacent South East of England region and should in any event show Biggin Hill Airport. The map on page 60 is confusing and perhaps it would be better to have maps which show the local road, cycle and public transport networks, together with some indications of the flows that comprise this movement. Page72- P.72-73 Generally welcome this section. We The comment is noted. Mr M Jennings 73/questionbdg1 believe that the cemeteries and churchyards Association of Croydon HAP is now not going ahead. Conservation Societies Observation Noted – No Action Page72- Options seem ok as they specifically include The support is welcomed. Mr M Jennings 73/questionbdg1 biodiversity. Association of Croydon Conservation Societies Support Agree - No Action page75/questionw1 In delivering these aims we suggest the addition This is being taken forward Ms Susan of the following option: through the Joint Waste Plan. Sheahan Environment Agency • Support appropriate provision of sites and Observation facilities for recycling and local waste Noted – No Action management and treatment. page64/questioncc1 As an additional aim we would suggest that The comment is noted and will Ms Susan Croydon should include the following: be developed as the Core Sheahan Strategy progresses. Environment Agency • Minimise the use of natural resources. More Observation efficient use of existing resources and Agree – Propose Changes renewable resources should be promoted and encouraged. page71/questionua2 Good ideals although I am a bit concerned about The comment is noted. We Mr M Jennings the plans to convert surplus park land, unused acknowledge that some land Association of Croydon Green Belt/MOL ----- in areas of close proximity will not be appropriate for Conservation Societies to urban settlements and use of unconventional urban agriculture. However, in Object underused spaces etc. This could open up to some instances urban Noted – Propose Changes loss some important natural habitats and agriculture can improve the sanctuary areas for wildlife eg banks, road biodiversity value of sites. The verges, grassland. Can we have a qualifying next Core Strategy option under ‘How do we deliver’ eg consultation report will consider the role of urban “Land proposed for conversion to urban agriculture as part of a wider agriculture plots and for urban agricultural uses green grid policy. will be subject to a full assessment of the way it is used by wildlife and of its biodiversity interest before such conversion is allowed.” page75/questionw1 We suggest that LB Croydon should also The comment is noted. Ms Susan consider the potential for a regional soil Sheahan management facility that can deal with Environment Agency contaminated soil. Management of this on a Observation strategic level can avoid situations where Noted – No Action smaller sites do not have the space to treat soil on-site. Inevitably, contaminated soil often ends up being disposed of to landfill due to these constraints on space. A regional soil washing facility or similar could accept waste from a large area, exchanging it for ‘clean, treated’ soil. Page70- P.70-71 We have some concerns over the The comment is noted. We Mr M Jennings 71/questionua1 change of use of Green Belt or MOL land for acknowledge that some land Association of Croydon urban agriculture. In the past some allotment will not be appropriate for Conservation Societies sites have been lost due to development or lack urban agriculture. However, in Object of use (e.g. Kensington Avenue and South some instances urban Noted – Propose Changes Norwood Lake sites.) Even in recent years there agriculture can improve the has been concern over what to do about biodiversity value of sites. The underused sites (e.g. South Croydon next Core Strategy Allotments). Today the situation is different with consultation report will insufficient allotment plots for the demand. In the consider the role of urban future requirements may change again. It seems agriculture as part of a wider that a flexible approach is required perhaps green grid policy. using underused park land of low ecological value to extend allotments (e.g. Norbury Park and Pampisford Road) or provide new allotments. These could be non-statuary and could be returned to their original use should demand fall. Some of the unconventional spaces suggested seem impractical for reasons of security, safety or health. Brownfield sites and roadside verges may well contain poisons either in the soil suffer from emissions from passing traffic. River banks would also be unsuitable for ecological reasons. Any land considered for change to urban agriculture should be first assessed for it’s ecological importance. page73/para1/bullet2 All new buildings should incorporate biodiversity This level of detail is not Ms Susan by design providing habitat for wildlife within the appropriate for the Core Sheahan built environment such as the erection of bat and Strategy, however, the report Environment Agency bird boxes and bricks. As older buildings are proposes an option requiring Observation replaced with new more streamlined designs the Code for Sustainable Homes Noted – No Action opportunity for nesting or roosting wildlife is lost Level 4. In order to meet Level and as a result certain species are being 4 proposers of development increasingly threatened and reduced. Relatively would have to consider simple and low cost techniques should be acquiring points for matters carried out as standard on all for new such as this. developments. page73/para1/question As above, the potential to enhance development The comment is noted.A Ms Susan bdg2 sites through the planning process should not be Development Management Sheahan overlooked. Sites, particularly larger sites and DPD will consider appropriate Environment Agency those adjacent to areas of open space and river policies. Observation corridors should be seen as of key value. Noted – No Action Planning permission should not be granted on such sites without a proposal to enhance the open spaces, ecological value and access to nature on those sites through river restoration and habitat creation and improvement. Such sites will bring the natural environment to residents on a local level and provide corridors between designated sites which is increases the survivability of wildlife allowing populations to commute and disperse between such sites and throughout the borough. Page67/Question GG2 For the reasons indicated below it is suggested The Council will consider Brian Madge that the release of some Greenfield sites further the arguments for and Brian Madge Ltd (including Greenbelt and MOL) cannot be against Green Belt and MOL Observation discounted at this stage. amendment in the next Noted – No Action consultation report for the Core Strategy. page62/para7/bullet6 Where are we now (page 62) - It should also be The comment is noted. Ms Susan stated that: Sheahan Environment Agency • A Strategic Flood Risk Assessment has been Observation prepared for the borough. This shows areas of Agree – Propose Changes the borough 'currently' at risk of flooding from all sources, and that these coincide with potential areas of growth particularly under the concentrated growth option. Notes on revised wording:

Inclusion of the word ‘currently’ addresses the title of this section and highlights the fact that is a major existing problem in the borough whatever the pattern of growth. This was graphically demonstrated in the July 2007 flood event - reference SFRA level Appendix G. Mention of the concentrated growth option makes the sentence a little more precise. Page61-64 P.61-64 No mention as to the effect of cars and Page 57 recognises the need Mr M Jennings other transport on CO2 emissions. Should be a to encourage more Association of Croydon stronger case for reduction in car use to sustainable modes of Conservation Societies minimise CO2 and congestion. transportation. Observation Disagree – No Change page75/questionw1 • Support the aims of the waste management The comment is noted. Ms Susan hierarchy over disposal. Sheahan Environment Agency Observation Noted – No Action page 57 - 59 In the ‘Transport & Movement’ section, we The support is welcomed. Mr Andrew particularly support the objective of better orbital Walters routes across the borough, both for public Biggin Hill Airport Limited transport and for private car use. While it would Support be nice to have a rail or tram connection, we Agree - No Action recognise the challenges involved in these and therefore recommend a focus on road based public transport, which has the merit of providing improvements for other road users. High quality bus corridors are cost effective and popular and can provide the appropriate form of public transport and can effectively share good quality roads with other road users, including cyclists and private cars. Improving key sections of the east west routes in the borough and across the boundary will be in line with the Outer London Commission’s conclusions to create hub and spoke networks. page74 We support the aims of this section which are in The support is welcomed. Ms Susan line with the aims of the Environment Agency. Sheahan Environment Agency Support Noted – No Action page67/questiongg1 Query – another Delivery option The comment is noted. The Mr M Jennings Infrastructure Delivery Plan Association of Croydon “Support for local Friends Groups to fully realise will identify delivery partners. Conservation Societies the ideas and plans within local Management Observation Plans.” Noted – No Action I am aware that many of our local Groups have their own local plans and I would not like to see the Council come along and arbitrarily dismiss what has been achieved locally page63/para2/bullet2 Require major new developments to offset 50% Evidence to support the next Miss Wendy of their CO2 emissions and at least 20% through consultation report on the Wong Chang renewable energy technologies- Whilst it is Core Strategy is being Berkeley Homes (south recognised that energy use and energy prepared that will assess the East London) Ltd consumption is vital in assisting in climate potential of large-scale Observation change, it is important that a cautious approach renewables in the borough as Noted – No Action is adopted when considering any new renewable well local requirements for energy policy. We would urge the Council to sustainable buildings. The introduce some flexibility in future energy viability of development will be policies especially taking into consideration site considered as part of the Core constraints and scheme viability. Strategy. Section5 The aspirations outlined in this section are The support is welcomed. Ms Susan supported by the Environment Agency. The Sheahan Core Strategy should incorporate policies to deal Environment Agency with the importance of biodiversity and the Support protection of designated and undesignated sites Noted – No Action and the deculverting of rivers. Culverts are particularly prevalent in this borough. page61-63 English Heritage welcomes the borough’s focus The support is welcomed. Ms Claire Craig on district wide networks for the provision of English Heritage renewable energy and the interest expressed in Support linking existing buildings to such networks. Agree - No Action English Heritage is of the view that this represents an optimal solution for historic buildings and conservation areas as it has the potential to avoid the need for contextually challenging fixtures while meeting this critical agenda. page64/questioncc3 Create links between natural habitats, including The comment is noted. The Ms Susan river corridors, and identify habitat networks. comment is noted and will be Sheahan developed as the Core Environment Agency Strategy progresses in a Observation `Green Grid and Rivers Agree – Propose Changes Strategy`. page64/questioncc3 Ensure that development does not result in a net The principle for protecting Ms Susan loss of biodiversity and that opportunities are biodiversity is contained in the Sheahan taken to enhance biodiversity by protecting Core Strategy report and Environment Agency SSSI’s etc and not granting planning permission considered in work on the Observation for development that would have significant Infrastucture Deivery Plan. Noted – No Action adverse effects unless mitigated for. Detailed policies for biodiversity will be contained with the Development Management DPD. page64/questioncc3 Require the inclusion of features beneficial to A Development Management Ms Susan biodiversity within new developments DPD will consider appropriate Sheahan policies. Environment Agency Observation Agree - No Action Page65- Document 2 The Council will consider Mr M Jennings 69/questiongg1-gb1 further the arguments for and Association of Croydon P.65-69 Generally welcome options however we against Green Belt and MOL Conservation Societies would hope that the review of Green Belt and amendment in the next Observation MOL boundaries would not result in a gradual consultation report for the Agree – Propose Changes decrease in the extent of this land. Core Strategy. page64/questioncc3 We would seek to include the following options Agreed. This is referred to on Ms Susan in this section: page 61 and will be Sheahan considered in the next version Environment Agency • Take opportunities to deculvert rivers of the Core Strategy. Observation Agree - No Action page67/questiongg2 I can’t object to the options for change assuming The comment is noted. The Mr M Jennings (as they say) that the Open Space Strategy and Infrastructure Delivery Plan Association of Croydon the BAP will feed into this overall strategy. We will identify delivery partners. Conservation Societies need to be consulted however about the over Observation arching big plans such as cycle/walking routes Noted – No Action and the Green Grid and I would like to see a new option under ‘How to deliver’ and that is

“Liaise and work with local Friends Groups (who already assist in the management of many areas of open space) to develop ideas such as the creation of an ‘Urban Forest’ and to manage local resources for the benefit of all. page64/para9/bullet1 In addition to the options proposed, the The comment is noted and will Ms Susan development of buffer zones through the be considered for a further Sheahan planning process should be included. The iteration. Environment Agency Environment Agency request that development Observation adjacent to a watercourse incorporates a buffer Agree - No Action zone managed as wildlife habitat which is free from access roads, car parking, hardstanding and fencing. This is a valuable way of creating habitat through each and every development so that developers will recognise the importance of ensuring watercourses are given space within development and that buffer zones are utilised as important links in the chain between larger open spaces regardless of their size. page64/para1/bullet1 There are some misconceptions in bullet point 1 The comment is noted. Ms Susan on p.64. We have no requirement for major Sheahan subterranean engineering to be avoided within Environment Agency an Inner Source Protection Zone. Source Observation Protection Zones relate to protection of the Agree – Propose Changes water supply from CONTAMINATION only. Where we will object to the use of deep piling, it would be on the basis of risk of contaminants entering the underlying groundwater, not restriction on groundwater flow. It should also be highlighted that the use of open loop ground source heat pumps can present a pollution risk to groundwater through the introduction of heat. This is becoming an ever-popular source of renewable energy. However, its use within source protection zones must be monitored particularly in the more sensitive SPZ 1’s. page61/para6/bullet8 In addition to deculverting watercourse, existing The next version of the Core Ms Susan open watercourses should be enhanced through Strategy will addres this point. Sheahan lowering and regrading the banks, where Environment Agency possible to reconnect the river with its floodplain Object improving the habitat for invertebrates, fish, Agree – Propose Changes aquatic and marginal plants and wildlife using the river corridor. This also creates valuable open space for people and access to nature which is often absent in urban and heavily developed areas. 6. The Places of Croydon Page/Paragraph/ Representation Recommended response Full Name Objective Organisation Nature of Response Officer Recommendation Upper Norwood The immediate cost Your comment is noted, but Mr Ray Hall The Chamber is made up of mainly small this is not an LDF issue. Crystal Palace and businesses; Norwood Chamber of Commerce Its members have committed approximately Observation £80k in kind in the last year in order to achieve No Action – Not an LDF Is its transformation; Page132/QuestionUN3 49. Regeneration of the Triangle should be The comment is noted. Mr David Walker encouraged with a mix of businesses and Crystal Palace Triangle services, addressing the empty premises but not Planning Group building more premises of the type already Observation provided in abundance. Noted – No Action Upper Norwood It should be noted that the Crystal Palace & Your comment is noted. Mr Ray Hall Nrowood chamber of Commerce has consuolted Crystal Palace and its members with the unanimous conclusion that Norwood Chamber of substantial day time retail needs to be added to Commerce the predominantly night time leisure offer in Observation Crystal Palace, alongside the maximizing of the Noted – No Action leisure potential and transport access of the area: the legacy of the Crystal Palace phenomenon being a key. Page132/QuestionUN3 46. Traders and residents are willing to work The comment is noted. Mr David Walker with you and neighbouring boroughs on a design Crystal Palace Triangle statement setting out our expectations for new Planning Group development and refurbishment of buildings and Observation spaces in the area. Noted – No Action Upper Norwood A Planning Framework This site is not in the London Mr Ray Hall In order to facilitate those three additional Borough of Croydon. Crystal Palace and components, the Crystal Palace & Norwood Norwood Chamber of Chamber of Commerce has concluded the Commerce following: The Observation Parliamentary Act that governs the top site in No Action – Not an LDF Is Crystal Palace Park enables a commercial development and ensures that any new building there would be in the style of the former Crystal Palace - and with a central barrel vault. A Chamber member, New Crystal Palace Ltd, has tabled proposals that meet those requirements; Upper Norwood Strategy Your comment is noted. Mr Ray Hall The central features of the regeneration strategy Crystal Palace and are, therefore: Norwood Chamber of Commerce •Harnessing the globally recognized 'Crystal Observation Palace' brand; Noted – No Action •Accelerating the revival of the business community in Crystal Palace; and •Re-establishing Crystal Palace as a global destination on the world stage.

Components In order to deliver this strategy, we see the need for three fundamental additional components to the existing Crystal Palace offer. They were/are:

- The New Crystal Palace: - In a renewed Crystal Palace Park; with the early - Repositioning of Crystal Palace FC into a multi sport stadium in the Park. Upper Norwood To the enormous credit of amenity groups, Your comment is noted. Mr Ray Hall traders' associations, local and central Crystal Palace and government bodies and now the businesses in Norwood Chamber of the Crystal Palace & Norwood Chamber of Commerce Commerce - a genuine vibrancy has returned to Observation the Crystal Palace area; That vibrancy is self Agree - No Action generated and fragile. It must not be assumed. It could fade. Its potential must, therefore, be harnessed quickly and with clarity of focus. Upper Norwood Its membership has grown from some 5 to 55 Your comment is noted, but Mr Ray Hall businesses in the last year. That growth this is not an LDF issue. Crystal Palace and continues. With a membership fee of £25, Norwood Chamber of however, the Chamber is not in a position to Commerce fund an Executive Officer by itself; Observation No Action – Not an LDF Is Upper Norwood The Croydon Economic Development Company Your comment is noted. Mr Ray Hall recognises the need to strengthen the capability Crystal Palace and of the Chamber and has proposed a grant of Norwood Chamber of £9.5kk in the financial year 2010-2011 and a Commerce further £4.5k in 2011-2012; Observation Noted – No Action Upper norwood The current planning framework, however, This is not in the London Mr Ray Hall contradicts the Parliamentary Act. That Borough of Croydon. Crystal Palace and framework does not permit the relevant planning Norwood Chamber of authority - the Council of the London Borough of Commerce Bromley (LBB) - to consider the possibility of Observation granting a detailed planning approval for a No Action – Not an LDF Is commercially based scheme on the site of the former Crystal Palace in Crystal Palace Park; Page132/QuestionUN3 45. The remaining original shop fronts should The comment is noted. Mr David Walker be more rigorously defended. Crystal Palace Triangle Planning Group Observation Noted – No Action Page132/QuestionUN3 44. Restoration of the cinema could be the The comment is noted. Mr David Walker catalyst for regeneration, providing a focus and Crystal Palace Triangle anchor for a range of smaller enterprises within Planning Group the centre. Observation Noted – No Action Upper Norwood Related to that is the need to recapture the Your comment is noted. Mr Ray Hall strength of footfall and spend that enabled the Crystal Palace and Crystal Palace Triangle town centre to grow Norwood Chamber of significantly when as a neighbour to the 1854 Commerce Crystal Palace; Observation Noted – No Action Upper Norwood The Leader of Bromley Borough Council has Your comment is noted. Mr Ray Hall proposed that £10K - £12K be granted to the Crystal Palace and Chamber probably for a 2 year period; Norwood Chamber of Commerce Observation Noted – No Action Upper norwood When the 1854 Crystal Palace demised by fire Your comment is noted. Mr Ray Hall in 1936, the standing of the town centre declined Crystal Palace and dramatically. Crystal Palace became a problem - Norwood Chamber of which was probably part of the reason why it Commerce was subdivided amongst its 5 host boroughs; Observation Noted – No Action Upper Norwood Cross borough forum Croydon will pursue cross Mr Ray Hall Crystal Palace is part of and relevant to five borough working for Crystal Crystal Palace and boroughs; Palace, but the proposal goes Norwood Chamber of beyond the scope of the Core Commerce Our view is that the briefs for the planning Strategy. Observation framework and the consultancy/delivery partner Noted – No Action need to be set in the context of an urgently needed cross borough round table meeting and a prospective cross borough forum; That first meeting should comprise the leaders and senior officers of the London boroughs of Bromley(LBB), Croydon (LBC), Lambeth (LBL) at minimum - and preferably also Southwark and Lewisham - to establish a clear procedural way forward for all things Crystal Palace, including the Park, the Triangle, the Parade and the Football Club; As a neutral but directly relevant body, the Crystal Palace & Norwood Chamber of Commerce would be willing to invite and host such a meeting if all boroughs were in agreement with that suggestion in principle; The timing seems to be right, as we understand that all five boroughs are preparing Local Development Frameworks for the areas relevant to Crystal Palace - and without a fully coordinated overall approach that is business and regeneration based; Upper Norwood 2) Relating to the above point two potential Croydon will pursue cross Mr Andy Quinn issues in the Bromley part of the triangle will borough working for Crystal have huge implications for future growth of the Palace, but the proposal goes Observation area. The park masterplan & the present issues beyond the scope of the Core Noted – No Action with the cinema campaign and retention of D2 Strategy. leisure use. If both issues can be sorted the gravitational shift of the triangle will shift towards Bromley. Bromley could potentially have two large D2 uses that will attract people to the area so it is paramount that Bromley share the vision of a vibrant town centre. Bromleys current stretch of the Triangle along Church Rd is sorely neglected which effects the whole town centre. The triangle as a whole constitutes the town centre. It is therefore the responsibility of Lambeth, Bromley & Croydon. It is therefore essential they all sign from the same hymn sheet and recognised the area as a whole needs regenerating and nurturing. Presently it could be argued that boroughs only consider the small parts of the town that is in there respective boroughs. As a result Crystal Palace is often seen as an after thought by the boroughs. The current application to change the use of the old bingo hall must be refused and the site safeguarded as D2 use in any new strategy ( I realise this is a current issue but it has to be considered in relation to Croydon's middle and long term vision for the area). Upper Norwood Again, that application can only be made when Your comment is noted. Mr Ray Hall the planning framework for Crystal Palace Park Crystal Palace and is consistent with its Parliamentary Act. Norwood Chamber of Commerce Observation Noted – No Action Upper Norwood The goal then would be that a master plan - Your comment is noted. Mr Ray Hall prepared based on economic viability Crystal Palace and established by LBB with its consultancy/delivery Norwood Chamber of partner in discussion with its 4 partner Commerce boroughs - can be the subject of an appropriate Observation Detailed Planning Application; Noted – No Action Upper Norwood A Consultancy/Delivery Partner Your comment is noted. Mr Ray Hall We, therefore, suggest that a formal cross Crystal Palace and borough forum is established, focussed on the Norwood Chamber of goal of establishing a shared planning Commerce framework and business plan for all things Observation Crystal Palace; Within the context of that forum, Noted – No Action our advice is that the London Borough of Bromley (LBB) seeks a consultancy/delivery partner that could help define and implement the staged delivery of a master plan for the whole of Crystal Palace Park, including relevant commercial development on its top site. Such a master plan must be conceived in the context of each Crystal Palace component; Upper Norwood Our view is that that the planning framework Your comment is Mr Ray Hall must also enable LBB, as the freeholder of noted.Croydon will pursue Crystal Palace and Crystal Palace Park, to conclude and deliver - cross borough working for Norwood Chamber of for its own sake and that of the broader Crystal Crystal Palace, but the Commerce Palace area - a final and economically viable proposal goes beyond the Observation solution for the Park. Our goal is to help achieve scope of the Core Strategy. Noted – No Action that;

Such a goal can only be achieved in the context of a planning framework adopted by all 5 Crystal Palace boroughs that is consistent on a cross borough basis;

Such a cross borough planning framework will only then work if its contents are central to all the policies of all statutory bodies that have relevance to central South London, such as the LDA, the Mayor of London's office, English heritage, UKTI and central government;

Such a cross borough and multi organizational approach can only be effective if there is a willing private sector capability that can maximize benefit through that framework. That framework, therefore, needs to be intelligent in terms of market need and capability;

Finally, central to that framework must be the expressed desires of the residential and business community in the Crystal Palace area. That is why this document has only become possible because of the high degree of consultation and participation over some 13 years within many dimensions of the broader community of the Crystal Palace area. Upper Norwood In order to progress forward, it is necessary for Your comment is noted. Mr Ray Hall LBB to establish a planning framework that Crystal Palace and would enable a Detailed Planning Application to Norwood Chamber of be made by New Crystal Palace Ltd for a master Commerce plan that would include all three of those Observation additional components; Noted – No Action Upper Norwood New Crystal Palace Ltd - with its interested Your comment is noted. Mr Ray Hall development partner - is, therefore, not in a Crystal Palace and position to make such a detailed planning Norwood Chamber of application until a consistent planning context is Commerce in place; Observation Noted – No Action Page132/QuestionUN3 51. CPTPG would welcome an Action Area The comment is noted. Mr David Walker Plan plus a Supplementary Planning Document Crystal Palace Triangle for the centre setting out design guidance. Planning Group Observation Noted – No Action Page132/QuestionUN3 52. It is essential that the adjacent boroughs The Council will work closely Mr David Walker and in particular Lambeth and Bromley sign up with adjoining boroughs for Crystal Palace Triangle and agree what Croydon is trying to achieve, the future planning of the Planning Group and joint working should be started without delay. Crystal Palace area. Observation Agree - No Action Page132/QuestionUN3 50. The one-way system has contributed to the The comment is noted. Mr David Walker closure of shops and cafés dependent on Crystal Palace Triangle passing trade that were already under economic Planning Group pressure, and further traffic calming measures Observation are needed. Disagree – No Change Upper Norwood The LDA has, until April 2009, had an option on Your comment is noted. Mr Ray Hall Crystal Palace Park. That has lapsed and is not Crystal Palace and intended to be renewed. The LDA has also Norwood Chamber of received an outline planning approval for their Commerce master plan for the Park - which is the subject of Observation a Public Inquiry: the outcome of which is Noted – No Action expected in July 2010; Upper Norwood As an alternative to the Chamber inviting and Your comment is noted. Mr Ray Hall hosting a cross borough forum, LBB - as the Crystal Palace and freehold owner of the Park - is seen then to be in Norwood Chamber of the best position to request and host such a Commerce meeting. If LBB felt it appropriate, the Chamber Observation would be pleased to be the joint invitee and joint Noted – No Action host. This follows the Leader of Bromley BC's proposal for a cross borough approach some two years or more ago. A venue in Crystal Palace would be helpful; If LBB deemed it inappropriate for the Chamber to participate in such a first meeting, the Chamber would understand accept that view; Upper Norwood The outcome needs to be a cross borough Area Your comment is noted. Mr Ray Hall Action Plan (AAP) and Business Plan (BP) for Crystal Palace and an area that is focussed on Crystal Palace Norwood Chamber of Triangle, Crystal Palace Park and include Commerce Crystal Palace Football Club; Such an AAP Observation would provide the planning framework for the Disagree – No Change Detailed Planning Application for the whole Park that New Crystal Palace Ltd ultimately seeks to be able to submit. The Crystal Palace business community: Such an AAP and BP must be shaped in partnership with the very capable and well networked business community that already exists in Crystal Palace; Upper Norwood As implied above, the Crystal Palace & Norwood Your comment is noted. Mr Ray Hall Chamber of Commerce is now seen as the voice Crystal Palace and for business in the Crystal Palace area: the Norwood Chamber of Chamber having revived significantly in recent Commerce times - and in good part because of the prospect Observation of a New Crystal Palace as part of a total Noted – No Action regeneration approach; Upper Norwood The consolidation and enhancement of the Your comment is noted. Mr Ray Hall Chamber is, therefore, a fundamental building Crystal Palace and block in the strategy we are proposing for Norwood Chamber of regenerating the business community, not only Commerce in the Crystal Palace area, but also radiating Observation across central South London; Noted – No Action Upper Norwood To enable the Chamber's full potential to be Your comment is noted. Mr Ray Hall realized as a channel and catalyst for that Crystal Palace and regeneration, there is the urgent need for the Norwood Chamber of appointment of an employed Executive Officer; Commerce Observation No Action – Not an LDF Is Upper Norwood Local businesses through the Chamber will then Croydon will pursue cross Mr Ray Hall be better able to contribute their local and borough working for Crystal Crystal Palace and broader knowledge into the cross borough round Palace, but the proposal goes Norwood Chamber of table proposed - and from there the beyond the scope of the Core Commerce establishment of a well rooted AAP and BP; Strategy. Observation Noted – No Action Upper Norwood Similarly that planning framework does not Crystal Palace park will be Mr Ray Hall permit consideration of a master plan for the considered in Bromley's Core Crystal Palace and whole Park that would include the above three Strategy. Norwood Chamber of components essential to the regeneration Commerce strategy we are proposing; Observation Noted – No Action Upper Norwood 20. Three roads define the town centre for the The comment is noted. Mr David Walker Upper Norwood hilltop: Westow Street, Westow Crystal Palace Triangle Hill and Church Road. Together they form the Planning Group Crystal Palace Triangle. Croydon has the bulk of Observation the commercial premises, with the north side of Noted – No Action Westow Hill in Lambeth and the east side of Church Road in Bromley. The town centre sits right on the Upper Norwood ridge, the streets falling away steeply on each side of the Triangle. Inside, the Triangle is largely residential. The entire centre is covered by conservation area designations: Croydon’s Upper Norwood Triangle conservation area, Lambeth’s Westow Hill conservation area, and Bromley’s Crystal Palace Park conservation area. Such complete coverage is probably unique among town centres, though English Heritage has declared the Croydon and Lambeth parts to be “at risk” due to inadequate protection by planning enforcement. Upper Norwood Conclusion Your comment is noted. Mr Ray Hall This document has been tabled by the Crystal Crystal Palace and Palace & Norwood Chamber of Commerce as a Norwood Chamber of basis for discussion with the goal of enabling a Commerce context for significant growth and transformation Observation for all things Crystal Palace; Noted – No Action The goal beyond that is the regeneration of central South London and the transformation of its business community for good - and from there the residential and broader community it serves. Upper Norwood 11. No strategy for the Upper Norwood hilltop It may not always be Mr David Walker would be complete without consideration of achievable to secure five Crystal Palace Triangle these three elements: the broader residential borough collaboration. Planning Group area, town centre and park. No strategy for Nevertheless the council will Observation Upper Norwood would be achievable without the seek to work with as many Agree - No Action collaboration of the five borough councils. partners as possible/appropriate. waddon The Core Strategy recognises the need to The comment is noted. Mr Michael improve public realm along Purley Way. Whilst Mulhern there is insufficient width for public realm Greater London Authority improvements, TfL recommends that any future Observation development along this corridor be sensitively Noted – No Action designed to allow for tree planting, landscaping and other environmental improvements/measures. Upper norwood Harnessing the potential of that brand is key to Your comment is noted. Mr Ray Hall the regeneration strategy outlined here: a Crystal Palace and strategy relevant not just to one town centre, but Norwood Chamber of the whole of central South London across all 5 Commerce host boroughs; Observation Noted – No Action waddon The Croydon Road/Purley Way and Fiveways The comment is noted. Mr Michael junctions are two key bottleneck junctions along Mulhern Purley Way. TfL would support the identification Greater London Authority of land in these locations that could enable Observation potential future highway improvements to be Noted – No Action taken forward, further discussions on this would be welcomed. Upper Norwood 40. The character of Crystal Palace centre and The comment is noted. Mr David Walker the wider Upper Norwood area is mainly its Crystal Palace Triangle Victorian housing stock and green areas. Planning Group Further erosion of this will inevitably affect Observation quality of life for local residents. Noted – No Action Upper Norwood Summary The support is welcomed. Mr David Walker 37. The Crystal Palace Triangle Planning Crystal Palace Triangle Group welcomes the identification in the Issues Planning Group and Options report of Upper Norwood as a Support distinctive ‘place’. Agree - No Action Upper norwood 36. The Crystal Palace Triangle Planning The comment is noted. Mr David Walker Group are willing to work with the Chief Planners Crystal Palace Triangle of each borough to achieve a coordinated plan Planning Group that draws on the local knowledge of the traders Observation and residents and the technical expertise of the Noted – No Action borough councils. It is ESSENTIAL that the adjacent boroughs and in particular Lambeth and Bromley sign up and agree what Croydon is trying to achieve, and joint working should be started without delay. If it needs a higher hand at the GLA to make this happen then we would actively encourage this. south croydon There is reference on the map (although not in An appropriate change will be Mr Michael the options for change) to the introduction of a made. Mulhern ‘hoppa-bus’. This is not a term generally used Greater London Authority and could be misleading. It would be better to Object change the note to read simply as ‘Consider Agree – Propose Changes improvements to transport links between Croham Road & Upper Selsdon Road’. norbury In line with London Plan policy 3C.23, improved The comment is noted. Mr Michael signage for cyclists using the A23 Norbury Road Mulhern should be further investigated. Greater London Authority Observation No Action – Not an LDF Is Upper Norwood 35. Crystal Palace Triangle is quite unlike The council recognises the Mr David Walker South Norwood or Thornton Heath. It would be a individuaiity of the 16 Places, Crystal Palace Triangle mistake to consider the three town centres as however, this would not be Planning Group part of one strategy. They are different in outlook weakened by the grouping of Observation and character. As you recognise, Crystal Palace certain Places into defined Noted – No Action is not your typical one long high street with Spatial Management Areas. multiple chains but is a distinct area characterised and bounded by the triangle surrounded by residential housing. It is a predominately a mix of local, quirky, independent shops with an artistic nature and predominately high quality bars and restaurants in numerous Victorian buildings in the conservation area. This defines the town. South Norwood and Thornton Heath are on the other hand slightly larger more traditional high streets with numerous high street multiples. There is no artistic or quirky feel or nature to their high streets. Trying to shoehorn the three areas in one policy would be detrimental to each; they have differing needs and priorities. Upper norwood 10. The second major feature of the area is the The council recognises the Mr David Walker Crystal Palace Park. The whole of the Park is in importance of Crystal Palace Crystal Palace Triangle LB Bromley and is Metropolitan Open Land, at Park and will make Planning Group one time under the control of the Greater appropriate references in Observation London Council and now run by the London future iterations of the core Agree – Propose Changes Development Agency, with management of the strategy. National Sports Centre contracted out to Greater London Leisure. This is where LB Lewisham comes into the picture, with residential areas hard against the northern perimeter of the park; Southwark, Lambeth and Croydon reaching the south side. Upper norwood Crystal Palace Triangle The comment is noted. Mr David Walker 19. Of all the issues identified for Upper Crystal Palace Triangle Norwood in the report, the vitality and viability of Planning Group the district centre is probably the most important. Observation Agree - No Action Upper Norwood 9. The Crystal Palace Triangle is in land area a The Council will work closely Mr David Walker tiny but crucial element of Upper Norwood, with adjoining boroughs to Crystal Palace Triangle located at the tip of Croydon, Lambeth and make sure that all sides of the Planning Group Bromley, yet central to the Upper Norwood Triangle are vibrant. Observation hilltop. The London Plan (both current and draft Agree – Propose Changes replacement) recognises it as a district centre, as do Croydon and Lambeth, though Bromley see it as a neighbourhood centre, disregarding the larger part lying outside the borough in Lambeth and Croydon. As well as these three boroughs, many Southwark residents live within easy walking distance and use businesses and facilities in the centre for their daily and longer- term needs. Upper Norwood 21. The hierarchy of town centre designations The comment is noted. Mr David Walker sends a signal to prospective retailers and Crystal Palace Triangle service providers, though they will do their own Planning Group market analysis in deciding where to invest. The Observation London Plan and DRLP designate the area as a Noted – No Action district centre (between major centres like Streatham or Catford and neighbourhood centres that typically serve a localised catchment), a designation accepted by Croydon and Lambeth; for Bromley it is a local neighbourhood centre the main function of which is to provide the day-to-day needs of local residents, especially those who are less mobile. DRLP identifies Upper Norwood/ Crystal Palace district centre as having a medium growth policy direction with moderate levels of demand for retail, leisure or office floorspace and with physical and public transport capacity to accommodate it. Upper Norwood 22. Croydon further distinguish the London The council will reconsider the Mr David Walker Plan district centres into three finer categories: town centre hierarchy in the Crystal Palace Triangle town centres like Thornton Heath and Norbury, next iteration of the core Planning Group district centres like Upper Norwood and South strategy. Observation Norwood and local centres like . Noted – Propose Changes The Leader of Croydon council has suggested that the status of Crystal Palace Triangle might be raised to town centre level within the Croydon hierarchy (though still within the broader London Plan district centre designation). We would like clarification of the benefits such a distinction would confer. Upper Norwood 23. Crystal Palace town centre has benefited in The comment is noted. Mr David Walker the past from council initiatives, including the Crystal Palace Triangle provision of a Town Centre Manager funded Planning Group through Croydon Enterprise and dedicated to Observation this one centre. Some traders have banded No Action – Not an LDF Is together into a lively Chamber of Commerce, though not all traders wish to join and the priorities of residents as consumers are similar but not identical to those of local traders. The Chamber of Commerce cannot be a substitute for a full-time town centre manager, and we look to the restoration of a dedicated town centre manager for Crystal Palace. Upper Norwood 25. Planning decisions in any part of the centre The comment is noted. Mr David Walker have implications for the whole centre, and must Crystal Palace Triangle not be taken in isolation by one borough council Planning Group or another. To take two current and major Observation examples, both of the key opportunities for Noted – No Action cultural regeneration (in planning terms D2 uses) are located in the Bromley part, at or towards the edge of the town centre: the former cinema in Church Road (now under Bromley council’s protection from an alternative use), and the site of Paxton’s glasshouse the original Crystal Palace (awaiting the Inspector’s report on the public inquiry into proposals for the Crystal Palace Park). The future of these sites affects residents and traders in five boroughs and decisions cannot be taken in isolation by one borough. This has been recognised by all five boroughs, who have made an input into decisions on both sites. This recognition needs extending. The five boroughs and the Greater London Authority acting together should take a comprehensive view of the planning needs of the entire town centre. Upper Norwood 34. There is a tremendous sense of community The comment is noted. Mr David Walker and local civic pride both in residents and Crystal Palace Triangle traders. This needs to be nurtured and Planning Group recognised. They are the people in the best Observation position to say how the area should develop and Agree - No Action it is essential their views are taken on board. There is a large artistic feel to the area with many local artists across many fields from painting, sculpting, music, vintage & antiques and fashion. The potential is there for this to become an artistic hub for the wider area, indeed to achieve the vision of the Crystal Palace and Norwood Chamber of Commerce to become the “heart” of south London. Upper Norwood 26. The Core Strategy discusses introducing The comment is noted. Mr David Walker more arts-based uses to boost the centre, and Crystal Palace Triangle recognises the Church Road side of the Triangle Planning Group as being in need of regeneration. The cinema Observation could be the catalyst for this regeneration, Noted – No Action providing a focus and anchor for a range of smaller enterprises within the centre. pg 130 para 1 bullet 2 27. We agree with your vision of Upper The support is welcomed. Mr David Walker Norwood as an attractive place to live and work Crystal Palace Triangle that has retained and must enhance its historic Planning Group character. The architectural heritage is robust Support and extends from late Georgian through Agree - No Action Victorian and Edwardian, with some notable modern examples, but much new development leaving a lot to be desired. Upper Norwood 28. This gives an identity to the area and also, The council consideres the Mr David Walker amongst other factors is one reason the area is nature of enforcement activity Crystal Palace Triangle seen as attractive and full of character. Although in the area to be appropriate. Planning Group the entire Triangle has designated conservation Observation area status, by your own assessment a recent Disagree – No Change report by English Heritage has put the conservation areas in the “at risk” category, and we believe the remaining original shop fronts should be more rigorously defended. However there appears to be a lack of enforcement or cohesive strategy from any of the boroughs to promote or safeguard this local character; some businesses are quite happy to rip out old shop fronts and replace them with inappropriate uPVC or aluminium shop fronts, with what appears to be very light-footed action from the planning authorities to enforce the conservation policies. Upper Norwood 29. The new core strategy must enforce and The comment is noted. Mr David Walker recognise the uniqueness of the local Crystal Palace Triangle architecture and conservation area as one of the Planning Group key factors that makes the area. It should Observation promote appropriate development and Noted – No Action encourage improvements to the conservation area which will draw people to the area. Modern contemporary development should be allowed but not at the expense of heritage buildings. There are post war developments on the Triangle that would be suitable for redevelopment. However any new development must be of the highest quality and complement and add to the local architecture. We are also with your vision of a regenerated district centre with high quality public realm and improved public spaces, pedestrian and cycle links. Traders and residents are therefore willing to work with you and neighbouring boroughs on a design statement setting out our expectations for new development and refurbishment of buildings and spaces in the area. pg 133 map 30. We less whole-heartedly agree with your The comment is noted. Mr David Walker analysis of the spatial issues facing the Crystal Crystal Palace Triangle Palace Triangle; good in parts. There are some Planning Group crime issues, partly due to a lack of coordination Observation between the licensing and planning arms of Noted – No Action Croydon council, and partly due to the lack of cooperation between Croydon and Lambeth. A recent example is Lambeth closing down a night club in Crystal Palace Parade because of noise disturbance and Croydon allowing a late-night licence to the Cambridge public house only a few steps away. The two premises being in separate Police divisions did not help. Another issue is the use of CCTV cameras to target only parking and traffic infringements and not the wider incidence of crime on the streets. The street environment teams of all three boroughs act swiftly and effectively to clean up graffiti after it has been reported, but are not equipped to prevent or apprehend the culprits. pg 131 map 31. We agree that the Triangle is showing signs The comment is noted. Mr David Walker of regeneration with a mix of restaurants, shops, Crystal Palace Triangle supermarket and community facilities, though Planning Group there are still too many empty premises as a Observation result of the economic downturn, and no need Noted – No Action for more premises of the type already provided in abundance. pg 131 map 32. You say the Triangle is congested with The council considers that the Mr David Walker traffic at peak times of the day, but that the one- one-way system has improved Crystal Palace Triangle way system has improved traffic flow. It is our traffic flow overall. Planning Group contention that the one-way system has Object contributed to the closure of shops and cafés Disagree – No Change dependent on passing trade that were already under economic pressure. Further calming measures are needed to reduce the impact of traffic and allow pedestrians to cross safely between the inside and outside of the Triangle. Upper Norwood 18. There has been a number of inappropriate A future iteration of the core Mr David Walker developments in the residential parts of Upper strategy will set out details of Crystal Palace Triangle Norwood, predominately suburban homes the quantum and type of Planning Group demolished with the site and garden housing proposed for Upper Observation redeveloped into flats. Although Croydon’s Norwood. Noted – Propose Changes planning policy is to encourage housing it must be in the right place. The character of Crystal Palace centre and the wider Upper Norwood area is mainly its Victorian housing stock and green areas. Further erosion of this will inevitably affect quality of life for local residents. There are a few sites on the Triangle where larger developments would be appropriate, but the surrounding residential areas should not have over-development. Brownfield redevelopment should be encouraged, but not greenfield or replacement of buildings that make the area special. Upper Norwood It should be noted that the CPNCC has already Your comment is noted. Mr Ray Hall initiated a process that will lead to a discussion Crystal Palace and amongst interested local people on a 'design Norwood Chamber of guide' for all things Crystal Palace focussed onto Commerce the Crystal Palace Triangle. The first meeting is Observation planned for January 2010. The goal is then to Noted – No Action share initial conclusions in a broader discussion with Council officers from Bromley, Croydon and Lambeth commencing in February 2010; Upper Norwood Such investment in the business community Your comment is noted. Mr Ray Hall through the Chamber is a major step forward in Crystal Palace and a process toward the regeneration of the inner Norwood Chamber of parts of all five Crystal Palace boroughs; Commerce Observation Noted – No Action Upper Norwood An equivalent approach to the London boroughs Your comment is noted. Mr Ray Hall of Lambeth, Southwark and Lewisham is Crystal Palace and intended: preparatory discussions having Norwood Chamber of already occurred. Commerce Observation Noted – No Action Upper Norwood v Goals Croydon will pursue cross Mr Ray Hall From all of the above, the minimum goals that borough working for Crystal Crystal Palace and need to be achieved are: Palace, but the proposal goes Norwood Chamber of beyond the scope of the Core Commerce Cross borough agreement to progress forward, Strategy. Observation leading to the funding and the urgent instruction Noted – No Action of an Action Area Plan (AAP) for Crystal Palace Park, Crystal Palace Parade and Crystal Palace Triangle; Upper Norwood That AAP would then provide a context for a Croydon will pursue cross Mr Ray Hall Detailed Planning Application for a master plan borough working for Crystal Crystal Palace and for the whole Park, including the top site, to be Palace, but the proposal goes Norwood Chamber of submitted and considered by LBB as the beyond the scope of the Core Commerce planning authority; That AAP would also provide Strategy. Observation a coordinated context for planning applications Noted – No Action by relevant parties for other parts of Crystal Palace Triangle area; Page132/QuestionUN2 43. The five boroughs and the Greater London The comment is noted. Mr David Walker Authority acting together should take a Crystal Palace Triangle comprehensive view of the planning needs of Planning Group the entire town centre. Observation Agree - No Action Upper Norwood The delivery of a transformed Crystal Palace Your comment is noted. Mr Ray Hall and a coordinated and regenerated central Crystal Palace and South London come then be within reach; Norwood Chamber of Commerce Observation Noted – No Action Upper Norwood In parallel, we see the need for a staged and Your comment is noted. Mr Ray Hall urgent promotions strategy that capitalizes on Crystal Palace and the globally known brand name of 'Crystal Norwood Chamber of Palace'; Commerce Observation Noted – No Action Upper Norwood Such a promotions strategy needs to be local, Your comment is noted. Mr Ray Hall London wide and global in its remit and relevant Crystal Palace and to all five Crystal Palace boroughs and their Norwood Chamber of businesses; Commerce Observation Noted – No Action Upper Norwood The goal would be to capitalize on the now Your comment is noted. Mr Ray Hall imminent opening of the extended East London Crystal Palace and Line and the resultant positioning of Crystal Norwood Chamber of Palace on the tube map; Commerce Observation Noted – No Action Upper Norwood That opening could provide the launch pad for Your comment is noted. Mr Ray Hall the facilitation and delivery of the regeneration Crystal Palace and strategy outlined here. Norwood Chamber of Commerce Observation Noted – No Action Upper Norwood Urgency Croydon will pursue cross Mr Ray Hall We suggest that January 2010 is the right time borough working for Crystal Crystal Palace and to commence the urgently needed borough and Palace, but the proposal goes Norwood Chamber of cross borough preparatory thinking and beyond the scope of the Core Commerce organizing, so that relevant action can be taken Strategy. Observation as soon as the context is clear; Noted – No Action Upper Norwood 41. We would like clarification of the benefits This will become clear as later Mr David Walker that would conferred by raising Crystal Palace iterations of the core strategy Crystal Palace Triangle Triangle to town centre level within the Croydon will set out policies in relation Planning Group hierarchy. to district centres. Observation Noted – Propose Changes Upper Norwood Our understanding, however, is that that master Your comment is noted. Mr Ray Hall plan - even of ratified - cannot be implemented Crystal Palace and by the LDA because of an inability to fund; An Norwood Chamber of alternative way forward is, therefore, urgently Commerce needed: hence the strategy outlined in this Observation document. Noted – No Action Upper Norwood The LDA has expressed a willingness to Your comment is noted. Mr Ray Hall consider an application for funds related to Crystal Palace and specific purposes as well. Such an application is Norwood Chamber of being prepared; Commerce Observation Noted – No Action Upper Norwood Timing Your comment is noted. Mr Ray Hall The timing and sequence for the above strategy Crystal Palace and could be: Norwood Chamber of Commerce January 2010 to July 2010: background cross Observation borough preparatory discussions by borough Noted – No Action councils with representation from the Crystal Palace & Norwood Chamber of Commerce (CPNCC). There needs to be an ealry discussion on whether and local amenity and other groups can participate. The same principle applies to borough base chambers of commerce; November 2010: After preparatory local council explorations, broadening the discussion through the cross borough forum to include amenity groups and chambers of commerce relevant to Crystal Palace. We would suggest that it is hosted in Crystal Palace; September 2010: The first formal forum meeting of leaders of the five Crystal Palace boroughs with representatives from business and amenity bodies as appropriate; February 2011: Expressions of interest invited by LB Bromley through OJEU for the role of consultancy and delivery partner for Crystal Palace Park; February 2011: The brief and mechanism for delivery of an Area Action Plan agreed and instructed by the participating boroughs; December 2012: The Area Action Plan completed;

December 2013: A Detailed Planning Application is submitted for a master plan by the final delivery partner/consortium for the whole of Crystal Palace Park, including the top site; May 2014: A decision is made on the application; May 2015: The first stage of implementation of the master plan by the delivery partner; The above is seen as a realistic time scale that may be improved upon. upper norwood 1) Croydon are heading in the right direction by Your comment is noted. Mr Andy Quinn recognising what makes Crystal Palace unique and seem determined to promote this in the new Observation Core Strategy. However, as you recognise Noted – No Action Crystal Palace is in the unique position of having the town centre spread across 5 boroughs (although it is more of a hindrance than a help). It is therefore ESSENTIAL that the bordering boroughs and in particular Lambeth & Bromley sign up and agree what Croydon is trying to achieve. If it needs a higher hand at the GLA to make this happen then this should be actively encouraged. Upper Norwood 33. The Croydon Core Strategy anticipates a The Council will work closely Mr David Walker masterplan for the district centre and the with adjoining boroughs to Crystal Palace Triangle surrounding area, prepared in partnership with make sure that all sides of the Planning Group adjacent boroughs. CPTPG would welcome an Triangle are vibrant. Observation Action Area Plan plus a Supplementary Planning Noted – No Action Document for the centre setting out design guidance for new developments, shop fronts, streetscape, etc. That way the local community of residents and traders may get some more say as to the type of uses and design that would be acceptable to create the vibrancy and vitality that Crystal Palace so desperately needs. It might also address the emerging issue of the lack of social and community infrastructure to meet the needs of residents and new residential development. Page130/Where we 3) There is a tremendous sense of community Your comment is noted. Mr Andy Quinn are now and local civic pride both in residents and traders. This needs to be nurtured and Observation recognised. They are the people in the best Agree - No Action position to dictate how the area should develop so it is essential there views are taken on board. There is a large artistic feel to the area with many local artists across many fields from painting, sculpting, music, vintage & antiques and fashion. The potential is there for this to become an artistic hub for the wider area. page132/QuestionUN3/ 4) The triangle is designated a conservation The distinctiveness of Places Mr Andy Quinn Upper Norwood area. This gives a sense of character to the area will be identified through a and also,amongst other factors is one reason Residential Character and Observation why the area is seen as attractive and Borough Character Appraisal, Noted – No Action characterful. However there appears to be a lack and this will iinform decision of enforcement or cohesive strategy from any of making on appropriate the local boroughs to promote or safeguard this development for the Place. local character with some businesses quite happy to rip out old shop fronts and replace them with inappropriate UPVC shopfronts with what appears to be very light footed action from the planning authorities to enforce the conservation policies. It is actually designated as a conservation area at risk according to recent reports from English Heritage. The new core strategy must enforce and recognise the uniqueness of the local architecture and conservation area as one of the key factors that makes the area. it should promote appropriate development and encourage improvements to the conservation area which will draw people to the area. Modern contemporary development should be allowed but not at the expense of heritage buildings. There are post war developments on the triangle that would be suitable for development. However any new development must be of the highest quality and compliment and add to the local architecture. Upper Norwood 5) Inappropriate development in the area. As A Residential Character Mr Andy Quinn mentioned above there has been a number of Appraisal, will be developed to inappropriate developments, predominately further l iinform decision Observation suburban homes demolished & the site & making on appropriate Noted – No Action garden redeveloped into flats. Although development for the Place. Croydons UDP policies is to encourage housing it must be in the right place. Crystal Palaces character is mainly its old Victorian housing stock and green areas. Further erosion of this will inevitably effect quality of life for local residents. There are a few sites on the triangle where it would be appropriate for larger developments but the surrounding residential areas should not have over development. Brownfield redevelopment should be encourage but not greenfield or replacement of buildings that make the area special. Upper Norwood We talked briefly how Croydon may put Crystal The distinctiveness of Places Mr Andy Quinn Palace, Upper Norwood & Thorton as part of will be identified through a centralising or spreading development and Borough Character Appraisal, Observation growth in the borough. I feel it would be a and this will inform a Noted – Propose Changes mistake to amalgamate the three town centres development managament as part of one strategy. In relation to Crystal approach that encompasses Palace I feel it would be a huge mistake to align the character whilst policies with that of the other two centres as they recognising common are rather different in outlook and character. As attributes. you recognise Crystal Palace is not your typical one long high st with multiple chains but is a distinct area characterised and bounded by the triangle surrounded by residential housing. It is a predominately a mix of local , quirky, independent shops with an artistic nature and predominately high quality bars & restaurants in numerous Victorian buildings in the conservation area. This defines the town. Upper Norwood & Thorton Heath are on the other hand slightly larger more traditional high st with numerous High st multiples. There is no artistic or quirky feel or nature to the High St. Therefore trying to shoe horn the three areas in one policy would be detrimental to each as they have differing needs & priorities. upper norwood REPORT The comment is noted. Mr David Walker 5. One of the sixteen places considered within Crystal Palace Triangle Croydon is Upper Norwood, an area stretching Planning Group from Crown Point to the Crystal Palace Triangle Observation and down towards South Norwood. This Noted – No Action response concentrates on that part of the issues and options report. Upper Norwood 42. We look to the restoration of a dedicated The comment is noted. Mr David Walker town centre manager for Crystal Palace. Crystal Palace Triangle Planning Group Observation No Action – Not an LDF Is Upper Norwood 6. The Crystal Palace Triangle Planning Group The comment is noted. Mr David Walker welcomes the identification in the Issues and Crystal Palace Triangle Options report of Upper Norwood as a distinctive Planning Group ‘place’, and recognition of the need for a number Observation of London borough councils to collaborate on Noted – No Action planning policy, control and implementation in the area. The need for such collaboration between boroughs has most recently been restated in the draft replacement London Plan [DRLP], published by Mayor Boris Johnson in October. Upper Norwood Elements of the area and the need for The comment is noted. Mr David Walker collaboration Crystal Palace Triangle 7. Upper Norwood sits on the slopes of inner Planning Group and outer, west and east London, overlooking Observation the central London basin to the north with views Agree - No Action across Lambeth and Southwark, Westminster, the City and the office towers of Docklands, and beyond to the Hampstead ridge; and to the south the wide expanse of suburban Bromley and Croydon, with visible traces of the . To the east is Lewisham, Greenwich, Bexley and the towers of the Queen Elizabeth Bridge at the Dartford river crossing. Upper Norwood was known as the “fresh air suburb” and continues to benefit from its elevation long after smoke control orders have removed the smog from the valleys. The area is largely residential, with good schools and attractive open spaces, and with two distinctive structural elements: the Crystal Palace Triangle and Crystal Palace Park. Upper Norwood 8. The bulk of Upper Norwood is in LB The comment is noted. Mr David Walker Croydon, but five London boroughs have a stake Crystal Palace Triangle in this broader area, which we refer to here as Planning Group the Upper Norwood hilltop. In terms of Mayor Observation Johnson’s subregions for cross-borough Agree - No Action collaboration, they are: Croydon and Bromley for the Outer, South London part; Lambeth and Southwark the Inner, Central London part; and Lewisham for Inner, East London. At the boundaries of Inner and Outer London, and South, Central and East London, collaboration is essential not only within but also between these subregions, if Upper Norwood is not to remain at the edge of everyone’s peripheral vision. Upper Norwood We expect that context to be when the decision Your comment is noted. Mr Ray Hall of the Inquiry by the Secretary of State on the Crystal Palace and outline planning approval of the LDA's master Norwood Chamber of plan for the Park, granted by LBB, is known. We Commerce understand this may be in July of 2010; Observation Noted – No Action page86-89/broad green The respondent’s properties lie in the transition The observation is noted. Mr Austin Mackie zone between these two neighbourhood areas Austin Mackie Associates (Broad Green and Waddon). We therefore Ltd comment on both locations as relevant. Observation Noted – No Action Waddon/ Broad Green The Respondents own a number of adjacent The observation is noted. Mr Austin Mackie sites in Grafton Road, on the boundary of the Austin Mackie Associates Waddon / Broad Green neighbourhoods. The Ltd sites lie in a transitional location, where older Observation commercial properties lie adjacent to Noted – No Action established residential properties, through which the sole access to the sites is obtained. When acquired the sites were in a poor state of repair and are typical of low grade secondary commercial locations, with poor access, poor quality buildings and supporting infrastructure. broad green pg 87 Pg 87 Broad Green Spatial map An appropriate change will be David Dilling made. CYPL 1 Selhurst school has closed although the Object building is still there Agree – Propose Changes Shirley/Page117 Opportunity to shape the future of Ashburton - The comment is noted. This is Cllr Avril Slipper Shirley Map in "Croydon Talk" Reference "Long a matter that is too detailed for London Borough of Lane Wood - consider improvements to make the Core Strategy to consider. Croydon more attractive to users." An elderly lady living in Observation Woodmere Avenue has said she remembers the Noted – No Action location from her youth, as Bluebell Wood. She suggested some bluebells could be planted. I thought this could be an excellent follow up to the litter picks. Addiscombe/Page85 The vegetation is overgrown and the lighting is The comment is noted. Cllr Avril Slipper poor. Residents are frightened to use this However improvements to London Borough of access to and from the Arena Tram Stop after alleyways specific is a matter Croydon dark. that is too detailed for the Observation Core Strategy to consider. Noted – No Action Addiscombe/Page85 The alleyway is very narrow, it suffers from The comment is noted. Cllr Avril Slipper graffitti and vandalism. However improvements to London Borough of alleyways is a matter that is Croydon too detailed for the Core Observation Strategy to consider. Noted – No Action Addiscombe/Page85 Following delivery of "Croydon Talk" on the The comment is noted. Cllr Avril Slipper Longheath Estate residents have asked that the However improvements to London Borough of reference to "Improve pedestrian routes along specific alleyways is a matter Croydon tram corridor and to tram stop at Arena" should that is too detailed for the Observation also include improvements to the alleyway Core Strategy to consider. Noted – No Action leading from the tram stop to Longheath Estate. There are regular complaints regarding this location. pg 87 Broad green I noticed a few errors on one of the maps. There Appropriate changes will be David Dilling may be others! made. CYPL Observation Noted – Propose Changes page118/para2/south Re the invitation in "Your Croydon" to comment The observation is noted and Carol Kellas croydon on "the areas in which we live" I would like to will be passed on to the say that Croham Park Avenue/Castlemaine appropriate department. Observation Avenue in S Croydon has fallen prey to fly No Action – Not an LDF Is tipping. First there were the 40 motobike tyres, followed this weekend by the huge pile of builder's rubble which has blocked our back lane. As this lane is unadopted we the residents will have to pay through the nose to get the mess cleared. We think we know where this stuff has come from (due to the fact that a bank letter with a name and address was found amid the mess) but doubtless no-one will want to know despite the fact of fly tipping being an offence. page92/questioncs2 Have read the details contained in the document The support is welcomed. Sally Anne relevant to Coulsdon and can see the positives Jewell in alot of the details contained. Metropolitan Police Support Agree - No Action Waddon/ Broad Green In respect of both Waddon and bordering areas The observation is noted. Mr Austin Mackie of Broad Green, we welcome the recognition Austin Mackie Associates that there are significant areas that suffer from Ltd very poor urban quality, including residential Observation neighbourhoods; much is the effect of pollution, Agree - No Action poor air quality, traffic and general disturbance created by concentrations of industrial activity and the leakage of some inappropriate commercial activities into residential areas. pg 77 The impact of such commercial activities upon There are already width Mr Austin Mackie residential areas needs to be reviewed, restrictions in this area. Any Austin Mackie Associates including introducing measures to restrict / further changes should be Ltd control the movement of traffic to / from pursued through Object commercial areas. Environmental Health No Action – Not an LDF Is legislation. Broad Green We welcome proposals to seek to adopt positive The support is welcomed. Mr Austin Mackie measures to enhance the quality and character Austin Mackie Associates of local residential areas, for example, to the Ltd west of Mitcham Road. Support Agree - No Action page122/para2/south Portland rd is a unique development oportunity Your comment is noted. Mr Ian norwood and woodside in Croydon . being an ecliptic mix of properties Leadbetter styles and uses . Portland rd however fails to work . Take for instance noz 1-47 whilst in an Observation area designated a conservation area , it fails to Noted – No Action meet any of the criteria . There is little to conserve , some of the shops are simply bricked up one is in a dangerous state of repair ,others have been converted into poor quality residential use virtualy none retain any original features . Yet with a little planning it could all be so different . Most of the units are two storey units with a flat roof shops on the front and a rear garden. . By taking back the building line to the two story part and increasing the building foot print developing to three stories with a dormer a 14ft deep frontage to portland rd would be obtained for communial planting with trees creating a unique development and transforming the area . This would also create a large number of new housing stock of high standard . There are also similar parades in this area , it is also worth thinking that with the requirment to reduce our carbon footprint by 80% in just 40 years we need to be very selective of the quality of "old" properties that are retained as these are difficult to insulate to achive this standard and if we fail it will be something move valuable than any building that will be lost. Page125 The approach suggested above, would The Council will consider Mr John Escott recognise that there may be areas of open further the arguments for and Robinson Escott Planning space, whether they be MOL, Green Belt or against Green Belt and MOL Observation other open space, that perform a limited function amendment in the next Noted – Propose Changes in terms of the purposes of MOL, Green Belt and consultation report for the other open space and yet, locationally, are well Core Strategy. related to existing development, have good accessibility credentials and can, appropriately, be considered to be suitable candidates for accommodating growth/development. In my view, this should be incorporated as a proposal of the LDF. The potential spatial options suggest improving the access to the tram stop and creating a new open space at Love Lane. This is easily achievable through a limited residential use on part of the land which would provide the appropriate surveillance to the tram stop and enable improved access. Such a development would also enable the creation of the open space. This can be facilitated by a minor adjustment to the MOL boundary. MOL in this area does not perform a strategic function due to the fractured nature of the land uses, the infrastructure provision and so on. Land to the west of the tram stop could be removed from MOL with the new open space designated as Local Open Space. South Norwood and Where we want to be: The comment is noted. The Mr Paul Scott Woodside/Where we Core Strategy will not set out People for Portland Road want to be • The currently defined district centre is drawn the boundaries of District Object too tightly and should include more of Portland Centres. These will be Road. Portland Road developed as a considered later in the Noted – No Action predominantly retail street as part of South process of preparing the Local Norwood at the same time as the High Street. Development Framework. The We accept that the full length of the retail area of suggestion of managed Portland Road will not recover to its former role. change in Portland Road is We believe that a managed change is required noted. that establishes a string of distinct places along Portland Road forming local community hubs with shops and services that serve the immediate and wider community. Addington pg 80 We support the Councils proposal to regenerate The support is welcomed. Jessica Sparkes the area of New Addington. Tesco Stores Limited Support Agree - No Action Page92/QuestionCS3 5. Parking in the town centre is an issue which The comment is noted. The Mr David needs clear policies & sensitive enforcement Council will consider the Rothberg which enhances the shopping & leisure review of car parking provision Coulsdon West Residents' experience so as to attract the largest numbers in district centres including Association to Coulsdon. Coulsdon in the next Object consultation draft of the Core Noted – No Action Strategy. Page100/QuestionNB3 It really is shutting the stable door after the A Development Management Mr Ken Hume horse but I think that you will find that most DPD will consider this. Norbury Business people vehemently oppose any more A5 or Partnership similar so we need to develop this policy Observation anyway.. Noted – No Action Page100/QuestionNB3 The take aways: As you know there was a very A Development Management Mr Ken Hume emotive response to the issue of too many take DPD will consider this. Norbury Business aways even from the young in the audience. Partnership Observation Noted – No Action Page100/QuestionNB3 The idea of displays in vacant shops needs to The comment is noted. Mr Ken Hume be pursued and rates concessions for this Norbury Business strategy are essential to encourage landlords. Partnership Observation Noted – No Action Page100/QuestionNB3 It is in my view highly unlikely that we will be a The comment is noted. Mr Ken Hume BID area as with most small areas apathy Norbury Business prevails. Therefore we need to find ways of Partnership enforcing minimum local authority standards to Observation ensure that we are not short changed in this way- Noted – No Action better communication channels are needed. Page100/QuestionNB3 Further, the high street seems always filthy and The comment is noted. Mr Ken Hume uninviting, A5 as below is one of the reasons, Norbury Business another is dog fouling and the lack of Partnership enforcement on this, also street cleaning needs Observation more supervision- it is done but nowhere near Noted – No Action well enough. Page100/QuestionNB3 We need to seriously look at loading bays, The comment is noted. Mr Ken Hume parking bays etc. I am aware that this is a TFL Norbury Business issue but it needs to be aired, too often Partnership everyone seems to hide behind the TFL Observation ownership and therefore nothing is done. No Action – Not an LDF Is Broad Green 2 Broad Green schools are actually Broadmead An appropriate change will be David Dilling unless there are plans to change the names. made. CYPL Object Agree – Propose Changes Page92/QuestionCS3 6. Coulsdon has always been lacking in the The comment is noted. The Mr David provision of sports and leisure facilities infrastructure needs Rothberg compared with other broadly similar associated with the Core Coulsdon West Residents' communities throughout outer London. Again, Strategy will be considered by Association proposals about provision have occasionally the Infrastructure Delivery Object surfaced but never progressed. This is critical to Plan which will be developed Noted – No Action ensure Coulsdon remains a community where alongside the Core Strategy. people wish to live. pg 77 These representations seek to encourage the The next iteration of the core Mr Austin Mackie Core Strategy and subsequent LDF documents strategy will outline an Austin Mackie Associates to adopt a positive approach to the regeneration industrial location strategy Ltd of such sites. The sites have already been put setting out the approach to Object forward as potential housing sites at an earlier these areas. Agree – Propose Changes stage of the LDF and it is the intention to promote their regeneration thorough the core strategy and subsequent development site documents Page92/QuestionCS3 4. Clarity about the potential levels of new The comment is noted. A Mr David housing provision and how this can be Strategic Housing Land Rothberg addressed without undermining the current Availability Assessment and a Coulsdon West Residents' residential character and open spaces. Also Residential Character Association reassurance that the all the appropriate Assessment are being Object infrastructure will be financed as part of these prepared. The findings of Noted – No Action developments. these will be considered by and incorporated into the next consultation draft of the Core Strategy. The infrastructure needs associated with the Core Strategy will be considered by the Infrastructure Delivery Plan which will be developed alongside the Core Strategy. Coulsdon/Where are 3. There is almost no mention of the nature of The comment is noted. The Mr David we now health services in Coulsdon. This is particularly infrastructure needs Rothberg critical given that the residents have seen associated with the Core Coulsdon West Residents' numerous plans and proposals over a number of Strategy will be considered by Association years but very limited delivery. In particular the the Infrastructure Delivery Object Woodcote Group practice at 140 Chipstead Plan which will be developed Noted – No Action Valley Road operates from premises that are not alongside the Core Strategy. fit for purpose. Their replacement is an urgent priority Page92/QuestionCS3 2. There is a need for a clearer statement of the The comment is noted. It will Mr David potential for expanded light industrial be taken into consideration Rothberg development in Coulsdon based on its strong when preparing the next Coulsdon West Residents' communication links. consultation draft of the Core Association Strategy. Object Noted – No Action Coulsdon/Page93 1. Only Smitham school is identified as a source The comment is noted. The Mr David for expanded provision at primary level. All next consultation draft of the Rothberg primary schools should be involved in the Core Strategy will consider Coulsdon West Residents' provision to address potential expansion of current capacity and projected Association school rolls. Should there be more on the nature demand for school places for Object and scale of secondary provision? both primary and secondary Noted – Propose Changes schools in the borough by area. coulsdon pgs 90-93 Coulsdon West Residents’ Association wishes to The comment is noted. Mr David flag up a number of issues relating to Coulsdon Rothberg which are identified in part in the Spatial Issues Coulsdon West Residents' and Options section of this draft document Association (pages 90-93). Observation Noted – No Action These are in no particular order:

1. Schools

2. Industry and Employment

3. Health provision

4. Housing

5. Parking and town centre.

6. Leisure facilities

These are all discussed to some extent in the consultation document but would like the following to be acknowledged. page92/para19 Certainly a key factor from having worked on the The comment is noted. Sally Anne ward for a period of time would be improved Jewell transport links and facilities for residents Metropolitan Police (Coulsdon). Observation Noted – No Action Page100/QuestionNB3 The business community is concerned at the The comment is noted. Mr Ken Hume lack of parking and the low exposure this Norbury Business framework appears to give parking- access to Partnership the shops by vehicle is the lifeblood of many Observation businesses and they are finding that the red No Action – Not an LDF Is route is killing business. Norbury/ Upper 8. We want to see balanced developments with The comment is noted. Norbury Norwood a mixture of larger homes, social housing and councillors/reside flats, for owner occupation, private and public nts rent. Norbury councillors/residents Observation Agree - No Action Page123 Thus, in relation specifically to South Norwood The comment is noted. Mr John Escott and Woodside, the area of land around Love Robinson Escott Planning Lane would be one such area for consideration. Observation I note that the isolated tram stop at Love Lane is Noted – No Action identified as an issue in that it has poor natural surveillance, a poor public realm, a poor access and a lack of security. pages 84/85 The section 'Places of Croydon' includes Park Park Hill is not considered Mr John Ingman Hill in Addiscombe (see pp84/85). But residents sufficiently large or of enough Park Hill Residents' of Park Hill do not see themselves as part of strategic significance to be a Association Addiscombe. Addiscombe Road marks a clear place in its own right. Object boundary between Park Hill and Addiscombe Disagree – No Change and it makes no sense to include Park Hill in the planning of this area. Admittedly it is not easy to see where else Park Hill should go - but it probably has more in common with South Croydon than other areas. It would best be regarded as a distinct neighbourhood in itself since it has a number of unifying features such as the age and range of housing and has a clear boundary - the mainline railway to the west, Addiscombe Road to the north, Radcliffe Road and to the east and Coombe Road to the south. page98/para2 Norbury’s current infrastructure is under great A transport strategy will be Mr Stephen pressure as follows: -The A23 is narrow and prepared as part of the Leadbetter almost always congested with traffic, even evidence base for the Core Central Norbury outside peak times. Strategy and to inform the Residents' Association infrastructure required to Observation support future growth. This Noted – No Action will be considered in the Infrastructure Delivery Plan. page98/para2/bullet9 Buses are crowded, with only the 109 travelling Your comment is noted. Mr Stephen the whole route via the A23 from Croydon Leadbetter through to Streatham, and slow through Norbury Central Norbury as bus lanes are limited due to the road being Residents' Association narrow. Observation Noted – No Action page98/para2/bullet9 Train services from Norbury station are regular Your comment is noted. Mr Stephen but not sufficiently frequent and are crowded at Leadbetter peak times from Norbury onwards on London Central Norbury bound services. Residents' Association Observation Noted – No Action Norbury This is a collation of views expressed by The comment is noted. Norbury Norbury residents to to the councillors during councillors/reside canvass conversations etc. culminating in a nts presentation by Simon Bashford to the Norbury Norbury Business Partnership and representatives of the councillors/residents four Norbury Residents’ Associations and Observation churches. Views reflect trends and changes Noted – No Action noted in the built environment as well as consideration of ideas for future trends. addiscombe We represent some 2,600 households in this The comment is noted. Mr John Ingman part of East Croydon, living in the area bounded Park Hill Residents' on the north by Addiscombe Road, to the south Association by Coombe Road, to the west by the main Observation railway line and on the east by Radcliffe Road. Noted – No Action We have over 600 members and produce a regular Newsletter which is distributed to all residents. Page46/para1 7. We are concerned at lack of social housing A later iteration of the core Norbury provision. strategy will set out the councillors/reside Council's social housing nts proposals Norbury councillors/residents Object Agree – Propose Changes page86/para1 (See comment 5)- I feel every 'village' should Infrastructure issues will be Miss Jean have a decent library and other cultural aspects addressed in the IDP. Newman such as an exhibition area and lecture room to add interest and a cafe, and perhaps small Observation cinema area, all of which can be fed from the Noted – No Action main Clocktower complex. South 9. There is scope for more building south of the A modified development Norbury Croydon/purley/kenley/ centre along existing roads, adjacent to existing strategy will be considered for councillors/reside coulsdon build and on brown field sites. a subsequent iteration of the nts Core Strategy. Norbury councillors/residents Observation Agree – Propose Changes Norbury/ Upper 12. There is already a need for a new secondary The comment is noted. The Norbury Norwood school in the north and more primary school need for supporting facilities councillors/reside classes. will be considered in an nts Infrastructure Delivery Plan. Norbury councillors/residents Observation Noted – No Action pg 100 NB3 This is a collation of views expressed by The comment is noted. Norbury Norbury residents to to the councillors during councillors/reside canvass conversations etc. culminating in a nts presentation by Simon Bashford to the Norbury Norbury Business Partnership and representatives of the councillors/residents four Norbury Residents’ Associations and Observation churches. Views reflect trends and changes Noted – No Action noted in the built environment as well as consideration of ideas for future trends. Page27/para2/Questio 11. We have concerns for the overdevelopment The comment is noted. The Norbury nG1 of the north with insufficient supporting facilities. need for supporting facilities councillors/reside will be considered in an nts Infrastructure Delivery Plan. Norbury councillors/residents Observation Noted – No Action Page63/para2/bullet1 5. There are concerns about the ability of drains The comment is noted. The Norbury and other services to cope with domestic need for supporting facilities councillors/reside drainage as well as the reduction of rainwater will be considered in an nts run off, especially as we are now experiencing Infrastructure Delivery Plan. Norbury more frequent heavy rainfall events. councillors/residents Observation Noted – No Action pg 98 para 2 bullet 6 14. We would like to see changes to the Norbury The comment is noted. Norbury Avenue entrance to Norbury Park and lighting councillors/reside along the paths. (also see pg 101 map) nts Norbury councillors/residents Observation No Action – Not an LDF Is Broad Green/West 2. We deplore the suggestion to build largely A modified growth strategy will Norbury Thornton/Norbury along the A23 corridor. North of central Croydon be considered for the next councillors/reside there are already and there have been planning iteration of the Core Strategy. nts approvals for more blocks of flats. Broad Green, Norbury West Thornton and Norbury have enough. councillors/residents Blocks of flats. There may remain scope for Object more south of the centre of Croydon. AP Ch page105/potentialspati I disagree with a concentrated option of A modified development Miss Sevgin aloptions development within the Brighton road proposal strategy will be outlined in the Djemil alone. An option for more even distribution of next iteration of the Core residential development is required in order to Strategy. Object accommodate for the increasing number of Agree – Propose Changes young Purley residents in the area. page134-137/waddon The respondent’s properties lie in the transition The observation is noted. Mr Austin Mackie zone between these two neighbourhood areas Austin Mackie Associates (Broad Green and Waddon). We therefore Ltd comment on both locations as relevant. Observation Noted – No Action page86/para2/bullet1 West Croydon: fruit and vegs shops are great, The comment is noted. Mr Ross Gentry vibrant, colourful environment, plenty of activity LBC – need to ensure that any regeneration does not Observation lose this distinctiveness but that it capitalises on Agree - No Action this and the diversity of the area page92/para2/bullet2 Coulsdon- Development sites and briefs have The council and its partners Mr Ross Gentry been notoriously slow, eg Cane Hill. Need to be are acturely planning for the LBC more proactive and engaging with developers – redevelopment of Cane Hill. Observation hope the Core Strategy can aid this change in Noted – No Action focus. Multiple places Our cables are normally buried to a depth of 1.1 The coment is noted. Leslie Morris metres or more below ground and cable profile National Grid drawings showing further details along the route Observation of the particular cable can be obtained via the Noted – No Action Asset Protection Team (free phone number provided below). Cables installed in cable tunnels, deeper underground, whilst less likely to be affected by surface or shallow works may be affected by activities such as piling. Ground cover above our cables should not be reduced or increased. Multiple places The relevant guidance in relation to working The coment is noted. Leslie Morris safely near to existing underground cables is National Grid contained within the Health and Safety Observation Executive’s (www.hse.gov.uk) Guidance Noted – No Action HS(G)47 “Avoiding Danger From Underground Services” and all relevant site staff should make sure that they are both aware of and understand this guidance. Multiple places The information supplied is given in good faith The coment is noted. Leslie Morris and only as a guide to the location of our National Grid underground cables. The accuracy of this Observation information cannot be guaranteed. The physical Noted – No Action presence of such cables may also be evident from physical protection measures such as ducts or concrete protection tiles. The person(s) responsible for planning, supervising and carrying out work in proximity to our cable(s) shall be liable to us, as cable(s) owner, as well as to any third party who may be affected in any way by any loss or damage resulting from their failure to locate and avoid any damage to such a cable(s). Addiscombe pg 83 We can find only one reference to Park Hill in The comment is noted. Mr John Ingman this document – on page 83 – which simply says Park Hill Residents' that the area can be difficult to access for Association visitors. We do not agree with this comment – Object and were surprised that a study of this kind has Noted – No Action so little to say about our area. page104/questionpy1 Re Purley (where I live): no amount of housing The Council's intention is to Jean Apps will bring a good variety of retail shops back into work with all stakeholders, Purley now that we have Tesco. We are also in including Tesco, to revitalise Object the shadow of the Whitgift Centre in Croydon. Purley. Disagree – No Change That is just a fact of life. Why not help revive the provision of shops in smaller towns and villages instead? This does not rule out the encouragement of other commercial and service enterprises in Purley town centre - those that would not be in competition with Tesco - and the enhancement of amenities (library, sport and recreational facilities etc.), which would also benefit people in outlying areas, given appropriate bus and parking provision. Page100/QuestionNB3 Springing from all of this, my feeling is that we The comment is noted. The Mr Ken Hume need more options so that youth actually have need fr community facilities Norbury Business other attractive options such as sport and music will be considered in an Partnership and we severely lack in this area any facilities at Infrastructure Delivery Plan. Observation all. Noted – No Action page105/potentialspati In addition, emphasis should be directed Housing mix and tenure will Miss Sevgin aloptions towards more houses with gardens rather than be outlined in the next Djemil flats. iteration of the Core Strategy. Observation Noted – No Action page27/questiong3 More affordable housing for younger people in The comment is noted. The Miss Sevgin the community, which should include houses as type of housing will be Djemil well some flats to be dispersed evenly considered in the next version throughout the borough. of the Core Strategy. Observation Noted – Propose Changes waddon 500 Purley Way is located within the Waddon The retail needs of those living sub area. Our view on the proposed spatial in the area will be just one B&Q Properties Ltd strategy for this area is as follows. factor in improving lifestyles. Observation Disagree – No Change Question WD1 Do you agree with where we want to be?

Question WD2 – Do you agree with the options and the way to deliver them

Question WD3 – Have you any other suggestions or more specific proposals that we have missed?

Whilst B&Q Properties Ltd agree that Waddon should aim to be an attractive place in which to live and work, and a thriving residential community, the vision for Waddon should also include the objective of encouraging improvements to the retail function of the retail uses in Purley Way, thereby improving the lifestyles of residents of Croydon and beyond. page122/para1 With respect to South Norwood and Woodside, The Council recognises that N Kwan the 'where we want to be' section should include there are pressures on along Fairview New Homes the opportunities for new housing/ increased the A23 corridor and these will Object development as a result of the existing high be considered in deciding a Noted – No Action public transport accessibility in the area balance of concentrated surrounding Norwood Junction rail station and development in the borough in the planned commitments resulting from the the next version. East London line in 2010. This could include opportunities for the reuse of underutilised industrial land, in particular for housing development, to respond to the acute housing shortage in Croydon. page87/spatialissues Of all the areas in Croydon the London Road It is proposed to carry out Miss Jean section leading up to West croydon with its semi public realm improvements Newman shanty town appearance must be one of the along the London Road which most in need of smartening up into the present are in keeping with the Observation time as it serves as the other main entrance to character of the area. Agree - No Action the town centre and in many ways the most central being as it is virtually on the shopping high street for the town. page109/potential The potential spatial options for Sanderstead The comment is noted. John Phillips spatial options include an option to “Investigate opportunities for Tandridge District Council more bus services with links for walkers on long Observation distance paths”. It is considered that the Council Noted – No Action would wish to be consulted on any opportunities that might come forward from this option which in principle is supported. Multiple places National Grid’s underground cables cross The comment is noted. Leslie Morris through the following neighbourhoods identified National Grid in the Issues and Options document: Observation Noted – No Action Waddon

Croydon

Addlescombe

South Croydon

Selsdon

Sanderstead

Addington

Our underground cables are protected by renewable or permanent agreements with landowners or have been laid in the public highway under our licence. These grant us legal rights that enable us to achieve efficient and reliable operation, maintenance, repair and refurbishment of our electricity transmission network. Hence we require that no permanent structures are built over or under cables or within the zone specified in the agreement, materials or soil are not stacked or stored on top of the cable route or its joint bays and that unrestricted and safe access to any of our cable(s) must be maintained at all times. South Norwood and • ‘Norwood Junction’ gives no indication to The comment is noted. The Mr Paul Scott Woodside/Where we where it is and consequently does nothing to name of Norwood Junction People for Portland Road are now enhance the presence of South Norwood. We station is not a Local Object would like the name changed either to ‘Norwood Development Framework Junction, South Norwood’ or ‘South Norwood’, matter. No Action – Not an LDF Is although we are conscious that ‘Norwood Junction’ is in itself now quite an historic name. Page100/QuestionNB3 The thinking was that the less responsible of The comment is noted. Mr Ken Hume these businesses have no commercial waste Norbury Business collection leading to vermin-this should surely be Partnership built in to their conditions of A5 leasing. Their Observation customers discard the waste without any regard No Action – Not an LDF Is for the local environment further denegrating the local environment. I feel that these businesses should have a responsibilty to clean up the mess that this creates. South Norwood and o South Norwood Lake – a former reservoir for South Norwood Lake is Mr Paul Scott Woodside/Where we the canal that once crossed the area. included on the diagrams on People for Portland Road are now pages 123 and 125 of the Object consultation document. Disagree – No Change South Norwood and o Brickfields Meadow – a former brickworks. Although it is not named Mr Paul Scott Woodside/Where we Historically one of many in the local area. specifically Brickfield Meadow People for Portland Road are now is included on the diagram on Object pages 123 and 125 of the consultation document. Disagree – No Change South Norwood and these include South Norwood Country Park Mr Paul Scott Woodside/Where we o South Norwood Country Park – former sewage is included on the diagrams on People for Portland Road are now works, site of a former medieval moated manor pages 123 and 125 of the Object house and now a nature reserve consultation document. Disagree – No Change South Norwood and No mention is made of our open spaces that are Open spaces and the links to Mr Paul Scott Woodside/Where we a key feature of the area them are included on the People for Portland Road are now diagrams on pages 123 and Object 125 of the consultation document. Disagree – No Change South Norwood and A major problem along Portland Road is empty, We will seek to address the Mr Paul Scott Woodside/Where we poor quality and poorly converted shops. A need for a business innovation People for Portland Road are now strategy is required to manage the change from centre and will consider the re- Object shopping area to other uses and to improve the use of empty shops for appearance of those that have been converted business space. Agree – Propose Changes into eyesore flats. We would like to see a ‘business village’ generated around the proposed business innovation centre, with the centre acting as an incubator with currently empty shops renovated to provide accommodation for businesses as they become more established. South Norwood and • We object to social housing being built in South The comment is noted. The Mr Paul Scott Woodside/Options for Norwood as the planning gain provision for other approach to provision of social People for Portland Road Change more ‘exclusive’ areas, including the town centre. housing will be addressed in a Object forthcoming Development Management DPD. Noted – No Action South Norwood and • Any redevelopment in the area should be Reference to resisting the sub- Mr Paul Scott Woodside/Where we limited. Where allowed it should include division of homes suitable for People for Portland Road are now adequate parking for residents. Smaller houses families will be included in the Object need to be protected from sub-division, with any next consultation draft of the further spread of the bedsits that dominate the Core Strategy. Noted – Propose Changes area to the south of Norwood Junction prevented and, where possible, reversed. South Norwood and • Investment should not be concentrated solely The comment is noted. A Mr Paul Scott Woodside/Options for in the district centre. The areas of local shopping modified development People for Portland Road Change parades, including those proposed along strategy will be outlined in the Object Portland Road, and , need next consultation of the Core outside investment too. Strategy. The Council will Noted – No Action investigate a tariff based approach to pool contributions to support necessary investments. South Norwood and • Norwood Junction is a two sided station but the The comment is noted. Whilst Mr Paul Scott Woodside/Where we southern side is extremely run down and of poor the Core Strategy will People for Portland Road are now quality despite serving approximately as many reference the broad principle Observation travellers as the north side. The current of improving connectivity, this underpass access to the platforms is a very poor is a matter that is too detailed Noted – No Action quality environment and offers limited for the Core Strategy to accessibility to mobility-impaired people, with consider. wheelchair access limited to platform 1. South Norwood and • The limited crossing points across the London The comment is noted. This is Mr Paul Scott Woodside/Where we to Croydon railway include a poor quality and a matter that is too detailed for People for Portland Road are now intimidating pedestrian tunnel under the station. the Core Strategy to consider. Object Improved north-south access is required. Noted – No Action South Norwood and The conservation area should be extended The designation of Mr Paul Scott Woodside/Where we further down Portland Road to fully protect the conservation areas is People for Portland Road are now extent of the largely original Victorian shopping considered separately from Object street. The current boundary is illogical and puts the Local Development at risk much of our heritage. Framework process. This Noted – No Action comment will be taken into account in the consideration of future changes to the South Norwood Conservation Area. South Norwood and • The infilling has continued to the present day The comment is noted. Mr Paul Scott Woodside/Where we with housing development of former brickworks People for Portland Road are now and small industrial sites that were interspersed Observation throughout the local area. Noted – No Action South Norwood and Where we are now: The comment is noted. Mr Paul Scott Woodside/Where we People for Portland Road are now • There is no mention of Woodside village in the Object description of the area. It could be described as an historic village settlement with some buildings Noted – No Action dating back to the 17th century, focused around a large village green, that was swallowed by predominantly Victorian and Edwardian development into the urban sprawl of South London and Croydon. South Norwood and o Improved public transport integration into and Future transport strategy will Mr Paul Scott Woodside/Where we out of the area, with better links between be informed by the People for Portland Road want to be different modes of transport, cleaner, safer and forthcoming Borough-wide Object more reliable travel and the creation of transport strategy. convenient links to Mayday Hospital and Crystal Noted – No Action Palace. South Norwood and • has a massive impact on the The comment is noted. The Mr Paul Scott Woodside/Where we whole of the South Norwood area and yet there Council will seek to work with People for Portland Road are now is very little compensation in return from Crystal all partners to implement the Observation Palace Football Club. They should offer more Core Strategy. back to the community and become more No Action – Not an LDF Is integrated with it. South Norwood and The railway land to either side of the east of Not a matter for the LDF. Mr Paul Scott Woodside/How do we Norwood Junction is not maintained and is People for Portland Road deliver these options usually in an appalling state with large build ups Observation of rubbish and the resultant rats. A proactive management regime needs to be put in place to No Action – Not an LDF Is manage these railway embankments. Upper Norwood Draft strategy document by the Crystal Palace & Your comment is noted. Mr Ray Hall Norwood Chamber of Commerce Crystal Palace and Norwood Chamber of Context Commerce This document sets out a strategy that has been Observation adopted by the Crystal Palace & Norwood Noted – No Action Chamber of Commerce as a framework for its activities on behalf of the business community in the Crystal Palace and Norwood area;

That area occupies 5 central South London boroughs: Croydon, Lambeth, Southwark, Lewisham and Bromley. That designation occurred in the post WW2 era. It has meant that none of the 5 boroughs has the ability to direct and shape a future of all things Crystal Palace: an inability that has had a detrimental effect on the viability of Crystal Palace town centre; Upper Norwood That goal has now been fully endorsed by the Your comment is noted. Mr Ray Hall Chamber with the enthusiastic personal support Crystal Palace and of your own Council Leader, Mike Fisher, as well Norwood Chamber of as the Leader of Bromley Council, Stephen Carr. Commerce Observation Noted – No Action Upper Norwood My main observation is that it does not Your comment is noted and it Mr Ray Hall recognize the biggest place and legacy based is referred to as Crystal Crystal Palace and brand name in central South London - and that Palace on page 133 of the Norwood Chamber of is "Crystal Palace". My view has been for many document. The Place will be Commerce years that that name must be capitalised on in identified as Crystal Palace, in Observation order to raise the profile of our South London subsequent iterations. Agree – Propose Changes community onto the world stage: with a substantial regeneration effect following. South Norwood and • The great potential of many of our open spaces The comment is noted. Mr Paul Scott Woodside/How do we is currently unrealised. This is especially the People for Portland Road deliver these options case with Brickfields Meadows and to a certain Observation extent the SNCP. Greater community use ought also be made of Woodside Green. Noted – No Action South Norwood and Love Lane Green should be taken back into The need for any additional Mr Paul Scott Woodside/How do we public ownership and reinstated as a local park. open space in this area will be People for Portland Road deliver these options This would also increase the size of the SNCP considered in strategy for Observation and Beckenham Cemetery green open area. green infrastructure. Noted – No Action South Norwood and The schools are not currently available as The comment is noted. Mr Paul Scott Woodside/How do we assets for the whole community. This needs to People for Portland Road deliver these options start rather than continue! Observation Noted – No Action South Norwood and Options for Change The Local Housing Market Mr Paul Scott Woodside/Options for Assessment and a Strategic People for Portland Road Change • We believe that South Norwood should remain Housing Land Availability Object a mixed community but with a family focus to Assessment will inform the allow best use to be made of our open spaces development of future policy in Noted – No Action and good transport links. Any future the Core Strategy on family development should be very limited and housing. predominantly good quality family houses. Too many flats are being built. South Norwood and Public realm improvements are required across The comment is noted. The Mr Paul Scott Woodside/How do we the area. These should take the opportunity to improvement of the public People for Portland Road deliver these options celebrate the rich history of the area and give realm in Croydon is an Observation the community opportunities to interact and important element of the Core develop. Strategy. A Residential Noted – No Action Character Appraisal and a Borough Character Appraisal are being developed to ensure that local distinctiveness and the unique characteristics of South Norwood and Woodside (and the other Places of of Croydon) are considered for future development proposals over the plan period. South Norwood and o Clean local generation of power for the local Evidence to support the next Mr Paul Scott Woodside/Where we community consultation report on the People for Portland Road want to be Core Strategy is being Object prepared that will assess the potential of renewables in the Noted – Propose Changes borough as well local requirements for sustainable buildings. South Norwood and The facilities in the area are typically poorly The comment is noted. The Mr Paul Scott Woodside/How do we signposted. This is especially true of the parks need for green links in the People for Portland Road deliver these options and open spaces. We would like to see ‘green borough will be considered as Observation links’ developed between the various open part of the green infrastructure spaces and a projection of the greenery of the portion of the Infrastructure Noted – No Action open spaces out into the surrounding streets. An Delivery Plan which will be example of this would be tree-lined streets prepared alongside the Core leading from the South Norwood Country Park to Strategy. Portland Road, with SNCP entrance markers (possibly pairs of trees) on Portland Road – ‘Bring The Country Park to Portland Road’. South Norwood and How do we deliver these options: Provision of community Mr Paul Scott Woodside/How do we facilities will be considered in People for Portland Road deliver these options • Additional sports and leisure facilities are more detail as part of the Observation needed in the area to replace those lost by the Infrastructure Delivery Plan cancellation of the planned sports centre in and in the next Core Strategy Noted – No Action 2006. Greater use should be made of the library consultation report. to create a community hub. South Norwood and • Many of the side streets off Portland Road The comment is noted. The Mr Paul Scott Woodside/Options for were originally lined with trees, but many have need for greening the borough People for Portland Road Change subsequently been lost to the detriment of the will be considered as part of Observation character of the area. The area needs to be re- the green infrastructure greened by the replacement of the trees, with portion of the Infrastructure Noted – No Action new ones where possible. Delivery Plan which will be prepared alongside the Core Strategy. South Norwood and • Regeneration is required to support Woodside The comment is noted. A Mr Paul Scott Woodside/Options for Green and the ‘places along Portland Road’ as modified development People for Portland Road Change well as along Whitehorse Lane. strategy will be outlined in the Observation next consultation draft of the Core Strategy. The Council Noted – Propose Changes will investigate a tariff based approach to pool contributions to support necessary investments. South Norwood and • Improvements to the public realm need to The comment is noted. The Mr Paul Scott Woodside/Options for extend beyond the designated town centre. In improvement of the public People for Portland Road Change particular we hope to see each of the ‘places realm in Croydon is an Observation along Portland Road’ defined by appropriate important element of the Core hard landscaping and highways improvements Strategy. Noted – No Action to make them distinctive and more pedestrian- focused. South Norwood and • We accept that some areas of the historic A Residential Character Mr Paul Scott Woodside/Options for centre of South Norwood need to be Appraisal and a Borough People for Portland Road Change redeveloped due to the very poor state of the Character Appraisal are being Observation existing buildings. This includes most of the first developed to ensure that local approx 25 properties on the eastern side of the distinctiveness and the unique Noted – No Action top end (north) of Portland Road. High quality characteristics of South modern development is required. We are Norwood and Woodside (and opposed to bland ‘could be anywhere’ and the other Places of Croydon) pastiche designs. are considered for future development proposals over the plan period. South Norwood and Target empty and poorly converted shops along The comment is noted. Mr Paul Scott Woodside/How do we all major roads for visual enhancement to lift the Meanwhile uses for vacant People for Portland Road deliver these options general feel and sense of pride in the area. properties and land shall be Observation investigated for inclusion within the next consultation Noted – Propose Changes draft of the Core Strategy. page106/SANDERSTE Riddlesdown Residents Association have on The Council will consider Mr Brian AD many occasion since 1954 been forced to further the arguments for and Longman defend the green belt land of Mitchley Woods against Green Belt and MOL Riddlesdown Conservation and the surrounding farm land from speculative amendment in the next Committee/Sanderstead, developers. consultation report for the Croham, Selsdon & Core Strategy. Ballards Neighbourhood Partnership Observation Noted – Propose Changes Page84/QuestionAC2 Clearly , the Council need to look at this issues Your comment will be Mr Paul Gardner now and certainly consider them in the context forwarded to the relevant of the wider proposals. We think that: Department Object No Action – Not an LDF Is • There needs to be more frequent litter collections. Page85 In addition, the proposals refer to a “new link via Your comment is noted, but Mr Paul Gardner Lloyd Park to Saffron Way and Upper Shirley this is too detailed for the Core Road”. We are not clear what is intended. We Strategy. The access Observation assume that this refers to pedestrian access and suggested on page 85 is Noted – No Action not a vehicular link – is this correct? Any proposed for pedestrians and connecting vehicular access would clearly end its feasibility will be up being used as a shortcut by drivers rather considered as part of the than for access to Lloyd Park. Green Infrastructure Strategy Page83/Where we are Litter is an increasing problem not just on Your comment will be Mr Paul Gardner now Mapledale Avenue but inside Lloyd Park. There forwarded to the relevant is one waste bin inside Lloyd Park close to the Department Observation top of Mapledale Avenue. However, this is rarely No Action – Not an LDF Is emptied and therefore usually overflowing with rubbish. Similarly, some people drop household waste inside the park. Page83/Where we are In the evenings, some people use the top of Your comment will be Mr Paul Gardner now Mapledale Avenue as a place to eat take away forwarded to the relevant food. This would not itself be a particular Department Observation problem except that most of them simply throw No Action – Not an LDF Is their litter on the ground. We are also aware that some people have used this area to use and trade drugs. We understand that the police are aware of this issue. A related and more general issue is that at times groups of young people congregate in areas of the park at night – recently one such group lit a bonfire and the Fire Brigade had to attend. While there is a community police officer, the relevant office is only available during working hours. Page83/Where we are For the same reasons, we experience a regular Your comment will be Mr Paul Gardner now stream of cars that using our drive to turn forwarded to the relevant around which can be both inconvenient and as Department. Observation presents a potential hazard. No Action – Not an LDF Is Page83/Where we are Understandably, a significant number of people Your comment will be Mr Paul Gardner now drive to Lloyd Park. However, there is very forwarded to the relevant limited parking and at times the top of Mapledale Department Observation Avenue can get quite congested with parked No Action – Not an LDF Is cars. This problem is exacerbated by the fact that there is a tarmac area outside the entrance to Lloyd Park which is overused for parking. Although there are some additional parking bays on Grimwade Avenue, many drivers do not use them and instead clog the top of Mapledale Avenue. Although the Council introduced double yellow lines a few years ago, these are not observed by some drivers and we have never seen any enforcement of the current parking restrictions. South Norwood and o True community partnerships that work with The Council will work in Mr Paul Scott Woodside/Where we organisations such as the Council to deliver partnership with the Local People for Portland Road want to be positive management and evolution of our area Strategic Partnership and Object to meet changing needs other groups representing the community to formulate and Noted – No Action deliver the spatial strategy for the borough. Page136/QuestionWD3 Existing developments along Purley Way tend to The comment is noted. Mr Michael be car based, out of town retail parks. There are Mulhern very limited pedestrian linkages between the Greater London Authority various sites but there is potential to ensure that Observation future developments are well linked through new Noted – No Action public realm, walking and cycling links, which should be further recognised. page116/para2/bullet5 Shirley- The current charging policy for the use The observation is noted and Mrs Lesley of school facilities by community groups is at will be passed on to the Godden odds with the strategic aim of encouraging the Education Service. use of local schools and other facilities for other Observation community uses. Noted – Propose Changes Page108/QuestionSA3 Sanderstead has two of Croydon's largest The comment is noted. A Mr Brian schools and a comprehensive review of borough wide transport Longman transport both public and private is well over strategy is currently being Riddlesdown Conservation due. The association is also concerned at the prepared. Committee/Sanderstead, gradual change to the residential character of Croham, Selsdon & the area with the demolition of housing stock for Ballards Neighbourhood the development of flats. Partnership Observation Noted – Propose Changes page77 The process of identifying sixteen places across The support is welcomed. Mr Michael the borough (including the Croydon Metropolitan Mulhern Town Centre) and in turn presenting distinct Greater London Authority objectives for each is supported. Support Agree - No Action Page104/QuestionPY3 The long awaited Coulsdon bypass has Your comment is noted. Peter Williams transformed traffic flow through the town and I am delighted to see such effort and resources Object being allocated to Coulsdon Centre to make it a Noted – No Action better living and shopping experience. This is exactly what Purley needs BEFORE contemplating knocking down existing housing stock in favour of major flat developments. In the short term the bypass has simply accelerated the speed at which ex M25 traffic reaches the Purley bottleneck. The optimum traffic solution was missed 30 years ago when the M23 was stopped at Hooley instead of being allowed to extend all the way in to the South Circular. Ever since that decision the suburbs were destined to excessive traffic congestion which we are still struggling to come to terms with. Page104/QuestionPY3 However having been a resident of Purley for 27 Your comment is noted. Peter Williams years I do believe before any decisions are made on new housing, offices, facilities etc the Object road system in the centre of Purley must be Noted – No Action sorted out. Over my period of residence in Purley I have watched the centre of the town die , due partly to Tesco’s with the final nail of the Red Routes, I have seen London transport proposals , TFL proposals, more than I can remember, but all have not got off the ground, apart from the one tied to the original Tesco’s development. Page100/QuestionNB3 It should also not be unusual for people to feel The comment is noted. Mr Ken Hume that the area is safe, clean and convenient, only Norbury Business then will you start to get the more inspirational Partnership businesses that will see Norbury as a viable Observation business destination. Noted – No Action Upper Norwood Significantly Crystal Palace town centre has Your comment is noted. Mr Ray Hall been defined as a district centre within Croydon Crystal Palace and borough because of the limited transport links Norwood Chamber of within that borough. When seen in the context of Commerce the transport access that exists in the other 4 Observation relevant boroughs, Crystal Palace is a town Noted – No Action centre; When also seen in the context of the scale of use of the 'Crystal Palace' name - town centre, parade, park, football club, sports centre, museum and 3 local street names - that name has a substantial South London wide presence; When then seen in the context of the legacy of the name Crystal Palace - and its direct association with the temporary Great Exhibition of Commerce and Industry in Hyde Park in 1851 and then the permanent Crystal Palace that was the climax of not only Crystal Palace Park but also much of South London - then the name becomes not a local phenomenon but a global brand; Page118/Where we We have some comments concerning the Your comment is noted, but Mr Paul Gardner are now proposals that relate to Lloyd Park. The this is too detailed for the Core proposals refer to “improving way finding and Strategy. The Green Observation links through the Whitgift estate to open space”. Infrastructure Strategy will Noted – No Action Clearly Lloyd Park is a great resource and consider links to parks. helping people to use this resource is a positive step. However, we live in the Whitgift estate adjacent to the entrance to Lloyd Park at the top of Mapledale Avenue and are aware of a number of issues relating to the access and use of Lloyd Park. These need addressing now, but if not addressed will become even more problematic if the number of people using the park increases. These issues are as follows: South Norwood and the centrally located childrens' play area should Your comment is noted. Mr Tony Woodside be cleaned and repainted/repaired, and equally Honregold importantly a regular and thorough programme Woodside No. 1 Residents for clearing litter and dumped items from the Association park should be implemented. The Woodside No. Observation 1 Residents Society will be happy to discuss No Action – Not an LDF Is these issues further with Croydon Council. Page100/QuestionNB3 It was also felt that these businesses tend to The comment is noted. The Mr Ken Hume attract large numbers of youths from both in and need fr community facilities Norbury Business outside of the local area leading to local people will be considered in an Partnership feeling intimidated by the number of young Infrastructure Delivery Plan. Observation congregating around them. Noted – No Action South Norwood and • Additional aspiration: South Norwood – A The Core Strategy will seek to Mr Paul Scott Woodside/Where we highly sustainable town. Building upon our ensure that all of the 16 People for Portland Road want to be excellent and improving public transport links places will be planned to be Object and green open spaces we would like to see sustainable neighbourhoods South Norwood develop as an urban eco-town over the next twenty years. Noted – No Action which incorporates: The suggestion that South Norwood develop as an urban eco-town is noted. South Norwood and • Additional Aspiration: We would like South The comment is noted. Mr Paul Scott Woodside/Where we Norwood and the new places along Portland People for Portland Road want to be Road to develop into places like Abbeville Road, Object Clapham, a mini Covent Garden and Crystal Palace. South Norwood and Portland Road used Noted – No Action to have street markets – a tradition we would like to see revived. South Norwood and o ‘Portland Parade’ – stretching from the The comment is noted. This is Mr Paul Scott Woodside/Where we swimming pool to the Gold Coast pub, this area a matter that is too detailed for People for Portland Road want to be will include other public facilities such as the the Core Strategy to consider. Object medical centres as well as a range of shops. The width of the road allows for shoppers’ Noted – No Action parking and scope for landscaping. South Norwood and o ‘Market Parade’ – a distinct parade of shops The comment is noted. This is Mr Paul Scott Woodside/Where we either side of a wide stretch of road allowing a matter that is too detailed for People for Portland Road want to be scope for widened pavements, shoppers’ the Core Strategy to consider. Object parking and landscaping along a traffic calmed highway. Noted – No Action South Norwood and These could be: The comment is noted. Mr Paul Scott Woodside/Where we Locating an enterprise centre People for Portland Road want to be o ‘Portland Square’ – a new gateway to South in Portland Road will be Object Norwood at the junction with Doyle and considered in the next Coventry Roads, where setting the proposed consultation draft of the Core Noted – No Action new business development centre slightly Strategy. However the exact further back than the old Queens Arms pub location is a matter that is too would allow a small public square to be formed. detailed for the Core Strategy to consider. Page84/QuestionAC3 There probably needs to be more parking Your comment will be Mr Paul Gardner spaces on Grimwade Avenue and the gates to forwarded to the relevant Lloyd Park brought forward to include the tarmac Department Object area (or simple collapsible bollards erected to No Action – Not an LDF Is prevent cars from parking on this area. South Norwood and Imagine Croydon Core Strategy Issues and The comment is noted. Mr Paul Scott Woodside Options – Initial Report People for Portland Road People for Portland Road Consultation Observation Response- September 2009 Noted – No Action On 1st September 2009 six members of the steering group of People for Portland Road met to review the South Norwood and Woodside section of The Places of Croydon chapter of the ‘Imagine Croydon Core Strategy Issues and Options – Initial Report’. The following is a summary of their comments on the document. Page84/QuestionAC3 The top entrances to should be locked at dusk Your comment will be Mr Paul Gardner as is the case in many parks in residential areas. forwarded to the relevant Department Object No Action – Not an LDF Is South Norwood and 2) the under-used and dilapidated pond dipping Your comment is noted. Mr Tony Woodside platform should be renovated, or in view of its Honregold condition, removed entirely Woodside No. 1 Residents Association Observation No Action – Not an LDF Is South Norwood and It is suggested that 1) further tree/shrub planting Your comment is noted. Mr Tony Woodside is undertaken particularly around perimeters as Honregold this would soften and green views especially Woodside No. 1 Residents where there is currently grey corrulgated (and Association often grafitti-covered) fencing providing an Observation unwelcoming and potentially intimidating No Action – Not an LDF Is backdrop, south norwood and Although some improvement works were Your comment is noted. Mr Tony woodside undertaken in Brickfield Meadow some years Honregold ago through a joint effort between the council Woodside No. 1 Residents and local voluntary groups/residents with some Association funding being provided by the National Lottery Observation recent years have seen the park and its fabric No Action – Not an LDF Is (eg pond dipping platforms, play areas) become degraded. As Croydon Council aims to have 'good quality open spaces that are well used and regarded' we feel it is important for a new programme of works to be designed and implemented to improve the quality of Brickfield Meadows to make it a more attractive, welcoming, cleaner and greener environment than it is at present. page114/questionsh3 This is a particularly unusual area and, clearly, a The comment is noted. Mrs Doreen prime example of how the one-size-fits-all Hyner approach does not work. Observation Agree - No Action no specific chapter Upon reading the article in "Croydon Talk" No action as not an LDF issue. Mrs Doreen regarding the re-writing of planning policies, I Hyner would like to advise that it is an awful pity that this does not take into account planning for Observation extensions/alterations to existing properties. We No Action – Not an LDF Is live in Badgers Hole, Oaks Road, Shirley and for 15 months now, with no end in sight, have endured the upset that the building/alterations to a Victorian cottage next to us has caused. The whole process has been unbelievable and, not once, were we advised by Croydon Council of any Planning Permission. Our complaint should be well documented and, unfortunately, the only response we received from the LBC was when we sent a letter to Andrew Pelling. page116/questionsh3 As a Shirley resident I read with interest in the The comment is noted. Patricia Godden Summer issue of Croydon talk, the improvements proposed for Shirley. As I walk Observation my dog I have noticed new seats in various No Action – Not an LDF Is locations particularly Shirley Hills and Spring Park Recreation Ground. Would it be possible to provide two or even one seat for Parkfields off Cheston Avenue? Although there are 3 seats, there used to be 5, one at the top of the park near the woods and one just past the gate near the top entrance. Could we have 2 new seats? Myself and other elderly ladies walk our dogs on a regular basis and it would be nice to have somewhere to sit at the top end after walking round the park. South Norwood and o Initiatives to improve the environmental Evidence to support the next Mr Paul Scott Woodside/Where we performance of the existing predominantly consultation report on the People for Portland Road want to be Victorian housing Core Strategy is being Object prepared that will assess the potential of renewables in the Noted – Propose Changes borough as well local requirements for sustainable buildings. South Norwood and Section 6, The Places of Croydon – South Woodside Green is not Mr Paul Scott Woodside Norwood and Woodside considered sufficiently large or People for Portland Road of enough strategic Object Generally: significance to be a Place in Noted – No Action its own right. • Woodside and South Norwood are distinctly different places historically, geographically and physically. They should not be included together as a single place within the strategy. Grouping them together as currently proposed demonstrates a fundamental misunderstanding of this area. Purley Over the years we have, with regret, accepted The observation is noted. Mr Barry Atwood that some traffic pollution and decline in the general shopping facilities at Purley is Observation concomitant with its location as a transport hub Noted – No Action and with its relatively good communications in and out of London. No doubt like most others who have moved here over the years, we needed a good rail service to Town. The increasingly adverse effects of traffic flow through the A23/A22 junction have been exacerbated by past planning mistakes such as the deleterious impact of the Day Aggregates’ plant, the excessive Tesco store and the policy of removing rather than creating adequate parking. Notwithstanding the consequent progressive loss of amenity at Purley’s heart, away from the through roads and the immediate centre, it is still mainly comprised of worthwhile and viable family homes. These date from the first half of the 20th century and have gardens that provide a much needed ‘green lung’ for the neighbourhood. There are no vacant sites for new buildings: replace the old with new denser development and the area with be further degraded to the disadvantage of all. purley Adjacent to the south east (Brighton Road) side The comment will be passed Mr Barry Atwood of the Webb Estate Conservation Area, these on to the Place-making Team. plans both show a Local Area of Special Observation Character. I have visited the Council website, No Action – Not an LDF Is but could find no reference to this LASC. I shall be grateful if you will explain where I can consult a map showing the precise area involved and giving details of how and when the LASC was designated etc. Purley Improved pedestrian access from the Tescos The observation is noted. Mr Barry Atwood site will also make their car park a more generally useful resource. It is, however, vital Observation that the existing multi-story and Whytecliffe Noted – No Action Road South car parks be retained and indeed improved, especially if the Council is seriously intending to promote park and ride from Purley . The Dale Road car park has now been sacrificed, the only other open space being at the top of Foxley Lane. Purley To the north and east of the shops - and The observation is noted. Mr Barry Atwood possibly on public land surrounding Tescos - there would appear to be some scope for further Observation good quality flats like those in Christchurch Noted – No Action Road and those on the western side of Brighton Road at the junction with Whytecliffe Road South. Purley Regeneration of Purley Town Centre: shops, The observation is noted. Mr Barry Atwood flats, amenities and parking Further iterations of the LDF will allocate development Observation 15. If pedestrian access to the Brighton Road sites. The need for Noted – No Action and High Street area were thus radically infrastructure will be improved, the existing commercial premises addressed in the IDP. there would begin to recover without massive investment. We believe it to be important that the existing Victorian/Edwardian shops should be preserved as part of the essential character of the town. The swimming pool should also certainly be retained and the Library re-sited close to it. Purley This would mean that High Street and the The observation is noted. Mr Barry Atwood stretch of Brighton Road in central Purley could then be largely pedestrianised and, although Observation (due to the Purley railway arch and the Noted – No Action commercial power and intransigence of Tescos) the A22 would still divide the Tescos site from Purley proper, it should be far easier for pedestrians to cross between the two. The greater area of public space made available at this point could also be united with the new Baptist Church development by closure of the short stretch of Brighton Road in front of it. Purley Unless London is offering some more radical The observation is noted. Mr Barry Atwood solution (such as routing M25 traffic via A217), the problem obviously has no easy solution. The Observation best solution that we have so far seen is the Noted – No Action rerouting of the north and south A23 traffic via a widened Banstead Road so that this at least would skirt the town centre. If Russell Hill Road was made two way for the A22 traffic, its junction with A23 would then be where Purley Way meets Foxley Lane. It might additionally be possible to divert most of the A235 traffic via Pampisford and Christchurch Roads. Purley 12. It is futile to think of serious regeneration in The Core Strategy will seek Mr Barry Atwood Purley until something is done to separate the ways to improve pedestrian through traffic from pedestrians. The problem is links, way-finding and Object of course well known: the centre of Purley is movement within the town Agree – Propose Changes divided up by A22, A23 and A235. If people are centre. unable to reach the shops, station, hospital, library, swimming pool etc. in safety and comfort, they will visit the centre only when they must. Purley Regeneration of Purley Town Centre: the road The observation is noted. The Mr Barry Atwood system fact that Croydon is economically important within Observation 11. Pages 50 and 51 respectively show Visions the sub-region does not Noted – No Action of Purley High Street and Town Centre in the automatically mean that future. As things stand, to hold out this kind of funding for A23/A22 junction idyllic view is no more than a pipe dream. How, improvements is available. for example, can a viable pedestrian Centre be placed across A235 outside Purley United Reformed Church unless the traffic through the district can be reduced? Notwithstanding all the efforts that have been put in over the years, these proposals offer no plans for such a reduction. If, as page 15 of the Initial Report suggests, Croydon is important to the Sub- region because of its “proximity to Gatwick” and “within a growth corridor that seeks to revitalise and reinvent the concept of suburbia”, why has finance for the improvement of the A23/22 road junction continually been refused? Purley 2. that, certainly as regards the sector defined Later iterations of the Core Mr Barry Atwood by Banstead Road/Foxley Lane and the Brighton Strategy will allocate areas for Road, any such development should be housing development. Object confined to the frontages of those roads and the Disagree – No Change immediate centre of Purley. Purley 1. that the areas of Purley such as are described The Core Strategy proposes Mr Barry Atwood in paragraph 9 should be excluded from any that all new development zone that might be assigned for development to should be appropriate to the Observation accommodate population growth; and context of each area. Disagree – No Change Purley It is possible that other portions of the “Indicative The designation of LASCs is Mr Barry Atwood Concentrated Growth Corridor” at Purley - eg not a Core Strategy matter. Russell Hill - might on similar grounds merit However, the comment will be Object LASC status but, unless the large orange/red passed on to the Place- No Action – Not an LDF Is blob is defined with more precision, it is difficult making Team to comment further specifically. The general conclusions, however, must be - South Croydon Comment: Because I live in South Croydon I The council has undertaken its Mr I.G.M. Hunter shall confine the bulk of my comments to that consultation exercise in Place. However, I was disappointed not to have accordance with the adopted Object had the opportunity to attend a Core Strategy Statement of Community Disagree – No Change meeting of the type held at Christ Church Hall, Involvement. A large number Purley on 10th September 2009 which raised of consultation meetings have many issues of concern to Purley residents. In been held, but staff and the introduction to this paper I criticised the lack financial resources are limited. of any local consultative meeting which has effectively deprived many South Croydon residents of the opportunity to raise issues affecting their present lives and which will impact on their and their children’s future. Purley This fact seems already to some extent to be The designation of LASCs is Mr Barry Atwood tacitly acknowledged by the Initial Report in not a Core Strategy matter. respect of the western sector of Purley, where However, the comment will be Object large areas of the “Indicative Concentrated passed on to the Place- No Action – Not an LDF Is Growth Corridor” are either Conservation Areas making Team (the Webb estate) or Local Areas of Special Character (a ring of properties surrounding the Webb Estate). In our view important additional areas have been omitted. page102/para2/bullet7 The swimming pool should also be retained and The Core Strategy is a high Mr Barry Atwood improved (see letter: para 15). level policy document. The need for infrastructure will be Object addressed in the IDP. Disagree – No Change Purley 6. Page 26 of the Initial Report shows a large The illustration is indicative Mr Barry Atwood undefined orange/red blob at Purley as part of only. Further iterations of the the “Indicative Concentrated Growth Corridor” LDF will seek to allocate Object put forward in Option 2. As the proposals stand, development with greater Disagree – No Change this area - precision.

• would be targeted for “new housing and commercial development” (see page 26),

• while at the same time its residential character would be retained and inappropriate development would be prevented (see page 104 “Options for change”).

The incompatibility of these two objectives suggests that the matter has not been thought through. Purley Purley: retention of residential character and The observation is noted. Mr Barry Atwood prevention of inappropriate development Observation Noted – No Action Purley It is no doubt very difficult for officials to ensure The Council has gone beyond Mr Barry Atwood that adequate notice is given of planning the Statement of Community proposals. Nevertheless, we feel that, if this Involvement to encourage Object major initiative has only just come to our notice, participation in the preparation Disagree – No Change there must be many others who might have of the Core Strategy. important comments to make but who are totally unaware of what is being discussed. We feel sure that the Christ Church meeting was poorly attended not through apathy on the part of residents but because they simply did not know about it. Given the radical proposals in respect of Purley and Coulsdon, a cynic might suggest that the absence of a Core Strategy Drop-in Surgery at Purley and the holding of the Smitham Surgery before residents were generally aware of the Report looks suspiciously like a deliberate ploy to avoid trouble. Purley Inadequate notice of the Croydon Core Strategy The Council has gone beyond Mr Barry Atwood consultation: We have been Croydon the Statement of Community ratepayers for more than 40 years, having lived Involvement to encourage Object in the Purley area since 1966. We are members participation in the preparation Disagree – No Change of the Bourne Society and actively interested in of the Core Strategy. the history of the neighbourhood, for example, Tudor and 19th century Croydon, the development of the Surrey Iron Railway, the Brighton line and the roads to the coast, as well as the connections that the 18th century radical and philologist, John Horne Tooke, had with the Purley district. We are, moreover, members of the local Residents’ Association and do our best to follow planning matters in the Purley and Coulsdon Advertiser and the Croydon Gazette. Thus, we actively commented on the still outstanding replacement of Purley Hospital and have tried to keep up with the various abortive initiatives to improve the interface between pedestrians and traffic at Purley Cross. It was therefore with surprise that we suddenly became aware of the Croydon Core Strategy Initial Report Imagine Croydon and the specific proposals for major development in Purley based in part on the establishment nearby of Local Areas of Special Character. It was only by chance via the on-line Purley Mail that we learned of the current consultation exercise and also of the meeting at Christ Church, Purley on 10 September. We would therefore ask that - at least from the next round onwards - more strenuous efforts are made to notify Purley residents of the proposals. Purley Away from the traffic, Coulsdon, Kenley, The observation is noted. Mr Barry Atwood Sanderstead, Selsdon and Addington are the sensible locations for any new family homes Observation (paras 26 - 30). Noted – No Action Purley Purley is already making a disproportionately The need for family homes Mr Barry Atwood large contribution to perceived public needs by eists across Crodon. Further accommodating Day Aggregates’ plant, Tesco’s iterations for the Core Object hypermarket etc.; its east - west Strategy will detail locations Disagree – No Change communications are not good; there is only for development more limited space for flats in the centre and along the precisely. main roads; new family houses should realistically be located in districts at the southern edge of the Borough where there is more room for manoeuvre (paras 18 - 25); Purley Provided pedestrian access is thus radically The observation is noted. Mr Barry Atwood improved, Purley Town Centre will recover without massive investment (paras 15- 17); Observation Noted – No Action Purley Purley Town Centre will not regenerate until The observation is noted. Mr Barry Atwood something is done to separate shoppers and other pedestrians from the traffic (paras 11 - 14); Observation Noted – No Action Purley Such areas should be excluded from any zone The Core Strategy proposes Mr Barry Atwood that might be assigned for development to that all new development accommodate population growth and, certainly should be appropriate to the Object as regards the sector defined by Banstead context of each area. No area Disagree – No Change Road/Foxley Lane and the Brighton Road, any is wholly excluded from such development should be confined to the development. frontages of those roads and the immediate centre of Purley (para 10); page 104/QuestionPY3 As places of architectural, merit, historical The designation of LASCs and Mr Barry Atwood relevance and environmental quality, Box Ridge Conservation Areas is not a Avenue (together with Hill Road, Purley Rise Core Strategy matter. Object and Purley Knoll) should be included in the zone However, the suggestion will No Action – Not an LDF Is designated as a Local Area of Special Character be passed on to the Place- (para 9); making Team. page22 That part of the Initial Report that deals with The comment is noted. The Addington fails to grasp the concept of positive potential spatial options for Devgrove opportunities briefly outlined at page 22 of the Addington do not a constitute Object Initial Report. an exhaustive list. Disagree – No Change Purley Main points The Council has gone beyond Mr Barry Atwood the Statement of Community 2. The main points of our reply to the Croydon Involvement to encourage Object Core Strategy Initial Report are: - participation in the preparation Disagree – No Change of the Core Strategy. • Purley’s residents have been given inadequate notice of the Report (paras 3 - 5); • Retention of Disagree that the residential Purley’s residential character is incompatible character will be threatened with targeting it generally for “new housing and by new development. The commercial development” (paras 6 - 10); core strategy will seek high standards of design appropriate to the character of each area. Purley Until we saw the Initial Report we were unaware The designation of LASCs is Mr Barry Atwood of the 2008 consultation exercise that, we now not a Core Strategy matter. understand, has resulted in the provisional However, the comment will be Object designation of Woodcote Valley Road as a passed on to the Place- No Action – Not an LDF Is LASC. Had we then known of this, we should making Team most certainly have proposed the northern limb of Box Ridge Avenue for inclusion, together with the surrounding area embracing Hill Road, the southern limb of Box Ridge Avenue, Purley Rise and Purley Knoll. Mainly pre-dating the Webb Estate - our own house was built in1905 -, these properties are, in our submission, of equal and often superior architectural, merit, historical relevance and environmental quality to most of those in Woodcote Valley Road. Bearing in mind first that the Report aims to “retain residential character and prevent inappropriate development” and secondly that the specified properties represent one of the earliest phases in Purley’s history, their sacrifice in favour of modern denser occupation would, in our view, be indefensible. We take this opportunity to propose the specified roads for inclusion in the Local Area of Special Character. page92/para2/bullet5 With regard to the reference on page 92 to The comment is noted. The expanding existing schools or providing new need for supporting facilities Homes and Communities ones to cater for the population growth and will be considered in an Agency residential development of Cane Hill, the HCA Infrastructure Delivery Plan. Observation notes that the number of school places Noted – No Action anticipated from the redevelopment of the Cane Hill site will be determined according to the mix and quantum of residential development proposed on the site. Page 118 Page 118 – Where we want to be. The comment is noted. The Mr I.G.M. Hunter aspiration is for all the public Bull point 2: Reference to “high Quality public realm to be of high quality. Observation realm” is not supported by sufficient evidence on Noted – No Action the “Spatial Issues” map (page 119), where is this realm? Page Where are we now. The comment is noted. The Mr I.G.M. Hunter 118/Para2/Bullet8 infrastructure needs Bull point 8: This point fails to mention the associated with the Core Observation complete absence of banks and post offices Strategy will be considered by Noted – No Action between the South Croydon/Selsdon Road the Infrastructure Delivery confluence and Purley along the, so-called, Plan. Concentrated Growth corridor of the Brighton Road. Very little effort was made by either the present Council or its predecessor to prevent the closures of branches these two important social elements and the Core Strategy makes no reference any plans to re-introduce such facilities in the wake of the proposed increase in housing and businesses in the area Question SC1 Q SC 1: No! The positive references end once Whilst it is not appropriate for Mr I.G.M. Hunter one goes South from South Croydon along the the core strategy to provide Brighton Road towards Purley. Several car details of specific sites (unless Object dealerships occupy valuable residential land they are a Strategic Site Disagree – No Change between Brantwood Road and the Purley Oaks Allocation), the principle is Recycling Centre. These are in addition to a contained on page 120 - number going North along the A23 from "allow for some change and Brantwood Road. Medium to long term Council future growth along Brighton policy should include the acquisition of that land Road for residential, for social housing and 3-4 Bedroom houses. community and small local employment uses". Page 120 Q SC 2 : No! Options for Change Bull point 6 This is a level of detail not Mr I.G.M. Hunter should be clearer with regard to the appropriate for a core strategy. maintenance of such facilities; will they be built Object by the Council but require the local residents to Disagree – No Change pay for their upkeep? Question SC2 Page Options for Change Bull point 7 is weak. Unless The comment is noted. A Mr I.G.M. Hunter 120 the Council obtains more control over the TfL borough-wide Transport transport policy as it affects the Borough Strategy is being prepared Object generally, meaningful changes are not going to which will inform the next Disagree – No Change happen. (See my comment on SC 3 and Annex consultation draft of the Core A). Strategy. Question SC3 Q SC 3 - Yes: a). Ensure that greater powers to The comment is noted. Mr I.G.M. Hunter influence transport decisions are acquired by the Council. Object Disagree – No Change n/a Section 6 of the Document attempts to do this by The council has undertaken its Mr I.G.M. Hunter referring to the “Places in Croydon”. Accepting consultation exercise in that there will also be common threads which accordance with the adopted Object link each “Place” e.g. transport, the report Statement of Community Noted – No Action focuses on where those living in that “Place” Involvement. A large number “want to be” and “how to get there”. The mistake of consultation meetings have which I believe the Council has made, is not been held, but staff and financially committing itself to holding public financial resources are limited. meetings in each of the “Places”, where this paper could have been discussed. Instead, it allowed the responsibility to be placed on to local Neighbourhood Associations etc. to which not every resident is a member, or which do not exist or which are so apathetic that they did not seek a presentation from the Council. norbury Within the areas identified within this section, the The comment is noted. MPA wish to ensure that policing facility Metropolitan Police provision is maintained and enhanced, mindful Authority of the MPA Asset Management Plan for Observation Croydon. The MPA have a number of properties Noted – No Action within these areas and would like to make the following site specific representations which involve the future of the MPA's property estate, as outlined in the AMP.

The MPA intend to develop a new front counter public policing facility in Norbury. Once this facility has been provided, this will facilitate the potential disposal of Norbury Police Station. The MPA will reiterate the potential future release of this site in the Site Specific Allocations document upon its publication for consultation.. addington Within the areas identified within this section, the The comment is noted. MPA wish to ensure that policing facility Metropolitan Police provision is maintained and enhanced, mindful Authority of the MPA Asset Management Plan for Observation Croydon. The MPA have a number of properties Noted – No Action within these areas and would like to make the following site specific representations which involve the future of the MPA's property estate, as outlined in the AMP.

The MPA intend to develop a new front counter public policing facility in Addington. Once this facility has been provided, this will facilitate the potential disposal of Addington Police Station. The MPA will reiterate the potential future release of this site in the Site Specific Allocations document upon its publication for consultation. page96questionKE3 Within the areas identified within this section, the The comment is noted. MPA wish to ensure that policing facility Metropolitan Police provision is maintained and enhanced, mindful Authority of the MPA Asset Management Plan for Observation Croydon. The MPA have a number of properties Noted – No Action within these areas and would like to make the following site specific representations which involve the future of the MPA's property estate, as outlined in the AMP.

The MPA intend to develop a new front counter public policing facility in Kenley. Once this facility has been provided, this will facilitate the potential disposal of Kenley Police Station. The MPA will reiterate the potential future release of this site in the Site Specific Allocations document upon its publication for consultation. page102/para3/bullet7 The argument that it would be replaced by pools The Infrastructure needs Mr Bill Tubb at Coulsdon and Five Ways, Waddon, seem to associated with the Core me fatuous. It seems ridiculous to consider the Strategy will be considered by Observation demolition of a well used and necessary public the Infrastructure Delivery Noted – No Action building only some 30years old. If we have one Plan. Which will be developed at Purley why decide to have another at alongside the Core Strategy. Coulsdon it makes no sense. If we build another An Open Space, Indoor and at Waddon that’s fine, there is a strong enough Outdoor Leosure Study is population in the Waddon area of Croydon to being prepared. This study keep a pool busy, one should have been built in will advise on the ned for that area years ago but it is not reasonable to leisure facilities in the borough. say a new pool at Waddon is a reason to demolish a good pool in Purley. The present Council do not attempt to make a logical argument to support their plan and ignore the very large local support to keep the pool already provided. pages 98-101/Norbury b.conduct a feasibility survey and re-instate The comment is noted. The Marie Norfield further and adult education into a school in need for community facilities Scot's Estate Residents Norbury. Until about 15 years ago the then will be considered in an Assocaition Norbury Manor High School for Girls was a Infrastructure Delivery Plan. Observation thriving adult education centre. We recognise Noted – No Action head teachers will have legitimate security concerns but with the development of local schools eg to include sixth forms there is a real opportunity to promote community-wide use of good quality buildings - currently denied CALAT for example in the poor condition of their centre in Ambassador House in Thornton Heath; Page102 bullet 2 We agree with the aim of a high quality public The Council will consider Mr Barry Atwood realm in Purley. While the existing Library details of change in Purley building should be preserved, its facilities could town centre in the Site Observation with advantage be relocated in the centre (see Allocation DPD. Noted – No Action letter: para 15). page93/figure On the “potential spatial options” diagram on It is considered that this is page 93, it is considered that the “Cane Hill already an appropriate level of Homes and Communities redevelopment site” should be added to the map detail for this diagram. Agency legend. In respect of the text label attached to Object the Cane Hill site, the HCA is supportive of the Disagree – No Change “land swap” concept in order to avoid an isolated community on top of the hill (although recognising that some new development may be sited on the hill, in proximity to the locally listed Chapel and Administration block). The reference within the text label attached to the Cane Hill site to its redevelopment for “mainly residential use” is fully supported by the HCA, in the context of its proposals for the site. Purley In Purley, as we have said, the pre-condition for The Core Strategy will seek Mr Barry Atwood this is separation of through traffic from ways to improve pedestrian pedestrians (see letter: para 12). links, way-finding and Object movement within the town Agree – Propose Changes centre. page92/para2/bullet3 The HCA is supportive of the option in the third The comment is noted. bullet point of the “How do we deliver these Homes and Communities options?” section on page 92 of the consultation Agency document, which suggests that the Cane Hill Observation “major development area” could be “swapped” Noted – No Action for an equal area close to Coulsdon Town Centre to enable the redevelopment to be part of the centre’s regeneration. This is entirely consistent with the HCA’s aspirations for the site, although it is worthy of note that consideration will also need to be given to the top of the hill, where the locally listed Chapel and Administration Block are intended to remain in situ. page92/para2/bullet2 The HCA supports the second bullet point of the The support is welcomed. “How do we deliver these options?” section on Homes and Communities page 92 of the consultation document, which Agency proposes change and future growth along Support Brighton Road (including Cane Hill and the Lion Agree - No Action Green Road Car Park) for housing, community, leisure, retail, commercial and small scale local employment uses. The HCA considers that the Cane Hill site is capable of making a significant contribution towards the Borough’s housing targets and therefore provides an excellent opportunity to accommodate growth within the Core Strategy Plan period. page92/para2/bullet3 In terms of the suggested options for delivery of The council wishes to protect the proposed changes, in the context of the all open spaces. It would Homes and Communities proposals to “slide” development at Cane Hill therefore not be appropriate to Agency down the hill towards Coulsdon, the HCA refer generally to the Object suggests that the first bullet point of the “How do reconfiguration of open space Disagree – No Change we deliver these options?” section should refer as an option for the whole of to the reconfiguration of open spaces, as well as the Coulsdon Place. protection. page92/para1/bullet1 In respect of the options for change for It is agreed that the wording of Coulsdon set out on page 92 of the consultation the first bullet point could be Homes and Communities document, it is considered that the first bullet improved. The support on the Agency point “protect the residential character and open second bullet point is Observation spaces” does not represent an option for welcomed. Agree – Propose Changes change. The HCA considers that the second bullet point, which suggests allowing for change and future growth for housing, community, offices, retail, hotels and small employment uses to assist regeneration, is a wholly appropriate option. page91/spatialissues On the spatial issues plan on page 91, it is noted An appropriate change will be that a number of sites are marked on the map. It made. Homes and Communities is therefore considered, given the scale of the Agency Cane Hill site in the context of Coulsdon, that it Observation would be appropriate for the Cane Hill site to be Agree – Propose Changes marked on this plan. page90/para2 Coulsdon-The HCA considers that an additional A future iteration of the core bullet point should be added into the “Where are strategy will recognise the Homes and Communities we now?” section on page 90 to refer to the importance of the Cane Hill Agency adjacency of Cane Hill to Coulsdon Town site for this Place. Object Centre, and the opportunity the redevelopment Agree – Propose Changes of the Cane Hill site brings to catalyse the regeneration of Coulsdon, particularly if the developable area of the Cane Hill site “slides” down the hill to adjoin Lion Green Road and Coulsdon Town Centre. page 71 Devogrove acknowledges the observation at The comment is noted. page 71 of the Initial Report that the Council Devgrove wishes to ensure that new developments have Observation growing areas at multiple levels for residents. Noted – No Action The anticipated approach to development off Kent Gate Way would provide the opportunity to implement such aspirations. Page 78 Page 78 of the Initial Report emphasizes the The comment is noted. good range of facilities available at Addington. Devgrove Furthermore, Addington does not suffer from the Observation flooding issues that arise in the A23 corridor. A Noted – No Action sustainable development opportunity arising on land between Kent Gate Way, Lodge Lane and Huntingfield would secure not only new housing but also necessary community facilities. For example, the opportunity would arise to tackle any shortfall in the delivery of open space / sports facilities. pg 80 QAD3 We do not consider that the options for change Identification of a site of this described at page 80 of the Initial Report are nature constitutes a level of Devgrove appropriate or adequately reflect the detail not appropriate for a Object opportunities that arise at Addington to deliver core strategy. Disagree – No Change new housing in a manner which responds to many of the Council’s development management policies outlined in the Report. In response to Question AD3, we would observe that the Core Strategy should incorporate reference to a specific sustainable development opportunity that arises on land between Kent Gate Way, Lodge Lane and Huntingfield. Addington In the light of the public transport accessibility The Council will consider related to Croydon Tramlink and the range of further the arguments for and Devgrove community facilities available at Addington, a against Green Belt and MOL Observation strategic opportunity arises in the vicinity of the amendment in the next Noted – No Action Addington Village tram stop to secure the consultation report for the provision of a sustainable neighbourhood Core Strategy. without impacting upon the basic purposes of the green belt. Paragraph 2.10 of PPG 2 states that local planning authorities, when drawing green belt boundaries, should take account of the need to promote sustainable patterns of development. Furthermore, paragraph B3 of Annex B to PPG 2, whilst dealing with safeguarded land, includes relevant advice to guide the general release of land from the green belt. Such land, required to accommodate necessary development, should be located where the development would represent an efficient use of land, well integrated with existing development, and well related to public transport and other existing and planned infrastructure, so promoting sustainable development. A further advantage of directing development to this location is that part of the site is previously developed land. Question AD3 In connection with Question AD 3, Devogrove is The comment is noted. now preparing a pamphlet outlining the nature of Devgrove the development opportunity that arises on land Observation between Kent Gate Way, Noted – No Action Purley Given also the quantity of cars and delivery The Core Strategy will seek Mr Barry Atwood trucks attracted by Tesco’s hypermarket and the ways to improve pedestrian volume of through traffic on A23 and A22, any links, way-finding and Object proposal to regenerate the town centre must movement within the town Noted – Propose Changes begin with serious works to separate vehicles centre. from pedestrians (see letter: paras 11 - 14). Provided pedestrian access is thus radically improved, Purley Town Centre will recover without massive investment (paras 15- 17). Page93 In the case of Cane Hill, the proposal to “slide” The comment is noted. The the development down the hill towards Coulsdon precise location of any Homes and Communities Town Centre has been conceived to stimulate development on the Cane Hill Agency the regeneration of the centre, and as such it is site will be addressed in a Observation considered that reference should be made within future consultation. Noted – No Action the consultation document to the significant role Cane Hill can play in delivering growth within, and the revitalisation of, Coulsdon. Sanderstead Sanderstead The support is welcomed. Mr David Hammond The protection of open spaces is welcomed and Natural England supported, Natural England also welcomes and Support commends schemes that promote and Agree - No Action encourage sustainable public transport options, including walking and cycling. Purley 1. This letter sets out our reply to the Croydon The observation is noted Mr Barry Atwood Core Strategy Initial Report: Imagine Croydon. The main points are listed here and explained in Observation the body of the letter. In the light of these points, Noted – No Action our answers to questions posed by the Report are set out in the Schedule attached. Page80/QuestionAD1 Addington - Groundwater protection issues The comment is noted. Ms Susan should be addressed in this location. Minimise Sheahan water discharged to sewers. Environment Agency Object Noted – No Action page96/para2/bullet2 Protecting the existing Green Belt and open The support is welcomed. Mr John Phillips space, including public access at Kenley Airfield Tandridge District Council is supported. In principle the possible location Support for a Kenley Airfield visitor centre with improved Agree - No Action parking and a perimeter pedestrian route in partnership with the Ministry of Defence and Tandridge District Council as specified in the potential spatial options for Kenley is welcome. The District Council’s involvement in this project should help to assist in producing a satisfactory outcome of the project. Kenley Kenley The support is welcomed. Mr David Hammond The area is described as having good open Natural England space/countryside access but with limited public Support transport accessibility. The protection of existing Agree - No Action open spaces is welcomed and supported. Natural England also welcomes and commends schemes that promote and encourage sustainable transport options, including walking and cycling. page69/para1/bullet1 The Council would need to be involved in The comment is noted. The Mr John Phillips discussions for any scheme reviewing any Council will consider further Tandridge District Council Green Belt boundary adjoining Tandridge the arguments for and against Observation District. Green Belt and MOL Noted – Propose Changes amendment in the next consultation report for the Core Strategy. Mr John Phillips Tandridge District Council

shirley Our comments here are limited to the two places Your comment is noted. Mr Andrew closest to the Airport on the east side of the Walters borough, Addington and Shirley. Biggin Hill Airport Limited Observation Similar considerations to Addington, also apply Noted – No Action to Shirley (Questions SH1, 2 and 3), albeit to a lesser extent because of the greater distance between the area and the Airport. Nevertheless, the east-west routes through Shirley are important from the point of view of access from the Croydon metropolitan centre and the Airport. Addington Addington The support is welcomed. Mr David Hammond Increased opportunities for walking and cycling Natural England are to be welcomed and encouraged. The Support protection of open spaces and enhancements is Agree - No Action welcomed and supported, as is increasing the usage and access of these sites. Addiscombe Addiscombe The comment is noted. Mr David Hammond The Council recognises that this is an area of Natural England deficiency which could be ameliorated through Observation planning gain in respect of new development Noted – No Action opportunities. Addiscombe/page 84 Addiscombe The support is welcomed. Mr David para 1 bullet 2 Hammond New opportunities for walking and cycling are to Natural England be welcomed and encouraged as are Support improvements to the public realm (soft Agree - No Action landscaping to be considered). Broad Green/page 86 Broad Green The support is welcomed. Mr David para 2 bullet 7 Hammond This area is recognised as an area of deficiency; Natural England improved links to public open spaces and Support community facilities is welcomed and supported. Agree - No Action Also supported are the proposed improvements to parks, recreation grounds and green links. Coulsdon Coulsdon The comment is noted. Mr David Hammond This area has limited public transport options, Natural England but provided with good open space provision Support and the Council’s aims to protect the open Noted – No Action spaces in this area are welcomed and supported. Natural England is aware of the development proposals at Cane Hill and wishes to be kept informed on developments, especially in respect of any changes to the site or relocation of any agreed development proposals. page84/questionac3 Opportunities for green roofs & rainwater re-use The comment is noted. Ms Susan (Addiscombe) Sheahan Environment Agency Observation Noted – No Action Purley Purley The support is welcomed. Mr David Hammond Improved links to open spaces by public Natural England transport are welcomed as is the retention and Support improvements to open space and recreational Agree - No Action facilities, Natural England also welcomes and commends schemes that promote and encourage sustainable public transport options, including walking and cycling. page92/questioncs3 Coulsdon- This area is a source protection zone The protection of Source Ms Susan 1 (SPZ 1). There are surface water flooding Protection Zones will be Sheahan issues around Brighton Road. Whilst we would included in the next of the Environment Agency encourage the use of SUDS to manage surface consultation draft of the Core Object water, infiltration to ground will be restricted Strategy. Agree – Propose Changes within SPZ1 due to the potential risk to groundwater. Issue is also applicable to any site within an SPZ1. Upper Norwood Upper Norwood The support is welcomed. Mr David Hammond Protection of opens spaces are welcomed and Natural England supported and Natural England also welcomes Support and commends schemes that promote and Agree - No Action encourage sustainable public transport options, including walking and cycling. Selsdon Selsdon The support is welcomed. Mr David Hammond Protection of open spaces together with Natural England improved access, including access to the Support Countryside is welcomed Agree - No Action Selsdon Selsdon The support is welcomed. Mr David Hammond Natural England also welcomes and commends Natural England schemes that promote and encourage Support sustainable public transport options, including Agree - No Action walking and cycling. Thornton Heath Thornton Heath The support is welcomed. Mr David Hammond Protection of open spaces is welcomed and Natural England supported as are the proposals to improve Support access and links between them. Agree - No Action Thornton Heath Thornton Heath The support is welcomed. Mr David Hammond Natural England also welcomes and commends Natural England schemes that promote and encourage Support sustainable public transport options, including Agree - No Action walking and cycling. South Croydon South Croydon The support is welcomed. Mr David Hammond Protection of existing open spaces together with Natural England improvements to encourage usage are Support welcomed and supported. Agree - No Action South Norwood and South Norwood and Woodside The support is welcomed. Mr David Woodside Hammond Protection of existing open spaces is welcomed Natural England and supported and Natural England also Support welcomes and commends schemes that Agree - No Action promote and encourage sustainable public transport options, including walking and cycling. Addington/ Shirley pg Our comments here are limited to the two places Your comment is noted. Mr Andrew 80 AD1-3 closest to the Airport on the east side of the Walters borough, Addington and Shirley. Biggin Hill Airport Limited Observation In relation to Addington, we are supportive of the Noted – No Action proposed improvements, as we expect that the Airport can be a significant source of employment for nearby residents of New Addington. The route to Biggin Hill is noted on the Spatial Issues map, but a reference in the text to the nearby employment opportunities would be a good example of cross-borough working, and the possibility of improving access to the Airport should be an option for change. The existing route from New Addington to Biggin Hill is sub standard even for the current bus service, cyclists and other road users and its upgrading would be in line with the Outer London Commission’s recommendations and also with the proposals in the Transport & Movement section of the Core Strategy. This is our response to Questions AD1, 2 and 3. Page77 Section five covers the issues and areas of The comment is noted. Mr David interest to Natural England, and the Council has Hammond identified sixteen different places which Natural England combined make up Croydon, and this approach Observation is acceptable to Natural England. Noted – No Action Shirley Shirley The support is welcomed. Mr David Hammond Protection of opens spaces is welcomed and Natural England supported and Natural England also welcomes Support and commends schemes that promote and Agree - No Action encourage sustainable public transport options, including walking and cycling. Waddon Waddon The support is welcomed. The Mr David comment about planting of Hammond Protection of open spaces is welcomed and native and indigenous species Natural England supported as is the proposal for target planting is noted. Support along major roads to ameliorate traffic, noise Agree - No Action and pollution affects, Natural England recommends the planting of native and indigenous species Waddon Waddon The support is welcomed. Mr David Hammond Natural England also welcomes and commends Natural England schemes that promote and encourage Support sustainable public transport options, including Agree - No Action walking and cycling. Norbury Norbury The support is welcomed. Mr David Hammond The retention and protection of open spaces is Natural England welcomed and supported and Natural England Support also welcomes and commends schemes that Agree - No Action promote and encourage sustainable public transport options, including walking and cycling. page120/questionsc3 Solutions to flood risk issues along Brighton Rd The comment is noted. Flood Ms Susan will be constrained by presence of SPZ1 risk and mitigation are taken Sheahan into account by the Core Environment Agency Strategy. PPS25 sequential Observation test has a presumption Noted – No Action against sensitive developments in high flood risk areas. page114/para2/bullet6 It was interesting to read of all the new The Core Strategy is not able Mrs P Pigram developments in the Croydon Talk leaflet, to influence education policy particularly with regard to education and the new in other boroughs. Observation academies. These are fine but what will happen No Action – Not an LDF Is to Edenham and Shirley High Schools? Will children still be “ bussed in” in even greater numbers from the Inner London boroughs? Surely the answer is that their local schools should be improved! Purley There is a significant misrepresentation on each Future iterations of the Core Mr Barry Atwood of the pages about Purley. Day Aggregates’ yard Strategy will seek to provide a at Purley is not a recycling centre. The company more accurate description of Object “supplies primary and recycled aggregates for the site. Agree – Propose Changes the construction and landscaping industry”. Their materials are brought in by rail and, as pointed out in paras 7 and 23 of the letter, sent out in heavy lorries which constitute a major prejudice to the local environment and hazard on Purley’s suburban roads. Questions PY1- Questions PY1- 3 The designation of LASCs is Mr Barry Atwood 3/purley not a matter for the Core 1. Retention of Purley’s residential character is Strategy, although the Object incompatible with targeting it generally for “new comment will be passed on to Disagree – No Change housing and commercial development” (letter: the Place-making Team. paras 6 - 10). Its places of architectural, merit, historical relevance and environmental quality, Later iterations of the Core should be further recognised by the inclusion of Strategy will allocate numbers Box Ridge Avenue (together with Hill Road, for housing development. The Purley Rise and Purley Knoll) in the zone Core Strategy proposes that designated as a Local Area of Special Character all new development should (letter: para 9). Such areas should be excluded be appropriate to the context from plans for development to accommodate of each area. population growth and, certainly as regards the sector defined by Banstead Road/Foxley Lane and the Brighton Road, any such development should be confined to the frontages of those roads and the immediate centre of Purley (para 10). Page97 Opportunities to create additional flood storage The creation of additional Ms Susan for the Caterham Bourne could be sought in flood storage for the Caterham Sheahan open areas. Bourne will be considered in Environment Agency the next consultation draft of Observation the Core Strategy. Agree – Propose Changes page96/para2/bullet3 The option to develop land in the vicinity of The comment is noted. Flood Ms Susan Godstone Road is a concern as this road runs risk and mitigation are taken Sheahan directly adjacent to the Caterham Bourne for into account by the Core Environment Agency much of its length. Any development around this Strategy. PPS25 sequential Object river corridor such seek to improve it by test has a presumption Noted – No Action providing more space, buffer zone habitats, against sensitive green corridors and reconnection to its developments in high flood floodplain. risk areas. Page136/QuestionWD3 The appropriateness and safety in flood risk The comment is noted. Flood Ms Susan terms of development in the A23 Purley Way risk and mitigation are taken Sheahan corridor will need to be addressed. into account by the Core Environment Agency Strategy. PPS25 sequential Observation test has a presumption Noted – No Action against sensitive developments in high flood risk areas. Coulsdon 22. In line with guidance set out in DfT Circular The comment is noted. A 02/2007, development proposed within these Borough-wide Transport Highways Agency areas might need to demonstrate how it will Strategy will be prepared to Observation mitigate any potential impacts to the SRN. inform the consultation report Noted – No Action Furthermore, if development proposals are of the Core Strategy. pursued in these locations then public transport accessibility might need to be enhanced with infrastructure improvements. See paragraph 9 below. Page93 The HA understands that a formal planning The comment is noted. application for the Cane Hill development site Highways Agency has yet to be submitted and proposals are yet to Observation be confirmed. It is recommended that, as far as Noted – No Action possible, the CS should include specific details on the development proposals for this site during the next stage of consultation. The HA also request to remain involved with this planning application as it comes forward. Kenley 22. In line with guidance set out in DfT Circular The comment is noted. A 02/2007, development proposed within these Borough-wide Transport Highways Agency areas might need to demonstrate how it will Strategy will be prepared to Observation mitigate any potential impacts to the SRN. inform the consultation report Noted – No Action Furthermore, if development proposals are of the Core Strategy. pursued in these locations then public transport accessibility might need to be enhanced with infrastructure improvements. See paragraph 9 below. Page136/QuestionWD3 Waddon- WD3 – The opportunity to reduce flood Although this is too site Ms Susan risk should be pursued by creating flood storage specific for the Core Strategy Sheahan as part of the proposed opening up of the to consider the principles Environment Agency Wandle through Wandle Park. underlying this comment will Object be included within the next Agree - No Action consultation draft of the Core Strategy. page128/questionth3 The Graveney/Norbury Brook is a main river The comment is noted. Flood Ms Susan which has become degraded and of poor quality risk and mitigation are taken Sheahan due to over development and being heavily into account by the Core Environment Agency modified and constricted. It is a lost opportunity Strategy. PPS25 sequential Object to create valuable open space and habitat. Any test has a presumption Noted – No Action future large scale development adjacent to this against sensitive river should ensure that it includes river developments in high flood restoration, particularly as this river runs through risk areas. The principles areas proposed for regeneration. underlying this comment will be included within the next consultation draft of the Core Strategy. Page127 The area shown as floodplain is definitely too The maps in Chapter 6 are for Ms Susan small here. Checking for new floodplain illustrative purposes only and Sheahan information should take place throughout the accurate flood risk maps can Environment Agency strategy development to ensure that the latest be in the Strategic Flood Risk Object information is being used. Assessment. Noted – No Action Page81/QuestionAD3 There may be opportunities for strategic surface The comment is noted. Ms Susan water balancing features in open areas. Further investigative work will Sheahan be undertaken looking at the Environment Agency surface water flooding issue. It Observation is recognised that surface Noted – No Action water flooding will have to be considered on a site by site basis as well as part of a wider green grid and rivers strategy. page124/questionsw3 South Norwood and Woodside-SW3 – Again, The maps in Chapter 6 are for Ms Susan checking for new floodplain information should illustrative purposes only and Sheahan take place throughout the strategy development accurate flood risk maps can Environment Agency to ensure that the latest information is being be in the Strategic Flood Risk Observation used. Assessment. Noted – No Action Purley This traffic problem, together with the fact that The next iteration of the core Mr Barry Atwood there is no available space in Purley for family Strategy will identify suitable houses, points to the conclusion that, if these locations for family housing. Object are needed to accommodate Croydon’s growth, Disagree – No Change they can only reasonably be located at the southern boundary of the Borough. Purley is suitable only for a limited quantity of new apartments in its centre and along the main roads (see letter: paras 18 - 30). page120/questionsc3 South Croydon- SC3 – Having a strategic The comment is noted. Ms Susan approach to the surface water flooding issue Further investigative work will Sheahan would allow consistent requirements to be set be undertaken looking at the Environment Agency for new development and identify any surface water flooding issue. It Observation opportunities for flood risk reduction. is recognised that surface Noted – Propose Changes water flooding will have to be considered on a site by site basis as well as part of a wider green grid and rivers strategy. page116/questionsh3 Shirley SH3 – The area shown as floodplain The maps in Chapter 6 are for Ms Susan appears to be too small. This should be checked illustrative purposes only and Sheahan against the latest information. Checking for new accurate flood risk maps can Environment Agency floodplain information should take place be in the Strategic Flood Risk Object throughout the strategy development to ensure Assessment. Noted – No Action that the latest information is being used. Question PY3 Brownfield sites are located predominately along The comment is noted. Ms Susan Brighton Rd. This area is within an SPZ 1. Sheahan However, risks to groundwater from site Environment Agency contamination can be managed, although there Observation will also be issues of managing surface water in Noted – No Action an inner source protection zone. Page97 Again referring to the potential spatial options - The support is welcomed. Ms Susan Consideration of opening up the Caterham Sheahan Bourne is welcomed. Environment Agency Support Agree - No Action Page104/QuestionPY2 We agree with the options except the inclusion The sequential test will be Ms Susan of an area of floodplain within an area shown for included with the Strategic Sheahan intensification of residential development along Housing Land Availability Environment Agency the Brighton Road. The sequential test and the Assessment which will not Object sequential approach required under PPS25 include sites within Flood Noted – No Action means that more vulnerable development such Zone 3B. a residential should be sited in lower flood risk zones unless there are no alternative sites in lower risk sites. Page104/QuestionPY3 Town centre proposals should include It is understood that the Ms Susan improvement of the Caterham Bourne which Caterham Bourne does not Sheahan flows through the centre of Purley and has been flow through Purley. Between Environment Agency culverted to the north west of the railway station. Purley and Croydon Object Metropolitan Centre it is Noted – No Action classified as a sewer rather than a river. It is not clear where it should be deculverted as the valley of the Bourne heads south east and north east from Purley. page101/potentialspati The extent of the floodplain is slightly larger than The maps in Chapter 6 are for Ms Susan aloptions shown on the Norbury Map. illustrative purposes only and Sheahan accurate flood risk maps can Environment Agency be in the Strategic Flood Risk Object Assessment. Noted – No Action page101/potentialspati Proposals for deculverting Norbury Book are The support is welcomed. Ms Susan aloptions welcomed. Sheahan Environment Agency Support Agree - No Action page100/questionnb3 There may be options to alleviate some flooding The comment is noted. Ms Susan through creating flood storage in open spaces. Sheahan Environment Agency Observation Noted – No Action page101/potentialspati Flood resilience should be a last resort. New A Strategic Housing Land Ms Susan aloptions development should focus on lower flood risk Availability Assessment is Sheahan areas first in line with the application of the being prepared and it will take Environment Agency sequential test in PPS25. The exceptions test is account of the sequential Object said to only be applicable where there are large approach to flood risk. Noted – No Action areas in flood zone 2 and 3 where the sequential test can not deliver acceptable sites. The ability to move development to area just beyond the floodplain but still close to existing centres could be explored. The note on the Potential spatial options plan indicating a focus for local facilities and retail south of the railway bridge may in part address this. page100/questionnb3 The Graveney/Norbury Brook is a main river The comment is noted. Flood Ms Susan which has become highly degraded and of poor risk and mitigation are taken Sheahan quality due to over development and being into account by the Core Environment Agency heavily modified and constricted. It is a lost Strategy. PPS25 sequential Object opportunity to create valuable open space and test has a presumption Noted – No Action habitat. Any future large scale development against sensitive adjacent to this river should ensure that it developments in high flood includes river restoration to restore this risk areas. The principles important south London river and its green underlying this comment will corridor. be included within the next consultation draft of the Core Strategy. page92/questioncs3 Where development takes the form of The comment is noted. Ms Susan redevelopment of existing sites, opportunities for Sheahan sustainable drainage into open areas might be Environment Agency sought. Observation Noted – No Action Page128/QuestionTH3 Thornton Heath TH3 – Opportunities for The comment is noted. The Ms Susan deculverting and naturalisation should be sought principles underlying this Sheahan in this area. comment will be included Environment Agency within the next consultation Object draft of the Core Strategy. Noted – No Action page77 Eight of the places (centres) examined within the A modified development Mr Michael Core Strategy are identified as district centres in strategy will be considered for Mulhern the London Plan or London Plan consultation a subsequent iteration of the Greater London Authority draft 2009, which should be recognised. The Core Strategy. Observation Core Strategy may benefit from some further Agree – Propose Changes clarity between the varying roles of district centres and local centres. In addition, the Core Strategy should also recognise the important role that local and district centres play in providing local employment and business opportunities across the borough. pages 98-101/Norbury “Promote greater use of safe options for cycling The comment is noted. Marie Norfield and walking for leisure and commuting as part of Scot's Estate Residents long-term development.” Assocaition Observation Noted – No Action pg 100 para 1 bullet 6 10.Amongst the specific initiatives which might The Core Strategy will set out Marie Norfield be developed (or revived) are to: transport policies relating to Scot's Estate Residents Norbury in more detail in later Assocaition a. review the scope for more local bus services version Observation for Norbury. For example, working with Purley Agree – Propose Changes Way businesses, to develop a (self-funding?) shopping bus service from Streatham and beyond via Norbury to the Purley to foster home deliveries; pages 98-101/Norbury b.set a target to match the level of service in The comment is noted. This is Marie Norfield those parts of London served by the tube by a level of detail not Scot's Estate Residents working with local train companies to improve appropriate to the core Assocaition services. For example, by running 3 services an strategy. Observation hour on Sundays and/or fast bus services into Noted – No Action London and Croydon instead; pages 98-101/Norbury c.plan for long term integration of bicycle use on The comment is noted. Marie Norfield a dedicated part of the road rather than the Scot's Estate Residents increasing, unregulated use of footpaths by Assocaition bicycle owners which is unsafe and carries Observation minimal penalty for injury or death of pedestrians; Noted – No Action pg 100 para1 bullet 6 d.extend the trams north to Norbury and beyond. The comment is noted. Marie Norfield Scot's Estate Residents Assocaition Observation Noted – No Action pages 98-101/Norbury c.using whatever appropriate government The comment is noted. Marie Norfield funding initiative is available, and working Scot's Estate Residents together with local churches, private gyms etc, Assocaition seek to widen access to sport and also plan a Observation dedicated sports centre. Along with the efforts Noted – No Action by local business in the summer dancing event, this might help create a greater sense of identity in the area, particularly amongst local young people; Question SC3 d). Consider re-instating the old railway line into The comment is noted. This Mr I.G.M. Hunter Selsdon as a Tramlink track, joining it to the suggestion will be passed on main line at Sanderstead, leaving the line again to transport colleagues. Observation after the Riddlesdown Tunnel crossing to Noted – No Action and Chelsham and linking to a southern extension of the New Addington service and terminating at Biggin Hill airport, thus improving an east/west public transport problem. pg 98 para 2 bullet 6 d.more systematic planting and replacement of The council will seek to Marie Norfield street trees, and shrubs (for example of the kind promote the development of Scot's Estate Residents that can be seen in the Royal Borough of "Green Infrastructure", Assocaition Kingston) and encouragement of the including the protection of Observation development of a ‘Friends of’ group for each street trees. Agree - No Action Norbury park. page92/para2/bullet3 Proposals to swap the Major Development Site The proposal relates to Mr Michael status from the Cane Hill site to another site another part of the same site. Mulhern closer to the Coulsdon district centre should be Greater London Authority assessed in line with PPS2 and London Plan Object policy. Further discussions with the Greater Disagree – No Change London Authority on this emerging proposal are required. PPS2 specifically allows a level of redevelopment on those Green Belt sites identified as Major Development Site, however, it cannot normally be used as a mechanism for reallocating this status to other sites that would not otherwise meet the Major Development Status tests as set out in PPS2. page104/para2/bullet4 9. Traffic congestion: -Improve Purley Cross and The comment is noted. The Revd Charles Russell Hill Road? -Need convincing traffic infrastructure needs Trefusis analysis to prove what’s best? associated with the Core Purley & Kenley Strategy will be considered by Neighbourhood Matters arising during discussion: It was pointed the Infrastructure Delivery Partnership out that there were a number measures that Plan which will be developed Observation could be taken to improve traffic flows around alongside the Core Strategy. Noted – No Action Purley. The current congestion situation in the This will be informed by a town was such that something must be done Borough-wide Transport sooner rather than later to alleviate this. The Strategy. meeting was also reminded that among the many past previous suggestions for the Purley Cross scheme was a tunnel.

Consensus: It was agreed that proper traffic analysis was needed in order to achieve a sustainable, efficient solution to the Purley Cross road situation. A tunnel for through traffic would be an appealing long term solution page78/para2/bullet10 The plan identifies New Addington as a district The Council intends to Mr Michael centre. New Addington is not identified as a promote New Addington as a Mulhern district centre in either the current London Plan district centre. Greater London Authority or draft consultation London Plan. Objectives to Object reclassify town centres should be carried out in Disagree – No Change line with PPS6 thresholds and the London Plan ‘Town Centre Health Check’ process. pg 100 para 1 bullet 6 “Rail and bus services have improved over the The comment is noted. Marie Norfield last decade but more could be done to integrate Scot's Estate Residents Norbury as part of an improvement in north- Assocaition south borough links and into central London Observation both by improving the frequency and range of Noted – No Action transport services on offer.” page102-104/purley We request that we be kept informed of The comment is noted. progress with this plus further LDF documents. London Fire and In addition we wish to reserve our client’s Emergency Planning position to submit further representations on Authority subsequent LDF consultations. Observation Noted – No Action page102-104/purley To ensure its service delivery is maintained for The comment is noted. the Borough, LFB are seeking to acquire a London Fire and temporary site during the period of redeveloping Emergency Planning the Purley site, and would be keen to enter into Authority discussions with the Council for a suitable Observation location with good access to main roads. Noted – No Action page102-104/purley LFB has identified the fire station at Brighton The comment is noted. Road in Purley to be redeveloped on site to London Fire and ensure that the station is able to provide an Emergency Planning adequate service and improve the existing Authority facilities for the local community in the future. Observation This is being undertaken as part of a PFI project Noted – No Action to deliver 9 new fire stations. Kenley 18. Anything else? The comment is noted. Revd Charles Trefusis There was some discussion about 20 mph limits. Purley & Kenley A vote was taken and 20mph limits in general Neighbourhood terms were not considered desirable. It was Partnership pointed out that current 20mph limits around Observation schools are appropriate during term time but not Noted – No Action during holiday time. The meeting thus agreed that where 20mph limits are in place, they should only apply at specific times. page104/para31/bullet5 14. Public transport: Trams? Railway? Buses? The comment is noted. A Revd Charles borough-wide Transport Trefusis Matters arising during discussion: It was agreed Strategy is being prepared Purley & Kenley that the railway was working at capacity in rush which will inform the next Neighbourhood hours. Any move to extend trams to Purley was consultation draft of the Core Partnership likely to increase road congestion down the Strategy. Observation A235 corridor - a vote was taken about this and Noted – No Action there was a slim majority against extending trams to Purley. It was also pointed out that bus links between the London borough of Purley and Sutton were poor and east-west public transport should be improved with better integration of Croydon and Sutton buses. If there was to be expansion of the tram network, east-west links might be a useful benefit.

Consensus: More capacity needed on trains in rush hours, better east-west public transport required, improved integration of bus services between Purley and Sutton. page104/para31/bullet5 13. Green space: Parks, green space? Trees? The comment is noted. The Revd Charles needs for green space will be Trefusis Matters arising during discussion: Purley is considered by the Purley & Kenley already poorly resourced in terms of green Infrastructure Delivery Plan Neighbourhood space and play space. It was pointed out that which will be prepared Partnership some new green space was of poor quality and alongside the Core Strategy. Object little use. Noted – No Action Consensus: Important that there is more high quality public green space and play space and more trees. page104/para1/bullet5 12. Public open space in the town centre: The comment is noted. Revd Charles Large/small? Town square? Space freed up by Trefusis Gyratory?) Purley & Kenley Neighbourhood Matters arising during discussion: The meeting Partnership was in agreement that Purley needed more Observation public space for markets and the like. Noted – No Action Consensus: More public space required. page104/questionpy3 11. High Street –Pedestrianise? (Market, The comment is noted. Revd Charles events?) However the Core Strategy is Trefusis not able to consider issues at Purley & Kenley Matters arising during discussion: The meeting this level of detail. Neighbourhood took a vote on pedestrianising the High Street, in Partnership which a majority declared in favour - but Graham Object Bass pointed that there could be a third option Noted – No Action which would be to pedestrian-prioritise the High Street, whereby vehicles could drive through it/park, but at low speed. This was considered to be an option worth considering.

Consensus: See discussion above. page104/para2/bullet4 10. Pedestrian access and links within centre: - The comment is noted. Revd Charles Station/High St/Brighton Rd/Russell Hill? - However the Core Strategy is Trefusis Railway? not able to consider issues at Purley & Kenley this level of detail. Neighbourhood Matters arising during discussion: Current links Partnership between the High Street and the station needed Object improving as did links between the High Street Noted – No Action and Brighton Road. There was also a requirement to improve pedestrian access over the railway line, which has now been considerably worsened with the installation of barriers at Purley station. The meeting also discussed cycle routes and said that current bike parking at the station was inadequate.

Consensus: Improved pedestrian access over the railway was required. An additional link between the High St and Brighton Rd was required. The pedestrian link between the station and the high street should be improved. (Current one is considered unpleasant with blind corners and unsafe). Also improved pedestrian accessibility is required to ease foot access from Russell Hill end of town. purley Retain the present character of the Town Centre Agree the need to prevent Mr Ibo Djemil and do not allow inappropriate residential inappropriate development. development . Observation Agree - No Action pages 98-101/Norbury b. a clear legal structure and penalties for The comment is noted. Marie Norfield landlords to ensure they maintain the Scot's Estate Residents cleanliness, and appearance of flats, Assocaition recognising that flats may be occupied by Observation families with a greater than traditional need for No Action – Not an LDF Is facilities such as rubbish collection; page114/para41 Leave Shirley alone! It is not an option for the core No more blocks of flats in Orchard Way strategy for no change to take Valerie Tree No more traffic in Orchard Way place in Shirley. Object No more shops or anything else in Orchard Way Disagree – No Change This area is for private homes, families and schools.Its fine as it is, with the exception of Chasely Green flats, which are an abomination, and should never never have been allowed. pages 98-101/Norbury 1. SERA are the newly formed residents Noted. Marie Norfield association covering the South-Eastern part of Scot's Estate Residents Norbury bounded by the London Road, Assocaition Craignish Avenue, Norbury Crescent and Observation Strathyre Avenue. The following is a response The comment is noted. based on comments from SERA members discussed at our meeting on 13 October 2009. We would be ready to discuss these proposals further.2. Our response relates directly to pages 98-101 of the document, about Norbury. page100/para1/bullets1 3. We welcome the proposals made for The support is welcomed. Marie Norfield ,6,7 maintaining the residential character, for Scot's Estate Residents improving transport and community centre and Assocaition school use Support Agree - No Action pages 98-101/Norbury but overall suggest the draft be sharpened to The core strategy will become Marie Norfield provide a greater sense of ambition. "sharper" as it outlines specific Scot's Estate Residents development proposals. Assocaition Observation Agree – Propose Changes pages 98-101/Norbury There could be less reference to history and The comment is noted. Marie Norfield more to current and future pre-occupations! Scot's Estate Residents Assocaition Observation Noted – No Action pages 98-101/Norbury 4. We recognise that the next few years may The comment is noted. Marie Norfield lead to a reduction in public spending but think it Scot's Estate Residents all the more important therefore for the council to Assocaition lead multi-sector working groups to tackle the Observation issues imaginatively in a cost-effective way. Noted – No Action Growth and 5.We welcome the government’s recognition of The comment is noted. Marie Norfield development – Croydon as an area of growth and the strategy’s Scot's Estate Residents including public realm option to ‘encourage regeneration of Norbury Assocaition improvements town centre’. Observation Noted – No Action pages 98-101/Norbury While we would be concerned about much more The core strategy seeks to Marie Norfield high-density development of flats and industrial encourage appropriate, high Scot's Estate Residents centres – the area has already seen major quality development. This Assocaition growth in the last five years does not necessarily exclude Observation higher density development. Disagree – No Change pg 100 6.We trust that development will be supported The comment is noted. The Marie Norfield with sufficient infrastructure such as transport, need for supporting facilities Scot's Estate Residents sewage etc, that it is planned properly in will be considered in an Assocaition consultation with residents, and that any Infrastructure Delivery Plan. Observation financial benefits from enterprise and rates are Noted – No Action ploughed back into Norbury. pages 98-101/Norbury “Work with and provide support to London buses The comment is noted. Marie Norfield and local rail companies to improve routes and Scot's Estate Residents provide more links.” Assocaition Observation Agree - No Action pages 98-101/Norbury a.the camouflage and greening of existing and The comment is noted. This is Marie Norfield new buildings and developments. We would a level of detail not Scot's Estate Residents request specific urgent action on Norbury appropriate to the core Assocaition Industrial Park – perhaps as a joint business- strategy. Observation residents-council venture – to improve its Noted – No Action appearance and cleanliness; pages 98-101/Norbury “Priority will be given to improve public transport The comment is noted. Marie Norfield and links as soon as possible.” Scot's Estate Residents Assocaition Observation Noted – No Action pages 98-101/Norbury c.work with local business and others to promote The comment is noted. Marie Norfield a continually improving high street/London Road Scot's Estate Residents environment. We appreciate the efforts of Assocaition business but suggest that more could be done to: Observation Noted – No Action pages 98-101/Norbury d.ensure the safe passage of pedestrians by The comment is noted. This is Marie Norfield ensuring that stalls, shop fronts and car show a level of detail not Scot's Estate Residents rooms do not protrude excessively onto the appropriate to the core Assocaition pavement especially around the south-direction strategy. Observation bus-stop where those unsteady on their feet Noted – No Action have to weave through people waiting for buses and shop fronts; pages 98-101/Norbury e.promote the presence of a wider range of While the council cannot Marie Norfield shops and businesses eg bakers/butchers control the type of shops, it Scot's Estate Residents representing all parts of the community. Use will seek to promote the Assocaition empty premises imaginatively for public use eg imaginative use of vacant Observation art work, meeting places, and further and adult premises and cleared sites. Agree – Propose Changes education; pages 98-101/Norbury f.ensure speedy clearance of rubbish – for The comment is noted. Marie Norfield residents as well as business - for example Scot's Estate Residents through the provision (re-instatement) of a Assocaition monthly free bulky collection service; Observation No Action – Not an LDF Is pg 100 para 2 bullet 3 g. consider re-installing the round French-style The comment is noted. This is Marie Norfield information point in the centre of Norbury which a level of detail not Scot's Estate Residents was in place for a year or so; appropriate to the core Assocaition strategy. Observation Noted – No Action pages 98-101/Norbury h.fostering initiatives like Camden Council’s ‘butt The comment is noted. Marie Norfield and gum’ receptacles combined with Scot's Estate Residents Westminster Council’s high pressure cleaning of Assocaition pavements; Observation No Action – Not an LDF Is pages 98-101/Norbury i. the early introduction of improved lighting for The comment is noted. Marie Norfield areas of higher street crime. Scot's Estate Residents Assocaition Observation No Action – Not an LDF Is pg 100 para 1 bullet 6 9.The document needs to give higher priority to The council's assessment is Marie Norfield improving transport for Norbury. The reference subjective. The next iteration Scot's Estate Residents to congestion is geographically obscure and that of the core strategy will set out Assocaition to “The area is well served for bus and rail transport policies relating to Object transport” is not, in our view, accurate ! Norbury in more detail. Agree – Propose Changes pages 98-101/Norbury The plan could be more ambitious. A suggested The wording set out in the Marie Norfield redraft, from the perspective of SERA residents, core strategy is considered Scot's Estate Residents might include: appropriate to identify the Assocaition challenges in this area. Object “There is severe congestion along the London Disagree – No Change Road during the working week and at weekends, hindering mobility, increasing costs for business, and causing unnecessary C02 emissions and air pollution.” pg 98 para 2 bullet 14 a.extending the use of Norbury library by re- The comment is noted. The Marie Norfield instating the use of the first floor, believed to need for community facilities Scot's Estate Residents have been lost due to disability legislation, with will be considered in an Assocaition the provision of a Stannah stairlift or other Infrastructure Delivery Plan. Observation development. We would like to see Norbury Noted – No Action library or another centre for example in the high street as provider of more events including lectures; adult education; films; more IT; pages 98-101/Norbury 8.Whatever development does take place, The comment is noted. Marie Norfield SERA would like to see the ‘public realm Scot's Estate Residents improvements’ cited in the plan including: Assocaition Observation Noted – No Action page84/Question AC1 The area to the west/south of Cherry Orchard The site in question is Road is not identified as a 'Spatial issue'. This contained within the Croydon Menta might be because this area is to be considered (Croydon Metropolitan Centre) Object through the Croydon Metropolitan Centre Place. However, the next Noted – No Action strategy, but as we note above, the Report says consultation draft of the Core little about the area in the CMC chapter either. Strategy will consider how the We would request urgent clarification from the 16 Places of Croydon Council as to whether the area will be interrelate. considered through the CMC or Addiscombe policy. We would recommend that the area be dealt with in CMC as the majority of the area is within the existing CMC (as defined in the adopted UDP) and given the location, characteristics, relationship to East Croydon Station and spatial issues of the area. page60/para1 These representations are submitted on behalf The comment is noted. of Menta. Menta are promoting major mixed use Menta regeneration on land to the west/south of Cherry Observation Orchard Road, Croydon. A planning application Noted – No Action for a mixed use development was withdrawn in July 2009. Menta remain committed to delivering regeneration in Cherry Orchard Road and now working with the Council and their partners in respect to the East Croydon Masterplan. These representations are submitted in the context of the above. page84/para2/bullet1 We strongly question "Implement planning policy A Residential Character to ensure the protection of residential character Appraisal and a Borough Menta with a prescribed area of tall buildings in Character Appraisal are being Object Croydon Metropolitan Centre and area of developed to ensure that local Noted – No Action transition of different zones of building heights distinctiveness and the unique stepping down in height" as a way of delivering characteristics of Croydon the options. Firstly the Report does not define over the plan period. The 'Croydon Metropolitan Centre'. Land to the west subject of tall building policy of Cherry Orchard Road is within the current will be developed in further CMC (as defined in the adopted UDP) and is detail in the Opportunity Area appropriate for tall buildings (indeed is Planning Framework. designated as such in the UDP). Menta would object strongly to any suggestion that this central and highly accessible location is not appropriate for tall buildings – the principle of tall buildings in this location has been established through Vision 2020, Alsop Masterplan and the UDP. The area already benefits from mid-scale buildings on the east of Cherry Orchard Road that provide a 'transition' to the residential areas further east. We would question how the 'zones' will be 'prescribed' and what assessment will be used to judge their acceptability or otherwise - the height of a building does not relate directly to the impact on 'residential character' which appears to be reasoning behind this option. The appropriateness of the area for tall buildings was confirmed by both CABE and the GLA when commenting on Menta’s recent planning application in the area (ref. no. 08/03821/P). Question SC3 c). If the number of household in the area is The comment is noted. This is Mr I.G.M. Hunter planned to rise, consider putting pressure, a level of detail not possibly in conjunction with the Sustainable appropriate for a core strategy. Observation Communities Act 2007, on the Post Office and Noted – No Action Banks to re-introduce outlets where none now exist. Recognise that not everyone will be happy to use electronic banking, given the sophisticated hacking that exists and bear in mind that the more secure the systems are made the more expensive they will become. page84/Question AC2 Question AC2 - Options you agree with the Further details regarding the options and the way to deliver them? CMC and its Environs will be Menta contained in the next Object We would expect an 'Option for change' to consultation draft of the Core Noted – No Action include seeking to ensure regeneration benefits Strategy. for Addiscombe from major development on Cherry Orchard Road/at the Station. Purley and Kenley 3. Flood risk implications (A23 Kenley Bourne)? A Strategic Housing Land Revd Charles Availability Assessment is Trefusis Matters arising during discussion: Flooding was being prepared and it will take Purley & Kenley agreed to be a long-term Purley problem and account of the sequential Neighbourhood climate change was liable to make it worse. approach to flood risk. Partnership Ongoing investigative work Object Consensus: No further development should be into surface water flooding will Disagree – No Change permitted in flood risk areas before effective anti- continue to inform the Core flood solutions are put in place. Strategy. Development proposals will be subject to national policy in the form of planning policy statement 25. page84/Question AC3 A 'Spatial issue' is stated as being "Tall buildings High quality design will be of Croydon town centre extend to the edge of considered in the next Menta Addiscombe with adverse visual impact on the consulatation draft of the Core Observation area's character". The "edge of Addiscombe” is Strategy. A Residential Noted – Propose Changes within the CMC. Given the CMC’s position in Character Appraisal and a hierarchy, scale, function, accessibility and Borough Character Appraisal historic prevalence of tall buildings it is are being developed to ensure appropriate for tall buildings to be located within that local distinctiveness and the centre and thus be visible from parts of the unique characteristics of Addiscombe. This was identified for tall buildings Croydon over the plan period. in the recent Alsop vision for the centre which The subject of tall building was itself subject to wide ranging consultation. policy will be developed in Furthermore, the appropriateness of the location further detail in the for tall buildings was confirmed by both CABE Opportunity Area Planning and the GLA when commenting on Menta’s Framework. recent planning application in the area (ref. no. 08/03821/P). The option, and in due course policy emphasis, should therefore be about securing high quality design for any future tall buildings in this location. Question SC3 b). Consider a future policy of compulsory This is a level of detail not Mr I.G.M. Hunter purchase on vacant car dealership premises appropriate for a core strategy. along the Brighton Road in order to facilitate the Observation building of housing in accordance with the Noted – No Action Mayor of London’s policy. page84/Question AC1 6. The Places of Croydon - Addiscombe The comment is noted. A Residential Character Menta Question AC1 - Do you agree with where we Appraisal and a Borough Observation want to be? Character Appraisal are being Noted – No Action developed to ensure that local The focus of ‘Where we are now’ is very much distinctiveness and the unique on retaining and enhancing the historic quality of characteristics of Croydon the area. Whilst it is clear that many parts of over the plan period are Addiscombe benefit from a historic townscape of considered. some quality, it is also true that the ward is diverse and some parts are of much lower quality and some parts suffer from a very poor townscape quality and are in significant need of regeneration. This should be recognised in the Report. page84/Addiscombe/B The 'Potential spatial options' plan states Further details regarding the ullet1 "modify/prescribe tall buildings and area of CMC will be contained in the Menta transition of different zones". It is not at all clear next consultation draft of the Observation to which area this applies and what is actually Core Strategy. The Core Noted – No Action proposed - is the intention is to modify existing Strategy will not address site tall buildings? Assuming a new policy approach specific issues in the CMC this – that departs from the UDP - is proposed for shall be addressed via new development near East Croydon Station, masterplanning, the OAPF, we would comment as above. the Site Allocations DPD and the Development Management DPD. page104/para1/bullet1 Imagine Croydon Feedback notes from special A Residential Character Revd Charles meeting of Purley & Kenley Neighbourhood Appraisal and a Borough Trefusis Partnership on October 13 2009 Character Appraisal are being Purley & Kenley developed to ensure that local Neighbourhood In attendance: Revd. Charles Trefusis distinctiveness and the unique Partnership (chairman), Cllrs. Graham Bass & Donald characteristics of Croydon Support Speakman + approx 45 residents (including a over the plan period. Agree - No Action minority from out of area (Waddon/Coulsdon/South Croydon)

Background: Charles Trefusis thanked Ken Trench and Tarsem Flora for their help in making the meeting possible. He told the meeting that there was currently no money available from the council/central government for many improvements in Purley. To aid the discussion process he had prepared a number of points to discuss. The notes below are the result of the discussion these points raised.

1. Population and housing growth. What is acceptable/desirable? Main considerations/constraints

Matters arising during discussion: Important to retain Purley’s character; quality of new development to be sustainable and of good design; pg 100 NB3 11.While we do not overlook the positives, more The comment is noted. The Marie Norfield could be done to plug gaps in the provision of need for community facilities Scot's Estate Residents local services in Norbury, available on people’s will be considered in an Assocaition doorsteps. Thornton Heath and South Norwood Infrastructure Delivery Plan. Observation for example have both thriving swimming pools Agree – Propose Changes and adult education centres. But these are not easily reached by public transport from Norbury. page104/para1/bullet2 8. Community infrastructure (NB 4 above): -Main The comment is noted. The Revd Charles priorities (schools, health centres, leisure etc)? infrastructure needs Trefusis associated with the Core Purley & Kenley Matters arising during discussion: Strategy will be considered by Neighbourhood the Infrastructure Delivery Partnership Discussion centred on the Sainsbury’s High Plan which will be developed Object Street site and multi-storey car park. It was alongside the Core Strategy. Noted – No Action thought that the existing multi-storey was structurally acceptable and that the old Sainsbury’s store site could be developed to provide a suitable mix of facilities/library/retail etc. It was pointed out that transport links to the hospital site were not good if you were disabled and relying on public transport. The facility of the pool should be retained, public conveniences were needed, improved library facilities were wanted, the need for a cinema was not discussed but would be beneficial, if it was commercially viable. It was pointed out to the meeting that the head lease of the Sainsbury’s site was now owned by an overseas-based developer so it will be more difficult to influence how the site is ultimately redeveloped.

Consensus: Before there is more development, the town wants improved car parking, public play space/green space, as well as improved leisure, health and educational resources. The meeting was that we are not happy with the current state of the multi-storey car park, but do not want to loose any of its car parking capacity – and want to at least maintain the total available car parking capacity in the town. page104/questionpy2 1. Population and housing growth. What is The comment is noted. The Revd Charles acceptable/desirable? Main infrastructure needs Trefusis considerations/constraints associated with the Core Purley & Kenley strong view that Purley was already over- Strategy will be considered by Neighbourhood populated and existing facilities (roads, health, the Infrastructure Delivery Partnership education, green space, parking etc) were Plan which will be developed Object inadequate. alongside the Core Strategy. Ntd N Ati page104/questionpy3 4. Willingness to trade additional housing for The comment is noted. The Revd Charles improved infrastructure. infrastructure needs Trefusis associated with the Core Purley & Kenley Has to be paid for by a developer – there is no Strategy will be considered by Neighbourhood money from the Council or central Government. the Infrastructure Delivery Partnership Plan which will be developed Observation Matters arising during discussion: There was alongside the Core Strategy. Noted – No Action some concern about taking money from developers but it was pointed out to the meeting that if some development was inevitable (see 1. above) then it would be better take Section 106 money from developers to improve facilities.

Consensus: Croydon Council should ensure that S106 money is spent within the area and also that new public facilities are provided either ahead of or at the same time as new housing developments are put in place. page104/questionpy2 5. High rise vs families? 25 per cent affordable A Residential Character Revd Charles housing? Appraisal and a Borough Trefusis Character Appraisal are being Purley & Kenley Matters arising during discussion: It was pointed developed to ensure that local Neighbourhood out to the meeting by the better-informed in the distinctiveness and the unique Partnership audience that Government requirements for characteristics of Croydon Object affordable housing is currently at levels of 40/50 over the plan period. The level Noted – No Action per cent, so it was highly unlikely that Purley of affordable housing will be could demand lower levels of affordable set appropriate to the housing. Tarsem Flora pointed out that borough's need. developments of 14 housing units or less were exempt from an affordable housing requirement.

Consensus: Meeting was against high rise developments and once again stressed that both private and affordable housing developments should be sustainable and of good design. To retain the character of the area, a limit of say 25% Affordable Housing would be appropriate. page104/questionpy1 7. Retail: what do we want? - More? Different? The comment is noted. Revd Charles Complement Tesco? -Tesco is here to stay Trefusis Purley & Kenley Matters arising during discussion: It was pointed Neighbourhood out to the meeting that the retail sector had Partnership changed and consumer expectations were such Observation that small grocers, greengrocers, fruiters, Noted – No Action butchers etc were not now viable in Purley due to the proximity of Tesco and Purley’s proximity to Croydon’s retail centre meant that many other small retailing enterprises in the town would also be unviable. What the meeting did think was important was that for any successful retail/commercial heart in Purley, the town had to offer the amenities (transport links, parking, attractive environment) to attract retail and commercial businesses to the town.

Consensus: The town would benefit from more specialist retail outlets, to reflect the wealth of the area and its consumers, to complement those offered by Tesco. page 84 para 2 bullet 5 The options say nothing about how major Further details regarding the regeneration may be delivered on Cherry CMC will be contained in the Menta Orchard Road, which is surprising as the scale next consultation draft of the Observation of the opportunity is unequalled in Addiscombe - Core Strategy. The Core Noted – No Action unless of course the area is intended to be Strategy will not address site covered in the Croydon Metropolitan Centre specific issues in the CMC this chapter. As stated above, this is not clear and shall be addressed via we request urgent clarification. masterplanning, the OAPF, the Site Allocations DPD and the Development Management DPD. 7. Delivering a Preferred Strategy Page/Paragraph/ Representation Recommended response Full Name Objective Organisation Nature of Response Officer Recommendation • “decrease traffic on key routes in the Borough” This suggestion will be taken into account in a future Highways Agency iteration of the core strategy. Observation Agree – Propose Changes 28. Furthermore, paragraph 3.2.14 of DCLG It is considered that the Guidance Note ‘Sustainability Appraisal of Sustainability Objectives Highways Agency Regional Spatial Strategies and Local should be high level and are Observation Development Documents’ states that appropriate. Disagree – No Change sustainability objectives should be expressed in the form of targets where practicable . In order to ensure that the emerging DPD focuses on improving sustainability, it is therefore recommended that key targets should be included within the SA. These could include, although need not be limited to, targets to: • The level of growth of traffic on key routes This suggestion will be taken within the District into account in a future Highways Agency iteration of the core strategy. Observation Agree – Propose Changes • The proportion of new development which is This suggestion will be taken meeting its travel plan objectives; and into account in a future Highways Agency iteration of the core strategy. Observation Noted – Propose Changes • The proportion of trips made by non-car modes; This suggestion will be taken into account in a future Highways Agency iteration of the core strategy. Observation Agree – Propose Changes Sustainability Appraisal and Monitoring The SA will include indicators for monitoring through the Highways Agency 27. Although the need for a sustainability AMR. Observation appraisal (SA) has been acknowledged in the Agree – Propose Changes CS, a SA has not been submitted for consultation at this stage of the LDF process. In order to ensure alignment with PPS12, it is recommended that the forthcoming SA, produced alongside the Core Strategy Preferred Options Report, should set out the monitoring arrangements for the Annual Monitoring report. This will ensure that the success of individual strategies outlined within the plan can be measured and assessed. These should include, although need not be limited to, the following transport related indicators: 26. Due to the quantum of development A transport model will seek to proposed for the borough, we suggest that a quantify the cumulative traffic Highways Agency spreadsheet-based model could be developed impact of developments in Observation to provide a strategic view on the overall part of the borough. Noted – No Action cumulative transport impacts of the CS. • “increase the proportion of trips by alternative These suggestions will be modes to the private car” taken into account in the SA. Highways Agency Observation Agree – Propose Changes Infrastructure The support is welcomed. Highways Agency 24. The HA is strongly supportive of the Support proposed completion of an Infrastructure Agree - No Action Delivery Plan which is intended to highlight the transport infrastructure requirements for the proposed development sites in the CS, sources of funding and provisional timetables for delivery. This will help to demonstrate that the CS and associated developments are deliverable in transport terms, and hence meet PPS12 requirement that a sound DPD should be ‘effective’, i.e. deliverable. Page 143 Page 143 – What happens next and how to get The council seeks to engage Mr I.G.M. Hunter involved. with all parties as set out in the Statement of Community Object Your Views – Active Community Engagement Involvement. Disagree – No Change Para. 1 Buried in this paragraph is a “cop out” for the Council in the event that inadequate consultation is given to a proposal. Members of the community and stakeholders must never not realise they have been “engaged”. The Council has, I thought, eschewed a “tick-box “ approach to public consultation because, often, the questions are skewed so as to achieve a particular policy. A recent classic Council example of this was the question “What do you want to see at the Arena”- not, “Do you want an Arena”. Moreover a “one to one” approach could be seen as a divide and conquer procedure, where the community as a whole is not aware of a particular action which might not be in their collective interest. Para. 2 Having already pointed out the dangers of selective engagements, I now see that the Council has already undertaken such action. Where is the input to this stakeholder/organisational involvement to be found? page139/para3/bullet1 Recommendation: Further to the Future iterations of the core recommendation made in Section 4 'How do we strategy will follow closely the Metropolitan Police deliver these options', the MPA would like to priorities set out in the London Authority recommend the wording of this paragraph be Plan. Object changed to read (additional wording underlined): Noted – Propose Changes • '...In the London Plan the highest priorities are affordable housing and transport movements followed by learning and skills, health facilities, policing facilities and childcare. page140/questionps2 In response to question PS2, it is outlined within Page 140 identifies a variety this section (under heading 'Where are we of delivery partners, but the Metropolitan Police now?') that planning obligations and Section 106 list is not exhaustive. Authority agreements will be use to secure priorities within Object the borough, this lists a number of the highest Disagree – No Change priorities, however policing facilities are not included. In order to comply with relevant London Plan Policies, reference to 'Policing Facilities' should be included as a S106 contribution priority. 25. The Infrastructure Delivery Plan, should The council will follow include of a framework which outlines how forthcoming government Highways Agency funding is to be secured. The HA would also guidance in the preparation of Observation encourage a Tariff approach (in line with the the IDP. Agree - No Action Community Infrastructure Levy (CIL)) in order to secure development contributions within the borough to fund necessary highway improvements. Page 140 Page 140 The comment is noted. While Mr I.G.M. Hunter the council will seek to consult Bull point 4: Once again, there is no direct fully with the community at all Observation reference to the input of the residents. These stages in the preparation of Noted – No Action are the people who will benefit, or suffer, as a the core strategy, result of the partnership deals. They have a right masterplans/planning to timely consultation. applications will also be subject to public consultation. page140/Question Delivering the Spatial Strategy The support is welcomed. This Nikki Honan PS1-2 Question PS1/2 Refer to points made under suggestion will be taken into HUDU HE1 and HE2: Question HE1 account in a future iteration of Support the core strategy. Noted – No Action How do we deliver these options? We welcome the fact that the Council will seek to secure planning contributions for health facilities.; Next steps HUDU supports the Local Authority working closely with Croydon PCT to further develop the preferred options for the core strategy, which could include: • Exploring shared health targets and outcomes. • Working together to identify possible policy This suggestion will be taken Nikki Honan interventions to improve health and reduce into account in a future HUDU inequalities; iteration of the core strategy. Observation Noted – No Action • Identifying the PCT pressure points in terms of The comment is noted. The Nikki Honan supply and demand of facilities; need for supporting facilities HUDU will be considered in the Observation Infrastructure Delivery Plan. Noted – No Action page139/para2/bullet2 Is the Core Strategy giving weight to the The IDP will contain a viability Mr Ross Gentry economy? 50% affordable housing and s106 assessment for planning LBC payments (want more family units, but then contributions. Observation developers have to pay more S106 to Noted – No Action education/transport). Needs to provide developers more certainty and help development happen rather than price them out. As a general point I would be interested to hear Future iterations of the core Ms Alison how work is progressing on your evidence base. strategy will refer to specific Fairhurst In future documents, you may find it helpful to evidence. Government Office for provide cross references to relevant parts of the London evidence base that underpin policies, or Observation consider the use of text boxes to include key Agree – Propose Changes summaries. This section states that following the production Future iterations of the core Ms Alison and adoption of your Core Strategy, Annual strategy will include Fairhurst Monitoring Reports will be produced to consider appropriate indicators. Government Office for how the policies within the Core Strategy are London being delivered. The Plan Making Manual says Object “It is not sufficient to defer the issue of Agree - No Action monitoring within the core strategy by simply saying that it will be dealt with in the annual monitoring report. The core strategy itself requires a framework for the annual monitoring report by identifying key targets and indicators against which the council can measure the effectiveness of the strategy, policies and proposals. Implementation and delivery targets must be clearly set out and relate to policy considerations. For example, affordable housing targets need to have a parent affordable housing policy and need to be firmly rooted in a proper understanding of the likelihood of funding for affordable housing. The targets should be properly explained and supported by evidence and it should be clear in their relationship to the strategy”. I welcome the statement within the Delivering The comment is noted. Ms Alison the Spatial Strategy Section which explains that Fairhurst Croydon’s Local Development Framework has Government Office for to make clear where, what, when and how London development will take place in the future. At the Observation next consultation stage you will need to show Noted – No Action how work is progressing on all of these fronts. In particular, any issues that arise that could have implications for the delivery of your Core Strategies vision and objectives. You may also want to provide linkages to the infrastructure delivery plan that you are producing to accompany this document. n/a • Exploring the spatial implications of the primary The comment is noted. Nikki Honan care strategy and matching this with housing HUDU growth and population change; and Observation Noted – No Action Page 139 Page 139 - Delivering the Spatial Strategy The key schemes will be set Mr I.G.M. Hunter out in the Infrastructure Where are we now Delivery Plan, which is subject Observation to public participation. Noted – No Action Bull point 2: This point indicates that The Council will produce a schedule of key schemes…. At what point will the residents of the Borough be brought into the consultation process which inevitably will affect their lives? Presumably well before the production of a schedule of key schemes, (ie: who determines if a scheme is Key anyway?). • “reduce the average distance over which A later iteration will set out the borough residents’ travel to work” balance between jobs growth Highways Agency and homes growth, which is Observation directly relevant to this point. Noted – Propose Changes Q PS 1 Q PS 1: No! While the onus will be on the The council will seek to Mr I.G.M. Hunter Council, it must, if the principles of a sustainable consult fully with the COMMUNITY are to be followed, properly community at all stages in the Object consult at all stages with the residents before preparation of the core Disagree – No Change key decisions are irreversibly entered into. strategy. Page 141 Page 141 – The Sustainability appraisal The SA which accompanies Mr I.G.M. Hunter the preparation of the core Para.3. From whose comments was the SA for strategy is being prepared by Object Croydon’s LDF created and where are the specialist consultants, who are Noted – No Action detailed comments, as opposed to a summary, experienced in developing to be found? such appraisals for local planning authorities. A full SA will accompany the submission draft of the core strategy. Page 142 - Monitoring Page 142 - Monitoring The comment is noted. Mr I.G.M. Hunter

This description suggests that changes to the Observation Core Strategy may be made within its life if Noted – No Action considered important enough by Council, residents, developers and business. It would be, under such conditions, right that a flexible approach to new proposals for development which are likely to impact upon existing policies, eithere by changing those previously agreed or which introduce a new approach or perspective to the Core Strategy, could be accepted. page143 It is noted that additional studies are being The comment is noted. conducted to supplement the CS. Evidence Highways Agency gathered through these studies should inform Observation the CS and help to identify the Preferred Option. Noted – No Action Page 140 Q PS 2: Not that I can think of at present. The comment is noted. Mr I.G.M. Hunter

Observation Noted – No Action page140/questionps2 Recommendation: Whilst the MPA support this The comment is noted. The approach, they wish to reiterate that policing need for community facilities Metropolitan Police facilities are important community facilities which will be considered in an Authority should be included as a key infrastructure Infrastructure Delivery Plan. Observation requirement for the future, and the MPA be The council recognises that Noted – No Action recognised as a Key Stakeholder during the MPA is a key stakeholder. consultation. Appendix 1 The comment is noted. Nikki Honan HUDU Example of a policy conformity matrix Observation Noted – No Action Topic Policy National policy guidance London Plan Community Strategy Core Strategy

objectives Core Strategy Policies

objectives policy

Sustainable communities

Housing

Greenspace

Transport

Health

Etc n/a Had there been an organised public meeting for It is the council's intention to Mr I.G.M. Hunter the residents of South Croydon many of the publish responses as set out questions posed in my response would have on page 141. Observation been asked and clarified then. They would have Agree - No Action included those I now ask regarding Section 7 of the Imagine Croydon document but which, unless there is an interim response to the input before the next iteration of the proposed Core Strategy, will not be answered. I do not find that situation at all satisfactory. I hope the undertaking in the final paragraph on page 141 will answer this concern. Page140/para2/Questi 4. Major developments need local retail, These suggestions will be Norbury on PS2 schools, health and transport services within taken into account in the SA. councillors/reside easy reach as well as parks and rooms for hire nts for community activities, and other social events. Norbury councillors/residents Observation Noted – Propose Changes • Developing a shared understanding of the The comment is noted. Nikki Honan health issues and inequalities facing Croydon; HUDU Observation Noted – No Action page139/para4 One of the key aspects behind CIL or even a The comment is noted. tariff based system is viability. Any infrastructure Mccarthy & Stone contributions system that is being considered Retirement Lifestyles Ltd needs to robustly assessed to identify what Observation would be viabile for the development industry to Noted – No Action provide that will still allow development and regeneration of Croydon to take place. In doing that the Council also needs to consider the impact of seeking infrastructure payments on other planning objectives such as the delivery of affordable housing. The higher the infrastructure contribution the lower the amount of affordable housing that is capable of being provided by residential developers. Questions PS1 and 2, Our final comment, in response to Questions An appropriate change will be Mr Andrew PS1 and 2, is to emphasise the need for cross- made. Walters borough working in particular in relation to the Biggin Hill Airport Limited opportunities created by having Biggin Hill Observation Airport close to the boundary of Croydon, to Agree – Propose Changes ensure that its benefits in terms of employment, flying and leisure activities are fully realised by the borough’s residents and businesses. Some of this can be achieved through existing partnerships, such as SELTRANS and the South London Partnerships plus other specific organisations such as South London Business and the Airport Consultative Committee. Barratt Homes (Kent) asks that the use of The council will follow planning gain and, potentially, the Community government guidance in Barratt Homes (kent) Infrastructure Levy appropriately considers both drawing up the IDP. It will Observation Government legislation and the current incorporate an appropriate Agree - No Action economic climate. Our client would wish to avoid viability assessment. unnecessarily stifling development in the Borough by placing overly onerous financial demands on developers. In this respect it is also important that any S106 contributions are reasonable, based on up-to-date assessments of need, supply, and demand and relate in scale and kind to development proposals. No Specific Chapter Barratt Homes (Kent) supports in principle the The comment is noted. Council’s partnership approach to securing Proposed detail will be Barratt Homes (kent) delivery. It would stress, however, that parts of provided in the delivery Observation the Borough, such as West Croydon, comprise a section of future versions of Noted – Propose Changes complex set of land ownerships and the Core Strategy and the regeneration should not be delayed on those Infrastructure Delivery Plan. sites which are capable of early delivery. Furthermore, PPS12 states that the delivery strategy is central to a Core Strategy. It should show: how objectives will be delivered; when, where, and by whom actions will take place; demonstrate that the agencies/partners necessary for its delivery have been involved in its preparation; and that the resources required have been given due consideration and have a realistic prospect of being provided in the life of the Strategy. These requirements need to be considered in subsequent drafts of Croydon’s Core Strategy. Page140/QuestionPS1 Barratt Homes (Kent) asks that the use of S106 The comment is noted. The contributions and, potentially, the Community Council's detailed policy on Barratt Homes (kent) Infrastructure Levy appropriately considers both Section 106 and CIL has yet Observation Government legislation and the current to be determined. Noted – No Action economic climate. Our client would wish to avoid unnecessarily stifling development in the Borough by placing overly onerous financial demands on developers. In this respect it is also important that any S106 contributions are reasonable, based on up-to-date assessments of need, supply, and demand and relate in scale and kind to development proposals. Barratt Homes (Kent) asks that the use of The council will follow planning gain and, potentially, the Community government guidance in Barratt Homes (kent) Infrastructure Levy appropriately considers both drawing up the IDP. It will Observation Government legislation and the current incorporate an appropriate Noted – No Action economic climate. Our client would wish to avoid viability assessment. unnecessarily stifling development in the Borough by placing overly onerous financial demands on developers. In this respect it is also important that any S106 contributions are reasonable, based on up-to-date assessments of need, supply, and demand and relate in scale and kind to development proposals. page141 Natural England will comment on the The comment is noted. Mr David Sustainability Appraisal as and when it is Hammond submitted. Natural England Observation Noted – No Action page140/para2/bullet2- The possible options for the Council’s approach The support is welcomed. 3 to delivering the spatial strategy include seeking Homes and Communities financial contributions on a case-by-case basis Agency for large developments only, and establishing a Support tariff approach to seeking contributions for all Noted – No Action development in the Borough. In respect of any contributions sought, the HCA notes that these must meet all the tests within paragraph B5 of ODPM (now CLG) Circular 05/2005. The HCA welcomes the case-by-case approach the Council proposes to adopt in respect of large developments, in the context of ensuring the viability of such schemes, and therefore their deliverability. page142 The monitoring of the document is in line with The support is welcomed. Mr David relevant legislation, and similar to other London Hammond Borough’s, no further comments offered. Natural England Support Noted – No Action page139/para2/bullet1 The HCA welcomes explicit reference within the The support is welcomed. delivery section of the consultation document to Homes and Communities the preparation of an Infrastructure Delivery Agency Plan, as required by PPS12. The emphasis on Support securing delivery within the text is also Noted – No Action supported. n/a Are the delivery mechanisms and timescales for The delivery mechanisms and Carmelle Bell implementation of the policies clearly identified? timescales for the delivery of Thames Water Property the key development sites in Observation the borough will be set out in a Agree - No Action future Site Allocations DPD. page140/questionps1 In response to question PS1, the MPA wish to The support is welcomed. support the proposed delivery plan. In particular Metropolitan Police bullet point 4 under the heading 'Possible Authority options for the Council's approach are as Support follows', which highlights that the Council will Noted – No Action work in partnership with other delivery bodies, authorities and agencies, in order to secure the implementation of key infrastructure requirements needed to secure the delivery of the Core Strategy. Introduction Page/Paragraph/ Representation Recommended response Full Name Objective Organisation Nature of Response Officer Recommendation page 8 2. Under the heading of ‘What is this document No action as Section 7 is Amanda for?’n page 8 you mention the first six parts, but mentioned under ` What is the Marshall fail to mention the seventh (‘Delivering a Document for ?`. Alsop Preferred Strategy). Observation Noted – No Action page7/para1 Introduction - The first paragraph of the The timetable will be corrected Ms Alison introduction states that you aim to complete the in future documents Fairhurst production of your Core Strategy by the end of Government Office for 2010. This needs updating to be in line with the London timetable shown on page 9 of the document. Object Agree – Propose Changes n/a 1. Introduction Noted. Nikki Honan HUDU Thank you for the opportunity to comment on the Support issues and options document ‘Imagine Croydon’. Noted – No Action We are pleased to see that the document includes a Health and Well Being section, and considers the wider determinants of health and health care inequalities as well as health care provision. We welcome references in the document to continued joint working with NHS Croydon to further refine the core strategy through the LDF process. This response from HUDU should be read in conjunction with any comments received from the PCT. No Specific Chapter Page/Paragraph/ Representation Recommended response Full Name Objective Organisation Nature of Response Officer Recommendation para 64/questioncc1 In general it is easier to provide the necessary The comment is noted. Christopher infrastructure for a small number of clearly Colloff defined sites rather than a large number of ThamesWater smaller sites. However, drainage areas do not fit Observation neatly over local authority boundaries and Noted – No Action therefore we also need to consider neighbouring boroughs ambitions as well as taking into account of proposed development within Croydon. The only other thing to sound a warning bell on The risk is noted. The Council Amanda is the issue of wearing people out with ongoing has considered this and Marshall consultation processes. Our Third City project combined the consultation on Alsop built constructively on the previous 20/20 Vision Imagine Croydon with this Observation work, but to go through another consultation document's consultation. Noted – No Action process so soon may beg the question, How many times am I (an ordinary citizen of the borough of Croydon) expected to engage in imagining the perfect future for my town? Bear in mind that ImagineCroydon is also now under way. There is a section of MOL land at love lane se25 The document recognises the leadbeaterian@a that the council sold off this should now be important role that urban ol.com brought back into public ownership and again agriculture can play within a food production . There should also be available sustainable community and Observation the provision of "panier" markets for local grown the future Site Allocations Noted – No Action food say produced in croydon or surrounding 25 DPD will consider suitable miles The site next to summerfield in South sites and the use of food as a Norwood may be used and it would be just local source of methane/energy will people selling there own or allotment produced be considered in the Joint food with pitches at a nominal fee !The other Waste DPD. side to growing more food is to use less and perhaps there should be a collection service from all the major supermarkets of unsold food that can be re entered into the food chain or composted via a methane plant into valuable energy the waste heat into hot houses and the waste then back to the land.Whilst there is a need for increased allotment space with in croydon there should also be some thought given to the provision of "city plots" these would be growing beds deep dug measuring just 12ft x 5ft these srrounded by a path would be the most productive sized plots to grow food on in an intensive way especialy if the hight dimention was used . The traditional plot was designed with traditional crops and staples in mind however the new vegatables can be grown more intensivly and in shallower containers . in addition a city plot can be made using a raised bed system so would be suitable for a disabled person and as it is not walked on only requires a trowel and hand fork to manage . No mention of services for the elderly The comment is noted. The particularly support services provided by infrastructure needs Pauline Morant voluntary organisations e.g. Helping Hand and associated with the Core Observation the provision of transport for elderly people. Strategy will be considered by Noted – No Action the Infrastructure Delivery Plan which will be developed alongside the Core Strategy. page62/para7/bullet7-9 I would like to take the opportunity to make the The comment is noted. Details Christopher following comments in relation to the provision of of the potential locations and Colloff water and sewerage infrastructure. The amount of new homes will be ThamesWater provision of new development will increase the set out in the next consultation Observation pressure on the existing water and sewerage draft of the Core Strategy. The Agree – Propose Changes infrastructure and is likely to result in the need infrastructure needs for network upgrades and potentially additional associated with the Core infrastructure. The infrastructure requirements Strategy will be considered by cannot be established without having greater the Infrastructure Delivery details of the location and amount of Plan which will be developed development proposed and as such should you alongside the Core Strategy. have further information on potential locations for new development together with details of approximate numbers of units we would welcome this information in order to model the impacts on the existing network and provide greater information on the need for upgrades. Should you have such information available Thames Water would be pleased to meet with you to discuss the infrastructure issues further. n/a Keep up your good work The support is welcomed

Observation Noted – No Action n/a First may I say how much better Croydon is, in This comment relates to the so many ways, now that it is controlled by the political governance of Conservatives. Croydon Council and cannot Observation be considered by the Core No Action – Not an LDF Is Strategy. para 64/questioncc1 Where capacity does not exist to serve The comment is noted. Work Christopher development it is essential that it is provided on developing the Colloff ahead of development if internal flooding of Infrastructure Delivery Plan ThamesWater property and pollution of the environment is to will address issues such as Observation be avoided. It is important not to under estimate this. Development proposals Noted – No Action the time required to deliver necessary will be subject to national infrastructure, for example: policy in the form of PPS 25. - local network upgrades take around 18 months - Water and Sewage Treatment Works upgrades can take 3-5 years - New treatment works and reservoirs can take 8-10 years In conclusion, this absolute mass of information The comment is noted. Amanda is going counter to your aim. Understandably Marshall you want people to answer the questions in the Alsop light of various key issues, but a massive Observation reduction is necessary if you want to get any Noted – No Action seriously useful or insightful feedback. This can all be put back later having been tuned to the wishes and suggestions of the public. On the basis of the above comments, we The comment is noted. Amanda suggest that whilst keeping your chapters (your Marshall list of headings), you should keep back 80% of Alsop the information until after the first public Observation consultation results have been gathered in. Noted – No Action para 64/questioncc1 Water and sewerage undertakers also have This is too detailed for the Christopher limited powers under the water industry act to Core Strategy. It will be Colloff prevent connection ahead of infrastructure considered in a future ThamesWater upgrades and sewer flooding can be caused Development Management Observation when developers make connections to the DPD. Noted – No Action existing sewerage network without proper consultation and authorisation from the relevant water company. We therefore rely heavily on the planning system to ensure infrastructure is provided ahead of development either through phasing or the use of Grampian style conditions. Thames Water would therefore seek positively worded conditions to assist with ensuring that any required water and sewerage infrastructure is in place before developments are occupied. para 64/questioncc1 It is our understanding that Section 106 This will be considered in the Christopher Agreements and the proposed Community Infrastructure Delivery Plan Colloff Infrastructure Levy cannot be used to secure which will include delivery ThamesWater water and waste water infrastructure upgrades. mechanisms. Observation However, it is essential to ensure that such Agree - No Action infrastructure is in place to avoid unacceptable impacts on the environment such as sewage flooding of residential and commercial property, pollution of land and watercourses plus water shortages with associated low pressure water supply problems. page22/para6 Growth within the Borough is not the only driver The comment is noted. Christopher for new water and sewerage infrastructure and Colloff additional infrastructure may also be required in ThamesWater order to comply with new consents and Observation obligations such as environmental quality Noted – No Action improvements; enhancing service through the reduction in the number of properties at risk of sewer flooding; and enhancing service through the reduction of odour at sewage treatment works. n/a 2. Soundness Noted. Nikki Honan HUDU The Planning and Compulsory Purchase Act Observation 2004 requires all Development Plan Documents Noted – No Action (DPDs) to be “sound”. Planning Policy Statement 12: ‘Local Development Frameworks’ (2008) confirms that a DPD must:

• Be based on robust evidence base;

• Show how it positively impacts on the health of the community in a locally distinctive and spatial manner and have regard to the health service plans, policies and strategies;

• Show how it will deliver the aims of the Sustainable Community Strategy;

• Show how it is general conformity with the London Plan; and

• Have clear mechanisms for implementation and monitoring. n/a Minerva welcome the opportunity of participating The comment is noted. in this early stage in the development of the Minerva Core Strategy, part of Croydon’s Local Observation Development Framework. Noted – No Action n/a Equally, detailed consultation must take place The comment is noted. Mr Robert with landowners and other stakeholders to Posselt ensure deliverable masterplans, concept Martin Robeson Planning statements, planning briefs and the OAPF are Practice developed. It is critical that all stakeholders hold Observation the same vision as the Council. Failure to Agree - No Action achieve this will jeopardise the implementation of the relevant visions/strategies. n/a I found the document easy to read and made The support is welcomed. Ms Alison good use of plans and diagrams. Fairhurst Government Office for London Support Noted – No Action n/a Our client would wish to highlight that, in order to The comment is noted. be justifiable, Development Plan Documents Barratt Homes (kent) (DPDs) should be founded on a robust and Observation credible evidence base. Noted – No Action n/a 3. Conformity for the LDF to be judged sound it Noted. Nikki Honan must: HUDU Observation • Be in general conformity with the London Plan; Noted – No Action • Give spatial interpretation to health service plans, policies and strategies; and

• Deliver the aims of the Sustainable Community Strategy. n/a Having lived in Croydon for the past 25 years I The support is welcome. Miss Jean am pleased to be living in such an innovative Newman borough and look forward to the interesting and exciting times to come in 2010. Support Noted – No Action In other words, it is not clear exactly what this The comment is noted. There Amanda massive document is. At first it seems as if it’s a is a procedure to follow , as Marshall first shot at the Core Strategy, which you say it per PPS12. Alsop will take 3 years to complete. But if you have Observation already knocked it into this kind of fully-crafted Noted – No Action piece of writing, how can it take a further 3 years to complete? Sustainability Croydon is the 12th safest borough of all the The comment is noted. Cheryll Wright Appraisal Page 48 London Boroughs – therefore the statement: Safer Croydon Partnership Rates of crime in Croydon are slightly higher Observation than those in London is incorrect Noted – No Action We would suggest that you need to follow a The comment is noted. Amanda procedure which starts from a position of not Marshall having any pre-conceived ideas, ie your minds Alsop are totally open and waiting to be filled with the Observation views of Joe Public. Then is the moment, with Noted – No Action those views received and recorded, for you to prepare your first draft, written in direct response to the public’s views. That draft would then be presented back to the same public forum for their further comment. Make the remaining information snappy, The next iteration of the Core Amanda accessible - something that people are actually Strategy will make more use Marshall going to read. For instance, on page 10 you talk of diagrams /sketches to Alsop about ‘data’, ‘census’, percentages, BME address this concern. Observation communities. This is difficult information to Agree – Propose Changes absorb even if people have the basic knowledge to understand it (doubtful). There are also similar parades in this area , it is Noted. The comment on leadbeaterian@a also worth thinking that with the requirment to carbon footprint relates to the ol.com reduce our carbon footprint by 80% in just 40 Core Strategy. However the years we need to be very selective of the quality remaining content of this Observation of "old" properties that are retained as these are comment is a level of detail Noted – No Action difficult to insulate to achive this standard and if not appropriate for a Core we fail it will be something move valuable than Strategy. A development any building that will be lost. Portland rd management DPD will however fails to work . Take for instance noz 1- consider this detail for new 47 whilst in an area designated a conservation developments. area , it fails to meet any of the criteria . There is little to conserve , some of the shops are simply bricked up one is in a dangerous state of repair ,others have been converted into poor quality residential use virtualy none retain any original features . Yet with a little planning it could all be so different . Most of the units are two storey units with a flat roof shops on the front and a rear garden. . By taking back the building line to the two story part and increasing the building foot print developing to three stories with a dormer a 14ft deep frontage to portland rd would be obtained for communial planting with trees creating a unique development and transforming the area . This would also create a large number of new housing stock of high standard. Portland rd is a unique development oportunity in Croydon . being an ecliptic mix of properties styles and uses. Portland rd is a unique development oportunity in Croydon . being an ecliptic mix of properties styles and uses. Staying with the same subject of accessibility, The Council will seek to be Amanda you ask several questions at the end of some of consistent in tis approach. Marshall the chapters, but not at the end of others. We Alsop suggest that you ask questions at the end of Observation each chapter and make them easily engaging Agree – Propose Changes rather than like a tough piece of homework, which people are not realistically going to engage with in their lunch hour or after a hard day at work. These are two sensible, clear and The information contained in Amanda straightforward questions, which most people the Place Section is not Marshall will have a view on. Whilst the first five Parts exhaustive or a `done deal` Alsop deal with the broader issues that the first but attempts to illustrate Observation question addresses, the penultimate Part deals spatially the issues and Disagree – No Change with each of the 16 ‘places’ you have identified. options. These could afford to be left as slightly lengthier than the others as each person will be intensely interested in their own particular ‘place’. It is our view that they should still not be nearly as long as they are at present, as this gives the unmistakable impression that the whole thing is a done deal and that the public consultation is merely lip-service. On a more prosaic level, Agreed. Greater consistency Amanda will be sought. Marshall 1. We’d suggest that you keep the same Alsop chapter headings that you start with at the Observation beginning of the document. Ie ‘Overview’ should Noted – Propose Changes not be changed to ‘Setting the Scene’ or vice- versa, and so on. n/a Is this, This is a Consultation Amanda a) A Consultation Document which is asking for Document which is asking for Marshall feedback on the draft Core Strategy? Or is it, feedback on the draft Core Alsop b) A Consultation Document asking the public Strategy and asking which is Observation two simple questions, and giving them this mass the preferred option for growth. Noted – No Action of information so that they can more readily answer them? We refer to the proposed LDF. The support is welcomed. Mr Paul Gardner

At the outset, we would like to say that we think Support that this is a very positive process and we are Noted – No Action pleased that Croydon Council are taking a holistic and long term approach towards its planning policies. n/a We therefore set out below a number of The comment is noted. comments on the Core Strategy Issues & Minerva Options – Initial Report. This follows the order in Observation the report and includes responses to a number Noted – No Action of the specific questions raised. n/a The workshops have found that, commonly, The comment is noted. emerging core strategies: Commission for Architecture and the Built - need to set out the vision and the strategy Environment more clearly, too often focus on policies rather Observation than the strategy Noted – No Action - need to focus on how to make places work better - lack maps, diagrams and photos to illustrate the strategy, best practice or to key features of the local area. Environment: -Town centre –Residential areas The next iteration of the Core Revd Charles –Public realm Strategy will set out in more Trefusis detail the quantum and type of Purley & Kenley Matters arising during discussion: Again, the homes growth expected in the Neighbourhood meeting demanded that the town centre should area. Partnership provide a quality environment and the public Observation spaces properly maintained by the council. It Noted – Propose Changes was suggested that the Council should have the power to designate areas as family areas to prevent unsuitable developments of high density flats in roads which are made up of family houses. Some delegates thought that this might cause problems that the consensus was that this was a good idea. More green areas were required.

Consensus: Town centre and public realm should provide a quality environment and be properly maintained. The ability for the council to designate roads/areas as family areas was a good idea and more green space was required. Parking: Residential: -Enough for additional new Noted. This is a level of detail Revd Charles homes? -Off street: maintain multi-storey car not appropriate for a Core Trefusis park capacity? -On street? -Commuters? Station Strategy. A development Purley & Kenley car park? management DPD will Neighbourhood consider parking provision in Partnership Matters arising during discussion: It was agreed new developments. Observation that Purley’s parking provision was inadequate. Noted – No Action It was also unrealistic to build new housing without any or inadequate parking. Off-street parking capacity should be at least be maintained but preferably increased. There was some discussion about the railway station car park which was thought could be extended by making it multi-storey. Park-and-ride was also discussed and apart from where you would put any park and ride facility it was thought that this facility would be better provided at Merstham. Provision of free on-street parking was discussed. Suggested that this had to be limited time period in order that shops and shoppers could benefit.

Consensus: More parking, both off-street and on (with say 30 minutes free parking) was required. No park-and-ride. Council should ensure that new residential developments had proper parking provision. n/a Thank you for consulting the Commission for The comment is noted. Architecture and the Built Environment (CABE). Commission for Architecture and the Built Unfortunately, due to limited resources, we are Environment unable to comment on this document. However Observation we would like to make some general comments Noted – No Action which you should consider. A good spatial plan is essential to achieving high quality places and good design. CABE believes that getting the local development framework core strategies right is one of the most important tasks planners are undertaking.

We have run workshops with over 50 local planning authorities to look at how well design is being embedded in core strategy documents, which form part of the local development framework. The workshops offer local authorities independent informal advice from an expert panel and allowed us to identify the strengths and weaknesses of current approaches to spatial planning and how design, functionality and space are dealt with in core strategy documents Public transport: Trams? Railway? Buses? The comment is noted. Revd Charles Following a transport study, Trefusis Matters arising during discussion: It was agreed the next iteration will set out Purley & Kenley that the railway was working at capacity in rush more detailed policies on Neighbourhood hours. Any move to extend trams to Purley was transport. Partnership likely to increase road congestion down the Observation A235 corridor - a vote was taken about this and Noted – Propose Changes there was a slim majority against extending trams to Purley. It was also pointed out that bus links between the London borough of Purley and Sutton were poor and east-west public transport should be improved with better integration of Croydon and Sutton buses. If there was to be expansion of the tram network, east-west links might be a useful benefit.

Consensus: More capacity needed on trains in rush hours, better east-west public transport required, improved integration of bus services between Purley and Sutton. Green space: Parks, green space? Trees? The concept of the `green Revd Charles grid` will be developed further Trefusis Matters arising during discussion: Purley is in The concept of the `green Purley & Kenley already poorly resourced in terms of green grid` will be developed further Neighbourhood space and play space. It was pointed out that in the next iteration of the Partnership some new green space was of poor quality and Core Strategy. Observation little use. Noted – Propose Changes Consensus: Important that there is more high quality public green space and play space and more trees. n/a The Mayor will issue his formal opinion on The comment is noted. Mr Michael general conformity when requested at the pre- Mulhern submission stage. However, I hope that the Greater London Authority policy concerns raised at this current stage can Observation be resolved before then, through further informal Noted – No Action discussions with Council officers. High Street –Pedestrianise? (Market, events?) Noted. This is a level of detail Revd Charles not appropriate for a Core Trefusis Matters arising during discussion: The meeting Strategy. Purley & Kenley took a vote on pedestrianising the High Street, in Neighbourhood which a majority declared in favour - but Graham Partnership Bass pointed that there could be a third option Observation which would be to pedestrian-prioritise the High Noted – No Action Street, whereby vehicles could drive through it/park, but at low speed. This was considered to be an option worth considering.

Consensus: See discussion above. Prevent back land developments – Loss of The Council will resist Revd Charles gardens, local character damaged etc. inappropriate development of Trefusis back gardens. Purley & Kenley Matters arising during discussion: It was thought Neighbourhood to be difficult to prevent all infill / back land Partnership developments. Observation Agree - No Action Consensus: The council must be able to provide proper controls to ensure that any back land development is sustainable, of high design quality and does not over-develop the site and is appropriate for the area (see 16 above family areas). Pedestrian access and links within centre: - Noted. This is a level of detail Revd Charles Station/High St/Brighton Rd/Russell Hill? - not appropriate for a Core Trefusis Railway? Strategy. However the Council Purley & Kenley accepts that through the Neighbourhood Matters arising during discussion: Current links development of key sites in Partnership between the High Street and the station needed Purley pedestrian access may Observation improving as did links between the High Street be improved. Noted – No Action and Brighton Road. There was also a requirement to improve pedestrian access over the railway line, which has now been considerably worsened with the installation of barriers at Purley station. The meeting also discussed cycle routes and said that current bike parking at the station was inadequate.

Consensus: Improved pedestrian access over the railway was required. An additional link between the High St and Brighton Rd was required. The pedestrian link between the station and the high street should be improved. (Current one is considered unpleasant with blind corners and unsafe). Also improved pedestrian accessibility is required to ease foot access from Russell Hill end of town. Anything else? Noted. This is a level of detail Revd Charles not appropriate for a Core Trefusis There was some discussion about 20 mph limits. Strategy. Purley & Kenley A vote was taken and 20mph limits in general Neighbourhood terms were not considered desirable. It was Partnership pointed out that current 20mph limits around Observation schools are appropriate during term time but not No Action – Not an LDF Is during holiday time. The meeting thus agreed that where 20mph limits are in place, they should only apply at specific times. Traffic congestion: -Improve Purley Cross and The Council recognises that Revd Charles Russell Hill Road? -Need convincing traffic measures to address transport Trefusis analysis to prove what’s best? deficiencies are needed Purley & Kenley before significant homes Neighbourhood Matters arising during discussion: It was pointed growth can be achieved. Partnership out that there were a number measures that Observation could be taken to improve traffic flows around Noted – Propose Changes Purley. The current congestion situation in the town was such that something must be done sooner rather than later to alleviate this. The meeting was also reminded that among the many past previous suggestions for the Purley Cross scheme was a tunnel.

Consensus: It was agreed that proper traffic analysis was needed in order to achieve a sustainable, efficient solution to the Purley Cross road situation. A tunnel for through traffic would be an appealing long term solution. . Community infrastructure (NB 4 above): -Main Noted. This is a level of detail Revd Charles priorities (schools, health centres, leisure etc)? not appropriate for a Core Trefusis Strategy. The future of the Purley & Kenley Matters arising during discussion: multi storey car park site will Neighbourhood be considered in the Site Partnership Discussion centred on the Sainsbury’s High Allocations DPD. Observation Street site and multi-storey car park. It was Noted – No Action thought that the existing multi-storey was structurally acceptable and that the old Sainsbury’s store site could be developed to provide a suitable mix of facilities/library/retail etc. It was pointed out that transport links to the hospital site were not good if you were disabled and relying on public transport. The facility of the pool should be retained, public conveniences were needed, improved library facilities were wanted, the need for a cinema was not discussed but would be beneficial, if it was commercially viable. It was pointed out to the meeting that the head lease of the Sainsbury’s site was now owned by an overseas-based developer so it will be more difficult to influence how the site is ultimately redeveloped.

Consensus: Before there is more development, the town wants improved car parking, public play space/green space, as well as improved leisure, health and educational resources. The meeting was that we are not happy with the current state of the multi-storey car park, but do not want to loose any of its car parking capacity – and want to at least maintain the total available car parking capacity in the town. 7. Retail: what do we want? - More? Different? Noted. This is a level of detail Revd Charles Complement Tesco? -Tesco is here to stay not appropriate for a Core Trefusis Strategy. A development Purley & Kenley Matters arising during discussion: It was pointed management DPD will include Neighbourhood out to the meeting that the retail sector had retail policies aimed at Partnership changed and consumer expectations were such achieving a balanced mix of Observation that small grocers, greengrocers, fruiters, retail offer. Noted – No Action butchers etc were not now viable in Purley due to the proximity of Tesco and Purley’s proximity to Corydon’s retail centre meant that many other small retailing enterprises in the town would also be unviable. What the meeting did think was important was that for any successful retail/commercial heart in Purley, the town had to offer the amenities (transport links, parking, attractive environment) to attract retail and commercial businesses to the town.

Consensus: The town would benefit from more specialist retail outlets, to reflect the wealth of the area and its consumers, to complement those offered by Tesco. 6. What business, industry, employment do we The council notes the Revd Charles want to encourage in facilitating expansion? comment in support of Cane Trefusis Hill for Purley & Kenley Matters arising during discussion: Generally commercial/technological Neighbourhood agreed that commercial developments should industries. The next iteration Partnership include offices and technology-based industries. of the Core Strategy will set Observation Manufacturing per se was not ruled out but it out in more detail the level of Noted – Propose Changes was thought that heavy industry in the Purley jobs growth expected in the area was not practical or desirable. It was area. mentioned that the old Cane Hill site would be an ideal site for much-needed commercial/technological industries for new local jobs.

Consensus: Meeting agreed that clean commercial and technical operations were beneficial. 5. High rise vs families? 25 per cent affordable The council agrees on the Revd Charles housing? point of sustainable design. Trefusis Affordable housing target will Purley & Kenley Matters arising during discussion: It was pointed be considered in the next Neighbourhood out to the meeting by the better-informed in the iterion of the Core Strategy Partnership audience that Government requirements for and will be informed by a Observation affordable housing is currently at levels of 40/50 viability assessment. Noted – Propose Changes per cent, so it was highly unlikely that Purley could demand lower levels of affordable housing. Tarsem Flora pointed out that developments of 14 housing units or less were exempt from an affordable housing requirement.

Consensus: Meeting was against high rise developments and once again stressed that both private and affordable housing developments should be sustainable and of good design. To retain the character of the area, a limit of say 25% Affordable Housing would be appropriate. Willingness to trade additional housing for The forthcoming Infrastructure Revd Charles improved infrastructure. Delivery Plan will set out the Trefusis infrastructure requirements Purley & Kenley Has to be paid for by a developer – there is no and their delivery mechanism. Neighbourhood money from the Council or central Government. Partnership Observation Matters arising during discussion: There was Agree – Propose Changes some concern about taking money from developers but it was pointed out to the meeting that if some development was inevitable (see 1. above) then it would be better take Section 106 money from developers to improve facilities.

Consensus: Croydon Council should ensure that S106 money is spent within the area and also that new public facilities are provided either ahead of or at the same time as new housing developments are put in place. 3. Flood risk implications (A23 Kenley Bourne)? The Council recognises that Revd Charles flood amelioration methods Trefusis Matters arising during discussion: Flooding was are needed before significant Purley & Kenley agreed to be a long-term Purley problem and homes growth can be Neighbourhood climate change was liable to make it worse. achieved. Applications for Partnership development in flood zones Observation Consensus: No further development should be shall be subject to national Agree – Propose Changes permitted in flood risk areas before effective anti- policy in the form of Planning flood solutions are put in place. Policy Statement 25. 2. Dispersed or concentrated growth or a The comment is noted. The Revd Charles combination? next iteration will consider a Trefusis modified spatial strategy to Purley & Kenley Matters arising during discussion: After some ensure growth is sustainable Neighbourhood discussion it was clear that the meeting was not and is likely to feature Partnership certain of the definition of concentrated or elements of the dispersed Observation dispersed. Tarsem, with the aid of a slide from gorwth and concentrated Noted – Propose Changes the Imagine Croydon presentation, explained growth options. that ‘concentrated’ growth meant growth that runs in a corridor along the A23 through the Borough and Croydon town centre, and ‘dispersed’ meant out to places like Kenley, Sanderstead, Selsdon etc.

Consensus: Majority voted for dispersed. Imagine Croydon Feedback notes from special The comment is noted. The Revd Charles meeting of next iteration will consider a Trefusis modified spatial strategy to Purley & Kenley Purley & Kenley Neighbourhood Partnership on ensure growth is sustainable. Neighbourhood October 13 2009 Partnership Observation In attendance: Revd. Charles Trefusis Noted – Propose Changes (chairman), Cllrs. Graham Bass & Donald Speakman + approx 45 residents (including a minority from out of area (Waddon/Coulsdon/South Croydon)

Background: Charles Trefusis thanked Ken Trench and Tarsem Flora for their help in making the meeting possible. He told the meeting that there was currently no money available from the council/central government for many improvements in Purley. To aid the discussion process he had prepared a number of points to discuss. The notes below are the result of the discussion these points raised. 1. Population and housing growth. What is acceptable/desirable? Main considerations/constraints

Matters arising during discussion: Important to retain Purley’s character; quality of new development to be sustainable and of good design; strong view that Purley was already over- populated and existing facilities (roads, health, education, green space, parking etc) were inadequate.

Consensus: Though many attending the meeting would have preferred no population growth/development, the majority accepted that some population growth/development was inevitable, but should be sustainable, limited to no more than 20 per cent of current population and to take place gradually over, say, the next 20 years. n/a Thank you for your letter 1 August 2009 The comment is noted. Mr Michael consulting the Mayor of London on the draft Mulhern Issues and Options stage of Croydon Council’s Greater London Authority Core Strategy Development Plan Document Observation (DPD). As you are aware, all development plan Noted – No Action documents have to be in general conformity with the London Plan under section 24 (1)(b) of the Planning and Compulsory Purchase Act 2004.

The Greater London Authority welcomes the opportunity to comment on this draft Issues and Options Core Strategy, however, given that it is still in an early stage of preparation the document has been reviewed at officer level only. This letter sets out those areas where further discussions may be required to ensure this Core Strategy complies with London Plan policy. n/a The following representations amplify the The comment is noted. previous comments made in respect of the Metropolitan Police MPA's objectives across the Borough. Authority

Observation Metropolitan Police Estate - Asset Management Noted – No Action Plan London Borough of Croydon. The need for additional policing facilities is highlighted in the Metropolitan Police Authority's Asset Management Plan for the London Borough of Croydon and gives a summary of police requirements in the Borough. n/a 47. Crime should be tackled by coordination Noted. This is a level of detail Mr David Walker between the licensing and planning arms of not appropriate for a Core Crystal Palace Triangle Croydon council, and cooperation between Strategy. Planning Group Croydon and Lambeth. Observation Noted – No Action n/a Also, some of the issues covered within these The comment is noted and Ms Alison sections may be more appropriate for lower level agreed. Fairhurst development plan documents, for example Government Office for Urban Agriculture. The Planning Inspectorates London ‘Examining Development Plan Documents: Observation Learning from Experience’ says that “The core Agree – Propose Changes strategy should focus relentlessly on the critical issues and the strategies to address them. Too many core strategies resemble local plans or Unitary Development Plans (UDP) in that they seek to address a full range of topics irrespective of whether these topic areas contain critical issues that relate to the way the area is intended to develop. So, for example, there is little need for any detail on matters such as tourism if the area is not one where tourism is an important consideration.” n/a The following comments focus on two matters. The comment is noted. Mr John Escott Firstly, the general question of options for Robinson Escott Planning growth and whether this should be ‘dispersed’ or Observation a ‘concentrated growth corridor’. Secondly, and Noted – No Action bearing in mind the comments in relation to options for growth, more specific comments relating to South Norwood and Woodside and the potential spatial options for land at Love Lane. n/a Sections 3 to 5 cover place themes. At the end The comment is noted. The Ms Alison of each of these themes are a set of options. infrastructure needs Fairhurst How do these relate to the two strategic options associated with the Core Government Office for of dispersed growth and concentrated growth? I Strategy will be considered by London would be interested to see how you plan to take the Infrastructure Delivery Observation the results of these options forward in the Plan. Noted – Propose Changes development of your spatial strategy for the borough n/a Subsequent to the granting of this consent, your The comment is noted. Council agreed a compulsory purchase order to Minerva allow as necessary the compulsory acquisition Observation under the terms of the CPO of those remaining Noted – No Action interests required to undertake the Park Place scheme. n/a The HA is an executive agency of the The comment is noted. Department for Transport (DfT). We are Highways Agency responsible for operating, maintaining and Observation improving England’s motorway and all-purpose Noted – No Action trunk road network, collectively known as the Strategic Road Network (SRN), on behalf of the Secretary of State for Transport. n/a We have also attached some key questions that The comment is noted. we use in the workshops for you to consider Commission for throughout the development of your Core Architecture and the Built Strategy document. Environment

Observation You might also find the following CABE Noted – No Action Guidance helpful.

“Making design policy work: How to deliver good design through your local development framework”

“Protecting Design Quality in Planning”

“Design at a glance: A quick reference wall chart guide to national design policy”,

“By Design: urban design in the planning system towards better practice “ (published by DETR) n/a There are three core messages for local The comment is noted. planning authorities that have emerged from our Commission for workshops. Architecture and the Built Environment Tell the story Observation Noted – No Action A good core strategy needs to tell the story of the place, explain how it works and highlight its qualities and distinguishing features. Telling the story helps everyone understand how change will be achieved.

Say what is wanted

Use the core strategy to set the agenda, express aspirations and be proactive and positive about the future of the place and say how to achieve this. Set out what you expect in terms of design quality and back this up with hooks to other development plan documents and supplementary planning documents.

Say it clearly

Make the core strategy relevant and comprehensible to a wide audience. Use diagrams at the start of the process to inform the text and communicate the strategy. n/a CB Richard Ellis are planning consultants to The comment is noted. Minerva Plc on whose behalf these comments Minerva are submitted in response to your invitation to Observation stakeholders to respond to your recently Noted – No Action published Core Strategy Issues & Options – Initial Report. I have read with interest your leaflet on the Your comment is noted. Peter Williams future of Croydon and I share your conviction that Croydon has the potential to be a great city. Observation Noted – No Action n/a I write on behalf of our client the Metropolitan The comment is noted. Police Authority (MPA) with regard to the above Metropolitan Police document. The MPA provide a vital community Authority service to the Borough of Croydon and policing Observation is recognised within the 2008 London Plan as Noted – No Action being an integral part of social infrastructure. Acknowledging this strategic policy context, representations have been made on several occasions to previous Croydon LDF documents, including the Croydon Metropolitan Area Action Plan and more recently representations to the Core Strategy & Site Specific Allocations DPD, Sustainability Appraisal Scoping Report which were submitted on 21 January 2009. n/a 48. CCTV cameras should be used to target Noted. This is a level of detail Mr David Walker crime on the streets. not appropriate for a Core Crystal Palace Triangle Strategy. Croydon's Crime Planning Group Reduction Strategy considers Observation this. Noted – No Action n/a Context to Representations The comment is noted. Metropolitan Police The MPA made representations to the Core Authority Strategy Sustainability Appraisal Scoping Report Observation on 21 January 2009 (letter attached) and Noted – No Action highlighted their desire to be included as a Key Stakeholder. It was also recommended that the provision of future policing facilities be well recognised within the Core Strategy. In addition, the MPA have submitted representations to a number of other consultation documents including; • Draft Statement of Community Involvement (SCI) on 20 April 2006;

• Croydon Metropolitan Centre Area Action Plan– Sustainability Appraisal Scoping Report on 13 March 2007;

• Identifying Future Development Sites 10 December 2007; and

• Metropolitan Centre Area Action Plan on 11 April 2008. n/a Mindful of this background, a number of The comment is noted. representations are hereby set out. Firstly I Metropolitan Police outline the brief policy context supporting our Authority representations, followed by an outline of the Observation MPA's objectives for the London Borough of Noted – No Action Croydon. Finally I set out our representations to a number of points raised in the draft Core Strategy which follows on from previous representations made to the Sustainability Appraisal Scoping Report. page61/para1/bullet1-2 I am sure this will also help raise profile of The comment is noted. Muhammad Ali adaptation to climate change and the council’s environmental and response to NI 188. sustainability team Observation Noted – No Action page102-104/purley We write on behalf of the London Fire and The comment is noted. Emergency Planning Authority to submit London Fire and representations to the London Borough of Emergency Planning Croydon Core Strategy Initial Report Authority consultation (CS) which was recently published Observation for consultation. Noted – No Action London Fire and Emergency Planning Authority (LFEPA) runs the London Fire Brigade (LFB) and operate 111 land fire stations located across Greater London.

Five of these stations are located within the London Borough of Croydon (Croydon) as detailed below:

1. Addington: 197-199 Lodge Lane, CR0 0QA

2. Croydon: 90 Old Town, CR0 1AR

3. Norbury: 1321/1325A London Road, SW16 4AU

4. Woodside: 2 Long Lane Addiscombe Road, Croydon, CR0 7AL

In addition, the LFB is seeking to improve the following fire station on site:

5. Purley: 128 Brighton Road, CR8 4DB n/a Thank you for allowing me the opportunity to The comment is noted. Mr I.G.M. Hunter comment on this, very extensive, and worthy paper. Observation Noted – No Action n/a Advice on sources of evidence was contained The comment is noted. Carmelle Bell within the 2005 Inspectorate guide to the Thames Water Property process of assessing the soundness of Observation Development Plan Documents which preceded Noted – No Action the 2008 guide. Key sources of evidence identified within the 2005 guide included:

“ Evidence - Of particular significance, will be representations from bodies that consider that the DPD either does or does not have sufficient regard to other relevant strategies for which they are responsible”. n/a Although the Inspectorate guide does not refer The comment is noted. Carmelle Bell to sources of evidence, paragraph 4.49 of Thames Water Property PPS12 acknowledges that “This revised PPS12 Observation presents “tests of soundness” in a different and Noted – No Action more simple way based on the fact that the Planning and Compulsory Purchase Act 2004 distinguishes between the legal requirements and the determination of soundness. However the rigour of the examination process remains unchanged and inspectors will be looking for the same quality of evidence and content.” n/a Is it clear who is going to deliver the required The forthcoming Infrastructure Carmelle Bell infrastructure and does the timing of the Delivery Plan will set out the Thames Water Property provision complement the timescale of the infrastructure requirements Observation strategy/policies?” and their delivery Noted – No Action mechanism/timing. n/a In relation to whether the Core Strategy is The comment is noted. Carmelle Bell effective and therefore ‘sound’ the most relevant Thames Water Property key questions set out in the Inspectorate guide Observation are: Noted – No Action “Key Questions:

- Does the DPD explain how its key policy objectives will be achieved? n/a 24. Croydon’s UDP explains that the The comment is noted. Mr David Walker opportunities for redevelopment at higher Crystal Palace Triangle densities are likely to be greatest in the Croydon Planning Group Metropolitan Centre and the Town Centres with Observation opportunities for major refurbishment at least Noted – No Action with some extensions, in the four District Centres and more modest refurbishment schemes/extensions in the Local Centres. Croydon Metropolitan Centre and the Town Centres have most potential for redevelopment schemes for shops and other main town centre uses (such as offices and leisure facilities) with the potential more for refurbishment schemes in the District and Local Centres.