Steve Dennington Department: Planning Spatial Planning Our reference: LDF08/LDD08/CG01 Croydon Council Date: 21 January 2020 6 th floor, Zone B Bernard Weatherill House 8 Mint Walk Croydon CR0 1EA Sent by email to: [email protected] Dear Steve Planning and Compulsory Purchase Act 2004 (as amended); Greater London Authority Acts 1999 and 2007; Town and Country Planning (Local Development) (England) Regulations 2012 RE: Croydon Local Plan Review Issues and Options (Regulation 18) 2019 Thank you for consulting the Mayor of London on Croydon’s Local Plan Review Issues and Options Document. As you are aware, all development plan documents must be in general conformity with the London Plan under section 24 (1)(b) of the Planning and Compulsory Purchase Act 2004. The Mayor has afforded me delegated authority to provide comments on the emerging Local Plan on his behalf. Transport for London (TfL) has provided comments, which I endorse, and which are attached as Annex 1. The draft new London Plan As you know, the Mayor published his draft new London Plan for consultation on 1st December 2017. The Panel’s report, including recommendations, was issued to the Mayor on 8th October 2019 and the Intend to Publish version of the London Plan was published on the 17th December 2019. Publication of the final version of the new London Plan is anticipated in March 2020, at which point it will form part of Croydon’s Development Plan and contain the most up-to-date policies. Croydon’s revised Local Plan will be required to be in general conformity with the new London Plan. The draft new London Plan and its evidence base are material considerations in planning decisions. Strategic Spatial Options The Mayor welcomes the strategic review Croydon is undertaking in order to meet its new housing target. Overall, he is supportive of the key aims of the three strategic options. In line with the draft new London Plan (Intend to Publish version), the Mayor would welcome development in line with Strategic Spatial options 1 and 2. With regards to Option 2, the Mayor City Hall, London, SE1 2AA ◆ london.gov.uk ◆ 020 7983 4000 would welcome a better understanding of how approximately 12,000 homes could be delivered along the Purley Way without impacting the industrial functions of the Purley Way Strategic Industrial Locations (SIL). In this regard, it is noted that Croydon’s housing target has decreased significantly from 29,490 homes over 10 years in the 2017 version of the draft Plan to 20,790 in the Intend to Publish version of the Plan and therefore development around the Purley Way SIL should not impede the long term functioning of the SIL. The Mayor’s Housing and Land team are currently working with your officers to inform the capacity of the Purley Way area, along with TfL to understand the transport requirements. The potential housing capacity that could be delivered in the Purley Way area should be informed by this capacity work, and subject to further discussion with the GLA and TfL. The draft new London Plan policy H1 places greater emphasis on delivery and Croydon should review the deliverability and sustainability of each of these two Options to inform which (or a combination of the two) is the most appropriate growth option for Croydon. The Mayor does not support the release of London’s Green Belt and the new London Plan housing targets do not rely on the release of the Green Belt. One the aims of the Green Belt is to assist in urban regeneration, by encouraging the recycling of derelict and other urban land. Croydon is proposing two large regeneration areas at Croydon Town and along the Purley Way. The release of the Green Belt could hinder or delay the development of these areas. Therefore, such an approach would not be in conformity with the London Plan. As stated above, Croydon’s housing target has dropped significantly and there is no justification for the release of the Green Belt. Croydon’s policy framework will need to clearly support the most deliverable option so that it provides clarity and confidence to developers to invest and bring sites (large and small) forward. Themed policies Housing target The Mayor welcomes Croydon’s ambition to deliver 46,040 homes between 2019 and 2039. The draft new London Plan (Intend to Publish version) sets Croydon a 10-year net housing completions target of 20,790 homes between 2019 and 2028. Of this target 6,410 completions should be identified from small sites. With regards to the delivery of small sites, including the numbers sets out in Croydon’s Strategic Spatial Options, the panel report specifically states that the small sites target can be taken to amount to a reliable source of windfall sites which contributes to anticipated supply and so provides the compelling evidence in this respect required by paragraph 70 of the National Planning Policy Framework of 2019. Whilst Croydon‘s Local Plan needs to consider the National Planning Policy Framework 2019, the Planning Practice Guidance (Paragraph: 013 Reference ID: 2a-013-20190220) is clear that where a spatial development strategy has been prepared by the Mayor, it is for the relevant strategic policy-making authority to distribute the total housing requirement which is then arrived at across the plan area. Croydon’s housing target is set out in the London Plan. Croydon’s 10-year housing target is based on the borough’s capacity as set out in the London Strategic Housing Land Availability Assessment 2017, which Croydon fed into; and a methodology for small sites. It does not rely on release of the Green Belt or further release of land in Strategic Industrial Locations. As stated above, given the significant drop in Croydon’s - 2 - housing target from the 2017 draft London Plan to the Intend to Publish version there is no justification to release Green Belt or impinge on SIL. Croydon should clearly set out how it will deliver 20,790 homes between 2019 and 2028 and that the proposed 25,250 homes to 2039 have had regard to the 2017 SHLAA and local evidence of capacity. Environment The Mayor welcomes Croydon’s intention to update and strengthen its environmental planning policies. In this regard the approaches set out in the London Plan (intend to Publish version) have been found sound and are based on up-to-date evidence. The most relevant policies are those set out in Chapters 8 and 9 of the draft new London Plan. The Mayor has raised concerns regarding the draft South London Waste Plan, and therefore Croydon should ensure it safeguards sufficient land to meet its element of South London’s waste apportionment over the plan period. Green Grid and Open space The Mayor would support policies that seek to create a Green Grid across Croydon and protect and improve access to open spaces. He would also support the protection and creation of additional open spaces and biodiversity. Chapter 8 of the draft new London Plan sets out the most relevant strategic policies that have been found by the Examination Panel. Transport The Mayor welcomes the council’s commitment to addressing the climate emergency and housing crisis and its recognition of the importance of transport in achieving this, as well as tackling other health and environmental challenges. In particular, the Mayor welcomes the recognition of the need for a future with reduced parking for cars, and the shift that is needed in how people view car ownership and use, particularly for short journeys. The Mayor would strongly support an ambitious parking policy that minimises the additional congestion, emissions and road danger created by new development in Croydon. He would expect this to at least be in line with the new London Plan, and welcome the possibility raised of applying lower maximum standards. Officers at TfL would be happy to discuss further how this could be approached and what enhancements to public transport, walking and cycling conditions in the borough could support this. Affordable housing In line with draft new London Plan policy H4, the Mayor welcomes Croydon’s aim to increase the delivery of affordable homes across the borough, and especially from schemes of 10-15 units. It should be noted that to be in conformity with the London Plan, Croydon must adopt the threshold approach for major developments as set out in draft new London Plan policy H5 and H6. The Mayor would also welcome an approach that seeks affordable housing contributions from schemes of less than 10 dwellings. - 3 - Housing type and quality The Mayor would welcome policies that seek to ensure the most appropriate forms of housing are delivered in Croydon, based on local evidence. The Mayor would also welcome policies that ensure high quality housing is delivered across the borough. Draft London Plan Chapter 3 sets out the Mayor’s design policies, including housing standards and Chapter 4 provides guidance on the provision of various forms of housing. Employment Offices Draft new London Plan policy E1 and Annex 1 identify potential for the growth in office floorspace in Croydon town centre which is noted as being a strategic outer London office location. London Plan evidence shows Croydon has lost a significant amount of office floorspace via office to residential permitted development rights. It would be useful if the Local Plan, based on strategic and local evidence, sets out the projected demand for office floorspace and how this will be delivered over the plan period. Draft new London Plan policy E1 seeks to focus office floorspace in town centres. A masterplan that seeks to intensify commercial uses, including offices at Purley Way should follow the town centre hierarchy.