Consultation Responses

30-Jan-13 Croydon OAPF consultation responses

MET police response Hammersons response Westfield response Gatwick response General Comments The plan is too prescriptive Changes to the OAPF have been made. The level of detail included is considered to be appropriate for this type of OAPF.

General Comments Local Context should be moved in the Change made. arrangement of the document to prior to Land Uses to make the document easier to follow

Chp1 Introduction The vision section is still too weak Changes made. As part of the flexible end state plan Changes made to better reflect the and this should be bulked up more 'In for Wellesley Road the text in aspriations for Wellesley Road and order to encourage investment'. paragraph 1.12 should reflect the these are now consistent across the following: 'each proposed Plan. development on or affecting Wellesley Road should be supported by transport testing and modeling provided by the applicant. Moreover, emphasis should be placed on all parties (including TfL, the Council and developers) working together to reasonably move towards a ‘flexible- end-state’ through careful and considered discussions, rather than one party being expected to deliver all the modifications to Wellesley Road'. Chp1 Introduction Support for student housing, hotel Noted. and the release of outdate office. Chp1 Introduction Remove figure 1.1 and 1.2 Changes made.

Chp1 Introduction Amend Figure 1.3 to say Retail Core - Change made. Retail led mixed use area including resi and leisure and reflected in Figure 3.3 Chp1 Introduction Paragraph 1.2 should cross reference Change made. those maps show the location of New Town. Chp1 Introduction Paragraph 1.12 Further detail on the Changes made. Wellesley Road flexible end state is needed. Chp 2 Location of the COA There is limited information on the six Additional information included - new Amend the Purley Way map to also Not required, the purpose of this map character areas. applications will be expected to include Beckenham and the A23 to is to highlight the relationship provide their own detailed assesment central London. between the COA and Purley Way - of how their proposal relates to the which are currently operating as surrounding character area. competitors and they should not be. Beckenham is not part of this relationship. Chp 2 Location of the COA A consistent term for Civic and Change made. Cultural or Fairfield and Mid Croydon should be adopted Chp 2 Location of the COA Fig 2.3 need to clarify where the Change made. figures for turnover for the Town Centre and Purley Way have come fromand this needs to be referenced

Chp 3 Land Uses Emergency services: In order to Change made to text:Croydon There is no reference to the need for There is no aspiration to prepare a The existing retail floorspace is set at Change made. ensure that the Crodyon Town Centre Council will work alongside the a masterplan for the retail core area. detailed masterplan for the retail core 195000 and this figure should be remains a safe and secure place for Mayor's Office for Policing and Crime as is the case with the other referenced as the Experian GOAD residents and visitors, it is important and the Metropolitan Police Service masterplan areas, the OAPF includes report for central Croydon sets this that the diverse nature of policing to ensure the delivery of necessary some guiding principles that figure at 218457 (Nov 11). needs as a result of development and policing facilities in Croydon Town applicants should use as the starting intensification can be met. Centre so that the impact of new point for their plans. In the future it develompent upon policing can be may be appropriate to prepare a appropriately mitigated. masterplan for the retail core and the OAPF allows for this to happen.

Page 1 of 40 30-Jan-13 Croydon OAPF consultation responses

MET police response Hammersons response Westfield response Gatwick response Chp 3 Land Uses Fig 3.2 change the key and update Change made. The vacancy rates appear inaccurate Change made. the map i.e. it should not be mixed and should be clarified - OAPF says retail but rather just retail. 11% but the GOAD says 18%.

Chp 3 Land Uses Clarification needs to be provided for Change made. The retail core section of text should Change made to support qualitative the land use figures in Fig 3.1. be updated to read “support the development and that the quantity is development of at least 28,000sq.m less important so long as a of additional retail floorspace (in reinvigoration is achieved. addition to a full scale department store)”.

Chp 3 Land Uses The inclusion of reference to the Change made. Paragraph 3.8 should be revised to Change made. Westfield assessment of the impact read “Focus growth in comparison of town centre shopping centres on retail within the retail core in surrouding high streets should be particular along North End and in removed. Whitgift and Centrale shopping centres”. And this may also need to be updated in chapter 2 as well

Chp 3 Land Uses The 24 hour route should not state Change made and the route no Paragraph 3.8 should note that the Not required, as it is too prescriptive that the route is 24 hour through longer runs through the cinema. only realistic location for a new and it is impossible to forecast with Centrale cinema and the routes department store is in the Whitgift certainty what could happen over the should be made clearer to respect Centre. twenty years, although reference is this in the text and the diagram. now made to this general south eastern area of the retail core.

Chp 3 Land Uses Paragraph 3.9 states that the overall Change made. Para 3.9 should be amended to say Change made. aim of the OAPF is to deliver housing that residential led development is - we should not state that this is the not the main priority of the OAPF - overall aim of the OAPF as there are but that it is one of them and that the other mixed uses that are also primary aim is meet modern important so alter this text to say - commerical need. one of the aims is to bringing new resi into the centre.

Chp 3 Land Uses Paragraph 3.15 should reflect the fact Change made. Support the inclusion of the Mayor's Noted. that Centrale is unlikely to be and Council's support for redeveloped. comprehensive renewal of the retail core and the text sould go further stating that this option is needed to ensure the area can be revitialised.

Chp 3 Land Uses Paragraph 3.17 should remove Change made. Paragraph 3.15 should be amended Inappropriate comment. reference to Westfield evidence. to recognise that the redevelopment of the Whitgift centre is a priority over that of Centrale.

Chp 3 Land Uses Paragraph 3.24 needs to be Change made. Paragraph 3.27 needs to be Change made to support qualitative amended and addressed in light of amended to note that “need for a new development and that the quantity is Hammersons objections, we could full scale department store, together less important so long as a include some aspirations ie, better with at least 28,000sq.m of additional reinvigoration is achieved. entry and improved footfall and better retail floorspace”, east west route and it also needs to reference the existing permission.

Chp 3 Land Uses The OAPF should make reference to Change made. Paragraph 3.3 needs to recognise Change made. the fact that the office buildings in the that Centrale may not be part of a Whitgift Centre are stand alone and comprehensive redevelopment and that, subject to redevelopment of the that it already has a planning bigger plot, these could potentially be permission. redeveloped.

Chp 3 Land Uses Paragraph 3.25- the Allders bullet Change made. Figure 3.6 - the key and map for the Change made. point should be removed and set as a location of amenity spaces in retail stand along as Allders is not part of core are not accurate (brown and Whitgift - also this building could be green). subdivided rather then redeveloped by a single occupier. Chp 3 Land Uses Paragraph 3.32 - Guiding Principles Change made. The guiding principles for the retail Change made. should include 'where feasible to the core need to more accurately reflect connection to district heating.` that the retail core area could accommodate 1100 homes and this could be on a range of sites across the area not just Whitgift and Centrale.

Page 2 of 40 30-Jan-13 Croydon OAPF consultation responses

MET police response Hammersons response Westfield response Gatwick response Chp 3 Land Uses Figure 3.5 - The Centrale shopping Change made. Paragraph 3.42 should not require Change made. centre does not own those units on securing an agreement with RSL's North End that are directly accessed but to engage with them early is fine. from North End and the map should The text could be amended as be amended. follows;“Engage with Registered Providers at the earliest time alongside the planning authorities, to discuss affordable housing details”.

Chp 3 Land Uses Figure 3.5 - the red routes should Change made. include the link onto Keeley Road.

Chp 3 Land Uses Figure 3.6 and key should say that it Change made. is approxiamtely 1100 units so as it can be more flexible. Chp 3 Land Uses Paragraph 3.38 should include Change made. suggestions for improvement to North End as per the other high streets.

Chp 3 Land Uses Figure 3.8 with the residential Change made. capacity figures is wrong and is not consistent throughout the document.

Chp 4 Local Context Figure 4.8 and its key needs to be Changes made - there are five amended to reflect the fact that there Conservation Areas in the COA. are six Conservation Areas in the COA.

Chp 4 Local Context Figure 4.7 does not accurately reflect This figure 4.7 has been removed as the development potential area of it was confusing. Whitgift, (this diagram needs to be amended to better illustrate that there is a need to stitch the COA's old and new areas together better).

Chp 4 Local Context

Chp 5 Public Realm The 24 hour route should not state Text amended. Principle 5 on the east / west route Change made. that the route is 24 hour through should note that this would not be a Centrale and the routes should be cycle lane. made clearer to respect this in the text and the diagram in the retail core section and also this should be better explained in the text in chapter five in the urban design principles that these routes are a mixture of public and private routes.

Page 3 of 40 30-Jan-13 Croydon OAPF consultation responses

MET police response Hammersons response Westfield response Gatwick response Chp 5 Public Realm Paragraphs 5.2 and 5.4 need to Changes made. The design principles should not Noted - but it is important to clearly clarify character area references and prejudice the detailed design work for set out Croydon Council's and the make them consistent. Wellesley Road. Mayor's starting position.

Chp 5 Public Realm Fig 5.3 the key needs to be state that changes made Figure 5.10 should be labelled as Change made. permeability in the purple blocks is an indicative layout for the public realm issue and can be significantly and this can be explained in more improved upon - the blocks are not detail in the text i.e; “The OAPF completely impermeable requires proposals within the COA to consider the provision of smaller spaces as indicatively shown in Figure 5.14

Chp 5 Public Realm Paragraph 5.9 and the map for the Changes made. Paragraph 5.18 should note that not Change made. high streets need to better clarify that all new routes will be cycle accessible the high streets do have a series of and even now cyclists are not allowed smaller streets that run off them i.e. on North End at all times and so the Frith Road. text should be amended.

Chp 5 Public Realm Paragraph 5.15 is unclear. Change made. Figure 5018 - the figures for child play Change made. in the retail core area are the wrong way around. Chp 5 Public Realm Figure 5.10 and Figure 5.14 need to Change made. show that whilst there is a route that runs through Centrale it is not a new 24 hour public route and this should be reflected in the diagrams - our maps should also state that these are indicative and that the exact location of these routes is open for discussion at planning application stage based on more detailed analysis.

Chp 5 Public Realm Para 5.16 to 5.13 the text needs to be change made. clearer that applicants will be expected to contribute to the delivery of new routes and spaces where appropriate / relevant Chp 5 Public Realm Fig 5.15 needs to be better reflect the change made. routes through the centrale site and also the text needs to show that the delivery of routes and spaces by applicants will only be agreed during the planning application stage and can only be delivered as part of new development

Chp 5 Public Realm Paragraph 5.32 need to reference Change made. how the child yield has been calculated and also how the split between on and off site should be provided. Chp 6 Building heights and Figure 6.4 needs to change the high Change made. In the introduction section of tall Change made. Where large windturbines are Noted and this is a standard form street text to North End. buildings the text should include the proposed then Gatwick Airport would procedure for Croydon Council. following;: “The OAPF need to be consulted, please refer to supports the development of tall 'Safeguarding of Aerodromes - buildings in certain locations in the Advice Note 7' for further information. COA that respect the surrounding context, including important heritage assets.”

Chp 6 Building heights and Paragraph 6.23 and 6.25 needs Change made. Paragraph 6.14 should be updated to Change made. form some further resolution to make sure include the following they are complementary. Paragraph caveat“However, the setting of a 6.23 should be removed - the plinth number of Listed buildings must be and tower approach. fully considered where this would be impacted upon by new development, or significantly enhanced by the removal of the existing buildings.”

Page 4 of 40 30-Jan-13 Croydon OAPF consultation responses

MET police response Hammersons response Westfield response Gatwick response Chp 6 Building heights and Images on page 68 need to be better Change made. Figure 6.7 - the building typologies This map has been deleted as it form woven into the text and say why we map is not accurate and should be caused a lot of confusion. have included them or we should amended to show the potential to remove them. allow tall buildings along the full length of Wellesley Road and not as resi above retail.

Chp 6 Building heights and Shading section paragraphs 6.37 to Change made. Figure 6.6 on 8 units per core for tall Change made. form 6.40 should note that shading towers would be better referring to analysis is not only required for tall the London Housing Design Guide. building but for all buildings.

Chp 6 Building heights and form

Chp 7 Transport Figure 7.2 to include the actual Not applicable. Supportive of the transport chapter Noted. corresponding rating. and transport model.

Chp 7 Transport Paragraph 7.28 - change this text to Change made. say that the new footbridge at East Croydon will assit will alleviating capacity on the platforms.

Chp 7 Transport Paragraph 7.30 - need to clarify how Change made. we can be sure that overcrowding on the tram is supressing demand - and the text should also explain why we think additional capacity is required.

Page 5 of 40 30-Jan-13 Croydon OAPF consultation responses

MET police response Hammersons response Westfield response Gatwick response Chp 7 Transport Paragraph 7.34 and 7.35 - how can Change made. we say that we need additional capacity post 2016 and then say that we have not done any work on what this would be, cost and delivered?

Chp 7 Transport Paragraph 7.41 - final bullet point on Change made. safeguarding land for bus stands and stops needs to be further clarified i.e. that we don’t want to loose capacity.

Chp 7 Transport Paragrapg 7.53 - needs more Change made. information on what elements of Wellesley Road are reaching capacity and which have been identified as the worst areas based on future traffice volumes. Chp 7 Transport Paragraph 7.75 - should include Change made. reference for the need to a comprehensive servicing and freight strategy for the retail core area.

Chp 7 Transport

Chp 8 Parking Figure 8.3 - the total number of car The figures included are the most Figure 8.3 - the total number of Change made. spaces in the retail core area is not accurate figures available to the parking spaces in the COA should be correct and should be amended. Mayor and Croydon Council. amended from 755 to 7673 as the current figure is wrong.

Chp 8 Parking Figure 8.4 and paragraph 8.10 have Change made. The 2nd car parking principle is not This principle is applicable along the different use % figures for car parks completely coherent with the second full length of Wellesley Road and in the retail core i.e. 80% or 75% parking strategy of retail expansion Park Lane and not just for a retail there should be consistency. and so the text in the principle should core redevelopment. be amended as follows: 2nd sentence in paragraph 8.28 should be changed to read “It should aim to reduce vehicular traffic on the section of Wellesley Road between the underpass and Sydenham Road and help deliver an improved public realm”.

Chp 8 Parking Hammersons supports the increase Noted. They are broadly supportive of car Noted. of 1000 car spaces in the retail core. parking scenario 2.

Chp 8 Parking Car parking option 2 should amend this is described as possible options Current Westfield plans on parking the level of car parking will be the proposed location of car entry and and that the detail will be determined provision in the retail core exceed the determined through a detailed exit points as this is too prescriptive at the application stage based on proposed level of parking by 388 planning application and should be and should be more flexible detailed modelling spaces - the parking figures should based on the inidicative figures be amended accordingly included in the OAPF

Chp 8 Parking The parking section on accessing This is an ongoing desire of both the parking should not be accessed off Mayor and Croydon and should Wellesley Road and that the redevelopment not take place now in underpass should be expored as an the future redevelopment options option - discussions and exploration could also explore this option in more of this has moved on significantly and detail the parking scenarios should reflect this Page 6 of 40 30-Jan-13 Croydon OAPF consultation responses

MET police response Hammersons response Westfield response Gatwick response Chp 8 Parking The parking scenario suggests that a This is now referred to as one option preferred option would be to access that should be explored. the parking at Fairfield and keep it all underground - however, this cannot be achieved as part of the Westfield development and so the text should be amended. Chp 8 Parking

Chp 8 Parking

Chp 9 Delivery Figure 9.1 - the character area should Change made be retail core and not North End.

Chp 9 Delivery Commercial phasing text should note Change made. that there are currently no redevelopment plans for Centrale.

Chp 9 Delivery Potential funding sources section Change made. needs to be updated especially relating to the potentiail 12% uplift in sales and rentals.

Chp 9 Delivery This chapter should include a section Change made. This chapter should include a section Change made. that says LBC would be prepared to that says LBC would be prepared to use CPO powers to help deliver its use CPO powers to help deliver its objectives. objectives. Chp 9 Delivery

Glossary Social infrastructure: (new definition). Change made Covers facilities such as health provision, early years provision, colleges and universities, community, cultural, recreation and sports facilities, places of worship, policing and other criminal justice or community safety facilities, children and yound people's play and informal recreation.

Integrated Impact Assessment

Page 7 of 40 30-Jan-13 Croydon OAPF consultation responses

MET police response Hammersons response Westfield response Gatwick response Integrated Impact Assessment

Integrated Impact Assessment

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English Heritage response Natural England response Local Resident 1 response Local Resident 2 response General Comments There are a large number of typos Changes made and errors that need to be amended

General Comments

Chp1 Introduction We need to be clearer that bringing This requirement is noted in the new people into the Croydon OAPF. Opportunity Area will only be benefical if sufficent amenity space and social infrastructure is also provided.

Chp1 Introduction The chapter Objectives should Change made. include `to create a mix of uses`. Chp1 Introduction

Chp1 Introduction

Chp 2 Location of the COA

Chp 3 Land Uses With reference to paragraph 3.61 on Disagree, it will be done on a case by How can planning make housing This question is addressed in Para 3.6 - degrees are offered from Change made. decentralised energy, English case basis as and when new more affordable for people? Croydon's Core Strategy, London Surrey University and not Sussex. Heritage encourage the Council to development comes forward. Plan and National Planning Policy prioritise networking buildings from Framework. conservation areas to decentralised energy network..

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English Heritage response Natural England response Local Resident 1 response Local Resident 2 response Chp 3 Land Uses New housing will need to have a Noted - level of three bed housing sufficent mix if it is to create a vbirant determined in Croydon's Core place, including a sufficent provision Strategy. of three bed housing (even three bed flats would accommodate a certain need).

Chp 3 Land Uses Retail Core - Paragraph 3.15- the The term leisure is more defined. term leisure needs to be more acurately defined. This could be a mix of indoor and outdoor public and private uses.

Chp 3 Land Uses It is important that the redevelopment This is important - and it is of the retail core does not destroy the considered that attracting new vitality of the retail area and that rents residents and workers and vistors in are not pushed too high for existing the COA will help support existing businesses. businesses. This is a central aim of the OAPF and is reflected in the text.

Chp 3 Land Uses Residential section - we should also This is clearly set out in the land use note that residential is not the only objectives section. required use in the town centre and there are other uses that are needed to ensure a vibrant place i.e. social infrastructure.

Chp 3 Land Uses What effect would cars entring and This will be addressed in the exiting the retail core from Poplar transport section of the OAPF. walk have on this street including buses?

Chp 3 Land Uses Using all the infill land for housing will A detailed capacity model is set out in leave no land for other uses. the Appendix that shows how the 7300 homes figure is arrived at.

Chp 3 Land Uses

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English Heritage response Natural England response Local Resident 1 response Local Resident 2 response Chp 3 Land Uses

Chp 3 Land Uses

Chp 4 Local Context 1960's edge city should make Reference included. The role of natural signature should Change made. In both the chapter objective and Change made. reference to the impact on WWII and be made more explicit and the role throughout the whole document- the bomb damage and the make up this can have in emphasising and remove the words `new development the COAs built environment today. supporting a particular place, i.e. should BUILD on Croydons heritage promoting the level changes. Include assets` - it should be changed to a statement that further guidance on complement - enhance and respect. this can be viewed in Natural Englands 'London Landscape Framework'. Chp 4 Local Context Paragraphs 4.8 and 4.9 need to be Changes to the introduction for Figure 4.9 - describes modernist Change made. rewritten - the description of historic heritage text made. buildings but we need to provide buildings is insufficent / post war more definition on what this is and modernist buildings are also historic why this map does not include other and we should note what the oldest more contmeporary buildings. building and mix is.

Chp 4 Local Context Heritage assets section needs to be Change made. We should recognise in this chapter Text included. rewritten to note that the conservation that there are also contemporary areas do not buildings in the COA and these contain all of the town centre’s contribute to the character of the area heritage assets. Do they perhaps - this can be good and bad. contain fragments of historic townscape from different stages in Croydon’s development? If this is the case then the sentence after that might perhaps read: “These conservation areas are largely surrounded by 1960’s city fringe development that contains some listed and locally listed buildings”. Chp 4 Local Context The OAPF should also note in the Change made. heritage assets section that new development should also be aware of the impact of new development on existing heritage assets outside of the OAPF area. Chp 4 Local Context We request that the fact that nearly Change made all of the Town Centre is an Archaeological Priority Zone be identified in the Heritage Assets section. Information from the Thames Water Desk Based Assessment of the town centre (referred to in the IIA comments above) is likely to provide substantive information that could be summarised in a paragraph here.

Chp 5 Public Realm Para 5.12 on Improving Wellesley Disagree - whilst this is important it is Include a stronger reference to the This is already sufficently recognised Paragraph 5.5 the benefits of Change made. Road should also make reference to not a driving principle behing the opportunities and potential to throughout all other policy Wellesley Road and the flyover the Heritage At Risk Wellesley Road changes to Wellesley Road. enchance access to nature, links to docuements and also in the OAPF. should also be noted in that they North Conservation Area and that this existing facalities and combating alleviate traffic. should be included in the principles fragmentation. for improving this road.

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English Heritage response Natural England response Local Resident 1 response Local Resident 2 response Chp 5 Public Realm Improvements to the public realm and Noted. Paragraph 5.7 Wellesley Road etc. Diagree. amenity can help deliver biodiversity should not have their capacity and natural environment reduced through the proposed public opportunities for wildlife, health and realm improvements. climate change adaptation.

Chp 5 Public Realm We need make it more explicit that This is already recognised in the Proposed improvements to the Noted and this is a key part of the the public realm strategy supports the public realm chapter - the importance station and the high street is high streets improvement connection to Wandle Park and the of de-culverting the Wandle. welcomed - street clutter is a big programme. broader de-culverting of the Wandle issue. River where feasible.

Chp 5 Public Realm Paragraph 5.22 could also refer to Noted. Figure 5.14 - the location of a Change made to the Fell Road the role the different types of amenity pedestrian crossing at Fell Road and crossing not to Edridge which has space would play in transport, Edridge Road is a very dangerous now been delivered. connections, reducing heat island place for a crossing and may be effect, health inaccurate.

Chp 5 Public Realm All of planned crossings over Noted. Wellesley Road will cause serious delays on this road. Chp 5 Public Realm

Chp 5 Public Realm

Chp 6 Building heights and Paragraphs 6.2 onwards should Change made. New tall buildings should not take development on open land will be form better reflect CABE and EH's over public land and if they are much considered as part of each planning guidance on tall buildings. higher then the existing they should application and in line with national be set back to retain views to the sky policy. The OAPF does note the importance of tall buildings retaining views to the sky.

Chp 6 Building heights and There are concerns about allowing The approach for building heights in Some of the recently permitted The OAPF and the masterplans are form buildings of potentially up to 15- the Southern area, Northern area and buildings in the masterplan areas go complementary documents. storeys across the Outer Area and Old Town has been slightly amended agaisnt the guidance set out in the the potential impact this would have so that exact heights will be building height chapter and maps and on the Old Town area and in determined on a case by case basis this should be reviewed. This particular the Minster and other listed but with a recognition that tall particullary relates to the MENTA buildings/ Some comfort is provided buildings would generally not be tower and the planned buildings in paragraph 6.34 about the need for appropriate. around West Croydon station. new buildings to relate to their character zones and this coudl be made more explicit.

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English Heritage response Natural England response Local Resident 1 response Local Resident 2 response Chp 6 Building heights and Paragraph 6.21 should also include Noted. Figure 6.8 - need to make sure all the All schools included. form reference for the need for new tall schools are located on this map buildings to avoid harming the setting including st Marys school as schools of heritage will be an extremely sensitive site. assets.

Chp 6 Building heights and Paragraph 6.21 particularly in the Noted. Note - Taberner House has a terrible Noted. form proposed central height area, the impact on the setting of the Town Hall need for them to. and the overshadowing of Queens Gardens.

Chp 6 Building heights and Note - No buildings around the town the impact of new development on form hall should be taller then 6-storeys. heritage assests is set out in the This important heritage asset is OAPF and this will be considered on already disappearing from view as a a case by case basis. It would not be result of other surrounding appropriate to set a height standard develompents without a clear understanding on the site, its surroundings and the design.

Chp 6 Building heights and form

Chp 7 Transport Include a reference to the role of Change made. How can we encourage the motorist This is the purpose of the OAPF to The baseline year of 2009 is now The modelling work as carried out in green infrastructure in encouraging to walk or use public transport when it encourage a more pedestrian and already 3 years out of date. 2010. walking and cycling. is cost prohibitive? cycle friendly environment to encourage these

Chp 7 Transport The Croydon - Mitcham tram line is Transport for London's detailed The impact of growth that will occur This is not the case. The modelling very busy. Do we have evidence to transport modelling report includes on the transport network (event work includes the assumed level of support that additional capacity on the relevant information and this is without growth planned in the OAPF) growth that will take place both inside this line will free up road capacity or available on the GLA website. is disregarded and why is this and outside of the COA and this has just attract new customers? acceptable to carry on regardless? informed the decisions.

Chp 7 Transport The actual cost of travel by tram, bus Not appropriate information to Paragraph 7.3 and 7.6 - states that The OAPF identifies those and rail and also by car should be include. there will be increases in traffic and interventions in the transport network included as part of the transport study congestions but that the OAPFs land that will be necessary to mitigate to show its impact on demand and use approach should reduce peoples increases in demand and movement. how each mode comapres against need to travel - but this is only true for each other. those that live in the COA or can get public transport into the area - but this is not true of everyone - these two paragraphs seem to contradict each other - how will the increase in traffic be managed.

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English Heritage response Natural England response Local Resident 1 response Local Resident 2 response Chp 7 Transport The perceived cost of travel by tram, It is not possible to measure this. Paragraph 7.41 - is there scope to Yes, and this analysis is included in bus and rail and also by car should further increase bus capacity in the the detailed transport model the be included as part of the transport area results of which are available on the study to show its impact on demand GLA website. and how each mode compares against each other. Chp 7 Transport The cost of car parking should be The cost of parking in publicly The ability to deliver a new bus Noted and this feasability stage work included in the Town Centre. useable but privately owned off street standing location at Wandle car park is currently underway. parking is not the role of Croydon will be difficult to deliver. Council. These charging levels are set by the private car park owners

Chp 7 Transport The cost of providing additional bus This is a key factor for consideration The proposed intervention in the TfL transport modelling work includes routes in the town centre and their and as and when new bus routes are OAPF will only serve to delay buses. the detailed review of this and the operating costs. identified there will be much more results are available on the GLA detailed work carried out by Croydon website. Council, Transport for London, and the GLA. Chp 7 Transport Paragraph 7.56 - we need to Text included to this effect. recognise the role of Wellesley Road as a road and that we need to maintain this function.

Chp 7 Transport Is there any evidence to support the Transport for London's transport proposal that a lot of the car journeys modelling work includes the detailed made along Wellesley road are review of this and the results are through traffic and in particular for available on the GLA website. cars using the underpass where do those journeys tend to go?

Chp 7 Transport The Poplar walk blue badge car park Noted and text included. is heavily subscribed and should the parking strategy not seek to ensure that sufficent space is provided in the town centre. Chp 7 Transport Servicing and deliery survey should Change made. be carried out. This this a particular issue on George Street. Chp 7 Transport Should one of the Wellesley Road No, transport safety is dealt with as principles be not to lead to an part of the transport sssessment for increase in accidents? any planning application

Chp 7 Transport The principles for Wellesley Road This is set out in the land use and car should not be to the detreminate of parking chapters of the OAPF. businesses and retail. Chp 7 Transport Figure 7.6 - provide good waiting This is a standard Transport for facilities at bus stops. London requirement - the purpose of the OAPF is not to repeat what is already set out in other documents.

Chp 8 Parking Are the parking spaces identified as The surplus spaces are based on surplus really surplus to need. Croydon Council and TfL surveys of use.

Chp 8 Parking The planned reduction of 500 car The planned reduction is based on parking spaces In New Town will the current level of use. mean that cars wishing to use the retail core but that currently park in New Town will now have to drive into the retail core which will increase traffic at certain junctions.

Chp 8 Parking The car parking figures included in Change made. the surveys do not appear to be accurate. Chp 8 Parking Closing more car parking spaces in The majority of car parks are owned the town centre would enable private and run by private operators who car parking operators to put up their already control the price. Leaving costs, which is one of the main 3000 vacant spaces sitting there concerns that local people raised does not keep the price of parking in about existing parking areas in the the COA down. centre. Chp 8 Parking There are big implications to the The detail of the closure of the closing of Fairfield car park as set out Fairfield car park are set out in the in that masterplan especially when masterplan. considered alongside the planned refurbishment work there will be an increased demand for parking which will have been removed.

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English Heritage response Natural England response Local Resident 1 response Local Resident 2 response Chp 8 Parking The surveys should be more robust. It is recognised that through any redevelopment proposals more robust survey work will be needed.

Chp 8 Parking If 7300 new homes and other uses The parking scenario is purely for outside of the retail core are to be public off street parking and not delivered the demand for car parking private residental. will go up. Chp 8 Parking The proposed approach of over The approach is about locating car concentrating car parking in the parking where people want to use it. centre will have a negative imapct on There is no point in keeping spaces the town centre - especially if people that are not used as it is a waste of think location is the most important land aspect of parking. Chp 8 Parking Is it practical to get all the retail core This would need to be explored parking in through the underground at through detailed development Fairfield proposals. Chp 8 Parking Closing the udnerpass would have a This would need to be explored serious impact on traffic on Wellesley through detailed development Road. proposals. Chp 9 Delivery The Wellesley Road obsession is Changing Wellesley Road is a key misplaced. objective for both the Mayor and Croydon Council.

Chp 9 Delivery Providing leisure uses will not Social infrastructure will be delivered necessarly deliver useable public in accordance with Croydon's uses i.e., public swimming pools and Council's Infrastructure Delivery Plan. this infrastructure is requried.

Chp 9 Delivery 9.59 - change the text to make it that Croydon Council are examing the the council could do some further various options for this. borrowing.

Chp 9 Delivery Disagree that transforming Wellesley Noted. Road will lead to more investment.

Chp 9 Delivery Expressed grave concerns about the Noted. contradiction of works to Wellesley Road and reducing car parking that would not attract new investment or make life better for people living and visiting the area. Strongly believed that the money being spent on public realm works would be wasted.

Glossary

Integrated Impact Assessment We can advise that the Planning The IIA has been updated . Policy Statement 5 (PPS 5) Planning for the Historic Environment Practice Guide is still current and is a valuable reference for this table in the National section

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English Heritage response Natural England response Local Resident 1 response Local Resident 2 response Integrated Impact Assessment English Heritage noticed that in both The IIA has been updated . Table 4.1 on page 46, and Table 6.1 on pages 58 and 59, Sustainability Appraisal (SA) Objective 8 pertaining to building and historic environment seems to follow straight after SA Objective 6. It is unclear to us whether an objective has been removed or two objectives (one for the built environment and one for heritage) have been fused together. We request that the source identified in the second column of Table 4.1 be amended to read English Heritage’s Heritage at Risk Register.

Integrated Impact Assessment All reference to obsolete PPS The IIA has been updated. gudiance should be removed from the IIA and this should be replaced with the correct NPPF guidance. Integrated Impact Assessment pg 26 of the IIA The IIA has been updated . - reference the significance of the settings of Croydon Town Centre’s heritage assets; - delineate the reference to St John’s Baptist Church Gateway Scheduled moment from the discussion of the centre’s listed buildings; - update reference to the English Heritage NMR Data Download to the Greater London Historic Environment - Recognise that the Town Centre is an Archaeological Priority Zone (APZ); - Replace reference to ‘At Risk’ lists with a single reference for both listed buildings and the conservation area at risk in English Heritage’s at Risk Register 2011; - identify the parks and gardens as locally listed heritage assets as there are no statutorily Registered Parks and Gardens of Historic Interest in the Town Centre; - revise map on page 27 to identify all the heritage assets in and near to Croydon Town centre, strengthening the map’s resolution

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Local resident 3 response Andrew Pelling response Highways Agency response Thames Water response General Comments No specific comments to make Noted

General Comments

Chp1 Introduction

Chp 2 Location of the COA The opportunity of West Croydon to Further text has been included in the take advantage of its access to West character area descriptions - Croydon station and the East London however, this opportunity has been Line has not been sufficently explained more in the other sections recognised. on land use and building form.

Chp 2 Location of the COA

Chp 3 Land Uses The plan does not provide sufficent The level of family housing is derived family housing provision. from Croydon's Core Strategy.

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Local resident 3 response Andrew Pelling response Highways Agency response Thames Water response Chp 3 Land Uses

Chp 3 Land Uses

Chp 3 Land Uses Broad support for conversion of Noted. existing office space into residential.

Chp 3 Land Uses Broad support for the provision of Noted. student housing in the town centre

Chp 3 Land Uses This plan does not provide for a more Matters of housing land supply and reasonable balance of development location are dealt with in Croydon's across the Borough i.e. seeking to Core Strategy. provide 7,300 homes and 17,000 residents in the town centre and this will have an impact on the rest of the borough i.e. Purley and Coulsdon.

Chp 3 Land Uses

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Local resident 3 response Andrew Pelling response Highways Agency response Thames Water response Chp 3 Land Uses

Chp 3 Land Uses There is little demand for flatted Disagree as evidence supporting housing in the Croydon Town Centre. Croydon's Core Strategy demonstrates. Chp 3 Land Uses

Chp 3 Land Uses

Chp 4 Local Context

Chp 5 Public Realm The MRF funding from the Mayor Noted and eleven million pounds of must be used to assist the struggling the Connected Croydon Programme town centre high streets to the north is being used to carry out physical and south of the pedestrianised North improvement to the high streets. End and this should be further set out in the plan.

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Local resident 3 response Andrew Pelling response Highways Agency response Thames Water response Chp 5 Public Realm

Chp 5 Public Realm

Chp 6 Building heights and The draft plan permits "tall" This is a 20 year plan. The OAPF form development and this I fear is a very seeks to ensure that new buildings serious planning error in terms of are viable. sustainability and the actual promotion of the urgently needed housing development that people can afford.I believe that there should be a presumption against new tall tower block housing - and there is a serious issues the viability of building tall buildings in the COA. There are numerous examples of failed tall buildings in the COA ie. Altitude 25 and Iylo. DEvelopers are land banking their permissions for tall buildings which is further restricting the supply of housing in the town centre

Chp 6 Building heights and Mid height development may well Mid height development is form deliver housing target numbers encouraged through the OAPF. quicker and more sustainably (as per many European Cities where there is an abundance of 5 and 6 storey residential buildings).

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Local resident 3 response Andrew Pelling response Highways Agency response Thames Water response Chp 6 Building heights and form

Chp 6 Building heights and form

Chp 7 Transport

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Local resident 3 response Andrew Pelling response Highways Agency response Thames Water response Chp 7 Transport

Chp 7 Transport

Chp 8 Parking Figure 8.5 and 8.6 which proposes a This proposed level of reduction is reduction of 250 spaces in Fairfiled now increased in line with the could have a negative impact on the requirements of the masterplan and ability of people to visit Fairfiled Hall this is based on robust surveys carried out at peak times. Chp 8 Parking

Chp 8 Parking

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Local resident 3 response Andrew Pelling response Highways Agency response Thames Water response Chp 8 Parking

Chp 8 Parking

Chp 9 Delivery The plan should recognise the need Change made. to manage water supply and waste water management as part of the delivery and the IDP. The plan should recognise that it can take between 1.5 to 3 years for local upgrades and 3 to 5 years for more strategic upgrades. Chp 9 Delivery The local authority will need to work Change made. closely with Thames Water during the life of this OAPF to plan carefully for future need and provision. This section and the section above should be included as a separate point on pg 120. Chp 9 Delivery Amend paragraph 9.58 final bullet Change made. point to make it read that service provides and the LA will have to work closely to plan for the provision of infrastructure. Chp 9 Delivery

Chp 9 Delivery

Glossary

Integrated Impact Assessment

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Local resident 3 response Andrew Pelling response Highways Agency response Thames Water response Integrated Impact Assessment

Integrated Impact Assessment

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National Grid response Rosepride response British Rail Board response Legal and General response General Comments Provided a general comment on its Noted. Support for the overall aspiration and Noted role as electrical and gas objectives of the OAPF transmission and distribution. The Council should be aware that the NPPF requires National Grids involvement in the preparation and review of DPD's. Over the next 20 years National Grid will work on increasing infrastructure capacity and new forms of energy provision.

General Comments The OAPF should further optimise Noted the delivery of regeneration as set out in Ministerial Statement 6 Sept 12 on Housing and Growth - this would help encourage flexibility for new development and this is particuallarly relevant for conversions.

Chp1 Introduction The general approach set out in Noted vision section and objectives is broadly supported.

Chp1 Introduction

Chp 2 Location of the COA

Chp 3 Land Uses Fig 3.9 on the location of family Changes made to make the family The inclusion of the British Rail Board Some additonal flexibility of text is The proposed level of housing in the Noted. housing is confusing and does not housing approach more simple. (Residuary) site on Lansdowne Road included. Civic and Cultural area is supported. seem to relate to the character areas falls within the outer area and or building height areas. What is the requires 45% housing. This is this too rationale for this approach, and strict. particularly to the inner and outer zones and why is West Croydon not the same as the other edge areas?

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National Grid response Rosepride response British Rail Board response Legal and General response Chp 3 Land Uses The central residential area should be This is not appropriate - the area Should the BRB site on Lansdowne this is to allow some other uses The proposed housing mix section Change made. extended to include West Croydon around Arcadia is clearly in the Old not be designated as fully residential should recognise that not all sites can and the Arcadia Site - and more Town area - to encourage more residential into deliver the allocated family housing robust justification should be the area target and that site specifics need to provided. be taken into account - this should be set out in the residential section of land uses - in particular highlighting the inability of conversions to achieve this.

Chp 3 Land Uses The ability of the Arcadia House site Noted -the level of three bed housing Support the identification of St. Noted. to accommodate 45% three bed can be agreed on a case by case Georges House for potential housing could have a negative impact basis but the starting point for a conversion. on the ability of the site to be discussion is the level included in the redeveloped. OAPF, however,the Arcadia house site is a site that is adjacent infrastructure and so is it reasonable for this site to accommodate 45% family housing. Chp 3 Land Uses We should make it clearer that the Noted and the text has been updated Welcome the proposed policy Noted. residential capacity work is not the to reflect this. dispensations to help deliver required level of housing in each of conversions of surplus office to the character areas including Old residential and other uses. Town and that the capacity model is just a broad understanding of capacity across the COA.

Chp 3 Land Uses Should it not be similar to the 20% Arcadia House site is a site that is The social infrastructure section Change made. as per the housing capacity adjacent infrastructure and so is it should also make reference to the guidiance? reasonable for this site to broader requriements of local people accommodate 45% family housing. and their importance i.e. creche, dentist, news agents etc…

Chp 3 Land Uses The energy section should also make This is already stated and is also reference to the fact that not all stated in the conversion section. development would be able to connect to a district energy system - particullary conversions. And also as the energy centre is aspirational this section of the OAPF should not be overly restrictive.

Chp 3 Land Uses

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National Grid response Rosepride response British Rail Board response Legal and General response Chp 3 Land Uses

Chp 3 Land Uses

Chp 4 Local Context

Chp 5 Public Realm Support the proposed public realm Noted. improvements

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National Grid response Rosepride response British Rail Board response Legal and General response Chp 5 Public Realm Play space requirements for Noted. conversions may not be acbievable on site.

Chp 5 Public Realm

Chp 6 Building heights and Fig 6.4 on building heights does not Change made Should the BRB site on Landsowne change made There is no recognition in the OAPF There is recognition, refer to figure form seem to relate well to the areas for Road that is identified as land that there is an existing tall building 6.1. family housing and it appears adjancent infrastructure not be on the St Georges site and the OAPF confusing and unclear encouraging solely residential and not should be amended to include this residential led

Chp 6 Building heights and Why has the proposed building height Change made. Figure 6.7 is not clear - particularly for Change made. form of 15-storeys been set for the outer the St Georges Site. area? Could this be made less strict to ensure that a more comprehensive site specific analysis to be carried out at the detailed application stage.

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National Grid response Rosepride response British Rail Board response Legal and General response Chp 6 Building heights and The extension of the edge height the extension of the height area into form area onto south end does not relate South End is to reflect the fact that to the family housing locations of there are a series of existing tall 20% - 45% and if this expection has buildings in this area and it would not been included for south end then why be viable to knock these and to not the arcadia site? rebuild smaller family houses. Such an approach would stiffle any potentail redevelopment. Chp 6 Building heights and Paragraph 6.18 should be amended The approach for building heights in form to note that there may be potential for the Southern area, Northern area and buildings in the outer area to be taller Old Town has been slightly amended then 15 storeys and the text should so that exact heights will be reflect that. determined on a case by case basis but with a recogniction that in general tall buildings not be appropriate.

Chp 6 Building heights and The Arcadia site should be well The approach for building heights in form positioned to accommodate a slender the Southern area, Northern area and tall building that acts as a marker for Old Town has been slightly amended the entry into Old Town - the OAPF so that exact heights will be should not reduce the sites viability - determined on a case by case basis it is in an accessible location - it is a but with a recognition that tall gateway site - the existing location buildings would generally not be and make up of the site is not appropriate. residential or high street - it is more commerical in nature and so a tall building may not be out of context - there is large infrastructure to the west and careful design could mitigate impact on conservation areas and local character.

Chp 6 Building heights and The area is simlar to West Croydon The approach for building heights in form masterplan area and so the same the Southern area, Northern area and approach to tall buildings should be Old Town has been slightly amended followed in this area and the edge so that exact heights will be area should be extended to include determined on a case by case basis the Arcadia site. but with a recognition that tall buildings would generally not be appropriate. Chp 6 Building heights and Figure 6.7 shows the Arcadia site as Arcadia House site is a site that is form being adjacent to infrastructure and adjacent infrastructure and so is it so could accommodate less family reasonable for this site to housing and a taller building this accommodate 45% family housing. needs to be resolved. Chp 6 Building heights and Paragraph 6.29 should be updated to Change made. form say that 'these typologies are indicative only and they do not preclude development that falls outside of these standards from coming forward and being acceptable - as shown with the cluster of towers around West Croydon - there needs to be greater clarity about the differences between why some sites at West Croydon station are allowed to be taller why the Arcadia site (which has many similar characteristics) is restricted to 15 storeys. Chp 7 Transport The transport model should ensure The modelling work has been. that the modelling work is carried out against the existing condition

Chp 7 Transport Parking standards for conversions Noted. should be more flexible so as to take account of site specifics.

Chp 7 Transport

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National Grid response Rosepride response British Rail Board response Legal and General response Chp 7 Transport

Chp 7 Transport

Chp 8 Parking

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National Grid response Rosepride response British Rail Board response Legal and General response Chp 8 Parking

Chp 8 Parking

Chp 9 Delivery

Glossary

Integrated Impact Assessment

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National Grid response Rosepride response British Rail Board response Legal and General response Integrated Impact Assessment

Integrated Impact Assessment

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Sport England response Local resident 4 Thynne response Royal Mail response General Comments Provides their broad principle support Noted for the OAPF. which provides a notable degree of flexibility as to the types of land uses that could come forward in the COA, including the New Town and East Croydon Character Area. `Taken as a whole, the Framework in our view provides a solid foundation for the successful reinvention of the Croydon Metropolitan Area. Above all, it provides coherent guidance which is not overly prescriptive, in accordance with the principles of NPPF.`

General Comments

Chp1 Introduction

Chp 2 Location of the COA

Chp 3 Land Uses The role of indoor and outdoor sport This is included in the public realm Welcomes the proposed inclusion of Noted. facilities should be made reference to section. additional residential in the town in the land use chapter as a required centre. land use and also in the overall objectives and in the social infrastructure requirements.

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Sport England response Local resident 4 Thynne response Royal Mail response Chp 3 Land Uses The retail core renewal should be the The proposal is not `an either /or preferred approach and not option`. It will be based on whether expansion. there is a demand for large scale development programme. The options include guidance for what is wanted for the retail core area in general with recognition that comprehensive approach would deliver most objectives.

Chp 3 Land Uses Welcome the proposed Noted. improvements to the high street.

Chp 3 Land Uses

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Sport England response Local resident 4 Thynne response Royal Mail response Chp 3 Land Uses

Chp 3 Land Uses

Chp 4 Local Context

Chp 5 Public Realm Welcomes the proposed Noted improvements to the public realm.

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Sport England response Local resident 4 Thynne response Royal Mail response Chp 5 Public Realm Welcome proposed improvements to Noted. Wellesley Road and that these be done incrementally.

Chp 5 Public Realm

Chp 6 Building heights and form

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Sport England response Local resident 4 Thynne response Royal Mail response Chp 6 Building heights and form

Chp 6 Building heights and form

Chp 7 Transport The identification of traffic congestion The detailed intervention will need to on the A23 and not addressing this be modelled and addressed as a issue now could have an imapct on separate project and this work will be further inward investment. undertaken by Transport for London and Croydon Council as and when development comes forward.

Chp 7 Transport Welcome the proposed walking and Noted. cycling improvements.

Chp 7 Transport Wary of increasing the frequency of The detail of this will be modelled trams and the potential impact this with tramlink. could have on other modes of transport.

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Sport England response Local resident 4 Thynne response Royal Mail response Chp 7 Transport Concerns expressed over the Noted potential impact on traffic on Billinton Hill and how this relates to pikc up and drop off locations.

Chp 7 Transport

Chp 8 Parking Loss of parking around East Croydon The proposed reduction in parking could have an impact on people rail- levels is based on survey work. Rail heading. heading offers very little benefit to the COA as a place.

Chp 8 Parking

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Sport England response Local resident 4 Thynne response Royal Mail response Chp 8 Parking

Chp 8 Parking

Chp 9 Delivery

Glossary

Integrated Impact Assessment

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Sport England response Local resident 4 Thynne response Royal Mail response Integrated Impact Assessment

Integrated Impact Assessment

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