- 9 June 2022
- Posted by: Cllr Sean Fitzsimons
- Category: Application, Planning, Ward Councillors
Dear Development Management
I write to object to this planning application and to ask for it to be referred to the planning committee.
Relevant Planning Policy and Guidance
The basis of my objection is that this application is non-compliant with the following planning policies and guidance:
- National Policy National Model Design Code (NMDC)
- National Policy Planning Framework 2021 new paragraph 124 Achieving appropriate densities:
- National Policy Planning Framework 2021 new paragraph 130 Design
- National Policy Planning Framework 2021 new paragraph 131 Importance of trees
- National Policy Planning Framework 2021 new paragraph 132 Early and Meaningful Consultation the community
- London Plan policies D3, Optimising site capacity through the design-led approach;
- London Plan D4, Delivering good design
- London Plan, Policy H2 Small sites
- London Plan: Small Site Design Codes LPG (out to consultation currently)
- Croydon Suburban Design Guide (SPD2 Suburban Design Guide Adoption Statement (croydon.gov.uk))
- 2022 Consultation on Revised Croydon Local Plan 2018: (Croydon Local Plan: Detailed Policies and Proposals (Proposed Submission draft).docx)
- Current Croydon Local Plan 2018
Policy DM10: Design and character
Policy DM27: Protecting and enhancing our biodiversity Policy
How do these policies and guidance apply to the application for 130 Oval Road
Over development of the site NPPF, London Plan, Croydon Suburban Design Guide, Small Site Design Code, and Croydon Local Plan all are clear that new developments are key to providing new homes, but this number of new homes on this backland site is an over development of a constrained site, with an unacceptable level of adverse impact on neighbouring properties, in terms of height, scale, and mass. The overdevelopment leads to the loss of wildlife habitat, fails to deliver a landscape led scene, and misses the opportunity to deliver a scheme that enhances the site.
130 Oval Road is listed as Site 68 in Croydon’s 2018 Local Plan, which is out for further review. The draft lists the indicative number of homes for the site as 12, a change from 10-57 in the 2018 original. These revised figures reflect the Council revised view of the number of homes appropriate for this site.
Doesn’t reflect the character of the area The dominant form of Cedar Road, the set of properties closest to the development are 2-storey terrace housing. Oval Road had a mix of 2-storey and 3-storey homes, some of which have basements. Croydon Suburban Design Guidance and the new Mayor of London Small Sites Design Code are clear that backland development need to reflect the character of the surrounding height, both in design and in height.
Height of the development Fails to meet the requirements that is set out in the recent Mayor of London Small Sites Design Guidance Building height 4.1.10 and 4.1.17 “Height, massing and orientation New development should be no taller than its surroundings in height.”. Four storeys are too tall for this backland site and is too tall in comparison to the surrounding buildings. The height of the proposed buildings has a particular impact on the adjoining properties in Cedar Road. The appropriate heights should be a mix of 2-storeys and 3-storeys, and not 3-storeys and 4 storeys, these lower heights would reflect the heights of the adjoining properties in Cedar and Oval Roads.
Landscape, environment, wildlife, trees The application is not in accordance with DM 27 and DM 28 of the Croydon plan. The overdevelopment of the site leads to a loss of green space and wildlife habitat, in an area of Croydon that is short of green space. In particular, if it fails to adhere to Policy 4.2.10 of London Plan H2. which states applications which impact existing biodiversity or green space, as a result of minor housing developments, should be minimised and mitigated through measures such as returning hard standing to green space, the installation of green roofs and green walls, or the provision of landscaping that facilitates sustainable urban drainage in order to achieve the principle of no net loss of overall green cover.
The Mayor of London’s Small Sites design code requires that planning policies and decisions should ensure that new streets are tree-lined unless there are clear, justifiable and compelling reasons why this would be inappropriate. This development doesn’t take a landscaped approach, as recommended in the Croydon Suburban Design Guide, with much of the site developed as housing, it fails to provide the enhanced green infrastructure NPPF recommends should be an integral requirement for this development.
Privacy, Overlooking, and Impact on adjoining properties Due to the height, mass, and scale of the development, the proposed development will have an adverse impact on properties on Cedar and Oval Road. the distance between the rear of properties in Cedar Road to the development is problematic and fails to deliver the minimum distance of 18 metres between the habitable rooms in the building.
Metal Railings fail to provide privacy for the occupier or for residents opposite. Fully enclosed or perforated balustrades to ensure privacy for occupiers.
lack of meaningful consultation with neighbouring properties The applicant has failed to consult the local community on its proposals for the site. NPPF Paragraph 132 states there is a need to engage the community over design. There is a presumption that meaningful engagement should be treated favourably by the planning authority. In this case, we have an absence of meaningful engagement by the developer and this should be held against them, otherwise, Croydon is giving carte blanche to other developers not to engage with communities.