Mr Tom Cole Montagu Evans LLP 5 Bolton Street Mayfair W1J 8BA

Development Management 6th Floor, Bernard Weatherill House 8 Mint Walk Croydon CR0 1EA Please ask for/reply to: Emil Ancewicz Email: emil.ancewicz@croydon.gov.uk Tel: 020 8726 6000 Our ref: 19/04617/PRE Date: 07/11/2019

Without Prejudice

Dear Mr Cole,

TOWN AND COUNTRY PLANNING ACT 1990

Site: 2 Witherby Close, Croydon, CR0 5SU

Proposal: Demolition of existing dwelling and erection of a two/three storey building comprising of 9 residential units.

I write in response to your pre-application enquiry, submitted drawings received on 30th September 2019 and our meeting at Bernard Weatherill House on 24th October 2019. Comments have been provided on the basis of the submitted plans.

Site context

The application site comprises a two storey detached dwelling situated on the western side of Witherby Close. This site is a corner plot that also abuts Coombe Road. The whole plot is elevated approximately 2.5 - 3 metres above Coombe Road. The wider surrounding area is mainly residential in character, comprising detached and semi-detached properties, and a number of flatted developments. Architectural expression and building typology are diverse; however, neighbouring dwellings share some common features, including two storey front projections with gabled ended or hipped roof, along with generous front gardens with planting and low boundary walls. As identified in your report, neighbouring houses along the south of Coombe Road have a planted sloped embankment, the latter of which, however, does not have a policy designation. There are no specific policies relating to this site. The site is at risk of Groundwater Water Flooding, as identified by the Croydon Plan.

Relevant Planning History

None.

Policy Background

National

At the national level any application would be considered under the National Planning Policy Framework (February 2019). I have no doubt you are fully cognisant with the NPPF so will not go into further detail here.

London

At the regional level the London Plan consolidated with alterations since 2011 (March 2016) is relevant and you should address any requirements as part of your submission. Key policies relevant to your submission are transport (policies 6.3, 6.11, 6.12, 6.13 and 6.14) and design (policies 7.4, 7.5 and 7.6).

Croydon

The Croydon Local Plan 2018 was adopted on 27th February 2018. CLP 2018 seeks to provide the basis for the development of Croydon up to 2036, with particular reference to new homes and jobs together with the overall environment. The significant changes proposed in Croydon over the next 20 years will require additional infrastructure such as new/expanded schools, an increase in health facilities, enhanced public transport and flood amelioration measures. This plan encompasses the strategic and detailed policies.

Key policies which are relevant to your submission are: SP2 (Homes), SP4 (Urban Design and Local Character), DM10 (Design and Character), DM13 (Refuse and Recycling), DM16 (Healthy Communities), SP6 (Environment and Climate Change), DM23 (Development and Construction), DM25 (Sustainable Drainage Systems and reducing flood risk), DM28 (Trees), DM29 (Promoting Sustainable Travel and Reducing Congestion) and DM30 (Car and Cycle Parking in New Development).

Croydon’s Suburban Design Guide SPD (2019) has now been adopted and has full weight in the full decision making process. This document provides guidance for suburban residential developments, development in Areas of Focussed Intensification and extensions and alterations to existing homes across the borough. The document provides technical design guidance that seeks to both limit any negative impact on places, including the amenity of existing residents, and frame opportunities where increased densities can enhance places and bring benefits to communities.

The above policy background represents the framework within which all applications are determined. Any submitted application must make specific reference to the above policies and how any proposed scheme would address these. Submitted documentation such as Planning Statements and Design and Access Statements need to accurately reflect the current policy position, in order to be considered up to date and relevant documentation. Failure to bring your application submissions in line with this policy will result in the invalidation of any future planning application.

The Proposal

The proposal involves the demolition of existing dwelling and erection of a two/three storey building comprising of 9 residential units.

Comments on the proposal

Principle

In accordance with current national and local plan policies, the principle of redevelopment of the site is considered acceptable given the need for housing within the borough and the residential nature of the surrounding area.

However, the key aim of this Labour administration is to deliver much needed affordable housing. Providing a 9-unit scheme would circumvent the requirement for affordable housing. The Council is actively seeking to optimise the development potential of sites and refusing applications where opportunities to provide affordable housing by optimising density have not been forthcoming.

Whilst there are extra planning considerations to overcome with a larger scheme, the Council strongly encourage you to consider the provision of additional units on the site. This should, of course, be balanced against other considerations and must not result in the reduction of the quality of the units or a compromise in the overall design quality. However, the provision of major scheme comprising affordable housing will strongly weigh in favour of the application.

If a larger scheme is not pursued, it will be necessary for you to demonstrate that various options have been tested and the reasons why these have been dismissed as viable options. The Council must be convinced that the site has been optimised in terms of the quantum of development.

Housing mix

Policy DM1.2 of the Croydon Plan 2018 states: ‘The Council will permit the redevelopment of residential units where it does not result in the net loss of 3 bedroom homes (as originally built) or the loss of homes smaller than 130m2’.

No existing plans have been provided, and thus the size of existing house is unclear. It however appears to be larger than 130 square metres. Planning history of neighbouring dwellings (that are of similar typology to subject house) suggests that No. 2 was likely originally built as four bed home, meaning that Policy DM1.2 would not apply to this scheme. Nevertheless, any revised scheme should include evidence demonstrating that the existing dwelling was not originally built as a three bedroom house or alternatively provide at least one 3 bedroom flat or house if no evidence is provided.

Policy SP2.7 seeks to ensure that a choice of homes is available in the borough that will address the borough’s need for homes of different sizes and that this will be achieved by setting a strategic target for 30% of all new homes up to 2036 to have three or more bedrooms. Within three years of the adoption of the Local Plan, 2 bed, 4 person units would also be considered family housing and would therefore contribute to such housing provision within the Borough.

The mix proposed is 1 x 3 bedroom, 5 x 2 bedroom and 3 x 1 bedroom dwellings. Assuming that the proposed two bedroom flats would have four bed spaces, the scheme is supported. Any revised scheme should aim to provide at least 30% of family-sized units (2 bed, 4 person units or larger), including at least one 3 bedroom flat or house (unless demonstrated that the existing dwelling was not originally built as a three bedroom home).

Townscape

Massing

Local Plan Policy DM10.1 states that proposals should be of high quality and, whilst seeking to achieve a minimum height of 3 storeys, should respect:

a. The development pattern, layout and siting;

b. The scale, height, massing, and density; and

c. The appearance, existing materials and built and natural features of the surrounding area.

This point is further clarified by the Suburban Design Guide which sheds light on the desirable height of new buildings in different local contexts. The subject site is a corner plot, which can accommodate an additional storey to the 3 storeys recommended in the Croydon Local Plan Policy DM10.1 (please see the below figure). Some corner plots may be able to accommodate further height provided the massing is responsive to neighbouring properties. Further, redevelopment of corner plots:

May extend beyond the neighbouring rear elevations to a greater amount than set out in guidance in Section 2.11 where it would enhance the definition of a suburban block and contribute positively to the townscape. This will be judged on a case by case basis and balanced against any unreasonable impact on neighbouring amenity.

Should respond to the positioning of neighbouring front elevations, which may require stepping in footprint to maximise development potential of a corner plot.

In this case, it seems that some of this guidance has been utilised (i.e. extending the development beyond the neighbouring rear elevations to a greater amount than set out in Section 2.11 of the SDG); however, the proposed massing does not appear to have been maximised as sought by the guidance. It is suggested that you explore opportunities to increase both height and footprint of the building. With regards to the

former, it is recommended that the height of the building is increased by one storey across the whole development, meaning that the corner section of the building would be 4 storey high, with the remaining part being stepped down to 3/3.5 storeys. Further, the massing of the building could be pulled closer to No. 4, assuming that you would be able to accommodate a driveway through the extended part of the building.

Whilst the principle of gabled ended roof form is supported, please refer to the below pictures for inspiration on how to successfully accommodate additional massing at corner plots (top picture: Northbrook Road scheme by Stitch Architects; bottom picture: residential scheme in Croydon by OB Architecture).

Layout

During the meeting we questioned whether the layout of the development should respond to the curvature of Coombe Road; however, you explained the site levels and other pedestrian access arrangements provided elsewhere along Coombe Road. You also explained that the buffer of heavy planting is typical of this side of the road. Thus, we have no principal objection to the building not responding to the curvature of Coombe Road. In any case, it may be worth exploring if the lower section of the building could be pulled closer to Coombe Road as this would help in creating an active street frontage.

Adequate levels of defensible space would be maintained along Witherby Close. It is however noted that the building line along the western side of Witherby Close is not well established, and therefore some slight stepping out from existing rearmost building line of existing dwelling may be acceptable, subject to maintaining adequate separation distance to opposite dwelling at No. 1.

The proposed layout necessitates surface level car parking and access which we feel is a major drawback of the scheme. Given the significant change in land levels across the site, it appears that basement level parking would be a good alternative, and would create a far more attractive development, allowing more of the area surrounding the built form to be given over to open green space/amenity areas. This would also better respect the amenity of the adjacent dwelling at No. 4 as vehicle movements along the boundary would be reduced.

Architectural Expression

It is clear from the character appraisal provided of the local area that you are considering the context as part of design development. Currently the proposal does not specify which aspects of the context you will be responding to, but the Council is encouraged by the evidence and design precedents provided. For the next stage of design development, you should demonstrate how the design responds to and interprets this context. This is applicable for both the form and materiality of the proposal. It should demonstrate how some elements of local design are referenced within the proposal.

Whilst the gable ends facing Coombe Road are supported in the indicative massing, the council questions the way that the roof form currently negotiates turning the corner, as the resulting roof form facing Witherby Close is currently wholly different to the other properties on Witherby Road. Due to the strong aesthetic of these properties, it is important that the proposal responds to and enhances this character. Crucially, respond does not mean replicate and allows for interpretation of existing character to create something new that enhances the area and its character.

Affordable Housing

Given the comments raised above in relation to the opportunities for increasing the massing of the development, it appears that the site is capable of providing 10+ units and still be policy compliant. If any revised scheme provides 10 units or more, the Council’s affordable housing policies will be applied.

Policies SP2.4 and SP2.5 of Croydon Local Plan (2018) set out that a minimum of 50% of units must be secured as affordable housing on sites of ten or more units. Any provision of less than 50% will need strong justification as to why the policy requirements are not achievable, to be demonstrated through the submission of a viability assessment which would be independently reviewed at your expense. All affordable units should be provided at a 60:40 split between affordable/social rent and intermediate products unless we have agreement from a Registered Provider that this split is not practical in this location. Any viability appraisal would additionally need to be very clear why on site provision is not feasible, and whether or not a Registered Provider would be interested in the site.

Under the new policies in Croydon Local Plan (2018) we would seek to achieve a 50% on-site provision for affordable units again with a 60:40 split. The new policy requirement also states that there is a minimum requirement of affordable housing to be provided either as:

30% affordable housing on the same site as the proposed development; or

15% if the site is in the District Centre and 15% affordable housing on a donor site with prior planning permission within the same place as the District Centre; or

15% affordable housing on the same site as the proposed development plus a Review Mechanism entered into for the remaining affordable housing (up to the equivalent of 50% overall provision through a commuted sum based on a review of actual sales values and build costs of completed units) provided 30% on-site provision is not viable, construction costs are not in the upper quartile and there is no suitable donor site.

Anything offered below any of these requirements would be refused.

Consideration of viability is a process should be started now so that the development can be designed to allow for maximum on-site affordable housing provision.

To be absolutely clear, under the new policy anything less than 15% on-site affordable housing will be refused.

If any revised scheme provides less than 10 units on site, we will require a strong justification (other than financial considerations) as to why it has not been achieved.

Residential amenities of adjoining occupiers

It is necessary to demonstrate both in plan and elevation the impact of the development on the closest adjoining occupiers. This should ensure that when measured from the middle of the window in closest habitable room of the closest adjoining occupier (at both ground and first floor), the depth and height of the building do not project beyond a 45 degree angle. If your proposal breaks this 45 degree angle in either way, it should either be set-in from the boundary or reduced in height, depending on the proposed impact.

No. 4 Witherby Close

The main dwelling that would be affected by the development is 4 Witherby Close.

This dwelling does not feature any side facing windows; however, you need to ensure that the proposed development (a) does not project beyond a 45 degree angle (both in plan and elevation), and that (b) adequate separation distances are maintained to prevent overlooking to habitable windows and private outdoor space within 10 metres perpendicular to the rear elevation of a dwelling (Policy DM10.6). In this particular case, the proposed development would also affect this neighbour by the inclusion of internal access road and car parking along the boundary. You need to ensure that each of this points is carefully addressed:

a) The submitted plans likely underestimate the distance between nearest habitable window at ground floor level of No. 4 and boundary of the site. Approved drawings as part of application ref. 16/01581/P do not clearly specify the function of the nearest room, and thus the window may in fact serve non-habitable room. If you can prove that the nearest window does not serve habitable areas of the dwelling, you will be able to draw the line from the second nearest window. In any case, you will also need to draw 45 degree lines from the nearest first floor front and rear facing windows (please see below).

It is likely that the rear 45 degree line (in plan) would be broken by the massing of the western part of the building. This would however not necessarily result in refusal of planning permission given that it is corner site and that sufficient separation distances would be maintained.

b) You need to ensure that the development does not overlook private outdoor space within 10 metres perpendicular to the rear elevation of No. 4. This only applies to windows at first floor level and above, because the outlook from ground floor level windows would be obscured by a boundary wall. Given the width of the site, any clear glazed windows looking directly at first 10 metres of the rear amenity space of No. 4 would be unacceptable. You should therefore explore options if angled or oriel windows can be incorporated in order to provide better outlook for the future occupiers (please refer the above figure). Oriel windows could mitigate the issues of overlooking by directing views away from neighbouring dwellings and obscuring elements (see Moray Mews by Peter Barber Architects for oriel windows inspirations, and documents approved as part of 16/04589/FUL permission for angled windows inspirations).

c) Even assuming that you comply with the above criteria, the scheme would still have some (albeit acceptable) impact on the amenities of No. 4. The impact would however be execrated by the provision of a driveway and parking spaces along the western boundary of the site. As suggested above, the site’s topography lends itself for the provision of an undercroft car parking which would address this issue. You could either provide a new vehicular access off Coombe Road or utilise existing access (preferred option). If you take the latter approach, then it is suggested that the massing of the building is pulled closer

to No. 4, and that a driveway through the extended part of the building is provided. This would allow you to provide additional accommodation, and would partially insulate the noise from comings and goings of the vehicles (assuming that the driveway would lead to an undercroft parking rather than surface level car parking).

Nos. 1 Witherby Close; 171 - 181 Coombe Road; and, flats to the rear

As it stands, the development would not affect the amenities of neighbours located to the east, north and west. You will need to ensure that any revised scheme maintains adequate separation distances (please refer to the Suburban Design Guide for more details).

* * *

Please note that impact on residential amenity can only be fully assessed as part of the submission of a formal application whereby the neighbours will be notified. It is strongly suggested that you discuss your proposals with the neighbours at this stage.

Living conditions of future occupiers

Internal space

All dwellings should adhere with the Technical Housing Standards in relation to their overall and individual bedroom sizes. Based on the proposed schedule of accommodation, all of the proposed units would exceed the minimum floor space requirements in terms of GIA.

No floorplans are available at this stage, and therefore we are not in position to provide detailed comments on the proposed housing standards. In any case, you should have regard to the below points:

The provision of all double aspect flats and houses is commended, alongside the mixture of typologies. The design should ideally aim to maintain these standards throughout the design development. However, the provision of a limited number of single aspect one-bedroom flats would also be acceptable.

If surface car parking is proposed (including to the front of the building), you will need to ensure that none of the proposed flats would have direct outlook into the car park. This could be prevented by the provision of generous defensible space with planting along the front wall of the building. During the meeting, it was suggested that an internal waste store could be contained within the front part of the building.

Internal layouts should be provided at the next stage of development, including an indication of a wheelchair adaptable dwelling in line with London Plan standards, as well as wider mobility around the site.

The London Plan Policy 3.8 and London Housing SPG Standard 11 requires 90% of the dwellings to be Category 2 ‘accessible and adaptable’ M4(2), with the remaining 10% of the dwellings designed to be Category 3 ‘wheelchair user dwellings’ M4(3). A condition would be attached to any permission requiring these standards to be provided prior to any residential occupation of the building, and retained as such for so long as the development remains in existence. Each case will be looked at on its own merits in terms of M4(2) and M4(3). Please show on your plans how at least one of the units could be a wheelchair user dwelling and how the remaining could be accessible and

adaptable. Accessible units usually require a bigger floor space. The layout of the M4(3) unit should be shown on your plans to show how the development would comply.

Private amenity space

Policy DM10.4 requires all proposals for new residential development to provide private amenity space. The policy requires that the private amenity space:

a. Is of high quality design, and enhances and respects the local character;

b. Provides functional space (the minimum width and depth of balconies should be 1.5m);

c. Provides a minimum amount of private amenity space of 5m2 per 1-2 person unit and an extra 1m2 per extra occupant thereafter.

All units would have access to adequate amount of private amenity space.

In any case, you will need to ensure that there is no unacceptable overlooking between balconies and neighbouring dwellings (including amenity spaces). Privacy screes may need to be incorporated to balconies looking at No. 4.

Communal amenity space

As well as provision of private amenity space, Policy DM10.5 requires proposals for new flatted development to incorporate high quality communal outdoor amenity space that is designed to be flexible, multifunctional, accessible and inclusive.

It is not clear whether the scheme provides any communal amenity space. Assuming that car parking would be moved into a basement beneath the proposed building, you should utilise space freed up for more meaningful communal amenity space and retention of biodiversity on site.

You should appoint a landscape architect to work on the concept and outline layout of the soft and hard landscaping at pre-planning, especially if this proposal will likely be delivered post-planning by the same design and development team.

Shared outdoor amenity space should be designed to accommodate a series of different uses, with quieter seating areas along with family orientated areas, and should seek to include a mixture of grassed and planted areas as a minimum, and a shared patio area.

The development should consider making a shared garden shed and garden tap as part of this element, to facilitate maintenance and ownership over the space by residents.

You should develop an enhancement to the site in regards to current levels of biodiversity, as well as improved surface water run-off rates. This could include varieties of planting, insect boxes, green roofs, SUDs features. See pages 79-83 of the Suburban Design Guide.

Following the adoption of the Croydon Plan 2018 all flatted developments must provide a minimum of 10m2 per child of new play space (Policy DM10.4), calculated using the Mayor of London’s population yield calculator. In this case you should review policy DM10.4 with table 6.2 seen below. I would recommend that any play-space provided is informal, made of natural materials and that you review the London Mayors Play and Informal Recreation SPG when designing this.

Parking and highways

The public transport accessibility level (PTAL) is rated as 2, which is very poor. The site is within a 12 minute walk from South Croydon station.

Your proposal should be reviewed in line with Policy DM30 and table 10.1 of the CLP 2018 seen below:

You are proposing 9 units but only 5 parking spaces. The amount of parking proposed is insufficient. Given the low PTAL of the site and existing parking issues in the area, it would be expected for the development to provide 1:1 parking. As part of any application you would need to provide a Transport Assessment comprising details of trip generation and vehicle ownership to calculate the anticipated demand.

Witherby Close has yellow lines that prevent parking Mon-Sat 9am to 5pm. and Coombe Road restrictions operate 7am to 7pm Mon-Sat. Whilst not supported, a car parking survey could be undertaken; however, we could only accept very limited on street parking as part of this proposal.

A parking stress survey would need to demonstrate that there is scope of any overflow parking to be accommodated on the surrounding road network (without causing any harm to highway safety or other road users). This needs to address the parking restrictions on Witherby Close and Coombe Road, and also take account of the cumulative impact of other infill developments that have taken place in the surrounding area.

Should the surrounding area provide a suitable amount of on street provision for any potential overspill parking, a condition would need to be attached should permission be granted, that would restrict occupants of the new dwellings from having access to parking permits.

As suggested above, you should aim to provide undercroft parking in order to provide adequate amount of communal amenity space and to meet biodiversity requirements (please refer to the below picture on the right inspiration).

The provision of new vehicular crossover off Coombe Road could be supported if benefits of the scheme mitigate the loss of a valuable tree along Coombe Road (discussed in subsequent sections). You will need to ensure that the vehicular access is level at the footway for cars to achieve 2.4x43.0m and 2x2m pedestrian sightlines either side of the vehicle access. Landscaping and boundary treatment should not exceed 0.6m to allow visibility within the sightlines. The driveway in particular will need to be designed carefully in this instance to prevent conflict in terms of in/out movements, which in turn could impact how the junctions surrounding the site can safely and efficiently function. Detailed drawings and statements will need to be submitted in regards to this.

The parking spaces at the front directly off of Witherby Close are not acceptable in the context shown as vehicles would not be able to enter and exit the site in forward gear. Parallel car parking spaces could in theory be provided to the front of the building; however, there would still be conflict between the spaces at the back and the vehicle movements between the rear and front spaces. In addition the crossover will be too wide for pedestrians to negotiate, and otherwise unacceptable in design aspects. It is suggested that no car parking is provided to the front of the building.

It is required to provide at least one disabled parking bay with ability to convert a second if needed. 20% of parking bays need to have EV charging points with the rest passive provision – we will require evidence showing how you have provided passive provision.

As part of any future submission is it is required to provide vehicle tracking details demonstrating access to each parking space and turning within the site.

Provision of pedestrian access off Coombe Road is supported.

Provision needs to be made for covered secure cycle storage in accordance with the standards set out in the London Plan. One space is required for one bedroom units and two spaces are required for each unit with two or more bedrooms. This equates to 15 spaces for the proposed development.

The proposed location of cycle store is acceptable, but it must be separate from refuse store. As per the Suburban Design Guide, it should be integrated within the envelope of the building form. Alternatively, it could be provided in the internal courtyard. You will need to show the method of cycle storage on plan

in any formal application, and consider at least one or two sockets for electric bikes and space for cargo bikes.

Policy DM13.1 requires refuse and recycling facilities to be sensitively integrated within the building envelope where they will not be visually intrusive. Carry distances for residents should be a maximum distance of 30m (from their front door excluding vertical distances) and drag distances for refuse operatives a maximum of 20m. Details of levels and gradients should be provided to ensure that the bins can be easy manoeuvred and collected. Slopes should be avoided wherever possible, but where needed the gradient should fall away from the bin storage area and should be no greater than 1:12. It is generally not acceptable for the route between the storage area and the collection vehicle (i.e. in the direction that filled bins will be pulled) to have any uphill gradients. Bin stores is also not indicated on the plans. Similarly to bike store, it should be integrated within the envelope of the building form.

Refuse store should be provided internally, so as not to clutter the street scene. The proposed location of refuse store is unacceptable as the carry distance would likely exceed 30 metres. It is suggested that refuse store is accommodated within the front part of the building. The size of bins required would be as follows:

o General waste – 130ltr for 1 bed flat, 140ltr for 2 bed flat, 150ltr for 3 bed flat.

o Dry recycling – 128ltr per flat o Food recycling – up to 15 flats – 1 x 140tr bin and 1 x 9ltr food caddy per

unit.

Your plans should demonstrate the proposed refuse store will be of sufficient size to accommodate the bins. For details of bin size, please refer to the Council’s Waste and Recycling in Planning Policy Document.

Demolition and Construction Traffic Management plan in draft will be required at application stage due to the location of the site at a junction.

Trees and landscaping

Existing trees

There is a number of trees across the site, in particular to the rear and along Coombe Road. None of them is protected by a TPO; however, Tree Officers recommended that two existing mature trees along Coombe Road are worth protection. It is

therefore suggested that the development is designed around these trees.

Any future submissino should include a Tree Survey and Tree Protection Plan. A Tree Protection Plan should also take into account all trees on neigbouring plots that could be affected by the development. The latter is not only limited to the main building, but also includes boudnary walls and areas of hardstanding. Please note that all trees around Campion Close apartments are protected (please see the above picture – TPO applies to any trees within the dotted line).

It is noted that a new vehicular access off Coombe Road would likely necessate the felling of an exising mature tree (please see the picture on the right). This should be avoided; however could be supported if sensible replacements are proviedd (in the form of two heavy standard trees as these would bring immediate benefit to the character of the area).

Soft landscaping

Please see our comments in ‘Communal amenity space’ section of this report.

Hard landscaping

All hard landscaping should be undertaken with permeable materials and this should be detailed on your plans. You should provide a pedestrian pathway, which could be indicated by an alteration in hard standing materials. At a minimum this should be shown and annotated on your block plan.

A low level front boundary needs to be shown on the plans. It is suggested that existing brick wall along Witherby Close is retained.

Ecology

The existing house would be demolished, some planting and soft landscaping is proposed to be removed and there are mature trees on and around the site. Based on Natural England Standing Advice https://www.gov.uk/guidance/protected-species-how-toreview-planning-applications a Phase 1 Ecological Survey should be undertaken to ensure the proposals would not harm any protected species and that there is no net loss in biodiversity.

Flooding

The site is at risk of Groundwater Flooding, as identified by the Croydon Plan. Further, the adjacent section of Coombe Road is at high risk of surface water flooding. Any future application would need to be accompanied by a Flood Risk Assessment which incorporates SuDS as set out in the NPPF.

SUDS elements should be considered in more detail. SUDs designers should consider the council’s recently developed guidance, in order to incorporate features such as green/brown roofs, filler trenches and drains, bioretention systems, permeable paving and rainwater harvesting such as water butts.

Policy DM25.3 requires site specific sustainable drainage systems in all development. This includes but is not limited to addressing the following issues in order of preference:

1 store rainwater for later use

2 use infiltration techniques, such as porous surfaces in non-clay areas

3 attenuate rainwater in ponds or open water features for gradual release

4 attenuate rainwater by storing in tanks or sealed water features for gradual release

5 discharge rainwater direct to a watercourse

6 discharge rainwater to a surface water sewer/drain

7 discharge rainwater to the combined sewer.

As detailed, you are advised to consider the direction of water flow across the site and where this may be dispersed to incorporating any features that will help reduce surface water run-off. The site would also appear to fall within an area susceptible to groundwater flooding and therefore should consider this.

Please visit the following link for flooding advice provided by the Lead Local Flood Authority (LLFA) https://www.croydon.gov.uk/environment/flood-water/advice-to-planning-applicants

Sustainability

Any proposed development should make the fullest contribution to minimising carbon dioxide emissions in accordance with the London Plan energy hierarchy (Be Lean; Be Clean; Be Green). You are required to demonstrate that sustainable design standards are integral to the proposal, including construction and operation, and ensure that they are considered at the beginning of the design process. Residential schemes require:

a. 19% reduction in CO2 emissions over 2013 Building Regulations. Prior to first occupation we require a copy of the EPC certificate(s) as evidence that the target has been met.

b. The scheme shall be designed and built so mains water consumption would meet a target of 110 litres or less per head per day

Other matters

Community Infrastructure Levy (CIL)

In accordance with London Plan Policy 8.3, the Mayor of London has introduced a London wide Community Infrastructure Levy (CIL). This will be paid on the commencement of new development in Greater London in relation to planning applications determined. The Mayoral charge for Croydon is currently £28.73/m2 of additional floor space.

In addition to the Mayoral CIL, development proposals would also be subject to Croydon’s Community Infrastructure Levy (CIL). The charge is currently £167.16/m2 of additional floor space.

Further information is available at:

http://www.croydon.gov.uk/planningandregeneration/croydons-planning-policyframework/community-levy/

Pre-commencement conditions

Owing to recent amendments to legislation, Section 100ZA of the Town and Country Planning Act 1990, the Local Planning Authority is now required to agree all pre-commencement conditions, should the application be recommended and granted approval, a minimum of 10 working days prior to determination with the applicant/agents for the site. Please be aware, that should this be the case the LPA will be in touch to confirm the proposed wording of the conditions and to gain your agreement to these.

Consultations

We recommend that you engage with the closest adjoining occupiers and most relevant residents association at an early stage to discuss the proposed development with them, to understand any concerns they have and explore opportunities for overcoming these.

Please be aware that if in future you submit a planning application related to this site, pre-application advice will be made available to the public subsequently.

Conclusion

Thank you for presenting the development of the scheme. The initial approach to site is supported, including the principle of development, and the applicant is commended for providing an assessment of the local character of the area. The massing, site layout, massing car parking need further working up. I would strongly advise that you undertake a second pre-app on this site.

All of the comments and advice above should be addressed in the submission of any formal application.

Applications should be submitted online through the Planning Portal

(www.planningportal.gov.uk) and you will be required to submit the following:

An Application Form and appropriate fee.

Site Location Plan at a scale of 1:1250

A Block Plan at a scale of 1:500

Topographical survey

Proposed Site Plan at a scale of 1:500 detailing any parking, landscaping, cycle/refuse storage, communal garden and play space and the location of the adjoining occupiers from the flank elevations for clarity.

Proposed coloured Elevations, Floorplans and Sections (detailing floor to ceiling heights) at a scale of 1:50 or 1:100. Plans should show finished floor levels. Further, plans should indicate the adjoining occupiers’ closest habitable windows and the 45 degree angle.

Existing and proposed sectional drawings through the site and showing relationship with adjacent properties and land levels.

Proposed streetscene elevations from front, rear of the site (indicating the adjoining occupiers’ closest habitable windows and the 45 degree angle).

3D visualisation from key viewpoints (including front and rear of the building).

Proposed Elevations and Floorplans for cycle and refuse stores at 1:50 or 1:100 (unless accommodated internally)

Design and Access Statement (among others, it should cover the following matters: (1) contextual analysis of the surroundings to inform elements of the design, such as the fenestration, detailing and materiality; (2) palette of materials with precedent photos and samples supported by the annotations of elevation drawings.

Vehicle tracking details demonstrating access to each parking space and turning within the site.

A scaled dimensioned drawing showing the parking layout and access design in compliance with Highway Visibility Splay Standards for pedestrians and motorists.

A proposed landscaping plan at an appropriate scale, including details of existing and new planting, species and pot sizes and boundary treatments.

Tree Survey and Tree Protection Plan.

Flood Risk Assessment and SUDs strategy.

A phase 1 ecology assessment and Biodiversity Assessment.

Transport Statement.

Draft demolition and Construction Traffic Management Plan.

A CIL Form.

Any other details which may be required by the Local Planning Authority to review the application.

Failure to provide the required information may result in an application not being registered and being returned. You are advised that applications should be submitted online through the Planning Portal (www.planningportal.co.uk).

If you require any additional information in relation to our policy documents, these can be sourced on our website at

https://www.croydon.gov.uk/planningandregeneration/framework/localplan

You will appreciate that the above comments are made without prejudice to any final decision that the Council may wish to take in respect of any formal planning application that you may wish to submit.

Yours sincerely,

Emil Ancewicz

Planning Officer

Submitting your application Online

The London Borough of Croydon Planning Department recommends that you submit your application online by using the Planning Portal one-stop-shop where you will find a simple and easy to use online application form that allows

you to send your application directly to us. You can even buy site maps and attach supporting documents and drawings if you wish.

The many advantages of submitting your application electronically includes help, guidance and information all in one place, not requiring to make multiple copies of plans and forms plus you‘ll get notification by email informing you that your application has been received. Also, by creating a login account the portal remembers your details thereby making it even easier when submitting further applications.

The Planning Portal has been designed to answer all your questions and guide you towards making a successful planning application. Just log onto the site at www.planningportal.gov.uk and follow the simple instructions