This post was first published by The Croydon Citizen on 19/09/2018.
Croydon’s new planning guidelines: great leap forward or stumble to uncertainty? (part 1)
Planning-development decision making in Croydon has been the subject of much controversy recently, with the apparent obsession with meeting the government’s and Mayor of London’s housing targets – regardless of the strategic policies and objectives of the Croydon Local Plan, with its detailed decision-making process.
Although the new Croydon Local Plan came into force earlier this year, it only has an effect if it complies with the government’s National Planning Policy Framework (NPPF) guidelines and the Mayor of London’s London Plan. These have been undergoing a process of change since the adoption of the Croydon Local Plan. In July, the government issued revised guidelines and the Mayor’s revised plan is currently subject to an inquiry.
So what are the implications of the new NPPF guidelines? It will take time to assess and understand what the significant changes are and how these will affect the way the Croydon Local Plan can be interpreted or ignored. The Croydon Local Plan cites particular paragraphs of the 2012 NPPF – so the council will need to issue a supplementary sheet to let people know what the 2018 replacement paragraphs are.
I have produced a note highlighting how the 2018 version has changed the 2012 one. This can be seen on my blog site. This article and the one that will follow are an attempt to start a discussion on what the new guidelines mean for Croydon. Except where it is clear that it is in new paragraphs, the new wording set out below is in italics.
In Section 2 on sustainable development, the government remains committed to the planning system contributing ‘to the achievement of sustainable development’, ‘meeting the needs of the present without compromising the ability of future generations to meet their own needs’. In 2012, the guidelines talked about the economic, social and environmental roles of sustainable development. Now they talk about them being objectives. These are ‘interdependent and need to be pursued in mutually appropriate ways’.
The government, however, also states that ‘local planning authorities may take decisions that depart from an up-to-date development plan, but only if material considerations in a particular case indicate that the plan should not be followed’ (paragraph 12). This opens up scope for much argument.
Sections 3 and 4 deal with plan-making and decision-making. Croydon already has its approved Local Plan. Decision making deals with technical matters.
Housing and the economy
As Section 5 on ‘delivering a sufficient supply of housing’ is a substantial rewrite, it needs to be carefully assessed so that future applications can be checked against it, given it takes precedence over the housing section of the Local Plan.
Section 6 ‘building a strong, competitive economy’ has been substantially rewritten, prioritising helping ‘create the conditions in which businesses can invest, expand and adapt… The approach taken should allow each area to build on its strengths, counter any weaknesses and address the challenges of the future…‘ (paragraph 80).
Communities and their centres
Section 7 ‘ensuring the vitality of town centres’ is key to how Croydon planners will need to assess future applications in the town and district centres. A key aim is to ‘promote their long-term vitality and viability – by allowing them to grow and diversify in a way that can respond to rapid changes in the retail and leisure industries, allows a suitable mix of uses (including housing) and reflects their distinctive characters‘ (paragraph 85(a)).
The implications of Section 8 ‘promoting healthy and safe communities’ needs wide discussion. The government remains committed to planning policies and decisions aiming ‘to achieve healthy, inclusive and safe places’ (paragraph 91). The previous phrase ‘promote social interaction’ has been amplified by ‘including opportunities for meetings between people who might not otherwise come into contact with each other – for example through mixed-use developments, strong neighbourhood centres, street layouts that allow for easy pedestrian and cycle connections within and between neighbourhoods, and active street frontages’ (paragraph 91a).
Paragraph 91(c) adds ‘enable and support healthy lifestyles, especially where this would address identified local health and well-being needs – for example through the provision of safe and accessible green infrastructure, sports facilities, local shops, access to healthier food, allotments and layouts that encourage walking and cycling‘.
Given the controversy about the council’s re-designation of parts of the Green Belt and Metropolitan Open Land during the consultation and inquiry into the Local Plan, and its failure to produce an acceptable designated list of Local Green Spaces, the sub-section in Section 8 ‘Open space and recreation’ is crucial to all the campaigners for the protection and enhancement of our parks and large and small open/green spaces.
Paragraph 99 states: ‘The designation of land as Local Green Space through local and neighbourhood plans allows communities to identify and protect green areas of particular importance to them. Designating land as Local Green Space should be consistent with the local planning of sustainable development and complement investment in sufficient homes, jobs and other essential services. Local Green Spaces should only be designated when a plan is prepared or updated, and be capable of enduring beyond the end of the plan period’.
Paragraph 100 sets out the criteria from 2012 which the inspector used to justify his rejection of the council’s submitted designated list of Local Green Spaces. The council has yet to act on his advice that it prepares supplementary planning guidance based on the criteria.
Transport and communications
Section 9 ‘promoting sustainable transport’ puts the emphasis on improving transport infrastructure, walking, cycling, public transport and mitigating ‘environmental impacts of traffic and transport infrastructure’. Paragraph 102(e) is an addition stating ‘patterns of movement, streets, parking and other transport considerations are integral to the design of schemes, and contribute to making high quality places‘.
The government is placing a caveat on planning attitudes to limit parking provision with a new paragraph (106): ‘Maximum parking standards for residential and non-residential development should only be set where there is a clear and compelling justification that they are necessary for managing the local road network, or for optimising the density of development in city and town centres and other locations that are well served by public transport (in accordance with chapter 11 of this framework). In town centres, local authorities should seek to improve the quality of parking so that it is convenient, safe and secure, alongside measures to promote accessibility for pedestrians and cyclists‘.
It now takes a clear view about minimising ‘the scope for conflicts between pedestrians, cyclists and vehicles’ and recognises the needs of those with ‘reduced mobility in relation to all modes of transport’ (paragraph 110).
Section 10, ‘supporting high-quality communications’, is largely about electronic and digital infrastructure, including the roll-out of 5G.