When Paul Scott, the architect behind Croydon’s disastrous planning and housing policies, endorsed a self-congratulatory article for the council’s website last month, he unwittingly unleashed the pent-up fury of eight of the borough’s biggest, and most influential, residents’ associations.
The article on behalf of the cabinet member for planning (job share; £39,195 per year in council allowances) came under the impressive-seeming headline, “Borough reaches milestone in long-term housing plan”.
Any pour souls who were patient enough to wade through all 800-plus words of councilspeak and dry prose were to be disappointed, though: nowhere did the council press officer who drafted this piece of piffle, nor Scott himself, bother to state what this “milestone” that they claimed had been reached might be.
“Croydon Council has begun the next stage of working out how many thousands of new homes will be delivered over the next 20 years to tackle the housing crisis and boost the borough’s economy,” the article began, quickly revealing that this would in fact be a justification for Scott’s personal mission to concrete over Croydon’s green spaces, playgrounds and suburban streets.
According to the Croydon Council article, “Based on government methodology, up to 46,040 new homes are needed in the borough by 2039.
“Last year the Mayor of London proposed in his draft London Plan that Croydon and other boroughs in the capital should plan to accommodate an increased number of new homes.”
The article then refers to a letter sent to London Mayor Sadiq Khan from Robert Jenrick, the Secretary of State for housing, that suggested “gentle densification”.
Scott has latched on this to claim that “this means at least 33,496 new homes by 2039 – 6,905 more than under the council’s approved Local Plan.”
But according to the eight residents’ associations, “Councillor Scott and Croydon Council hide their ideology behind a London-wide housing crisis, even though this has not caused other London boroughs to concrete over their suburbs.”
Geoff James, the planning officer for KENDRA, the Kenley and District Residents’ Association, has written a lengthy critique of Scott’s claims, in which he says, “Councillor Scott’s position is not tenable, as he can only attempt to support this policy by making very selective and erroneous interpretations of the comments from the examiners of the draft London Plan, and of a recent letter from Robert Jenrick.”
James’s paper already has the backing of the Foxley RA, Hartley and District RA, Purley and Woodcote RA, Riddlesdown RA, Woodland Way RA, Old Coulsdon RA and Sanderstead RA. Between them, these RAs are reckoned to represent more than 6,000 households in the south of the borough.
In Scott’s article, it was noticeable that he has quietly opted to scale-down one of his grand plans – to build 12,000 flats on brownfield sites in former industrial estates along the Purley Way. It seems likely that Scott has been forced to scale down this part of his building project after being scolded in a letter sent to the council from the Mayor of London in January which said, “the Mayor would welcome a better understanding of how approximately 12,000 homes could be delivered along the Purley Way without impacting the industrial functions of the Purley Way Strategic Industrial Locations”.
According to Scott’s latest article, he now “only” wants to squeeze 9,000 homes alongside the toxic A23 urban motorway. But that is potentially is bad news for the leafier suburbs to the south of the borough, who fear that Scott will expect to load another 3,000 flats in their neighbourhoods.
“Croydon was already in the grip of a London-wide housing crisis before the coronavirus pandemic, and the need to tackle homelessness, overcrowding and affordability is now more important than ever,” Scott wrote.
“The government and the Mayor of London have made clear we must build more homes in Croydon than we previously planned, and to do this will require small, large, urban and suburban sites.”
James and the residents’ associations say that Scott wants to “build on the suburbs to reach greater new-build housing targets that will materially exceed any of the already ambitious targets set by the Mayor of London”.
In his paper, James writes, “To achieve the housing targets that Paul Scott has set, it is necessary to intensify housing density in the suburbs.
“The council has actively attracted developers to ply their trade within the borough. The way for these developers to make the most profit is to buy a family home on a medium-sized plot and replace it with a much larger new building, typically of no more than nine flats. In Kenley, and in all the other southern wards, we are seeing permissions granted for this format over and over again.
“The southern part of the borough lacks the infrastructure that is present in the northern part. The residents in southern wards have many fewer access points to the National Health Service. Our quality of roads and pavements is poor, the housing is often set on steep hills, and very few areas are deemed to have sufficient access to public transport. Use of a car has therefore become a necessity, rather than a choice.”
James highlights that national planning policy allows profit-hungry developers to avoid having to provide any “affordable” housing within their schemes if they are building nine or fewer units. Some sly developers have even bought up a succession of family homes along one street and – rather than submit a single application for planning permission for all of the properties – has applied for permission for separate blocks of nine flats on each plot.
One member of the Croydon planning committee has referred to this as a “9-9-9 housing emergency”. Though the council’s planning department and the planning committee have never sought to do anything about this transparent gaming of the system.
James writes, “The bulk of the new developments are aimed at the executive market because this leads to the greatest profit for the developer and are consequently far from ‘affordable’. In Kenley, we have a large number of intensification proposals that are being assessed under the Croydon Local Plan. Of these 38 intensive planning proposals, 34 (89 per cent) are for nine units or fewer.”
And James suggests that Scott’s housing targets for Croydon are not deliverable. Supporting his argument is none other than Sadiq Khan.
“The Mayor of London has told Croydon Council in a letter dated January 21 2020 that the current housing targets, as set by Cllr Paul Scott, are an ‘ambition’ and are not consistent with the London Plan.
“Anyone challenging the council on their over-ambitious housing targets is presented with an explanation that the targets are taken from the Mayor’s draft London Plan and are broadly in line with the previous housing target for Croydon. So the current Croydon Local Plan remains valid.
“Yet the Mayor’s housing targets have been reduced since being reviewed by the examiners.
“Croydon’s new housing delivery targets are not sustainable,” James writes. “It is not just about meeting housing targets. We need the right kind of homes to be built in the right places.”
Mayor Khan’s draft London Plan underwent examination by experts, and they, James writes, “went to some length to explain why they disagreed with the very planning policies upon which Croydon Council depends to deliver their housing targets”. The examiners specifically warned Croydon (and Scott) against trying to meet high housing targets with an excessive dependency on the development of what are called “windfall sites”: demolishing and converting existing homes.
“At the ward level this is exactly what is occurring in our southern wards,” James writes.
“Croydon Council is careful to avoid ward-level conversations on housing targets. This is because, for many of the southern wards, it is clear that the Croydon Local Plan seeks to deliver 100 per cent of new housing from windfall sites.”
In their review, the examiners said,
“… the imposition of such large increases in this element of the target is heavy-handed“.
windfall sites “…would not positively contribute to the Good Growth objectives”.
“… cumulative impacts… need to be considered in relation to small sites. These include the consequences for the special character of an area including green cover and tree canopies, for health and social infrastructure and for transport”.
And in another comment, the examiners might have had Croydon Councillor Scott in mind when they said, “legitimate concern that this eventuality would lead to an over-attention on the number of units to be delivered rather than achieving the right sort of development in the right place”.
With the examiners and Mayor of London backing up the residents’ associations’ arguments, James writes, “It has become clear that Councillor Scott is seeking to achieve high levels of new housing delivery from small sites by granting nearly 100 per cent of the windfall applications that are presented to the planning committee.
“It is straightforward to recognise from the examiners’ comments that Councillor Scott fails to recognise how such a ‘windfall’ delivery strategy does not contribute to Good Growth objectives, focuses too much attention on the achievement of numerical targets, and particularly fails to consider the cumulative impacts.
“His strategy also assumes that all developments are acceptable even when they have serious problems.”
James cites some of the issues that have arisen with windfall developments around Kenley, Purley and Sanderstead:
- There are no acceptable (ie safe) walking routes to access public transport
- Poor availability of public transport (the site is given a public transport rating – PTAL – of 3 or less)
- There are insufficient accessible local retail outlets or other local facilities
- The only access to local schools is very often by car
- The local roads and pavements are too narrow to be safe for pedestrians
- There are already excessive levels of on-street parking
- There are other poor infrastructure facilities, such as drainage, sewers and power
- Local services (such as education and healthcare) are already under extreme pressure
There is some political irony in the situation, in that while the Labour Mayor of London is scaling back Croydon’s housing targets, and the Tory MP for Croydon South, Chris Philp, is almost daily issuing objections to the latest windfall development proposed in his constituency, Croydon’s Labour-run council has grasped hold of a letter from the Conservative housing minister to justify their ambition to concrete over the borough.
Jenrick’s letter in March, James writes, has made Scott “feel empowered”.
But James suggests that Scott and the council have wilfully misinterpreted a large part of the Jenrick letter (which is available here, as a pdf).
“The Jenrick letter makes several things very clear,” James writes.
“Intensification must ‘complement the surrounding area and not be to its detriment’. It should only be applied gently, and only in areas where it is appropriate. ‘Gentle intensification’ should only be around high streets and town centres. Intensification should be in areas that are able to accommodate it. It should not provide excessive numbers of one- and two-bed flats to the detriment of family-sized dwellings which are and will continue to be needed.
“The Jenrick letter is clearly telling Councillor Scott that Croydon Council is being too aggressive in their process to intensify the suburbs and that they need to significantly slow down. They need to build the right sort of housing and not simply approve everything.”
According to James, in the council planning article, Scott “ridiculously contradicts himself” by saying that “Development should be focused on areas with good public transport.”
James writes, “Such an approach would have resulted in most planning applications in Kenley and other southern wards being refused – but this has not happened.”
James and the residents’ associations accuse Scott of patronising them at planning meetings, while invariably praising his fellow architects and talking-up developers’ plans.
“Any attempt to ask the council to consider cumulative impacts of the windfall developments of family homes being replaced by nine flats is invariably met with a statement that this single development will have an insignificant impact on the area,” James writes.
“But these responses are in direct contradiction to the examiners’ warnings over the London Plan and now also the letter from Robert Jenrick.
“By granting nearly everything, Councillor Scott and the council fail to recognise the sheer number of developments that have already been approved and how each small impact is cumulative for the area. But Councillor Scott has his ideology. The article on the council website shows that he will try to twist everything to support his views.”
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