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 London Borough of Croydon’s Local Plan

Update 24/2/17

The latest and second version of Croydon Council’s, “Croydon Local Plan” (CLP) was sent to the Secretary of State for Communities and Local Government by Croydon Council on 3 February 2017. A Planning Inspector, Mr Paul Clark has now been appointed by the Secretary of State. Public hearings will now commence from 16 May 2017. The Local Plan included a proposal to locate a Gypsy & Travellers’ site (Site 324 in the CLP) on the current Purley Oaks Highways Depot, behind the Purley Oaks Household & Recycling Centre, Riddlesdown Rd. See proposed plan.

Letter below, sent to the RRA (and other interested parties) from Chris Banks the Programme Officer for the Planing Inspector, Mr Paul Clark.

The RRA along with other local RAs will be making representations to the Planning Inspector at the hearings from 16 May;

“Dear Sir or Madam:

London Borough of Croydon – Examination of the Strategic Policies Partial Review (SPPR) and Detailed Policies and Proposals (DP&P) Local Plan documents

As you will know on 3rd February 2017 London Borough of Croydon submitted the above Local Plan 2017 to the Secretary of State for independent examination. The Secretary of State has appointed Inspector Paul Clark MA MRTPI MCMI as the Inspector from the Planning Inspectorate to carry out an independent examination of this Local Plan. The Inspector's task is to consider the soundness of the submitted plan, based on the criteria set out in paragraph 182 of the National Planning Policy Framework (the framework). I have been appointed as the independent Programme Officer. The Programme officer is an independent officer of the examination and works on behalf of the Inspector to organise and manage the administrative and procedural matters of the examination process and is the appropriate point of contact for any queries in relation to the examination.

The Hearings are proposed to start at 10.00 am on Tuesday 16th May 2017 at Community Space, Bernard Weatherill House, 8 Mint Walk, Croydon, CR0 1EA.

You will have indicated on your original representation form as to whether you wish to take part in the oral examination. It is essential for the programming of the examination that I know your current position with regards to your intentions to appear at the hearings. Therefore I would appreciate confirmation of your current position, which I am happy to receive via e-mail or letter by Tuesday 14th March 2017 if possible.

I will be using e-mail as the preferred method of communication as this is quicker and more cost effective as opposed to paper mailings. If you receive a paper copy of this letter and you are happy to receive further mailings electronically please let me have your e-mail address. However, if you would prefer paper please let me know.

I have attached The Inspector Guidance Notes for your information. If you are not familiar with the process I strongly suggest you read through the document, which you will find helpful as well as the link below.

In addition The Planning Inspectorate has produced a booklet Guidance from the Planning Inspectorate

This can be found at: http://www.planningportal.gov.uk/planning/plans

All documents submitted are available for viewing or download on the following London Borough of Croydon Web site;


If you have any queries on the scope of the Hearing process please feel free to contact me.

Yours faithfully

Chris Banks

Programme Officer”

“Introductory Guidelines

LB Croydon Strategic Policies Partial Review and Detailed Policies and Proposals Local Plan Documents examination

Advice to those making representations


1.1 My name is Paul Clark. I am a Chartered Town Planner. I have been appointed by the Secretary of State to hold an Examination into the soundness of the Strategic Policies Partial Review (SPPR) and Detailed Policies and Proposals (DP&P) Local Plan Documents (LPDs) prepared by the London Borough of Croydon.I am assisted by the Programme Officer for the Examination, Chris Banks. He is contracted to the Council but, for the purposes of the examination, acts as an independent officer under my direction.

Purpose of this advice

2.0 In my introduction I referred to the “Examination” of the Strategic Policies Partial Review (SPPR) and Detailed Policies and Proposals (DP&P) Local Plan documents.  People may think that a Hearing which is provisionally programmed for May is the examination.  That is not so. The examination started on 3 February 2017 when the Council submitted the Local Plan documents to the Secretary of State for Communities and Local Government.  Much of the examination is carried out by correspondence.  The examination continues until I issue my binding report to the Council unless the Local Plan Documents are first withdrawn.  So the examination is already under way.

2.1 There are several aspects to the examination.  One is whether the Local Plan document complies with legal and procedural requirements.  Another is whether it is sound.  Soundness is tested in four ways; has the plan been positively prepared to meet objectively assessed requirements; is the LPD justified; would it be effective; and, is it compliant with national policy?

2.2 There are only three possible outcomes of the Examination.  One is that I find the plan sound, without any need for change.  That will not be the case here because the Council has itself already put forward some changes to the plan.

2.3 The second possible outcome is that I change the plan.  You may be aware that I may only make a change to a submitted LPD if the Council agrees to my doing so and if that change is itself sound, in accordance with all of the soundness tests including the legal and procedural requirements for consultation and sustainability appraisal. Thus, unless others have previously done the consultation and sustainability appraisal, the extent of changes that I may make, if needed to make a LPD sound, is very limited.

2.4 Failing that, a finding of unsoundness, which is the third possible outcome, is inevitable.  That would be very regrettable in view of the time and effort which has been put into the process so far, so is to be avoided if at all possible.  If necessary, the examination can be suspended for further work to be undertaken, or terminated by withdrawal of the plan.

2.5 As I examine the LPDs any concerns I may have about soundness will be expressed in the form of questions which will be sent to the Council (or in a few instances, to those such as yourself who have made representations).  Any such questions can be found on the examination website. Any responses made by the Council or others will also be found there.


2.6 As the examination progresses, I will group my concerns and the representations made by others into themes for discussion at a hearing session in a document to be entitled Matters and Issues.  That will represent what I expect to be discussed at the Hearing sessions in May, if not resolved in writing before then.  A further briefing note will be sent nearer the time to those who I will invite to participate in any hearing session.

Role of the Programme Officer

3.1 The examination process is designed to be fair to everyone.  What that means in practice is that the only person who can contact or speak privately to me is the Programme Officer.  Everyone else can only speak to me publicly during the Hearing sessions, so that everyone else can hear publicly what is said to me.  Anything that is written to me, Chris will copy and either distribute to everyone else who might be interested or will publish on the Examination website.  That way, there are no private meetings, no deals done behind closed doors.

3.2 So, Chris is key to the smooth running of the examination, since I can only communicate with you via him, and vice versa.  He will contact you for any documents that I request. He will make sure that any documents submitted are copied, circulated and published on the website.  He will keep in contact with those who are invited to make sure they are going to turn up at the relevant hearing session on time.  He will alert those people to any last minute changes in the timetable.  He keeps the library of examination documents. He assists me with all procedural and administrative matters.  Any queries that you have about the Examination or the Hearing sessions themselves should be addressed to Chris in the first instance.

3.3 Chris’s contact details are on the letter which accompanies this advice note.

The hearing sessions

4.1 Those who have made a specific proposal to change the plan have a right to participate in the hearing sessions.  Others may participate by invitation.  Others are welcome to attend to listen to the discussion, even if not invited to take part.  All sessions are open for the public and the press to observe.

4.2 In submitting the LPD the Council also submitted two Schedules of Recommended Main Modifications.  These may satisfy some respondents’ concerns.  It would be helpful to Chris and I if respondents would indicate whether or not this is in fact the case.

The nature of the hearing sessions

5.1 Let me explain the nature of the hearing sessions.  They are not an examination of the representations made.  They are an examination of the LPDs.  The representations made throw light on to the LPDs but it is the soundness of the LPDs themselves which is the focus of the hearings, not the strength of the objections or representations.

5.2 Prior to each hearing session I will issue a statement of what I believe to be the main issues which need to be discussed and who I would like to be involved in the discussion.

5.3 In most cases, it will be unnecessary for participants to prepare additional material but further advice will be given nearer the time.

Site visits

6.1 Because of the nature of one of these Local Plan documents, dealing with site allocations, I am likely to carry out a programme of site visits.  This may occur before, during or after the Hearing sessions.  This will usually be done unaccompanied unless there is a need to gain access to private land, in which case an accompanied visit will be arranged through the programme officer.

6.2 If anyone anticipates the need for me to visit a site, or to see a site from a particular viewpoint, in order to understand a particular argument, it would be helpful to say so to Chris sooner, rather than later.

After the Hearing sessions

7.1 The examination remains open until I have submitted my report to the Council but once I have completed the Hearing sessions I will only receive material which I have specifically requested.  Any unsolicited material will be returned to the sender.

7.2 If, during the course of the examination, it appears to the Council that I am likely to find the LPD unsound, then it may put forward a change or changes to address the issue.  As explained earlier, I can only endorse a change to the LPD if that change is itself sound, in accordance with all of the soundness tests including the legal and procedural requirements for consultation and sustainability appraisal.  The Council may need extra time before I issue my report for these processes to take place.  The timetable for the issue of my report will be announced in the light of these considerations.

Useful documents and websites

10.1 National Planning Policy Framework, paragraphs 150 to 185.  DCLG March 2012; https://www.gov.uk/guidance/national-planning-policy-framework

10.2 National Planning Practice Guidance; https://www.gov.uk/government/collections/planning-practice-guidance

10.3 The Planning Inspectorate website; https://www.gov.uk/guidance/local-plans

10.4 The Planning Inspectorate’s Procedural Guidance in the Examination of Local Plans; https://www.gov.uk/government/publications/examining-local-plans-procedural-practice

10.5 The Planning Advisory Service; http://www.pas.gov.uk/plan-making

10.6 The examination website; https://www.croydon.gov.uk/planningandregeneration/framework/localplan/croydon-local-plan-examination/croydon-local-plan-examination  “

Update 19/10/16

The RRA submitted further comments on matters in our area and also locally in Purley. Our letter can be viewed here.

Some useful links

Croydon Local Plan: Strategic Policies – Partial Review (Preferred and Alternative Options) www.croydon.gov.uk/localplanone

Croydon Local Plan: Detailed Policies and Proposals (Preferred and Alternative Options) www.croydon.gov.uk/localplantwo

This is a link to the Assessment used by the Council for all possible travellers sites in the Borough, dated August 2015

This link is Government planning policy issued in August 2015, to all Local Authorities, about locating traveller sites in Boroughs; https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/457420/Final_planning_and_travellers_policy.pdf

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