London Borough of Croydon – Consultation Statement: Central Croydon, Church Street and Croydon Minster Conservation Area Appraisals and Management Plans Supplementary Planning Documents Consultation Statement: Central Croydon, Church Street and Croydon Minster Conservation Area Appraisal and Management Plan Supplementary Planning Documents This consultation statement has been prepared in accordance with Regulation 12 of the Town and Country Planning (Local Development) (England) Regulations 2012. 1. Name of Supplementary Planning Documents Central Croydon, Church Street and Croydon Minster (formerly Parish Church) Conservation Area Appraisal and Management Plans (CAAMPs). 2. Purpose of SPDs The purpose of the SPDs is to provide more detailed / area-specific advice on the application of policies within the Croydon Local Plan that are concerned with the preservation and enhancement of conservation areas and to help applicants make successful applications. 3. Persons/groups/bodies consulted in connection with preparation of SPDs Before the formal consultation process began, the draft CAAMPs for the Central Croydon, Church Street and Croydon Minster (formerly Parish Church) Conservation Areas went through a process of internal consultation within the Planning and Building Control division. Additionally, a meeting was held with the Central Croydon Conservation Area Advisory Panel to inform the production of draft CAAMPs. The following groups were informed of the formal consultation: Owners/occupiers of all addresses that lie within the conservation areas The Old Town Masterplan Stakeholder Project Board comprising of the following organisations - BT, The Church House Business Centre, Clowater, Croydon Council, Croydon Minster, Croydon Old Town Business Association, Durkan, English Heritage, Greater London Authority, House of Reeves, The Portas Town Team, QPark Car Park, Rosepride, Transport for London and The Whitgift Foundation. The Croydon Local Plan database Statutory consultees The Old Town Masterplan mailing list Visitors to the area Readers of the Croydon Guardian by way of a press notice and the Croydon Council Planning webpages 4. How were people consulted? The formal consultation process for the draft CAAMP SPDs for the Central Croydon, Church Street and Croydon Minster (formerly Parish Church) conservation areas adhered to the Council’s adopted Statement of Community Involvement (2012) and also the statutory requirements of the Town and Country Planning (Local Planning) (England) Regulations 2012. Consultation took place between 10 February 14 and 24 March 14. Consultation comprised of the following: Electronic versions of the draft CAAMPs and were made available for download from the Council’s website. London Borough of Croydon – Consultation Statement: Central Croydon, Church Street and Croydon Minster Conservation Area Appraisals and Management Plans Supplementary Planning Documents Two public consultation events on the Conservation Area Appraisals and Management Plans. One on a Wednesday evening and one on a Saturday. (Approximately 80 people attended) An exhibition explaining the draft SPDs was on display at the public consultation events for the CAAMPs and remained on location for a week. Comments forms were provided for consultees to leave their comments. (However, if comments were supplied in a different way they were recorded as part of the consultation.) Publicity for the consultation comprised of the following: An email was sent to the Old Town Masterplan mailing list (over 120 addresses), the general conservation mailing list and the Croydon Local Plan consultation contacts database (which includes statutory consultees) to inform stakeholders about the consultation process. Copies of the draft CAAMPs were available to view at Access Croydon and at each of the Borough’s libraries. Letters were sent to every affected owner and occupier within the conservation areas. Approximately twenty site notices were placed within the conservation areas. An advertisement in The Croydon Guardian. 5. Summary of the main issues raised during the consultation Central Croydon CAAMP Issue A: This conservation area includes the eastern retail frontage to The Whitgift Shopping Centre on North End - Croydon’s retail core which is centred around North End. The Whitgift Shopping Centre site was granted outline planning permission for redevelopment in February 2014. One representation requested that the Central Croydon CAAMP should not prejudice the successful delivery of the scheme. As a means of achieving this, it requested that the SPD should recognise that a balanced approach be taken to all development proposals which facilitate comprehensive redevelopment to be in line with the Croydon Local Plan and the Croydon Opportunity Area Planning Framework (OAPF). Issue B: One representation commented that tall buildings are likely to be built within the setting of the Central Croydon conservation area which would have an impact on its character. It requested that to be in accordance with the NPPF that the CAAMP emphasise that the likely harm of proposed buildings within the immediate setting of the conservation area be assessed and taken in to account when determining pre-applications and planning applications for such buildings. Issue C: Several representations argued that the guidance was overly restrictive. Issue D One representation argued that two buildings within the conservation area on Surrey Street should be removed from it because they do not make a special contribution towards the conservation area. It was also put forward that redevelopment of these sites should not be constrained by the guidance within the CAAMP. London Borough of Croydon – Consultation Statement: Central Croydon, Church Street and Croydon Minster Conservation Area Appraisals and Management Plans Supplementary Planning Documents Issue E Several key architectural features and building materials that are prominent in the area were identified by one representation that were not included in the CAAMP. Issue F Several minor factual errors and examples of unclear text were highlighted by a number of representees. Church Street CAAMP All of the main issues identified through the consultation on the Church Street CAAMP related to the Tamworth Road character area. Issue A: One representation argued that there is no uniformity to the Tamworth Road character area and that the area had developed organically and should be allowed to continue to do so. It argued that the contrasting scale of buildings should be celebrated as indicated in the OAPF and that taller buildings than those currently located on the street should be permitted. Issue B: Several representations argued that the former Mission Chapel does not make a positive contribution to the conservation area as stated in the draft CAAMP because it has lost many of its original architectural features and is modest in character. Issue C: Building on the point made in Issue A, one representation argued that a tall building on the Cairo New Road site that lies within the immediate setting on the conservation area would have a positive impact on Croydon’s skyline and that there already exists positive precedents in Croydon Metropolitan Centre for this approach to development within the immediate setting of Croydon’s conservation areas. Issue D Several minor factual errors and examples of unclear text were highlighted by a number of representees. Croydon Minster CAAMP Issue A: One representation suggested that the CAAMP should state that the Minster should remain the principle landmark in the area as a Grade I listed building, parts of which are of medieval origin. Issue B Several minor factual errors and examples of unclear text were highlighted by a number of representees. 6. How have the issues described above been addressed in the SPD? All of the individual comments received and the Croydon Council responses to them are provided in the Appendix to this Consultation Statement. London Borough of Croydon – Consultation Statement: Central Croydon, Church Street and Croydon Minster Conservation Area Appraisals and Management Plans Supplementary Planning Documents A summary of how the issues outlined above have been responded to is provided below: Central Croydon CAAMP Issue A: The CAAMP guidance does not contradict existing Croydon Council Planning Policy and the redevelopment of the retail core and the adherence to the guidance in the CAAMP are not considered mutually exclusive. To stress this point, the redevelopment of the retail core and the Council’s support for this (which is enshrined in planning policy) is now referenced in the Management Plan. Issue B: The recommendation made is considered sound and in accordance with the NPPF and English Heritage guidance and the CAAMP has been altered accordingly. Issue C: The CAAMP is planning guidance has been written in accordance with the NPPF and English Heritage guidance and describes how the special character of the Central Croydon conservation area should be preserved and enhanced. The content of the Church Street CAAMP has therefore not been changed in response to this comment. Issue D: The Central Croydon CAAMP has not been changed in response to this comment. The buildings are included in the conservation area because they are located on an important historic street within the conservation area and are surrounded by buildings that do make a positive contribution to the conservation area. The CAAMP states that redevelopment of the sites is permitted. however, the design of new buildings on the sites would need to follow the CAAMPs guidance for it to enhance the conservation area. Issue E: The architectural features and building materials identified have now been listed in the Central Croydon CAAMP. Issue F: Minor factual errors have been corrected and amendments to made to the text to improve clarity. Church Street CAAMP Issue A: The Council disagrees with the argument given and therefore the content of the CAAMP has not been altered as a result of this comment. There is a group of distinctive Victorian buildings on the street that make a positive contribution and give the character area broad consistency in terms of building age, scale and building materials. Furthermore, although the character of Tamworth Road has been undermined by the introduction of some unsympathetic 20th Century development, much of it lies outside of the present conservation area boundary. The CAAMP is consistent with other Croydon Council planning policy regarding the approach to development within conservation areas. The CAAMP provides more site specific detail than the OAPF. Issue B: The Council disagrees with the viewpoint expressed. The building has historical significance as the first Mission Hall opened by the Christian Mission (later the Salvation Army) outside of London’s East End. It also has some architectural significance despite it having been subject to some unsympathetic alterations. In October 2014 the Council locally listed the building which further demonstrates the value it places on the building. Issue C: The text was amended to provide more clarity on the requirements for development on this site. Whilst it is recognised that tall buildings are very likely to come forward within London Borough of Croydon – Consultation Statement: Central Croydon, Church Street and Croydon Minster Conservation Area Appraisals and Management Plans Supplementary Planning Documents the setting of the Church Street Conservation Area (and the other conservation areas in Croydon Metropolitan Centre) a planning application should demonstrate how the development would not cause undue harm to the special character of the Church Street Conservation Area. If a tall building is proposed the applicant will need to demonstrate how they have managed the transition in scale to avoid an imposing impact on the conservation are. Issue D: Minor factual errors have been corrected and amendments to made to the text to improve clarity. Croydon Minster CAAMP Issue A: The text has been amended to state that the Minster should remain the principle landmark in the area. Issue B: Minor factual errors have been corrected and amendments to made to the text to improve clarity.