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5. Employment

Strategic policy

Where we are now

5.1 The key issues that the borough faces in terms of planning for employment up to 2036 are:

• Land for industry and warehousing will need to have continued protection to support these sectors in the future.
• There is approximately 30% vacant office floor space in Croydon Metropolitan Centre and current low rents do not support the development of new office floor space, although some speculative office is being built out.
• Supporting the area around East Croydon Station and New Town as Croydon Metropolitan Centre's office centre. 
• The public realm of Croydon Metropolitan Centre has seen considerable investment and improvement, but renewal remains necessary as poor public realm discourages businesses from locating in Croydon and people shopping in the town.
• Encouraging development in Croydon Metropolitan Centre through flexible and pragmatic planning, that contributes to the centre's economic prosperity and vitality.
• Croydon faces competition from other areas of London and the South East for inward investment both in office and retail markets.
• The increase in the population of Croydon and planned house building will result in an increase in the need for jobs.
• Establishing a policy response to the contracting of retail uses within District and Local Centres, increased vacant premises on the edges of the District and Local Centres along with poorly designed conversions to other uses, has further impacted on the public realm and ability of the Centres to attract new business and create attractive residential areas.

Where we want to be

Strategic Objective 1:	Establish Croydon as the premier business location in South London and the Gatwick Diamond.
Strategic Objective 2:	Foster an environment where existing, new, innovative, cultural and creative enterprises can prosper.
Strategic Objective 4:	Reduce social, economic and environmental deprivation, particularly where it is spatially concentrated, by taking priority measures to reduce unemployment, improve skills and education and renew housing, community and environmental conditions.
Strategic Objective 8:	Improve accessibility, connectivity, sustainability and ease of movement to, from and within the borough.
Strategic Objective 9:	Ensure the responsible use of land and natural resources and management of waste to mitigate and adapt to climate change.

 

How we are going to get there

 

Table 5.1 Four-tier approach to land and premises in industrial locations

 

Designations shown on the Policies Map

Each of the designations set by this policy are shown on the Policies Map. The designations are summarised in Table 5.2 below:

Table 5.2 Designations set by Policy SP3 shown on the Policies Map

Designation	Locations
Strategic Industrial Location	Marlpit Lane Purley Way North Purley Way South
Separated Industrial Location	Gloucester Road (East) Selsdon Road Vulcan Way
Integrated Industrial Location	Gloucester Road (West) Thornton Road Union Road
Croydon Metropolitan Centre	Croydon Metropolitan Centre
District Centre	Addiscombe Coulsdon Crystal Palace New Addington Norbury Purley Selsdon South Norwood Thornton Heath
Local Centre	Beulah Road Brighton Road (Sanderstead Road) Brighton Road (Selsdon Road) Broad Green Hamsey Green Pollards Hill Sanderstead Shirley Thornton Heath Pond
Office Retention Area	New Town and East Croydon areas of the Croydon Opportunity Area

 

What will it look like

Figure 5.1 Employment in Croydon (2011-2036)

 

Figure 5.2 Employment in Croydon (2011-2036)

Why we have taken this approach

Innovation, Investment & Enterprise

5.2 The vision from Croydon's Sustainable Community Strategy states 'We will be London's most enterprising borough – a city that fosters ideas, innovation and learning and provides skills, opportunity and a sense of belonging for all'. A network of Enterprise Centres focusing on cultural and creative industries and innovation will be pursued across the borough as part of realising this vision.

5.3 The Council is committed to training, work placements and apprenticeships and views them as being a sustainable way to improve employment prospects for local people. The Council is determined to ensure that S106 obligations secure placements for local people during the construction phase of building projects and the provision of skills training.

5.4 In the face of strong competition from other uses, planning policies giving strong protection for industrial sites have served the borough well in terms of retaining the stock of industrial and warehousing premises and land¹⁰.

5.5 To achieve our vision to '…be London's most enterprising borough …' it is essential that Croydon has the capacity to meet expected demand for industrial and warehousing activities. The evidence base indicates that the current supply is tight and predicted to become more so. The Croydon Monitoring Report (April,2015) found that overall there was a net loss of almost 42,000m² of Class B floor space in Croydon between 2011 and 2015.

5.6 The '4-tier' approach is a strong approach to the protection of industrial capacity (in line with Croydon's 'restrictive transfer' status¹¹ ) which supports the South London Waste Plan DPD, yet also offers greater prospects of bringing about investment and renewal of industrial/employment locations, bringing forward new workshops/studios in town centre locations and meeting other policy objectives.

5.7 'Tier 1' locations benefit from better separation from nearby residential properties and therefore lend themselves to the highest level of protection for industrial and warehousing activity. Two of the areas, Purley Way (comprising Purley Way North and South) and Marlpit Lane, are also identified as Preferred Industrial Locations in the London Plan – see Figure 5.1). 'Tier 1' locations due to their strategic function and economic importance will be subject to the highest policy protection to ensure their economic importance is assured.

5.8 'Tier 2' Locations are industrial estates where residential development grew up alongside the commercial buildings. This proximity between uses has not resulted in undue harm to residential amenity and therefore, new mixed-use schemes, that are well designed and give priority to the area's commercial functionality, are acceptable. New Class B1b, B1c, B2 and B8 premises in mixed use developments should be designed to meet the needs of future occupiers and to preclude future conversion to residential use. Mixed use developments in these locations must not result in an increase in operational difficulties for businesses. 'Tier 2' locations also perform an important economic function so will be subject to strong policy protection to ensure their role is assured.

5.9 The fringes of some Tier 1 and Tier 2 locations within the context of Policy SP3.2 have the potential for transition through development that enables the locations to relate better to their surrounding uses and character. This transition could come in the form of intensification of development, high density development and the introduction of new land uses or mix of land uses.

5.10 Extending protection of industrial/warehousing activities to sites falling within town centres ('Tier 3') will help the Council limit the losses in the borough wide stock of such premises. The promotion of new workshops in these locations will also add a greater degree of diversity (and theoretically a greater resilience), to the employment offer of the borough's town centres. However, the Council will adopt a flexible approach to B1 uses (excluding B1a office), leisure, visitor accommodation, and housing and community facilities within Croydon Metropolitan Centre.

5.11 The Council is aware that D1 uses can struggle to find suitable premises. This has led, in the past, to situations where 'Tier 1' type premises have been lost to community uses to the detriment of the area's business function. Allowing the change of use or redevelopment of 'Tier 2 and 4' premises in the more accessible locations, to D1 use class activities (non-residential institutions), not only helps safeguard 'Tier 1' for continued industrial uses, it also opens up a significant supply of premises for community uses/groups to consider. Restricting this flexibility to higher PTAL locations means that uses which attract large numbers of visitors will be able to make more use of public transport.

5.12 Likewise Gypsies and Travellers also struggle to find suitable sites for new pitches. To enable provision of sites throughout the Plan period, particularly the last ten years of the Plan period, the development of 'Tier 1' sites to use as Gypsy and Traveller pitches (for those families with a qualified connection to Croydon) will be permitted. In the case of Gypsies and Travellers, a qualified connection is defined as being resident on an existing authorised site in Croydon (but with no space to expand), being the parent, grandparent, child, grandchild, brother or sister of a Gypsy or Traveller currently resident in Croydon on an authorised site; or having resided in Croydon on unauthorised sites for a period of not less than five years ending on the date of adoption of the Local Plan. If there is no qualified connection then the use of Tier 1 sites would not be permitted.

5.13 In order to demonstrate that there is no demand for a scheme comprised solely of Class B1b and B1c, B2 and B8 uses in 'Tiers 2, 3 and 4' locations, evidence will need to be submitted that a marketing exercise has been undertaken for a minimum of 18 months. The Council will need to be satisfied that the site has been offered at a price commensurate with the value of the site for the permitted uses and that active promotion has been undertaken by agents marketing the site.

5.14 Croydon is good at producing creative talent (BRIT School, College of Art, Dance, Dubstep etc.), but less successful at providing them with a base in the borough¹² . Other London boroughs have been able to address this – e.g. the 'Chocolate Factory' in Hackney and Westbourne Studios in Kensington and Chelsea. Evidence supports promotion and supporting cultural and creative industries to assist in changing Croydon's image¹³ .

5.15 The study, 'Understanding and Shaping the Cultural Sector in the London Borough of Croydon, Sept 2010', highlights clusters of creative industries talent in four locations with a recommendation that the Enterprise Centre in CMC act as a flagship for the sector. Developing a central location as a 'hub' will provide a clear signal that Croydon is 'open for creative businesses'.

5.16 The Fairfield Halls is a cultural asset synonymous with Croydon and is also of regional importance, therefore its retention and remodelling merits inclusion within the Strategic Policies of the Croydon Local Plan.

5.17 Across Croydon, but particularly within Croydon Metropolitan Centre, there are substantial amounts of underused sites/buildings. This usually corresponds with sites that are pending development. The Council considers such sites lying dormant a potential opportunity. Organisations within this sector such as ACAVA (Association for Cultural Advancement through Visual Art) and ACME (providing artists with affordable studio and living space) are experts at making temporary use of such space. Elsewhere in the Strategic Policies other temporary uses are promoted such as urban greening, urban agriculture and providing space for community groups.

5.18 As well as encouraging new activity in this sector, it is essential that the Council continues to protect existing capacity for activities such as theatres, cinemas, art galleries etc. This is supported by Policy Action 2.1 of the London Mayor's Cultural Metropolis Strategy.

5.19 Derelict sites and buildings can impact on the perception of the borough and the visual quality of the public realm. They can have an adverse impact on community safety owing to lack of active frontages. A policy to encourage creative and cultural uses can enhance the public realm to help build social cohesion, support cultural diversity and engender a sense of safety and belonging as well as helping this sector to grow in the borough. Town Centres

5.20 The process of conducting town centre health checks should ensure that the role of the borough's town centres and their relationships to one another is fit for purpose and adequately supports the London network of town centres and the borough's convenience and comparison retail needs. Centres can be reclassified in the light of subsequent reviews or alterations to future LDF DPDs. Changes to the upper tiers in the network (Major and above) should be coordinated first through the London Plan.

5.21 The objective to direct town centre uses to existing centres (because of their higher levels of accessibility and ability to support multiple purpose trips) remains central to government policy in the National Planning Policy Framework and provides justification for this policy. The mix of uses in each centre will be determined by factors such as existing clusters of activity (e.g. vibrant evening economy, grouping of large offices, presence of higher education providers, etc.) as well as other designations. For example, both Crystal Palace and Croydon Metropolitan Centre are identified in the Sub-Regional Development Framework, South London, 2006 (Table 1D.3), as Primary Locations for future visitor accommodation.

5.22 Croydon Metropolitan Centre (CMC) has the highest level of regional and sub-regional accessibility in the borough. The case for it to be the principal location for the town centre uses is supported by the importance attached to CMC in the London Plan. The Council is committed to facilitating development within Croydon Metropolitan Centre. Therefore, the Council will seek to strengthen Croydon's role as a Metropolitan Centre and adopt a flexible approach to B1 uses (office, light industry and research & development) retail, leisure (including evening/night-time economy uses), visitor accommodation, and housing and community facilities within Croydon Metropolitan Centre. This flexible approach will be supplemented by the Croydon Opportunity Area Framework and the Council's masterplans that apply to the Croydon Metropolitan Centre. Policies in the Transport and Communications section to improve Wi-Fi connectivity and mobile phone bandwidth will support this policy.

5.23 Furthermore, changing the town centre hierarchy as set out in Croydon's Unitary Development Plan to the hierarchy set out in the London Plan brings the Strategic Policies into general conformity with the regional plan. Development in Croydon Metropolitan Centre will be promoted in accordance with the London Plan designation as an 'Opportunity Area, a 'Metropolitan Centre', a 'Potential Outer London Development Centre' for 'Strategic Office' and 'Higher Education' uses and in accordance with its status as a 'Strategic Cluster of Night-Time Activity with Regional/Sub-Regional Importance'.

5.24 Regular town centre 'health checks' form part of the Council's promotional role and help to ensure boundaries, policies and classifications remain relevant. The nature of planned growth in the borough over the plan period could necessitate the need to provide additional town centres. Conversely, other centres which face challenges resulting from changes in retailing (growth in online shopping, competition from out-of-town retail, etc.) may require consolidation.

5.25 In addition to the London Plan town centre hierarchy, Neighbourhood Centres have been identified. These offer the opportunity for clusters of uses, in particular community uses, to emerge or be supported by planning policy. The identification of Neighbourhood Centres goes beyond recognising centres solely for their retail function, but for the wider role they play in supporting the local community.

5.26 Croydon is in competition for inward investment with other parts of London, notably the Thames Gateway and the M4 corridor (the Western Wedge). It also competes with centres in Surrey and West Sussex and to do so successfully, the stock of commercial premises needs to be improved. Policy SP4 (Urban Design & Local Character) will also help Croydon to retain/attract new job opportunities.

5.27 It is anticipated that the level of reduction in retail vacancies will be achieved through the regeneration of Croydon as a Metropolitan Centre and through a mixture of new lettings and redevelopments of town centre sites. Within Croydon Metropolitan Centre, the Opportunity Area Planning Framework will address this point and the uptake of approximately 15,500m² floor space alone could equate to the provision of approximately 800 additional jobs. For the District and Local Centres the proposed reduction in vacancy would equate to an uptake of approximately 16,000m2 floor space and provision of approximately 850 additional jobs.

5.28 The demand for office space in the borough over the period 2013 to 2031 is for between 29,440m² and 91,840m².It is estimated that there is potential for 60,010m2 of space. This space requirement is of a similar scale to that estimated for the 2010 Employment Land Review. The majority of this office space demand, (90%), is projected to be for Grade A accommodation in prime locations within the Croydon Metropolitan Centre in the vicinity of East Croydon station, within the New Town area (as defined in the Opportunity Area Planning Framework). Croydon being identified as a strategic outer London office location in the London Plan means this area is the borough's most attractive to commercial developers. Therefore, development in this area is encouraged to be office based (in full or part) and it is required that office development is explored fully as part of any development proposal. Demand is highest in this area for Grade A Office floor space (as defined in the Glossary in Appendix 1). There remains demand for cheaper, lower quality accommodation for new businesses so, within the Office Retention Area loss of office floor space needs to be justified by the submission of a viability appraisal to show that there is no demand for office floor space, proportionate office floor space or refurbished offices. Office floor space provision within a scheme will also be considered against the complexion and merits of the other uses proposed. This growth and protection will increase the opportunities for employment in Croydon Metropolitan Centre, support its urban renewal and contribute to the Croydon Local Plan's spatial vision of being London's most enterprising borough.

 

Development in Croydon Metropolitan Centre, District and Local Centres

Strategic Objectives and related Croydon Local Plan strategic policies

Policy SP3.6

Policy SP3.7

Policy SP3.8

Policy SP3.9

Policy SP3.10

Policy SP3.11

Policy SP3.12

Policy SP3.13

 

Why we need this policy

5.29 Retailing is at the heart of the borough's town centres. However, they are also places where a wide range of other uses help to ensure vitality and viability is maintained. This policy sets out the approach to uses by location within a centre. For this purpose it sets the following designations:

1. Boundaries of the Croydon Metropolitan Centre, District and Local Centres (the borough's town centres);
2. Primary Shopping Areas;
3. Main Retail Frontages; and d) Secondary Retail Frontages.

 

5.30 These boundaries have been reviewed during the preparation of this Plan to ensure they meet the needs of the borough. The review has been supported by an Assessment of Boundaries and Designations for Croydon Metropolitan Centre, District and Local Centres including analysis of mixed use developments (2012 and 2015) and a Review of Town Centre Designations (2013).

5.31 London Plan policy 2.15 identifies a range of measures boroughs should undertake in relation to town centres, including setting out policies for each type of area within centres.

5.32 Paragraph 23 of the National Planning Policy Framework states 'Planning policies should be positive, promote competitive town centre environments and set out policies for the management and growth of centres over the plan period'.

 

Table 5.3 New development proposals and changes of use in Croydon Metropolitan Centre and District and Local Centres

 

Designations shown on the Policies Map

Each of the designations set by this policy are shown on the Policies Map. The designations are summarised in Table 5.4 below:

Table 5.4 Designations set by Policy DM4 shown on the Policies Map

Designation	Locations
Primary Shopping Area	Croydon Metropolitan Centre Addiscombe District Centre Coulsdon District Centre Crystal Palace District Centre New Addington District Centre Norbury District Centre Purley District Centre Selsdon District Centre South Norwood District Centre Thornton Heath District Centre Beulah Road Local Centre Brighton Road (Sanderstead Road) Local Centre Brighton Road (Selsdon Road) Local Centre Broad Green Local Centre Hamsey Green Local Centre Pollards Hill Local Centre Sanderstead Local Centre Shirley Local Centre Thornton Heath Pond Local Centre
Main Retail Frontage	See Appendix 3 for locations
Secondary Retail Frontage	See Appendix 3 for locations

 

How the policy works

5.33 In part, this policy sets thresholds for uses within the Main and Secondary Retail Frontages. This policy limits the saturation of A5 uses as the associated waste and delivery issues can cause harm to residential amenity. The clustering of hot-food takeaways can have an adverse impact on the vitality and viability of town centres, therefore limiting hot-food takeaways will help to ensure residents have a greater choice of retail services.

5.34 Studies have identified that one in three children is overweight or obese by the time they leave primary school and in 2014, an estimated 62% of the adult population were overweight or obese¹⁷ .Croydon was selected as a pilot for the Mayor of London's Food Flagship program and one of the aims of the program is to improve the quality of food available to schools and communities. Limiting the number of hot food takeaways in the borough's town centres will support the public health agenda of tackling obesity and associated health problems and will promote access to healthier food options.

5.35 Proposals for B1 uses will be supported in Secondary Retail Frontages to create opportunities for office, research & redevelopment and light industrial workshops within town centres. However, these uses should not undermine the retail function of the frontages and will be only permitted if they provide an active frontage.

5.36 The reason why 250m² is the threshold for community uses within Secondary Retail Frontages in Croydon Metropolitan Centre and District and Local Centres, is that it would allow uses such as dentist surgeries and a High Street police office to operate but would deter larger scale activities from potentially undermining the A Use Class focus of these locations.

5.37 Across the borough there are many examples of mixed use developments in town centres, but outside of Main and Secondary Retail Frontages, where the ground floor units have been left as an empty shell. The costs of fitting out these units to a standard that allows them to be used for their intended purpose can be prohibitive and the resultant boarded up units harm the vitality of the centre. To avoid this all mixed use developments within a town centre but outside of a designated frontage will be required to have either an end user for the unit (evidenced by a pre-let agreement or by the applicant being the end user) at the time of granting permission or to provide a free fitting out of the unit for the first occupier.

5.38 All speculative schemes in town centres but outside of Main and Secondary Retail Frontages will also be required to be designed in a way that would allow conversion of the ground floor unit to residential or the same use as the remainder of the building if not residential. In some cases, the Council may enter a legal agreement with the applicant to ensure that the ground floor unit is let and if not then converted to the same use as the remainder of the building.

5.39 For the purposes of Part 3 Class M of the General Permitted Development Order (2015), which sets out the circumstances where planning permission is not required for changes of use from retail to residential use, Main Retail Frontages and Secondary Retail Frontages are considered to be key shopping areas. In these locations any change of use from a retail use to residential will require an application to be made for planning permission which will be considered against the requirements of this policy.

Key supporting documents

• Croydon's Monitoring Report (annual)
• Borough Wide Retail Needs Study Update (2008)
• Croydon Metropolitan Centre Retail Strategy (2009)
• Office, Industrial & Warehousing Land/Premises Market Assessment (2010)
• Employment Land Review Update (2013)
• Review of Town Centre Designations (2013)
• Assessment of boundaries and designations for Croydon Metropolitan Centre, District and Local Centres including analysis of mixed use developments (2012 and 2015)
• Appendix 3 – Designated shopping frontages

 

Development in Neighbourhood Centres

Strategic Objectives and related Croydon Local Plan strategic policies

Strategic Objective 5

Strategic Objective 6

Strategic Objective 7

Policy SP4.9

Policy SP5.3

Policy SP5.4

Policy SP5.5

Policy SP5.6

Policy SP5.7

 

Why we need this policy

5.40 The Council seeks to provide a range of services and community facilities to contribute to its aim of creating healthy and liveable neighbourhoods as set out in the Croydon Local Plan Strategic Policy SP5.3 and Strategic Objectives 5, 6 and 7. This will help in promoting healthy communities in line with paragraphs 69 and 70 of the National Planning Policy Framework.

5.41 In appropriate areas, the Council will seek to promote development of community facilities that will serve a neighbourhood demand for these uses.

5.42 Community facilities are defined in the Croydon Local Plan as facilities providing for the health and wellbeing, social, educational, spiritual, recreational, leisure and cultural needs of the community.

5.43 Neighbourhood Centres are not intended to compete with designated District or Local Centres, and should serve a local need smaller in scale to that of a Local Centre. They should be able to meet the day-to-day needs of the local community and allow for modest growth in order to accommodate local needs.

5.44 Typically more limited in retail offer to Local or District Centres, Neighbourhood Centres may contain a place of worship, playground, school, public house, GP and pharmacy.

5.45 Neighbourhood Centres serve the whole community, but are particularly important to those who do not have access to a car, are unable to travel far or those with a disability.

5.46 The London Plan states that boroughs should identify and promote the complementary offers of the other smaller centres in the network including neighbourhood centres and local shopping parades. These play a key role in meeting 'walk to', everyday needs and are often the core of local 'Lifetime' neighbourhoods.

5.47 Neighbourhood Centres typically serve a localised catchment often most accessible by walking and cycling and include local parades and small clusters of shops, mostly for convenience goods and other services. They may include a small supermarket, sub-post office, pharmacy, launderette and other useful local services. They can play a key role in addressing areas deficient in local retail and other services.

5.48 The London Plan sets out its ambitions to plan for a range of social infrastructure required for London's communities and neighbourhoods to support a high and improving quality of life. It supports a city of diverse, strong, secure and accessible neighbourhoods and seeks to ensure that neighbourhoods provide convenient access, especially by foot, to local goods and services needed on a day to day basis. . Local neighbourhoods should act as a focal point for local communities and enhance their overall attractiveness.

5.49 Surplus commercial capacity should be identified and brought forward to meet housing and local community needs, recognising that this process should contribute to strengthening the 'offer' of the Centre as a whole.

5.50 The London Plan advocates a light touch approach regarding neighbourhood centres in order to sustain and improve their convenience offer while supporting redevelopment of surplus units for housing.

5.51 The Urban Design Compendium notes that 'local facilities bring residents together, reinforce community and discourage car use'. Furthermore, it states that newsagents should be within a five minute walk, and local shops, health centres and other services which serve a local need, should be a ten minute walk. This approach is also considered appropriate in Shaping Neighbourhoods: A Guide for Health, Sustainability and Vitality.

 

Table 5.5 New development proposals and changes of use in the vicinity of Neighbourhood Centres

 

Designations shown on the Policies Map

Each of the designations set by this policy are shown on the Policies Map. The designations are summarised in Table 5.6 below:

Table 5.6 Designations set by Policy DM5 shown on the Policies Map

Designation

Location

Neighbourhood Centre

Ashburton Park Brighton Road/Downlands Road Brigstock Road Coulsdon Road/Court Avenue Fieldway Green Lane/Northwood Road Kenley (Godstone Road) London Road/Kidderminster Road Lower Addiscombe Road/Cherry Orchard Road Portland Road/Watcombe Road/Woodside Avenue Selhurst Road Selsdon Park Road/Featherbed Lane Shirley Road South End/Parker Road/St Peter's Church South Norwood Hill Spring Park/Bridle Road Waddon Road/Abbey Road Woodside Green

 

How the policy works

5.52 This approach is the preferred approach as it assists in promoting the development of community facilities to serve neighbourhood areas and complies with the National Planning Policy Framework and the London Plan.

5.53 Neighbourhood Centres are not town centres (unlike District and Local Centres). Thresholds are applied to specific uses within Neighbourhood Centres to ensure that proposed developments only serve a neighbourhood need and should not be to the detriment of designated Local or District Centres whilst enabling development of town centre uses that serve the local community.

5.54 This policy seeks to ensure that flexibility is granted to community facilities that wish to locate in Neighbourhood Centres in order to serve a local identified need.

5.55 Where indicated as acceptable in principle, proposals will also have to comply with other policies in the plan such as those on neighbouring amenity or traffic safety.

5.56 Neighbourhood Centres typically serve their immediate residential properties, and as such a five to ten minute walk is considered an appropriate distance.

5.57 The Council will not permit the development or expansion of retail or commercial premises that would significantly increase the 'offer' of the Neighbourhood Centre to the detriment of a Local or District Centre. For this reason, development of retail and town centre community uses with a floor space above 280m² will still be subject to a sequential test in accordance with Policy DM8: Development in edge of centre and out of centre locations.

5.58 For the purposes of Part 3 Class M of the General Permitted Development Order (2015), which sets out the circumstances where planning permission is not required for changes of use from retail to residential use, designated Shopping Parades within Neighbourhood Centres are considered to be key shopping areas. In these locations any change of use from a retail use to residential will require an application to be made for planning permission which will be considered against the requirements of this policy which would not allow for the conversion.

Key supporting documents

• Croydon's Monitoring Report (annual)
• Assessments of boundaries and designations for Croydon Metropolitan Centre, District and Local Centres (2012 and 2015)
• Borough Wide Retail Needs Study Update (2008)
• The Urban Design Compendium (2000)
• Barton, H., et al. (2003) Shaping Neighbourhoods: A Guide for Health, Sustainability and Vitality

Development in Shopping Parades

Strategic Objectives and related Croydon Local Plan strategic policies

Policy SP3.6

Policy SP3.7

Policy SP3.8

Policy SP3.9

Policy SP3.10

Policy SP3.11

Policy SP3.12

Policy SP3.13

 

Why we need this policy

5.59 The primary function of Shopping Parades is to provide local convenience shopping facilities. This policy sets out the policy approach to different uses within Shopping Parades and also designates each Shopping Parade in the borough.

5.60 In relation to drawing up Local Plans, paragraph 23 of the National Planning Policy Framework states that local planning authorities should 'set policies for the consideration of proposals for main town centre uses which cannot be accommodated in or adjacent to town centres'.

5.61 A review of all retail units outside any town centre or Shopping Parade based on the Croydon Monitoring Report 2014/15 has identified that there are a number of locations in the borough that could benefit from designation as a Shopping Parade.

 

Table 5.7 New development proposals and changes of use in Shopping Parades

Use	Expansion of existing uses or newly proposed uses
A1	Changes of use or proposals which do not result in an increase in floor space of the overall Parade are acceptable in principle. Other development will be subject to the provisions of Policy DM8: Development in edge of centre and out of centre locations.
A2 – A4 and Community Uses	Acceptable in principle as long as it does not result in more than 50% of the ground floor of units (within the entirety of the Parade) falling outside the A1 Use Class
A5	Acceptable in principle as long as it does not result in more than 50% of the ground floor of such units (within the entirety of the Parade) falling outside the A1 Use Class, allows for a range of A2-A4 uses as well as A5, provides an active frontage, provides adequate arrangements for dealing with waste (including customers' waste) and for any delivery service intended and is accredited in accordance with the Council's Eat Well Croydon scheme
B1 (Change of use only)	Changes of use to office, research & development and light industrial workshops are acceptable in principle as long as it does not result in more than 50% of the ground floor of units (within the entirety of the Parade) falling outside the A1 Use Class, allows for a range of A2-A4 uses as well as B1 and provides an active frontage
All Other Uses (including new development of B1)	Unless it relates to a Community Use or change of use to B1 use, proposals involving an increase of non Class A ground floor space within parades will be refused

 

Designations shown on the Policies Map

Each of the designations set by this policy are shown on the Policies Map. The designations are summarised in Table 5.8 below:

Table 5.8 Designations set by Policy DM6 shown on the Policies Map

Designation

Location

Shopping Parade

Bensham Lane Brighton Road/Biddulph Road Brighton Road/Kingsdown Avenue Brighton Road/Newark Road Brigstock Road Bywood Avenue Calley Down Crescent Chapel View Cherry Orchard Road Chipstead Valley Road Crossways Parade Crown Parade Elmfield Way Fiveways Corner Forestdale Centre Godstone Road, Kenley Green Lane Grovelands Headley Drive Kenley Station Lacey Green London Road/Fairholme Road London Road/Mead Place London Road/Nova Road Lower Addiscombe Road Lower Addiscombe Road/Davidson Road Lower Addiscombe Road/Warren Road Lower Barn Road Mayday Milne Park East Mitcham Road/Aurelia Road Mitcham Road/Wentworth Road Monks Orchard Norbury Road Portland Road Portland Road/Sandown Road Purley Oaks Purley Way St James's Road Sanderstead Station Selhurst Road Selsdon Road Shirley Poppy Shirley Road Shirley Road/Bingham Road Shrublands Southbridge Road South Norwood Hill Stoats Nest Road Taunton Lane The Parade, Coulsdon Road Thornton Road Waddon Road Wayside, Fieldway West Croydon Whitehorse Lane Whitehorse Road Whitehorse Road/Pawsons Road Wickham Road Windmill Road/St Saviour's Road Windmill Road/Union Road Woodside Green

 

How the policy works

5.62 This policy seeks to ensure that at least 50% of the units within the Shopping Parade are within Class A1 use. Under certain circumstances when one or more units within a Parade are much larger than the other units (for example, when there is an 'anchor' store) the 50% threshold may be applied to the gross floor space within the Parade rather than the number of units. Unless it relates to a community use, proposals involving the net loss of ground floor A Class floor space within Shopping Parades will be refused. The Council's annual land use surveys suggest this threshold is generally effective in securing a predominance of A1 Class activity in Shopping Parades but does not render them prone to issues of long-term vacancy.

5.63 The policy limits the opening of new A5 units or changes of use to A5 in shopping parades. This will help to ensure residents have a greater choice of local retail services and will limit associated waste and delivery issues that can cause harm to residential amenity. Controls on the opening of new hot food takeaways support access to healthier food options outside town centres as shopping parades are often located in residential areas in close proximity to open spaces and schools.

5.64 Sui generis activities which serve the local area (such as a launderette) and community facilities are also acceptable uses within Shopping Parades. Shopping Parades can also provide space for small start-up companies who need office or workshop space so changes of use to Class B1 uses are also acceptable to facilitate this. However all other uses (including sui generis which serve a wider catchment) are not acceptable uses. New development of Class B1 uses are also unacceptable as new development of this type could threaten the retail character of a Shopping Parade in a way that change of use would not.

5.65 For the purposes of Part 3 Class M of the General Permitted Development Order (2015), which sets out the circumstances where planning permission is not required for changes of use from retail to residential use, Shopping Parades are considered to be key shopping areas. In these locations any change of use from a retail use to residential will require an application to be made for planning permission which will be considered against the requirements of this policy.

Key supporting documents

• Croydon's Monitoring Report (annual)
• Assessments of boundaries and designations for Shopping Parades (2012 and 2015)
• Appendix 3 – Designated shopping frontages

 

Development in Restaurant Quarter Parades

Strategic Objectives and related Croydon Local Plan strategic policies

Policy SP3.6

Policy SP3.7

Policy SP3.8

Policy SP3.9

Policy SP3.10

Policy SP3.11

Policy SP3.12

Policy SP3.13

 

Why we need this policy

5.66 The Restaurant Quarter in South End has grown over many years into a popular collection of largely independent bars and restaurants. The area is also home to Scream Studios, a recording studio and live music venue, which, along with other complementary activities, helps to diversify the cultural/leisure offer.

5.67 This policy applies to the ground floor only and seeks to encourage more bar and restaurant activity. The policy differs from that which relates to Shopping Parades by not placing a limit on the number of A3 and A4 uses within the frontage. It creates a new designation, a Restaurant Quarter Parade, to be shown on the Policies Map.

5.68 In relation to drawing up Local Plans, paragraph 23 of the National Planning Policy Framework states that local planning authorities should 'set policies for the consideration of proposals for main town centre uses which cannot be accommodated in or adjacent to town centres'.

5.69 A survey of South End indicated that the cluster of bars and restaurants is significant not only in terms of the cultural and leisure offer, but also as a generator of direct and indirect employment. 5.70 Policy 4.6c of the London Plan encourages the designation and development of cultural quarters.

 

Table 5.9 New development proposals and changes of use in Restaurant Quarter Parades

Use	Expansion of existing uses or newly proposed uses
A3 - A4	Acceptable in principle
A5	Proposals for new A5 uses or extensions to existing A5 uses will be refused
All Other Uses	Unless it relates to a Community Use (up to 250m2 gross), proposals involving an increase of non A3 - A4 Class ground floor space within Restaurant Quarter Parades will be refused

Designations shown on the Policies Map

Each of the designations set by this policy are shown on the Policies Map. The designations are summarised in Table 5.10 below:

Table 5.10 Designations set by Policy DM7 shown on the Policies Map

Designation	Location
Restaurant Quarter Parade	South End

 

How the policy works

5.71 This policy seeks to promote bar and restaurant activity by limiting the amount of other uses that can occupy (or extend) the ground floor of premises. A new Restaurant Quarter Parade has, therefore, been designated at 6 - 78 (even) and 1 - 77 (odd).

5.72 The policy limits Class A5 activity (which could undermine the area's function if restaurants and bars are replaced with hot-food takeaways). This will help to safeguard and promote the Restaurant Quarter.

5.73 Allowing community uses to locate here but limiting their size will enable complementary activities to move into the area but not dominate it.

Key supporting documents

• Appendix 3 – Designated shopping frontages

Development in edge of centre and out of centre locations

Strategic Objectives and related Croydon Local Plan strategic policies

Policy SP3.6

Policy SP3.7

Policy SP3.8

Policy SP3.9

Policy SP3.10

Policy SP3.11

Policy SP3.12

Policy SP3.13

 

Why we need this policy

5.74 In line with the 'Town Centres First' principle, commercial activity should be directed to town centres to take advantage of their better transport functions and so as not to undermine the established centres. However, there are circumstances when proposals for town centre uses in edge of centre and out of centre locations may be acceptable.

5.75 In relation to drawing up Local Plans, paragraph 23 of the National Planning Policy Framework states that local planning authorities should 'set policies for the consideration of proposals for main town centre uses which cannot be accommodated in or adjacent to town centres'.

 

Table 5.11 Development of main town centre uses in edge of centre and out of centre locations

 

How the policy works

5.76 This policy applies to all commercial uses equating to the National Planning Policy Framework's main town centre uses. Together these are defined as the following:

1. Retail development (including warehouse clubs and factory outlet centres);
2. Leisure, entertainment facilities and the more intensive sport and recreation uses (including cinemas, restaurants, drive-through restaurants, bars and pubs, night-clubs, casinos, health and fitness centres, indoor bowling centres, and bingo halls);
3. Offices; and
4. Arts, culture and tourism development (including theatres, museums, galleries and concert halls, hotels and conference facilities).

 

Table 5.12 Definition of edge of centre and out of centre location (informed by Annex 2 of the National Planning Policy Framework)

Use	Edge of centre when…	Out of centre when…
Retail development	Within 300m of the boundary of the centre's Primary Shopping Area and well connected	More than 300m from the boundary of the centre's Primary Shopping Area
Offices	Within 300m of the boundary of the centre or within 500m of East Croydon, West Croydon, Norbury, Thornton Heath, Norwood Junction, Purley or Coulsdon Town stations	More than 300m from the boundary of the centre and more than 500m from East Croydon, West Croydon, Norbury, Thornton Heath, Norwood Junction, Purley or Coulsdon Town stations
Other commercial use	Within 300m of the boundary of the centre	More than 300m from the boundary of the centre

 

5.77 When undertaking a sequential test, applicants will be required to demonstrate there is no town centre or edge of centres sites or units that accommodate their proposal. For a site or unit to be able to accommodate a proposal it must be both suitable for the proposed development (noting that both applicants and the Council should be flexible over issues such as format and scale) and likely to be available at the point in time that the proposal is expected to be delivered. For out of centre locations they will be required to assess whether there are any existing vacant out of centre units which can accommodate the proposal as it is sequentially preferable to occupy an existing unit in an out of centre location than develop a new unit.

5.78 Extensions to existing, changes of use to or new A5 uses will not be permitted in edge of centre or out of centre locations unless the end user is accredited in accordance with the Council's Eat Well Croydon scheme, and the ward in which the proposal is located has a density of hot food takeaways which is at the national average or less. This will restrict the opening of unhealthy hot food takeaways in close proximity to schools and open spaces. In turn this will support the public health agenda of tackling obesity, particularly for children and young people, and promotes access to healthier food options.

Figure 5.3 Density of takeaways in Croydon in 2016

5.79 As set out in the National Planning Policy Framework, the purpose of an impact assessment is to understand the impact of the proposal on existing, committed and planned public and private investment in a centre or centres in the catchment area of the proposal. It also assesses the impact of the proposal on town centre vitality and viability, including local consumer choice and trade in the town centre and wider area, up to five years from the time the application is made.

5.80 Where a proposed extension results in a unit greater than 2,500m² of floor space, an impact assessment will be required. Impact assessment will be required to assess the impact of the whole unit and not just the proposed extension.

5.81 For major schemes where the full impact will not be realised in five years, the National Planning Policy Framework states impact should also be assessed up to ten years from the time the application is made. Impact assessments will be required to assess the impact of the whole unit if it results in a floor space greater than 2,500m².

5.82 The use of planning conditions on the subdivision, extensions and the range of goods and mix of convenience and comparison goods sold ensures that developments in edge of centre and out of centre locations do not have any significant adverse impact of the vitality and viability of the Metropolitan, District and Local Centres. 5.83 New community facilities in edge of centre or out of centre locations are acceptable in principle. This does not apply to facilities considered to be a D2 use. These main town centre uses will require a sequential test and an impact assessment.

5.83 New community facilities in edge of centre or out of centre locations are acceptable in principle. This does not apply to facilities considered to be a D2 use. These main town centre uses will require a sequential test and an impact assessment.

Key supporting documents

• Croydon's Monitoring Report (annual)
• Borough Wide Retail Needs Study Update (2008)
• Croydon Metropolitan Centre Retail Strategy (2009)

 

Expansion of industrial and warehousing premises in Strategic, Separated and Integrated Industrial Locations

Strategic Objectives and related Croydon Local Plan strategic policies

Strategic Objective 1

Policy SP3.1

Policy SP3.2

 

Why we need this policy

5.84 Croydon continues to lose industrial/warehouse capacity at a rate which exceeds the forecast decline in demand. A natural response to this situation could be to adopt a more restrictive approach to the loss of such premises than was previously the case. However, such an approach would not be consistent with the London Plan or the National Planning Policy Framework.

5.85 Alternatively, the Council could seek to allocate more land for industrial/warehouse activities by extending one or more of the existing Strategic, Separated or Integrated Industrial Locations. However, the physical constraints associated with the Locations (railway lines, quarry walls, Metropolitan Open Land and neighbouring residential uses) means this is not practical.

5.86 The Office, Industrial & Warehousing Land/Premises Market Assessment recommends that the Council promote improved estate management at Purley Way North (Mill Lane area), Selsdon Road (north and central parts of estate) and Vulcan Way with the intention of encouraging redevelopment and intensification of land use, and improving environmental quality.

5.87 The Employment Land Review Update (2013) found that forecasts for demand and supply of industrial/warehousing land in Croydon was broadly consistent with the Office, Industrial & Warehousing Land/Premises (2010) and the Land for Industry and Transport Supplementary Planning Guidance (2012).

5.88 The Mayor of London's Supplementary Planning Guidance on Land for Industry and Transport sets out an annual indicative industrial land release benchmark for Croydon of 0.5 hectare with a total release benchmark for 2011 – 2031 of 9 hectares. However, as Croydon lost 9 hectares of industrial land in a single five year period between 2006 and 2010, it is likely that expansion in Strategic and Separated Industrial Locations will be required to compensate for losses to the industrial stock elsewhere.

 

How the policy works

5.89 The approach promoted by this policy is to encourage greater density of occupation within the current boundaries of the Strategic, Separated and Integrated Industrial Locations. There are isolated examples where higher densities have been achieved without compromising the operational ability of the premises and the Council is keen to see more of this type of development.

Key supporting documents

• Office, Industrial & Warehousing Land/Premises Market Assessment (2010)
• Employment Land Review Update (2013)
• Land for Industry and Transport Supplementary Planning Guidance (2012)

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¹ Para 10.3, Croydon Metropolitan Centre Retail Strategy, Dec 2009 (Drivers Jonas)

² Para 7.7, L.B. Croydon Office, Industrial, Warehousing Land/Premises Market Assessment, August 2010 (URS & Stiles Harold Williams)

³ Employment Land Review 2014

⁴ Including both Purley Way North and Purley Way South

⁵ Excluding Class B1a (Offices)

⁶ To be acceptable in these locations, employment generating sui-generis uses must provide employment which is comparable in terms of activities and job numbers to industrial/warehousing uses.

⁷ To be acceptable in these locations, employment generating sui-generis uses must provide employment which is comparable in terms of activities and job numbers to industrial/warehousing uses.

⁸ To be acceptable in these locations, employment generating sui-generis uses must provide employment which is comparable in terms of activities and job numbers to industrial/warehousing uses.

⁹ To be acceptable in these locations, employment generating sui-generis uses must provide employment which is comparable in terms of activities and job numbers to industrial/warehousing uses.

¹⁰ Table 7.3, p.107 - LB Croydon Office, Industrial, Warehousing Land/Premises Market Assessment (August 2010)

¹¹ The London Plan sets out the approach each borough should take in relation to industrial land. For some boroughs, this means releasing an identified over supply for alternative uses. For Croydon, it means continuing with a more restrictive approach to the transfer of industrial sites to other uses.

¹² 'Understanding and Shaping the Cultural Sector in L.B. Croydon (Draft Final Report)' (Sept 2010)

¹³ 'Understanding and Shaping the Cultural Sector in L.B. Croydon (Draft Final Report)' (Sept 2010)

¹⁴ For the purposes of this policy all floors within purpose built shopping centres are considered to be ground floors.

¹⁵ For the purposes of calculating the percentage of units within a given frontage, the Council will apply a rule of seven units either side of the subject property and an equal number of units on the opposite side of the road (if the frontage designation extends there also). Guidance is given in Appendix 2.

¹⁶ For the purposes of calculating the percentage of units within a given frontage, the Council will apply a rule of seven units either side of the subject property and an equal number of units on the opposite side of the road (if the frontage designation extends there also). Guidance is given in Appendix 2.

¹⁷ Building the foundations: Tackling obesity through planning and development (Town and Country Planning Association, March 2016)

¹⁸ "Well connected" is defined as a location benefitting from a Public Transport Accessibility Level of 4 and above.

¹⁹ "Well connected" is defined as a location benefitting from a Public Transport Accessibility Level of 4 and above.

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