The content of this section is related to the theme of Croydon as 'A Place with a Sustainable Future.' It considers how the borough can become a sustainable, well connected place and an environment prepared for the impacts of a changing climate.
8.1 The key issues that the borough faces in terms of planning for climate change up to 2036 are:
Strategic Objective 5: |
Ensure that high quality new development both integrates, respects and enhances the borough's natural environment and built heritage. |
Strategic Objective 9: |
Ensure the responsible use of land and natural resources and management of waste to mitigate and adapt to climate change. |
Strategic Objective 10: |
Improve the quality and accessibility of green space and nature, whilst protecting and enhancing biodiversity. |
Strategic Objective 11: |
Tackle flood risk by making space for water and utilising sustainable urban drainage systems. |
SP6.1 In order to reduce greenhouse gas emissions and deliver development that is adaptable in a changing climate, the Council will apply a presumption in favour of development provided applications meet the requirements of Policy SP6 and other applicable policies of the development plan.
Energy and carbon dioxide (CO2) reduction
SP6.2 The Council will ensure that future development makes the fullest contribution to minimising carbon dioxide emissions in accordance with the London Plan energy hierarchy (use less energy, supply energy efficiently and use renewable energy), to assist in meeting local, London Plan and national CO2 reduction targets. The Council will promote the development of district energy networks where opportunities exist due to high heat density1 or an increase in heat density brought about by new development. This will be achieved by:
Sustainable design and construction
SP6.3 The Council will seek high standards of sustainable design and construction from new development, conversion and refurbishment to assist in meeting local and national CO2 reduction targets. This will be achieved by:
Flooding, urban blue corridors and water management
SP6.4 The Council, as a Lead Local Flood Authority, will work in partnership with the Environment Agency, community groups, water and highways infrastructure providers, developers and other Lead Local Flood Authorities to reduce flood risk, protect groundwater and aquifers, and minimise the impact of all forms of flooding in the borough. This will be achieved by:
SP6.5 The Council and its partners will promote the implementation of 'Urban Blue Corridors', enabling a network of multifunctional spaces and corridors that provide safe routes and storage for flood water within the urban environment. This will be achieved by:
Waste management
SP6.6 The Council supports the objectives of sustainable waste management set out in the London Plan and national policy. The Council will identify the necessary capacity in collaboration with the neighbouring boroughs of Merton, Kingston and Sutton to maximise self-sufficiency in managing the waste generated within the four boroughs. This will be achieved through the South London Waste Plan DPD and any further revisions.
Minerals
SP6.7 The Council will support schemes for aggregate recycling facilities within the borough and seek to reduce the environmental impact of aggregates by supporting the enhancement and development of aggregate recycling facilities where there is no significant detriment to local amenity (see Policy SP8 regarding freight movement and railheads).
Figure 8.1 Map of Policy SP6 Environment and Climate Change
Energy and carbon dioxide (CO2) reduction
8.2 In 2012, the London Borough of Croydon was responsible for 1,544 kilo tonnes of carbon dioxide (CO2) emissions5 . While this level of emissions is eighth highest across the 33 London Boroughs, total emissions from Croydon's homes are the second highest across the boroughs. The London Plan includes a target to reduce CO2 emissions by 60% by 2025 and the Climate Change Act sets out that emissions will be reduced by 80% by 2050 (based on 1990 levels). The Croydon Climate Change Mitigation Action Plan 6sets out targets for reducing borough wide CO2 emissions. A key part of this action plan is the minimisation of CO2 emissions arising from new and existing buildings, through sustainable design and construction and low/zero carbon energy generation. This approach is embedded in the 'We Are Croydon Vision'7 .
8.3 The Sustainable Design and Construction Evidence Base8 and District Energy Feasibility Study9 highlights that there is significant potential, in the form of high heat densities, for district energy. National planning policy and the London Plan support the development of district energy as a cost effective means of achieving low (and zero) carbon development in urban areas. The National Technical standards (2015) for new housing and the London Plan set minimum levels for CO2 reduction. The London Plan also allows for the offsetting of residual CO2 emissions where it can be demonstrated that it is not feasible to achieve the required CO2 target fully onsite. Development applications proposing the utilisation of biomass heating systems or biomass combined heat and power systems will be required to provide appropriate information to allow assessments to be made of the effectiveness of measures to minimise the impact on local air quality.
Sustainable design and construction
8.4 Adoption of the National Technical Standards (2015) and London Plan requirements will ensure that new developments achieve high standards of environmental performance which address: energy/water consumption, environmental impact of materials, waste, surface water run-off, pollution, construction management, ecology and occupant health and wellbeing. The design of developments should maximise the potential to use innovative construction technologies, pre-fabrication elements and sustainable materials alongside the use of recycled materials as referred to in the Mayor's SPG on 'Sustainable Design and Construction' (2014). A requirement for major refurbishments and conversions to meet the National Technical Standards (2015) and London Plan requirements will ensure that opportunities to modernise and improve Croydon's existing buildings are maximised. Overall, this approach will help meet the objectives set out in Croydon's Climate Change Mitigation Strategy and Climate Change Adaptation Strategy.
Flooding, urban blue corridors and water management
8.5 The Strategic Flood Risk Assessment for Croydon, Sutton, Merton and Wandsworth (SFRA, 2015) identifies the main risks of fluvial flooding in the vicinity of the Norbury Brook through Thornton Heath and Norbury and through Kenley, Purley and Waddon along the Brighton Road and Godstone Road valleys and around the culverted River Wandle10 Croydon has been ranked the 4th settlement in England most susceptible to surface water flooding11 . The Surface Water Management Plan (SWMP) identifies parts of the borough to be particularly susceptible to surface water flooding, including Brighton Road through Purley up to Central Croydon and the A22 Godstone Road12 . The SFRA identifies significant episodes of surface water flooding at Purley Cross, Kenley Station, Brighton Road Coulsdon, Hamsey Green, Purley Oaks Road, Norbury and Thornton Heath 13. The SFRA also identifies areas in the borough where groundwater may occur and where groundwater may come close to the ground surface 14. Croydon experienced severe flooding in 2014 associated with the Caterham Bourne and high groundwater levels.
8.6 The SFRA, SWMP scoping report, Sustainable Design and Construction Evidence Base and policies in the London Plan recommend the application of sustainable urban drainage (SuDs) to ameliorate flood risk, improve water management and reduce surface water run-off. The Council, as the Local Planning Authority and the Lead Local Flood Authority, is required to ensure that SuDS are implemented in all major developments. The requirement to utilise SuDS in all development, including those in low risk areas, is in view of the fact that surface water from one area of a catchment may contribute towards enhanced flood risk in another area of that catchment. In addition, flood events are expected to become more frequent and more significant in the future as the U.K.'s climate changes and this requirement will go some way to adapting to this change. The installation of SuDS, such as green roofs, can have several additional benefits: increasing biodiversity and urban cooling, providing additional open space in built-up areas and improvements to water quality. Flood Risk Assessments will highlight site specific issues and help inform the best solutions to reduce flood risk and improve water management. The Level 2 SFRA and SWMP can be used to guide which SuDS will be the most suitable based on site specific considerations.
8.7 A Department of Environment, Food and Rural Affairs (DEFRA) commissioned research report, involving Croydon Council, entitled 'Developing Urban Blue Corridors' proposes tackling pluvial flood risk in a more innovative and strategic manner through the establishment of a network of multifunctional spaces for water15 . It propounds the establishment of safe flood corridors and setting development back from natural overland flow paths and ponding areas. Establishing a network of multifunctional spaces and corridors for flood water provides additional opportunities for improving biodiversity, recreation, urban cooling and access improvements to ponds and open water sites such as South Norwood Lake and Waddon Ponds. The approach is supported by policy within the London Plan 16. The Croydon Local Plan's Detailed Policies and Proposals will set detailed policies for establishing Urban Blue Corridors in Croydon.
8.8 The Environment Agency has defined Source Protection Zones (SPZs), for groundwater sources such as wells, boreholes and springs used for public drinking water supply. These zones show the risk of contamination from any activities that might cause pollution in the area. The closer the activity, the greater the risk. A formation of chalk underlies Croydon. Fractures in the chalk rock allow groundwater to collect and flow underground. They also allow large quantities of groundwater to be brought to the surface through pumping of wells. The water from these wells supplies over 70% of Croydon's drinking water, and should be protected to ensure water is available to current and future generations. Considerate planning is needed so that development does not have a detrimental effect on the public's valuable water resource. Through this package of measures Croydon has the potential to reduce urban diffuse pollution in its water bodies and help improve the ecological status of the borough's surface waters such as the River Wandle, Norbury Brook and Caterham Bourne.
Waste management
8.9 The Council has developed the South London Waste Plan DPD with the neighbouring boroughs of Kingston, Merton and Sutton. The Waste Plan forms part of each borough's Local Development Framework and ensures that collectively, the boroughs meet the London Plan, national and EU requirements. Detailed planning policies for the assessment and delivery of new waste management facilities are set out in the South London Waste Plan DPD. Policy 5.16 of the London Plan seeks to manage as much of London's waste within London as practicable; working towards managing the equivalent of 100 per cent of London's waste within London by 2031 and creating positive environmental and economic impacts from waste processing working towards zero biodegradable or recyclable waste to landfill by 2031. Within this context, the London Plan emphasises that boroughs should maximise self-sufficiency. The London Plan provides updated guidance and revised waste apportionment that the South London Waste Plan will seek to meet.
8.10 When considering planning applications for new waste management facilities, the Council will have regard to the policies of the South London Waste Plan DPD, the site selection criteria to be set out in the Croydon Local Plan's Detailed Policies and Proposals and the additional location criteria set out in the London Plan and national policy. Within Croydon, some Strategic Industrial Locations have been identified as potentially suitable for waste management facilities and are identified in the South London Waste Plan DPD.
Minerals
8.11 An aggregates company has access to a rail head at Purley. Whilst the borough has no minerals for extraction the levels of growth envisaged over the plan period will require sustainable means with which to transport and distribute aggregates as well as recycling aggregates.
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8.12 As part of its commitment to achieving sustainable development and promoting the economic and social wellbeing of the borough, the Council needs to ensure that there is effective protection of the environment and prudent use of natural resources. To do this the Council needs to assess the environmental impacts of development and take action to ensure that sustainable development objectives are met. The entire borough of Croydon is also an Air Quality Management Area.
The Council will promote high standards of development and construction throughout the borough by:
Why we are proposing
8.13 In Croydon, developments of 10 or more new homes or 500m2 or more of non-residential floor space are expected to meet high sustainable construction standards in accordance with the Croydon Local Plan.
8.14 Developers should seek to minimise the adverse environmental impacts of development during construction in line with the Sustainable Design and Construction Supplementary Planning Guidance 2014 and by considering the following best practice measures:
8.15 Solid wall insulation will also be encouraged in existing developments where planning permission may be required.
Air quality
8.16 The entire borough of Croydon is an Air Quality Management Area (AQMA) and therefore developers should give careful consideration to the air quality impacts of their proposed development through an Air Quality Assessment.
8.17 Since very few developments are 'zero emission' developments, most development will have a negative impact on air quality. As Croydon is an AQMA, new developments should be at least 'air quality neutral'. Developers should consider measures to minimise emissions of air pollution at the design stage and should incorporate best practice in the design, construction and operation of the development. Where a development has a negative impact on air quality, developers should identify mitigation measures that will minimise or offset the emissions from the development. These mitigation measures should be implemented on-site. This is especially important where provision has been made for a large number of parking spaces, where the development will generate a significant number of trips, will give rise to other potentially significant sources of pollution or will be used by large numbers of those particularly vulnerable to poor air quality, such as children or older people. Poor air quality is linked to the development of chronic diseases and can increase the risk of respiratory illness. Tackling poor air quality can improve health problems and minimise the impacts on vulnerable groups, especially asthma in children and heart and respiratory diseases in older people.
8.18 The Council has produced an Interim Policy Guidance (Standards and Requirements for Improving Local Air Quality) on requirements for improving local air quality, which sets out situations when an assessment may be required and suggests methods of undertaking such an assessment within the Croydon area. Developers or architects involved in new residential development, new industrial and commercial development, or mixed use development with housing should consult the Interim Planning Guidance on Improving Local Air Quality and the Mayor of London's Control of Dust and Emissions Supplementary Planning Guidance.
Noise
8.19 There is a need to ensure that residents and businesses are protected from environmental disturbance during the construction of major developments.
8.20 The Council's Code of Practice has been prepared to help developers and their contractors ensure that they undertake their works in the most considerate manner, in order to reduce the impact of the work on local communities. It also provides guidance on a Construction Logistic Plan required for major developments and the assessment of traffic movements.
8.21 Most planning applications received by the Council are assessed for the impact of environmental noise on the new development. This to ensure that the proposed development has adequate sound insulation in order to minimise the adverse impact of noise from a railway or a busy road, aircraft or an industrial activity. Residential developments close to railways and other noise sensitive sites will need a noise assessment.
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8.22 Whilst a site may contain elevated levels of 'contaminants', it may or may not be defined in legislation as contaminated land.
8.23 The legislation defines contaminated land as 'any land which appears to the local authority in whose area it is situated, to be in such a condition, by reasons of substances in, on or under the land that:
8.24 Land contamination is likely to have arisen from the activities of past industrial and waste disposal practices. Elevated levels of heavy metals, oils, pesticides, and asbestos or landfill gas are a few examples of substances or materials which could be considered contaminants and which, where not properly managed, could cause harm to health or the environment.
8.25 The planning system aims to ensure that the effects of historical contamination do not cause any harm to the future users of a site. Provisions in the planning process ensure that, where contamination is an issue on a site, it is cleaned up or remediated before or as part of its redevelopment. Contaminated sites can be redeveloped into uses such as housing, schools and hospitals.
8.26 Before the introduction of the Environmental Protection Act 1990, there were instances where the previous controls dealing with contamination were not so effective, and going back further in time, controls werelimited or non-existent. This may have resulted in contamination not being addressed or satisfactorily dealt with prior to or during the site's development. It is these sites that the legislation aims to deal with by ensuring that, where potentially contaminated sites do exist, they are found and cleaned up.
8.27 It is the responsibility of the Council to determine whether it considers the site to be contaminated. Planning controls through the imposition of conditions assists in helping to govern these sites.
DM24.1 The Council will permit development proposals located on or near potentially contaminated sites, provided that detailed site investigation is undertaken prior to the start of construction in order to assess:
DM24.2 Where the assessment identifies unacceptable risks to human health, adjacent land uses or the local environment, site remediation and aftercare measures will be agreed or secured by condition to protect the health of future occupants or users.
DM24.3 All development proposals on contaminated sites should be accompanied by a full risk assessment, which takes into account existing site conditions.
8.28 In addressing contamination, it is recognised that retrospective remedial actions, carried out after a site has been developed, will be significantly more expensive and difficult, than if the remediation is carried out prior to or as part of a site's development. As a consequence of this, when a site is to be developed, the Council will seek to ensure that any issues of contamination are addressed through the imposition of planning conditions prior to its development. The scale of remediation of the land should reflect the nature and risk posed by any contaminants. The Council's Contaminated Land Officer will advise on remedial measures and that measures are successfully implemented.
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8.29 The National Planning Policy Framework states that development should be directed away from areas at a highest risk of flooding and that Local Plans should apply a sequential, risk-based approach to the location of development. Where development is required in areas at risk of flooding, it should be safe for the lifetime of development without increasing flood risk elsewhere.
8.30 The National Planning Policy Framework and Planning Practice Guidance state that sustainable drainage systems should be given priority in major developments unless demonstrated to be inappropriate. However, the use of sustainable drainage systems in all developments provides the opportunity to manage surface water as close to the source as possible and provide wider amenity and biodiversity benefits.
DM25.1 The Council will ensure that development in the borough reduces flood risk and minimises the impact of flooding by:
DM25.2 In areas at risk of flooding development should be safe for the lifetime of development and should incorporate flood resilience and resistant measures into the design, layout and form of buildings to reduce the level of flood risk both on site and elsewhere.
DM25.3 Sustainable drainage systems are required in all development and should:
Table 8.1 Application of Sequential test and Exception test to applications in Croydon
Flood Zones |
Land uses |
Sequential Test |
Exception Test |
Flood Risk Assessment |
|---|---|---|---|---|
Flood Zone 1 |
All uses are permitted |
Required if identified at risk from other sources of flooding |
Not applicable |
All major17 developments and all developments in areas identified as at risk from other sources of flooding |
Flood Zone 2 |
Highly vulnerable uses will only be permitted if the Exception Test is passed More vulnerable and Highly vulnerable uses should set Finished Floor Levels a minimum of 300mm above the known or modelled 1% annual probability flood level (1 in 100 year) including climate change |
Required for all development unless allocated in the Croydon Local Plan 2018 |
Required for highly vulnerable uses |
All development |
Flood Zone 3a |
Highly vulnerable uses will not be permitted More vulnerable uses should set Finished Floor Levels a minimum of 300mm above the known or modelled 1% annual probability flood level (1 in 100 year) including climate change Basements dwellings will not be permitted |
Required for all development unless allocated in the Croydon Local Plan 2018 |
Required for essential infrastructure and more vulnerable uses |
All development |
Flood Zone 3b |
Water compatible uses will be permitted Highly vulnerable, more vulnerable and less vulnerable uses will not be permitted Basements dwellings will not be permitted |
Required for all development unless allocated in the Croydon Local Plan 2018 |
Required for essential infrastructure |
All development |
8.31 When preparing Flood Risk Assessments regard should be had to the Strategic Flood Risk Assessment, Surface Water Management Plan, Local Flood Risk Management Strategy, other local flood history, relevant flood defence asset information and Environment Agency flood maps. Flood Risk Assessments should assess the risk from all sources of flooding and should be informed by the latest evidence on climate change allowances.
8.32 The Sequential Test and Exception Test are not required for sites allocated in this Plan, for minor development 18 or change of use19 . For all other development in Flood Zones 2 and 3 the Sequential Test and Exception Test should form part of the Flood Risk Assessment, having regard to the guidance in the Strategic Flood Risk Assessment. A Sequential Test is required for development in Flood Zone 1 if the area has been identified at risk from other sources of flooding.
8.33 For residential development, a Sequential Test may be made against the Council's published five year supply of housing land and should demonstrate that the five year supply of housing land cannot be met on sites with a lower risk of flooding. For all other uses a Sequential Test should be based on the catchment of the proposed use.
8.34 Where a site is at risk of groundwater, the Council will request a Basement Impact Assessment as part of the Flood Risk Assessment for any basement application. These assessments should be informed by ground investigations to help assess the flood risks to basement development.
8.35 Croydon has experienced a number of surface water flood events and has been ranked by Department of Environmental, Food and Rural Affairs as the 4th settlement in England most susceptible to surface water flooding20 . The Local Flood Risk Management Strategy identifies up to 33,614 residential properties at risk from surface water in the borough21 . Extensive records are held of surface water flooding across the borough with particularly significant episodes at Purley Cross roundabout and Brighton Road, Kenley station, Brighton Road (Coulsdon), Hamsey Green, Purley Oaks Road, Norbury and Thornton Heath22 . Due to the risk posed by surface water flooding in Croydon, development should utilise sustainable drainage systems to achieve better than greenfield runoff rates from the site. Greenfield runoff rates are defined as the runoff rates from a site, in its natural state, prior to any redevelopment and are typically between two and eight litres per second per hectare 23. If better than greenfield runoff rates cannot be achieved, this should be justified to the Local Planning Authority and Lead Local Flood Authority as part of a drainage strategy. In these instances greenfield runoff rates should be achieved as a minimum in line with the London Plan.
8.36 Sustainable drainage systems should always be considered as early in the design process to inform the design of the development. Proposals should demonstrate an understanding of how surface water will flow across the site, taking account of topography and locating drainage features accordingly. A drainage strategy should demonstrate that the site will achieve better than greenfield runoff rates and that sustainable drainage systems have been designed in line with the London Plan drainage hierarchy. Drainage design should follow the principles of water sensitive urban design and demonstrate a sustainable drainage management train. A sustainable drainage management train identifies the different stages of movement of water through and across a site, identifying suitable sustainable drainage techniques for each stage. For example, a management train could consist of a green roof, a soakaway and permeable paving used in different parts of a development. The drainage strategy should also demonstrate how the drainage system will be managed and maintained for the lifetime of the development.
8.37 Sustainable drainage systems provide wider benefits than just reducing surface water runoff from a site. They provide opportunities to improve water quality by removing pollutants, improve the quality and attractiveness of public realm and open spaces and enhance biodiversity through the creation of habitats such as ponds and wetlands. Sustainable drainage systems should be designed to manage water as close to the source as possible and include treatment stages which not only manage the flow of water but provide wider benefits to the site. The contribution of trees in reducing flood risk should be recognised in developing sustainable drainage systems and the wider benefits that can be realised. Detailed guidance on sustainable drainage systems will be produced by the Lead Local Flood Authority.
1 55 residential units or 1,000m2 commercial development per hectare
2 55 residential units per hectare for developments of over 100 homes; 75 units per hectare for developments of 20 or more but under 100 homes
3 10 or more residential units, a site of 0.5 hectares or more or 1,000m2 commercial development
4 Enablement for district energy connection which incorporates provision of a communal heating system operating to defined temperatures with a suitable on site space for associated heat connection plant and pipe connection to the perimeter of the site.
5 Department of Energy & Climate Change, UK local authority and regional carbon dioxide emissions national statistics: 2005-2012
6 Croydon Council "Croydon Climate Change Mitigation Action Plan" 2010
7 We Are Croydon vision (page 45)
8 LBC Sustainable Design and Construction Evidence Base 2010 (page 58-61)
9 AECOM District Energy Feasibility Study 2009
10 SFRA Appendix A Figure 2.1
11 National Rank Order of Settlements Susceptible to Surface Water Flooding, DEFRA 2009
12 London Borough of Croydon Surface Water Management Plan, Phase 1 Scoping Study - Final Draft (page 23)
13 SFRA Appendix A Figure 2.3
14 SFRA Appendix A Figure 2.4
15 URS Scott Wilson, Kingston University and Croydon Council. 'Developing Urban Blue Corridors Scoping Study Final Report' (March 2011). Report for DEFRA.
16 London Plan Policies 5.10, 5.11, 5.12, 5.13, 7.27, 7.28, 7.30
17 Developments of 10 or more residential units, 1,000m2 or more of non-residential floor space or sites more than 0.5ha in extent
18 In relation to flood risk, minor development means: minor non-residential extensions with a footprint less than 250 square metres; alterations that do not increase the size of buildings; household development within the curtilage of the existing dwelling and physical extensions to the existing dwelling itself. This excludes the creation of a separate dwelling within the curtilage of the existing dwelling.
19 This excludes change of use to a caravan, camping or chalet site or to a mobile home or park home site.
20 National Rank Order of Settlements Susceptible to Surface Water Flooding, DEFRA 2009
21 London Borough of Croydon Local Flood Risk Management Strategy
22 London Borough of Croydon, Merton, Wandsworth Strategic Flood Risk Assessment Level 1
23 London Plan Sustainable Design and Construction Supplementary Planning Guidance
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