Croydon Development Plan Revisions – What do you think?

The Local Plan provides an overall strategy, guides decisions on future development proposals and addresses the needs and opportunities of the borough over a 20 year time horizon. The Current plan was drawn up in 2018 by the Labour administration. The Plan must be consistent with the London wide plan and UK government planning guidelines.

Changes to the plan are being made to reflect Mayor Perry’s views on development which is called his “Business Plan 2022-2026”.  Final consultation on these revisions will be taking place during Jan and Feb of 2024 and adopted later in the year. The main changes from the current plan – the 2018 plan are as follows.

In terms of Urban Design, the Mayor has already revoked SPD2 which the previous regime used to justify many inappropriate infill developments. The new recommendations are for the removal of all suburban intensification areas and the removal of 3 storey blanket policy.  The Mayor will also promote design over density, respecting Croydon’s unique character and identity and allocate larger brownfield sites and sustainable locations to meet housing targets.

All this is much appreciated and a confirmation of what we have seen recently in Planning Committee decisions over the last 18 months.

However is Croydon building sufficient new homes – and the right mix of housing for these policies to continue and Mayor Perry not to be reeled in by either Mayor Khan or the Department of Levelling Up, Housing and Communities.

The current target per annum agreed with Mayor Khan is 2,079 units up to 2029 and Croydon Council are proposing around 1,200 per annum from 2029 until December 2040.  The Council is currently meeting these targets and had a pipeline of 11,893 as of March 2022 – the last time figures were published.

I suspect Croydon is well in excess of its targets given the number of block completed around East Croydon in the last year. As I have said before, to me all this high rise development around East Croydon is on balance good.

However how is Croydon doing in meeting its targets on affordable homes and family homes. The answer is badly.   For affordable homes the target is 50% and the current run rate is 17%. For family homes – homes with three bedrooms or more – the target is 30% and the current run rate is 16%.

Whilst Croydon is not alone in not meeting its targets I think these targets are worth trying to achieve. For example what is going to happen to all those 20 somethings living in the new 1 and 2 bed flats in the towers all around East Croydon.  Are they all going to have to leave us when they turn into new families. And what about those people who cannot afford these new flats and there is insufficient affordable housing.

We at the CVRA will be raising these affordability and size issues in the January consultation.  If there is anything else you would like us to raise, please get in touch.

The Council’s update document can be found below:

Plan Revision Document

Consultation on the Lloyd Park bowling green and the Council’s plan for the evolution of the park

The Friends of Lloyd Park are consulting with local residents’ associations regarding the Council’s plan evolution of the park.  Examples of questions are “do you want areas of the park where dogs have to be on leads?” and “do you want more events (such a music festivals) in the park.

It was a three minute survey for me (so probably a two minute survey for most) so if you are a user of the park or impacted by it please fill in the survey.  The link , below.

Turkish Kangol Dogs in Lloyd Park


A follow up from our MP Chris Philp.

Below is the email from Chris.  I was concerned that the only thing we had heard from the police or MPs regarding this incident was from Croydon Central MP Sarah Jones who stated “The dogs have once again been seized and the local police are doing everything they can to ensure they don’t get released back to the owner.” So I asked Chris Philp MP to request an update from the police.  The response is below. It says the investigation is ongoing under section 3 of the Dangerous Dogs Act 1991 and also that the courts will decide whether the dogs are released back to the owners. The fact that the courts will make the decision (which I believe is under the Dogs Act 1871 and is independent of a any proceedings under the 1991 Act) is, to me, reassuring.
Thank you Chris for this update

Dear Jeremy, 
Following from our previous correspondence, I have now received a response from the Metropolitan Police. Please find a copy of this response attached for your reference which I do hope you find helpful.

“The South BCU take all dog related matters, that are reported directly to police, very seriously. Regardless whether we have a complaint that meets the threshold of an offence under s.3 of the Danger Dogs Act legislation or not.
We have a working practice were all irresponsible dog owners or owners of problematic dogs, will be engaged with, regardless of social background of the owner and the breed of dog involved. There is legalisation in place for police to deal with prohibited breeds, i.e. Pit bull terriers, Japanese Tosa, Dogo de Argentino and  Fila Brasileiro and we will looked to enforce this piece of legislation where applicable.
The LEAD (Local Environmental Awareness on Dogs) Initiative is a police led initiative that deals with ALL dogs related incidents that do not meet the threshold of an offence under the Dangerous Dogs Act legislation. Through engagement and early intervention we, (and through working with partner agencies), offer intervention by way of  police engagement regardless of the breed of dog and the social background of the owner.  LEAD has highlighted that through early intervention we can prevent escalation. If during the process offences are highlighted or it is felt that enforcement is required, this will be taken. LEAD encourages partnership work and shares the responsibility/risk. LEAD helps in dealing with Safe Guarding communities.
LEAD is endorsed by Government departments (DEFRA) and Government ministers, National Dog Charities, RSPCA, Blue Cross, Battersea Dogs Home etc.  While also being recognised as ‘Best Practice’
In relation to the community’s concerns in regards to the three Turkish Kangal Dogs linked to Coombe Farm. Firstly, and most importantly, ALL THREE DOGS are currently being held in secure police kennels and will be staying within police kennels until such time the courts have made a final decision.
We currently have two ongoing  investigations into these dogs and their actions under s.3 of the Dangerous Dogs Act. One non-aggravated offence, (NO injuries caused to a person or Assistance dog) and an aggravated offence, (injuries Caused to a person or an assistance dog).
As these are still ongoing investigations you will understand that we are unable to quote on the matters at hand. But we can assure you that police are working diligently to uphold the legislation under the act, in a way that will protect and safeguard the local communities. However the final decisions will lie with the courts and it will be up to them to decide the final outcome on the evidence produced.”

Thank you again for taking the time to contact me and if I can be of any other assistance please let me know.

Kind regards,


Rt Hon Chris Philp MP
Member of Parliament for Croydon South
House of Commons, London SW1A 0AA | @chrisphilp_mp

Purley Pool Development – Some Questions

Would you use the proposed new pool in Purley? Would you go there by public transport? Do you currently use any of the four public pools currently in operation in the Borough? Would you prefer more affordable accommodation provided by the developer rather than a Leisure Centre?

The contentious issues surrounding the current plans are;
– The considerable reduction in parking available, down to a proposed 40 spaces for both the residents and the users of the leisure centre.
– The height of the tallest tower  –  twelve stories.
– The lack of affordable accommodation because of the costs of building the leisure centre.
– The running costs of the pool and leisure centre.
Both Chris Philp  and Jason Perry are in favor of the scheme but agree that the residents need to be consulted and listened to.
There are interesting trade offs here and just because we do not live in Purley it does not mean we do not have a say – as for example it will be our Council Tax used to support the leisure centre if it can not cover its costs. Another issue might be that if this is a say 40 year development then within 15 years it will probably be the case that cars are no longer a polluting problem and we will be regretting restricting parking availability.
More information is here:
We are liaising with other residents associations to come up with a consistent set of comments.
What are your views?

Eyesore Fixed in Castlemaine Avenue!

April 2023

Well done to Councillor Denton, the developer and the Castlemaine resident who reported the mess in the first place.
For some reason the developer of 86 Coombe Lane had left a gap in the boundry wall. Over the last year this gap, around 2m by 2m, has filled up with rubbish (and worse) and became an eyesore and health hazard. Councillor Denton got involved and as you can see a fence has been put up. This might be a temporary solution but it has removed the eyesore. I said when this was built it was a nice looking block. It is again. Well done all.

Meeting with the Planning Department March 7 2023

March 2023

Meeting with the Planning Department March 7 2023

Your Chairman went along to the 6 monthly meeting with the Planning Department (PD) earlier this month.

At the previous meeting, which was the first under the new administration of Mayor Perry, the whole meeting was spent talking about new build targets, the levels of completions against those targets and the adverse impact of the cumulative numbers of new developments on the availability of school places, transport and health services for residents in some of the other areas of Croydon. However there was less animosity as there had been at previous meetings as it was already apparent that the rate of approvals in the suburbs of Croydon was slowing down.

As I wrote at the time, listening to the complaints from other RAs made me realise that on balance most of us within Croham Valley had not been badly affected by the last administration’s desire to build so much in the suburbs of Croydon.

This time the PD gave us an update on the internal workings of the department and the plans over the next few years.

In 2022 the Department had been reviewed by the Government’s Planning Advisory Service (PAS) and the results have just been released. Not surprisingly the PAS stated that the department had somewhat fallen behind in processing applications as it had been under resourced (see below). In addition the PD had some bad practices and had lost the confidence of Croydon residents. The PAS did say however that the department was willing to learn.

The PAS made many recommendations;

  • The PD make the process of validating new applications more efficient along with many other working practices recommendations.
  • The PD becomes better at communicating citing poor communication (rather than actual use) around the use of the monies from the CIL and Section106 received by Croydon from developers.
  • The Department become better at Enforcement against developers who build something other than that which has been approved!
  • The Department improve their IT. See more of this below regarding Tree Preservation Orders.

I wondered whether some of the bad press the PD received was due to their poor IT.

The PD then went on to talk about enforcement. The council have a bad reputation for enforcement. The three new townhouses down Croham Road are three story but the plans said they should be four. This was reported over a year ago but no action has been taken and the townhouses are now occupied. As an aside we obviously prefer three stories but want to make the point that compliance is compliance.

Councillor Jeet Bains (Conservative – in charge of the Planning process) explained that Brent – a similar sized Council has many times the number of enforcement officers. We were told that recruiting the right type of people (someone ready to have a vigorous discussion) is difficult. Since May 2022 outstanding cases are down partly as a result of having a “no phone answering” session”.

The numbers since May 2022 are:

Cases outstanding then 1,350.
Now 1,100
Closed 800
New cases 550 (my calculation)
6 Enforcement Notices
2/3 Prosecutions

We did not have a chance to discuss the apparent low levels of enforcement notices/prosecutions compared to the number of cases closed. The Council acknowledged that it needed to publicise its successes, prioritise the big cases give more information of what is being enforced generally and going forward communicate progress a lot better.

A part of the discussion on Enforcement it was agreed that protecting trees was a priority and that both planning and enforcement officers would “drop everything” if it was reported a tree with a TPO was in danger. It was acknowledged however that the TPO details were on paper and should have been computerised by now in common with many other Councils.

Steve Pennington from the PD talked about planning policy in general.

The “Local Development Scheme” (LDS) which is the project plan for the planning policy process (if that makes sense) is out of date and is to be replaced. The new Scheme is to go to Cabinet in March. The timetable for the Local Plan Review is attached below.

The Local Plan Review (for consultation early next year) is to focus on;

  • design criteria
  • removal of intensification areas
  • long term new build numbers
  • post current planning cycle
  • HMO policy
  • Strengthening of Green Belt

The PD made the following comments

  • No change in existing targets following the recent Governmental NPPF consultations.
  • Despite retraction of the SPD2 document the Local Plan still has to be in compliance with the London Plan. However no specific issues were raised.
  • The small sites target is still in operation – although there was no further discussion on this. I think it was implied that going forward there will be better designed applications to fill the small site target.

The last topic presented on by the PD was in terms of Validation of planning applications. This was one of the items of improvement mentioned by the PAS. Most of the changes suggested seemed common sense. Many changes were directed towards clarifying the requirements for small developments/extensions.

What was more interesting were the statistics regarding timing of approvals. In addition to individual decisions going to the Inspectorate if a desicion is not made within 8/13 weeks for a small/large application (if I am correct) I was not aware that the Inspectorate will start the process of making all decisions if a PD falls below 70% compliance for less than 8 week for small and 60% compliance within the 13 weeks (or longer if prior agreement with the developer) for large.

The PD stated that after significant extra work they are currently at 75% compliance for both small and large whereas in May 22 they were very close to breaching both targets. The RAs were appreciative that the PD had retained its own decision making abilities.

Overall I sensed a PD coming to terms with the new administration and seeming to enjoy the more relaxed relationships with the RAs arising from the policies of the new administration.

Talk by Mayor Perry to the CVRA 3 November 2022

November 2022

Talk by Mayor Perry to the CVRA 3 November 2022

We thank Jason and Maria and Danielle for attending our AGM. Here is a write up of Jason’s talk.
Jason said he had come from a production at the Fairfield Halls reminding us that it is open!

Jason told us that it is a privilege to be Mayor. The Council is in a “no overall control” status but the Mayor is in charge of everything except for the quasi-judicial aspects of planning and licensing. The Planning Committee is split 50:50 but in addition with a Concervative Chair

A brief overview of the current issues were:

The debt is still there at £1.5bn. Interest costs are £50m per year.

The main short term priority is to clean up the Borough. Jason is talking to Viola whereas no-one from the previous regime had talked to them for over 6 months. In addition Jason has given the police additional powers to deal with anti-social behaviour issues.

Jason is also concentrating on Regeneration both in terms of encouraging inward investment and and applying for every type of development grant available.

In terms of planning policy the new new emphasis is on design rather than density.

Jason took questions from the audience.

Q1: Was Jason worried that despite Planning Committee rejection of various proposals the developers will win on appeal to the inspectorate especially as the Planning Department have been recommending acceptance.
Jason replied that most recent appeals have been won. Twelve recently. This has given Jason the opportunity to nudge the Planning Department towards interpreting the current guidelines in light of the “design rather than density” objectives of Jason’s regime.

Q2: Funding for Community Groups has been reduced.
Jason agreed but referred to the debt levels. He said that they are encouraging community groups to work together. Previously there was some overlap.

Q3: What is Jason’s view on the Borough’s social responsibilities in terms of providing housing and helping the homeless
Jason replied that there were over 1,000 refugees in Croydon’s hotels – which was more than their share. In terms of other homeless he was trying to promote a more holistic strategy as many homeless have not previously wanted to engage with the help offered. In terms of Social Housing, Croydons stock was in a bad way from actions from the last regime.

Q4: Jason was asked about the lack of bus shelters for over 18 months
Jason replied that the supplier – Valo Smart City is having problems fulfilling the contract. This is potentially a legal issue.

Q5: There were complaints regarding blocked drains at the bottom of Croham Manor Road. The resident complained that she was fed up with repeatedly pulling leaves out of the drains.
Maria mentioned she would report to the relevant department.

Q6: There was a report of a dangerous dog in Lloyd Park.
Maria said she would work with Fairfield Councillors and the Dog team to deal with.

Q7: There were complaints that the Coombe Farm site in the middle of the park was in poor condition and continued to be an eyesore.
Jason indicated that it was a difficult issue as it is privately owned but was been looked at.

Q8: Jason was asked when there would be full recognition that “wrong had been done” by the previous regime.
Jason talked about the Penn report (on the how of what happened) and the Kroll report (possible illegal actions in the redevelopment of Fairfield Halls) and said they would be published in due course.
It was agreed that the electors had recognised wrong had been done because if not he would not be Mayor.
Lastly Jason pointed out that moist of the current regime’s efforts were trying to help provide better services going forward.

Q9: The cycle lane on the Brighton Road has harming local businesses
Jason and Maria agreed and said it would be looked at.

Q10: What was the Council’s response to the Cost of Living Crisis.
Jason said they were doing what they could but there were not additional C.O.L.C. funds available from the Government.

Jason and Maria and Danielle were thanked for their time and their competent and considerate replies.

Letter Sent to the South Croydon Ward Councillors 13 October 2022 objecting to Melville Avenue turning into a Healthy School Street

October 2022

Dear Michael, Maria and Danielle,

Croydon Council is proposing that Melville Avenue becomes a Healthy School Street and therefore access to non-residents is restricted during school opening and closing times. It is claimed this will make for safer and quieter streets and therefore encouraging more walking and cycling resulting in healthier pupils and better air quality.

I do not believe any of these objectives will be met in any significant way to overcome the inconvenience involved for many of the residents in Melville Avenue and the surrounding streets. This view is shared by many other residents.

Melville Avenue, Castlemaine Avenue and Croham Park Avenue run in parallel between Croham Road and Coombe Road. They are linked via Ballater Road and Binfield Road. My view is that if the scheme goes ahead the vast majority of the traffic that currently enters Melville Avenue will go via Castlemaine Avenue and Croham Park Avenue instead.

Why do we think this? We conducted a survey of the traffic going along Melville Avenue on Thursday the 6th October (attached). Of the traffic in Melville during the proposed restricted periods 239 cars dropped off or picked up pupils with 125 for Old Palace Junior School and 114 for Coombe Wood School. This was out of a total of almost 1,600 journeys – so around 15% of journeys were school drop offs or pick ups. The numbers are below.

Results of Traffic Survey of Melville Av, Castlemaine Av and Croham Park Av on Thursday 6 October 2022. A Term time day with no rail or tube or tram strikes.

Traffing Turning INTO Melville Castlemaine and Croham Park Avenues
 From CoombeFrom CrohamTotal
08:00 – 09:30   
Melville Av0247247
Castlemaine Av20878286
Croham Park Av105185290
14:00 – 16:00   
Melville Av15450204
Castlemaine Av22549274
Croham Park Av148142290
AM + PM   
Melville Av154297451
Castlemaine Av433127560
Croham Park Av253327580
Traffing Turning OUT OF Melville Castlemaine and Croham Park AvenuesIns less Outs
 Into CoombeInto CrohamTotalTotal
08:00 – 09:30    
Melville Av1686223017
Castlemaine Av7519627115
Croham Park Av204101305-15
14:00 – 16:00    
Melville Av24550295-91
Castlemaine Av3019522549
Croham Park Av14312626921
AM + PM    
Melville Av413112525-74
Castlemaine Av10539149664
Croham Park Av3472275746
Notes: The Numbers look consistent : Well done Peter, Helen, Angela and Sharon (and her CPA team) We would ecpect more cars into the network than out AM and for this to reverse PM as teacers and others park AM and then un-park PM The number of cars exiting Melville into Coombe turning right was 67 AM (40%) and 107 PM (45%) The number of drop offs/pick ups outside Coombe wood School was 66 AM and 48 PM The number of drop offs outside Old Palace Junior School was 80 AM / 45 PM, (62 AM / 30 PM from cars going towards Coombe and 18 AM / 15 PM from cars going towards Croham) Only 129 AM / 94 PM of the cars in the network are dropping off or collecting pupils.

Why do we think most of this traffic will divert? There are three reasons for this.

Old Palace School is a private junior school and nursery with a large catchment area. This cannot be ignored. I spoke to a parent who said he came from Shirley with no realistic other way of his daughter getting to school. He said he would have to park either in Castlemaine Avenue or Croham Road or come earlier. I suspect most will.

For Coombe Wood School parents currently driving up Melville, I cannot see that parents dropping off or or picking up in Castlemaine Avenue will be much of a deterrent for them as Castlemaine Avenue is less than 400 yards from the Coombe Wood School gates via Ballater Road and is less than 150 yards to the school gates from its junction with Coombe Road. This latter distance is closer to the school than locations along Melville Avenue where many of the cars dropped off/picked up during the survey.

Lastly all the cars not dropping off will mostly be commuters. This is the majority. Closing Melville Avenue to them will also force the overall majority into Castlemaine Avenue and Croham Park Avenue.

However I agree Melville will be safer. But Melville is already safe – whereas the Castlemaine/Coombe junction is not (as per

Before I go to the downsides, I am interested in what targets you have for sustainable/healthy journeys to school. There were at maximum about 120 pupils dropped off / picked up at Coombe Wood School from Melville. Now that is 120 of around 1,250 pupils so I would say the vast majority of pupils are already choosing either to walk, cycle or use public transport – as the school said they would do when it set up. Well done to all of you at the school. So what is the Council’s target!

Now for the downsides to the scheme. If our survey is representative and our assumptions are correct you are going to increase the traffic in Castlemaine by around 95%. This will increase queuing time whilst exiting Castlemaine Av to greater than currently from Melville and Castlemaine. Therefore your overall intention of improving air quality will not happen.

The other downsides are of course for residents having to arrange permits for themselves and for visiting trades people and helpers whether professional or family. We have many older people and some disabled living in Melville (and Castlemaine Avenue and Croham Park Avenue) who need a multiple of helpers. One said to me this scheme is discriminating against the old and disabled. I agree.

If you want to be sure you will improve the already good sustainable journey percentage for Coombe wood school and to force Old Palace Parents to not drive you should include Castlemaine Avenue. However if you do you have to include Croham Park Avenue as well as traffic will increase there by 180% if all Melville and Castlemaine traffic go through there.

Whilst I applaud the aims of the scheme for our roads based on our experience and our survey numbers – it will not work in its current state. If you are determined to go ahead without Castlemaine and Croham Park Avenue I make two requests:

First you wait until the results of the consultation of the previous trial schemes – which the ended April 2022 – is published.

Second and most importantly please do your own traffic surveys before and during implementation of the trial period on our roads so we can all see your actual results and all be guided by them.

Finally if you insist on bringing in this scheme then I suggest you do not need to make Melville one way as planned as the poor behaviour caused by the small number of parents who reverse and u-turn whilst picking up at present will obviously disappear. Therefore the only remaining people going up Melville from Coombe Road during the restricted times will be the very small number of residents in that part of Melville.

However if you do not bring in this scheme then you can eliminate this poor parent driving by putting a traffic warden outside the school at 15:15. If will undoubtedly be revenue raising.


Jeremy Gill
*** Address ***

Why is Croydon’s housing target so high?

September 2022

Recently I went to the latest six-monthly meeting between the representatives of the local resident associations and Croydon’s Planning Department.  We now have had a few Croydon Council Planning Committee meetings since our Mayor has been elected and the new Committee have been reversing some of the approval decisions by made by the Planning Department so overall we are seeing a reduction in approvals but it is still worth getting an insight into the Planning Department.

Even though Croydon is behind its target for the current ten year planning cycle which started in 2019 (albeit not by much),  many of the reps were complaining that the extra infrastructure needed to support the additional housing already built was not there. The planners told us it was their responsibility to consult with the  infrastructure providers. The ones mentioned repeatedly were  Thames Water, primary school providers, transport providers and the NHS.  However we were told the adequacy of infrastructure could not be a determining factor in making individual planning decisions.

This all seems reasonable enough for individual decisions but you would think that at some point someone would say ” we are already too stretched in that bit of the Borough, we better slow down over there”.  You would think the housing targets by ward would take this into account but the planners say the targets are discretionary and every application is judged on its own merits! Interestingly almost immediately after the meeting three West London Boroughs announced an indefinite  ban on all new approvals due to electricity shortages.  This will be pointed out at our next meeting!

So how do we get to a situation where infrastructure is not keeping up yet we are below target. Is it because our target is so high?

Croydon’s 10-year housing target is 20,790 units (2079 per year).  This is significantly higher than our outer London neighbours with Bromley’s target being 7,740 units (774 per year) and Sutton’s target 4,690 (469 per year).  Looking across London, four boroughs have similar targets.  These are Barnet, Brent, Ealing and Southwark.  Only three have higher targets.  These are Greenwich, Newham and Tower Hamlets. Of these seven boroughs only Barnet like Croydon is an outer London Borough.

So why have Barnet and Croydon been allocated such high targets?  Part of the answer for Croydon is simple. If you look at “The London Plan 2021” page 165, the only outer London area with the highest Public Transport Access Level (which is 6b) is Croydon Town Centre.  So it is planned for a significant majority of the new builds to be built in the centre of Croydon, as we can see happening.  As long as these flats are of sufficient quality to be a credit to Croydon in the future then to me this is good.  Interestingly there is no 6b equivalent for Barnet – a reader might know what they did to be allocated such a target.

However out of our 2,079 target,  640 is for Small Site developments. These are on sites of 1/4 hectare or less ( just over 1/2 an acre or less).  Here Croydon really sticks out.  We have the second highest SS target of 641 per annum – just behind  Hackney with 658.  Even unlucky Barnet does not even come close with 434.  Comparing with our neighbours, Bromley is 379 and Sutton is 268. Whilst the SS targets for Bromley and Sutton are closer to Croydon’s SS target as a percentage compared to the large and small sites target combined, you would initially think that Bromley’s should be higher than ours and Sutton’s smaller than ours based solely on size. I hope you are keeping up.

Here we have to go back again to the maps within the London Plan 2019.  One of the determinants of high SS development is being close to Public Transport Access Level 3-6 or within 800yards of a train tube or tram station or stop. Looking at page 169, all of Croydon above Croydon town centre (except Crystal Palace) is caught by this definition as is a lot of the south as it is along either the Brighton Line, the Caterham Line, the East Grinstead Line or the Tram up to New Addington. Shirley is not designated neither is the area around Sanderstead/Selsdon or the Old Coulsdon area.

Comparing to our neighbours, Sutton is half our size but has the same percentage of SS eligible areas so a target of about half of ours makes sense whereas almost all of Bromley below Bromley town centre is not eligible for high SS development so their target also seems reasonable if access to transport is the main criteria.

The only research I have done to write this article is to look at the London Plan 2019. I am sure there is more to this than meets the eye (Barnet again!) but our target looks reasonable given the criteria which again seems reasonable 

Also this does not answer the infrastructure issue and whether the recent SS development is within the 800m from transport but might explain one factor in the Planning Department recommending the recent development in The Gallop.  By my calculations  as  the crow flies parts of the Gallop are within 800m of Coombe Lane Tram Stop.

More implications of all this  to follow.