111 South Norwood Hill, London, SE25 6DD

111 South Norwood Hill, London, SE25 6DD — London Borough of Croydon — Appeal Decision Site visit made on 13 February 2024 by M Cryan BA(Hons) DipTP MSc MRTPI an Inspector appointed by the Secretary of State Decision date: 03 JUNE 2024 Appeal Ref: APP/L5240/W/23/3323117 111 South Norwood Hill, London, SE25 6DD • The appeal is made under section 78 of the Town and Country Planning Act 1990 against a refusal to grant planning permission. • The appeal is made by Maia Ltd against the decision of the Council of the London Borough of Croydon. • The application Ref 22/05330/FUL, dated 22 December 2022, was refused by notice dated 9 March 2023. • The development proposed is the demolition of the existing building and the erection of a replacement building comprising six flats with associated landscaping. Decision 1. The appeal is dismissed. Preliminary and Procedural Matters 2. The Government published revised versions of the National Planning Policy Framework (“the Framework”) on 5 September 2023, replacing the July 2021 version extant at the time the application was determined, and again on 19 December 2023. The amendments made did not have any bearing on the main issues in this appeal, and it was not therefore necessary to seek comments from the main parties on them. 3.

111 South Norwood Hill, London, SE25 6DD — London Borough of Croydon — Appeal Decision The decision notice issued by the Council gave seven reasons for which planning permission had been refused. The Council’s appeal statement indicated that the fourth of these (relating to parking permits and the need for a financial contribution to address transport impacts) had been dealt with by the submission of a completed planning obligation, and that the seventh (relating to fire safety) had been addressed by the submission of a fire safety statement, and that it therefore no longer wished to maintain those reasons for refusal. 4. No planning obligation is in fact before me and, in any case, the appellant disputed that a financial contribution in respect of transport impacts would be necessary; the fourth reason for refusal therefore still forms the basis of one of the main issues identified below (though I have combined all highway and parking matters in a single issue). None of the evidence before me, however, indicates that I should take a different stance to the Council on the matter of fire safety; it is not therefore addressed in the main issues. Main Issues 5.

111 South Norwood Hill, London, SE25 6DD — London Borough of Croydon — Appeal Decision The main issues are therefore: • The effect of the proposed development on the character and appearance of the area; https://www.gov.uk/planning-inspectorate

111 South Norwood Hill, London, SE25 6DD — London Borough of Croydon — Appeal Decision The main issues are therefore: • The effect of the proposed development on the character and appearance of the area; https://www.gov.uk/planning-inspectorate Appeal Decision APP/L5240/W/23/3323117 • Whether the proposed development would provide acceptable living conditions for future occupiers, with regard to outlook, accessible communal amenity space, and daylight; • The effect of the proposed development on parking demand and highway safety, and whether it should make a financial contribution towards other transport improvements; • Whether the proposed development would make acceptable provision for the storage and collection of refuse; and • Whether the development would include adequate cycle parking and storage facilities. Reasons Character and appearance 6. No 111 South Norwood Hill is a 1920s detached house on a roughly triangular plot at the junction of South Norwood Hill with Whitehorse Lane. It is divided internally into three self-contained flats. In style and appearance, the existing building is typical of its era; it has a hipped tiled roof with front catslide and inset dormer, a high front gable a projecting front bay window and porch, and is finished in white-painted render with red brick or tile details.

111 South Norwood Hill, London, SE25 6DD — London Borough of Croydon — Appeal Decision The local topography slopes down from north-west to south-east along South Norwood Hill, as a result of which the building is set prominently above the street. 7. The proposed development is the demolition of the existing building, and the erection of a new building comprising six flats across four floors, on a roughly one third larger footprint. The building would be of a flat-roofed design; the lower ground floor would provide a redbrick “base” for the white/pale grey rendered ground and first floors above, while the second floor would be set back from the floors below and finished in darker grey aluminium or zinc cladding. Balconies, and window and door frames would be of bronze-coloured powder coated aluminium. The form and materials proposed would give the new building a distinctly contemporary appearance. 8. The surrounding area is predominantly residential, and features a range of types of housing, of varying scale and materials. However, it appears based on my observations during my site visit that the immediate surrounding area is dominated by detached, semi-detached and short terraced blocks of houses from the interwar period in the first half of the 20th century.

111 South Norwood Hill, London, SE25 6DD — London Borough of Croydon — Appeal Decision The existing property is therefore in many ways typical and illustrative of the character and appearance of the area. Furthermore, the neighbouring houses to the north, Nos 113 and 115 South Norwood Hill are (to all practical intents and purposes, barring some minor cosmetic differences) identical to No 111. 9. The Council describes the appeal property as having “no particular architectural merit”, a statement which considered on its own I would not take issue with. However, Nos 111, 113 and 115 together form a simple, yet pleasing and coherent composition, in a prominent spot. The proposed block of flats would break up this composition, and its flat-roofed form, recessed third floor, and cantilevered balconies would be visually at odds with its more traditionally- styled neighbours. This would be jarring, something made all the more apparent by the building’s elevated position alongside a busy junction. https://www.gov.uk/planning-inspectorate 2

111 South Norwood Hill, London, SE25 6DD — London Borough of Croydon — Appeal Decision Appeal Decision APP/L5240/W/23/3323117 10. The proposed materials would appear, on the face of things, to be of a reasonable quality, and the muted palette of colours selected does not appear to be garish or wildly at odds with those found elsewhere nearby. Notwithstanding the Council’s concerns, I find these aspects of the scheme to be acceptable. However, this would not mitigate the other harm which I have found. 11. The appellant has drawn my attention to the relatively recent development at No 139 South Norwood Hill1, which the submitted Design and Access Statement identifies as a “context precedent” for the appeal scheme. No 139 is a little over 100m or so north-west of the appeal site, and I was able to view that building during my site visit. There are undoubtedly some common threads between the two designs; notably a contemporary flat-roofed,“boxy” (in an entirely neutral sense) design, though No 139 appears simpler in form than the appeal scheme, and with a more limited palette of materials.

111 South Norwood Hill, London, SE25 6DD — London Borough of Croydon — Appeal Decision It is also a bigger building on a larger corner plot, which mean that to some extent it is viewed on its own terms; the appeal scheme, on the other hand, would be seen sandwiched between, and would visually jar with, its neighbours on either side. While I therefore acknowledge the similarities, I do not consider that No 139 sets a precedent that justifies allowing the appeal scheme. 12. I conclude the proposed form and design of the development would make it an intrusive and prominent building, which would be harmful to the character and appearance of the area. The proposal therefore conflicts with Policies SP4 and DM10 of the 2018 Croydon Local Plan (“the CLP”), and Policies D3 and D4 of the London Plan 2021. Together, and among other things, these policies seek to ensure that development is of a high quality, and respects the development pattern, layout and appearance, materials and built features of the surrounding area. Living conditions 13. The development would provide two three-bedroom and two one-bedroom flats (one of each on each of the ground and first floors), and two two-bedroom flats (one on the lower ground floor, one on the second floor). 14.

111 South Norwood Hill, London, SE25 6DD — London Borough of Croydon — Appeal Decision The principal windows of the habitable rooms of Apartment 1, on the lower ground floor, would be on the north-east facing front elevation towards South Norwood Hill (Bedroom 2 would also have a second high-level window on the south-east facing side elevation, and the lounge/kitchen would have a large L- shaped window or door opening onto a terrace). The submitted drawings show the external ground level to be between around 0.8m and 1.15m above that of the terrace, which would be bounded by a retaining wall. At around 1.2m, the retaining wall would not be tall in itself, but in combination with the overhanging balconies of Apartments 2 and 3 on the floor above, it would mean that the windows of the habitable rooms within Apartment 1 would offer a somewhat constrained outlook. 15. The six flats would each have one or two balconies or terraces, and as a result all would least meet the minimum private amenity space requirement set out in Policy DM10.4 of the CLP and Policy D6 of the London Plan 2021. There would also be 95m2 of communal garden space (including a 30m2 play space for 1 LPA Ref: 17/00265/FUL https://www.gov.uk/planning-inspectorate 3

111 South Norwood Hill, London, SE25 6DD — London Borough of Croydon — Appeal Decision Appeal Decision APP/L5240/W/23/3323117 children) at the rear of the building, which would be accessed via external steps at the side of the building. 16. Policy D7 of the London Plan 2021 requires that at least 10 percent of dwellings2 meet Building Regulation requirement M4(3) wheelchair user dwellings, and that all other dwellings2 meet Building Regulation requirement M4(2) accessible and adaptable dwellings. Approved Document M3 states that “optional requirement M4(2) will be met where a new dwelling makes reasonable provision for most people to access the dwelling and incorporates features that make it potentially suitable for a wide range of occupants, including older people, those with reduced mobility and some wheelchair users”. It goes on to add that this includes, within the curtilage of the dwelling or of the building containing the dwelling, “step free access to the dwelling and to any associated parking space and communal facilities intended for the occupants to use”. The stepped access to the communal garden would not comply with this standard. 17.

111 South Norwood Hill, London, SE25 6DD — London Borough of Croydon — Appeal Decision There is no development plan requirement to provide communal open space (other than play space) in this case, and I recognise that the sloping topography of the site may make meeting the accessible and adaptable dwellings standard challenging so far as external spaces are concerned. However, while I accept that some cases (for example, where retained existing buildings are to be altered or extended) may warrant flexibility on this point, none of the evidence before me convincingly justifies applying the same flexibility in this situation, where the site is effectively being comprehensively redeveloped. As a result of the failure to provide accessible and adaptable housing, including access to shared gardens, the development would not be able to meet the lifetime needs of future occupiers. 18. All six flats would provide adequate amounts living space for future occupiers, meeting or exceeding the minimum floorspace requirements set out in the development plan.

111 South Norwood Hill, London, SE25 6DD — London Borough of Croydon — Appeal Decision I also note that the Council was initially of the view that the second bedrooms in both Apartment 3 (ground floor) and Apartment 5 (first floor) would not receive adequate daylight, but on the basis of an additional daylight analysis submitted during the appeal considered the matter addressed satisfactorily; none of the evidence before me leads me to a different view on this point. That the development would be acceptable in these respects would not mitigate the other harm I have found on this main issue. 19. The submitted drawings suggest that the rooms within Apartment 1 might also be susceptible to a degree of overlooking and would therefore lack the expected degree of privacy. Passers-by on the footway of South Norwood Hill would be at a higher level and could possibly see down into those rooms4. I have not sought further comment on this point from the main parties, however, as given my other findings it could not alter my overall conclusion. 20. I therefore conclude that, because of the constrained outlook from Apartment 1, and the lack of access for all to the communal garden, the development would not provide acceptable living conditions for future occupiers.

111 South Norwood Hill, London, SE25 6DD — London Borough of Croydon — Appeal Decision The proposal would therefore conflict with Policies SP2.8, SP4.1 and DM10 of the CLP, and with Policies D3, D6 and D7 of the London Plan 2021. 2 “…Which are created via works to which Part M volume 1 of the Building Regulations applies…” 3 https://www.gov.uk/government/publications/access-to-and-use-of-buildings-approved-document-m 4 As shown in Drawing 21805 P 108 Rev: A “East (Front) Elevation https://www.gov.uk/planning-inspectorate 4

111 South Norwood Hill, London, SE25 6DD — London Borough of Croydon — Appeal Decision The proposal would therefore conflict with Policies SP2.8, SP4.1 and DM10 of the CLP, and with Policies D3, D6 and D7 of the London Plan 2021. 2 “…Which are created via works to which Part M volume 1 of the Building Regulations applies…” 3 https://www.gov.uk/government/publications/access-to-and-use-of-buildings-approved-document-m 4 As shown in Drawing 21805 P 108 Rev: A “East (Front) Elevation https://www.gov.uk/planning-inspectorate 4

111 South Norwood Hill, London, SE25 6DD — London Borough of Croydon — Appeal Decision Appeal Decision APP/L5240/W/23/3323117 Together, and among other things, these policies seek to ensure that all development is of a well-designed, contributes to the creation of sustainable communities, provides high-quality accessible outdoor amenity space, and meets the needs of residents over a lifetime (including by applying optional requirements M4(2) and M4(3) of the Building Regulations. Parking, highways and transport Parking 21. The appeal site has a Public Transport Accessibility Level (“PTAL”) of 2, which the Council describes as poor public transport connectivity. The submitted Transport Technical Note (“the TTN”) notes that Norwood Junction railway station is approximately a 1km walk from the site, just over the 960m walking distance taken into account in the PTAL assessment, and that part of the site is within an area with a PTAL of 3; it therefore suggests that the PTAL score “underplays the true accessibility of the site”. Nevertheless, the PTAL assessment provides an objective rating of the site’s public transport accessibility as required by the development plan. 22.

111 South Norwood Hill, London, SE25 6DD — London Borough of Croydon — Appeal Decision While there are bus stops close to the site, given the overall level of public transport provision it is likely that many future occupants of the development would want to have access to a car for various purposes. Policy T6.1 of the London Plan 2021 sets out residential parking standards and, for the mix of dwellings proposed in a part of outer London with a PTAL of 2 (or 3, for that matter) it requires a maximum of five spaces. The proposed development would not provide any off-street parking. 23. The Council considers a parking level of 85% or higher to be an indicator of parking stress. The TTN submitted with the appeal scheme included a parking survey, prepared using the “Lambeth Methodology”, which found an average of 82% of spaces occupied overnight, which would suggest that the area has the capacity – though not by a wide margin – to meet the demand for on-street parking arising from the development. However, the surveys were carried out on Wednesday 13 and Thursday 14 July 2022.

111 South Norwood Hill, London, SE25 6DD — London Borough of Croydon — Appeal Decision This was the week before summer term ended for Croydon’s local authority schools (on Friday 22 July 2022), contrary to the Lambeth guidance5 that “surveys should not be undertaken in weeks that include Public Holidays and school holidays, and it is advised that weeks preceding and following holidays should also be avoided”. The Council also commented that surveys “were undertaken when private schools were closed”, which is likely given the generally longer summer holidays in such schools. 24. I cannot, of course, be sure of the combined impact this would have had on parking demand in the area, but it seems certain that at least some households would have been away on holiday at the time and the survey results would therefore have been lower than would “normally” be expected. 25. Since September 2022 the Council has adopted and specified the Richmond methodology for parking surveys. The precise differences between the two methodologies, and what might have been the practical implications of using one rather than the other in this case, have not been explained to me.

111 South Norwood Hill, London, SE25 6DD — London Borough of Croydon — Appeal Decision However, for the reasons I have just set out there is a real risk that the TTN 5 https://www.lambeth.gov.uk/sites/default/files/2021-10/lambeth-parking-survey-guidance-2021.pdf https://www.gov.uk/planning-inspectorate 5

111 South Norwood Hill, London, SE25 6DD — London Borough of Croydon — Appeal Decision However, for the reasons I have just set out there is a real risk that the TTN 5 https://www.lambeth.gov.uk/sites/default/files/2021-10/lambeth-parking-survey-guidance-2021.pdf https://www.gov.uk/planning-inspectorate 5

111 South Norwood Hill, London, SE25 6DD — London Borough of Croydon — Appeal Decision Appeal Decision APP/L5240/W/23/3323117 has understated the position. Given how close parking demand in the area appears to be to the 85% stress threshold, an increased demand for parking, even from a relatively small number of additional dwellings, would be likely to increase parking pressure within the area. It would therefore be appropriate to carry out a parking survey in line with the current guidance. 26. The junction of South Norwood Hill and Whitehorse Lane is controlled by traffic signals and has “no waiting at any time” restrictions. The site is not within a controlled parking zone (“CPZ”), although parking restrictions apply south-west of the appeal site (including on Whitehorse Lane) on days when there are football matches or other events at Selhurst Park stadium. Much of the area around the site nevertheless has unrestricted on-street parking. During my site visit I noticed that few spaces were available very close to the appeal site, though there were some further up South Norwood Hill and on side streets.

111 South Norwood Hill, London, SE25 6DD — London Borough of Croydon — Appeal Decision My visit took place at mid-afternoon on a weekday, at a time when many people might be at work or doing the “school run”; there would be likely to have been many fewer spaces available in the evening or during the weekend. Overall, my observations support the view that the area is one with a high level of parking demand. 27. As the appeal site is not within a CPZ, for the moment the development’s intended “car-free” status could not be secured. Both main parties have referred to a planning obligation which would restrict the ability of future occupiers to obtain parking permits for any future CPZ. Given the on-street parking situation I have just described, it seems to me that such a measure would prevent parking stress in the area being exacerbated in the future. However, no completed planning obligation has been provided to me. 28. To conclude on this matter, there are shortcomings in the submitted parking survey, which mean that it has not been demonstrated that the development would have an acceptable effect on parking availability. There is also no means of preventing an unacceptable increase in demand for on-street car parking.

111 South Norwood Hill, London, SE25 6DD — London Borough of Croydon — Appeal Decision The proposal would therefore conflict with Policies SP8, DM29 and DM30 of the CLP, and Policies T6 and T7 of the London Plan 2021. Together, and among other things, these policies seek to support the use of sustainable means of transport, and to reduce the impact of traffic congestion and car parking. Other transport and highways issues 29. The Council’s officer report also referred to the width of the site access and the potential for motorcycles to be parked within the forecourt where they may cause an obstruction (slightly oddly, this was referred to specifically in the context of refuse collections). However, regardless of the width of the site access, there is nothing before me to suggest either that this would be a significant issue, or that it is anything which could and should be dealt with as anything other than an issue for the managers of the development. It is not therefore a factor which in itself weighs against the proposal. 30.

111 South Norwood Hill, London, SE25 6DD — London Borough of Croydon — Appeal Decision Policies SP8, DM29 and DM30 of the CLP, and Policies T4 and T6.1 of the London Plan 2021 seek to promote development which, among other things, makes full use of public transport, cycling and walking; does not have a detrimental impact on highway safety for pedestrians, cyclists, public transport users and private vehicles; and reduces the impact of car parking. The development plan also recognise that financial contributions may be required to address adverse transport impacts which have been identified. I understand https://www.gov.uk/planning-inspectorate 6

111 South Norwood Hill, London, SE25 6DD — London Borough of Croydon — Appeal Decision Policies SP8, DM29 and DM30 of the CLP, and Policies T4 and T6.1 of the London Plan 2021 seek to promote development which, among other things, makes full use of public transport, cycling and walking; does not have a detrimental impact on highway safety for pedestrians, cyclists, public transport users and private vehicles; and reduces the impact of car parking. The development plan also recognise that financial contributions may be required to address adverse transport impacts which have been identified. I understand https://www.gov.uk/planning-inspectorate 6

111 South Norwood Hill, London, SE25 6DD — London Borough of Croydon — Appeal Decision Appeal Decision APP/L5240/W/23/3323117 that the planning obligation which has been prepared also provides for a financial contribution of £1,500 per unit towards sustainable transport improvements, though the appellant disputes that this is necessary (and, again, I note that the completed obligation has not been provided to me). 31. The Council’s officer report does not explain how the level of contribution sought has been calculated. The internal planning application consultation response from the Council’s transportation team refers to funding “improvements to sustainable transport including but not limited to on street car clubs with EVCP's as well as EVCP's in general as per policies in the Local Plan”, but there is no detailed evidence to show how and where contributions would be spent. Accordingly, I cannot be certain that the contributions sought would be necessary to make the development acceptable or that they would be directly related to the development, and fairly and reasonably related in scale and kind. 32.

111 South Norwood Hill, London, SE25 6DD — London Borough of Croydon — Appeal Decision Consequently, and notwithstanding the aims of the development plan policies, I am unable to conclude that a planning obligation seeking to provide these contributions would comply with Regulation 122 of the Community Infrastructure Levy Regulations 2010. In these circumstances, the absence of a planning obligation does not weigh against the development. Refuse facilities 33. The proposed development would include a dedicated bin storeroom on the lower ground floor of the building, measuring around 17m2; the submitted drawings show this accommodating 12 bins in total, two each per flat (one for general waste, one for dry recycling). The bin store would have its own external access door, with an acceptably-level walking route to the collection area. There would also be a dedicated 10m2 area for bulky goods on the forecourt. The Council’s officer report suggested that fewer, but larger bins (presumably therefore requiring sharing between flats) should be provided, and that an agreed refuse management plan would be necessary to ensure that the bins were taken to, and returned from, the collection point at the appropriate times. 34.

111 South Norwood Hill, London, SE25 6DD — London Borough of Croydon — Appeal Decision I note the appellant’s comment that the “fewer, larger bins” suggestion would not be appropriate given the width of the footway in front of the site, and the presence of railings which would limit the manoeuvring of larger bins to the collection vehicle. However, this is a relatively minor bone of contention between the main parties, and at odds with what (on my reading) is suggested about larger bins in the relevant section of the TTN. I am satisfied that this could be resolved, and the necessary refuse management plan secured, by means of an appropriately-worded condition, were the proposal acceptable in all other respects. 35. Subject to such a condition, I am satisfied that the proposed development would make acceptable provision for the storage and collection of refuse. It would therefore comply in these respects with Policy DM13 of the CLP, and Policy T7 of the London Plan 2021; together these policies seek to ensure that refuse and recycling facilities are safe, sensitively and conveniently located, and easily accessible. https://www.gov.uk/planning-inspectorate 7

111 South Norwood Hill, London, SE25 6DD — London Borough of Croydon — Appeal Decision Appeal Decision APP/L5240/W/23/3323117 Cycle facilities 36. There would be a dedicated cycle storeroom on the lower ground floor, with seven Sheffield stands providing storage for up to 14 cycles. There would be two further Sheffield stands outside the building for visitors. Access to the cycle store from outside would be via the main entrance door to the building and an inner door. It is intended that both doors would be power-operated, and both would appear to comply with the minimum 1.2m width sought by the London Cycling Design Standards, so this would not be an unacceptably inconvenient arrangement for residents. Although the door to the storeroom would be within the stairwell, the submitted section drawing suggests to me that the staircase would not significantly obstruct the doorway. 37. The cycle store would provide more than the minimum 11 cycle spaces for residents sought by the development plan.

111 South Norwood Hill, London, SE25 6DD — London Borough of Croydon — Appeal Decision Given the Council’s concerns about whether wider or adapted bikes could be accommodated, and the limited space around two of the Sheffield stands, it would seem sensible to allow for some reconfiguration of the cycle parking provision, including the provision of charging points for electric cycles within the store (given the hilly nature, by London standards, of the surrounding area). As with the refuse facilities, these would be relatively minor changes and, were the scheme otherwise acceptable, I am satisfied they could be addressed by a condition. 38. Subject to such a condition, I am satisfied that the scheme would include adequate cycle parking and storage facilities. It would therefore comply with Policy DM30 of the CLP, and Policy T5 of the London Plan 2021, which together seek to create a healthy environment in which people choose to cycle, including by ensuring that adequate safe and secure cycle parking is provided. Other Matters 39. The appellant has referred to a previous grant of planning permission to remodel the existing building (including the construction of a side extension) on the appeal site to create five flats6.

111 South Norwood Hill, London, SE25 6DD — London Borough of Croydon — Appeal Decision All the evidence before me is that that permission has expired without being implemented. Given the changes in national and regional planning policy since that scheme was allowed, including in respect of transport and access, and achieving well-designed and beautiful places, it is far from certain that such a scheme would be approved today. This previous permission therefore carries very limited weight in favour of the appeal scheme, whether as a fallback or precedent. 40. The appellant also states that “the fabric of the existing building is coming to the end of its serviceable life”; specifically it is said that a new roof is required, along with thermal upgrade works. I have no reason to doubt the broad thrust of these comments, though such works are a periodic necessity for almost any building, and they do not amount to a mitigation of the harm I have found or a justification for allowing the scheme. Planning Balance and Conclusion 41. The appeal scheme would provide six new flats, a net gain of three dwellings, at a time when the government is seeking to significantly boost the supply of housing. Given the small scale of the proposal, this is a benefit which carries moderate weight in its favour.

111 South Norwood Hill, London, SE25 6DD — London Borough of Croydon — Appeal Decision 6 LPA Ref: 20/02944/FUL https://www.gov.uk/planning-inspectorate 8

111 South Norwood Hill, London, SE25 6DD — London Borough of Croydon — Appeal Decision 6 LPA Ref: 20/02944/FUL https://www.gov.uk/planning-inspectorate 8 Appeal Decision APP/L5240/W/23/3323117 42. I have found that the development would make acceptable provision for the storage and collection of refuse and recycling, and for the parking and storage of bicycles. I have also found that, in this case, the absence of a mechanism to secure a financial contribution to transport improvements does not weigh against the proposal. 43. However, I have found that the development would be harmful to the character and appearance of the area, and there would be significant shortcomings in terms of living conditions for future occupiers. It has also not been demonstrated that the scheme would have an acceptable effect on parking availability, nor is there a mechanism to secure its long-term car free status. 44. The proposal therefore conflicts with the development plan taken as a whole. There are no material considerations, including those of the Framework, that indicate the proposal should be determined other than in accordance with the development plan. 45. I therefore conclude that the appeal should be dismissed.

111 South Norwood Hill, London, SE25 6DD — London Borough of Croydon — M Cryan Inspector https://www.gov.uk/planning-inspectorate 9