Friday 29 February 2008


Further to my earlier article about the letter from Berwin Leighton Paisner (Arrowcroft's lawyers), informing me that the Secretary of State had extended the deadline for making representations in respect of Arrowcroft's further environmental submission from 15 February to 17 March.

It seems that Berwin Leighton Paisner have made a "snafu" in their letter. They refer to the revised deadline (17 March) twice. However, in the final paragraph in bold print they state:

"If you wish to make any representations on the further environmental information you should do so in writing to the Planning Inspectorate...before 15 February 2008..."

The 15th of February is of course the original deadline for submissions, and ten days before the date of the letter sent out by Berwin Leighton Paisner.

It seems that Berwin Leighton Paisner are prone to making errors and mistakes.

The question is, have they made any other errors and mistakes?

Thursday 28 February 2008

Letter To Hazel Blears

Submitted to Hazel Blears today:

"Right Honourable Hazel Blears MP
The Secretary of State for Communities and Local Government Planning Division
Government Office for London
9th Floor, Riverwalk House
157-161 Millbank
LondonSW1P 4RR

28 February 2008

Dear Ms Blears,

Subject London Borough of Croydon (Gateway Site) Compulsory Purchase Order 2007

I have received a letter (dated 25 February 2008) from Berwin Leighton Paisner, solicitors for Arrowcroft Ltd, in respect of Arrowcroft’s further environmental information submitted to you on 24 January 2008. They state that the deadline for submitting objections to Arrowcroft’s revised/new data has been extended to 17 March 2008.

I wish to formally object that, despite the fact that the public inquiry into the CPO has officially ended, Arrowcroft are still being allowed to submit revised/altered information:

· This is outwith the time limit of the inquiry

· It is my, and indeed many other residents’, understanding that once the inquiry ended no further information could/should be submitted

· Berwin Leighton Paisner, Arrowcroft’s solicitors, are seemingly setting the timetable and deadlines for objections

· Berwin Leighton Paisner, and by definition Arrowcroft, appear to be acting on your behalf

· The additional information being submitted after the end of the inquiry, and onus to object to it, is confusing to the residents of Croydon (myself included) who are negatively impacted by Arrowcroft’s plans. We have no specific legal expertise, and trust you to act impartially.

I have the following questions:

1. Who is running this inquiry, you or Arrowcroft?

2. Given the ongoing bombardment of information and changes by Arrowcroft, how can lay people possibly keep track or indeed understand what is happening?

3. Given the ongoing changes of information and revised deadlines for objections, how can we possibly keep track of the process that is being followed by you in trying to come to a decision wrt the CPO?

4. Has the application been altered?

5. Why is Arrowcroft being allowed to set the deadlines?

In my opinion the independence and impartiality of the inquiry is being severely, and openly, compromised by Arrowcroft’s and Berwin Leighton Paisner’s actions.

I look forward to hearing from you.

Thank you in advance.

Yours sincerely,


Croydon Against The Arena

cc Deborah Tobin – Planning Inspectorate
Andrew Pelling MP

Wednesday 27 February 2008

Deadline Extended

Berwin Leighton Paisner LLP (Arrowcroft's lawyers) have written to me, and other objectors to the Arena, to advise that the Secretary of State has extended the deadline for making representations wrt Arrowcroft's additional environmental information (submitted 25th January) to the 17th of March.

Monday 18 February 2008

The Theatres Trust

15 February 2008
Ms Deborah Tobin
The Planning Inspectorate
4/04 Kite Wing
Temple Quay House
2 The Square
Temple Quay
Bristol BS1 6PN

Dear Ms Tobin,

Town and Country Planning Act 1990 – Section 77 Application by Arrowcroft Limited. Site at land adjoining East Croydon Station, George Street, Dingwell Road and Lansdowne Road, Croydon Application ref: APP/L5240/V/1198485 Town and Country Planning (Environmental Impact Assessment)(England and Wales) Regulations 1999

London Borough of Croydon (Land West of East Croydon Station, the Gateway Site) Compulsory Purchase Order 2007

The Theatres Trust was sent a CD on 25 January 2008 of information which responds to comments and criticisms of the Environmental Statement (dated 2007) made by objectors to the planning application. I am writing to express our concern over proposals for the replacement for the Croydon Warehouse Theatre (WT).

The Theatres Trust is The National Advisory Public Body for Theatres and a statutory consultee on planning applications affecting land on which there is a theatre. This applies to all theatre buildings, old and new, in current use, in other uses, or disused. It was established by The Theatres Trust Act 1976 'to promote the better protection of theatres'. Our main objective is to safeguard theatre use, or the potential for such use, but we also provide expert advice on design, conservation, property and planning matters to theatre operators, local authorities and official bodies.

The Theatres Trust has no confidence in the additional information supplied following the Public Inquiry and does not consider that the proposals put forward guarantee a proper replacement for the Croydon Warehouse Theatre. The referred plans are inadequate in that there are no existing and proposed sections or plans for the theatre and therefore it is difficult to assess the integral design or whether the theatre will be fit for purpose. Theatres are very complex buildings technically and do need to be very carefully planned both inside and out. Furthermore, we would need to be certain that safeguards are in place to secure the sustainability of the theatre set out in a Section 106 Agreement.

We are deeply concerned about the suggestion on page 39 (S12.5 P12.51) of WSP's Response that 'the relocation of the WT will be dependant on agreeing lease terms and Theatre to relocate, fit out and operate a replacement theatre and the production of a business plan demonstrating to Arrowcroft's satisfaction that would be able to operate a theatre within the development on a viable basis.' This clause would make the prospect of the Warehouse Theatre moving to new premises virtually impossible.

The Warehouse Theatre or indeed any other theatre operator would never be able to prove that such a business would be viable particularly where additional capital money would be required for fit-out. Small independent theatre companies have very tight margins and work for the cultural benefit of the local community. They rely on public funding from bodies such as the Art Council Lottery Fund, the Heritage Lottery Fund, The Big Lottery, the RDA or the local authority. Funders require evidence of need to be demonstrated by catchment and competition analysis, public benefit, social, economic and environmental impact, and evidence that stakeholders' views have been taken on board through consultation.

Furthermore we note that a separate application for the Warehouse Theatre would be required and that it is only Arrowcroft who have to be satisfied that the theatre can operate on a viable basis. With so many indeterminable outcomes the Trust fails to see how a replacement theatre would meet conditions as required by Arrowcroft. In addition Arrowcroft appears to put all the risk onto the theatre but does not accept any responsibility or offer any compensation for the environmental or operational conditions that would be imposed by its development and which would adversely affect the delivery of a viable business plan.

Without clear plans planning permission and fair provisions with a Section 106 The Theatres Trust continues to oppose the application.

Yours sincerely,

Mark J Price
Planning and Architecture Adviser

The Theatres Trust is the National Advisory Public Body for Theatres, protecting theatres for everyone.

A list of the trustees can be viewed here.

Friday 15 February 2008

Canning and Clyde Road Residents Association

Attention: Deborah Tobin
The Planning Inspectorate
4/04 Kite Wing
Temple Quay House
2 The Square
Temple Quay
13 February 2008

Dear Ms Tobin

APP / L52040 / V / 06 / 1198485
Application by Arrowcroft Limited in respect of a proposed development at land adjoining East Croydon Station
Notice of Submission of Further Information to an Environmental Statement

We have been informed by Berwin Leighton Paisner that we have an opportunity to comment upon the Further Information to an Environmental Statement for the important East Croydon Gateway site. As before, we are sending this objection on behalf of Park Hill Residents Association, Morland Park Residents Association, H.O.M.E. Residents Association and our own Association. This represents over 4,000 households in the vicinity of the proposed development. We are aware of strong opposition to the applicant’s scheme by other residents who do not have the representation of an association.

Our comments in this letter do not repeat anything we said in our letter of 11 August 2007 with reference to the Planning Application nor anything in the Canning & Clyde Road Residents Association letter of 18 August with reference to the Compulsory Purchase Order. We would ask that the comments in all three letters and supporting documentation be taken into account by the Inspector and Secretary of State.

Our comments are restricted to the Transport Assessment and Crowd Management Strategy sections of the revised statement.

1. Transport Assessment

1.1 The revised Transport Assessment states that the mass transport system has enough spare capacity to accommodate the peak hour of patrons arriving at East Croydon for an event at the Arena on a Monday to Friday. It only shows that there is spare capacity on trams from Wellesley and Lebanon Gardens or on trains from South Croydon, Selhurst and Norwood Junction. This is not adequate. The Transport Assessment needs to demonstrate that the transport system has spare capacity for the whole of the journey that is required to be made. In the evening peak hour there is no or very little spare capacity on trains leaving Clapham Junction for East Croydon or on trams from Wimbledon. This means that the usable spare capacity available for Arena patrons on trains from

Clapham Junction and trams from Wimbledon has been substantially overstated and indicates a need to increase train and tram services. It is our understanding that there is no spare track capacity to increase train services or trams available to increase tram services.

1.2 Patrons arriving for evening events at the Arena by car will be travelling into Croydon at a time when the main travel demand is out of Croydon. Most roads, except those such as the Mitcham Road, where peak travel demand is similar in both directions, will have some spare capacity but traffic congestion will be increased at junctions such as Purley Cross, Lombard Roundabout and Fiveways. Congestion at junctions has only been considered in the immediate vicinity of East Croydon but the impact of the Arena may be more serious on certain junctions further afield. This issue needs to be considered.

1.3 There is no comparison for door-to-door journey time between car and mass transport (if available) for homeward journeys after 2300 hours and no evidence that there is adequate spare capacity on all southbound trains after 2300 hours on a Friday night to demonstrate that mass transport is a reasonable alternative to the car.

Arena patrons are likely to want to get home without having to hang around too long and therefore leave en masse. There are likely to be severe capacity problems in and around East Croydon Station as people leave.

The simultaneous egress of large numbers of cars from any car park will be a slow, noisy and polluting process. It may well deter motorists from using the car parks again on their next visit to the Arena and will encourage them to park in surrounding roads instead.

After customers to public transport have queued and been subjected to stewards with loudhailers it may well make the use of cars seem more appealing for a subsequent visit.

1.4 The distribution of arrivals by time and the modal split for patrons arriving for events at the Arena are all based on those found at the inner suburban O2 Arena. There is no evidence provided to show that these distributions are valid for Croydon. The overstatement of capacity available for Arena patrons arriving by tram and train indicated in para 1.1 above indicates that the proportion arriving by car is likely to be understated.

Should evening events at the Arena cause mass transport to overload or the road network to gridlock, the prosperity of the town centre will be jeopardised together with the attractiveness of the town as a residential location.

The developer assumes that parking restrictions will be enforced (against fierce local opposition) on surrounding roads and that patrons arriving by car will park in designated car parks as this will prove cheaper. The car parks mentioned are all privately owned and the Council has no control over the pricing. The Council only controls four very small car parks in Central Croydon.

The Fairfield car park is as close as the Allders and Whitgift car parks, with better pedestrian links (i.e. avoiding subways) and more readily accessible by vehicles from the A232. There is nothing more quickly guaranteed to kill Fairfield than to deprive the car borne audience space in the underground car park which is both (relatively) safe and convenient; why should the existing audience be shunted off to somewhere else? The reverse policy should apply (i.e. very high parking charges unless one is a Fairfield/Ashcroft patron).

1.5 The responsibility for procuring an adequate train service lies with the Department of Transport. The Southern Railway does not have grounds to object as their franchise expires in 2009 which is before the Arena can open (para 18.7.27).

1.6 As the tram stops are outside the station, patrons leaving Arena events may well choose to access them along Dingwall Road. There would need to be crowd management on Dingwall Road, as non-Arena bus passengers for routes which stop in Dingwall Road would then prefer to use Dingwall Road stops rather than East Croydon Interchange stops to reduce the risk of being left behind.

2. Crowd Management Strategy

2.1 The Crowd Management Strategy only defines responsibilities. It does not give any indication of the controls needed to facilitate the free movement of buses and trams along Dingwall Road and over East Croydon bridge when patrons leave an event at the Arena.

2.2 The author of the Croydon Management Strategy does not appear to be familiar with East Croydon Station and its surroundings. All three island platforms can be, and are, served by both northbound and southbound trains so segregation of patrons into northbound and southbound is not practical.

2.3 The tram stops are outside the station which means that people wishing to reach them would use Dingwall Road.

2.4 There are normally queues for buses and taxis at East Croydon Station in the late evening even when bus and train services are running well. Further crowding is liable to occur when services are disrupted.

2.5 In 6.1.1 a pedestrian travel time of approximately 3.5 minutes indicates too short a time for any significant crowd dispersal of thousands of pedestrians. Only a much longer walk than this would work.

2.6 There is no mention of how the co-ordination is to take place of the control of customers into the Station using the exit ramp from the Plaza with those using the main entrance into East Croydon Station.

2.7 There is no mention of crowd control for those congregating to await coaches at the end of an event.

2.8 The developer does not consider pedestrian noise (with or without ‘binge drinking’) outside the immediate site. No account is taken of people returning to their cars in residential streets late at night.

2.9 Showsec state that the Police will be responsible for the crowd outside the Arena site. Has anyone asked the Police if they have sufficient resources to do this? Who will meet the cost?

Finally we note that many of the developer’s submissions of material for the Planning Inquiry have been late and have had to be revised when challenged.

Yours sincerely

Anne Bridge
Secretary, Canning and Clyde Road Residents Association

Also on behalf of Park Hill Residents Association, Morland Park Residents Association, H.O.M.E Residents Association and the Croydon Transport Focus Group