# 3 High Street, South Norwood, Croydon

- **Decision:** dismissed, 3 September 2026
- **Decided by:** Planning Inspector: P D Sedgwick
- **Authority:** Croydon (London)
- **Appeal reference:** 6011471
- **Application reference:** 25/02346/FUL
- **Procedure:** written-representations
- **Development:** First and second floor rear extension with rear dormer to create 2 one-bed flats, plus detached pharmacy storage outbuilding
- **Homes:** 2
- **Site context:** inside-settlement, conservation-area
- **Green Belt:** no
- **Framework applied:** August 2026 NPPF
- **Determinative policies:** HE6(4), P3(2)(b), TR6(4)
- **Development plan policies:** London Plan 2021 D3, D4, HC1, T4, T6, Croydon Local Plan 2018 SP4, SP8, DM10, DM18, DM29, DM30, South Norwood CAAMP SPD 2022
- **Main issues:** conservation area, living conditions, parking and highway safety
- **Tags:** conservation-area, old-heritage-wording, old-wording-slip, transitional-no-consultation, small-scheme, heritage-harm-decisive

## Summary
Upward and rear extension to create two flats above a pharmacy in the South Norwood CA. Dismissed on three grounds: CA appearance, the neighbour's light and outlook, and parking in the absence of a signed car-free obligation. The letter treats the 2026 Framework as materially the same as 2024 and uses 2024 language throughout: "less than substantial" and "significantly and demonstrably outweigh".

## Issues and findings
- **Transition.** "The wording of the relevant paragraphs of the new Framework are similar to that of the 2024 version", so no consultation (DL ¶2).
- **Heritage.** "The harm would be localised and less than substantial" (DL ¶7). "Any harm to a designated heritage asset is a matter of considerable weight requiring justification and, in accordance with the Framework, I must weigh the harm against the public benefits" (DL ¶14). The "considerable" weight matches HE6(3).
- **Living conditions: FAIL.** "tunnelling effect and sense of enclosure … overbearing presence" to the neighbour's kitchen window (DL ¶9).
- **Parking: FAIL.** No signed car-free UU despite PTAL 5 (DL ¶¶12–13).

## Planning balance
Benefits of two flats, effective use of land, jobs and pharmacy storage were collectively given "considerable weight". But the harms "would significantly and demonstrably outweigh the benefits, when assessed against the policies in the Framework taken as a whole" (DL ¶15). That is the 2024 ¶11(d) formula, not S4's "substantially outweighed".

## What made the difference
A roof form that broke the uniformity of a positive terrace, harm to a specific neighbouring window, and the lack of a signed car-free deed. Any one of these might have been curable.

## Transferable points
- Inspectors are still using "less than substantial" for CA harm after 17 August 2026 (DL ¶7), paired with HE6(3)-style "considerable weight" (DL ¶14).
- Old tilted-balance wording persists in within-settlement cases where S4(1) should apply (DL ¶15).
- Car-free development in a high-PTAL area still needs a signed obligation at appeal (DL ¶12).

## Policy findings
- **HE6(4): fail (considerable weight).** crown-roofed extension above eaves breaks terrace uniformity — "localised and less than substantial" harm to CA appearance; "considerable weight requiring justification" (DL 5-7, 14)
- **P3(2)(b): fail.** 5m-deep first-floor projection 1.5m from neighbour's kitchen window — tunnelling, loss of afternoon light (DL 8-10)
- **TR6(4): fail.** no signed car-free s106 in PTAL 5 area with saturated parking — congestion and highway harm (DL 11-13)
- **HO7: benefit (considerable weight).** collective benefits (2 flats, effective use of land, jobs, pharmacy storage, sedum roof) given considerable weight (DL 15)
- **S4(1): fail.** balance expressed in 2024 words — harms "would significantly and demonstrably outweigh the benefits" (DL 15)

## Key facts
- Terrace identified as a positive contributor in the 2022 CAAMP; guidance limits rear extensions to one storey lower and 3m deep
- Appellant willing to sign a car-free s106 but no signed deed provided

## Sources
- https://appeal-planning-decision.service.gov.uk/published-document/17e3ae88-40f4-4666-9186-c9f80d15ee98
- https://appeal-planning-decision.service.gov.uk/comment-planning-appeal/appeals/6011471

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Source: https://planningdistilled.org/research/england/nppf-navigator/decisions/PINS-6011471.html

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