A Croydon HMO appeal has allowed a former care home in South Norwood to become a 17-bedroom house in multiple occupation, despite a dispute about on-site parking. Inspector N Bowden granted full planning permission on 9 November 2026 for the conversion at 21 Lancaster Road.
The scheme provides four vehicle parking spaces for a maximum of 17 occupants. Croydon Council had questioned whether that was sufficient, but the Inspector accepted the site’s public transport connections and a completed planning obligation restricting future residents from applying for permits within the local controlled parking zone.
The Croydon HMO appeal is a useful example of how parking evidence, travel options and an enforceable obligation can determine a larger HMO proposal. It does not establish a fixed parking standard for HMOs: the Inspector’s assessment turned on the circumstances of the site and its immediate surroundings.
Why the Croydon HMO appeal was allowed
The appeal concerned the former care home at 21 Lancaster Road in South Norwood, within the London Borough of Croydon. The applicant, Forum Properties Ltd, proposed demolishing an outbuilding, making alterations and changing the existing Class C2 use to a sui generis HMO with 17 bedrooms for no more than 17 people. It was a full application, reference 25/02308/FUL, rather than an application relying on permitted development rights.
Croydon’s refusal originally raised two matters. By the time the Inspector considered the case, a signed unilateral undertaking had addressed the second reason, and the Council confirmed that it no longer pursued it. The single main issue left for the Croydon HMO appeal was whether the development would provide sufficient off-street parking.
The site lies within a controlled parking zone, but close to streets where parking is not controlled. It has a Public Transport Accessibility Level (PTAL) of 3, with an area assessed at PTAL 4 nearby. Shops and other facilities around South Norwood High Street are also accessible. Those features mattered because the Council’s concerns had to be weighed against the realistic alternatives to travelling by car.
Four spaces for a 17-person HMO
The appellant proposed four parking spaces in front of and alongside the building. The evidence suggested that anticipated demand might amount to between five and nine spaces, drawing on local car ownership, census information and experience of HMO residents elsewhere. That meant a shortfall could occur, and the Inspector did not simply dismiss the Council’s concern about existing pressure on nearby streets.
London Plan policy T6 gives a starting point of car-free development in places that are well connected by public transport and applies maximum parking standards. The Inspector noted that neither the London Plan nor Croydon’s local plan specified a particular vehicle parking standard for HMOs. The Croydon HMO appeal therefore required an evidence-based assessment, not a calculation against a fixed HMO ratio.
The Inspector considered that people could use public transport and reach nearby services without a car. Although some overspill parking remained possible, the Inspector found that the four parking spaces are likely to be sufficient
. The decisive balance included the approved parking spaces, local transport choices and the covenant in the completed undertaking preventing residents from applying for controlled-zone parking permits.
The distinction is important. A general assertion that future occupiers probably will not own cars is unlikely to resolve every parking objection. In this Croydon HMO appeal, the Inspector had specific evidence about accessibility, neighbouring streets and an enforceable obligation. Whether the same arrangement would be acceptable elsewhere would depend on the relevant local policies and the quality of the supporting evidence.
Why earlier dismissed appeals did not decide this one
The Council relied on two other local appeal decisions, concerning 21A Central Parade and 127 Bensham Manor Road. Those sites also had parking pressures, controlled parking zones and PTAL 3 ratings. It would have been tempting to treat the earlier dismissals as requiring another refusal, but the Inspector identified material differences between the cases.
According to the decision, the earlier proposals did not appear to include obligations restricting occupiers from applying for controlled-zone permits. The Lancaster Road site was also particularly close to an area with a higher PTAL rating. Those relatively narrow distinctions were sufficient for the Inspector to reach a different conclusion. The Croydon HMO appeal shows why appeal comparisons need a proper account of facts, mitigation and conditions, not just an apparently similar address or use.
Heritage, fire safety and the conditions imposed
The building is locally listed and lies within a conservation area. Those facts required consideration of the heritage context, but no party had raised a substantive objection concerning the effect of the proposed changes on the heritage assets. The Inspector therefore did not undertake a lengthy separate heritage analysis.
The permission includes a limit of 17 residents, a requirement for refuse and cycle facilities shown on the plans, and a fire safety report to be approved before first occupation. The Inspector consulted the appellant about the pre-commencement condition. Conversely, the Inspector declined to impose a management-plan requirement where the Council had not explained what it needed to cover beyond refuse arrangements already addressed.
For anyone considering a similar scheme, our HMO planning permission guide explains why a larger HMO usually needs full planning permission and why the distinction between Class C4 and sui generis accommodation matters. Our HMO planning policies guide also covers the range of considerations councils may apply to individual proposals.
What the Croydon HMO appeal means in practice
The result does not mean that four spaces will always be adequate for 17 HMO occupants. The evidence still suggested some unmet demand. What won the case was the combination of sustainable location, viable transport alternatives, an on-site provision and a completed restriction on controlled parking permits. An appellant who relies on only one of those elements may face a different outcome.
Nor should the change from an existing care home be described as the creation of 17 entirely new homes. The Inspector considered that the scheme largely changed the tenure and form of shared residential occupation, rather than materially increasing the overall amount of accommodation provided in the building. The Inspector noted that new residents would support local shops and services, as the care home use could, and that the conversion works would bring only a small and brief benefit.
Inspector N Bowden allowed the Croydon HMO appeal, reference 6013878, on 9 November 2026, for application 25/02308/FUL. The decision can be read on the Planning Inspectorate appeal page. The appeal decision is also available on AppealBase.
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