Bromley Unitary Development Plan

Proof of Philip Kolvin

Crystal Palace Park

Crystal Palace Campaign

Section 19

We want parks and green spaces to meet people's needs today while preserving their historical and cultural importance.

Urban Green Spaces Taskforce[118]


The National Sports Centre objection (objection refs. 0296U and 20075E, 20084E, 20062F and 20084F)


Objections have been lodged to the designation of the Sports Centre as a Major Developed Site and to the extent of the perimeter. The Council has not provided any justification for the designation in its reasoned responses, but has added text in paragraph 8.18a of the Second Deposit Draft.


The objection should not be overstated. There is an objection in principle to the notion of Major Developed Sites within Metropolitan Open Land. However, since development in MDS is contingent upon satisfaction of the criteria in PPG2 Annex C, it is not thought that that objection could survive a sensitively designed scheme, or indeed a properly delineated and worded proposal. But the delineation is liberal and the wording infelicitous.


The first concern is that Bromley has drawn the perimeter of the designated MDS very widely indeed, presumably, once again, in the interests of "flexibility." I am told by Bromley that the area of the MDS is 16.8 hectares.


Secondly, the Campaign has tried on many occasions to secure for the community some consultation or involvement in ideas for regenerating the Sports Centre, but it has been largely unsuccessful. It has always been hard to understand why Bromley would not wish to involve the community in this exercise, which involves the regeneration of what is essentially a community and regional facility, which acts as a national facility usually only once a year. This has bred an uncertainty and suspicion as to the future plans. Paragraph 8.18a states that the Council wishes to act in partnership: however this has been belied in its actions over the last 6 years in relation to the Sports Centre. It states that a Planning Brief is to be prepared. One year after that was written, none has been seen.


Therefore, I view the policy options for the UDP as being either to leave the site designated as MOL, so that limited infilling may be permitted, and greater development than that if it can satisfy the test of very special circumstances. Alternatively, if a quasi-MDS status is to be conferred, it should be on the bases a) that the perimeter is drawn around the existing boundary and not some extended line; b) that there is far greater clarity and transparency as to what is proposed; and c) that such proposals are the subject of strict criteria in the UDP itself. The perimeter on the proposals map is drawn so as practically to sever the Park laterally. Furthermore, assurance is required that any proposed redevelopment is purely for sporting purposes, and not an attempt to introduce non-sports uses onto the site.


In the objections to the second deposit draft UDP, I make further textual observations. In relation to paragraph 8.17a, I observe that the text is an unwarranted diminution of Annex C of PPG2. For example, it simply omits that proposed development should not lead to a major increase in the developed proportion of the site. Bromley replies that a general reference to the Annex C criteria is made. So it is, but the error is to refer to some of the criteria specifically but to omit others of importance. Either all of the main criteria should be referred to or none of them.


Similarly, paragraph 8.18a has nothing to say about increasing the built footprint on the site, whereas Annex C makes it clear that this is not generally tolerated: see Annex C para C4(d). The Council's response is that general reference is made, as to which my previous comments apply.

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[118] - Green Spaces, Better Places, Final Report of Urban Green Spaces Taskforce, DTLR 2002.

©Philip Kolvin