Bromley Unitary Development Plan

Proof of Philip Kolvin

Crystal Palace Park

Crystal Palace Campaign

Section 9

For towns and cities, elements of sustainable development include … creating and protecting green space.

Sustainable Development, The UK Strategy[29]


Open Space Analysis


I have enquired of Bromley whether it has undertaken either an open space or recreational needs assessment. On 16th September 2003, the Planning Assistant, Development Plan, wrote to me, stating:

"The Council has not as yet undertaken an open space or recreational needs assessment."


I find it hard to understand how Bromley is able to defend its decision to remove all open space protection from approximately 5 hectares of such important open space without having undertaken any such assessment. Be that as it may, I have thought it prudent to assist the Inquiry by providing such data as I can on open space provision in this part of London.


In "Green Capital, the Mayor's State of the Environment Report for London"[30], an exercise of mapping London's MOL and Green Belt by borough was performed.[31] It was revealed that Lambeth, Lewisham and Southwark were in the worst ten performing boroughs in terms of their percentage given over to MOL and Green Belt. Lambeth was third worst with 4.3%. Lewisham was seventh worst with 8.5% and Southwark tenth worst with 16.8%. The average was 31.5%. Bromley was, by this measure, the greenest borough because of its huge tracts of Green Belt lying on its southern borders - 7,732 hectares, which is over 20% of the Green Belt in London. This demonstrates very clearly why the loss of a few hectares is not felt acutely in Bromley's town hall, but is felt very acutely in the much less green neighbourhoods surrounding the Park.


Green Capital also showed gains and losses in recreational open space from 1998-2000 by borough. The net loss figures are of a very low order. To lose 5 hectares of recreational open space in one fell swoop, and particularly open space of this policy importance, would be rare, if not unique, in the capital.


All of the boroughs surrounding the Park have identified areas of open space deficiency, based on the criteria drawn up by the London Planning Advisory Committee. However, not all the boroughs have used the same criteria, so objective and comparative analysis is not easy. As may be seen:

  • Croydon has substantial tracts of land all over the borough, including areas near Crystal Palace, which suffer from a local park deficiency.[32]
  • Lambeth is substantially deficient in open space, particularly in the central to southern areas.[33]
  • Bromley has relatively small areas of open space deficiency, based on the standard of more than 400 metres from a local park. There are such areas to the south and east of Crystal Palace.[34]
  • Lewisham has large areas of open space deficiency, including areas just to the north of Crystal Palace Park.[35]
  • Southwark has adopted a fairly sophisticated mapping approach based on the London Open Space Hierarchy developed by the London Planning Advisory Committee. That shows the main deficiencies of open space to be in the north and centre of the borough where access to district parks is concerned, and in the south of the borough where access to local parks is concerned.[36]


In addition to the quantum of green space, it is pertinent to examine the population densities in the area, since the denser the population, the greater the need for green space to alleviate the pressure of urban living. The Office for National Statistics has published data on residential densities in London[37]. The average borough has 4,572 per square kilometre. Lambeth, Southwark and Lewisham have, respectively, 9,947, 8,506 and 7,096 people per square kilometre, making them the fifth, eighth and twelfth densest boroughs in London. Again, this reflects their inner city status. Bromley has the least dense population - 1,972 per hectare, again underlining the differing priorities between the residents of its verdant outer suburbs and the inner city suburbs who are reliant on the Park.


However, perhaps a more surprising statistic is that Lambeth, Southwark and Lewisham are also the fifth, eighth and twelfth densest boroughs in England and Wales.[38] This reflects the fact that the Inner London boroughs are the most densely populated in England and Wales. This re-emphasises the need to provide and maintain green space for their enjoyment.


It is also important to note that the population trends in London are upwards. So, Inner London is projected to increase from 2,765,000 in 2001 to 2,863,000 in 2011 and 2,963,000 in 2021, an overall rise of 7%. Outer London is projected to increase from 4,450,000 in 2001 to 4,607,000 in 2011 and 4,773,000 in 2021, an overall rise of 7.2%.[39] Therefore unless, which seems improbable, the amount of open space actually increases, the pressure on open space will increase.


It is possible to carry out a more sensitive analysis on a borough basis.

Table 1: Population changes in the five boroughs.[40]


1991 population

2001 population

Increase 1991 - 2001 (%)

2016 estimate

Increase 2001 - 2016 (%)
































These figures demonstrate again that there have been very substantial increases in population over the last decade in the boroughs surrounding this Park. Over the decade or so to come, the main increases will be in the three inner London Boroughs abutting the Park. This again suggests a need to enhance open space provision and not to deplete the stock of it.


A still more local analysis has been very hard to accomplish, since ward boundary changes make proper comparisons impossible. The studies we have carried out are appended.[41] The most robust figures are for the Bromley wards around the Park, which showed a 7.15% increase in the decade to 2001. For all areas, while minimal reliance may be placed on the ward data, the trend is clearly upwards, as suggested by the borough figures given above.


As much as the raw data concerning green space, the perception of Londoners regarding their green space is important. The 2002 Annual London Survey, conducted for the Greater London Authority by MORI, showed that Londoners are concerned about loss of green space, which, according to the report "underlines the importance residents place on their immediate environment." In fact, 45% of those canvassed cited loss of green space as being a problem, up from 41% in 2001.


While none of this data is by itself conclusive, it represents a best attempt to put objective material before the Inquiry, in the absence of any attempt by the London Borough of Bromley to consider the overall provision of green or recreational space in general or MOL in particular.


Before leaving this section, I ought to comment qualitatively on provision for children's play, as a father who lived in Norwood, and who is a frequent visitor to all of the parks in the area. The quality of children's play facilities in Crystal Palace Park, although recently improved, remains very poor. Remembering that this is a Metropolitan Park with a substantial sub-regional catchment, the facilities are small, quite old-fashioned and unimaginative. They are also a very long way for residents of Norwood to walk, particularly with small children. It is worth pointing out that there is very little other provision for Norwood residents. The nearest alternative play facilities are in Norwood Park, which is a long way from Crystal Palace Park, and where the facilities are usually nearly derelict. It is interesting to compare facilities in Crystal Palace Park with those in Dulwich Park, a far smaller park with a smaller catchment, but whose modern, colourful and imaginative play equipment is almost always used to bursting point. The idea of losing to development informal open play areas on the ridge adjoining Norwood is of acute concern to many Norwood residents, in my view rightly.


In More than Swings and Roundabouts, Planning for Outdoor Play[42] it is pointed out that adults perceive playgrounds as small areas of land with standard playground equipment to be used in a prescribed way. In that context, the standard playground in Crystal Palace Park is somewhat depressing. There is also an absence of variety of the form encouraged by More than Swings and Roundabouts, so as to facilitate use by children of all ages, such as skateboard and skate parks, bike tracks and jumps, hangout or youth shelters, adventure playgrounds, other open access play projects, city farms, woodland spaces and nature reserves, fun trails and activity courses etc. All of these activities imply the need for more open space rather than less.

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[29] - HMSO, 1994.
[30] - 2003
[31] - Appendix 19.
[32] - Appendix 20.
[33] - Appendix 21.
[34] - Appendix 22.
[35] - Appendix 23.
[36] - Appendix 24.
[37] - Appendix 25.
[38] - Office for National Statistics.
[39] - Demographia, sourced from Office for National Statistics
[40] - Office for National Statistics data.
[41] - Appendix 26, source: Office for National Statistics.
[42] - Children's Play Council, 2002, page 73

©Philip Kolvin