L.13 Reserved Matters - CP Campaign letter 31 August 2000

Crystal Palace Campaign


Mr Stuart MacMillan
Chief Planner
London Borough of Bromley
Civic Centre
Stockwell Close

31 August 2000


Dear Mr MacMillan,

Planning Application 00/01986: Crystal Palace

We oppose the application for approval of reserved matters on the following grounds:


When the matter was last before the Committee, on 6 May 1999, the developer's Project Manager Mr O'Donnell read from a letter dated 4 May 1999, which had been sent by Ian Livingstone of London & Regional Properties Ltd to your Head of Heritage and Urban Design, Robin Cooper. In this, Mr Livingstone made certain undertakings over concerns raised during Reserved Matters consultation. These undertakings included the development of a community forum to discuss issues concerning a reduction in car parking, adequate public transport provision and internal uses of the building. With regard to the last issue, the points below were quoted

  1. Provision of permanent exhibition space.
  2. Provision of enlarged public space.
  3. Provision of a public meeting/performance area.
  4. Provision of restaurant operations (limitation or prohibition on 'fast food')
  5. The removal of the family entertainment centre and its replacement with other uses such as book shops, music shops etc.
  6. Opening hours and general management of the development and environment.
  7. Provision of Imax cinema
  8. Reduction in cinema seats and the provision of dedicated art house screens.

These undertakings were given in order to secure approval of reserved matters, and created legitimate expectations in the public who opposed the scheme. None of the undertakings have been observed. The Council should defer consideration of this application until the developer complies with the undertakings. Otherwise, there will not have been fair dealing between the developer, the planning authority and the public.


This is, on any view, a major scheme with significant ramifications for the Park and surrounding area, abutting a conservation area and within a Grade II* listed historic Park.

Many thousands of people are anxious and concerned about the proposals, and have expressed their views in a variety of ways. Notwithstanding this, the developer has made no attempt whatsoever to demonstrate what the finished product will actually look like. We refer in particular to the flat elevation drawings, which may be meaningful to experts but will be of very limited assistance to lay people who may wish to comment on the scheme. Similarly, there is a technical description of the lighting methods to be used, but no depiction of how the building will actually look when lit. The developer has access to CAD technology which would produce such illustrations at the touch of a button. The developer should be asked to do so, and the application should not be determined until the public have had an opportunity to comment on the material. We would like to see the following:

  1. A straightforward, face-on, illustration of the building viewed from the west side of Crystal Palace Parade, also showing the northerly vehicle ramp and service and access roads and vehicle barriers. Daytime and night-time illustrations should be provided.
  2. Ditto the southerly vehicle ramp.
  3. A face-on illustration of the main entrance of the building, viewed from the west side of Crystal Palace Parade. Daytime and night-time illustrations should be provided.
  4. Ditto the side elevations, showing the vehicle ramps and the building.
  5. Ditto the eastern elevations.

Previously, we have seen only an oblique illustration of the building taken at night from the Park, which deliberately underestimates the impact of the building, and an illustration taken of the front elevations, which succeeds in missing out the vehicle ramps. We trust that the developer has sufficient belief in this building to expose it properly to public scrutiny.

We reserve the right to make further comments once the developer has provided the information requested. We would add, in passing, that we do not regard plans 1901/01/15/T and 16/T as a serious attempt to depict the scheme for the purposes of meaningful consultation.


We are unable to comment on the lighting scheme except as follows in respect of light pollution in general and its effects on bird life in particular. a) All external lighting should be positioned and operated at such an intensity as to minimise light pollution of the night sky. b) Drawing L1442/x/L.05 shows tree up-lighting. This should be eliminated for the reason above and so as not to disturb birds. c) Drawings L1442/x/D.04 and D.05 do not indicate the final destination of the beams from DPA luminaires ref.xN and xN.1. These beams should not escape beyond the building into the night sky and the plans for these, those directed down the gabion walls, should show the width of the spread of the beams and the light intensity. Will the down-lighting affect pedestrian and other traffic at the foot of the walls and will the up-lighting affect the clarity of the views for those looking out of the building as well as reflecting onto adjacent residential buildings and passing traffic?

We venture to suggest that the information is inadequate to enable any member of the Development Control Committee to reach an informed judgement on the nature and effects of the lighting scheme. This is of particular concern given the dominant effect the building will have when lit up on the skyline.


We regard the ramps as entirely unacceptable structures. The plans show how the ramps are entirely independent structures, standing well proud of the building. The fact that they are, in part, standing on gabion banking renders the entirety still more obtrusive. This can be seen particularly from plans 10327 RM 02 and 03 and 10327-10-10, 12 and 21. We regard the gabion banking itself as more suited to motorways, riverbanks, or railway cuttings.

The barrier along the sides of the ramps will effectively remove most of the headlight glare at night. However, will there be any spill off light from the top of the ramps where cars turning to go down will shine their lights towards houses at the top of Farquhar Road?

Are any arrangements to be made to incorporate sound-absorbing baffles into the ramp and roof walls and will the surfaces and car park be of sound-dampening material to minimise the effect of e.g. engines starting, running, doors slamming, frequent gear changes, acceleration up the ramp etc.?


The "viewing platforms" on the roof are extremely small and abutted by car parking spaces. No attempt has been made to make them attractive, whether by landscaping or otherwise. They are simply tiny gaps in an enormous car park. There is no indication of how pedestrian and car traffic are to be separated to get to and from the viewing platforms and into the building. There should, at the very least, be pedestrian only or pedestrian priority pathways marked.


We consider that there is an over-use of granite in general. Taken together with the gabion walls, this will provide an unnecessarily leaden and overpowering appearance. This is not a court or governmental building in the middle of a town, but a building to replace the Crystal Palace at the top of the park. The consistent use of granite and gabion belies this. What arrangements will be made to have the gabion regularly cleaned, to remove discarded rubbish and unwanted growth? What chemicals will be used? Since there are about 6,000 sq. metres of gabion wall it is possible to calculate the amount required and frequency of dosing. Has adequate separate drainage been supplied? Are special treatment basins required before discharging to Thames Water?

Furthermore, RHWL Drawings 10327-10-20 and 10327-10-21 refer to "Cladding Specification". Is this available? We note that reference is made not to gabion but to: "EXTERNAL GLAZING & STAINLESS STEEL CLADDING PACKAGE". What is this?


The lift shafts and plant service units on the roof are an appallingly obtrusive feature on the skyline. The building is sufficiently brutal as it is, with a 285m long guard-rail in place of the tree-lined ridge, which currently characterises views into the site from near and far. The plant units seem to extend 4.8 metres above the top of the handrail and, should not be allowed. Does the height of the building envelope, at 23.7m, exceed the height for which permission was given?

We see no indication that the developer has sought to ameliorate this impact. Indeed, we believe the impact to be exacerbated by the use of steel mesh as a facing material. See drawings 10327-47-02 and 10327-10-21.

Comparing RHWL drawings 10327-10-11 (West elevation), 10327-10-10 (East elevation) and 10327-10-13 (elevations) with 10327 RM 02 (East and West elevations), reveals a discrepancy in the rooftop plant structure: it is shown as continuous on 10327 RM 02 but as in two parts on the other three drawings. This requires clarification.

Comparing RHWL drawing 10327 RM 01 with 0327 RM 02, the rooftop plant structure appears longer in 02 than in 01. This needs clarification by way of revised drawings.

We are concerned that car roofs will glint in the sunlight. Higher roofs will protrude above the guard-rail. Plan 10327-10-20 shows a low car roof. We are sure that higher vehicles than that will be able to access the roof. If they do, then Bromley's contribution to London's skyline will be hundreds of car roofs. The parapet wall will require to be higher if the car-deck cannot be made lower. From the drawings, it is difficult to confirm the number of roof-top car parking spaces &endash; are there to be 950? If there are less than this number, where are the remaining cars to park?


The planting in general is inadequate. We are extremely disappointed to note that there has been an abandonment of the idea of planting an avenue of trees along Crystal Palace Parade, including along a central reservation. We have consistently pointed to the impact that this building will have on residential areas to the west. The failure to carry out any professional assessment of the impact on the skyline ridge from that direction has given us grave cause for concern. This is particularly since the building involves destruction of 140 trees and replacement with the features referred to above. The deleterious impact of the building would have been ameliorated by tree planting along the length of the Parade. But it appears that this is not now to happen, presumably on grounds of economy. We view this as unacceptable. This represents the last chance to deal with this particular impact. The Council has powers to deal with it. We would ask that those powers be exercised. We hope that, before the matter comes before the Committee, the developer will provide alternative planting proposals. Without such proposals, approval should be refused.

The Land Use Consultants landscape proposals supporting statement, at paragraph 3.6 states, "All trees within the subway area will be retained. Where necessary for health and safety reasons minor arboricultural works will be carried out as required." With regard to the subway area, LUC drawing 1901 01 02 Rev B shows details of tree protection hoarding elsewhere on the site, but no protection is offered for the trees in the subway area or to the subway itself. This omission must be rectified. Further, given that the subway area is shown as outside the application site boundary, whose responsibility is it to carry out the minor works referred to above?

In connection with the above, we regard it as totally unsatisfactory that there are no proper plans regarding tree removal around the Anerley Hill Tunnel. How can the Committee assess the plans without knowing what the proposal is regarding trees? A tree survey, along with details of tree removal, tree protection and tree work must be provided prior to consideration by the Committee. Failing this, permission should be withheld.

Tree no. 131 on the tree schedule is a mature, high-quality specimen of great importance to near and far views. It should be retained.


A sign by RHWL is shown on 1901/01/14. We believe that details of this sign should be provided now, so that it may be considered in context &endash; as should details of the plinths which are also shown on this drawing.


The entire tunnel arrangement is unsatisfactory since it is more suited to motorway design than to an historic park entrance. There is too much tarmac at the entrance and the steel shutters will make this look like a fortress. The stone clad wall and the railings over are highly obtrusive. Taken together with the road signs, this will provide an arrangement which would not look out of place on a toll road. It has no place whatsoever in the midst of a conservation area in a park. This all requires to be rethought. See, e.g. 213/RP/1.

Land Use Consultants drawing 1901 01 03 Rev B shows the inside edge of the right turn of the tunnel extending beyond the site boundary. If this is the case, the developer must make a fresh planning application.

WSP drawing 213/RP/1 states: "Proposed height barrier to be designed by Gustafson Porter." Details of this design are required. Details are also required of height restriction, traffic warning signs and advance direction signs on Anerley Hill. An artist's impression showing all signs, signals, junction boxes, barriers, road humps, bollards, control cabinets, pedestrian refuges, street lighting, tree planting and retaining walls is essential so as to enable a proper assessment of the full impact of this junction on the Park and Anerley Hill.

Furthermore no drawing, from any of the various architects, shows the traffic control arrangements which will be essential at the entrance/exit to the Crystal Palace Parade ramp. Whilst the Parade traffic control may fall within Southwark, and be outside the site boundary, some control/signage will be required within the boundary of the site and this information should be provided now.


The Gustafson/Porter drawings make no allowance for the Weigh Bridge and equipment on the proposed Museum Plaza. It is essential that is incorporated and retained in any landscaping proposals outside the Museum.


Land Use Consultants drawing 1901 01 13 refers to paint and graffiti removal at specific points. The whole of the brick up-stand and piers supporting the listed railings should be cleaned and any replacement bricks required should be matched and, if necessary, acquired from a reputable architectural salvage company. Additional railings to be provided on the site are somewhat crude affairs by comparison with the Paxton originals.


The statement on drainage is flawed in the following respects:

  1. The Thames Water letter dated 30 November 1998 states that further details are required to prove that the sewer system is designed to comply with Sewers for Adoption and Thames' standard practice documents. Those details have not been provided and it follows that Thames Water are not demonstrably content with the proposals.
  2. The Environment Agency, on 19th November 1998, required to be consulted on the proposed water features and enhancement works. Those details have not been provided.
  3. Drainage seems to depend on the provision of the canal in the Park without any of the other works the subject of the Gustafson scheme. It is quite wrong that the canal should go in without any of the other works proposed by Gustafson. A canal running across the Park without any of the remainder of the Gustafson scheme is a dissonant note in the Park landscape. Without the Park project, an alternative approach to drainage should be sought.
  4. The ability to drain foul water appears to depend on the provision of only 70 WCs in the development. We have difficulty seeing how 20 cinemas, 3 leisure boxes, a retail unit and 14 liquor licences could provide so few WCs for staff and customers. The developer should be asked to demonstrate that 70 WCs would be adequate for the probable number of staff and customers. It would be helpful to have an indication as to the ratio of female:male facilities (e.g. 3:1).
  5. It is not clear from page 4 that high flows will have contaminants removed. They should be removed, even in high flow conditions.
  6. WSP Statement On Foul and Surface Water Drainage, page 4 states: "The two petrol/oil interceptors have been located to ensure that they can be accessed by a tanker for routine regular maintenance from the Anerley Hill access road." WSP drawing 213/RP/1 shows a typical tunnel section with "min. 2.5m headroom". Is this sufficient to allow access by the tanker referred to above? This must be the only access point to the site for such tankers &endash; they must not be allowed access from Crystal Palace Parade.


We have examined the proposed flows on the information provided and the basis on which Thames Water accepted discharge levels. This would be 29 litres per second for food preparation areas, 70 WCs, 36 hand washbasins and/or discharge from the swimming pool filter backwash. However, if a WC can discharge at a rate of about 1 litre per second then the worst case here alone should be 70 litres per second. There are implications here for the Pumping Station (north west corner of the site) i.e. to get the water into the College Road pipes. First there may be a noise problem and, secondly, a larger system means even more noise. What sound pressure levels generated from the Pumping Station can be expected within, say, one metre and three metres of the installation and at the nearest occupied buildings?


Certain drawings do not appear to have been supplied to the Upper Norwood Library:

The Land Use Consultants landscape proposals supporting statement paragraph 3.4 refers to "drawing at GP 0100 Rev B".

RHWL drawings 10327-10-20 and 21 refer to other drawings. These are 10327-47-03 and 04, 10327-40-01, 0327-24-01, 02 and 03.

WSP drawing 213/RP/1 refers to drawings 213/RP/2 and 213/RP/3 for long sections and cross-sections.

Can all these drawings please be supplied?

Yours sincerely,



Please reply to: Crystal Palace Campaign
33 Hogarth Court, Fountain Drive, London SE19 1UY Telephone/Fax: 020 8670 8486
E-mail: VA.Day@ukgateway.net Campaign Website: www.crystal.dircon.co.uk
Associate Member The London Forum of Amenity and Civic Societies

Ed: the numbering may not be exactly as in the original - however, the text is verbatim.

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