Submitted to Bromley Council by the Crystal Palace Campaign, May 2001

 1 - Chapter 3: Strategic Objectives - Transport Objectives

  1. The third strategic transport objective is to reduce reliance on the private car, restrain its use and encourage greater use of public and alternative means of transport. However, none of the means listed includes limiting parking provision for developments and other on or off street parking provision. The list ought to have included such means, so as to comply with PPG13 para 51. It is insufficient to promote alternatives to the use of the private car without also limiting parking provision.
  2. Furthermore, the commentary to the transport objectives should refer to parking charges and the enforcement of parking restrictions, so as to comply with PPG13 para 57.

2 - Chapter 3: Strategic Objectives - Para 3.7: Recreation and Leisure Objectives

  1. While the general objectives are acceptable, the commentary is unclear. The last sentence brings in Crystal Palace Park almost by a sidewind: the issue is far too important to be dealt with in a sub-clause. The sentence should read:

    It intends to provide for recreation and leisure needs through its strategies for parks, sports and the arts, and to promote improvements in facilities subject to the other policies in the Plan.

3 - Chapter 3: Strategic Objectives - Town Centre and Shopping Objectives

  1. The fourth objective implies a weakening of the sequential approach. The objective should be to locate new retail and leisure in town centres as preferred locations. The fourth objective does not say this, and stands in contradiction to paragraph 35 of PPG13.

4 - Chapter 3: Strategic Objectives - General

The Plan should include the following text, setting out strategic objectives for Crystal Palace Park, with accompanying commentary:

Crystal Palace Park and environs objectives

  1. To maintain and enhance the role of Crystal Palace Park as the principal strategic park for south-east London.
  2. To recognise the high value placed by local people upon Crystal Palace Park as open parkland.
  3. To respect the historic importance of the site of the Crystal Palace.
  4. To preserve and enhance the listed terraces, the listed subway under Crystal Palace Parade and other heritage features of the Park.
  5. To ensure that any development proposal for the site accords with the status of the Park as Metropolitan Open Land, a listed historic park and a Conservation Area.
  6. To protect the residential environs of the Park.
  7. To improve the facilities offered by the National Sports Centre, so far as consistent with its status as Metropolitan Open land.

    Crystal Palace Park is the principal strategic park for south-east London, and is highly valued by local people as a place for parkland recreation. The Park was also the site of the Crystal Palace from 1854 to 1936, and the Park contains important features associated with that era, including the geological time trail, the dinosaurs, terraces, statuary and a subway. The Crystal Palace museum is an important historical and educational facility regarding the Crystal Palace. The Park is Metropolitan Open Land and is listed as Grade II* on the Register of Historic Parks and Gardens. Most of the Park is a Conservation Area. There is strong community commitment to preserving the park both as open parkland and an historic park, and to preventing substantial new development upon it.

    The National Sports Centre requires refurbishment. This may be achieved without the need for significant new building. Any refurbishment should include commitment to reducing parking, reducing the non-sporting buildings and removing unnecessary areas of hard-standing.

    The Park is surrounded by residents of five boroughs, and its future should be planned with the full participation of the local community and the neighbouring boroughs. While regeneration of certain areas near to the Park is a desirable objective, this should not be attained at the expense of the Park itself. An environmentally sensitive treatment of the Park will itself produce regeneration benefits, being an attractor of neighbouring business and residential uses.


5 - Chapter 5: Transport &endash; Third objective.

  1. For objections to the third objective, see paragraph 1a above.

6 - Chapter 5: Transport - Sixth objective

  1. The sixth objective includes a commitment to "continuing to provide a reasonable level of parking for shopping and leisure visits." Not only is it unclear what is meant by "a reasonable level", but the objective ought to be to limit parking provision so as to promote sustainable transport choices (see PPG13 paras 51 and 52). 

7 - Chapter 5: Transport - Policy T1

  1. Policy T1 fails to follow national guidance to the effect that policies for retail and leisure should seek to promote the vitality and viability of existing town centres, which should be the preferred locations for new retail and leisure development (see e.g. PPG13 para 35). By terming Crystal Palace a place of high transport accessibility, the Plan apparently encourages the development there of large regional retail and leisure facilities, to which the Park and surrounding road network is wholly unsuited.
  2. Nor is it accepted that Crystal Palace is a place of high transport accessibility in comparison with traditional town centres such as Bromley and Croydon, which are the natural receptors of such facilities.

8 - Chapter 5: Transport - Policy T3 and Appendix II

  1. Policy T3 provides that the Council will normally require off-street parking to be provided according to the standards in Appendix II. This creates a presumption in favour of the standards. Appendix II.1 provides that the parking standards are derived as a maximum, but less than the standard will not normally be acceptable. The effect is to make the maximum the standard. This is inimical to the concept of a maximum, because it creates a presumption against provision below the maximum.
  2. The policy ought to be:

    When considering development proposals:

    1. The Council will normally refuse permission for off-street parking in excess of the maximum set out in Appendix II.
    2. The Council will set levels of off-street parking at new developments so as to promote sustainable transport choices.

9 - Chapter 6: Conservation and the Built Environment - Policy BE11

  1. This policy does not adequately reflect PPG15 para 2.24. The policy should read:

    The Council will protect registered parks and gardens in determining planning applications.
    The Council will seek to ensure that historic parks and gardens are appropriately managed and maintained.

  2. The commentary should include the following text:

    Crystal Palace Park is a site of particular sensitivity. It is the only Grade II* listed park in the borough. Most of the Park is a Conservation Area and all of it is Metropolitan Open Land. Any proposed treatment of the Park will need to pay close regard to these designations.

10 - Chapter 6: Policy BE14

  1. The commentary1 refers to major skyline ridges, but the policy neglects to do so. The policy should read:

    The Council will not normally permit development that adversely affects strategically important local views, views of local importance, landmarks and major skyline ridges.

11 - Chapter 6: Policy BE17 para 6.56

  1. The paragraph wrongly excludes Conservation Areas, historic parks and Metropolitan Open Land. These designations should be included by appropriate drafting.

12 - Chapter 7: Policy NE12 para 7.38

  1. The second sentence should also refer to Metropolitan Open Land. It should read:

    Proposals, for example, for open space recreational uses, which, in principle, may be acceptable within the Green Belt or Metropolitan Open Land, can affect the appearance of the land.

13 - Chapter 8: Green Belt and Open Space - Objectives

  1. The second objective should refer to Metropolitan Open Land. It should read:

    To enhance the Green Belt and Metropolitan Open Land through active management and advice.

14 - Chapter 8: Green Belt and Open Space: Strategic Considerations

  1. The strategic considerations should include the following:

    The Council intends to provide the strongest protection for open space that is, or that has the potential to be, of value to the community (Consultation Draft PPG17 para 5).

15 - Chapter 8: Green Belt and Open Space: Policy G2 and Proposals Map

  1. The removal of the designation of the top-site (UDP Proposal Site 9) as Metropolitan Open Land is opposed.
  2. This land is highly prized by the local community as part of the Park and, given its topographical dominance of the Park and the open panoramic views from the land, makes an important contribution to the overall perception of openness. RPG3 offers protection to such land.
  3. There is no justification for the removal of the Metropolitan Open Land designation, other than the Council's widely opposed desire to impose a large development on the site. Further, Crystal Palace Parade is a natural and defensible boundary for Metropolitan Open Land, which should be retained. The site itself provides a view into the Park from the public highway, which is an important break in the urban fabric and provides a natural visual amenity which could and should be strengthened.
  4. Removing the Metropolitan Open Land designation of the site is also contrary to national policy as to protection of open space which is or has the potential to be of value to the community. See PPG17 paras 5, 24, 27, 31, 51 etc.

16 - Chapter 8: Green Belt and Open Space: Policy G2 and Proposals Map

  1. The designation of the National Sports Centre as a Major Developed Site is objectionable.
  2. Such designation is not advocated in guidance for Metropolitan Open Land. There is no justification for creating such a designation here. The Sports Centre may be refurbished in a manner consistent with its Metropolitan Open Land designation.
  3. Further, the Proposals Map shows a very substantial perimeter to the National Sports Centre, which suggests a proposal to increase its spread and the footprint of buildings substantially, particularly to the north and west. The areas of hard-standing around the Centre should be removed, not used as justification to increase its coverage. The area to the north is important open space, preventing the almost total lateral severance of the Park on the north-south axis.
  4. Further, Annex C para C2 of PPG2 makes it clear that infilling means the filling of small gaps between built development. The major development on the site is the Sports Centre itself and the stadium. The desire to infill cannot justify the creation of a substantial perimeter around the entire site of the National Sports Centre where development may occur. The scope for redevelopment is negligible, given the other designations of Crystal Palace Park and the listed status of the Sports Centre itself, which are highly material considerations militating against redevelopment: see in particular paras C11 and C12 of PPG2 Annex C.
  5. Therefore, the commitment should be simply to refurbish the existing buildings, removing unnecessary hard-standing and enhancing the visual attractiveness of the site.

17 - Chapter 8 - Green Belt and Open Space, policy G3

  1. The following sub-paragraph should be added, to comply with para 51 of PPG17:
    1. the development should be to the minimum scale consistent with the requirements of the outdoor recreational activity.

18 - Chapter 8 - Recreation, Leisure and Tourism, policy L1

  1. Policy BE11 (Historic Parks and Gardens) should be referred to in the body of the Policy, and not merely cross-referenced after the commentary.

19 - Chapter 9 - Recreation, Leisure and Tourism, policy L10

  1. The policy apparently confuses sporting leisure and community uses with commercial leisure. This is also apparent from "Recreation and Leisure Objectives" (page 13 of Plan) and the Objectives cited at the head of Chapter 9. Sporting leisure and community uses should receive discrete treatment, observing the guidance in PPG17. Commercial leisure should be separately treated, having regard to policy guidance in (amongst other places) PPG6 and 13. Confusing the two could result in commercial leisure being proposed in a place unsuitable for such a purpose, albeit arguably suitable for indoor sports or community use.
  2. In so far as the policy is applicable to sporting leisure and community uses, it should follow the guidance in PPG17 para 41, that:
    1. intensive recreational uses should be located in or on the edge of town centres where they can contribute to town centre vitality and viability;
    2. greenfield sites for built facilities should be avoided.

20 - Chapter 11 - Town Centres and Shopping - Policy S6

  1. Policy S6 is drafted so that edge of centre proposals are not required to demonstrate need. This potentially conflicts with the Minister for Planning's Parliamentary answer of 11th February 1999.
  2. Further, it should be provided that edge and out of centre proposals will only be permitted if:
    1. they are in scale with their surroundings, including any nearby centre;
    2. they do not affect the vitality or viability of neighbouring town centre;
    3. they are not in conflict with other policies in the Plan..
  3. A new paragraph of commentary should be added:

    Developers are expected to be flexible about the format, design and scale of the development, so that they may be accommodated in town centres, which remain the preferred location for retail and leisure developments (para 1.12 PPG6). Edge of centre and out of centre proposals have the potential to harm the vitality and viability of neighbouring town centres, and could overwhelm the smaller centres within or around the borough. Developers should demonstrate why such proposals cannot be accommodated in town centre locations. In any event, proposals must not be disproportionate in a local context, cause economic harm to neighbouring centres or conflict with other policies in the Plan.

21 - Chapter 16 - Schedule of Proposed Sites - National Sports Centre

  1. On the Proposals Map, the perimeter is drawn far too widely. It should run around the existing buildings of the Sports Centre and the stadium.
  2. The proposal should be to refurbish the existing facilities, consistently with the site's designation as Metropolitan Open Land.

22 - Chapter 16 - Schedule of Proposed Sites - Crystal Palace Park

  1. The site proposal, which is "to provide leisure and recreational development, with associated food and drink premises, in conjunction with the existing bus station" is strongly resisted.
  2. The site proposal fails to take into account:
    1. the location of the site in a listed historic park;
    2. the three adjoining Conservation Areas;
    3. the current designation of the site as Metropolitan Open Land;
    4. the widespread local desire not to have such a facility on this site;
    5. the historic resonance of the site, being the location of the Crystal Palace;
    6. the topographical significance of the site, being the highest tree-lined ridge in the metropolis;
    7. the neighbouring residential areas;
    8. the absence of any attempt to involve the community or invite its participation in an environmentally sensitive future for the site;
    9. national planning policy regarding preservation of open space, historic parks, trees, conservation areas, location of commercial leisure etc.
  3. If (which is not accepted) there should be a specific site proposal for this tract of historic parkland, this proposal represents an impoverishment of imagination. In terms of design and use, any proposal should reflect the appearance, style and spirit of the original Palace so as to perpetuate the importance of the Crystal Palace in the architectural, cultural and social heritage of the nation.
  4. Further, the description of the top-site as "Disused Land" is a misnomer. Until the Council fenced off the wooded part of it, the land was widely used for informal recreation, and treated by the community as an important part of the Park, with a pleasing ambience and panoramic views.


Crystal Palace Campaign
May 2001

Ed. The above is verbatim as presented but has different paragraph nomenclature to the original.

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10/10/02 Last updated 10/10/02