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]
19 The National Sports
Centre objection (objection refs. 0296U and 20075E, 20084E,
20062F and 20084F) 19.1 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. 19.2 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. 19.3 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. 19.4 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. 19.5 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. 19.6 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. 19.7 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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Notes:
[118] - Green Spaces, Better Places, Final Report of Urban Green Spaces Taskforce, DTLR 2002.
©Philip Kolvin