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Crystal Palace News
Crystal Palace Foundation comments to the London Borough of Bromley on the Crystal Palace Park Park Masterplan
Friday 6th June 2008
The Crystal Palace Foundation
(Registered Charity 285563)
Bob McQuillan Esq
Acting Chief Planner
Civic Centre,
Stockwell Close
BROMLEY BR1 3UH
6th June 2008
Dear Mr McQuillan,
Outline Planning Application DC/07/03897OUT and Conservation Area Consent Application DC/07/03906/CAC
Crystal Palace Park, London SE20 8DT
1. The Crystal Palace Foundation objects to these applications on a number of counts. This submission is not intended to be comprehensive, but gives sufficient detail to enable the conclusion to be reached that these applications should be refused. The Masterplan is considered on a zone-by-zone basis; observations and objections are summarised within bordered paragraphs.
2. Preliminary note: PPG15 Historic Parks and Gardens, para 2.24, states, ‘…local planning authorities should protect registered parks and gardens in preparing development plans and in determining planning applications. The effect of proposed development on a registered park or garden or its setting is a material consideration in the determination of a planning application.’
One effect of the development proposed by the applicant, and therefore a material consideration in terms of PPG 15, is with regard to trees and the landscape – the Park’s setting. That the issues of the proposed development and of trees and the landscape are intrinsically linked here is shown in the applicant’s Environmental Statement (Main Document), Section 4: Description of the Proposals where it is stated: ‘4.11. The outline planning application also includes the removal of a number of trees (as shown on Parameter Plan 4 Tree Removal and Retainment Plan).’
Therefore, in a number of Zones the treatment of trees is taken as the framework upon which to explore issues associated with planning proposals, design and access, and to reach conclusions.
3. The Arboricultural Survey has been undertaken by JCA Ltd in accordance with British Standard 5837: 2005 - Trees in Relation to Construction – Recommendations. This Standard recommends a ‘cradle to grave’ approach, i.e. from the appointment of a qualified arboriculturist before the design of any proposal, through to his/her involvement in the discharge of relevant planning conditions and on-site monitoring. This will ensure that trees are considered prior to and within the design, the construction and the future management of proposed development sites. Existing trees have environmental and social benefits, and can provide an immediate sense of maturity on a park or green space, whether or not any area is proposed for development. Indeed, one aim of a BS 5837 Arboricultural Survey is to ensure that trees are successfully and appropriately retained when or if a development takes place.
4. Whereas the Arboricultural Survey has been conducted in accordance with BS 5837, the following should be noted:
The Environmental Statement (Main Document)), Section 4: Description of the Proposals, paragraph 4.83 says: ‘Parameter Plan 4 shows the trees and hedgerows within the Site that would be removed or retained under the Proposals. Based on the Arboricultural Survey conducted by JCA Limited (included as Technical Appendix 3.1), these range from Category A to R trees. As part of the scheme, approximately 470 trees would be removed…’
This gives the impression that JCA recommends that 470 trees be removed.
However, in the Arboricultural Survey Appendix 1: Tree Descriptions and Recommendations (Masterplan application document Technical Appendix 3.1C to the Environmental Statement (Main Document)), a count from the spreadsheet shows that JCA recommends a total of just 83 trees for removal.
5. This difference of 387 trees must comprise those that are viable according to the Arboricultural Survey, and should or could be retained, but would be removed by the applicant in order to facilitate the implementation of the planning, design and access proposals within these applications. Despite proposals for replacement planting, this level of tree felling within A, B and C retention categories cannot be countenanced in the context of this application.
Zone A – Anerley Hill.
A1. In Zone A the Arboricultural Survey Appendix 5: SITE PLAN (Masterplan application document Technical Appendix 3.1B to the Environmental Statement (Main Document)) shows that 20 of the 21 trees at the location described in the application as College and Lodge (Ref 10), fall within one of the two BS 5837: 2005: 4.3.1 retention categories, i.e. B or C; only one is shown as category R (tree for removal).
A2. However, the TREE REMOVAL AND RETAINMENT PLAN (Parameter Plan 4 (PP4) at the Masterplan Design & Access Statement Volume 2, Appendix 3) shows all except one of the above B and C trees to be removed.
A 3. The insertion of the College and Lodge and its replacement planting cannot compensate for the loss of 20 trees in retention categories B and C at this location.
A 4. To the west of the College and Lodge location, still in Zone A, there are more than fifty trees shown in the Arboricultural Survey as being in BS 5837: 2005: 4.3.1 retention categories A (retention most desirable), B (retention desirable) and C (tree which could be retained). However the TREE REMOVAL AND RETAINMENT PLAN shows that at least fifty individual trees are to be removed here, along with a number of groupings of trees.
The Masterplan proposes significant changes in topography, and on the Anerley Hill edge this would chiefly comprise removed (cut) materials. The Design and Access Statement says that ‘The most extensive change would be along Anerley Hill edge and in the centre of the Park within the Transitional Landscape, with undulating terracing and significant ground modelling to facilitate level access into the Park.’ This would make possible the planting of a number of new trees, but it is clear that many existing trees would need to be removed to facilitate this level access, along with the boundary wall and railings. There are sufficient alternative level access points without altering the existing boundary, contours and sylvan nature of the Anerley Hill edge. Further, given that the Park is designated an Area of Archaeological Significance any cut or fill activities should be entirely minimal and, if any such activities are carried out, they must take place only after a full, site-based (i.e. not desk-based) archaeological investigation and survey.
Note: If an intention of the proposed ground modelling here is to prepare level ground for a Tramlink extension within the safeguarded zone shown on Parameter Plan A3, this should be stated.
A 5. With regard to the Anerley Hill edge, the Foundation would commend to the local planning authority the observations under ‘PARK EDGES’ contained on page 4 of the Crystal Palace Park Dialogue Main Group questionnaire responses – a supporting document that accompanied the agenda for the Main Group Meeting of 17th May 2008.
For ease of reference, the questionnaire response document is appended to this letter.
A 6. One cluster of trees planned for removal in Zone A is parallel to what would be the southern edge of the proposed South Greenhouse (Ref 02).
To strip the Park of these trees is unacceptable. This area (as with many others where trees are planned for removal) falls within the designated Site of Importance for Nature Conservation, is Metropolitan Open Land and within the Conservation Area.
A 7. College and Lodge. This mundane design has little merit, and shows no sympathy with the historic Park, but will instead reflect the language of the proposed South Greenhouse, which is opposed – see below. The proposed Lodge building would be overbearing for residents of Ledrington Road and in this regard the Foundation would commend to the local planning authority the observations under ‘NEW LODGE’ contained on pages 6 and 7 of the Crystal Palace Park Dialogue Main Group questionnaire responses – a supporting document that accompanied the agenda for the Main Group Meeting of 17th May 2008.
For ease of reference, the questionnaire response document is appended to this letter.
A 8. The Greenhouses. At 6.9.6 of the Masterplan Planning Statement the proposed north and south greenhouses are discussed. It is said that despite their significant size, the use of lightweight material and glazing will minimize impact upon the landscape. This is disputed, since their insertion, along with the associated removal of significant numbers of established trees, will have a major impact upon the landscape. It is also said that the greenhouses are not dissimilar to the original Crystal Palace design. However, despite it being said that they have glazing articulation to reflect the original Palace grid, the proposed structures owe little to Paxton’s design; even the roof is single pitched glazed, with east facing opening lights, paying no homage whatsoever to a Paxton signature feature – the ridge and furrow roof construction.
Additionally, the question of security here would be of paramount importance.
Objections:
In Zone A, the Crystal Palace Foundation objects to the proposals for the College and Lodge. Further, the Crystal Palace Foundation objects to the proposals for the proposed South Greenhouse, the design of which owes little to Paxton. Additionally, the plans for major topography realignment, along with the removal of approximately 70 viable trees are totally unacceptable.
Zone B – Palace Terrace.
B 1. The Arboricultural Survey Appendix 5: SITE PLAN (Masterplan application document Technical Appendix 3.1B to the Environmental Statement (Main Document)) shows approximately 150 category A, B or C trees. However the TREE REMOVAL AND RETAINMENT PLAN shows around 50 of these (one third of the total within the Zone) to be removed here, along with a number of groupings of trees; eight of these trees (6 London plane and 2 lime) fall into category A (retention most desirable).
B 2. It is noted here that a number of the trees proposed for removal in Zone B are situated on the old caravan site which, in recent memory, was first occupied by environmental activists and subsequently jealously guarded and tended by the Ridge Wildlife Group.
B 3. In the Environmental Statement (Main Document), Section 4: Description of the Proposals, paragraph 4.36 proposes: ‘Selective removal of some existing trees and planting of a grid of new trees within the footprint of the former Crystal Palace. While the grid of trees would be based on Paxton’s 24-foot grid, the tree planting would be designed to avoid the predicted positions of the original columns of the Palace and any foundations running between the columns, as well as the nave fountains. Measures would also be taken to limit the growth of the tree roots to prevent potential damage to the remains of Crystal Palace’. However, the intention here is not clear. A grid of new trees within the footprint of the former Crystal Palace…designed to avoid the predicted positions of the original columns of the Palace and any foundations running between them…? Being apparently offset to ensure that their location will not precisely reflect the Palace footprint, how can the planting be said to be based on Paxton’s 24-foot grid? How will tree root growth be limited?
Observations:
In Zone B, whilst applauding the proposal that the Palace footprint be delineated, there is concern at the planned loss of one third of the existing tree cover and the ambiguity of the scheme as proposed.
● In order to retain a number of existing trees within an informal setting, whilst at the same time ensuring a formal and accurate delineation of the Palace footprint, an alternative of, say, low-level, shallow-rooted (box?) hedge or shrub planting, should be discussed.
B 4. Crystal Palace Park Museum (Ref 07). This is the principal building proposed for Zone B. The Foundation has consistently argued and pressed for a museum worthy of the history of Crystal Palace – from its birth as the exhibition hall for the Great Exhibition in 1851, to the reconfigured building and its demise on the Park in 1936, along with its memory and the history of the Park since. The Foundation presented its proposals for a museum, to the Dialogue process in 2003. This would be based within and around the existing Museum building, with an extended Brunel South Tower being topped out with a camera obscura (a feature of the Sydenham Crystal Palace) and viewing area. Did the applicant consider this proposal before submitting the present application? Similarly, the trustees of the Crystal Palace Museum, in their 2005-2007 business plan and in a presentation to the Dialogue group, put forward a scheme based around the current museum building. Did the applicant consider this proposal before submitting the present application?
B 5. The Pattern Book (The Environmental Statement: Design of the Proposals, Appendix 4.2) sets out only the principles of the proposed Park buildings. It gives an illustrative section showing a potential museum option; the elevations and footprint lack sufficient detail, and there is no indication as to likely content (e.g. exhibition areas, circulation space; gallery; library and research facilities; retail; conference facilities; IT suite; Crystal Palace Band practice area) or the space that would be required to accommodate them. So it is only possible to comment on the Museum proposal within the context of its footprint and envelope:
B 5.1. The footprint of the proposed museum falls within ‘the pink land’ area of ‘the relevant land’ delineated on the signed plan attached to the Bromley London Borough (Crystal Palace) Act 1990. Paragraph 4. of the Act states: ‘The principal building to be constructed in any development of the pink land consequent upon the provisions of this Act shall reflect the architectural style of the original Crystal Palace.’ (Note: It has been established that ‘the original Crystal Palace’ refers to the building erected on Crystal Palace Park.)
Under the Masterplan proposals, the museum would be the principal building and would, therefore, be required to comply with this provision.
Insufficient detail is given to show how the proposed building would reflect the architectural style of the original Crystal Palace.
B 5.2. Further, the undertakings attached to the Act specify that ‘…the building should contain a predominance of glass and metal or similar materials and that the building should reflect the spirit of the original Crystal Palace’.
There is insufficient detail to show how the proposed building will comply with this undertaking.
(Note: The undertakings additionally specify that ‘In consultation with the Crystal Palace Foundation the Council shall require that any development of the relevant land carried out pursuant to the provisions of this Bill shall include provision of exhibition space on the history of the Palace and park.’ This matter will need to be addressed at a later stage.)
B 5.3. At this outline stage, it appears that the proposed Crystal Palace Park Museum, as shown in the Masterplan, owes little to any Paxton design – despite it being said to be ‘…echoing the design language of the greenhouses in rhythm and consistency of detail’ and ‘…with glazing proportions to reflect the original Palace grid’ (– statements found at Environmental Statement: Design of the proposals, Appendix 4.1 – Design Guidelines 3: Parkzone & related design guidelines 3.2B: Crystal Palace Park Museum).
B 5.4. And by virtue of the fact that it would accommodate a hard surface rooftop viewing area, the Museum can pay no homage whatsoever to a Paxton signature feature – the glass, ridge and furrow roof construction.
B 5.5. In the Pattern Book at Environmental Statement: Design of the Proposals, Appendix 4.2, the examples of glazing shown from Bregenz, Paris and London, owe nothing to Paxton other than their modularity, and otherwise fail to echo or reflect the language or the style of the original Crystal Palace.
B 6. If a pastiche of Paxton’s Palace is unacceptable, then so will be a design that merely pays lip service to its modularity – a design that would require constant and repeated explanation as to how it reflects, echoes or otherwise chimes in with the original Crystal Palace.
B 7. Furthermore, the phasing proposals appear to indicate that a museum here would not be completed until the end of year six following any grant of permission. However, there is the potential for this park to accommodate a museum of international renown; one that would become a key visitor destination and, as such, one that would generate a very substantial income. So when matters relating to governance of the Park and/or the museum are resolved, the museum’s income will become a significant issue.
It is, therefore a) a pity that greater priority is not attached to the provision of a magnificent museum on the Park, and b) essential that governance issues are resolved at an early stage so that the governing body/authority is in a position to deliver, year on year, such elements of improvements to the Park (but in particular, a museum) as may in due course be approved – whether in the context of this application or at another time.
B 8. If the phasing means that a new museum will not be completed until the end of year six following any grant of permission, it means that the current museum will need to viable, operational and open to the public for that period. The Sustainability Statement shows indicative key phases. During the second two years: ‘The former CPP Museum would be refurbished to allow this building to be utilised as a Park Rangers facility’; what would happen to the current museum during these works? And during the third two years: ‘The Park Ranger Building would be dismantled, relocated and operational’ and there would be ‘Completion of construction works for the new museum…’ Can we assume, therefore, that the ‘former’ museum would relocate to the new museum?
B 9. It is unfortunate that the terms ‘the former museum’ and ‘the current Crystal Palace Museum’ are both used within the application.
B 10. Note: The proposed building is referred to as the Crystal Palace Park Museum (stress added). This appellation sends out a parochial message; it is as if it just happens to be this Park’s museum – within which there may be found something relating to the Crystal Palace. However, the name of the current museum – The Crystal Palace Museum – immediately conveys the message that this museum is about the memory of an iconic structure and its rich history, from the Great Exhibition building in Hyde Park, to the Sydenham building and its demise, to the Crystal Palace Park of today.
The Crystal Palace Museum is inclusive; it encapsulates it all.
Objection:
In Zone B, whilst recognising that a museum worthy of the Crystal Palace and its history is essential, the Crystal Palace Foundation objects to the outline proposals for the Crystal Palace Park Museum as set out in the Masterplan.
Zone C – Terraces
C 1. The major proposal here is for sunken gardens. Apparently, the position of the former fountains has been partially investigated and it is said that the new sunken gardens would be unlikely to disturb in situ features below ground; this is of concern. Cutting into this area which is, effectively, an archaeological site, would constitute major works to introduce new features into a Grade II* listed Park – features that were never a part of the original.
C 2. With regard to the terrace structures, we would agree that sensitive repair is required, but it is said in the Design and Access Statement Vol.1 (Main Document) that ‘where elements are completely lost, such as some of the staircases, replacements would be to a new design allowing for the introduction of new functions, such as ramps and slides, to aid both accessibility and enjoyment.’ Again, consider the integrity of the listed structures and how they would sit with features that would be so overtly discordant. And the north grand staircase being reconfigured to a ramped construction would be totally out of the question.
C 3. The Environmental Statement (Non-technical Summary) says that ‘The Proposals would temporarily affect the setting of the Crystal Palace Park Conservation Area, nearby conservation areas and the Grade II* status of the Park during the demolition and construction phase.’ So, when finished, with entirely new features and new structures (here, and in the rest of the Park), can the applicant be certain that the integrity of the original will not be so adversely affected as to have the Grade II* listing downgraded?
C 4. The previous (Kathryn Gustafson) proposals would have seen the upper terrace side of the balustrades protected by box hedging. These structures have been restored and vandalised once already. What measures would be taken to protect them if restored again?
C 5. At present, the wide, grassed area of the terrace is appreciated as such, and used for a variety of purposes. Being punctuated by two sunken gardens would remove this characteristic.
Objection:
The Crystal Palace Foundation is concerned as to the whole ethic behind proposals for this Zone which, to compound the incongruity, would be flanked by ersatz Palace wings. The Foundation, therefore, objects to proposals for Zone C – the Terraces.
Zone D – Transitional Landscape.
Observation:
The reasons for removal of some category A, B and C trees here in the context of this application are understood, and the replanting proposals are commended. It would be good to see the complete rebuilding of the Rosery, together with the bandstand – illustrations of which exist.
Zone E – NSC. The Crystal Palace Foundation makes no comment.
Zone F – Tidal Lakes
The principal building in this Zone is the Café and Dinosaur Interpretation Centre. The Design & Access Statement says, inter alia, ‘In the spirit of Paxton, the aim is to create buildings which are contemporary, innovative and distinctive, that are sensitive to their historic landscape setting, utilising modern construction methods and prefabrication techniques, and that are exemplary in terms of sustainability and environmental design.’
This argument has resulted in an illustrative drawing that is said to refer back to Paxton in certain respects, but in fact bears no clear identity that would lead one to associate it with Paxton or this Park. It would, therefore neither preserve nor enhance the character or appearance of the conservation area.
Objection:
The Crystal Palace Foundation objects to the Café and Dinosaur Interpretation Centre.
Zone G – Cricket Ground.
G 1. In Zone G, the Arboricultural Survey Appendix 5: SITE PLAN (Masterplan application document Technical Appendix 3.1B to the Environmental Statement (Main Document)) shows that each of the trees on and immediately surrounding the location described in the application as Park Rangers Building (Ref 10), falls within one of the two BS 5837: 2005: 4.3.1 retention categories, i.e. B – T1221: semi-mature Leyland cypress; T1222: early-mature eucalyptus; T1223: early-mature sycamore, or C – G1224: young Lawson cypress; T1226: semi-mature ash; T1227: young Lawson cypress, none is shown as category R (tree for removal).
The Arboricultural Survey Appendix 1: TREE DESCRIPTIONS AND RECOMMENDATIONS (Masterplan application document Technical Appendix 3.1C to the Environmental Statement (Main Document)) reflects the Survey SITE PLAN in showing none of the trees above as recommended for removal. However, the TREE REMOVAL AND RETAINMENT PLAN (Parameter Plan 4 (PP4) at the Masterplan Design & Access Statement Volume 2, Appendix 3) shows all of the above trees to be removed.
The irony is that to insert a Park Rangers’ building trees must be removed.
Objection:
In Zone G, it must be possible, given the disposition of tree cover, to accommodate a building in this vicinity without removing any of the trees detailed above. Therefore the Foundation objects to the proposal for a Park Rangers Building at this location if it means a loss of any of the trees as set out in this application. The Foundation reserves the right to comment on the detailed design of any building proposed here.
Sydenham Residential (Ref 11)
G 2. The applicant may see the Sydenham Residential proposal as the appropriate re-use of previously developed land. However, whereas PPS3 may be used elsewhere to justify developments on backland, garden and ‘windfall’ sites, this Park is none of those and should not be treated as if it were.
G 3. Built development here will neither preserve nor enhance the character or appearance of open parkland in the Conservation Area; rather, it is essentially designed to imitate the existing Arts & Crafts-style houses that are outside this boundary of the Park.
G 4. This proposal is said to be primarily a means to funding improvements to the Park, but the local planning authority must not allow Crystal Palace Park to be treated in the same way as any other back garden. Setting such a precedent will mean that countless other areas of this Park will be seen as fair game for the primary purpose of fund-raising for future Park works.
G 5. Additional comments: 1. It is said that the new buildings should relate to the scale and character of the existing villas. The Masterplan Design & Access Statement, Vol. 2, Appendix 2: Pattern Book offers an illustrative photo-collage showing a potential option for the proposed villas in relation to existing villas along Crystal Palace Park Road. The proposed buildings appear to be of greater height than the existing villas. And whilst the elevations are of interest, they could not be described as reflecting Arts & Crafts style. 2. It is said that the development would help define the edges of the Park – housing should not be a definer of Park edges. 3. It is said that the development would create a sense of place – the sense of place already exists and would not be enhanced by this proposal.
4. If this proposal proceeds, will its footprint remain within the designated Conservation Area and the Grade II* listed Park in perpetuity? Or will these designations be removed under future changes brought forward in Local Development Documents and incorporated into the Local Development Framework – and the currently defined boundary of the Park then reconfigured so as to show the built development as being outside the Park – as are the other villas alongside? If this is the ultimate intention or the likely scenario then, prior to the determination of this application, should not the matter of residential development here be the subject of public examination before the Planning Inspectorate?
G 6. In 2005 the matter of housing was discussed within the Crystal Palace Park Dialogue process. Subsequently, in December 2005, the Foundation adopted the policy of opposition to the principle of further encroachment by housing on Crystal Palace Park. Therefore:
Objection:
In Zone G, in the light of its adopted policy, and consistent with the arguments above, the Crystal Palace Foundation objects to the Sydenham Residential proposal.
Zone H – English Landscape.
H 1. Within this Zone is shown a proposal for Rockhills Residential (Ref 08).
Trees: The Arboricultural Survey Appendix 5: SITE PLAN (Masterplan application document Technical Appendix 3.1B to the Environmental Statement (Main Document)) shows that each of the trees on and immediately surrounding the Rockhills Residential location falls within one of the first three BS 5837: 2005: 4.3.1 retention categories, i.e. A (retention most desirable), B (retention desirable) or C (tree which could be retained); none is shown as category R (tree for removal). The Survey’s SITE PLAN legend includes the following: ‘NB. These categories do not necessarily represent or correspond to recommendations for action taken in this report.’
H 2. In fact, with regard to the trees on this area, the Arboricultural Survey Appendix 1: TREE DESCRIPTIONS AND RECOMMENDATIONS (Masterplan application document Technical Appendix 3.1C to the Environmental Statement (Main Document)) reflects the SITE PLAN (see H 1 above) in showing that none is recommended for removal.
So the Arboricultural Survey reflects an aim of BS 5837, in that it provides the basis for considering how to retain and accommodate one of the Park’s key assets – its trees – within a proposed development site.
H 3. However, a TREE REMOVAL AND RETAINMENT PLAN appears as Parameter Plan 4 (PP4) at the Masterplan Design & Access Statement Volume 2, Appendix 3. This PLAN does not appear within the text of the Arboricultural Survey document produced by JCA Ltd (Masterplan application document Technical Appendices 3.1A, 3.1B, 3.1C). But the PLAN’s legend does give credit to JCA thus: ‘ARBORICULTURAL SURVEY by JCA Ltd…’
Whilst this acknowledgment may be a noble action on the part of the PLAN’s authors, it unfortunately creates the impression that JCA in some way endorses the burden of actions proposed in the PLAN and, in particular, those relating to the removal of category A, B and C trees on and immediately surrounding the Rockhills Residential location. However:
H 4. No such endorsement is contained within the Arboricultural Survey.
Indeed, its author says:
6.1.1.4 Northern section. This includes an area of semi-derelict woodland in the open land to the north of the radio mast (containing occasional massive oaks) and the Caravan Club facility, formerly the site of Rockhills; Paxton’s home.
6.1.1.5 The Caravan Club site provides an outstanding example of good tree management. There are some fine, large Oaks, Limes and Beech in this area, but also plentiful new planting including a delightful line of Evergreen Oak. There are remnants of a path system – probably dating back to Paxton’s period of tenure – in the wooded area alongside Old Cople Lane.
and
6.3 I understand that a number of alterations are proposed for the park over the coming years. I am unaware of the specific details of any proposals. However the following comments can be made about the site in terms of its suitability for development:
6.3.3 Decisions about which trees are to be retained should be influenced by their retention categories as suggested below.
6.3.3.1 Category A trees: These are high quality, high amenity trees which should be retained if at all possible. Significant amendments to any proposed development should be considered before removing these trees. These are marked green on the plan.
6.3.3.2 Category B trees: These are reasonably high quality trees whose retention is desirable. Minor amendments to any proposed development should be considered before removing these trees. These are marked blue on the plan.
6.3.3.3 Category C trees: These are lower quality trees, the removal of some of these should be considered acceptable, if required to facilitate any proposed development. These are marked grey on the plan.
H 5. One of the reasons given at Masterplan Environmental Statement (Main Document), 5: Alternatives and Design Evolution for the selection of the current configuration of the Rockhills proposal is given as: ‘5.66…the retention of mature trees.’ However, the authors of the TREE REMOVAL AND RETAINMENT PLAN appear to have paid little attention to the Arboricultural Survey recommendations regarding amendments to the configuration of a proposed development so as to accommodate trees – other than to retain two mature, category A oaks, as shown in drawing 5.3 of the Masterplan Environmental Statement (Main Document) 5: Alternatives and Design Evolution - Figures. Instead, the optimised option at 5.3 appears to show that the proposed residential blocks have simply supplanted an area rich in mature and semi-mature trees worthy of retention – as described in the Arboricultural Survey and listed below; (a plan showing the outline footprint of the proposed buildings superimposed upon the existing trees would have been helpful here).
H 6. The following is a categorised and quantified list of those trees currently on the proposed Rockhills Residential location that are planned for removal under the TREE REMOVAL AND RETAINMENT PLAN; descriptive notes are taken from the Arboricultural Survey:
Category A (retention most desirable). T665: early-mature horse chestnut; T658: early-mature sycamore; T659: early-mature sycamore.
Total: 3 trees.
Category B (retention desirable). T642: mature laurel screen; T644: semi-mature aspen; T649, 650, 651, 652, 653, 654, 655, 656, 657: nine young evergreen oak*; T660: early-mature sycamore; T661: semi-mature redwood; T663: mature birch; T664: early-mature sycamore; G666: early-mature holly/yew/laurel; T676: semi-mature birch; T679: semi-mature birch; T682: young lime.
Total: 17 trees, 1 screen and 1 group.
* Described in the Arboricultural Survey as ‘…a delightful line of Evergreen Oak.’
Category C (trees which could be retained). T644: semi-mature aspen; T662: early-mature yew; T667: early-mature sycamore; T668: mature cedar of Lebanon; G669: young holly; T670: young lime; T671: young false acacia; T672 young flowering cherry; G673: young Leyland cypress (2); T674: young birch; T675: young birch; T677: semi-mature birch; T678: semi-mature birch; T680: semi-mature birch; T681: semi-mature cherry.
Total: 13 trees and 2 groups.
Total proposed for removal in categories A, B and C:
33 trees, one screen and 3 groups.
Objection:
In Zone H, the Crystal Palace Foundation objects to the removal of so many category A, B and C trees at Rockhills Residential, since no amount of planting here or elsewhere on the Park would mitigate their loss – with which would also be lost the very character of this area, so aptly described in the extracts from the Arboricultural Survey at H 4. 6.1.1.4 and 6.1.1.5 above.
Rockhills Residential (Ref 08)
H 7. The area proposed for development here is within that designated as Metropolitan Open Land (MOL) in the London Borough of Bromley’s adopted Unitary Development Plan (UDP). The appropriateness or otherwise of any new building within MOL is discussed at Policy G2 of the UDP.
1. An examination of UDP Policy G2 clearly shows that the proposed development first fails the appropriateness test on five counts, in that it does not comply with any of the purposes at G2(i), G2(ii), G2(iii), G2(iv) or G2(v).
2. Further, if the applicant or the local planning authority considers this proposal to be a material change of use (which it clearly is), it remains inappropriate under Policy G2 in that it will neither maintain the openness nor be consistent with the purposes of including land in MOL.
3. The proposal for residential development here represents a departure from the adopted UDP – a departure that is inappropriate and unacceptable.
4. The applicant may argue that to build here would create openness elsewhere, i.e. at the caravan site. But the applicant cannot adopt a ‘Rob Peter to Pay Paul’ argument. Instead, the proposal site must be considered discretely and, when so considered, it would not be open in terms of public accessibility but, instead, a restricted, private residential development on a public park, separately leased for specific, exclusive use (albeit that the public may wander about its exterior). This observation is particularly potent and compelling when considered in the context of paragraph 3.2.4. of the Masterplan Design & Access Statement, Vol. 1 (Main Document) reproduced here, which shows that rather than insert areas of private and exclusive use, the Masterplan seeks to remove them:
3.2.4 Public and private spaces
Public space in Crystal Palace Park comprises 90% of the Park area, but its coherence as a Park is disrupted by areas that are subject to separate leases for specific, exclusive use - from fishing to broadcasting.
These areas create fragmentation by:
• Their restrictive and, in some cases, inappropriate uses
• Single use elements and spaces
• Inappropriate zoning
• Lack of permeability in terms of access and visually through these spaces
• Lack of connection with the rest of the Park.
The Masterplan seeks to remove areas of private and exclusive use and to improve access, park facilities, education facilities, interpretation options and events of every scale. It aims to help reclaim the Park’s former status as an essential destination for local, national and international visitors and, in doing so, contribute to the environmental, economic and social vitality of the area.
5. Despite the applicant’s arguments to the contrary, there are no very special circumstances that would clearly outweigh the harm to MOL that would be caused by the inappropriateness of this proposal. In fact, the Park enjoys its own very special circumstance by virtue of the designations attached to it, e.g. as Grade II*, Metropolitan Open Land, Conservation Area, Site of Archaeological Importance and Site of Importance for Nature Conservation.
6. In its Planning Policy Schedule the applicant’s response to paragraph 23 of PPS1 is to openly state that the Rockhills development is primarily a means to funding improvements to the Park. This immediately categorises the proposal as ‘enabling development’, i.e. this is its primary purpose. This is not appropriate in the context of Policy G2.
7. Whereas PPS3 may be used elsewhere to justify developments on backland, garden and ‘windfall’ sites, this Park is none of those yet the applicant appears to be treating it in the same way.
H 8. If the local planning authority allows Crystal Palace Park to be treated in the same way as any back garden, on any side street, it will have set a precedent under which countless other areas of this very special Park will be seen as fair game for the primary purpose of raising funds for future Park works.
The local planning authority must not allow this precedent to be set.
H 9. Additional comments: 1. The Rockhills residential proposal will neither preserve nor enhance the character or appearance of the conservation area. 2. It is said that the development would provide natural surveillance in an area of the Park where needed – why is such surveillance needed here, and where else is it needed but perhaps not provided, e.g. around the proposed greenhouse areas? 3. It is said that the development would help define the edges of the Park – neither flatted developments nor housing should be a definer of Park edges. 4. It is said that the development would create a sense of place – the sense of place already exists and any such development, and its associated level of tree removal, would only serve to weaken it.
5. If this proposal proceeds, will its footprint remain within the designated MOL area, the Conservation Area and the Grade II* listed Park in perpetuity? Or will those designations be removed under future changes brought forward in Local Development Documents and incorporated into the Local Development Framework – and the currently defined boundary of the Park then reconfigured so as to show the built development as being outside the Park?
If this is the ultimate intention or the likely scenario then, prior to the determination of this application, the matter of residential development on this Park should be the subject of public examination before the Planning Inspectorate.
H 10. In 2005 the matter of housing was discussed within the Crystal Palace Park Dialogue process. Subsequently, in December 2005, the Foundation adopted the policy of opposition to the principle of further encroachment by housing on Crystal Palace Park (which appears to accord with the prevailing public mood). Therefore:
Objection:
In Zone H, in the light of its adopted policy, and consistent with the arguments above, the Crystal Palace Foundation objects to the Rockhills Residential proposal.
H 11. Continuing in Zone H, the Arboricultural Survey Appendix 5: SITE PLAN (Masterplan application document Technical Appendix 3.1B to the
Environmental Statement (Main Document)) shows that each of the trees on the location described in the application as North Greenhouse (Ref 09), falls within one of the first three BS 5837: 2005: 4.3.1 retention categories, i.e. A (retention most desirable), B (retention desirable) or C (tree which could be retained); none is shown as category R (tree for removal).
H 12. The following is a categorised and quantified list of those trees now on the proposed North Greenhouse location that are planned for removal under the TREE REMOVAL AND RETAINMENT PLAN; descriptive notes are taken from the Arboricultural Survey:
Category A (retention most desirable). T1603: early-mature yew; G1607: early-mature oak (group); W1611: mixed unmanaged woodland area. Largely self-sown ash, sycamore and holly. Good habitat, hazel and hawthorn understorey. Action: remedial prune.
Category B (retention desirable). G1604: early-mature oak; G1605: early-mature oak; G1608: early-mature oak.
Category C (tree which could be retained). G1606: semi-mature holly.
H 13. To strip the Park of this number of healthy and good specimen oaks, together with a yew, and what the Arboricultural Survey describes as a valuable mixed woodland habitat is unacceptable – particularly since this area falls within the designated Site of Importance for Nature Conservation, not to mention its Metropolitan Open Land and Conservation Area designations.
H 14. At 6.9.6 of the Masterplan Planning Statement the North and South Greenhouses are discussed. It is said that despite the significant size of the structures, the use of lightweight material and glazing will minimize impact upon the landscape. This is disputed, since their insertion will require the removal of significant numbers of trees. It is also said that the greenhouses are not dissimilar to the original Crystal Palace design. However, despite it being said that they have glazing articulation to reflect the original Palace grid, the proposed structures appear to owe nothing to Paxton’s design; even the roof is single pitched glazed, with east facing opening lights, paying no homage whatsoever to a Paxton signature feature – the ridge and furrow roofline. And as with the proposed South Greenhouse, security is paramount.
Objections:
In Zone H, the Crystal Palace Foundation objects to the insertion of the North Greenhouse here, a structure which, despite statements to the contrary, owes little to Paxton’s design for the Crystal Palace or of its ‘wings’.
Further, the Crystal Palace Foundation objects to the removal of this valuable sylvan area in Zone H in order to accommodate the North Greenhouse.
Treetop Walkway – Observations:
If built, would this compromise the park’s Grade II* listing? Is it consistent with and appropriate under the UDP’s MOL policy? Will it preserve and enhance the character and appearance of the conservation area? Would scarce financial resources be better spent on the restoration of original features (see The Crystal Palace Marine Aquarium ADDENDUM)?
Aquarium Mist Garden, Zone H
See: The Crystal Palace Marine Aquarium ADDENDUM.
Yours sincerely
K R Lewington, Trustee –
for and on behalf of Crystal Palace Foundation Trustees
ADDENDUM:
The Crystal Palace Marine Aquarium
APPENDIX:
Crystal Palace Park Dialogue:
Main Group Masterplan Questionnaire Responses.
(Supporting document with agenda for Main Group Meeting of 17th May 2008).
www.crystalpalacefoundation.org.uk
ADDENDUM to Crystal Palace Foundation Objections to and Observations on Outline Planning Application DC/07/03897OUT and Conservation Area Consent Application DC/07/03906/CAC, Crystal Palace Park, SE20 8DT
Zone H: Proposed Aquarium Mist Garden.
The Crystal Palace Marine Aquarium
Site workers from the Crystal Palace Foundation have been involved with the excavation of the Aquarium since the early 1980s. Much about the history of the site and its significance in the world of aquaria has been gleaned in this time, and the learning process continues.
Built in 1871, it was briefly the largest of its type in the world, holding 120,000 gallons of seawater, of which 100,000 gallons were held in large reservoirs below floor level. There were 60 tanks in all, of which 38 were for the public and the rest for private research. At any one time over 300 species were on display. The aquarium was built on part of the site left vacant by the 1866 Crystal Palace fire and was a popular fad of the day – a the first public aquaria had been set up by Phillip Gosse at London Zoo in 1853.
What made the Crystal Palace Aquarium special was the fact that it was a marine and not a freshwater exhibit. No one before had created a working marine aquarium of this scale and diversity. The Crystal Palace was lucky to secure the services of William Alford Lloyd, the leading aquarist of his day, who developed a system of continuous circulation of the water, which was kept in the dark as much as possible and at strictly governed temperatures. Machinery to achieve this was doubled up to ensure the continuous flow. Excavations of the reservoirs have also shown that declivities were built into the system. These were designed to increase the ‘scouring’ action of the water and make the system as natural as possible. The rock face extant in tank 18a is also significant and probably the only one of its type left from this period.
Although not a commercial success, the site is regarded throughout the aquarium world for its technical merit and innovation. Excavations have yielded samples of the vulcanite piping that the water ran through, which was quite cutting edge for its day but necessary, as seawater could not travel through metal conduit. Charles Darwin is said to have been a regular visitor.
The Crystal Palace Foundation is keen to conserve and preserve what is left of the site (approx 25% of the original) in its current form. It has a place both in the history of the Crystal Palace and the world of aquaria and is, of course, one of the more tangible parts of what still remains.
Observation:
Whilst feeling that a mist garden would not be appropriate, the Crystal Palace Foundation would be glad to provide alternative suggestions for the site if called upon.
Martin Frelford, Vice-Chairman, Crystal Palace Foundation, June 2008.
APPENDIX to Crystal Palace Foundation Objections to and Observations on Outline Planning Application DC/07/03897OUT and Conservation Area Consent Application DC/07/03906/CAC, Crystal Palace Park, SE20 8DT
Crystal Palace Park Dialogue: Main Group Masterplan Questionnaire Responses.
(Supporting document with agenda for Main Group Meeting of 17th May 2008).
Nineteen responses were returned. The responses have been transcribed and are collated according to topic below.
HILLTOP
Topic: Tree Planting (Tree Palace)
Location: Hilltop
What concerns you about it? How would you like it to be changed?
Boring. Regimented. [The trees] should not be used to hide any overspill car parking. The bus terminus/ tram terminus should not be extended any further onto the Hilltop. Use some imagination. Use indigenous tree species. Use the area for the ‘little Crystal Palace’ [a greenhouse on the Hilltop over the subway entrance, housing community arts facilities, a museum, butterfly house and viewing platform], cafes, playgrounds, keep fit exercise walks. In other words treat this Park as a park, not a prime building location as your starting point.
It has little support as indicated by dotting exercise – it is an insult to the history of the site - it does not capitalise on the brand name or history of the site (could be used to regenerate the whole of South London and provide 1000 local jobs). Not what majority want on the site. Excludes the Crystal Palace ever being rebuilt.
Consider building a new Crystal Palace, which has £265 million private funding and would provide funding for the park on an ongoing basis.
Unimaginative, a small replica palace would be much more appropriate.
No car parking allowed and small palace in its place as Ray Hall’s plan.
Topic: New Museum Building
Location: Crystal Palace Parade
What concerns you about it? How would you like it to be changed?
So far the Museum Building doesn’t look like the icon the Park needs on Crystal Palace Parade. Its commanding position on the Parade is such that the building needs to be of exemplary and innovative design.
Topic: Upwind Tower
Location: Near Museum
What concerns you about it? How would you like it to be changed?
This was not consulted on and people do not want this looming over the town. I want this idea to be scrapped.
TERRACES
Topic: Glasshouses
Location: Italian Terrace
What concerns you about it? How would you like it to be changed?
The greenhouses are wrong in this location – hidden and therefore prone to vandalism. A greenhouse on the Hilltop over the subway entrance, housing community arts facilities, a museum, butterfly house and viewing platform would give the area a new Crystal Palace. It would be a fitting landmark building.
The size and positioning and also the “square box” design.Use a similar design for the glass and shape of the building for how Crystal Palace looked.
Too big, too ambitious, too expensive to maintain, too ugly.Transfer to a position near the subway, where there might be a museum or small gallery, and a butterfly house. Make this a more modest, less expensive greenhouse, which reflects a little, the shape of the old palace.
No need for them. It does not make a park.
Give more for the children: a zoo.
Topic: Sunken Gardens
Location: Italian Terrace
What concerns you about it? How would you like it to be changed?
The sunken gardens are a totally unnecessary expense in construction and maintenance. They ruin the only flat open space in the park.
Abandon the sunken gardens.
The expense! Everything possible should be done to reduce the expense, and this is attractive but unnecessary!
Concentrate on the general landscaping - that is, removing much of the concrete and ‘greening’ the park and restoring the terraces (which are the main asset of the Park) and making the Park a beautiful green area for rest and recreation. Nothing is ever said about the cost of maintenance - the simpler the park the less it will cost to maintain.
Topic: Removal of Large Trees for Glasshouses, Paths etc.
Location: Italian Terrace
What concerns you about it? How would you like it to be changed?
Large trees should have priority in the park and any development plans – glasshouses, paths etc should be adjusted to preserve large trees.
No large trees to be felled, decaying trees should remain standing, with paths moving rather then felling the trees.
ENGLISH LANDSCAPE
Topic: Treetop Walkway
Location: English Landscape
What concerns you about it? How would you like it to be changed?
This park serves an ever-growing residential population who need green open space. Do not turn this park into Disneyland. A treetop walk is a stupidly expensive-construction, maintenance, security – ugly blot on a wonderful landscape – the rusty heap of a rotting (literally) concert platform is bad enough.
Scrap the idea completely and think “parkland”.
There is more to this than I first thought! It can not only allow people to see the treetop canopy from close up, it can also provide views of the surrounding Park and could be of natural materials, like the tree-house walk at Alnwick (in Northumberland).
This is a ridiculous, criminal waste of money! This park is not Kew Gardens with a forest of big trees – it would have to be artificially manufactured at huge expense – a monumental waste of money (those attracted by it probably have no idea how much it would cost).
I would like the whole stupid idea to be abandoned. Just concentrate on keeping grass, shrubs and trees; tended and replaced when necessary.
Topic: Concert Bowl Lake
Location: Near Concert Bowl
What concerns you about it? How would you like it to be changed?
Don’t want it filled-in or changed.
I would not like it changed.
Cont’d
PARK EDGES
Topic: Removal of Large Section of Earth by Proposed West Greenhouse
Location: Left-Hand Side of Cintra Gate
What concerns you about it? How would you like it to be changed?
The wildlife corridor and natural screening from the road by this hilly section will be lost. No advantage what so ever!
Do not remove this section of hill to facilitate the tram route!
Topic: Lowering and Opening Edges
Location: Anerley Hill Edge
What concerns you about it? How would you like it to be changed?
Lowering the hill will destroy trees, habitat for wildlife: when in the park I enjoy the park being edged by traditional ‘pre-Victorian’ hedging 30” wide not viewing busy traffic and breath fumes and listening to it!
The Anerley Hill edge should not be opened up, the edge should not be lowered, the trees and shrubs should not be destroyed.
Topic: Removal of Park Railings
Location: Anerley Hill
What concerns you about it? How would you like it to be changed?
The railings and walls are quite nice, and I cannot see any logic in their proposal to remove them.
Don’t change it – leave the railings.
Topic: Traffic
Location: Anerley Hill Edge
What concerns you about it? How would you like it to be changed?
The idea of opening up the views of the park are excellent. However, not much attention has been paid to the high-speed traffic (lots of it) travelling down the Hill.
The same could be said of the Norwood Gate where the integration of the park with the Triangle, hampered by the volume of traffic, does not seem to have been solved.
Are there some schemes for traffic calming and a careful separation of pedestrians and motorised traffic? How about bicycle routes?
PARK EDGES (continued)
Topic: Removal of Boundary Fences
Location: Park-Wide
What concerns you about it? How would you like it to be changed?
My sole concern was the idea of (as I understood it) removing all the boundary fences. I wonder if this would create security issues at night – chiefly raising opportunities for vandalism, but also (in unlit areas) making the Park a less welcoming place to walk across.
Topic: Bus Garage
Location: Norwood Gate
What concerns you about it? How would you like it to be changed?
Ugly.
Move it to the caravan park.
NEW LODGE
Topic: New Lodge
Location: Ledrington Road Green
What concerns you about it? How would you like it to be changed?
Its design and size. It’s obvious impact on the amenities of the local residents. There is no justification for this building. This building can be removed from the whole masterplan, thus giving us more park as a result.
It will destroy trees, the biodiversity of the green, it will cover the whole green; it is huge, too high, it will rise above the terraces, it is being planned to cover land that has always been used by the community – it will cause many birds/butterflies/and small mammals to lose their home.
Nothing should be built on Ledrington Green; colleges should be built on land that has/or has had a building on it. Flats and hotels should not be built on parkland!
It’s inappropriate use for Capel Manor (the thin end of the wedge in this regard), the size and the inappropriate location. It should be an athlete’s hostel only, much smaller and located between the railway line and Ledrington Road towards Capel Manor, not as a huge visual intrusion to this entrance to the Park.
The design (so far) looks like a huge ugly block. Please make the hostel more sympathetic to its surroundings, blend with houses on Anerley Hill, in the area and with the Park.
Please make the hostel more sympathetic to its surroundings, blend with houses on Anerley Hill, in the area and with the Park.
The hostel does not need to be right in front of the Anerley Hill houses.
The site is unsuitable, being greenfield adjoining Metropolitan Open Land, and would seriously affect local residents – loss of open space, light (five-storey building) and parking. Likely to depress property values.
Reconsider how much accommodation is really needed, whether for athletes or Capel Manor, and find another site. Not having to construct a platform over the railway tunnel would save money.
The ‘masterplan’ was designed to improve the parkland yet this building will be constructed on green land at one of the park’s main entrances. The design is oversized for the location and will ruin the views of the park on arrival from the station or Anerley Hill. There will be an obvious impact on the residents in the area.
A new location should be found and consideration into whether this will still be required when this is not a national sports centre. Surely it would make more sense to incorporate this into the design of the new leisure centre of perhaps even the old building when refurbished. Failing this, a less intrusive location should be found where there would be no impact on the Park and residents.
NEW LODGE (continued)
Topic: New Lodge
Location: Ledrington Road Green
What concerns you about it? How would you like it to be changed?
It’s taking away a piece of the park that is currently used by residents of the area.
It’s big and will overshadow our houses and change the peaceful area at the rear of our properties.
I don’t think it’s needed based on what we’ve been told!This building should not be built on this part of parkland – and perhaps not at all on the Park considering some of the usage is for Capel Manor? Can the accommodation facilities for the downgraded National Sports Centre not be incorporated elsewhere, in a less intrusive spot i.e. not on already utilised, loved and regarded parkland?
It is a tall and large building that will affect the lives of all residents on Anerley Hill and access to the only garden we have.
To object/refuse the plans as this building is not necessary and should be removed from the masterplan.
Its design and size (out of keeping with adjacent houses and towering over them) and its obvious impact on the amenities of the local residents. It will destroy the view from our living room, second bedroom and roof terrace. Complete loss of privacy from this giant of a building.
There is no justification for this building whatsoever and it can be removed from the whole masterplan giving us more park as a result.
Its size, which is huge, means it will overpower the houses in the area. We will no longer have privacy or any kind of view from our windows or roof terrace – which was the main reason for purchasing the property in the first place. The design is also out of keeping with the area.
I would prefer the building to be removed from the masterplan. It is not a vital building at all. As a community we would benefit from more park area. I believe London as a city would benefit from a more beautiful, green area without a huge building put in.
This building is massively oversized for the plot and will have a major detrimental impact on its neighbours. It is not in fitting with the local environment. There is no need for this building – an option the London Development Agency (LDA) has not considered! Remove this building from the masterplan: One less building in the Park/ greenbelt/ conservation area adjacent to Metropolitan Open Land.
The affect it is going to have on the Ledrington Road residents.If the building was removed it would open up the Park to the residents. Why does it need to be there?
TRAM
Topic: Tram
Location: Anerley Hill
What concerns you about it? How would you like it to be changed?
Extending the tram further than Crystal Palace station is not appropriate, will ruin this area of the park and should not be facilitated by the masterplan.
Stop the proposed tram at Crystal Palace station. There is no necessity to waste huge sums of public money flattening this area – only to benefit Transport for London.
The route will decimate a “wildish” area of woodland, and also seriously disrupt Anerley Hill residents overlooking it, plus the double whammy of the Lodge building as well.
Put the tram on the road if it really needs to come to Crystal Palace (for which I do not think we need the tram).
I strongly support Tramlink leading to the Triangle. I don’t mind how it gets there but it’s important that one or more stops serve the Park and (at least very close by) Crystal Palace railway station.
On balance, I think that I favour a Park route so long as it does not “marginalise” part of park by placing it on the “wrong side of the track”. The Masterplan will need to reflect Transport for London’s decision.
ROCKHILLS
Topic: Retain the Caravan Club/No to Housing at Rockhills
Location: Rockhills
What concerns you about it? How would you like it to be changed?
The campsite is extremely valuable to local residents, visitors and to the Park. It brings commerce to the Triangle, it is a perfect position near bus and train routes for visitors who must find it a lovely introduction to this country (if they are foreign) and because it has so many trees and shrubs keeps the green aspect of the park.
So to build over this area, or any of the Park, would be sacrilege and defeat the object of a park – to provide green space for residents and visitors. The camp-site also contributes financially.
What concerns you about it? How would you like it to be changed?
Loss of historic association between club and park. Loss of income to the local community.
Loss of income to the park in terms of rent.
There will be no overall gain to the Park, will reduce its security and will add considerably to the overall cost. The Caravan Park has never been inside the Park.
The LDA and masterplanners have made it abundantly clear that they are not prepared to consider any changes although the club has demonstrated a willingness to talk on a without prejudice basis.
Topics: No to Housing at Rockhills
Location: Rockhills
What concerns you about it? How would you like it to be changed?
Everything! It is criminal to even think of building on precious open space – a public park which should be preserved forever for public recreation, green space and fresh air.
These plans should be consigned to the dustbin, where they belong. Leave this space open parkland. Concentrate on refurbishing/refreshing the park as simply as possible, so that this sort of investors paradise not even be thought of!
HORTICULTURE
Topic: Capel Manor Horticulture Students
Location: Crystal Palace Park
What concerns you about it? How would you like it to be changed?
What guards/ regulations will be in place to stop over-pruning/ incorrect pruning of plantings in the park.
With 260 pupils there need to be clear guidelines on what plants/areas Capel Manor will be able to work in, and inspections to limit over-pruning.
BIODIVERSITY
Topic: Clearing Out Undergrowth and Dead Trees
Location: Park-Wide and Edge of Railway Cutting
What concerns you about it? How would you like it to be changed?
Bushes and heavy undergrowth provide a safe environment for small birds, mammals and insects to breed and live. To rethink the park redesign, taking account of the need to provide some ‘wild’ environment to promote and preserve the native wildlife rather than extermination of their habitat.
WATER
Topic: Water Features
Location: Park-Wide
What concerns you about it? How would you like it to be changed?
I don’t think enough has been made of water in the Park. The integration of the water system satisfies operational but not necessarily aesthetic needs. I have always thought that we could do with a multi-purpose space rather like the courtyard at Somerset House which could not only accommodate water features in summer but also an ice-rink in winter. Further there should be some moving water, not on the Paxton scale but sufficient to draw attention to the park. Water noises are sometimes a useful way of masking traffic noises. The water areas should be structured in such a way that there is a degree of flexibility. For example, the ponds and other areas could be prepared, by having plinth-facilities built into them, to accommodate changing displays of sculpture, which could change from time to time.
[A water feature] was set up for Princess Diana but I think it comes from Hyde Park.
But there’s no need for one that is secure.
SPORTS
Topic: National Sports Centre
Location: Park Centre
What concerns you about it? How would you like it to be changed?
Will it happen?
I would like guarantees that it will happen.
Central location means that athletes and spectators have reasonable expectations about access, especially by car, which is contrary to other park usage.
Tramlink into park. Could help with access to National Sports Centre including athletic events. Ideally I would demolish National Sports Centre and rebuild essential facilities at periphery, preferably adjacent [to the] railway station!
No need for one, it’s a park – a place for flowers and things, so little ones and family and all can see the wonders.
Think, but not [about] money. It can be done.
PARK FACILITIES
Topic: Skateboard Park
Location: Unknown
What concerns you about it? How would you like it to be changed?
What guarantees do we have that it will happen?
Would like guarantees.
Topic: Caravan Club, One O’Clock Club, St John’s Ambulance Facility
Location: Rockhills and Sydenham Gate
What concerns you about it? How would you like it to be changed?
The camping and caravan site is a well-used public facility, appropriate to Metropolitan Open Land. It brings business and tourism to the area and the park – just what the London Development Agency (LDA) wants. To replace with huge private blocks of flats is immoral and not appropriate use for public parkland.
Scrap all housing proposals. Keep the Caravan Club – Old Cople Lane can be improved without sale of parkland. If “infilling” is required at the edge of the Park, fill with adventure playgrounds and a café, appropriate uses for a park!
ENTIRE MASTERPLAN
Topic: Masterplan
Location: Park-Wide
What concerns you about it? How would you like it to be changed?
The lot. Housing: no one wants that, and we all know that??? But it is driving ahead.
The masterplan is a detailed, well-researched and innovative document reflecting a comprehensive view for the regeneration and future of Crystal Palace Park. It also is highly practical and presents concepts and solutions, which can actually be achieved.
Nevertheless, there are a few general areas, which could do with more attention.
I would just like to take this opportunity to say again that I was very impressed with the Masterplan and would struggle to find more than one aspect of it that I would change.
Topic: Overall Urbanisation and Architectural Approach
Location: Park-Wide
What concerns you about it? How would you like it to be changed?
It threatens to destroy the natural, open aspect of the Park as a quiet refuge to visitors to the area and local residents alike.
It also adds considerably to the overall cost although presumably will justify the doubtless large sum already spent on fees.
A change of approach – a Bushey Park solution to a situation, which hardly needs much fixing.
Topic: General Openness
Location: Park-Wide
What concerns you about it? How would you like it to be changed?
Is the Park too open all round? The desire to have ‘views’ may inadvertently have reduced the quiet secluded zones.
Within the constraints of security, it should be an aim to allow people to ‘get lost’ if they wish so that new and surprising sections of the Park (and views) are opened up as they walk through the Park. Paxton’s Axis may allow a long view of the whole park but shouldn’t open up everything from a single place.
PLANNING
Topic: Detailed Design Phase
Location: Park-Wide
What concerns you about it? How would you like it to be changed?
The Masterplan, by its nature, does not contain ‘finished details’. These will be crucial to the success of the park regeneration. It will be at the detailed design phase that the realisation of the various concepts will have to be finalised. So questions like energy conservation will need positive and defined answers in all the buildings around the park - not only the houses. The use of, say, photo-voltaic cells to generate electricity and ground source heat exchange for renewability need to be considered and fully justified.
FUNDING
Topic: Funding
Location: Park-Wide
What concerns you about it? ow would you like it to be changed?
Did anyone think about the funding for the Park before they started? But housing: “Yes”. Money for ‘old rope’.
No Fat Cats living off the deal.
And then accommodation and classrooms for students; more money for the Big Boys and the London Borough of Bromley and the London Development Agency (LDA). Honey in the pot. Where’s the Park???
We are generally content with the proposals in the masterplan and are not pressing for changes.
Because of uncertainties in full funding, priority must be given to the essential “greening” of the centre of the Park and the restoration of the Terraces.
GOVERNANCE/DECISION-MAKING
Topic: Governance/Decision-Making
Location: Park-Wide
What concerns you about it? How would you like it to be changed?
I’m sorry, but it’s sad to see the London Borough of Bromley doing this when we know the five Borough Council’s could run the park with no trouble; but this is a rail road job by the London Development Agency (LDA) and the London Borough of Bromley, and the people have no say in the matter. As in the end the housing will go up and this crazy masterplan will go ahead.
ACCESS AND SECURITY CONCERNS
Railings
•There are some perfectly good railings around this park – keep them, improve them but don’t scrap them, then wonder why young men and women are dragged into the bushes, so the public have to then spend millions replacing them. Use public money for the public good – stop wasting it.
•The removal of the railings and walls on Anerley Hill.
•It would seem rash to remove, at great cost no doubt, the railings round the Park, when they might have to be replaced at a later date at enormous expense (i.e. ridiculous removal of railings round the ponds in the Dinosaur area….)
Fencing
•The fencing around the park should remain.
Lighting
•Lighting in park should be limited and of low intensity.
24 Hour Opening
This has been reasonably well addressed in the masterplan. It includes features which facilitate better visibility, improved lighting levels by day and night and clearly marked information points which should be manned. However, the practicalities of 24 hours opening need further discussion.
Housing at Park Edges
•Don’t use the pretence of housing as a method of security – aren’t the London Development Agency (LDA) ever embarrassed by such rubbish statements?
Caravan Club
•The loss of the Caravan Club will make this end of the Park [at Rockhills] less secure.
Greenhouses
•Vulnerability of the proposed greenhouses from vandalism.
Hilltop Tree Palace
•I do not believe that the top site tree palace will be a safe place for people to promenade. I believe that in the evenings it will provide a venue for boy racers and alcoholics lounging about on the benches and using the fountains as the public toilets.
Historical Features
•In the past, both the subway under the Parade and terraces have been targeted for graffiti and other vandalism. I strongly support restoration of these historic features but only to extent that results are safeguarded from future problems. Plans for subway (museum and space for dining area etc) would seem to offer built-in security, so long as access is always staffed. I don’t know an answer for terraces?
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