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Planning Policy
The inclusion of building houses on protected parkland in the LDA planning application for Crystal Palace Park:

• conflicts with Bromley’s adopted Unitary Development Plan,
• is contrary to government planning policy guidance PPG2 and PPG15,
• is contrary to the requirements of the Mayor’s London Plan, i.e. protection of open spaces, Metropolitan Open Land (MOL),
• and the requirement to demonstrate ‘exceptional circumstances’ as embodied within PPG15 and the London Plan has not been established. (Unless the LDA can prove otherwise, housing or buildings that are not ancillary to MOL are not acceptable.)
• The Mayor’s objectives (as detailed in his London Plan) state: “Protect and improve the green belt, Metropolitan Open Land, other designated open spaces …The Mayor will and boroughs should maintain the protection of MOL from inappropriate development.”
• The loss of the Crystal Palace Caravan Club* for housing is contrary to the Mayor’s London Plan, Policy 3D.9 MOL, which states: “ …land that includes open air facilities, especially for leisure, recreation, sport, arts and cultural activities and tourism which serve the whole or significant parts of London.”

Special designations

• Important mature trees will be lost to built development.
• The historic landscape of a Registered Grade II* Historic Park will be harmed, i.e. views within, into and out of the Park.
• Housing will threaten the Park’s natural wildlife habitats.
• Housing will conflict with the character of the Conservation Area as set out in Bromley’s SPG for the Crystal Palace Park Conservation Area.
• Housing is harmful to the setting of Listed Buildings i.e. structures – the terraces, the sports centre, the dinosaurs and the historic park.

Planning history

• The LDA are proposing changes in planning land-use terms e.g. from day nursery (Class use D1) to housing (Class use C3), but any changes of use cannot be made in an ‘outline’ application.

Site considerations

• It is accepted that the One O'clock Club, St John’s Ambulance centre and the lottery-funded Park Maintenance depot, although within the Park boundary are not on MOL, however their proposed relocation within the Park would result in a net loss of MOL and Grade II* registered parkland.

Surrounding area

• Housing will have adverse effects on the surrounding area and neighbouring properties from an increase in traffic, and major road infrastructure changes to accommodate access, e.g. changes to the road system at Sydenham Hill, Westwood Hill, Crystal Palace Park Road and Ledrington Road.
• Page 70 of the EIA Non-Technical Summary admits that the height, bulk and scale of the proposed residential developments “…are likely to cause a small number of adverse impacts…[to adjacent and existing properties]”
• The proposed design of the multi-storey blocks of flats is incompatible with the adjacent period buildings and conflicts with the small scale pattern of development in the conservation area.
• Blocks of flats on the periphery of the Park are contrary to the philosophy of the Masterplan, which advocates permeability (visual and physical) at the boundaries of the Park. Housing is visually damaging to the landscape and the setting.
• The road system is inadequate for the whole Masterplan; traffic chaos ensues when there is just a single large event in the Park.
• Sale of parkland for housing is a permanent loss of pubic parkland.
• Housing provides no employment except briefly during construction stage.

Notes:

• *The Crystal Palace Caravan Club is London’s only tourist camping and caravan site, and brings considerable economic benefits to the local and wider London area. Unlike housing, the area of parkland it occupies would easily revert to parkland should the Club decide to cease operating. Despite LDA claims to the contrary, there is public use of the site and its facilities.
• PPG means Planning Policy Guidance and is government statutory legislation with which boroughs must comply unless 'exceptional circumstances' can be proved.
• SPG means Supplementary Planning Guidance – These are planning guidelines drawn up by local authorities to emphasise aspects of PPGs.

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