Crystal Palace Campaign_UDP

(L.20) Unitary Development Plan (Second Deposit Draft)- Objections, October 2002

Some information in response to the many queries we have received.

Dear Crystal Palace Campaign Supporters,

Thanks so much for the many enquiries concerning the Second Deposit Draft of the Unitary Development Plan. I am pleased to append a table which the Campaign has submitted in response to the Draft. If you would like to adopt/adapt this for your own purposes, please feel free to do so. You will see that this is quite a short document which reflects the fact that at this stage of the process we can only make comment on added or deleted material. Our objection to the First Deposit Draft (see link below) was of course a much longer document. Our main objection was to the removal of the Metropolitan Open Land (MOL) designation of the top-site: regrettably Bromley has not restored the MOL designation in this Second Deposit Draft.

You will see that the new Draft seems to give an amber light for park and ride facilities in the Green Belt, whereas we believe that the light should remain red. It also strengthens the Council's resolve to designate the National Sports Centre as a Major Developed Site, which will weaken Green Belt control of the site, so we have reiterated and added to our objection.

You may also like to consider the removal in the Second Draft of "Area containing Crystal Palace Park" from the list of "Areas of Archaeological Significance" in Appendix IV (see the website link below). The Park is still covered by the Policy Planning Guidance, PPG16, "Archaeology and Planning" - but the removal of the Park from the list seems to re-inforce the general downgrading of the status of the Park in the eyes of Bromley Council**.

While some of these things may seem technical, they are important for preserving the Park in the long term, so please do take the trouble to get your comments to the London Borough of Bromley in time for the deadline which is 31st October 2002.

If you have any questions, please don't hesitate to get in touch*.

Kind regards,

Philip Kolvin,
Chairman

* in view of the short time to the deadline please contact our secretary directly
by phone: 020-8670 8486 or
by e-mail: VA.Day@ukgateway.net
**evidentally the top site has now been restored to the list of items of archaeological significance. (7/7/03)

The UDP details may be inspected

during normal office hours at the Civic Centre
at any of the Borough's Libraries
on the London Borough of Bromley website www.bromley.gov.uk (the revisions to the Proposals Map are not available on the website only the Written Statement)

Copies can be obtained

from the Civic Centre
by emailing a request to UDP@bromley.gov.uk subject: Unitary Development Plan (Second Deposit Draft)
by telephoning the UDP helpline on 020 8313 4730
by writing to the Planning Policy Group at

The Civic Centre
Stockwell Close
Bromley BR1 3UH

Other information:

Some background information, May 2001
Original Campaign submission to First deposit Draft, May 2001

The table below can be printed out on its own (for possible inclusion in your own letter) by clicking here: Print TABLE

(This is in .pdf format and requires Acrobat Reader - most internet systems have this reader but, if not, it is available as a free download from Adobe-get reader)

Policy / Paragraph No.

Chapter / Specific Site

Object / support

Reasons

Paragraph 5.28a

5

Object

This is an unwarranted relaxation of policy in PPG2. A park and ride facility is inappropriate development in the Green Belt because it does not accord with the purposes in paragraph 3.4 of PPG2. To suggest that it may be permitted where it would not "seriously compromise" the purposes of putting land in the Green Belt is a departure from the test for very special circumstances set out in paragraph 3.2 of PPG2. Park and ride facilities should be subject to the usual Green Belt tests, rather than being subject to a relaxed policy of their own.

Paragraph 8.6

8

Support

Open space which is or has the potential to be of value to the community ought to be protected.

Policy G1

8

Object

The first suggested deletion and addition changes the policy from a clear statement of the council's policy to a statement about presumptions, causing a loss of clarity and force.

Paragraph 8.13

8

Support

This accords with PPG2.

Paragraph 8.17a

8

Object

It is not accepted that PPG2 can be used to justify a Major Developed Site designation of Metropolitan Open Land. Objection is therefore made to the whole policy. In any event, the text itself is a misleading diminution of the text of Annex C of PPG2: compare 3rd sentence of text with para C3(a),(b) and (c) of Annex C.

Paragraph 8.18a

8

National Sports Centre

Object

The main objection is that the National Sports Centre should not be designated as a Major Developed Site, for reasons previously given. Further, even if the designation is adopted:

(i) Car parking cannot be considered part of the relevant area of the site for the purposes of PPG2 Annex C: see paragraph C5.
(ii) The test is not just " visual impact on the Park", but also impact on the purposes of including land in the Green Belt, together with the other criteria in Annex C.

The idea of a Planning Brief, which assists in better integration of the Centre in the green space of the Park is to be welcomed, subject to appropriate participation by the community and other stakeholders in the development of the brief. But regeneration of the Centre can and should be achieved within Green Belt control.

Paragraph 9.24

9

Object

The reference to paragraph 1.15 of PPG6 appears to be in error, and the addition of the words " or on the edge of" is an unwarranted dilution of the sequential approach.

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Last updated 20/10/02;24/10/02

Policy / Paragraph No.	Chapter / Specific Site	Object / support	Reasons
Paragraph 5.28a	5	Object	This is an unwarranted relaxation of policy in PPG2. A park and ride facility is inappropriate development in the Green Belt because it does not accord with the purposes in paragraph 3.4 of PPG2. To suggest that it may be permitted where it would not "seriously compromise" the purposes of putting land in the Green Belt is a departure from the test for very special circumstances set out in paragraph 3.2 of PPG2. Park and ride facilities should be subject to the usual Green Belt tests, rather than being subject to a relaxed policy of their own.
Paragraph 8.6	8	Support	Open space which is or has the potential to be of value to the community ought to be protected.
Policy G1	8	Object	The first suggested deletion and addition changes the policy from a clear statement of the council's policy to a statement about presumptions, causing a loss of clarity and force.
Paragraph 8.13	8	Support	This accords with PPG2.
Paragraph 8.17a	8	Object	It is not accepted that PPG2 can be used to justify a Major Developed Site designation of Metropolitan Open Land. Objection is therefore made to the whole policy. In any event, the text itself is a misleading diminution of the text of Annex C of PPG2: compare 3rd sentence of text with para C3(a),(b) and (c) of Annex C.
Paragraph 8.18a	8 National Sports Centre	Object	The main objection is that the National Sports Centre should not be designated as a Major Developed Site, for reasons previously given. Further, even if the designation is adopted: (i) Car parking cannot be considered part of the relevant area of the site for the purposes of PPG2 Annex C: see paragraph C5. (ii) The test is not just " visual impact on the Park", but also impact on the purposes of including land in the Green Belt, together with the other criteria in Annex C. The idea of a Planning Brief, which assists in better integration of the Centre in the green space of the Park is to be welcomed, subject to appropriate participation by the community and other stakeholders in the development of the brief. But regeneration of the Centre can and should be achieved within Green Belt control.
Paragraph 9.24	9	Object	The reference to paragraph 1.15 of PPG6 appears to be in error, and the addition of the words " or on the edge of" is an unwarranted dilution of the sequential approach.