Mr. Alan Novitzky
C/o Mr. C. Banks, Programme Officer
4th August, 2009
Dear Mr. Novitzky,
Crystal Palace Park Public Inquiry
I am writing this submission to the Planning Inquiry as an objector to the LDA’s
Masterplan for Crystal Palace Park, both as a Landscape Architect and as a Croydon
resident and frequent user of the Park. I have formulated my observations from perusal of
the Masterplan, my knowledge of the Park as a frequent visitor over 28 years and from
additional information acquired at the Inquiry.
The Masterplan would sweep away many of the outdoor sports facilities, excepting the
athletics track, its pitch and the cricket field. This appears to be driven by a desire to hide
sports activities underground. Indoor activities cannot adequately compensate for sport in
the open air, on the full-size pitches. League hockey and 11-a-side football could no
longer be held there. Tennis and netball would no longer have facilities. This would be
the case even if the Regional Sports Centre was built. In my view, the RSC should be
built and functioning prior to any of the proposed works to the NSC, associated buildings
and podium being implemented, as these house many other sports facilities.
In cross-examination, J. Gibbons admitted that the brief given to the landscape architects
who drew up the Masterplan required them to exclude outdoor sports facilities and the
podium (which houses the indoor running track and weight training rooms). Therefore
they were not required to consider any options to retain any of these facilities. This
failure of the LDA’s brief, limiting the scope of the landscape architects, appears to be
the root cause of the Masterplan’s deficiencies.
In response to this, I make the following observations:
• It is perfectly possible to produce a plan retaining these outdoor facilities while
greening much of the central area. It is a false premise to insist that this Masterplan
approach is the only option for the Park. Indeed, J. Gibbons admitted that the Paxton
axis still exists - the podium follows the line of the original main footpath in the Park
• The NSC is in the north basin, the running track and stadium in the south basin. I
believe the Masterplan was developed when the podium was not being used, as
originally envisaged, to provide access to the main entrance of the NSC. Now that
this has been re-instated as the main entrance to the NSC, the podium is well-used for
this purpose; for access to the lower part of the Park; for catching late afternoon
sunshine; for observing the running track and hockey pitch, and for elevated views
across. I have also observed it to be popular for skateboarders and children playing on
• The double avenue of Plane trees in the lower park leads up to the podium, which is a
visual obstruction. At this point the podium could be cut back with one central
staircase being provided together with ramps for disabled access.
• The podium was part of the original design of the NSC. The building was designed to
be accessed at that level. It was not designed to be half-buried.
• The new footpath proposed in the Masterplan has no merit over the podium. The
podium and the roof of the indoor training pool could be treated as a roof terrace. The
latter could be planted as a green roof, with gravel and sedums. This would introduce
a new ecological niche in the Park, rather than more amenity grassland of the type
which is to bury the sports pitches. Such grassland is not in short supply in the Park.
• Various pieces of redundant tarmacadam and concrete hard standings within the Park
can be removed, including those on the east side of the NSC. Much of this dates from
the time when Crystal Palace Park was used as a motor racing circuit.
• Parking areas on either side of the Paxton axis, and that below the terraces, may be
surplus to requirements.
• Where fencings are redundant, they should be removed. All fencing should be re-
assessed, replaced at the heights required and with quality design. German landscape
architects are expert in modern street furniture and fencings, and could have been
asked for their input on this aspect.
• Reinvigoration of the Park, the repair of the retaining elements and balustrades of the
terraces, are good.
• The building of new greenhouses is, I believe, also a commendable vision. However,
I have a few comments on the layout. Would perhaps the Paxton Society have
preferred these to be on the upper terrace, orientated to be viewed from below, with
some trees planted behind as a backdrop? To the rear, adjacent to the bus stops and
Crystal Palace Parade, perhaps an overspill car park could be incorporated under the
trees with stabilised grass or gravel (National Trust is very good at this – possibly
rubber crumb or mesh in the grass). This could double up as space currently used for
events, for community festivals and fun fairs. No parking should extend to the front
of the terrace, for obvious reasons, because of the detrimental impact on views from
• Wherever the glasshouses are built, the space between them, on the Italian Terraces,
should not be sub-divided by the proposed sunken gardens. The level gardens and
pools could be located immediately in front of each greenhouse, if located as
proposed, so that the large grass terrace could continue to be used and enjoyed as it is
now for flying kites, picnics, and informal sports activities, taking in that feeling of
space. Ramps could be designed into the edge of these. In my view, they should not
be located in the centre of the Italian Terraces, as proposed by the Masterplan.
• The tennis and netball courts, and other sports pitches, can be semi-screened by
I worked for a number of years as a Landscape Architect for LB Lambeth. In that
capacity, I became familiar with requirements for adventure playgrounds and the layout
and construction of a skateboard park in Brixton. I therefore have the following
observations to make on the Masterplan proposals for these facilities and their location in
• The proposed adventure playground cannot be a real option. An adventure
playground needs to be securely fenced to prevent unauthorised access, contain a play
building and should be fully staffed with play leaders. These are needed principally
because the facilities offered cannot be in an open park as these would not meet the
stringent British Standards and other requirements governing unsupervised children’s
• If an adventure playground is required, staffing must be fully funded. It would
perhaps be better sited near the new café and interpretation centre, rather than in the
green space proposed. Its proposed location in the Masterplan would be more of an
obstruction, physically and visually, than the nearby existing tennis courts.
• A proper skateboard park uses concrete on a steel mesh to form bowls and ramps. It
needs an appropriate range of features to suit a range of skills from beginners to
experts. The shape and size of the proposed “skate bowl” does not appear
satisfactory, nor is its location. To advocate a large concrete area in such a green
space, where it is not overlooked, would not appear to meet the needs of
skateboarders, nor contribute to the greening of the Park. The site chosen for the
skateboard park in Brixton is a corner site, well-observed from the pavements, of
sufficient size to accommodate a wide range of challenges and is thus attractive to
• The Masterplan envisages such a large scale, engineered approach that many trees are
to be lost. Raising the ground levels next to the NSC not only loses facilities, but the
use of expanded polystyrene blocks with a skin of topsoil, will give a green carpet,
not a space for future tree planting to be sustainable. Trees are unlikely to be
sustainable, because although they could be planted in pits, they would be unlikely to
grow due to the polystyrene limiting their root growth. Also, trees should not be
planted adjacent to a retaining wall, for structural reasons.
• Not having full information of the proposed new water elements in the Masterplan, I
cannot make detailed observations on them. However, I understand from the inquiry,
that the central “rill” would only be that at times of high rainfall, when it would act as
an overflow drain. If this is a central feature of the design, it is unsatisfactory as for
most of the time, it will be an empty channel in the main footway.
• However, the gravel bed channel, being a “natural” French drain type, threading from
the fishing lake to the tidal lake, could be a good feature in the location proposed.
• The reintroduction of “marshlands” between the concert platform and
intermediate/fishing lake would add to the ecology as an additional habitat. I
understand from a local resident that something similar was in the Park in the 1950s
• I understand that Capel College already has facilities in the Jubilee Stand of the
athletics stadium. The proposed new college building would not be required if this
stand remained. The latter functions both as an events spectator stand and providing
accommodation for this and other uses in the under-croft.
• Observations made at the Inquiry, on the proposed treetop walk, were that a similar
structure at Kew Gardens is successful. As a season ticket holder and frequent visitor
to Kew Gardens, I note that the treetop walk there does appear to be very popular
with new visitors and children. However, this has been at the expense of rendering a
secluded woodland area below into a much noisier and overlooked space. The
proposed treetop walk appears to intrude into the well-treed space of the English
Landscape section. Is it likely to have repercussions on the roosting and nesting of
birds? Also, as it would have level access at both ends (without lifts or stairs as at
Kew Gardens) how would bikes, or even motorbikes, be prevented from gaining
access? Remember also that Kew Gardens are shut at night and are very well-
supervised when open.
• The Masterplan, with the exception of the terraces, is very unlike Paxton’s original
plan for the Park, particularly in its hillocky middle section. Yet the spirit of Paxton is
invoked to justify removal of sports facilities, used by local clubs, schools and to host
the London Youth Games.
• Water tables at the foot of the steps from the lower Italian Terrace (I presume these
are raised pools) are a nice idea. However, surely not all the trees in this area need to
be removed to accommodate them.
• The storage and filtration ponds are not a particularly good shape. Their pointed ends
could usefully be smoothed out.
• The removal of the unsightly concrete stands, seating and poster boards is an
improvement. What will the central pavilion that replaces them be like? As this is
right in the middle of the axis, will it impede the view?
• The site survey photographs appear to have been taken in the greyest winter weather.
The ‘after’ computer-generated views show the scene in summer sunshine, with new
planting of trees at a mature stage, some 30 years old, as a minimum. This gives a
false impression of the effects of the major engineering works on the existing mature
• The significant views from the Palace Terraces are long distance, well beyond the
Park boundary. Views into the park show the top of the roof of the NSC and stands,
as if ships in a harbour, amid the mature tree canopy. This is not an unpleasant
intrusion, as maintained by the LDA. To have such middle foreground interest is not a
scar on the view, in my opinion.
• The engineering works proposed by the LDA will actually remove the last vestiges of
Paxton’s embankments around the north basin. These are to be filled in and smoothed
out to give a flat grassed area immediately next to the NSC, which the Masterplan
proposes as a casual sports area. However, unfenced ball games immediately next to
glazed buildings are not normally encouraged.
• Although I am not an architect, I consider that an unbiased architect’s assessment of
the NSC should be undertaken to confirm whether the proposed works to the building
will harm the fabric of the NSC now or in the future. The proposal, removing air
circulation and heating, sinking the NSC in a “hole”, may cause damp problems to the
building. As the Inquiry established, heating and ventilation systems are to be
removed. I understand that the RSC, if it ever materialises, will provide a new pool
underground. As such, it will never evoke the response (which I witnessed in May
2009) of a little girl looking through the glass doors of the NSC at the pool, sparkling
in the late afternoon sunshine, and saying “Oh! I would love to swim in there!”
• I believe the large areas of tarmac for the car parks could be considerably reduced.
Although drop-off points for school coaches and other sporting fixtures should be
included, parking for these could perhaps be provided on the periphery of the Park, or
• The LDA are trying to maintain, I believe, that the removal of the sports pitches is the
same thing as car parks and concrete hard-standings. However, if the former are
defined as open space already, they cannot legitimately be regarded as a trade-off for
new green space, in order to justify building housing on Metropolitan Open Land.
• The NSC should be left at the existing level with podium access, retaining the sports
facilities and pitches, with new fencing.
• Build RSC. Those facilities, only where adequately or better provided within the
RSC, can be removed from below the podium and the peripheral buildings, leaving
sports pitches intact, newly re-fenced and the remaining spaces left to be planted,
paved or grassed at the existing levels.
• Keep both stands at the athletics stadium, retaining the college in the Jubilee Stand,
which also accommodates office space, sports physiotherapy and a children’s gym.
Seating on grass banks is not a good alternative for sports events. Our summers are
known for their showers. Maintenance of steeply sloping grass banks is expensive
and a nightmare to carry out. The stadium is used for other events, such as concerts
and as well as sports.
• It was stated at the inquiry that Capel Manor is not providing adequate public access
to the farm. The original children’s zoo provided much public access in previous
years, including donkey rides.
• The transmitter buildings have not been included in the Masterplan and this area
• The Caravan Park adjoins a leafy lane entrance to the Park. The Rockhills Gate could
be reopened without the need either to displace the caravans or to build private
housing. I can see no landscape reason for the inclusion of this development.
• The reservoir is part of Paxton’s original scheme. Surely a sensitive treatment in
consultation with archaeological bodies could be developed to make this more of an
• As a Landscape Architect, I am not opposed, in principle, to the tree planting on the
Palace Terrace. However, the centres shown appear to be much too close. I believe it
might be proposed to thin them out later. Why are only London Planes proposed?
Other varieties should be explored. Fraxinus species, Betula species and Sorbus
species could be used. They could be closer planted and support a more diverse
ecology, though, of course, they are not as long-lived as London Planes. To create a
glade this close together, these species would be better fitted, with a clear stem to 8
foot. Some of the areas below the canopy of these trees should have blocks of mixed
planting to provide ecological niches for the species lost from the removal of the
• Who will maintain the water bodies, planting, greenhouses? At present, Bromley
Council seems unable or unwilling to maintain even a supply of loo rolls in the ladies
toilet in the lower park. A squalid, uncared for and unsanitary building, which all park
visitors, including children in the playground, are forced to use. A total refit of this
building and proper maintenance should be undertaken before a lot of other works in
• Proposed centre pond with access path across – good.
• The reshaping around the cricket ground is unnecessary, as this flat area is used by
many people for picnics and general recreation. There used to be a miniature railway
circuit around the perimeter of this space, which was a popular attraction in the
summer. I am not opposed to the use of the cricket ground, but only in the terms of,
for example, Richmond Green. But this would have to be carefully worked out with
• The centre axis path served visitors in Paxton’s time by providing a promenade for
viewing the basins, fountains and cascades. These features have not been there for
over a century. It now serves, via the podium, as the access to the NSC and sports
complex. If the NSC becomes just another 5-a-side football venue, it will not be
serving the numbers currently using it. Many Park visitors will continue to use the
peripheral pathways to visit the many attractions around the Park.
1. Improvements to the Park are needed. Unnecessary areas of tarmac and concrete not
in use can be removed.
2. All fencing should be surveyed and that not required or redundant should be removed.
New high quality fencing at proper heights should be erected.
3. Planting of additional trees, shrubs, herbaceous plants to screen and enhance the Park
in the central area, and other locations should be proposed
4. A full assessment of car parking should be done, removed where possible or re-laid
where still required. Dressed gravel could possibly be used, with additional tree
planting where needed.
5. Terraces – see detailed paragraph.
6. Greenhouses – see detailed paragraph.
7. The podium should be kept, but reduced in length (see detailed paragraph) chopped
back at eastern end just beyond lower road (in new or old line). Central steps and
8. Roof terrace treatment can be given to the podium and adjoining roofs.
I hope that you will be able to take into account the concerns I have raised in writing your
report on the Planning Inquiry.
Sally. J. Durrans, Dip L.A.